NC0001422_HORpts & Recommendations_20170925

Duke Energy Progress, Inc.
L.V. Sutton Energy Complex
Wilmington, New Hanover County
RECEIVEDINCDEUDWR
SEP 2 6 ZOV
Water Q Section
Permitting
Draft NPDES Wastewater Permit No. NC0001422
Hearing Officer's Report and Recommendations
September 25, 2017
David May
Division of Water Resources

5
ROY COOPER
Governor
lm;wMICHAEL S. REGAN
a Secretary
Water Resources S. JAY ZIMMIERMAN
Environmental Quality Director
MEMORANDUM
TO- Jay Zimmerman, Director, Division of Watte�rr Resources
FROM- David May, Regional Supervisor 0L1- "
RECEIVEDINCDEQIDWR
Water Quality Regional Operations Section
Washington Regional Office SEP 2 6 2017
Water (duality
SUBJECT Hearing Officer's Report and Recommendations Permitting Section
Duke Energy Progress, Inc. — Draft NPDES Wastewater Permit No NC0001422
L V Sutton Energy Complex
DATE- September 25, 2017
On June 22, 2017, 1 served as the Hearing Officer for the public hearing held at the Department
of Environmental Quality office in Wilmington, North Carolina. The public hearing was held to
allow for comment on the draft NPDES wastewater permit for Duke Energy Progress' L V.
Sutton Energy Complex.
Oral comments were provided at the public hearing Independent of the public hearing, written
comments were also provided throughout the public comment periods, concluding on June 22,
2017 and September 18, 2017. In preparation of the subject report, all input has been
considered in making final recommendations
The report has been prepared using the following outline -
I Site History
II Facility Background
III Site Visit
IV Public Record (June 22, 2017 Public Hearing and Comments Summary)
V Recommendations
VI. Attachments
Nothing Comparesn,
State of North Carolina I Environmental Quality I Water Resources -Water Quality Regional Operations Section -Washington Regional Office
943 Washington Square Mall, Washington, North Carolina 27889
252-946-6481

HEARING OFFICER REPORT
for
Renewal/Major Modification of NPDES Permit/ NC0001422
Duke Energy L.V. Sutton Energy Complex
This report is presented to the Director of the North Carolina Division of the Water Resources
INTRODUCTION
On May 18, 2017 a notice of Public Hearing was published in the Wilmington Star -News,
requesting public comment on Draft NPDES Permit renewal/modification for L.V. Sutton
Energy Complex located in the Cape Fear River Basin The permit modification included the
following changes. 1) update to effluent limits to reflect results from the Reasonable Potential
Analysis and Mercury Evaluation, and updates to NC standards; 2) reduced sampling frequency
for acute tocixity; 3) addition of new outfalls to accommodate stormwater discharges from a
future coal ash landfill. The public notice also provided information on a public hearing to be
held to solicit additional comment.
A public hearing was held on June 22, 2017, at the Department of Environmental Quality
regional office in Wilmington, NC. Oral and written comments became part of the public record,
which was closed at the end of the hearing. David May with the Division of Water Resources'
Washington Regional Office served as the Hearing Officer.
On August 16, 2017, the draft permit was re -noticed in the Wilmington Star -News to incorporate
a Compliance Boundary map into the permit. An opportunity for public comment on the updated
Draft Permit was provided through the re -notice process.
This Hearing Officer Report summarizes the mayor issues raised through the public hearing
process, as well as the Hearing Officer recommendations for the NPDES permit renewal/major
modification. The Director of the Division of Water Resources (DWR) will take final action on
these recommendations.
FACILITY BACKGROUND
Duke Energy's L V. Sutton Energy Complex is a natural gas-fired 620 MW combined cycle
generation facility The power block consists of two combustion turbine generators (each with a
HRSG — heat recovery steam generator) and one steam turbine generator. Historically, the
facility operated 3 coal-fired units. The coal-fired units were shut -down in the fourth quarter of
2013. On February 11, 2015 the Wilmington Regional Office delineated the Effluent Channel at
the Sutton Energy Complex in accordance with the requirements of 15A NCAC 02B .0228. The
new Outfall 008 was established to accommodate discharge from this outfall. This facility
discharges to Sutton Lake (classified C -waters on November 5, 2014) and Cape Fear River
(classified C -swamp waters) in the Cape Fear River Basin. The Cape Fear River is listed on the
303(d) list of the impaired waters to the contravention of the dissolved oxygen standard.

The facility discharges wastewater via four external permitted wastewater outfalls: Outfall 001
(cooling water and 1984 ash pond discharges); Outfall 002 (1971 ash basin); Outfall 004 (1984
ash basin); Outfall 008 (cooling water from the combined cycle unit); four internal wastewater
outfalls: Internal Outfall 005 (wastewater from the combined cycle unit to the Effluent Channel);
Internal Outfall 006 (wastewater from the combined cycle unit to the Effluent Channel); Internal
Outfall 007 (stormwater/wastewater from the closure activities for coal-fired units to the Effluent
Channel); Internal Outfall 009 (wastewater from the new simple cycle combustion turbine
expected to be online in 2017 to the Effluent Channel); and seven internal stormwater outfalls:
Internal Outfall SW001 (runoff from the temporary laydown area and the parking lot to the
Effluent Channel) ; Internal Outfall SWO02 (runoff from the parking lot and Peaker Combustion
Turbine area to the Effluent Channel) ; Internal Outfall SWO03 (runoff from the parking lot to
the Effluent Channel) ; Internal Outfall S W004 (Pumped stormwater from the 115 Electrical
Switchyard area to the Effluent Channel) ; Internal Outfall SWO05 (discharge from the south
wet detention basin to the Effluent Channel) ; Internal Outfall S WO06 (Discharge from the rip
rap armored emergency spillway for the north infiltration basin that treats stormwater from a
parking lot and surrounding areas to the Effluent Channel) ; Internal Outfall S WO07 (Runoff
from the potential rail loading yard, rail spur, and truck roads installed to transport coal ash from
the site to the Effluent Channel).
SITE VISIT
A prior site visit was conducted August 6, 2015 at the L.V. Sutton Energy Complex. Duke
Energy staff and Division of Water Resources staff, including the hearing officer, attended the
site visit. Ash basin structures and outfalls were recognized during the facility overview. The
August 6, 2015 site visit provided a representative overview of the facility.
PUBLIC RECORD
The Division held a public hearing in Wilmington, NC on June 22, 2017. Approximately 7
people attended the public hearing and 2 attendees provided oral comments. Attendance sheets
are attached. Attendees and speakers included representatives from environmental interest
groups, Duke Energy, and concerned citizens. The Division received 45 written comments via e-
mail, with 2 copies also transmitted through postal mail.
Listed below is a summary of issues raised, and Division staff response to those comments
1) Limits. Effluent limits for arsenic, mercury, and other parameters in draft permit are
viewed as being weaker and less stringent than the current permit.
Response: Permit limit changes are based on results from the Reasonable Potential
Analysis, results from the Mercury Evaluation, and updates to the North Carolina Surface
Water Standards (15A NCAC 2B .0200).
The RPA procedure utilized by the Division is in accordance with EPA's regulation at 40
CFR 122.44(d)(1). Permit limits are added only if the results of the RPA suggest
potential for exceeding the water quality standards, and are not arbitrarily assigned.
2

However, absence of permit limits does not allow the facility to violate instream water
quality standards.
2) Limits. Draft limits are not adequately protective of Sutton Lake and the Cape Fear
River.
Response: See response for 1) above.
3) Limits. Clean Water Act prohibits weaker effluent limits from being adopted in newly
modified versions of permits. Parameters of concern include arsenic, mercury, lead,
cadmium, and iron.
Response: See response for 1) above. In addition, the US EPA provided prior review
and evaluation of the draft permit and did not note concern of the modified effluent
limits. As such, conclusion is drawn that the US EPA's silence on the matter infers that
no conflict is viewed with the CWA.
Also, when revised limits are based on updated surface water standards and RPAs, which
are still designed to be protective of water quality, such revisions are not viewed as back-
sliding when they are supported by established protocol and processes
Although 33 U.S.C. § 1342(0) provides position on Anti -Backsliding ("less stringent"
effluent limitations), 33 U.S.C. § 1342(0)(2) Exceptions provides provisions for permits
to be renewed, reissued, or modified. 33 U.S.C. § 1342(0)(3) Limitations specifies that a
permit can not be modified or re -issued with less stringent effluent limits if
implementation of such limit would result in violation of a water quality standard.
Effluent limits in the draft permit are based on established protocol and are designed to
be protective of water quality standards.
33 U.S.C. § 1313(d)(4) Limitations On Revision of Certain Effluent Limitations provides
further effluent modification provisions.
4) Limits. Fish in Sutton Lake serve as a food source for the public. Permit limits should
be protective of Sutton Lake and fish based food source
Response: See response for 1) above. Also, the permit requires annual fish tissue
monitoring at Sutton Lake and the Cape Fear River.
5) Compliance Boundary. The permit does not include a map depicting the Compliance Boundary.
Prior Compliance Boundary maps have depicted the Compliance Boundary extending into Sutton
Lake and the old streambed of Catfish Creek
Response: The Compliance Boundary (for which groundwater quality standards may not be
exceeded) is established as specified in 15A NCAC 2L 0107 Compliance Boundary. The draft
permit has been updated to reference the Compliance Boundary and include a Compliance
Boundary map.
3

6) Outfall 001 Sample Collection. Samples collected from Outfall 001 undergo some level of
mixing and dilution prior to discharge into the Cape Fear River and are not representative of
discharged water
Response: Samples collected at Outfall 001 are considered representative of discharges to the
Cape Fear River. River water is not mixing with effluent prior to discharge and diluting samples
Other outfalls that discharge to Sutton Lake have limits established to be protective of water
quality and are based on established processes.
7) In addition to comments provided by the public, Duke Energy provided the following
input:
a) Provide compliance schedule for Outfall 001 — Dewatering Phase lead limit (Section
A.(2 )
Response: A permit modification application can be submitted requesting
incorporation of a compliance schedule for lead subsequent to issuance of an updated
permit.
b) The Division should provide a position that a permit modification request based on
water quality modeling will be processed as a minor modification.
Response: Classification of a permit modification request based on modeling results
as either a minor or mayor modification is not viewed as a position that should be
referenced in a permit. Such determination can be addressed outside of the subject
permitting process.
c) Ammend chloride footnote in Section A.(2.) Outfall 001 -dewatering phase to
indicate that the chloride limit doesn't apply if elevated chloride levels are due to
natural conditions in the estuary.
Response: Footnote 7 state "The discharge from this facility shall not cause
Chlorides level in the receiving stream to exceed 230 mg/L. If the Chlorides level
exceeds 230 mg/L due to natural background conditions, the discharge cannot cause
Chlorides to increase in the receiving stream. Language that states the 230 mg/L does
not apply when chlorides are naturally above 230 mg/L could imply chlorides levels
could be discharged at unlimited levels. Such elevated chloride levels could have
potential to increase chloride concentrations in the stream above the naturally
occurring background levels.
The existing language provides flexibility to discharge elevated levels of chlorides
when naturally occurring concentrations are elevated in the receiving stream, as long
as chloride levels are not increased over back ground concentrations.
d) Remove Section A.(5.) Outfall 004 -dewatering phase from permit as it's viewed as having
or serving the same purpose as Section A.(2.) Outfall 001 -dewatering phase If A.(5.)
remains, A (5 ) should have the same footnotes as provided in A.(2.).
Response: Wastewater from Outfall 004 can be directed to Outfall 001 for discharge
into the Cape Fear River versus Sutton Lake. Although limits are consistent between
0

A.(2.) and A.(5 ), Outfall 004 serves a specific source (19 84 New Ash Pond) and
retention of A.(5.) is viewed as appropriate.
Additionally, discharge from Outfall 004 through Outfall 001 may occur at times
when flow is also discharging from Sutton Lake through Outfall 001. In the event
water also discharges from Sutton Lake, in addition from flow from Outfall 004,
effluent quality may be different between the two locations. As such, retention of
A.(5.) is viewed as appropriate.
A permit modification application can be submitted requesting incorporation of a
compliance schedule for copper, nickel, and lead subsequent to issuance of an
updated permit.
Since monitoring data recorded through the eDMR system will be entered under
separate outfalls, eDMR complications are not anticipated through any potential
duplication of laboratory data. If so, eDMR issues can be addressed through
technical assistance.
e) Remove As, Se, Hg, and N from monitoring requirements in Section A.(8.)
Outfall 007 (since viewed as redundant to monitoring requirements for Outfall 008).
Response: Internal Outfall 007 covers stormwater flows from the closure activities
for coal-fired units, separate from stormwater outfalls SW001 through SW007).
Outfall 007 covers a specific discharge with sampling parameters assigned as
appropriate based on discharge characteristics.
f) Remove weekly measurement frequency for instream temperature monitoring
requirements in Section A.(10.) Outfall 008 since daily monitoring is also required for
temperature.
Response: An automated temperature monitoring system that continuously monitors
temperature provides flexibility with temperature monitoring requirements. As such,
a daily/weekly measurement frequency shouldn't increase sampling efforts
g) Change Sample Type for instream Temperature from grab to instantaneous in
Section A.(10.) Outfall 008 since temperature is monitored through an automated
temperature recording station.
Response: Although temperature may be recorded through an automated
temperature monitoring system, the sample type may still be referenced as "grab."
As such, additional sampling flexibility is provided in the event issues arise with the
automated system.

h) Apply a compliance schedule to all new water quality based limits (arsenic,
selenium, copper) in Section A.(10.) Outfall 008.
Response: There's no indication that the limits for the subject parameters are not
achievable. A compliance schedule may be evaluated at a later date upon receipt of
information to support such a need.
HEARING OFFICER RECOMMENDATIONS
Based on review of the public record and written/oral comments received during the public hearing
process, I recommend to the Division Director that the Duke Energy Draft NPDES Permit (L.V.
Sutton Energy Complex) be issued. Once issued, the permit may be further modified through a
subsequent application process to reflect any requested changes by Duke Energy.
David May, Heari icer
APPENDICES
Date
A. Draft Permit, Fact Sheet and Announcement of Public Hearing
B. Prior Permit and Groundwater Monitoring Plans
C Summary of Comments (Written and Oral)
D. Hearing Registration Sheets
E. Presentation from the Public Hearing

Appendix A
RECEIVEDINCDEQIDWR
SEP 2 6 2017
Draft Permit, Fact Sheet, and Water (;lu Section Permitting Section
Announcement of Public Hearing

May 2017 Public Notice

Permit NC0001422
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
Draft PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Water Quality
Commission, and the Federal Water Pollution Control Act, as amended,
Duke Energy Progress, LLC
is hereby authorized to discharge wastewater from a facility located at the
L. V. Sutton Energy Complex
801 Sutton Steam Plant Road, Wilmington
New Hanover County
to receiving waters designated as the Cape Fear River and Sutton Lake in the Cape Fear
River Basin in accordance with the discharge limitations, monitoring requirements, and
other applicable conditions set forth in Parts I, II, and III.
This permit modification shall become effective
This permit and the authorization to discharge shall expire at midnight on
Signed this day
S. Jay Zimmerman P.G., Director
Division of Water Resources
By the Authority of the Environmental Management Commission
Page 1 of 23

Permit NC0001422
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under
the permit conditions, requirements, terms, and provisions included herein.
Duke Energy Progress, LLC is hereby authorized to:
1. Continue to discharge cooling water, low volume wastes, stormwater, and
treated wastewater from internal wastewater outfalls 005, 006, 007, and 009
to the Effluent Channel, and internal stormwater outfalls SW001, SW002,
SW003, SW004, SW005, SW006, and SWO07 to the Effluent Channel (the
Effluent Channel discharges via external Outfall 008 to the Sutton .Lake); ash
pond discharge, groundwater, treated wastewater, landfill leachate, and
stormwater runoff (Outfall 001, Outfall 002 and Outfall 004); Outfall 001 may
also include cooling water from Outfall 008; at a facility located at Sutton
Steam Electric Plant, 801 Sutton Steam Plant Road, Wilmington, New Hanover
County, and
2. Discharge wastewater (via Outfall 002, Outfall 004, and Outfall 008) at the
locations specified on the attached map into the Sutton Lake which is
classified C -Swamp waters in the Cape Fear River Basin.
3. Discharge non -contact stormwater (via Outfall 010 - North Pond Emergency
Spillway and Outfall 011 - South Pond Emergency Spillway) from landfill (after
landfill is capped) at the locations specified on the attached map into the
Sutton Lake which is classified C -Swamp waters in the Cape Fear River Basin.
Discharge is only allowed for storm events that exceeds 25 -year 24-hour storm
events.
4. Discharge treated wastewater, ash pond discharge, stormwater, landfill
leachate, and groundwater (via Outfall 001) at the location specified on the
attached map into the Cape Fear River, classified C -Swamp waters in the Cape
Fear River Basin.
Page 2 of 23

Permit NC0001422
Part I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 001 -
normal operation/ decanting) [15A NCAC 0213 .0400 et seq., 0213 .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to the Cape Fear River from Outfall 001 - removing the free
water above the settled ash layer that does not involve mechanical disturbance of the ash
(recirculation cooling water, non -contact cooling water, and treated wastewater from outfalls
002, and 004). Such discharges shall be limited and monitored6 by the Permittee as specified
below:
CHARACTERISTICS
Monthly
Avera a
Daily
I Maximum
Measurement
Fre ency
Sample
&Type
Sample
Location'
Flow, MGD
Daily
Estimate or
pump logs
Effluent
Tem erature',2, OC
Quarterly
Grab
U, D
Tem erature2, OC
Daily
Grab
Effluent
H7
6.0 <_
H!5 9.0
Weekly
Grab
Effluent
Oil and Grease
15.0 m L
20.0 m L
Weekly
Grab
Effluent
Total Suspended Solids,
mg/L8
30.0 mg/ L
100.0 mg/ L
Weekly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , m L
Weekly
Grab
Effluent
Total Phosphor -us, m L
Weekly
Grab
Effluent
Dissolved Oxygen, m L
Weekly
Grab
Effluent
Acute Toxicity3
Monthly
Grab
Effluent
Total Mercury4
Weekly
Grab
Effluent
Total Arsenic
10.0 µ L
340.0 µ L
Weekly
Grab
Effluent
Total Selenium
5.0 µg/L
56.0 µg/L
Weekly
Grab
Effluent
Total Iron, m L
Weekly
Grab
Effluent
Total Lead, pg L
Weekly
Grab
Effluent
Total Cadmium
Weekly
Grab
Effluent
Total Aluminum, m L
Weekly
Grab
Effluent
Total Co erg
7.88 L
10.47 L
Weekly
Grab
Effluent
Total Nicke19
25.0 L
335.2 L
Weekly
Grab
Effluent
Total Zinc, L
Weekly
Grab
Effluent
Turbidity -5
Weekly
Grab
Effluent
Notes:
1. U: Upstream, 2700 feet above outfall (intake structure on the Cape Fear River). D: Downstream,
1.25 miles below outfall. Instream monitoring is provisionally waived in light of the
permittee's participation in the Lower Cape Fear River Basin Association. Instream
monitoring shall be conducted as stated in this permit should the permittee end its
participation in the Association.
2. The receiving water's temperature shall not be increased by more than 2.8°C above ambient
water temperature and in no case exceed 32°C, except in the mixing zone described as follows:
Extending from the eastern shore to the centerline of the river and extending not more than
1.25 miles downstream nor more than 2700 feet from the point of discharge. The cross-
sectional area of the mixing zone shall not exceed 9% of the total cross sectional area of the river
at the point of discharge nor 2.5% at the mouth of Toomer's Creek.
3. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%); Part I, Condition A. (13.).
4. The facility shall use EPA method 1631E.
5. The discharge from this facility shall not cause turbidity in the receiving stream to exceed 50
NTU. If the instream turbidity exceeds 50 NTU due to natural background conditions, the
discharge cannot cause turbidity to increase in the receiving stream.
6. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (25.).
Page 3 of 23

Permit NC0001422
7. The facility shall continuously monitor pH when the decanting process commences (and the
pump is operating) and the decanting pump shall be shutoff automatically when 15 minutes
running average pH falls below 6.1 standard units or rises above 8.9 standard units. Pumping
will be allowed to continue if interruption might result in a dam failure or damage.
8. The facility shall continuously monitor TSS concentration when the decanting process
commences (and the pump is operating) and the decanting pump shall be shutoff automatically
when the one half of the Daily Maximum limit (15 minutes average) is exceeded. Pumping will
be allowed to continue if interruption might result in a dam failure or damage.
9. The limits will become effective 12 months from the permit effective date. This time is allowed to
evaluate dilution models for a potential mixing zone and determine potential treatment
technologies.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The level of water in the ash pond should not be lowered more than 1 ft/week, unless
approved by the DEQ Dam Safety Program. The facility shall use a floating pump suction pipe
with free water skimmed from the basin surface using an adjustable weir.
The facility is allowed to drawdown the wastewater in the ash pond to no less than three feet
above the ash.
When the facility commences the ash pond/ponds decommissioning process, the facility
shall treat the wastewater discharged from the ash pond/ponds by the physical -chemical
treatment facilities.
Page 4 of 23

Permit NC0001422
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
001 -dewatering phase) [15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the commencement date of the dewatering operation and lasting
until expiration, the Permittee is authorized to discharge to the Cape Fear River from Outfall 001
Dewatering -removing the interstitial water/ash pore water (recirculation cooling water, non -
contact cooling water, and treated wastewater from outfalls 002, and 004). Such discharges
shall be limited and monitored6 by the Permittee asspecified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Avera a
Daily
Maximum
Measurement Sample Sample
Frequency Type Location'
Flow
2.1 MGU
(applies only to ash
and dischaz e
Daily
Estimate or
pump logs
Effluent
Flow
Daily
Estimate or
pump logs
Effluent
Temperature 1,2, OC
Quarterly
Grab
U, D
Tem erature2, OC
Daily
Grab
Effluent
H9
6.0<
pHs 9.0
Daily
Daily
Effluent
Oil and Grease
15.0 m L
20.0 m L
Weekly
Grab
Effluent
Total Suspended Solids
mg/L10
30.0 mg/L
100.0 mg/L
Weekly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , m L
Weekly
Grab
Effluent
Total Phosphorus, m L
Weekly
Grab
Effluent
Dissolved Oxygen, m L
Weekly
Grab
Effluent
Total Chlorides?
230.0 m L
230.0 m L
Weekly
Grab
Effluent
Acute Toxicity3
Monthly
Grab
Effluent
Total Iron, m L
Weekly
Grab
Effluent
Total Cadmium, pg L
Weekly
Grab
Effluent
Chromium (VI), pg ZL
Weekly
Grab
Effluent
Total Aluminum
8.0 m L
8.0 m L
Weekly
Grab
Effluent
Total Nickel$
25.0 L
335.2 L
Weekly
Grab
Effluent
Total Lead
2.94 µ L
75.4 µ L
Weekly
Grab
Effluent
Total Arsenic
10.0 µ L
340.0 µ L
Weekly
Grab
Effluent
Total Selenium
5.0 µ L
56.0 µ L
Weekly
Grab
Effluent
Total Mercury4
47.0
n L
Weekly
Grab
Effluent
Total Copper, pg/L8
7.88 µ L
10.47 µ L
Weekly
Grab
Effluent
Total Zinc, µ L
Weekly
Grab
Effluent
Turbidit 5
Weekly
Grab
Effluent
Notes:
1. U: Upstream, 2700 feet above outfall (intake structure on the Cape Fear River). D: Downstream,
1.25 miles below outfall. Instream monitoring is provisionally waived in light of the
permittee's participation in the Lower Cape Fear River Basin Association. Instream
monitoring shall be conducted as stated in this permit should the permittee end its
participation in the Association.
2. The receiving water's temperature shall not be increased by more than 2.8°C above ambient
water temperature and in no case exceed 32°C, except in the mixing zone described as follows:
Extending from the eastern shore to the centerline of the river and extending not more than
1.25 miles downstream nor more than 2700 feet from the point of discharge. The cross-
sectional area of the mixing zone shall not exceed 9% of the total cross sectional area of the river
at the point of discharge nor 2.5% at the mouth of Toomer's Creek.
3. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%); Part I, Condition A. (13.).
4. The facility shall use EPA method 1631E, this is an annual average limit.
Page 5 of 23

Permit NC0001422
5. The discharge from this facility shall not cause turbidity in the receiving stream to exceed 50
NTU. If the instream turbidity exceeds 50 NTU due to natural background conditions, the
discharge cannot cause turbidity to increase in the receiving stream.
6. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (25.).
7. The discharge from this facility shall not cause Chlorides level in the receiving stream to exceed
230 mg/ L. If the Chlorides level exceeds 230 mg/ L due to natural background conditions, the
discharge cannot cause Chlorides to increase in the receiving stream.
8. The limits will become effective 12 months from the permit effective date. This time is allowed to
evaluate dilution models for a potential mixing zone and determine potential treatment
technologies.
9. The facility shall continuously monitor pH when the decanting process commences (and the
pump is operating) and the decanting pump shall be shutoff automatically when 15 minutes
running average pH falls below 6.1 standard units or rises above 8.9 standard units. Pumping
will be allowed to continue if interruption might result in a dam failure or damage.
10. The facility shall continuously monitor TSS concentration when the decanting process
commences (and the pump is operating) and the decanting pump shall be shutoff automatically
when the one half of the Daily Maximum limit (15 minutes average) is exceeded. Pumping will
be allowed to continue if interruption might result in a dam failure or damage.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The level of water in the ash pond should not be lowered more than 1 ft/week, unless
approved by the DEQ Dam Safety Program.
When the facility commences the ash pond/ponds decommissioning process, the facility
shall treat the wastewater discharged from the ash pond/ponds by the physical -chemical
treatment facilities.
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
002 -normal operation)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to Sutton Lake and/or to the 1984 ash pond from Outfall 002 -
removing of free water above the settled ash layer that does not involve mechanical disturbance of
the ash (Old Ash Pond - coal pile runoff, low volume wastes, ash sluice water, and stormwater
runoff). Such discharges to Sutton Lake shall be limited and monitored3 by the Permittee as specified
below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQ
Monthly
Average
Daily
Maximum
Measurement
Free uency
Sample
Type
Sample Location
Flow, MGD
Weekly
Pump Logs
or similar
Effluent
Temperature, OC
Weekly
Grab
Effluent
Oil and Grease
15.0 mg/L
20.0 mg/L
Weekly
Grab
Effluent
Total Suspended
Solids
30.0 mg/ L
100.0 mg/ L
Weekly
Grab
Effluent
H
6.0<_
H <_ 9.0
Weekly
Grab
Effluent
Total Copper
7.88 µ L
10.47 µ L
Weekly
Grab
Effluent
Total Zinc, µ L
Weekly
Grab
Effluent
Total Arsenic
10.0 µg/ L
340.0 µg/ L
Weekly
Grab
Effluent
rotaelenium
5.0 µg/L
56.0 µg/L
Weekly
Grab
Effluent
ercu 1
Weekly
Grab
Effluent
Page 6 of 23

Permit NC0001422
Total Iron, m L
LIMITS
MONITORING REQUIREMENTS
Weekly
Grab
Effluent
Total Nickel
25.0 µ L
335.2 µ L
Weekly
Grab
Effluent
Total Aluminum,
m L
Effluent
Tem erature, OC
Weekly
Grab
Effluent
Acute Toxicity 2
Oil and Grease
15.0 m L
Monthly
Grab
Effluent
Notes:
1. The facility shall use EPA method 1631E.
2. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%); Part I, Condition A. (13.).
3. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (25.).
4. The receiving water's temperature shall not be increased by more than 2.8°C above ambient
water temperature and in no case exceed 32°C.
The level of water in the ash pond should not be lowered more than 1 ft/week, unless
approved by the DEQ Dam Safety Program. The facility shall use a floating pump suction pipe
with free water skimmed from the basin surface using an adjustable weir.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (4.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
004 -normal operation/ decanting)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to Sutton Lake and/or to Outfall 001 from Outfall 004 -
removing of free water above the settled ash layer that does not involve mechanical disturbance of
the ash (1984 New Ash Pond - ash sluice water, coal pile runoff, groundwater, landfill leachate,
low volume wastes, and stormwater runoff). Such discharges to Sutton Lake shall be limited and
monitored3 by the Permittee as specifjed below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
a
Sample
Location
Flow, MGD
Weekly
Pump Logs
or similar
Effluent
Tem erature, OC
Weekly
Grab
Effluent
Oil and Grease
15.0 m L
20.0 m L
Weekly
Grab
Effluent
Total Suspended
Solids4
30.0 mg/ L
100.0 mg/ L
Weekly
Grab
Effluent
H5
6.0s pHs 9.0
Weekly
Grab
Effluent
Total Copper
7.88 µ L 10.47 µ L
Weekly
Grab
Effluent
Total Zinc, µ L
Weekly
Grab
Effluent
Total Arsenic
10.0 µ L 340.0 µ L
Weekly
Grab
Effluent
Total Selenium
5.0 µ L 56.0 µ L
Weekly
Grab
Effluent
Total Mercury'
Weekly
Grab
Effluent
Total Iron, m L
Weekly
Grab
Effluent
Total Nickel
25.0 µ L 335.2 µ L
Weekly
Grab
Effluent
Total Aluminum,
m L
Weekly
Grab
Effluent
Acute Toxicity 2
Monthly
Grab
Effluent
Notes!
1. The facility shall use EPA method 1631E.
2. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%); Part I, Condition A. (13).
3. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (25.).
Page 7 of 23

Permit NC0001422
4. The facility shall continuously monitor TSS concentration when the dewatering process
commences (and the pump is operating) and the dewatering pump shall be shutoff
automatically when the one half of the Daily Maximum limit (15 minutes average) is exceeded.
Pumping will be allowed to continue if interruption might result in a dam failure or damage.
5. The facility shall continuously monitor pH when the dewatering process commences (and the
pump is operating) and the dewatering pump shall be shutoff automatically when 15 minutes
running average pH falls below 6.1 standard units or rises above 8.9 standard units. Pumping
will be allowed to continue if interruption might result in a dam failure or damage.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The level of water in the ash pond should not be lowered more than 1 ft/week, unless
approved by the DEQ Dam Safety Program. The facility shall use a floating pump suction pipe
with free water skimmed from the basin surface using an adjustable weir.
The facility is allowed to drawdown the wastewater in the ash pond to no less than three feet
above the ash.
When the facility commences the ash pond/ponds decommissioning process, the facility
shall treat the wastewater discharged from the ash pond/ponds by the physical -chemical
treatment facilities.
A. (5.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
004 -dewatering phase)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the commencement date of the dewatering operation and lasting
until expiration, the Permittee is authorized to discharge to Outfall 001 from Outfall 004
Dewaterinq-removing the interstitial water/ash pore water (1984 New Ash Pond - ash sluice
water, coal pile runoff, groundwater, landfill leachate, low volume wastes, and stormwater
runoff). Such discharges shall be limited and monitored5 at Outfall 001 by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
ONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
a
Sample
Location
Flow
2.1 MGD
(applies only to ash
pond discharge)
Daily
Estimate
or pump
logs
Effluent
Temperature, °C
Weekly
Grab
Effluent
H7
6.0!g pH <- 9.0
Daily
Daily
Effluent
Oil and Grease
15.0 m L 20.0 m L
Weekly
Grab
Effluent
Total Suspended Solids
mg/L6
30.0 mg/ L 100.0 mg/ L
Weekly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , m L
Weekly
Grab
Effluent
Total Phosphorus, m L
Weekly
Grab
Effluent
Dissolved Oxygen, m L
Weekly
Grab
Effluent
Total Chlorides
230.0 m L 230.0 m L
Acute Toxicity2
Monthly
Grab
Effluent
Total Iron, m L
Weekly
Grab
Effluent
Total Cadmium, pg L
Weekly
Grab
Effluent
Chromium , µ L
Weekly
Grab
Effluent
Total Aluminum
8.0 m L 8.0 m L
Weekly
Grab
Effluent
Total Nickel
25.0 L 335.2 L
Weekly
Grab
Effluent
Total Lead
2.94 µ L 75.4 µ L
Weekly
Grab
Effluent
Total Arsenic
10.0 µ L 340.0 µ L
Weekly
Grab
Effluent
Page 8 of 23

Permit NC0001422
Total Selenium
5.0 µ L 1 56.0 µ L
Weekly
Grab
Effluent
Total Mercury3
47.0 n L
Weekly
Grab
Effluent
Total Copper, µ L
7.88 µ L 10.47 µ L
Weekly
Grab
Effluent
Total Zinc, µ L
Location
Weekly
Grab
Effluent
Turbidit 4
Pump Logs or
Weekly
Grab
Effluent
Notes:
1. The receiving water's temperature shall not be increased by more than 2.8°C above ambient
water temperature and in no case exceed 32°C.
2. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%); Part I, Condition A. (13.).
3. The facility shall use EPA method 1631E, this is an annual average limit.
4. The discharge from this facility shall not cause turbidity in the receiving stream to exceed 50
NTU. If the instream turbidity exceeds 50 NTU due to natural background conditions, the
discharge cannot cause turbidity to increase in the receiving stream.
5. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (25.).
6. The facility shall continuously monitor TSS concentration when the dewatering process
commences (and the pump is operating) and the dewatering pump shall be shutoff
automatically when the one half of the Daily Maximum limit (15 minutes average) is exceeded.
Pumping will be allowed to continue if interruption might result in a dam failure or damage.
7. The facility shall continuously monitor pH when the dewatering process commences (and the
pump is operating) and the dewatering pump shall be shutoff automatically when 15 minutes
running average pH falls below 6.1 standard units or rises above 8.9 standard units. Pumping
will be allowed to continue if interruption might result in a dam failure or damage.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The level of water in the ash pond should not be lowered more than 1 ft/week, unless
approved by the DEQ Dam Safety Program. The facility shall use a floating pump suction pipe
with free water skimmed from the basin surface using an adjustable weir.
When the facility commences the ash pond/ponds decommissioning process, the facility
shall treat the wastewater discharged from the ash pond/ponds by the physical -chemical
treatment facilities.
A. (6.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
005)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
Beginning with the commencement of this discharge and lasting until expiration, the Permittee is
authorized to discharge from Internal Outfall 005 (Combined Cycle Plant - ultrafilter water
treatment system filter backwash, closed cooling water cooler blowdown, Reverse
Osmosis/Electrodeionization system reject wastewater, and other low volume wastewater) to
the Effluent Channel. Such discharges shall be limited and monitored' by the Permittee as
specified below:
Page 9 of 23
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
EFFLUENT
Monthly
Daily
Measurement
Sample
Sample
CHARACTERISTICS
Average
Maximum
Frequency
Type
Location
Flow, MGD
Daily
Pump Logs or
Influent or
Effluent
similar
Oil and Grease
15.0 mg/ L
20.0 mg/ L
2/Month
Grab
Effluent
Total Suspended Solids
30.0 mg/L
100.0 mg/L
2/Month
Grab
Effluent
pH
6.0 < pH < 9.0
2 / Month
Grab
Effluent
Page 9 of 23

Permit NC0001422
Notes:
1. • The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. Please See Special Condition A. (25.).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (7.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
006)
[15A NCAC 02B .0400 et seq., 02B.0500 et seq.]
Beginning with the commencement of this discharge and lasting until expiration, the Permittee is
authorized to discharge from Internal Outfall 006 (Combined Cycle Plant - low volume
wastewater including the Heat Recovery Steam generator blowdown and auxiliary boiler
blowdown) to the Effluent Channel. Such discharges shall be limited and monitored, by the
Permittee as specified below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location
Flow, MGD
Sample
Sample
Daily
Pump Logs or
similar
Influent or
Effluent
Oil and Grease
15.0 mg/ L
20.0 mg/ L
2/Month
Grab
Effluent
Total Suspended Solids
30.0 mg/ L
100.0 mg/ L
2 / Month
Grab
Effluent
pH
6.0 < pH < 9.0
2 / Month
Grab
Effluent
Notes:
1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. Please See Special Condition A. (25.).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (8.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
007)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from Internal Outfall 007 (stormwater flows from the closure
activities for coal-fired units, separate from stormwater outfalls SWO01 through SWO07) to the
Effluent Channel. Such discharges shall be limited and monitoredz by the Permittee as specified
below:
FftFLUENT
LIMITS
MONITORIWG REQUIREMENTS
CHARACTERISTICS
Monthly
Daily
Measurement
Sample
Sample
Avera—
Maximum
Frequency
Type
Location
Flow, MGI)
Weekly
Pump Logs
Effluent
or similar
Oil and Grease
15.0 m L
20.0 m L
Monthly
Grab
Effluent
Total Suspended
30.0 mg/ L
100.0 mg/ L
Monthly
Grab
Effluent
Solids
Total Arsenic, µ L
Quarterly
Grab
Effluent
Total Selenium, µ L
Quarterly
Grab
Effluent
Nitrate/nitrite as N,
Quarterly
Grab
Effluent
m L
Total Mercury', ng/L
Quarterly
Grab
Effluent
Notes:
Page 10 of 23

Permit NC0001422
1. The facility shall use EPA method 1631E.
2. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (25.).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (9.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
009)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from Internal Outfall 009 (low volume wastes from a new
simple cycle combustion turbine) to the Effluent Channel. Such discharges shall be limited and
monitored' h%- the Permittee as specified below:
EFFLUENT
LIMITS
MONITORING RLIiIREMEN't"S
CHARACTERISTICS
Daily
I Maximum
Measurement
Frequency
Monthly Daily
Measurement
Sample
Sample
I )ails
Average Maximum
Frequency
a
Location
Flow, MGD
Grab
Weekly
Pump Logs
Effluent
--Daily
Daily/Weekly Daily/Weekly
Grab
or similar
Oil and Grease
Oil and Grease
15.0 m L 20.0 m L
Monthly
Grab
Effluent
Total Suspended
30.0 mg/L 100.0 mg/L
Monthly
Grab
Effluent
Solids
Total Nitrogen
NO2 + NO3 + TKN , m L
Monthly
pH
6.0 < pH < 9.0
2 / Month
Grab
Effluent
Notes:
1. • The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. Please See Special Condition A. (25.).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (10.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
(Outfall 008)5
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to Sutton Lake from Outfall 008 (from internal wastewater
outfalls 005, 006, 007, and 009, and internal stormwater outfalls SWO01 through SWO07).
Such discharges shall be limited and monitored') by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
I Maximum
Measurement
Frequency
Sample
a
Sample
Location'
Flow, MGD
I )ails
Estimate
or pump
logs
Effluent
Temperature OC
Grab
Effluent
Temperature 1,2, OC
--Daily
Daily/Weekly Daily/Weekly
Grab
Instream
Oil and Grease
15.0 m L
20.0 m L
Monthly
Grab
Effluent
Total Suspended Solids
30.0 m L
100.0 m L
Monthly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , m L
Monthly
Grab
Effluent
Dissolved Oxygen, m L
Monthly
Grab
Effluent
H
6.0s 14<_ 9.0
Daily
Grab
Effluent
Total Phosphorus, m L
Monthly
Grab
Effluent
Acute ToXicjty3
Quarterly
Grab
Effluent
Total Mercu , n L
Quarterly
Grab
Effluent
Page 11 of 23

Permit NC0001422
Total Arsenic
10.0 µ L 340.0 µ L Quarterly
Grab
Effluent
Total Selenium
5.0 µ L 56.0 µ L Quarterly
Grab
Effluent
Total Copper7
7.88 µ L 10.47 µ L Quarterly
Grab
Effluent
Total Zinc, µ L
Quarterly
Grab
Effluent
Notes•.
1.Instream: 1000 feet from outfall.
2. The receiving water's temperature shall not be increased by more than 2.8°C above ambient
water temperature and in no case exceed 32°C. The limit is not being implemented until
further notice (Please see A. (20.)).
3. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%); Part I, Condition A. (23.).
4. The facility shall use EPA method 1631E.
5. The facility shall install a screen or a barrier at the end of the Effluent Channel to minimize
fish migration into the Channel. The screen/barrier shall be installed by July 1, 2017.
6. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. Please See Special Condition A. (25.).
7. The limit becomes effective 36 months from the effective date of the permit (Please see A.
(30.)).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (11.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
010)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge non -contact stormwater from Outfall 010 - the North Pond
Emergency Spillway of the capped landfill. Such discharges shall be limited and monitored' by the
Permittee asspecified below:
EFFLUENT
CHARACTERISTICS
LIMITS
Monthly Daily
Average I Maximum
MONITORING `REQUIREMENTS
Measurement Sample Sample
Frequency a Location
Flow, MGD
Per discharge event
Estimate
Effluent
H
6.0:5; pH
< 9.0
Per discharge event
Grab
Effluent
Oil and Grease
15.0 m L
20.0 m L
Per discharge event
Grab
Effluent
TSS
30.0 m L
100.0 m L
Per discharge event
Grab
Effluent
1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. Please See Special Condition A. (25.).
Discharge is only allowed for storm events that exceeds 25 -year 24-hour storm events.
A. (12.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
011)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge non -contact stormwater from Outfall 011 - the South Pond
Emergency Spillway of the capped landfill. Such discharges shall be limited and monitored' by the
Permittee as specified below:
CHARACTERISTICS
Monthly Daily Measurement Sample Sample
Average I Maximum I Fre Luency I Type Locatio
Flow. MGD I Per discharae event I Estimate Effluent
Page 12 of 23

Permit NC0001422
H
6.0:5
pH < 9.0
Per discharge event
Grab
Effluent
Oil and Grease
15.0 m L
20.0 m L
Per discharge event
Grab
Effluent
TSS
30.0 m L
100.0 m L
Per discharge event
Grab
Effluent
1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. Please See Special Condition A. (25.).
Discharge is only allowed for storm events that exceeds 25 -year 24-hour storm events.
A. (13.) ACUTE TOXICITY LIMIT (MONTHLY)- OUTFALLS 001, 002, and 004.
[15A NCAC 02B .0200 et seq.]
The permittee shall conduct acute toxicity tests on a monthlU basis using protocols defined in the
North Carolina Procedure Document entitled "Pass/ Fail Methodology For Determining Acute
Toxicity In A Single Effluent Concentration" (Revised -July, 1992 or subsequent versions). The
monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24 hour static test. The
effluent concentration at which there may be at no time significant acute mortality is 90% (defined
as treatment two in the procedure document). Effluent samples for self-monitoring purposes must
be obtained during representative effluent discharge below all waste treatment.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR -1) for the month in which it was performed, using the parameter
code TGE6C. Additionally, DWR Form AT -2 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1623 Mail Service Center
Raleigh, North Carolina 27699-1623
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than
30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/ physical
measurements performed in association with the toxicity tests, as well as all dose/response data.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT)
test form indicating the facility name, permit number, pipe number, county, and the month/year of
the report with the notation of "No Flow" in the comment area of the form. The report shall be
submitted to the Water Sciences Section at the address cited above.
Should any test data from either these monitoring requirements or tests performed by the North
Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit
may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
A. (14.) STRUCTURAL INTEGRITY INSPECTIONS OF ASH POND DAMS
The facility shall meet the dam design and dam safety requirements per 15A NCAC 2K.
A. (15.) BEST MANAGEMENT PRACTICES PLAN
Page 13 of 23

Permit NC0001422
The Permittee shall continue to implement a Best Management Practices (BMP) Plan to control the
discharge of oils and the hazardous and toxic substances listed in 40 CFR, Part 117 and Tables II
and III of Appendix D to 40 CFR, Part 122, and shall maintain the Plan at the plant site and shall
be available for inspection by EPA and DWR personnel.
A. (16.) INTAKE SCREEN BACKWASH
Continued intake screen backwash discharge is permitted without limitations or monitoring
requirements.
A. (17.) NO DISCHARGE OF PCBs
As specified by 40 CFR 423.13 (a), there shall be no discharge of polychlorinated biphenyl
compounds such as those commonly used for transformer fluid.
A. (18.) BIOCIDE CONDITION
The permittee shall not use any biocides except those approved in conjunction with the permit
application. The permittee shall notify the Director in writing not later than ninety (90) days prior to
instituting use of any additional biocide used in cooling systems which may be toxic to aquatic life
other than those previously reported to the Division of Water Resources. Such notification shall
include completion of Biocide Worksheet Form 101 and a map locating the discharge point and
receiving stream. Completion of Biocide Worksheet Form 101 is not necessary for those outfalls
containing toxicity testing. Division approval is not necessary for the introduction of new biocides
into outfalls currently tested for whole effluent toxicity.
A. (19.) FISH TISSUE MONITORING NEAR ASH POND DISCHARGE - OUTFALL
001, and OUTFALLS 002/004
The facility shall conduct fish tissue monitoring at two locations (Sutton Lake and Cape Fear River)
annually and submit the results with the NPDES permit renewal application. The objective of this
monitoring is to evaluate potential uptake of pollutants by fish tissue near the ash pond discharge.
The parameters analyzed in fish tissue shall be arsenic, selenium, and mercury. The monitoring shall
be conducted in accordance with the sampling plan approved by the Division. The plan should be
submitted to the Division within 180 days from the effective date of the permit. Upon approval, the
plan becomes an enforceable part of the permit.
Copies of all the study plans, study results, and any other applicable materials should be submitted
to:
1) Electronic Version Only (pdf and CD)
Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
2) Electronic Version (pdf and CD) and Hard Copy
Division of Water Resources
Water Sciences Section
1623 Mail Service Center
Raleigh, NC 27699-1623
A. (20.) CLEAN WATER ACT SECTION 316 (a) THERMAL VARIANCE
In order to obtain thermal variance/mixing zone for Lake Sutton/ Cape Fear the facility shall
develop and conduct comprehensive 316(a) studies. The 316(a) studies shall be performed in
accordance with the Division of Water Resources approved plan. The temperature analysis and the
balanced and indigenous study plan shall conform to the specifications outlined in 40 CFR 125
Subpart H and the EPA's Draft 316(a) Guidance Manual, dated 1977, and the Region 4 letter to
NCDENR, dated June 3, 2010.
The study shall be performed in accordance with the following schedule:
Page 14 of 23

Permit NC0001422
1) Effective date of the permit +60 days - submit the Draft Study Plan to the DEQ and EPA, the
DEQ will perform the Plan review and provide the comments to Duke within 30 days of the
Plan receipt.
2) Effective date of the permit +120 days - meet with the DEQ to provide responses to the
DEQ/EPA comments and discuss the Study Plan.
3) Effective date of the permit +150 days - submit the Final Study Plan to the DEQ and to the
EPA.
4) After obtaining an approval of the Study Plan, conduct 2 years of the monitoring.
5) 270 days after completing the monitoring, submit the study results and an application for
316(a) variance to DEQ.
Copies of all the study plans, study results, and any other applicable materials should be submitted
to:
1) Electronic Version Only (pdf and CD)
Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
2) Electronic Version (pdf and CD) and Hard Copy
Division of Water Resources
Water Sciences Section
1621 Mail Service Center
Raleigh, NC 27699-1621
A. (21.) CLEAN WATER ACT SECTION 316(b)
The permittee shall comply with the Cooling Water Intake Structure Rule per 40 CFR 125.95. The
permittee shall submit all the materials required by the Rule with the next renewal application.
Copies of all the study plans, study results, and any other applicable materials should be submitted
to:
1) Electronic Version Only (pdf and CD)
Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
2) Electronic Version (pdf and CD) and Hard Copy
Division of Water Resources
Water Sciences Section
1623 Mail Service Center
Raleigh, NC 27699-1623
A. (22.) LOWER CAPE FEAR MODELING
The permittee may elect to conduct a water quality model of the dilution factor for Outfall 001.
Contingent upon EPA approval of the Lower Cape Fear Modeling and its results, the Reasonable
Potential Analysis will be conducted again and the permit limits will be based on the new flow
numbers established by the model.
A. (23.) ACUTE TOXICITY LIMIT (QUARTERLY) - OUTFALL 008
[15A NCAC 02B .0200 et seq.]
The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined in the
North Carolina Procedure Document entitled "Pass/ Fail Methodology for Determining Acute Toxicity
In A Single Effluent Concentration" (Revised December 2010 or subsequent versions). The
monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24-hour static test. The
effluent concentration at which there may be at no time significant acute mortality is 90% (defined
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Permit NC0001422
as treatment two in the procedure document). The tests will be performed during the months of
February, May, August, and November. These months signify the first month of each three-month
toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained
during representative effluent discharge and shall be performed at the NPDES permitted final
effluent discharge below all treatment processes.
Should any single quarterly monitoring indicate a failure to meet specified limits, then
monthly monitoring will begin immediately until such time that a single test is passed. Upon
passing, this monthly test requirement will revert to quarterly in the months specified above.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR -1) for the month in which it was performed, using the parameter
code TGE6C. Additionally, DWR Form AT -2 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1623 Mail Service Center
Raleigh, North Carolina 27699-1623
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than
30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/ physical
measurements performed in association with the toxicity tests, as well as all dose/response data.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT)
test form indicating the facility name, permit number, pipe number, county, and the month/year of
the report with the notation of "No Flow" in the comment area of the form. The report shall be
submitted to the Water Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then
monthly monitoring will begin immediately until such time that a single test is passed. Upon
passing, this monthly test requirement will revert to quarterly in the months specified above.
Assessment of toxicity compliance is based on the toxicity testing quarter, which is the three-month
time interval that begins on the first day of the month in which toxicity testing is required by this
permit and continues until the final day of the third month.
Should any test data from either these monitoring requirements or tests performed by the North
Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit
may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
A. (24.) INSTREAM MONITORING
The facility shall conduct semi-annual instream monitoring (intake structure on the Cape Fear
River (approximately 3 miles upstream) and 2.6 miles downstream of the Outfall 001, and
approximately 1000 ft. from Outfall 004 (Bay 8) for total arsenic, total selenium, total mercury
(method 1631E), total chromium, chlorides, dissolved lead, dissolved cadmium, dissolved copper,
dissolved zinc and total hardness (as CaCO3). For the purpose of this requirement, semi-annual
means that samples are collected twice per year with at least 120 calendar days between sampling
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Permit NC0001422
events. The monitoring results shall be reported on the facility's Discharge Monitoring Reports and
included with the NPDES permit renewal application. Instream monitoring is provisionally
waived considering the permittee's participation in the Lower Cape Fear River Basin
Association provided the Association agrees to sample for all the parameters listed in this
condition and at the specified locations. Instream monitoring shall be conducted as stated in
this permit should the permittee end its participation in the Association.
A. (25.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports
and specify that, if a state does not establish a system to receive such submittals, then permittees must submit
monitoring data and reports electronically to the Environmental Protection Agency (EPA). The final NPDES
Electronic Reporting Rule was adopted and became effective on December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this permit
(Standard Conditions forNPDES Permits):
• Section B. (11.)
• Section D. (2.)
• Section D. (6.)
• Section E. (5.)
Signatory Requirements
Reporting
Records Retention
Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)]
Effective December 21, 2016, the permittee shall report discharge monitoring data electronically using the NC
DWR's Electronic Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted
electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit
DMRs electronically using the internet. Until such time that the state's eDMR application is compliant with
EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be required to submit all
discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR
submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR
to the following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being
physically located in an area where less than 10 percent of the households have broadband access, then a
temporary waiver from the NPDES electronic reporting requirements may be granted and discharge
monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or alternative forms approved by
the Director. Duplicate signed copies shall be submitted to the mailing address above. See "How to Request a
Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following compliance monitoring
data and reports, when applicable:
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Permit NC0001422
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver from
Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41 (1) (9), the permittee must identify the initial recipient at the time of each
electronic submission. The permittee should use the EPA's website resources to identify the initial recipient
for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA or
the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving
electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type of
electronic submission and for each state. Instructions on how to access and use the appropriate electronic
reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting Rule is found at:
htti2://ww-,v2 el2a.gov/compliance/final-national-pollutant-discharge-elimination-system-npdes-electronic-
re orting=rule.
Electronic submissions must start by the dates listed in the "Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic
reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division.
Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written
approval at least sixty (60) days prior to the date the facility would be required under this permit to begin
submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and shall
thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the Division
unless the permittee re -applies for and is granted a new temporary electronic reporting waiver by the Division.
Approved electronic reporting waivers are not transferrable. Only permittees with an approved reporting
waiver request may submit monitoring data and reports on paper to the Division for the period that the
approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on the
following web page:
httl2://deq.nc.gov/about/divisions/water-resources/edrnr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.)
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section
B. (11.)(a) or by a duly authorized representative of that person as described in Part II, Section B. (11.)(b). A
person, and not a position, must be delegated signatory authority for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and
login credentials to access the eDMR system. For more information on North Carolina's eDMR system,
registering for eDMR and obtaining an eDMR user account, please visit the following web page:
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Permit NC0001422
1-ittl)://deq.nc.gov/about/`divisions/water-resources/`edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the
following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL, BE
ACCEPTED:
"I certi, underpenalty 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 properlygather and evaluate the information submitted Based
on my inquiry of the person or persons who manage the system, or those persons directyresponsibleforgathering 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. "
5. Records Retention [Supplements Section D.-"
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from the
date of the report. This period may be extended by request of the Director at any time [40 CFR
122.41].
A. (26.) APPLICABLE STATE LAW (STATE ENFORCEABLE ONLY) [G. S. 143-215.1(b)]
This facility shall meet the requirements of Senate Bill 729 (Coal Ash Management Act). This permit
may be reopened to include new requirements imposed by Senate Bill 729.
A. (27.) STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop and implement a Stormwater Pollution Prevention Plan (SPPP). The
SPPP shall be maintained on site unless exempted from this requirement by the Division. The SPPP
is public information. The SPPP should also specifically and separately address deconstruction,
demolition, coal, and/or coal ash hauling or disposal activities. The SPPP shall include, at a
minimum, the following items:
1. Site Overview. The Site Overview shall provide a description of the physical facility and the
potential pollutant sources that may be expected to contribute to contamination of stormwater
discharges. The Site Overview shall contain the following:
(a) A general location map (USGS quadrangle map or appropriately drafted equivalent map),
showing the facility's location in relation to transportation routes and surface waters; the
name of the receiving waters to which the stormwater outfalls discharge, or if the discharge
is to a municipal separate storm sewer system, the name of the municipality and the
ultimate receiving waters; and accurate latitude and longitude of the points of stormwater
discharge associated with industrial activity. The general location map (or alternatively the
site map) shall identify whether any receiving waters are impaired (on the state's 303(d) list
of impaired waters) or if the site is located in a watershed for which a TMDL has been
established, and what the parameters of concern are.
(b) A narrative description of storage practices, loading and unloading activities, outdoor
process areas, dust or particulate generating or control processes, and waste disposal
practices. A narrative description of the potential pollutants that could be expected to be
present in the stormwater discharge from each outfall. The narrative should also reference
deconstruction, demolition, coal, and/or coal ash hauling or disposal activities where
applicable.
(c) A site map drawn at a scale sufficient to clearly depict: the site property boundary; the
stormwater discharge outfalls; all on-site and adjacent surface waters and wetlands;
industrial activity areas (including storage of materials, disposal areas, process areas,
loading and unloading areas, and haul roads); site topography and finished grade; all
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Permit NC0001422
drainage features and structures; drainage area boundaries and total contributing area for
each outfall; direction of flow in each drainage area; industrial activities occurring in each
drainage area; buildings; stormwater Best Management Practices (BMPs); and impervious
surfaces. The site map must indicate the percentage of each drainage area that is
impervious, and the site map must include a graphic scale indication and north arrow.
(d) A list of significant spills or leaks of pollutants during the previous three (3) years and any
corrective actions taken to mitigate spill impacts.
(e) Certification that the stormwater outfalls have been evaluated for the presence of non-
stormwater discharges. The permittee shall submit the first certification no later than
90 days after the effective date of this permit to the Stormwater Permitting Program
Central Office and shall re -certify annually that the stormwater outfalls have been
evaluated for the presence of non-stormwater discharges. For any non-stormwater
discharge identified, the permittee shall indicate how that discharge is permitted or
otherwise authorized. The certification statement will be signed in accordance with the
requirements found in Part II, Standard Conditions, Section B, Paragraph 11.
2. Stormwater Management Strategy. The Stormwater Management Strategy shall contain a
narrative description of the materials management practices employed which control or
minimize the stormwater exposure of significant materials, including structural and
nonstructural measures. This strategy should also address deconstruction, demolition, coal,
and/or coal ash hauling or disposal activities where applicable. The Stormwater Management
Strategy, at a minimum, shall incorporate the following:
(a) Feasibility Study. A review of the technical and economic feasibility of changing the
methods of operations and/or storage practices to eliminate or reduce exposure of materials
and processes to rainfall and run-on flows. Wherever practical, the permittee shall prevent
exposure of all storage areas, material handling operations, and manufacturing or fueling
operations. In areas where elimination of exposure is not practical, this review shall
document the feasibility of diverting the stormwater run-on away from areas of potential
contamination.
(b) Secondary Containment Requirements and Records. Secondary containment is required
for: bulk storage of liquid materials; storage in any amount of Section 313 of Title III of the
Superfund Amendments and Reauthorization Act (SARA) water priority chemicals; and
storage in any amount of hazardous substances, in order to prevent leaks and spills from
contaminating stormwater runoff. A table or summary of all such tanks and stored
materials and their associated secondary containment areas shall be maintained. If the
secondary containment devices are connected to stormwater conveyance systems, the
connection shall be controlled by manually activated valves or other similar devices (which
shall be secured closed with a locking mechanism). Any stormwater that accumulates in
the containment area shall be observed for color, foam, outfall staining, visible sheens and
dry weather flow, prior to release of the accumulated stormwater. Accumulated stormwater
shall be released if found to be uncontaminated by any material. Records documenting the
individual making the observation, the description of the accumulated stormwater, and the
date and time of the release shall be kept for a period of five (5) years. For facilities subject
to a federal oil Spill Prevention, Control, and Countermeasure Plan (SPCC), any portion of
the SPCC Plan fully compliant with the requirements of this permit may be used to
demonstrate compliance with this permit.
In addition to secondary containment for tankage, the permittee shall provide drip pans or
other similar protection measures for truck or rail car liquid loading and unloading stations.
(c) BMP Summary. A listing of site structural and non-structural Best Management Practices
(BMPs) shall be provided. The installation and implementation of BMPs shall be based on
the assessment of the potential for sources to contribute significant quantities of pollutants
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Permit NC0001422
to stormwater discharges and on data collected through monitoring of stormwater
discharges. The BMP Summary shall include a written record of the specific rationale for
installation and implementation of the selected site BMPs. The BMP Summary should also
address deconstruction, demolition, coal, and/or coal ash hauling or disposal activities
where applicable. The permittee shall refer to the BMPs described in EPA's Multi -Sector
Permit (MSGP) and Industrial Stormwater Fact Sheet for Steam Electric Power Generating
Facilities (EPA -833-F-06-030) for guidance on BMPs that may be appropriate for this site.
The BMP Summary shall be reviewed and updated annually.
3. Spill Prevention and Response Procedures. The Spill Prevention and Response Procedures
(SPRP) shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. Facility personnel responsible for implementing the SPRP shall be
identified in a written list incorporated into the SPRP and signed and dated by each individual
acknowledging their responsibilities for the plan. A responsible person shall be on-site at all
times during facility operations that have increased potential to contaminate stormwater runoff
through spills or exposure of materials associated with the facility operations. The SPRP must
be site stormwater specific. Therefore, an oil Spill Prevention Control and Countermeasure plan
(SPCC) may be a component of the SPRP, but may not be sufficient to completely address the
stormwater aspects of the SPRP. The common elements of the SPCC with the SPRP may be
incorporated by reference into the SPRP.
4. Preventative Maintenance and Good Housekeeping Program. A preventative maintenance
and good housekeeping program shall be developed and implemented. The program shall
address all stormwater control systems (if applicable), stormwater discharge outfalls, all on-site
and adjacent surface waters and wetlands, industrial activity areas (including material storage
areas, material handling areas, disposal areas, process areas, loading and unloading areas, and
haul roads), all drainage features and structures, and existing structural BMPs.
The program shall establish schedules of inspections, maintenance, and housekeeping activities
of stormwater control systems, as well as facility equipment, facility areas, and facility systems
that present a potential for stormwater exposure or stormwater pollution where not already
addressed under another element of the SPPP. Inspection of material handling areas and
regular cleaning schedules of these areas shall be incorporated into the program. Compliance
with the established schedules for inspections, maintenance, and housekeeping shall be
recorded and maintained in the SPPP. The program should also address deconstruction,
demolition, coal, and/or coal ash hauling or disposal activities where applicable. The Good
Housekeeping Program shall also include, but not be limited to, BMPs to accomplish the
following:
(a) Minimize contamination of stormwater runoff from oil-bearing equipment in
switchyard areas;
(b) Minimize contamination of stormwater runoff from delivery vehicles and rail cars
arriving and departing the plant site;
(c) Inspect all residue -hauling vehicles for proper covering over the load, adequate gate -
sealing, and overall integrity of the container body. Repair vehicles as necessary;
and
(d) Reduce or control the tracking of ash and residue from ash loading and storage
areas;
5. Facility Inspections. Inspections of the facility (including tanks, pipes, and equipment) and all
stormwater systems shall occur as part of the Preventative Maintenance and Good
Housekeeping Program at a minimum on a semi-annual schedule, once during the first half of
the year (January to June), and once during the second half (July to December), with at least 60
days separating inspection dates (unless performed more frequently than semi-annually).
6. Employee Training. Training programs shall be developed and training provided at a
minimum on an annual basis for facility personnel with responsibilities for: spill response and
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Permit NC0001422
cleanup, preventative maintenance activities, and for any of the facility's operations that have
the potential to contaminate stormwater runoff. The facility personnel responsible for
implementing the training shall be identified, and their annual training shall be documented by
the signature of each employee trained.
7. Responsible Party. The SPPP shall identify a specific position or positions responsible for the
overall coordination, development, implementation, and revision of the SPPP. Responsibilities
for all components of the SPPP shall be documented and position assignments provided.
8. SPPP Amendment and Annual Update. The permittee shall amend the SPPP whenever there is
a change in design, construction, operation, site drainage, maintenance, or configuration of the
physical features which may have a significant effect on the potential for the discharge of
pollutants to surface waters. All aspects of the SPPP shall be reviewed and updated on an
annual basis. The annual update shall include:
(a) an updated list of significant spills or leaks of pollutants for the previous three (3)
years, or the notation that no spills have occurred (element of the Site Overview);
(b) a written re -certification that the stormwater outfalls have been evaluated for the
presence of non-stormwater discharges (element of the Site Overview);
(c) a documented re-evaluation of the effectiveness of the on-site stormwater BMPs (BMP
Summary element of the Stormwater Management Strategy).
(d) a review and comparison of stormwater sample analytical data to any applicable
limits or benchmark values (if applicable) over the past year.
If the Director notifies the permittee that the SPPP does not meet one or more of the minimum
requirements of the permit, the permittee shall have 30 days to respond. Within 30 days of
such notice, the permittee shall submit a time schedule to the Director for modifying the SPPP
to meet minimum requirements. The permittee shall provide certification in writing to the
Director that the changes have been made.
9. SPPP Implementation. The permittee shall implement the Stormwater Pollution Prevention
Plan and all appropriate BMPs consistent with the provisions of this permit, in order to control
contaminants entering surface waters via stormwater. Implementation of the SPPP shall
include documentation of all monitoring, measurements, inspections, maintenance activities,
and training provided to employees, including the log of the sampling data and of actions taken
to implement BMPs associated with the industrial activities, including vehicle maintenance
activities. Such documentation shall be kept on-site for a period of five (5) years and made
available to the Director or the Director's authorized representative immediately upon request.
A. (28.) ADDITIONAL CONDITIONS AND DEFINITIONS
1. EPA methods 200.7 or 200.8 (or the most current versions) shall be used for analyses of all
metals except for total mercury.
2. All effluent samples for all external outfalls shall be taken at the most accessible location
after the final treatment but prior to discharge to waters of the U.S. (40 CFR 122.416)).
3. The term low volume waste sources means wastewater from all sources except thouse for
which specific limitations are otherwise established in this part (40 CFR 423.11 (b)).
4. The term chemical metal cleaning waste means any wastewater resulting from cleaning any
metal process equipment with chemical compounds, including, but not limited to, boiler
tube cleaning (40 CFR 423.11 (c)).
5. The term metal cleaning waste means any wastewater resulting from cleaning [with or
without chemical cleaning compounds] any metal process equipment including, but not
limited to, boiler tube cleaning, boiler fireside cleaning, and air preheater cleaning (40 CFR
423.11 (d)).
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6. For all outfalls where the flow measurement is to be "estimated" the estimate can be done by
using calibrated V -notch weir, stop -watch and graduated cylinder, or other method
approved by the Division.
7. During normal operations removing of the free water above the settled wet ash layer shall
not involve mechanical disturbance of the ash.
A. (29.) COPPER COMPLIANCE SCHEDULE (Outfall 008)
1. 9 months from the permit effective date, submit to DEQ a copper evaluation study plan
describing steps to be undertaken to identify the source of copper at outfall 008 discharge in
order to comply with the copper limits set forth in section A. (10.) of the permit. The study
should consider potential wastewater sources, practices such as vegetation management, and
background sources.
2. 18 months from the permit effective date, submit a progress report describing the findings of
the study. If a source of copper has been identified, the interim report shall include proposed
measures that will be evaluated to treat or eliminate the source of copper. If a source of copper
has not been identified, the interim report shall provide additional steps planned or necessary to
comply with the copper limits set forth in section A. (10.) of the permit.
3. 27 months from the permit effective date. Submit a progress report. If a source of copper
was identified in the 18 month report, this report should discuss the success of the efforts to
treat or eliminate sources of copper. If a source of copper has not been identified, the interim
report shall provide additional steps planned or necessary to comply with the copper limits set
forth in section A.(10.) of the permit.
4. 36 months from the permit effective date the discharge shall be in compliance with the
copper limitation.
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DEQ/DWR
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
RENEWAL
NPDES No. NC0001422
Facility Information
Applicant/ FaciliName: Duke Energy Progress, LLC/ L.V. Sutton Energy Complex
Applicant Address: 801 Sutton Steam Plant Road, Wilmington, NC 28401
Facility Address: same
Permitted Flow N/A
Type of Waste: 100 % Industrial
Facility/Permit Status: Renewal Class
County- New Hanover
Miscellaneous
Receiving Stream:
Cape Fear River
(001), Sutton Lake
002, 004, 008
Regional Office:
WiRO
Stream Classification:
C SW (001)
C (002, 004, 008)
SI: 18-(63)
Quad
J27SW
Castle Hayne
303(d) Listed?:
Yes
Impaired for D.O.
(Cape Fear River
Permit Writer:
Sergei Chernikov, Ph.D.
Subbasin:
030617 (CPF)
Date:
March 1, 2017
Drainage Area mit :
Summer 7Q10 (cfs)
Tidally influenced
(Outfall 001);
Lake (Outfalls
002, 004, and 008
30Q2 cfs :
See above
Average Flow cfs :
See above
IWC % :
100 all outfalls
Primary SIC Code:
SUMMARY
This is a renewal of the NPDES wastewater permit for L.V. Sutton Energy Complex. Duke Energy
Progress Sutton Plant is a natural gas-fired 620 MW combined cycle generation facility. The power
block consists of two combustion turbine generators (each with a HRSG — heat recovery steam
generator) and one steam turbine generator. Historically, the facility operated 3 coal-fired units. The
coal-fired units were shut -down in the fourth quarter of 2013
The facility is regulated by federal effluent guidelines (40 CFR Part 423 — Steam Electric Power
Generating Point Source Category) — BPT/BAT.
On February 11, 2015 the Wilmington Regional Office delineated the Effluent Channel at the Sutton
Energy Complex in accordance with the requirements of 15A NCAC 02B .0228. The new Outfall 008
was established to accommodate discharge from this effluent channel.
Wastewater outfalls:
Outfall 001 — cooling pond discharge, recirculated cooling water, non -contact cooling water,
groundwater, landfill leachate, and treated wastewater from Outfall 004 (new ash pond). The new ash
pond can discharge directly to Sutton Lake through Outfall 004 or to Cape Fear River through Outfall
001. The Outfall 001 is discharging through the mixing box that was set-up to concurrently discharge
ash pond wastewater and water from Sutton Lake. The compliance point for Outfall 001 is located
within the mixing box.
Duke Energy Progress, Inc. - Sutton NC0001422
NPDES Renewal
Page 1

Outfall 002 - wastewater associated with the old ash pond. May consist of low volume waste, yard
drains, oily waste treatment. Wastewater can be discharged to Sutton Lake or to Cape Fear River
through Outfall 001.
Outfall 004 - wastewater associated with the new ash pond. May consist of low volume waste, yard
drains, oily waste treatment. Wastewater can be discharged to Sutton Lake or to Cape Fear River
through Outfall 001.
Outfall 008- Primarily consists of recirculating cooling water from the Combined Cycle generation
unit, contains flows from internal outfalls 005, 006, 007, 009, and stormwater outfalls.
Internal Outfall 005 - wastewater from the Combined Cycle generation unit.
Internal Outfall 006 - wastewater from the Combined Cycle generation unit.
Internal Outfall 007 - stormwater/wastewater flows from the closure activities for coal-fired units.
Internal Outfall 009 - low volume wastes from a new simple cycle combustion turbine expected to
be online in 2017.
Outfall 010 - non -contact stormwater from North Pond Emergency Spillway, the pond will receive
stormwater from the coal ash landfill after landfill is capped.
Outfall 0 11 - non -contact stormwater from South Pond Emergency Spillway, the pond will receive
stormwater from the coal ash landfill after landfill is capped.
Stormwater outfalls discharging to the effluent channel and then to Sutton Lake via Outfall 008:
Internal Outfall SWO01 - Runoff from the temporary laydown area and the parking lot.
Internal Outfall SWO02 - Runoff from the parking lot and Peaker Combustion Turbine area.
Internal Outfall SWO03 - Runoff from the parking lot.
Internal Outfall SWO04 - Pumped stormwater from the 115 Electrical Switchyard area.
Internal Outfall SWO05 - Discharge from the south wet detention basin.
Internal Outfall SWO06 - Discharge from the rip rap armored emergency spillway for the north
infiltration basin that treats stormwater from a parking lot and surrounding areas.
Internal Outfall SWO07 - Runoff from the potential rail loading yard, rail spur, and truck roads
installed to transport coal ash from the site.
ASH POND DAMS
Seepage through earthen dams is common and is an expected consequence of impounding water
with an earthen embankment. Even the tightest, best -compacted clays cannot prevent some water
from seeping through them. Seepage is not necessarily an indication that a dam has structural
problems, but should be kept in check through various engineering controls and regularly monitored
for changes in quantity or quality which, over time, may result in dam failure.
Currently, no seeps have been detected at the site.
Duke Energy Progress, Inc. - Sutton NC0001422
NPDES Renewal
Page 2

REASONABLE POTENTIAL ANALYSIS(RPA)-OUTEALL 001, OUTFALL 002, OUTFALL 004,
OUTFALL 008
The Division conducted EPA -recommended analyses to determine the reasonable potential for
toxicants to be discharged at levels exceeding water quality standards/EPA criteria by this facility.
For the purposes of the RPA, the background concentrations for all parameters were assumed to be
below detections level. The RPA uses 95% probability level and 95% confidence basis in accordance
with the EPA Guidance entitled "Technical Support Document for Water Quality -based Toxics
Control." The RPA included evaluation of dissolved metals' standards, utilizing a default hardness
value of 25 mg/L CaCO3 for hardness -dependent metals. The RPA spreadsheets are attached to this
Fact Sheet.
a) RPA for Decanting/Normal operation of Ash Pond (Outfall 001, 002, and 004).
The long term discharge data on the EPA Form 2C was used, it was supplemented by the
analysis of the free standing water in both ash ponds, landfill leachate analysis from similar
landfills, and groundwater sampling results. Since the highest available values for each
parameter was used, it is assumed that this RPA is applicable to all discharges that represent
coal ash contaminated water (outfalls 001, 002, 004). Calculations included: As, Be, Cd, Al,
Cr, Cu, F, Pb, Hg, Mo, Ni, Se, Ag, Zn, Ba, Sb and TI (please see attached). The historic
flow of 12.84 MGD was used in the analysis, the groundwater pumping volume of 1.3 MGD
and landfill leachate volume of 0.1 MGD was added to the historic flow. The RPA indicated
the need for following the water -quality based limits: As, Cu, Ni, and Se.
b) RPA for Dewatering of Ash pond (Outfall 001 and Outfall 004).
To meet the requirements of the Coal Ash Management Act of 2014, the facility needs to
dewater ash ponds by removing the interstitial water. The facility's highest discharge rate
from the dewatering process will be 2.1 MGD. The facility submitted data for the standing
surface water in the ash ponds, interstitial water in the ash, and interstitial ash water that was
treated by filters of various sizes. To evaluate the impact of the dewatering on the receiving
stream the RPA was conducted for the wastewater that will be generated by the dewatering
process. To introduce the margin of safety, the highest measured concentration for a
particular parameter was used. The RPA was conducted for As, Be, Cd, Chlorides, Al, Cr,
Cu, F, Pb, Hg, Mo, Ni, Se, Ag, Zn, Ba, Sb and Tl (please see attached). The RPA indicated
the need for the following water -quality based limits: As, Chlorides, Al, Cu, F, Pb, Hg, Mo,
Ni, Se, and Zn.
c) RPA for Combined Cycle Unit (Outfall 008).
The RPA was also conducted for the Combined Cycle Unit. Calculations included: As, Be,
Cd, Al, Cr, Cu, Pb, Hg, Mo, Ni, Se, Ag, Zn, Ba, Sb and Tl (please see attached). The flow
volume of 211 MGD was used in the RPA. The RPA indicated the need for the following
water -quality based limits: As, Cu, and Se.
The proposed permit requires that EPA methods 200.7 or 200.8 (or the most current versions) shall
be used for analyses of all metals except for total mercury.
MERCURY EVALUATION (Outfall 001 normal operation
The State of North Carolina has a state-wide mercury impairment. The TMDL has been developed
to address this issue in 2012. The TMDL included the implementation strategy, both documents were
approved by EPA in 2012.
Duke Energy Progress, Inc. - Sutton NC0001422
NPDES Renewal
Page 3

The mercury evaluation was conducted in accordance with the Permitting Guidelines for Statewide
Mercury TMDL.
Year
2015
2016
Annual average
1.69
1.91
concentration n /L)
Maximum sampling
3.43
9.8
result n /L
Allowable mercury concentration for this facility is 12.0 ng/L. All annual average mercury concentrations
are below the allowable level. All maximum sampling results are below the TBEL of 47.0 ng/L. Based on the
Permitting Guidelines for Statewide Mercury TMDL, the limits are not required.
INSTREAM MONITORING -OUTFALL 002
The permit required semi-annual upstream and downstream monitoring near the ash pond
discharge. These monitoring stations have been established through the Lower Cape Fear River
Program. The monitored parameters are: total arsenic, total selenium, total mercury (method
1631E), total chromium, dissolved lead, dissolved cadmium, dissolved copper, and dissolved zinc.
The results for all parameters are below detection level upstream and downstream of the Outfall
001. It is required that the monitoring of the instream stations will continue during the next permit
cycle.
CWA SECTION 316(a�
Since the Sutton Lake has been reclassified to the "waters of the State" on November 5, 2014, the
facility'has to develop a strategy to meet the state temperature standard in Sutton Lake. In order to
obtain thermal variance/mixing zone for Lake Sutton/Cape Fear River the facility shall develop and
conduct comprehensive 316(a) studies. The 316(a) studies shall be performed in accordance with the
Division of Water Resources approved plan. The temperature analysis and the balanced and
indigenous study plan shall conform to the specifications outlined in 40 CFR 125 Subpart H and the
EPA's Draft 316(a) Guidance Manual, dated 1977, and the Region 4 letter to NCDENR, dated June
3, 2010.
CWA SECTION 316(bl
The permittee shall comply with the Cooling Water Intake Structure Rule per 40 CFR 125.95. The
Division approved the facility request for an alternative schedule in accordance with 40 CFR
125.95(a)(2). The permittee shall submit all the materials required by the Rule with the next renewal
application.
TOXICITY TESTING -OUTFALL 001, OUTFALL 002, OUTFALL 004, AND OUTFALL 008
Current Requirement: Outfall 001, 002, 004, 008 — Acute P/F @ 90% using Pimephales
pmmelas
Recommended Requirement: Outfall 001, 002, 004, 008 — Acute P/F @ 90% using Pimephales
pmmelas
This facility has passed all toxicity tests during the previous permit cycle, please see attached.
For the purposes of the permitting, the long term average flow was used in conjunction with the
7Q10 summer flow to calculate the percent effluent concentrations to be used for WET.
COMPLIANCE SUMMARY
During the last 5 years, the facility has exceeded limit 3 times, please see attached. The limit violations were for
Oil and Grease (2 times - Outfall 005) and flow volume (Outfall 001), please see attached.
Duke Energy Progress, Inc. - Sutton NC0001422
NPDES Renewal
Page 4

PERMIT LIMITS DEVELOPMENT
• The temperature limits (Outfall 001 and Outfall 008) are based on the North Carolina water
quality standards (15A NCAC 2B .0200).
• The limits for Oil and Grease and Total Suspended Solids (Outfall 001, Outfall 002, Outfall
004, Outfall 005, Outfall 006, Outfall 007, Outfall 008, Outfall 009, Outfall 010, and Outfall
011) are based on the requirements in 40 CFR 423.
• The pH limits (Outfall 001, Outfall 002, Outfall 004, Outfall 005, Outfall 006, Outfall 008,
Outfall 009, Outfall 010, and Outfall 011) are based on the North Carolina water quality
standards (15A NCAC 2B .0200).
• The Whole Effluent Toxicity limit (Outfall 001, Outfall 002, Outfall 004 and Outfall 008) is
based on the requirements of 15A NCAC 2B .0500.
• The Water Quality Based Effluent Limits for Total Arsenic, Total Selenium, Total Copper,
and Total Nickel (Outfall 001, Outfall 002, and Outfall 004) are based on the results of the
Reasonable Potential Analysis.
• The Water Quality Based Effluent Limits for Total Aluminum, Total Lead, and Chlorides
(Outfall 001 — dewatering and Outfall 004 - dewatering) are based on the results of the
Reasonable Potential Analysis.
• The turbidity limit (Outfall 001 and Outfall 004 -dewatering) is based on North Carolina water
quality standards (15A NCAC 2B .0200).
• Mercury limit in the permit (Outfall 001 -dewatering) is based on the results of the
Reasonable Potential Analysis.
• The Water Quality Based Effluent Limits for Total Arsenic, Total Selenium, and Total
Copper (Outfall 008) are based on the results of the Reasonable Potential Analysis.
PROPOSED CHANGES
• A separate effluent page for the dewatering of the New Ash Pond (Outfall 004) was added to
the permit (Please see Special Condition A. (5)).
• The daily maximum limit for Total Arsenic was increased based on the updates to the North
Carolina standards (Outfall 001, Outfall 002 and Outfall 004).
• Limits for Total Copper were added to the permit based on the results of the Reasonable
Potential Analysis (Outfall 001, Outfall 002 and Outfall 004).
• Limits for Total Nickel were added to the permit based on the results of the Reasonable
Potential Analysis (Outfall 001, Outfall 002 and Outfall 004).
• Limits for Total Iron were removed from the permit based on the updates to the North
Carolina standards (Outfall 001, Outfall 002 and Outfall 004).
• Limits for Total Cadmium were removed from the permit based on the results of the
Reasonable Potential Analysis (Outfall 001).
• Limits for Total Lead were removed from the permit based on the results of the Reasonable
Potential Analysis (Outfall 001 -normal operation).
• Limits for Chlorides were added to the permit based on the results of the Reasonable
Potential Analysis (Outfall 001 - dewatering).
• Monitoring for Hexavalent Chromium was added to the permit based on the results of the
Reasonable Potential Analysis (Outfall 001 - dewatering).
• The daily maximum limit for Total Lead was increased based on the updates to the North
Carolina standards (Outfall 001 - dewatering).
• Limits for Total Mercury were removed from the permit based on the results of the Mercury
Evaluation (Outfall 001 -normal operation, Outfall 002 -normal operation, Outfall 004 -
normal operation).
Duke Energy Progress, Inc. - Sutton NC0001422
NPDES Renewal
Page 5

• Limits for Total Arsenic, Total Copper, and Total Selenium were added to the permit based
on the results of the Reasonable Potential Analysis (Outfall 008).
• The Acute Toxicity monitoring frequency was reduced to Monthly (Outfall 002 and Outfall
004) to be consistent with other Duke permits.
• The Special Conditions Fish Tissue Monitoring near Ash Pond Discharge and Clean Water
Act Section 316(b) have been updated, please see A. (19.) and A. (21.).
• The Clean Water Act Section 316(a) Special Condition was added to the permit, please see
A. (20.).
• The Outfall 010 and 011 were added to the permit to accommodate discharges of
stormwater from the future coal ash landfill.
• The Ash Pond Closure Special Condition was removed from the permit since the facility
submitted Closure Plan in 2016.
• The Biocide Special Condition was updated to be consistent with other Duke permits, please
see A. (18.).
• The compliance schedule for Total Copper limit was added (Outfall 008), please see A. (29.).
• The compliance schedule for Total Copper limit and Total Nickel limit were added (Outfall
001).
PROPOSED SCHEDULE
Draft Permit to Public Notice: May 19, 2017 (est.)
Permit Scheduled to Issue: August 7, 2017 (est.)
STATE CONTACT
If you have any questions on any of the above information or on the attached permit, please contact
Sergei Chernikov at [phone] or [e-mail].
Duke Energy Progress, Inc. - Sutton NC0001422
NPDES Renewal
Page 6

duke Energy Progress, LLC. NPDES Permit NC00001422
,.V. Sutton Electric Plant 2016 Permit Renewal Application
N
Dike
North Pond
emergency
spillway
Makeup o
Pump
w,.
o�
Y © G
Outfall 004
m
Sutton Cooling Pond
m Ash
U Landfill
1984 (New) Ash ootprint
Pond
s
©Outfall 002
s�
Outfall 008 1971 (Old)
Ash Pond
o�
G
Internal
O
• Final (external) Outfalls utfall 007 South Pond
Effluent emergency
spillway
• Internal Outfalls Channel to
Cooling
O Stormwater Pond
Internal Outfall 009
0 1000 2000 3000 Recirculating
Condenser
Feet Outfall 001 Cooling Water
Release
CC Block
Internal Outfall 006
CC Block
Sutton Energy Internal Outfall 005
Complex
Attachment 1- Site Ma
NORTH CAROLINA L. V. Sutton Energy Complex
New Hanover County
Al -1

Duke Energy Progress, LLC. NPDES Permit NC00001422
M. Sutton Electric Plant 2016 Permit Renewal Application
Outfall 002
Old Ash
Outfall 008 Pond (1971)
Cooling Pond
Internal
Outfall 007
(approx) South Pond
emergency
spillway
Stormwater
infiltration pond
emergency
spillway
ISW-1
ISW-2 Internal
ISW-3 Outfall 009
(approx)
�0
ISW-4 ISW-6
�O
mss. Recirculated
Outfall 001 cooling water
® Final (external) Outfalls and ISW-5
t,•0�
• Internal Outfalls
o Stormwater Internal Outfalls
005,006
Attachment 1- Site Ma
L. V. Sutton Energy Complex
New Hanover County
Al- 2

PUBLIC NOTICE
N.C. DEPARTMENT OF ENVIRONMENTAL QUALITY INTENT TO ISSUE NPDES
WASTEWATER DISCHARGE PERMIT #NC0001422
Public comment or objection to the draft permit modification is invited. All comments received by June
22, 2017 will be considered in the final determination regarding permit issuance and permit provisions.
PERMIT APPLICATION
Duke Energy Progress, LLC, 526 South Church St., Charlotte, N.C., has applied for renewal of its
NPDES wastewater permit (NC0001422) for L.V. Sutton Energy Complex, 801 Sutton Steam Plant Rd.,
Wilmington, New Hanover County. The facility discharges treated industrial wastewater and stormwater
to Sutton Lake and Cape Fear River in the Cape Fear River basin. This discharge may affect future
allocations in this portion of the Cape Fear River basin.
The draft wastewater permit and related documents are available online at: https:Hgoo.gl/3WtzMF.
Printed copies of the draft permit and related documents may be reviewed at the department's
Wilmington Regional Office. To make an appointment to review the documents, please call 910-796-
7215.
Public comment on the draft permit modification should be mailed to: Wastewater Permitting, 1617
Mail Service Center, Raleigh, N.C., 27699-1617.
Public comments may also be submitted by email to: publiccommentskncdenr.gov. Please be sure to
include "Sutton" in the email's subject line.
PUBLIC HEARING
The N.C. Department of Environmental Quality will hold a public hearing to accept comments on the
draft permit modification on Thur., June 22 at 6 p.m. at Wilmington Regional Office, 127 Cardinal
Drive Ext., Wilmington, N.C. Registration for those who wish to speak will begin at 5 p.m.

August 2017 Re -Notice

Permit NC0001422
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
Draft PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Water Quality
Commission, and the Federal Water Pollution Control Act, as amended,
Duke Energy Progress, LLC
is hereby authorized to discharge wastewater from a facility located at the
L. V. Sutton Energy Complex
801 Sutton Steam Plant Road, Wilmington
New Hanover County
to receiving waters designated as the Cape Fear River and Sutton Lake in the Cape Fear
River Basin in accordance with the discharge limitations, monitoring requirements,
compliance boundary map, and other applicable conditions set forth in Parts I, Il, and III.
This permit modification shall become effective
This permit and the authorization to discharge shall expire at midnight on
Signed this day
S. Jay Zimmerman P.G., Director
Division of Water Resources
By the Authority of the Environmental Management Commission
Page 1 of 24

Permit NC0001422
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under
the permit conditions, requirements, terms, and provisions included herein.
Duke Energy Progress, LLC is hereby authorized to:
Continue to discharge cooling water, low volume wastes, stormwater, and
treated wastewater from internal wastewater outfalls 005, 006, 007, and 009
to the Effluent Channel, and internal stormwater outfalls SW001, SW002,
SW003, SW004, SW005, SW006, and SWO07 to the Effluent Channel (the
Effluent Channel discharges via external Outfall 008 to the Sutton Lake); ash
pond discharge, groundwater, treated wastewater, landfill leachate, and
stormwater runoff (Outfall 001, Outfall 002 and Outfall 004); Outfall 001 may
also include cooling water from Outfall 008; at a facility located at Sutton
Steam Electric Plant, 801 Sutton Steam Plant Road, Wilmington, New Hanover
County, and
2. Discharge wastewater (via Outfall 002, Outfall 004, and Outfall 008) at the
locations specified on the attached map into the Sutton Lake which is
classified C -Swamp waters in the Cape Fear River Basin.
3. Discharge non -contact stormwater (via Outfall 010 - North Pond Emergency
Spillway and Outfall 011 - South Pond Emergency Spillway) from landfill (after
landfill is capped) at the locations specified on the attached map into the
Sutton Lake which is classified C -Swamp waters in the Cape Fear River Basin.
Discharge is only allowed for storm events that exceeds 25 -year 24-hour storm
events.
4. Discharge treated wastewater, ash pond discharge, stormwater, landfill
leachate, and groundwater (via Outfall 00 1) at the location specified on the
attached map into the Cape Fear River, classified C -Swamp waters in the Cape
Fear River Basin.
Page 2 of 24

Permit NC0001422
Part I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 001 -
normal operation/ decanting) [15A NCAC 0213 .0400 et seq., 0213 .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to the Cape Fear River from Outfall 001 - removing the free
water above the settled ash layer that does not involve mechanical disturbance of the ash
(recirculation cooling water, non -contact cooling water, and treated wastewater from outfalls
002, and 004). Such discharges shall be limited and monitored6 by the Permittee as specified
below:
-
b E N T
itHARACTERISTICS
MNUFMCQUIREMENTS
Monthly Daily Measurement Sample
Avera e . Maximum___ Frec�uen Type,_ „..;
Sample
Location'
Flow MGD
Daily
Estimate or
pump logs
Effluent
Tem erature1,2, °C
Quarterly
Grab
U, D
Tem erature2, °C
Daily
Grab
Effluent
H7
6.0<
Hs 9.0
Weekly
Grab
Effluent
Oil and Grease
15.0 m L
20.0 m L
Weekly
Grab
Effluent
Total Suspended Solids,
mg/L8
30.0 mg/L
100.0 mg/L
Weekly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , m L
Weekly
Grab
Effluent
Total Phosphorus, m L
Weekly
Grab
Effluent
Dissolved Oxygen, m L
Weekly
Grab
Effluent
Acute ToxiCity3
Monthly
Grab
Effluent
Total Mercury4
Weekly
Grab
Effluent
Total Arsenic
10.0 µ L
50.0 µ L
Weekly
Grab
Effluent
Total Selenium
5.0 µg/L
56.0 µg/L
Weekly
Grab
Effluent
Total Iron, m L
Weekly
Grab
Effluent
Total Lead, pg L
Weekly
Grab
Effluent
Total Cadmium
Weekly
Grab
Effluent
Total Aluminum, m L
Weekly
Grab
Effluent
Total Co erg
7.88 L
10.47 p L
Weekly
Grab
Effluent
Total Nicke19
25.0 L
335.2 p L
Weekly
Grab
Effluent
Total Zinc, L
Weekly
Grab
Effluent
Turbidit 5
Weekly
Grab
Effluent
Total Hardness, m L
Weekly
Grab
Effluent
Notes:
1. U: Upstream, 2700 feet above outfall (intake structure on the Cape Fear River). D: Downstream,
1.25 miles below outfall. Instream monitoring is provisionally waived in light of the
permittee's participation in the Lower Cape Fear River Basin Association. Instream
monitoring shall be conducted as stated in this permit should the permittee end its
participation in the Association.
2. The receiving water's temperature shall not be increased by more than 2.8°C above ambient
water temperature and in no case exceed 32°C, except in the mixing zone described as follows:
Extending from the eastern shore to the centerline of the river and extending not more than
1.25 miles downstream nor more than 2700 feet from the point of discharge. The cross-
sectional area of the mixing zone shall not exceed 9% of the total cross sectional area of the river
at the point of discharge nor 2.5% at the mouth of Toomer's Creek.
3. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%); Part I, Condition A. (13.).
4. The facility shall use EPA method 1631E.
5. The discharge from this facility shall not cause turbidity in the receiving stream to exceed 50
NTU. If the instream turbidity exceeds 50 NTU due to natural background conditions, the
discharge cannot cause turbidity to increase in the receiving stream.
Page 3 of 24

Permit NC0001422
6. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (25.).
7. The facility shall continuously monitor pH when the decanting process commences (and the
pump is operating) and the decanting pump shall be shutoff automatically when 15 minutes
running average pH falls below 6.1 standard units or rises above 8.9 standard units. Pumping
will be allowed to continue if interruption might result in a dam failure or damage.
8. The facility shall continuously monitor TSS concentration when the decanting process
commences (and the pump is operating) and the decanting pump shall be shutoff automatically
when the one half of the Daily Maximum limit (15 minutes average) is exceeded. Pumping will
be allowed to continue if interruption might result in a dam failure or damage.
9. The limits will become effective 36 months from the permit effective date. Please see Special
Condition A. (30.).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The level of water in the ash pond should not be lowered more than 1 ft/week, unless
approved by the DEQ Dam Safety Program. The facility shall use a floating pump suction pipe
with free water skimmed from the basin surface using an adjustable weir.
The facility is allowed to drawdown the wastewater in the ash pond to no less than three feet
above the ash.
When the facility commences the ash pond/ponds decommissioning process, the facility
shall treat the wastewater discharged from the ash pond/ponds using the physical -chemical
treatment facilities.
No later than August 1, 2019 separate the discharge of treated wastewaters from the
discharge of waters from Sutton Lake. Treated wastewaters include wastewaters from the
ash pond discharge, groundwater extraction, landfill leachate, stormwater runoff, and any
additional wastewaters from Outfalls 002 and 004. Treated wastewaters shall continue to be
discharged through Outfall 001 and subject to the Effluent Limitations and Monitoring
Requirements in Section A. (1.)
Page 4 of 24

Permit NC0001422
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
001 -dewatering phase) [ 15A NCAC 02B.0400 et seq., 02B.0500 et seq.]
During the period beginning on the commencement date of the dewatering operation and lasting
until expiration, the Permittee is authorized to discharge to the Cape Fear River from Outfall 001
Dewatering -removing the interstitial water/ash pore water (recirculation cooling water, non -
contact cooling water, and treated wastewater from outfalls 002, and 004). Such discharges
shall he limited and monitored by the Permittee as s ecificd below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIRE S
Monthly
Averum
a a
Daily Measurement Sample TSample
Maxim Frequency a
Location'
Flow
2.1 MGD
(applies only to ash
and discharge)
Daily
Estimate or
pump logs
Effluent
Flow
Daily
Estimate or
pump logs
Effluent
Tem erature1,2, OC
Quarterly
Grab
U, D
Tem erature2, °C
Daily
Grab
Effluent
H9
6.0<
pH <_ 9.0
Daily
Daily
Effluent
Oil and Grease
15.0 m L
20.0 m L
Weekly
Grab
Effluent
Total Suspended Solids
mg/L10
30.0 mg/L
100.0 mg/L
Weekly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , m L
Weekly
Grab
Effluent
Total Phosphorus, m L
Weekly
Grab
Effluent
Dissolved Oxygen, m L
Weekly
Grab
Effluent
Total Chlorides'
230.0 m L
230.0 m L
Weekly
Grab
Effluent
Acute ToxiCity3
Monthly
Grab
Effluent
Total Iron, m L
Weekly
Grab
Effluent
Total Cadmium, pg L
Weekly
Grab
Effluent
Chromium (VI), µ L
Weekly
Grab
Effluent
Total Aluminum
8.0 m L
8.0 m L
Weekly
Grab
Effluent
Total Nickel8
25.0 L
335.2 L
Weekly
Grab
Effluent
Total Lead
2.94 µ L
75.4 µ L
Weekly
Grab
Effluent
Total Arsenic
10.0 µ L
50.0 µ L
Weekly
Grab
Effluent
Total Selenium
5.0 µ L
56.0 µ L
Weekly
Grab
Effluent
Total Mercury4
47.0 n L
Weekly
Grab
Effluent
Total Copper, pg/L8
7.88 µ L
10.47 µ L
Weekly
Grab
Effluent
Total Zinc, µ L
Weekly
Grab
Effluent
Turbidit 5
Weekly
Grab
Effluent
Total Hardness, m L
Weekly
Grab
Effluent
Notes:
1. U: Upstream, 2700 feet above outfall (intake structure on the Cape Fear River). D: Downstream,
1.25 miles below outfall. Instream monitoring is provisionally waived in light of the
permittee's participation in the Lower Cape Fear River Basin Association. Instream
monitoring shall be conducted as stated in this permit should the permittee end its
participation in the Association.
2. The receiving water's temperature shall not be increased by more than 2.8°C above ambient
water temperature and in no case exceed 32°C, except in the mixing zone described as follows:
Extending from the eastern shore to the centerline of the river and extending not more than
1.25 miles downstream nor more than 2700 feet from the point of discharge. The cross-
sectional area of the mixing zone shall not exceed 9% of the total cross sectional area of the river
at the point of discharge nor 2.5% at the mouth of Toomer's Creek.
3. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%); Part I, Condition A. (13.).
4. The facility shall use EPA method 1631 E, this is an annual average limit.
Page 5 of 24

Permit NC0001422
5. The discharge from this facility shall not cause turbidity in the receiving stream to exceed 50
NTU. If the instream turbidity exceeds 50 NTU due to natural background conditions, the
discharge cannot cause turbidity to increase in the receiving stream.
6. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (25.).
7. The discharge from this facility shall not cause the Chlorides level in the receiving stream to
exceed 230 mg/L. If the Chlorides level exceeds 230 mg/L due to natural background
conditions, the discharge cannot cause Chlorides to increase in the receiving stream.
8. The limits will become effective 36 months from the permit effective date. Please see Special
Condition A. (30.).
9. The facility shall continuously monitor pH when the decanting process commences (and the
pump is operating) and the decanting pump shall be shutoff automatically when 15 minutes
running average pH falls below 6.1 standard units or rises above 8.9 standard units. Pumping
will be allowed to continue if interruption might result in a dam failure or damage.
10. The facility shall continuously monitor TSS concentration when the decanting process
commences (and the pump is operating) and the decanting pump shall be shutoff automatically
when the one half of the Daily Maximum limit (15 minutes average) is exceeded. Pumping will
be allowed to continue if interruption might result in a dam failure or damage.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The level of water in the ash pond should not be lowered more than 1 ft/week, unless
approved by the DEQ Dam Safety Program.
When the facility commences the ash pond/ponds decommissioning process, the facility
shall treat the wastewater discharged from the ash pond/ponds using the physical -chemical
treatment facilities.
Discharge to Sutton Lake during dewatering is not authorized.
No later than August 1, 2019 separate the discharge of treated wastewaters from the
discharge of waters from Sutton Lake. Treated wastewaters include wastewaters from the
ash pond discharge, groundwater extraction, landfill leachate, stormwater runoff, and any
additional wastewaters from Outfalls 002 and 004. Treated wastewaters shall continue to be
discharged through Outfall 001 and subject to the Effluent Limitations and Monitoring
Requirements in Section A. (2.)
Page 6 of 24

Permit NC0001422
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
002 -normal operation)
115A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to Sutton Lake and/or to the 1984 ash pond from Outfall 002 -
removal of free water above the settled ash layer that does not involve mechanical disturbance of the
ash Old Ash Pond - coal pile runoff, low volume wastes, ash sluice water, and stormwater
runoff). Such discharges to Sutton Lake shall be limited and monitored3 by the Permittee as specified
below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency-
Sample
e
Sample Location
Flow, MG I)
Weekly
Pump Logs
or similar
Effluent
Temperature, OC
Weekly
Grab
Effluent
Oil and Grease
15.0 mg/L
20.0 mg/L
Weekly
Grab
Effluent
Total Suspended
Solids
30.0 mg/L
100.0 mg/L
Weekly
Grab
Effluent
H
6.0 s pH < 9.0
Weekly
Grab
Effluent
Total Copper
7.88 µ L 10.47 µ L
Weekly
Grab
Effluent
Total Zinc, µ L
Weekly
Grab
Effluent
Total Arsenic
10.0 µg/L 50.0 µg/L
Weekly
Grab
Effluent
Total Selenium
5.0 µg/L 56.0 µg/L
Weekly
Grab
Effluent
Total Mercury 1
Weekly
Grab
Effluent
Total Iron, m L
Weekly
Grab
Effluent
Total Nickel
25.0 µ L 335.2 µ L
Weekly
Grab
Effluent
Total Aluminum,
m L
Weekly
Grab
Effluent
Acute Toxicity 2
Monthly
Grab
Effluent
Notes:
1. The facility shall use EPA method 1631 E.
2. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%); Part I, Condition A. (13.).
3. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (25.).
4. The receiving water's temperature shall not be increased by more than 2.8°C above ambient
water temperature and in no case exceed 32°C.
The level of water in the ash pond should not be lowered more than 1 ft/week, unless
approved by the DEQ Dam Safety Program. The facility shall use a floating pump suction pipe
with free water skimmed from the basin surface using an adjustable weir.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 7 of 24

Permit NC0001422
A. (4.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
004 -normal operation/ decanting)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to Sutton Lake and/or to Outfall 001 from Outfall 004 - removal
of free water above the settled ash layer that does not involve mechanical disturbance of the ash
(1984 New Ash Pond - ash sluice water, coal pile runoff, groundwater, landfill leachate, low
volume wastes, and stormwater runoff). Such discharges to Sutton Lake shall be limited and
monitored3 by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMIT §"'
G REQ
, "
Monthly
Average I
Daily
Maximum
Measurement Sample
a
Sample
Location
Flow, MGD
Weekly
Pump Logs
or similar
Effluent
Temperature, °C
Weekly
Grab
Effluent
Oil and Grease
15.0 m L
20.0 m
L
Weekly
Grab
Effluent
Total Suspended
Solids4
30.0 mg/L
100.0 mg/L
Weekly
Grab
Effluent
HS
6.0!5
H:5 9.0
Weekly
Grab
Effluent
Total Copper
7.88 µ L
10.47 µ
L
Weekly
Grab
Effluent
Total Zinc, µ L
Weekly
Grab
Effluent
Total Arsenic
10.0 µ L
50.0 µ
L
Weekly
Grab
Effluent
Total Selenium
5.0 µ /L
56.0 µ
L
Weekly
Grab
Effluent
Total Mercury 1
Weekly
Grab
Effluent
Total Iron, m L
Weekly
Grab
Effluent
Total Nickel
25.0 µ L
335.2 µ
L
Weekly
Grab
Effluent
Total Aluminum,
m L
Weekly
Grab
Effluent
Acute Toxicity 2
Monthly
Grab
Effluent
Notes:
1. The facility shall use EPA method 1631E.
2. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%); Part I, Condition A. (13).
3. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (25.).
4. The facility shall continuously monitor TSS concentration when the dewatering process
commences (and the pump is operating) and the dewatering pump shall be shutoff
automatically when the one half of the Daily Maximum limit (15 minutes average) is exceeded.
Pumping will be allowed to continue if interruption might result in a dam failure or damage.
5. The facility shall continuously monitor pH when the dewatering process commences (and the
pump is operating) and the dewatering pump shall be shutoff automatically when 15 minutes
running average pH falls below 6.1 standard units or rises above 8.9 standard units. Pumping
will be allowed to continue if interruption might result in a dam failure or damage.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The level of water in the ash pond should not be lowered more than 1 ft/week, unless
approved by the DEQ Dam Safety Program. The facility shall use a floating pump suction pipe
with free water skimmed from the basin surface using an adjustable weir.
The facility is allowed to drawdown the wastewater in the ash pond to no less than three feet
above the ash.
When the facility commences the ash pond/ponds decommissioning process, the facility
shall treat the wastewater discharged from the ash pond/ ponds using the physical -chemical
treatment facilities.
Page 8 of 24

Permit NC0001422
A. (5.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
004 -dewatering phase)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the commencement date of the dewatering operation and lasting
until expiration, the Permittee is authorized to discharge to Outfall 001 from Outfall 004
Dewatering -removing the interstitial water/ash pore water (1984 New Ash Pond - ash sluice
water, coal pile runoff, groundwater, landfill leachate, low volume wastes, and stormwater
runoff). Such discharges shall be limited and monitored5 at Outfall 001 by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS
,"
4wWWWWw �,
LIMITS
MONITORING REQUIREMENTS
Monthly
Average]
Daily Measurement Sample Sample
MazAptM Frequency a Location
Flow
2.1 MGD
(applies only to ash
pond discharge)
Daily
Estimate
or pump
logs
Effluent
Temperature, OC
Weekly
Grab
Effluent
H7
6.0<
pH!g 9.0
Daily
Daily
Effluent
Oil and Grease
15.0 m L
20.0 m L
Weekly
Grab
Effluent
Total Suspended Solids
mg/L6
30.0 mg/L
100.0 mg/L
Weekly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , m L
Weekly
Grab
Effluent
Total Phosphorus, m L
Weekly
Grab
Effluent
Dissolved Oxygen, m L
Weekly
Grab
Effluent
Total Chlorides
230.0 m L
230.0 m /L
Acute Toxicit3r2
Monthly
Grab
Effluent
Total Iron, m L
Weekly
Grab
Effluent
Total Cadmium, pg L
Weekly
Grab
Effluent
Chromium (VI), µ L
Weekly
Grab
Effluent
Total Aluminum
8.0 m L
8.0 m L
Weekly
Grab
Effluent
Total Nickel
25.0 L
335.2 pg L
Weekly
Grab
Effluent
Total Lead
2.94 µ L
75.4 µ L
Weekly
Grab
Effluent
Total Arsenic
10.0 µ L
50.0 µ L
Weekly
Grab
Effluent
Total Selenium
5.0 pg L
56.0 µ L
Weekly
Grab
Effluent
Total Mercury3
47.0 n L
Weekly
Grab
Effluent
Total Copper, µ L
7.88 µ L
10.47 µ L
Weekly
Grab
Effluent
Total Zinc, µ L
=Weekly
Grab
Effluent
Turbidity4
I Weekly
Grab
Effluent
Notes:
1. The receiving water's temperature shall not be increased by more than 2.8°C above ambient
water temperature and in no case exceed 32°C.
2. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%); Part I, Condition A. (13.).
3. The facility shall use EPA method 1631E, this is an annual average limit.
4. The discharge from this facility shall not cause turbidity in the receiving stream to exceed 50
NTU. If the instream turbidity exceeds 50 NTU due to natural background conditions, the
discharge cannot cause turbidity to increase in the receiving stream.
5. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (25.).
6. The facility shall continuously monitor TSS concentration when the dewatering process
commences (and the pump is operating) and the dewatering pump shall be shutoff
automatically when the one half of the Daily Maximum limit (15 minutes average) is exceeded.
Pumping will be allowed to continue if interruption might result in a dam failure or damage.
7. The facility shall continuously monitor pH when the dewatering process commences (and the
pump is operating) and the dewatering pump shall be shutoff automatically when 15 minutes
Page 9 of 24

Permit NC0001422
running average pH falls below 6.1 standard units or rises above 8.9 standard units. Pumping
will be allowed to continue if interruption might result in a dam failure or damage.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The level of water in the ash pond should not be lowered more than 1 ft/week, unless
approved by the DEQ Dam Safety Program. The facility shall use a floating pump suction pipe
with free water skimmed from the basin surface using an adjustable weir.
When the facility commences the ash pond/ponds decommissioning process, the facility
shall treat the wastewater discharged from the ash pond/ponds using the physical -chemical
treatment facilities.
A. (6.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
005)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
Beginning with the commencement of this discharge and lasting until expiration, the Permittee is
authorized to discharge from Internal Outfall 005 (Combined Cycle Plant - ultrafilter water
treatment system filter backwash, closed cooling water cooler blowdown, Reverse
Osmosis/Electrodeionization system reject wastewater, and other low volume wastewater) to
the Effluent Channel. Such discharges shall be limited and monitored' by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurementl
Frequency
Sample
Type
Sample
Location
Flow, MGD
Daily
Pump Logs or
similar
Influent or
Effluent
Oil and Grease
15.0 mg/L
20.0 mg/L
2/Month
Grab
Effluent
Total Suspended Solids
30.0 mg/L
100.0 mg/L
2/Month
Grab
Effluent
pH
6.0 < pH < 9.0
2/Month
Grab
Effluent
Notes:
1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. Please See Special Condition A. (25.).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 10 of 24

Permit NC0001422
A. (7.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
006)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
Beginning with the commencement of this discharge and lasting until expiration, the Permittee is
authorized to discharge from Internal Outfall 006 (Combined Cycle Plant - low volume
wastewater including the Heat Recovery Steam generator blowdown and auxiliary boiler
blowdown) to the Effluent Channel. Such discharges shall be limited and monitored' by the
Permittee as specified below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
Monthly Daily
Average Maximum
MONITORING REQUIREMENTS
Measurement
Frequency
Sample
Type
Sample
Location
Flow, MGD
Daily
Pump Logs or
similar
Influent or
Effluent
Oil and Grease
15.0 mg/L
20.0 mg/L
2/Month
Grab
Effluent
Total Suspended Solids
30.0 mg/L
100.0 mg/L
2/Month
Grab
Effluent
pH
6.0 < pH < 9.0
2/Month
Grab
Effluent
Notes:
1.. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. Please See Special Condition A. (25.).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (8.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
007)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from Internal Outfall 007 (stormwater flows from the closure
activities for coal-fired units, separate from stormwater outfalls SWO01 through SWO07) to the
Effluent Channel. Such discharges shall be limited and monitored2 by the Permittee as specified
below:
Notes.
1. The facility shall use EPA method 1631E.
2. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (25.).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 11 of 24
=RING REQ
CHARACTERISTICS
Monthly
�'h aily
Measurement
Sample
Sample
Average
Maxim
Fre uenc
Flow, MGD
Weekly
Pump Logs
Effluent
or similar
Oil and Grease
15.0 m L
20.0 m L
Monthly
Grab
Effluent
Total Suspended
30.0 mg/L
100.0 mg/L
Monthly
Grab
Effluent
Solids
Total Arsenic, µ L
Quarterly
Grab
Effluent
Total Selenium, µ L
Quarterly
Grab
Effluent
Nitrate/nitrite as N,
Quarterly
Grab
Effluent
m L
Total Mercury', ng/L
Quarterly
Grab
Effluent
Notes.
1. The facility shall use EPA method 1631E.
2. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. Please See Special Condition A. (25.).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 11 of 24

Permit NC0001422
A. (9.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
009)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from Internal Outfall 009 (low volume wastes from a new
simple cycle combustion turbine) to the Effluent Channel. Such discharges shall be limited and
monitored' by the Permittee as specified below
FFLUENT
LIMITS
M NITO G -REQUIREMENT$"" `'
°CHARACTERISTICS
Daily
Monthly
Daily
Measurement
Sample Sample
Average
Maximum
Frequency
Location
Flow, MGD
Weekly
Pump Logs Effluent
Daily
Grab
Instream
Oil and Grease
or similar
Oil and Grease
15.0 m L
20.0 m L
Monthly
Grab Effluent
Total Suspended
30.0 mg/L
100.0 mg/L
Monthly
Grab Effluent
Solids
Monthly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , m L
pH
6.0 < pH < 9.0
2/Month
Grab Effluent
Notes.
1.The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. Please See Special Condition A. (25.).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (10.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
(Outfall 008)5
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to Sutton Lake from Outfall 008 (from internal wastewater
outfalls 005, 006, 007, and 009, and internal stormwater outfalls SW001 through SWO07).
Such discharges shall be limited and monitored6 by the Permittee as specified below:
EFFLUENT I LIMITS I MONITORING REQUIREMENTS
CHARACTERISTICS
MonthlyI Daily I Measurement I Sample Sample
Averaze Maximum Frequencv Type 1
Flow, MGD
Daily
Estimate
or pump
logs
Effluent
Temperature OC
Daily
Grab
Effluent
Temperature 1.2, °C
Daily
Grab
Instream
Oil and Grease
15.0 mg
L
20.0 m
L
Monthly
Grab
Effluent
Total Suspended Solids
30.0 m
L
100.0 m
L
Monthly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , m L
Monthly
Grab
Effluent
Dissolved Oxygen, m L
Monthly
Grab
Effluent
H
6.0
<_
Hs 9.0
Daily
Grab
Effluent
Total Phosphorus, m L
Monthly
Grab
Effluent
Acute ToXiCity3
Quarterly
Grab
Effluent
Total Mercu , n L
Quarterly
Grab
Effluent
Total Arsenic?
10.0 µ
L
50.0 µ
L
Quarterly
Grab
Effluent
Total Selenium?
5.0 µ
L
56.0 µ
L
Quarterly
Grab
Effluent
Total Co erg
7.88 µ
L
10.47 µ
L
Quarterly
Grab
Effluent
Total Zinc, µ L
Quarterly
Grab
Effluent
Notes:
1.. Instream: 1000 feet from outfall.
Page 12 of 24

Permit NC0001422
2. The receiving water's temperature shall not be increased by more than 2.8°C above ambient
water temperature and in no case exceed 32°C. The limit is not being implemented until
further notice (Please see A. (20.)).
3. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%); Part I, Condition A. (23.).
4. The facility shall use EPA method 1631E.
5. The facility shall install a screen or a barrier at the end of the Effluent Channel to minimize
fish migration into the Channel. The screen/barrier shall be installed by July 1, 2017.
6. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. Please See Special Condition A. (25.).
7. The limits become effective 36 months from the effective date of the permit (Please see A.
(29.)).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (11.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
010)
[15A NCAC 02B .0400 et seq., 02B.0500 et seq.]
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge non -contact stormwater from Outfall 010 - the North Pond
Emergency Spillway of the capped landfill. Such discharges shall be limited and monitored' by the
Permittee asspecified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITO
MON&MVid
ENT=WMEMW
Monthly
Average
Daily
Maximum
Measurement Sample
Fre Luency Type
Sample
Location
Flow, MGD
Per discharge event
Estimate
Effluent
H
6.0!5 pH
s 9.0
Per discharge event
Grab
Effluent
Oil and Grease
15.0 m L
20.0 m L
Per discharge event
Grab
Effluent
TSS
30.0 m L
100.0 m L
Per discharge event
Grab
Effluent
1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. Please See Special Condition A. (25.).
Discharge is only allowed for storm events that exceeds 25 -year 24-hour storm events.
A. (12.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
011)
[15A NCAC 02B .0400 et seq., 02B.0500 et seq.]
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge non -contact stormwater from Outfall 011 - the South Pond
Emergency Spillway of the capped landfill. Such discharges shall be limited and monitored' by the
Permittee as specified below:
EFFLUENT
CHARACTERISTICS
L
MON&MVid
REQUIREME
- r...,.,.
Monthly
fterage
Daily Measurement Sample
Maximum Fre ue T e
Sample
Location
Flow, MGD
Per discharge event
Estimate
Effluent
H
6.0!5
H s 9.0
Per discharge event
Grab
Effluent
Oil and Grease
15.0 m L
20.0 m L
Per discharge event
Grab
Effluent
TSS
30.0 m L
100.0 m L
Per discharge event
Grab
Effluent
1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. Please See Special Condition A. (25.).
Discharge is only allowed for storm events that exceeds 25 -year 24-hour storm events.
Page 13 of 24

Permit NC0001422
A. (13.) ACUTE TOXICITY LIMIT (MONTHLY)- OUTFALLS 001, 002, and 004.
[15A NCAC 02B .0200 et seq.]
The permittee shall conduct acute toxicity tests on a monthlu basis using protocols defined in the
North Carolina Procedure Document entitled "Pass/ Fail Methodology For Determining Acute
Toxicity In A Single Effluent Concentration" (Revised -July, 1992 or subsequent versions). The
monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24 hour static test. The
effluent concentration at which there may be at no time significant acute mortality is 90% (defined
as treatment two in the procedure document). Effluent samples for self-monitoring purposes must
be obtained during representative effluent discharge below all waste treatment.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR -1) for the month in which it was performed, using the parameter
code TGE6C. Additionally, DWR Form AT -2 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than
30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/ physical
measurements performed in association with the toxicity tests, as well as all dose/response data.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT)
test form indicating the facility name, permit number, pipe number, county, and the month/year of
the report with the notation of "No Flow" in the comment area of the form. The report shall be
submitted to the Water Sciences Section at the address cited above.
Should any test data from either these monitoring requirements or tests performed by the North
Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit
may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
A. (14.) STRUCTURAL INTEGRITY INSPECTIONS OF ASH POND DAMS
The facility shall meet the dam design and dam safety requirements per 15A NCAC 2K.
A. (15.) BEST MANAGEMENT PRACTICES PLAN
The Permittee shall continue to implement a Best Management Practices (BMP) Plan to control the
discharge of oils and the hazardous and toxic substances listed in 40 CFR, Part 117 and Tables II
and III of Appendix D to 40 CFR, Part 122, and shall maintain the Plan at the plant site and shall
be available for inspection by EPA and DWR personnel.
A. (16.) INTAKE SCREEN BACKWASH
Continued intake screen backwash discharge is permitted without limitations or monitoring
requirements.
Page 14 of 24

Permit NC0001422
A. (17.) NO DISCHARGE OF PCBs
As specified by 40 CFR 423.13 (a), there shall be no discharge of polychlorinated biphenyl
compounds such as those commonly used for transformer fluid.
A. (18.) BIOCIDE CONDITION
The permittee shall not use any biocides except those approved in conjunction with the permit
application. The permittee shall notify the Director in writing not later than ninety (90) days prior to
instituting use of any additional biocide used in cooling systems which may be toxic to aquatic life
other than those previously reported to the Division of Water Resources. Such notification shall
include completion of Biocide Worksheet Form 101 and a map locating the discharge point and
receiving stream. Completion of Biocide Worksheet Form 101 is not necessary for those outfalls
containing toxicity testing. Division approval is not necessary for the introduction of new biocides
into outfalls currently tested for whole effluent toxicity.
A. (19.) FISH TISSUE MONITORING NEAR ASH POND DISCHARGE - OUTFALL
001, and OUTFALLS 002/004
The facility shall conduct fish tissue monitoring at two locations (Sutton Lake and Cape Fear River)
annually and submit the results with the NPDES permit renewal application. The objective of this
monitoring is to evaluate potential uptake of pollutants by fish tissue near the ash pond discharge.
The parameters analyzed in fish tissue shall be arsenic, selenium, and mercury. The monitoring shall
be conducted in accordance with the sampling plan approved by the Division. The plan should be
submitted to the Division within 180 days from the effective date of the permit. Upon approval, the
plan becomes an enforceable part of the permit.
Copies of all the study plans, study results, and any other applicable materials should be submitted
to:
1) Electronic Version Only (pdf and CD)
Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
2) Electronic Version (pdf and CD) and Hard Copy
Division of Water Resources
Water Sciences Section
1621 Mail Service Center
Raleigh, NC 27699-1621
A. (20.) CLEAN WATER ACT SECTION 316 (a) THERMAL VARIANCE
In order to obtain thermal variance/ mixing zone for Lake Sutton/ Cape Fear the facility shall
develop and conduct comprehensive 316(a) studies. The 316(a) studies shall be performed in
accordance with the Division of Water Resources approved plan. The temperature analysis and the
balanced and indigenous study plan shall conform to the specifications outlined in 40 CFR 125
Subpart H and the EPA's Draft 316(a) Guidance Manual, dated 1977, and the Region 4 letter to
NCDENR, dated June 3, 2010.
The study shall be performed in accordance with the following schedule:
1) Effective date of the permit +60 days - submit the Draft Study Plan to the DEQ and EPA, the
DEQ will perform the Plan review and provide the comments to Duke within 30 days of the
Plan receipt.
2) Effective date of the permit +120 days - meet with the DEQ to provide responses to the
DEQ/EPA comments and discuss the Study Plan.
3) Effective date of the permit +150 days - submit the Final Study Plan to the DEQ and to the
EPA.
4) After obtaining an approval of the Study Plan, conduct 2 years of monitoring.
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Permit NC0001422
5) 270 days after completing the monitoring, submit the study results and an application for
316(a) variance to DEQ.
Copies of all the study plans, study results, and any other applicable materials should be submitted
to:
1) Electronic Version Only (pdf and CD)
Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
2) Electronic Version (pdf and CD) and Hard Copy
Division of Water Resources
Water Sciences Section
1621 Mail Service Center
Raleigh, NC 27699-1621
A. (21.) CLEAN WATER ACT SECTION 316(b)
The permittee shall comply with the Cooling Water Intake Structure Rule per 40 CFR 125.95. The
permittee shall submit all the materials required by the Rule with the next renewal application.
Copies of all the study plans, study results, and any other applicable materials should be submitted
to:
1) Electronic Version Only (pdf and CD)
Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
2) Electronic Version (pdf and CD) and Hard Copy
Division of Water Resources
Water Sciences Section
1621 Mail Service Center
Raleigh, NC 27699-1621
A. (22.) LOWER CAPE FEAR MODELING
The permittee may elect to conduct a water quality model of the dilution factor for Outfall 001.
Contingent upon EPA approval of the Lower Cape Fear Modeling and its results, the Reasonable
Potential Analysis will be conducted again and the permit limits will be based on the new flow
numbers established by the model.
A. (23.) ACUTE TOXICITY LIMIT (QUARTERLY) — OUTFALL 008
[15A NCAC 02B .0200 et seq.]
The permittee shall conduct acute toxicity tests on aguarterlu basis using protocols defined in the
North Carolina Procedure Document entitled "Pass/ Fail Methodology for Determining Acute Toxicity
In A Single Effluent Concentration" (Revised December 2010 or subsequent versions). The
monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24-hour static test. The
effluent concentration at which there may be at no time significant acute mortality is 90% (defined
as treatment two in the procedure document). The tests will be performed during the months of
February, May, August, and November. These months signify the first month of each three-month
toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained
during representative effluent discharge and shall be performed at the NPDES permitted final
effluent discharge below all treatment processes.
Should any single quarterly monitoring indicate a failure to meet specified limits, then
monthly monitoring will begin immediately until such time that a single test is passed. Upon
passing, this monthly test requirement will revert to quarterly in the months specified above.
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Permit NC0001422
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR -1) for the month in which it was performed, using the parameter
code TGE6C. Additionally, DWR Form AT -2 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than
30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/ physical
measurements performed in association with the toxicity tests, as well as all dose/response data.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT)
test form indicating the facility name, permit number, pipe number, county, and the month/year of
the report with the notation of "No Flow" in the comment area of the form. The report shall be
submitted to the Water Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then
monthly monitoring will begin immediately until such time that a single test is passed. Upon
passing, this monthly test requirement will revert to quarterly in the months specified above.
Assessment of toxicity compliance is based on the toxicity testing quarter, which is the three-month
time interval that begins on the first day of the month in which toxicity testing is required by this
permit and continues until the final day of the third month.
Should any test data from either these monitoring requirements or tests performed by the North
Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit
may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
A. (24.) INSTREAM MONITORING
The facility shall conduct semi-annual instream monitoring (intake structure on the Cape Fear
River (approximately 3 miles upstream) and 2.6 miles downstream of the Outfall 001, and
approximately 1000 ft. from Outfall 004 (Bay 8) for total arsenic, total selenium, total mercury
(method 1631E), total chromium, chlorides, dissolved lead, dissolved cadmium, dissolved copper,
dissolved zinc and total hardness (as CaCO3). For the purpose of this requirement, semi-annual
means that samples are collected twice per year with at least 120 calendar days between sampling
events. The monitoring results shall be reported on the facility's Discharge Monitoring Reports and
included with the NPDES permit renewal application. Instream monitoring is provisionally
waived considering the permittee's participation in the Lower Cape Fear River Basin
Association provided the Association agrees to sample for all the parameters listed in this
condition and at the specified locations. Instream monitoring shall be conducted as stated in
this permit should the permittee end its participation in the Association.
Page 17 of 24

Permit NC0001422
A. (25.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports
and specify that, if a state does not establish a system to receive such submittals, then permittees must submit
monitoring data and reports electronically to the Environmental Protection Agency (EPA). The final NPDES
Electronic Reporting Rule was adopted and became effective on December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this permit
(Standard Conditions for NPDES Permits):
• Section B. (11.)
• Section D. (2.)
• Section D. (6.)
• Section E. (5.)
Signatory Requirements
Reporting
Records Retention
Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (aX
Effective December 21, 2016, the permittee shall report discharge monitoring data electronically using the NC
DWR's Electronic Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted
electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit
DMRs electronically using the internet. Until such time that the state's eDMR application is compliant with
EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be required to submit all
discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR
submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR
to the following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being
physically located in an area where less than 10 percent of the households have broadband access, then a
temporary waiver from the NPDES electronic reporting requirements may be granted and discharge
monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or alternative forms approved by
the Director. Duplicate signed copies shall be submitted to the mailing address above. See "How to Request a
Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following compliance monitoring
data and reports, when applicable:
Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver from
Electronic Reporting" section below).
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Permit NC0001422
2. Electronic Submissions
In accordance with 40 CFR 122.410)(9), the permittee must identify the initial recipient at the time of each
electronic submission. The permittee should use the EPA's website resources to identify the initial recipient
for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA or
the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving
electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type of
electronic submission and for each state. Instructions on how to access and use the appropriate electronic
reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting Rule is found at:
https: / /www.federalregister.gov/documents /2015 / 10/22 /2015-24954/national-pollutant-dischai ge-
elim ination-system-nudes-electro ni c-reborti nu, -rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic
reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division.
Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written
approval at least sixty (60) days prior to the date the facility would be required under this permit to begin
submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and shall
thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the Division
unless the permittee re -applies for and is granted a new temporary electronic reporting waiver by the Division.
Approved electronic reporting waivers are not transferrable. Only permittees with an approved reporting
waiver request may submit monitoring data and reports on paper to the Division for the period that the
approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on the
following web page:
hup://deq.nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.)
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section
B. (11.)(a) or by a duly authorized representative of that person as described in Part II, Section B. (11.)(b). A
person, and not a position, must be delegated signatory authority for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and
login credentials to access the eDMR system. For more information on North Carolina's eDMR system,
registering for eDMR and obtaining an eDMR user account, please visit the following web page:
htU2://deq.nc.gov/about/div,isions/water-resources/­­edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the
following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE
ACCEPTED:
'7 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 quaked personnel properly gather and evaluate the information submitted. Based
Page 19 of 24

Permit NC0001422
on my inquiry of the person orpersons who manage the ystem, or those persons directly responsible forgathering the information,
the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are
signcant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. "
5. Records Retention [Supplements Section D. (6.)]
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from the
date of the report. This period may be extended by request of the Director at any time [40 CFR
122.41].
A. (26.) APPLICABLE STATE LAW (STATE ENFORCEABLE ONLY) [G.S. 143-215.1(b)]
This facility shall meet the requirements of Senate Bill 729 (Coal Ash Management Act). This permit
may be reopened to include new requirements imposed by Senate Bill 729.
A. (27.) STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop and implement a Stormwater Pollution Prevention Plan (SPPP). The
SPPP shall be maintained on site unless exempted from this requirement by the Division. The SPPP
is public information. The SPPP should also specifically and separately address deconstruction,
demolition, coal, and/or coal ash hauling or disposal activities. The SPPP shall include, at a
minimum, the following items:
1. Site Overview. The Site Overview shall provide a description of the physical facility and the
potential pollutant sources that may be expected to contribute to contamination of stormwater
discharges. The Site Overview shall contain the following:
(a) A general location map (USGS quadrangle map or appropriately drafted equivalent map),
showing the facility's location in relation to transportation routes and surface waters; the
name of the receiving waters to which the stormwater outfalls discharge, or if the discharge
is to a municipal separate storm sewer system, the name of the municipality and the
ultimate receiving waters; and accurate latitude and longitude of the points of stormwater
discharge associated with industrial activity. The general location map (or alternatively the
site map) shall identify whether any receiving waters are impaired (on the state's 303(d) list
of impaired waters) or if the site is located in a watershed for which a TMDL has been
established, and what the parameters of concern are.
(b) A narrative description of storage practices, loading and unloading activities, outdoor
process areas, dust or particulate generating or control processes, and waste disposal
practices. A narrative description of the potential pollutants that could be expected to be
present in the stormwater discharge from each outfall. The narrative should also reference
deconstruction, demolition, coal, and/or coal ash hauling or disposal activities where
applicable.
(c) A site map drawn at a scale sufficient to clearly depict: the site property boundary; the
stormwater discharge outfalls; all on-site and adjacent surface waters and wetlands;
industrial activity areas (including storage of materials, disposal areas, process areas,
loading and unloading areas, and haul roads); site topography and finished grade; all
drainage features and structures; drainage area boundaries and total contributing area for
each outfall; direction of flow in each drainage area; industrial activities occurring in each
drainage area; buildings; stormwater Best Management Practices (BMPs); and impervious
surfaces. The site map must indicate the percentage of each drainage area that is
impervious, and the site map must include a graphic scale indication and north arrow.
(d) A list of significant spills or leaks of pollutants during the previous three (3) years and any
corrective actions taken to mitigate spill impacts.
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Permit NC0001422
(e) Certification that the stormwater outfalls have been evaluated for the presence of non-
stormwater discharges. The permittee shall submit the first certification no later than
90 days after the effective date of this permit to the Stormwater Permitting Program
Central Office and shall re -certify annually that the stormwater outfalls have been
evaluated for the presence of non-stormwater discharges. For any non-Stormwater
discharge identified, the permittee shall indicate how that discharge is permitted or
otherwise authorized. The certification statement will be signed in accordance with the
requirements found in Part II, Standard Conditions, Section B, Paragraph 11.
Stormwater Management Strategy. The Stormwater Management Strategy shall contain a
narrative description of the materials management practices employed which control or
minimize the Stormwater exposure of significant materials, including structural and
nonstructural measures. This strategy should also address deconstruction, demolition, coal,
and/or coal ash hauling or disposal activities where applicable. The Stormwater Management
Strategy, at a minimum, shall incorporate the following:
(a) Feasibility Study. A review of the technical and economic feasibility of changing the
methods of operations and/or storage practices to eliminate or reduce exposure of materials
and processes to rainfall and run-on flows. Wherever practical, the permittee shall prevent
exposure of all storage areas, material handling operations, and manufacturing or fueling
operations. In areas where elimination of exposure is not practical, this review shall
document the feasibility of diverting the stormwater run-on away from areas of potential
contamination.
(b) Secondary Containment Requirements and Records. Secondary containment is required
for: bulk storage of liquid materials; storage in any amount of Section 313 of Title III of the
Superfund Amendments and Reauthorization Act (SARA) water priority chemicals; and
storage in any amount of hazardous substances, in order to prevent leaks and spills from
contaminating stormwater runoff. A table or summary of all such tanks and stored
materials and their associated secondary containment areas shall be maintained. If the
secondary containment devices are connected to stormwater conveyance systems, the
connection shall be controlled by manually activated valves or other similar devices (which
shall be secured closed with a locking mechanism). Any Stormwater that accumulates in
the containment area shall be observed for color, foam, outfall staining, visible sheens and
dry weather flow, prior to release of the accumulated stormwater. Accumulated stormwater
shall be released if found to be uncontaminated by any material. Records documenting the
individual making the observation, the description of the accumulated Stormwater, and the
date and time of the release shall be kept for a period of five (5) years. For facilities subject
to a federal oil Spill Prevention, Control, and Countermeasure Plan (SPCC), any portion of
the SPCC Plan fully compliant with the requirements of this permit may be used to
demonstrate compliance with this permit.
In addition to secondary containment for tankage, the permittee shall provide drip pans or
other similar protection measures for truck or rail car liquid loading and unloading stations.
(c) BMP Summary. A listing of site structural and non-structural Best Management Practices
(BMPs) shall be provided. The installation and implementation of BMPs shall be based on
the assessment of the potential for sources to contribute significant quantities of pollutants
to stormwater discharges and on data collected through monitoring of stormwater
discharges. The BMP Summary shall include a written record of the specific rationale for
installation and implementation of the selected site BMPs. The BMP Summary should also
address deconstruction, demolition, coal, and/or coal ash hauling or disposal activities
where applicable. The permittee shall refer to the BMPs described in EPA's Multi -Sector
Permit (MSGP) and Industrial Stormwater Fact Sheet for Steam Electric Power Generating
Facilities (EPA -833-F-06-030) for guidance on BMPs that may be appropriate for this site.
The BMP Summary shall be reviewed and updated annually.
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Permit NC0001422
Spill Prevention and Response Procedures. The Spill Prevention and Response Procedures
(SPRP) shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. Facility personnel responsible for implementing the SPRP shall be
identified in a written list incorporated into the SPRP and signed and dated by each individual
acknowledging their responsibilities for the plan. A responsible person shall be on-site at all
times during facility operations that have increased potential to contaminate stormwater runoff
through spills or exposure of materials associated with the facility operations. The SPRP must
be site stormwater specific. Therefore, an oil Spill Prevention Control and Countermeasure plan
(SPCC) may be a component of the SPRP, but may not be sufficient to completely address the
stormwater aspects of the SPRP. The common elements of the SPCC with the SPRP may be
incorporated by reference into the SPRP.
4. Preventative Maintenance and Good Housekeeping Program. A preventative maintenance
and good housekeeping program shall be developed and implemented. The program shall
address all stormwater control systems (if applicable), stormwater discharge outfalls, all on-site
and adjacent surface waters and wetlands, industrial activity areas (including material storage
areas, material handling areas, disposal areas, process areas, loading and unloading areas, and
haul roads), all drainage features and structures, and existing structural BMPs.
The program shall establish schedules of inspections, maintenance, and housekeeping activities
of stormwater control systems, as well as facility equipment, facility areas, and facility systems
that present a potential for stormwater exposure or stormwater pollution where not already
addressed under another element of the SPPP. Inspection of material handling areas and
regular cleaning schedules of these areas shall be incorporated into the program. Compliance
with the established schedules for inspections, maintenance, and housekeeping shall be
recorded and maintained in the SPPP. The program should also address deconstruction,
demolition, coal, and/or coal ash hauling or disposal activities where applicable. The Good
Housekeeping Program shall also include, but not be limited to, BMPs to accomplish the
following:
(a) Minimize contamination of stormwater runoff from oil-bearing equipment in
switchyard areas;
(b) Minimize contamination of stormwater runoff from delivery vehicles and rail cars
arriving and departing the plant site;
(c) Inspect all residue -hauling vehicles for proper covering over the load, adequate gate -
sealing, and overall integrity of the container body. Repair vehicles as necessary;
and
(d) Reduce or control the tracking of ash and residue from ash loading and storage
areas;
S. Facility Inspections. Inspections of the facility (including tanks, pipes, and equipment) and all
stormwater systems shall occur as part of the Preventative Maintenance and Good
Housekeeping Program at a minimum on a semi-annual schedule, once during the first half of
the year (January to June), and once during the second half (July to December), with at least 60
days separating inspection dates (unless performed more frequently than semi-annually).
6. Employee Training. Training programs shall be developed and training provided at a
minimum on an annual basis for facility personnel with responsibilities for: spill response and
cleanup, preventative maintenance activities, and for any of the facility's operations that have
the potential to contaminate stormwater runoff. The facility personnel responsible for
implementing the training shall be identified, and their annual training shall be documented by
the signature of each employee trained.
7. Responsible Party. The SPPP shall identify a specific position or positions responsible for the
overall coordination, development, implementation, and revision of the SPPP. Responsibilities
for all components of the SPPP shall be documented and position assignments provided.
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Permit NC0001422
8. SPPP Amendment and Annual Update. The permittee shall amend the SPPP whenever there is
a change in design, construction, operation, site drainage, maintenance, or configuration of the
physical features which may have a significant effect on the potential for the discharge of
pollutants to surface waters. All aspects of the SPPP shall be reviewed and updated on an
annual basis. The annual update shall include:
(a) an updated list of significant spills or leaks of pollutants for the previous three (3)
years, or the notation that no spills have occurred (element of the Site Overview);
(b) a written re -certification that the stormwater outfalls have been evaluated for the
presence of non-stormwater discharges (element of the Site Overview);
(c) a documented re-evaluation of the effectiveness of the on-site stormwater BMPs (BMP
Summary element of the Stormwater Management Strategy).
(d) a review and comparison of stormwater sample analytical data to any applicable
limits or benchmark values (if applicable) over the past year.
If the Director notifies the permittee that the SPPP does not meet one or more of the minimum
requirements of the permit, the permittee shall have 30 days to respond. Within 30 days of
such notice, the permittee shall submit a time schedule to the Director for modifying the SPPP
to meet minimum requirements. The permittee shall provide certification in writing to the
Director that the changes have been made.
9. SPPP Implementation. The permittee shall implement the Stormwater Pollution Prevention
Plan and all appropriate BMPs consistent with the provisions of this permit, in order to control
contaminants entering surface waters via stormwater. Implementation of the SPPP shall
include documentation of all monitoring, measurements, inspections, maintenance activities,
and training provided to employees, including the log of the sampling data and of actions taken
to implement BMPs associated with the industrial activities, including vehicle maintenance
activities. Such documentation shall be kept on-site for a period of five (5) years and made
available to the Director or the Director's authorized representative immediately upon request.
A. (28.) ADDITIONAL CONDITIONS AND DEFINITIONS
1. EPA methods 200.7 or 200.8 (or the most current versions) shall be used for analyses of all
metals except for total mercury.
2. All effluent samples for all external outfalls shall be taken at the most accessible location
after the final treatment but prior to discharge to waters of the U.S. (40 CFR 122.41a)).
3. The term low volume waste sources means wastewater from all sources except thouse for
which specific limitations are otherwise established in this part (40 CFR 42 3. 11 (b)).
4. The term chemical metal cleaning waste means any wastewater resulting from cleaning any
metal process equipment with chemical compounds, including, but not limited to, boiler
tube cleaning (40 CFR 423.11 (c)).
5. The term metal cleaning waste means any wastewater resulting from cleaning [with or
without chemical cleaning compounds] any metal process equipment including, but not
limited to, boiler tube cleaning, boiler fireside cleaning, and air preheater cleaning (40 CFR
423.11 (d)).
6. For all outfalls where the flow measurement is to be "estimated" the estimate can be done by
using calibrated V -notch weir, stop -watch and graduated cylinder, or other method
approved by the Division.
7. During normal operations removing of the free water above the settled wet ash layer shall
not involve mechanical disturbance of the ash.
A. (29.) COPPER(Cu), ARSENIC(As), and SELENIUM(Se) COMPLIANCE
SCHEDULE (Outfall 008)
1. Nine months from the permit effective date, submit to DEQ an evaluation study plan
describing steps to be undertaken to identify the source of Cu, As, and Se at Outfall 008
Page 23 of 24

Permit NC0001422
discharge in order to comply with the limits set forth in section A. (10.) of the permit. The
study should consider potential wastewater sources, practices such as vegetation
management, and background sources.
2. Eighteen months from the permit effective date, submit a progress report describing the
findings of the study. If a source of Cu, As, and Se has been identified, the interim report
shall include proposed measures that will be evaluated to treat or eliminate the source of
pollutants. If a source of Cu, As, and Se has not been identified, the interim report shall
provide additional steps planned or necessary to comply with the limits set forth in section
A.(10.) of the permit.
3. Twenty-seven months from the permit effective date submit a progress report. If a source of
Cu, As, and Se was identified in the 18 -month report, this report should discuss the success
of the efforts to treat or eliminate sources of Cu, As, and Se. If a source of Cu, As, and Se
has not been identified, the interim report shall provide additional steps planned or
necessary to comply with the limits set forth in section A.(10.) of the permit.
4. Thirty-six months from the permit effective date the discharge shall be in compliance with
the Cu, As, and Se limitations.
A. (30.) COPPER (Cu) and NICKEL (Ni) COMPLIANCE SCHEDULE (Outfall 00 1)
I. Nine months from the permit effective date, submit to DEQ an evaluation study plan
describing steps to be undertaken to identify the source of Cu and Ni at Outfall 001 in order
to comply with the limits set forth in sections A. (1.) or A. (2.) of the permit. The study should
consider potential wastewater sources, practices such as vegetation management, and
background sources.
2. Eighteen months from the permit effective date, submit a progress report describing the
findings of the study. If a source of Cu and Ni has been identified, the interim report shall
include proposed measures that will be evaluated to treat or eliminate the source of the
pollutants. If a source of Cu and Ni is not identified, the interim report shall provide
additional steps planned or necessary to comply with the limits set forth in sections A. (1.) or
A. (2.) of the permit.
3. Twenty-seven months from the permit effective date submit a progress report. If a source of
Cu and Ni was identified in the 18 -month report, this report should discuss the success of
the efforts to treat or eliminate sources of the pollutants. If a source of Cu and Ni has not
been identified, the interim report shall provide additional steps planned or necessary to
comply with the limits set forth in sections A. (1.) or A. (2.) of the permit.
4. Thirty-six months from the permit effective date the discharge shall be in compliance with
the Cu and Ni limitations.
A. (31.) COMPLIANCE BOUNDARY
The compliance boundary for the disposal system shall be specified in accordance with 15A
NCAC 02L .0107(a) or (b) dependent upon the date permitted. An exceedance of groundwater
standards at or beyond the compliance boundary is subject to remediation action according to
15A NCAC 02L .0106(c), (d), or (e) as well as enforcement actions in accordance with North
Carolina General Statute 143-215.6A through 143-215.6C.
Page 24 of 24

'luke Energy Progress, LLC. NPDES Permit NC00001422
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G
Internal
Outfall 007
® Final (external) Outfalls
South Pondemergency
Effluent
spillway
• Internal Outfalls
Channel to
Cooling
Stormwater
Pond
Internal Outfall 009
0 1000 2000 3000
Recirculating
Condenser
Feet
Outfall 001
Cooling Water
Release
CC Block
Internal Outfall 006
CC Block
Sutton Energy Internal Outfall 005
Complex
Attachment 1- Site Ma
NORTH CAROLINA
L. V. Sutton Energy Complex
New Hanover County
Al- 1

Duke Energy Progress, LLC. NPDES Permit NC00001422
.V. Sutton Electric Plant 2016 Permit Renewal Application
4DOutfal 1002
Old Ash
Outfall 008 Pond (1971)
Cooling Pond
Internal
Outfall 007
(approx) South Pond
emergency
spillway
Stormwater
infiltration pond
emergency
spillway
ISW-1
ISW-2 Internal
ISW-3 Outfall 009
.dam (approx)
�O
ISW-4 ISW-6
Recirculated
• Final (external) Outfalls Z
Outfall 001 cooling water
and IS
0W-5
• Internal Outfalls
Stormwater Internal Outfalls
005,006
Attachment 1- Site Ma
L. V. Sutton Energy Complex
New Hanover County
A1-2

1984 ASH
' P\. Al\1 ■
•,�. f' NOTES:
AERIAL PHOTOGRAPHY OBTAINED FROM USDA FSA NAIP, DATED 06112/2016.
PARCEL BOUNDARY WAS OBTAINED FROM THE NC CENTER FOR GEOGRAPHIC
.�... < INFORMATION AND ANALYSIS, AT (hltp://servicm.nconemap.govn
DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE
. PLANE COORDINATE SYSTEM FIPS 3200 (NAD83).
t
11
tiCt
l k
1
1-
1984 ASH
10
♦�i
4 zoo loo o zoo aoo FIGURE 1
LEGEND GRAPHIC SCALE IN FEET
REVISED WASTE AND
WASTE BOUNDARY 148 RIVER STREET, SUITE 220
GREENVILLE, SOUTH CAROLINA 29601 COMPLIANCE BOUNDARIES
PHONE [phone]
L__� COMPLIANCE BOUNDARY m L.V. SUTTON ENERGY COMPLEX
DUKE ENERGY SITE BOUNDARY synTerra DRAWNBBr:P.IGL DATE:.7/20/2017 WILMINGTON NORTH CAROLINA
CHECHED BY: P. WALDREP �
PROJECT MANAGER: P. WALDREP

Star -News
- -- S1A ItN h N'tiUN 1.1 N f XOM
1003 South 17th Street • Wilmington, NC 28401 • Classified ph: 910-343-2323 • Legal ads ph: 910-343-2342
Order:
W002560455
Pubs:
115
Rate:
L9
Phone:
[phone]
Class:
0001
Charges:
$ 0.00
Account:
N7335083
Start
08/16/2017
List Price:
$ 160.89
Name:
Thedford, Wren
Stop
08/16/2017
Pay-
$ 0.00
Caller:
Wren/email/kjy
Inser-
2
Balance:
$ 160.89
Taken By:
43
Columns:
1
Lines:
62
Schedule:
8/16 lx, 8/16 lx, , ,
Taken On:
08/11/2017
PUBLI NOTIC
N.C. DEPARTMENT OF
ENVIRONMENTAL QUALITY INTENT
TO ISSUE NPDES WASTEWATER
DISCHARGE PERMIT *NC0001422
Public comment or objection to the
draft permit modification is invited.
All comments received by Septem-
ber 18, 2017 will be considered in
the final determination regarding
permit issuance and permit provi-
sions.
PERMIT APPLICATION
Duke Energy Progress, LLC, 526
South Church St., Charlotte, N.C.,
has applied for renewal of its
NPDES wastewater permit
(NC0001422) for L.V. Sutton Energy
Complex, 801 Sutton Steam Plant
Rd., Wilmington, New Hanover
County. The facility discharges
treated industrial wastewater and
stormwater to Sutton Lake and
Cape Fear River in the Cape Fear
River basin. Some of the parame-
ters are water quality limited. This
discharge may affect future alloca-
tions in this portion of the Cape
Fear River basin.
The draft wastewater permit and
related documents are available
online at: https://goo.gi/3WtzMF.
Printed copies of the draftpermit
and related documents may be re-
viewed at the department's Wil-
mington Regional Office. To make
anappointment to review the
documents, please call 910-796-
7215.
Public comment on the draft permit
modification should be mailed to:
Wastewater Permitting, 1617 Mail
Service Center, Raleigh, N.C.,
27699-1617.
Public comments may also be sub-
mitted by email to:
[e-mail]
Please be sure to include "Sutton"
in the email's subject line.
Attention: Fax:
This is a final proof. If any information is incorrect, please contact your sales representative prior to the deadline of the first insertion. Oth-
erwise your order is accepted as having been approved.

Appendix B
Current Permit
RECOVEDINCDEQJOR
SEP 262017
Wase► `g $ection
perm►tt►n

WaterResources
ENVIRONMENTAL QUALITY
March 3, 2016
Mr. Harry Sideris, Senior Vice Piesident
Environmental, Health and Safety
Duke Energy Carolinas, LLC
Mail Code EC13K
P.O. Box 1006
Chailotte, North Carolina 28201-1006
Dear ML Sidens:
PAT MCCRORY
Govenio)
DONALD R. VAN DER VAART
Sec)etay
S JAY ZTMMERMAN
DL ecto)
Subject- Error Correction Letter
Permit No. NC0001422
L.V. Sutton Energy Complex
New Hanover County
On December 3, 2015, the Division of Water Resources issued Major Modification (NPDES
Permit No. NC0001422) for L.V. Sutton Energy Complex. It has been brought to our attention that
the Modification has several errors:
1) The schedule for 316b submission is incorrect, this error is the result of the EPA objection
to the 5 year expiration date for the Modification
2) The Sutton Lake classification is incorrect, it will be classified C-Sw This error is the result
of the recent re-classification of the Sutton Lake to the "waters of the State".
3) The Whole Effluent Toxicity Test for Sutton Lake is incotiect, it should be Acute. This
error is the result of the recent te-classification of the Sutton Lake to the "waters of the
State".
4) The instteam monitoring waives: was added to the permit. The waiver was omitted since
Monitoring Coalition did not confirm their commitment to the mote rigorous sampling
regime when the permit was issued.
Therefore, the Division made a correction to the appropriate pages in the Major Modification.
Please insert the enclosed coitected sheets and discard the old sheets. This permit modification
becomes effective on the effective date of the permit.
All other terms and conditions in the original permit remain unchanged and in full effect. These
modifications are issued pursuant to the iequitements of North Carolina General Statute 143-215.1
and the Memorandum of Agreement between Noith Carolina and the U.S. Environmental Protection
Agency dated December 6, 1983.
State of North Carolina I Environmental Quality I Water Resources
1617 Marl service Center I Raleigh, North Carolina 27699-1611
919 707 9000

If any parts, measurement fiequencies or sampling requirements contained in this modification
ate unacceptable to you, you have the .tight to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings, Post Office Drawer 11666, Raleigh, North Carolina 27604 Unless such
demand is made, this decision shall be final and binding. If you have any questions concerning this
permit, please contact Sergei Chernikov at telephone number [phone].
Sincerely,
ZS. Jay Zimmerman, P G.
�_,( Director, Division of Water Resources
Hardcopy Central Files
NPDES Files
Wrlrnmgton Regional Office, SWPS
E -copy. US EPA, Region IV
Aquatic Toxicology Unit
Carrie Ruhlman, WSS

Peimit NC0001422
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective Therefore, the exclusive authority to operate and discharge from this facility arises under
the permit conditions, requirements, terms, and provisions included herein
Duke Energy Progress, LLC is hereby authorized to:
Continue to discharge cooling water, low volume wastes, stormwater, and
treated wastewater from internal wastewater outfalls 005, 006, 007, and 009
to the Effluent Channel, and internal stormwater outfalls SW001, SW002,
SW003, SW004, SW005, SW006, and SWO07 to the Effluent Channel (the
Effluent Channel discharges via external Outfall 008 to the Sutton Lake); ash
pond discharge, groundwater, treated wastewater, and stormwater runoff
(Outfall 001, Outfall 002 and Outfall 004), at a facility located at Sutton Steam
Electric Plant, 801 Sutton Steam Plant Road, Wilmington, New Hanover
County, and
2. Discharge wastewater (via Outfall 002, Outfall 004, and Outfall 008) from said
treatment works at the locations specified on the attached map into the Sutton
Lake which is classified C -Swamp waters in the Cape Fear River Basin.
3. Discharge wastewater and groundwater (via Outfall 001) from said treatment
works at the location specified on the attached map into the Cape Fear River,
classified C -Swamp waters in the Cape Fear River Basin.
Page 2 of 19

Permit NC0001422
Part I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 001 -
normal operation)? [15A NCAC 02B .0400 et seq , 02B 0500 et seq
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to the Cape Fear River from Outfall 001 - removing the free
water above the settled ash layer that does not involve mechanical disturbance of the ash
(recirculation cooling water, non -contact cooling water, and treated wastewater from outfalls
002, and 004) Such discharges shall be limited and monitored6 by the Permittee as specified
below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
onthly
::Average
Sample
Daily Measureme=�T;yp
Maximum FrequencyLocations
Flow, MGD
Daily
Estimate or
um logs
Effluent
Tem eraturei,2, OC
Tem erature2, OC
Quarterly
Daily
Grab
Grab
U, D
Effluent
H
6 0s
H s 9 0
Weeks
Grab
Effluent
Oil and Grease
15 0 m L
20 0 mg/L
WeekIV
Grab
Effluent
Total Suspended Solids,
mg/L
30 0 mg/L
100 0 mg/L
Weekly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , mg/L
Weekly
Grab
Effluent
Total Phosphorus, mg/L
Weekly
Grab
Effluent
Dissolved O gen, mg/L
Weekly
Grab
Effluent
Acute Toxicity3
Monthly
Grab
Effluent
Total Mercury4
47 0 ng/L
47 0 n L
Weekly
Grab
Effluent
Total Arsenic
10.0 pg/L
50 0 µ L
Weekly
Grab
Effluent
Total Selenium
5,0 µg/L
56 0 pg/L
Weekly
Grab
Effluent
Total Iron
1 0 mg/L
1.0 mg/L
Weekly
Grab
Effluent
Total Lead
25 0 µg L
33 8 µg L
Weekly
Grab
Effluent
Total Cadmium
2 0µg L
15 0 µg L
Weekly
Grab
Effluent
Total Aluminum
Weekly
Grab
Effluent
Total Copper, jig/L
Weekly
Grab
Effluent
Total Zinc, lig/L
Weekly
Grab
Effluent
Turbidity -5
Weekly
Grab
Effluent
Notes•
1. U: Upstream, 2700 feet above outfall D Downstream, 1 25 miles below outfall Instream
monitoring is provisionally waived in light of the permittee's participation in the Lower
Cape Fear River Basin Association. Instream monitoring shall be conducted as stated in
this permit should the permittee end its participation in the Association.
2 The receiving water's temperature shall not be increased by more than 2 8°C above ambient
water temperature and in no case exceed 32°C, except in the mixing zone described as follows -
Extending from the eastern shore to the centerline of the river and extending not more than
1 25 miles downstream nor more than 2700 feet from the point of discharge The cross-
sectional area of the mixing zone shall not exceed 9% of the total cross sectional area of the river
at the point of discharge nor 2 5% at the mouth of Toomer's Creek.
3. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%), Part I, Condition A. (10.).
4 The facility shall use EPA method 1631E
5 The discharge from this facility shall not cause turbidity in the receiving stream to exceed 50
NTU If the instream turbidity exceeds 50 NTU due to natural background conditions, the
discharge cannot cause turbidity to increase in the receiving stream
6. No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system, See Special
Condition A. (23 )
Page 3 of 21

Permit NC0001422
7 The drawdown rate shall not exceed 1 foot/week to maintain the integrity of the dams, unless
approved by the DEQ Dam Safety Program
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 4 of 21

Permit NC0001422
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
001 -dewatering phase)8 [15A NCAC 02B 0400 et seq., 02B 0500 et seq ]
During the period beginning on the commencement date of the dewatermg operation and lasting
until expiration, the Permittee is authorized to discharge to the Cape Fear River from Outfall 001
Dewatering -removing the interstitial water/ash pore water (recirculation cooling water, non -
contact cooling water, and treated wastewater from outfalls 002, and 004) Such discharges
shall be limited and monitored6 by the Permittee as specified below
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement Sample Sample
Fre uency Type Location'
Flow
2 1 MGD
(applies only to ash
pond discharge)
Daily
Estimate
or pump
logs
Effluent
Temperature',2, OC
Quarterly
Grab
U, D
Temperature2, OC
Daily
Grab
Effluent
H
6 0<
H < 9,0
Daily
Daily
Effluent
Oil and Grease
15 0 in L
20 0 m L
Weekly
Grab
Effluent
Total Suspended Solids
mg L7
30 0 mg/L
100.0 mg/L
Weekly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , mg/L
Weekly
Grab
Effluent
Total Phosphorus, m L
Weekly
Grab
Effluent
Dissolved Oxygen, mg/L
Weekly
Grab
Effluent
Acute TomCjt 3
Monthly
Grab
Effluent
Total Iron
1 0 m L
1 0 m L
Weekly
Grab
Effluent
Total Cadmium
2 0 µ L
15 0 µ L
Weekly
Grab
Effluent
Total Aluminum
Weekly
Grab
Effluent
Total Lead
25.0 pg L
33 8 µ L
Weekly
Grab
Effluent
Total Arsenic
10 0 pg/L
50 0 pg/L
Weekly
Grab 4
Effluent
Total Selenium
5.0 pg/L
56 0 pg/L
Weekly
Grab
Effluent
Total Mercu 4
47 0 ng/L
47 0 n L
Week1V
Grab
Effluent
Total Copper, µ L
Weekly
Grab
Effluent
Total Zinc, µ L
Weekly
Grab
Effluent
Turbidity,9
Weekly
Grab
Effluent
Notes:
1 U Upstream, 2700 feet above outfall D- Downstream, 1 25 miles below outfall Instream
monitoring is provisionally waived in light of the permittee's participation in the Lower
Cape Fear River Basin Association. Instream monitoring shall be conducted as stated in
this permit should the permittee end its participation in the Association.
2 The receiving water's temperature shall not be increased by more than 2.8°C above ambient
water temperature and in no case exceed 32°C, except in the mixing zone described as follows -
Extending from the eastern shore to the centerline of the river and extending not more than
1 25 miles downstream nor more than 2700 feet from the point of discharge The cross-
sectional area of the mixing zone shall not exceed 9% of the total cross sectional area of the river
at the point of discharge nor 2.5% at the mouth of Toomer's Creek
3 Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%), Part I, Condition A (10 )
4 The facility shall use EPA method 1631E
5 The discharge from this facility shall not cause turbidity in the receiving stream to exceed 50
NTU If the Instream turbidity exceeds 50 NTU due to natural background conditions, the
discharge cannot cause turbidity to increase in the receiving stream
6. No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system See Special
Condition A. (23.).
7 The facility shall continuously monitor TSS concentration and the dewatering pump shall be
shutoff automatically when the limits are exceeded
Page 5 of 21

Pemit N00001422
8. The drawdown rate shall not exceed 1 foot/week to maintain the integrity of the dams, unless
approved by the DEQ Dam Safety Program.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 6 of 21

Permit NC0001422
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
002 -normal operation)4, s
[15A NCAC 02B .0400 et seq , 02B .0500 et seq ]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to Sutton Lake and/or to the 1971 ash pond from Outfall 002 -
removing of free water above the settled ash layer that does not involve mechanical disturbance of
the ash (Old Ash Pond - coal pile runoff, low volume wastes, ash sluice water, and stormwater
runoff). Such discharges to Sutton Lake shall be limited and monitored3 by the Permittee as specified
below -
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement Sample
Frequency Type
Sample Location
Flow, MGD
Weekly
Pump Logs
or similar
Effluent
Oil and Grease
15 0 mg/L
20 0 mg/L
Weekly
Grab
Effluent
Total Suspended
Solids
30 0 mg/L
100 0 mg/L
Weekly
Grab
Effluent
H
6 0 <_ pHs
9 0
Weekly
Grab
Effluent
Total Copper, pg/L
Weekly
Grab
Effluent
Total Zinc, pg/L
Weekly
Grab
Effluent
Total Arsenic
10 0 µg/L
50 0µg/l,
Weekly
Grab
Effluent
Total Selenium
5 0 µg/L
56 0 µg/L
Weekly
Grab
Effluent
Total Mercury
47 0 ng/L
47 0 ng/L
Weekly
Grab
Effluent
Total Iron
1 0 m L
1 0 mg/L
Weekly
Grab
Effluent
Total Aluminum
Weekly
Grab
Effluent
Acute Toxicity 2
Quarterly
Grab
Effluent
imoTes:
1. The facility shall use EPA method 1631E
2 Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%), Part I, Condition A. (21 )
3. No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system See Special
Condition A (23 )
4 The facility shall submit EPA Form 2C for Outfall 002 as soon as practicable, but no later than
180 days from the effective date of this permit
5 The drawdown rate shall not exceed 1 foot/week to maintain the integrity of the dams, unless
approved by the DEQ Dam Safety Program
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 7 of 21

Permit NC0001422
A. (4.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
004 -normal operation)4, s
[15A NCAC 02B 0400 et seq , 02B 0500 et seq ]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to Sutton Lake and/or to Outfall 001 from Outfall 004 -
removing of free water above the settled ash layer that does not involve mechanical disturbance of
the ash (New Ash Pond - ash sluice water, coal pile runoff, low volume wastes, and stormwater
runoff) Such discharges to Sutton Lake shall be limited and monitored3 by the Permittee as specified
below
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement Sample Sample
Frequency Tye Location
Flow, MGD
Weekly
Pump Logs
or similar
Effluent
Oil and Grease
15.0 mg/L-
20 0 mg/L
Weekly
Grab
Effluent
Total Suspended
Solids
30 0 mg/L
100 0 mg/L
Weekly
Grab
Effluent
H
6 0:- pH < 9 0
Weekly
Grab
Effluent
Total Copper, pg/L
Weekly
Grab
Effluent
Total Zinc,µ L
Weekly
Grab
Effluent
Total Arsenic
10 0 pg/L
50 0 µ L
Weekly
Grab
Effluent
Total Selenium
5 0 pg/L
56 0 µ L
Weekly
Grab
Effluent
Total Mercury 1
47 0 ng/L
47 0 ng/L
Weekly
Grab
Effluent
Total Iron
1 0 m L
1.0 m L
Weekly
Grab
Effluent
Total Aluminum
Weekly
Grab
Effluent
Acute Toxicity 2
Quarterly
Grab
Effluent
Notes:
1 The facility shall use EPA method 1631E.
2 Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%), Part I, Condition A, (21).
3 No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system. See Special
Condition A, (23 ).
4 The facility shall submit EPA Form 2C for Outfall 004 as soon as practicable, but no later than
180 days from the effective date of this permit
5 The drawdown rate shall not exceed 1 foot/week to maintain the integrity of the dams, unless
approved by the DEQ Dam Safety Program
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 8 of 21

Permit NC0001422
A. (9.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
008)5,7
[15A NCAC 02B 0400 et seq , 02B 0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to Sutton Lake from Outfall 008 (from internal wastewater
outfalls 005, 006, 007, and 009, and internal stormwater outfalls SWO01 through SW007)
Such discharges shall be limited and monitored6 by the Permittee ass ecified below,
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement Sample
Fre uenc a
Sample
Location'
Flow, MGD
Daily
Estimate
or pump
logs
Effluent
Temperature OC
Daily
Grab
Effluent
Temperature 1,2, OC
Daily/Weekly Daily/Weekly
Grab
Instream
Oil and Grease
15 0 mg/L
20 0 mg/L
Month'
Grab
Effluent
Total Suspended Solids
30 0 mg/L
100 0 m L
Monthly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , mg/L
Monthly
Grab
Effluent
Dissolved Oxygen, mg/L
Monthly
Grab
Effluent
pH
6 0 s Hs 9 0
Daily
Grab
Effluent
Total Phosphorus, mg/L
Monthly
Grab
Effluent
Acute Toxicity3
Quarterly
Grab
Effluent
Total Mercury4, ng/L
Quarterly
Grab
Effluent
Total Arsenic, µ L
Quarterly
Grab
Effluent
Total Selenium, pg/L
Quarterly
Grab
Effluent
Total Copper, AL
Quarterly
Grab
Effluent
Total Zinc, pg/L
Quarterly
Grab
Effluent
Notes:
1. Instream- 1000 feet from outfall The facility is allowed 12 months from the effective date of
the permit to begin daily mstream temperature monitoring The time is allowed for the
facility to budget, design, and install the automatic monitoring station In the interum, the
instream temperature monitoring shall be conducted on a weekly basis.
2 The receiving water's temperature shall not be increased by more than 2 8'C above ambient
water temperature and in no case exceed 32°C The limit is not being implemented until
further notice (Please see A. (26 ))
3. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%), Part I, Condition A (21 )
4 The facility shall use EPA method 1631E.
5 The facility shall install a screen or a barrier at the end of the Effluent Channel to minimize
fish migration into the Channel The design of the screen/barrier shall be submitted to the
Division for approval no later than 6 month from the effective date of the permit. The
screen/ barrier shall be installed no later than 6 months after Division approval.
6 No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system See Special
Condition A (23 )
7 The facility shall submit EPA Form 2C for Outfall 008 as soon as practicable, but no later
than 180 days from the effective date of this permit
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 11 of 21

Permit NC0001422
and III of Appendix D to 40 CFR, Part 122, and shall maintain the Plan at the plant site and shall
be available for inspection by EPA and DWR personnel
A. (14.) INTAKE SCREEN BACKWASH
Continued intake screen backwash discharge is permitted without limitations or monitoring
requirements.
A. (15.) NO DISCHARGE OF PCBs
As specified by 40 CFR 423.13 (a), there shall be no discharge of polychlorinated biphenyl
compounds such as those commonly used for transformer fluid.
A. (16.) BIOCIDE CONDITION
The permittee shall not use any biocides except those approved in conjunction with the permit
application. The permittee shall notify the Director in writing not later than ninety (90) days prior
to instituting use of any additional biocide used in cooling systems which may be toxic to aquatic
life other than those previously reported to the Division of Water Resources. Such notification shall
include completion of Biocide Worksheet Form 101 and a map locating the discharge point and
receiving stream. Completion of a Biocide Worksheet 101 is not necessary for the introduction of a
new biocide into an outfall currently being tested for toxicity.
A. (17.) FISH TISSUE MONITORING NEAR ASH POND DISCHARGE - OUTFALL
001, and OUTFALLS 002/004
The facility shall conduct fish tissue monitoring at two locations (Sutton Lake and Cape Fear River)
annually and submit the results with the NPDES permit renewal application. The objective of the
monitoring is to evaluate potential uptake of pollutants by fish tissue near the Ash Pond discharge.
The parameters analyzed in fish tissue shall be arsenic, selenium, and mercury. The monitoring shall
be conducted in accordance with the Sampling Plan approved by the Division After the plan is
approved by the Division, it will become an enforceable part of the permit
A. (18.) CLEAN WATER ACT SECTION 316(B)
The permittee shall comply with the Cooling Water Intake Structure Rule per 40 CFR 125 95. The
permittee shall submit all the materials required by the Rule with the renewal application
submitted after July 14, 2018.
A. (19.) ASH POND CLOSURE
The facility shall prepare an Ash Ponds Closure Plan in anticipation of the ash pond closure. This
Plan shall be submitted to the Division one month prior to the closure of the ash ponds
A. (20.) LOWER CAPE FEAR MODELING
The permittee may elect to conduct a water quality model of the dilution factor for Outfall 001.
Contingent upon EPA approval of the Lower Cape Fear Modeling and its results, the Reasonable
Potential Analysis will be conducted again and the permit limits will be based on the new flow
numbers established by the model
A. (21.) ACUTE TOXICITY LIMIT (QUARTERLY) - OUTFALLS 002, 004, 008
[15A NCAC 02B .0200 et seq.]
The permittee shall conduct acute toxicity tests on a quarter lr� basis using protocols defined in the
North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute
Toxicity In A Single Effluent Concentration" (Revised -July, 1992 or subsequent versions). The
monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24 hour static test. The
effluent concentration at which there may be at no time significant acute mortality is 90% (defined
as treatment two in the procedure document) Effluent samples for self-monitoring purposes must
be obtained during representative effluent discharge below all waste treatment.
Page 13 of 21

Permit NC0001422
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR -1) for the month in which it was performed, using the parameter
code TGE6C Additionally, DWR Form AT -2 (original) is to be sent to the following address-
Attention- North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1623 Mail Service Center
Raleigh, North Carolina 27699-1623
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than
30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/ physical
measurements performed in association with the toxicity tests, as well as all dose/response data.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT)
test form indicating the facility name, permit number, pipe number, county, and the month/year of
the report with the notation of "No Flow" in the comment area of the form. The report shall be
submitted to the Water Sciences Section at the address cited above.
Should any test data from either these monitoring requirements or tests performed by the North
Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit
may be re -opened and modified to include alternate monitoring requirements or limits
NOTE Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
A. (22.) INSTREAM MONITORING
The facility shall conduct semiannual instream monitoring (1000 ft. upstream and 1000 ft.
downstream of the Outfall 001, and 1000 ft from Outfall 004) for total arsenic, total selenium,
total mercury (method 1631E), total chromium, total lead, total cadmium, total copper, and total
zinc. The monitoring results shall be submitted with the NPDES permit renewal application
Instream monitoring is provisionally waived in light of the permittee's participation in the
Lower Cape Fear River Basin Association. Instream monitoring shall be conducted as stated
In this permit should the permittee end its participation in the Association.
A. (23.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
(STATE ENFORCEABLE ONLY) [G. S. 143-215.1(b)]
Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs)
and specify that, if a state does not establish a system to receive such submittals, then permittees
must submit DMRs electronically to the Environmental Protection Agency (EPA). The Division
anticipates that these regulations will be adopted and is beginning implementation in late 2013
NOTE- This special condition supplements or supersedes the following sections within Part II of
this permit (Standard Conditions for NPDES Permits)
• Section B (11 ) Signatory Requirements
• Section D (2.) Reporting
Page 14 of 21

WaterResources
ENVIRONMENTAL QUALITY
December 3, 2015
Mr. Harry Sideris, Senior Vice President
Environmental, Health and Safety
Duke Energy Carolinas, LLC
Mail Code EC13K
P.O. Box 1006
Charlotte, North Carolina 28201-1006
0 Dear Mr. Sideris:
PAT MCCRORY
Goveraa
DONALD R, VAN DER VAART
Secielaty
S JAY ZIMMERMAN
Subject: Issuance of NPDES
Major Modification
Permit NC0004961
L.V. Sutton Energy Complex
New Hanover County
Facility Class I
DL eclor
The Division of Water Resources is forwarding herewith the Final NPDES permit for
Riverbend Steam Station. This permit renewal is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between North Carolina and the U.S. Environmental Protection Agency
dated October 15, 2007 (or as subsequently amended)
A public hearing was held on August 6, 2015 in Wilmington seeking comments on
the Draft permit. This Final permit incorporates recommendations of the DWR
Hearing Officer and EPA as well as other changes:
1) The limits for Oil and Grease and TSS were added to Outfall 001.
2) The monitoring frequency for all parameters In the effluent was increased to
Weekly (Outfall 001 - normal operation), with an exception of Whole Effluent
Toxicity.
3) The transfer of wastewater from Old Ash Pond to New Ash Pond and Outfall 001
was authorized.
4) The requirements to minimize fish migration up the Effluent Channel were
modified (Outfall 008).
5) The Total Aluminum limits were removed from Outfall 001, Outfall 002, and
Outfall 004 since North Carolina does not have Al standard and approximately
89% of the surface water samples in the state exceeds the EPA recommended
criteria of 87 µg/L.
6) The requirement to limit drawdown rate to 1 foot/week (unless approved by
DEQ) were added to Outfall 001, Outfall 002, and Outfall 004.
7) The groundwater was added to the list of the waste streams discharged through
Outfall 001.
State of North Carolina I Environmental Quality I Water Resources
1617 Mail service Center I Raleigh, North Carohna 27699-1611
919 707 9000

8) The following requirement was added to Outfall 002, Outfall 004, and Outfall
008: The facility shall submit EPA Form 2C as soon as practicable, but no later
than 180 days from the effective date of this permit.
9) The Technology Based Effluent Limits for Total Arsenic, Total Selenium, and
Total Mercury were eliminated (Outfall 001, Outfall 002, and Outfall 004) to
meet the updated requirement in 40 CFR 423.
If any parts, measurement frequencies, or sampling requirements contained in this
permit are unacceptable to you, you have the right to an adjudicatory hearing upon
written request within thirty (30) days following receipt of this letter. This request must
be in the form of a written petition, conforming to Chapter 150B of the North Carolina
General Statutes, and filed with the office of Administrative Hearings, 6714 Mail Service
Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this
permit shall be final and binding.
Please take notice that this permit is not transferable except after notice to the Division
of Water Resources. The Division may require modification or revocation and reissuance
of the permit. This permit does not affect the legal requirements to obtain other permits
which may be required by the Division of Water Resources, the Division of Land
Resources, the Coastal Area Management Act, or any other federal or local governmental
permit.
If you have any questions on this permit, please contact Sergei Chernikov at 919-807-
6386.
SrncerelAD',V,7
ean, P.G.
,n of Water Resources
Hardcopy- Central Files,
NPDES Files
Wilmington Regional Office, Water Quality
NPDES files
E -copy: US EPA, Region IV
Aquatic Toxicology Unit

Peimit NC0001422
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Water Quality
Commission, and the Federal Water Pollution Control Act, as amended,
Duke Energy Progress, LLC
is hereby authorized to discharge wastewater from a facility located at the
L. V. Sutton Energy Complex
801 Sutton Steam Plant Road, Wilmington
New Hanover County
to receiving waters designated as the Cape Fear River and Sutton Lake in the Cape Fear
River Basin in accordance with the discharge limitations, monitoring requirements, and
other applicable conditions set forth in Parts I, II, III, and Appendix A.
This permit modification shall become effective December 7, 2015.
This permit and the authorization to discharge shall expire at 27lldnight on December 31,
2016.
Signed this day December 3, 2015.
S. ay Z' merman P.G., Director
Divis o4,6f Water Resources
By the Authority of the Environmental Management Commission
Page 1 of 19

Permit NC0001422
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under
the permit conditions, requirements, terms, and provisions included herein.
Duke Energy Progress, LLC is hereby authorized to:
Continue to discharge cooling water, low volume wastes, stormwater, and
treated wastewater from internal wastewater outfalls 005, 006, 007, and 009
to the Effluent Channel, and internal stormwater outfalls SW001, SW002,
SW003, SW004, SW005, SW006, and SWO07 to the Effluent Channel (the
Effluent Channel discharges via external Outfall 008 to the Sutton Lake); ash
pond discharge, groundwater, treated wastewater, and stormwater runoff
(Outfall 001, Outfall 002 and Outfall 004); at a facility located at Sutton Steam
Electric Plant, 801 Sutton Steam Plant Road, Wilmington, New Hanover
County, and
2. Discharge wastewater (via Outfall 002, Outfall 004, and Outfall 008) from said
treatment works at the locations specified on the attached map into the Sutton
Lake which is classified C waters in the Cape Fear River Basin.
3. Discharge wastewater and groundwater (via Outfall 001) from said treatment
works at the location specified on the attached map into the Cape Fear River,
classified C -Swamp waters in the Cape Fear River Basin.
Page 2 of 19

Permit NC0001422
Part I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 001 -
normal operation)? [15A NCAC 02B 0400 et seq , 02B 0500 et seq
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to the Cape Fear River from Outfall 001 - removing the free
water above the settled ash layer that does not involve mechanical disturbance of the ash
(recirculation cooling water, non -contact cooling water, and treated wastewater from outfalls
002, and 004) Such discharges shall be limited and monitored6 by the Permittee as specified
below.
EFFLUENT
CHARACTERISTICS
LIMITS
Monthly Daily
Average Maximum
MONITORING REQUIREMENTS
Measurement Sample Sample
Fre uency Type Location'
Flow, MGD
Daily
Estimate or
pump logs
Effluent
Temperaturel•2, OC
Quarterly
Grab
U, D
Temperature2, OC
Daily
Grab
Effluent
H
6 0s pH <_ 9.0
Weekly
Grab
Effluent
Oil and Grease
15 0 mg/L
20 0 mg/L
Weekly
Grab
Effluent
Total Suspended Solids,
mg/L
30 0 mg/L
100 0 mg/L
Weekly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , mg/L
Weekly
Grab
Effluent
Total Phosphorus, mg/L
Weekly
Grab
Effluent
Dissolved Oxygen, mg/L
Weekly
Grab
Effluent
Acute Toxicity3
Monthly
Grab
Effluent
Total Mercury¢
47.0 n L
47 0 n L
Weekly
Grab
Effluent
Total Arsenic
10.0 µg L
50 0 µ L
Weekly
Grab
Effluent
Total Selenium
5 0 µg/L
56.0 µg/L
Weekly
Grab
Effluent
Total Iron
1 0 m L
1 0 mg L
Weekly
Grab
Effluent
Total Lead
25 0 µ L
33 8 µg L
Weekly
Grab
Effluent
Total Cadmium
2 0 µ L
15 0 µ L
Weekly
Grab
Effluent
Total Aluminum
Weekly
Grab
Effluent
Total Copper, lig/L
Weekly
Grab
Effluent
Total Zinc, L
Weekly
Grab
Effluent
Turbiditys
Weekly
Grab
Effluent
Notes:
1. U• Upstream, 2700 feet above outfall D. Downstream, 1 25 miles below outfall
2. The receiving water's temperature shall not be increased by more than 2.8°C above ambient
water temperature and in no case exceed 32°C, except in the mining zone described as follows
Extending from the eastern shore to the centerlme of the river and extending not more than
1 25 miles downstream nor more than 2700 feet from the point of discharge The cross-
sectional area of the mixing zone shall not exceed 9% of the total cross sectional area of the river
at the point of discharge nor 2 5% at the mouth of Toomer's Creek
3 Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%), Part I, Condition A, (10 )
4 The facility shall use EPA method 1631E.
5. The discharge from this facility shall not cause turbidity in the receiving stream to exceed 50
NTU If the instream turbidity exceeds 50 NTU due to natural background conditions, the
discharge cannot cause turbidity to increase in the receiving stream.
6 No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system See Special
Condition A, (23 ).
7. The drawdown rate shall not exceed 1 foot/week to maintain the integrity of the dams, unless
approved by the DEQ Dam Safety Program
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 3 of 19

Peimit NC0001422
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
001 -dewatering phase)$ [15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the commencement date of the dewatering operation and lasting
until expiration, the Permittee is authorized to discharge to the Cape Fear River from Outfall 001
Dewatering -removing the interstitial water/ash pore water (recirculation cooling water, non -
contact cooling water, and treated wastewater from outfalls 002, and 004) Such discharges
shall be limited and monitored6 by the Permittee as specified below,
EFFLUENT -
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement Sample Sample
Frequency TVDe Location'
Flow
2.1 MGD
(applies only to ash
pond discharge)
Daily
Estimate
or pump
logs
Effluent
Tem eraturei,2, OC
Quarterly
Grab
U, D
Tem erature2, OC
Daily
Grab
Effluent
H
6 0 _<
H s 9 0
Daily
Daily
Effluent
Oil and Grease
15.0 m L
20 0 m L
Weekly
Grab
Effluent
Total Suspended Solids
mg L7
30.0 mg/L
100 0 mg/L
Weekly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , m L
Weekly
Grab
Effluent
Total Phosphorus, m L
Weekly
Grab
Effluent
Dissolved Oxygen, m L
Weekly
Grab
Effluent
Acute ToxiCity3
Monthly
Grab
Effluent
Total Iron
10 m L
1 0 m L
Weekly
Grab
Effluent
Total Cadmium
2.0 µ L
15.0 µ L
Weekly
Grab
Effluent
Total Aluminum
Weekly
Grab
Effluent
Total Lead
25 0 pg
33.8 µg L
Weekly
Grab
Effluent
Total Arsenic
10 0 µ L
50 0 pg/L
Weekly
Grab
Effluent
Total Selenium
5 0 µ L
56.0 pg/L
Weekly
Grab
Effluent
Total Mercury4
47,0 n L
47.0 ng/L
Weekly
Grab
Effluent
Total Copper, pg/L
Weekly
Grab
Effluent
Total Zinc, pg/L
JWeekly
Grab
Effluent
Turbiditys
IWeekly
Grab
Effluent
Notes:
1 U• Upstream, 2700 feet above outfall. D: Downstream, 1.25 miles below outfall
2. The receiving water's temperature shall not be increased by more than 2 8°C above ambient
water temperature and in no case exceed 32°C, except in the mixing zone described as follows:
Extending from the eastern shore to the centerline of the river and extending not more than
1 25 miles downstream nor more than 2700 feet from the point of discharge The cross-
sectional area of the mixing zone shall not exceed 9% of the total cross sectional area of the river
at the point of discharge nor 2.5% at the mouth of Toomer's Creek.
3. Acute Toxicity Limit (Fathead Minnow, 24 hour at 90%); Part I, Condition A (10.).
4 The facility shall use EPA method 1631E
5. The discharge from this facility shall not cause turbidity in the receiving stream to exceed 5C
NTU. If the instream turbidity exceeds 50 NTU due to natural background conditions, the
discharge cannot cause turbidity to increase in the receiving stream.
6 No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system. See Special
Condition A (23.).
7 The facility shall continuously monitor TSS concentration and the dewatering pump shall be
shutoff automatically when the limits are exceeded
8. The drawdown rate shall not exceed 1 foot/week to maintain the integrity of the dams, unless
approved by the DEQ Dam Safety Program.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 4 of 19

Peimit NC0001422
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
002 -normal operation)4, 5
[15A NCAC 02B .0400 et seq , 02B 0500 et seq ]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to Sutton Lake and/or to the 1971 ash pond from Outfall 002 -
removing of free water above the settled ash layer that does not involve mechanical disturbance of
the ash (Old Ash Pond - coal pile runoff, low volume wastes, ash sluice water, and stormwater
runoff). Such discharges to Sutton Lake shall be limited and momtored3 by the Permittee as specified
below
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement Sample Sample Location
Frequency Type
Flow, MGD
Weekly
Pump Logs
or similar
Effluent
Oil and Grease
15.0 mg/L
20 0 mg/L
Weekly
Grab
Effluent
Total Suspended
Solids
30 0 mg/L
100 0 mg/L
Weekly
Grab
Effluent
H
6 0 s pHs
9 0
Weekly
Grab
Effluent
Total Copper, µ L
Weekly
Grab
Effluent
Total Zinc, pg/L
Weekly
Grab
Effluent
Total Arsenic
10.0 µg/L
50.0 µg/L
Weekly
Grab
Effluent
Total Selenium
5 0 µg/L
56.0 µg/L
Weekly
Grab
Effluent
Total Mercury
47 0 ng/L
47.0 ng/L
Weekly
Grab
Effluent
Total Iron
1 0 mg/L
1 0 mg/L
Weekly
Grab
Effluent
Total Aluminum
Weekly
Grab
Effluent
Chronic Toxicity 2
Quarterly
Grab
Effluent
Notes:
1. The facility shall use EPA method 1631E.
2 Chronic Toxicity Limit (Cenodaphnia dubia at 90%); Part I, Condition A. (21 )
3 No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system, See Special
Condition A. (23 )
4 The facility shall submit EPA Form 2C for Outfall 002 as soon as practicable, but no later than
180 days from the effective date of this permit.
5 The drawdown rate shall not exceed 1 foot/week to maintain the integrity of the dams, unless
approved by the DEQ Dam Safety Program
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 5 of 19

Permit NC0001422
A. (4.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
004 -normal operation)4, 5
[15A NCAC 02B 0400 et seq , 02B .0500 et seq ]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to Sutton Lake and/or to Outfall 001 from Outfall 004 -
removing of free water above the settled ash layer that does not involve mechanical disturbance of
the ash (New Ash Pond — ash sluice water, coal pile runoff, low volume wastes, and stormwater
runoff). Such discharges to Sutton Lake shall be limited and monitored3 by the Permittee as specified
below
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement Sample Sample
Frequency Type Location
Flow, MGD
Weekly
Pump Logs
or similar
Effluent
Oil and Grease
15.0 mg/L
20.0 mg/L
Weekly
Grab
Effluent
Total Suspended
Solids
30 0 mg/L
100 0 mg/L
Weekly
Grab
Effluent
pH
6 0< pH s 9.0
Weekly
Grab
Effluent
Total Copper, µ L
Weekly
Grab
Effluent
Total Zinc, µ L
Weekly
Grab
Effluent
Total Arsenic
10 0 pg/L
50 0 pg/L
Weekly
Grab
Effluent
Total Selenium
5 0 pg/L
56 0 pg/L
Weekly
Grab
Effluent
Total Mercury
47.0 ng/L
47 0 ng/L
Weekly
Grab
Effluent
Total Iron
1 0 mg/L
1.0 m L
Weekly
Grab
Effluent
Total Aluminum
Weekly
Grab
Effluent
Chronic Toxicity 2
Quarterly
Grab
Effluent
Notes:
1. The facility shall use EPA method 1631E.
2 Chronic Toxicity Limit (Cenodaphnia dubia at 90%), Part I, Condition A (21),
3. No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system See Special
Condition A (23 )
4 The facility shall submit EPA Form 2C for Outfall 004 as soon as practicable, but no later than
180 days from the effective date of this permit
5 The drawdown rate shall not exceed 1 foot/week to maintain the integrity of the dams, unless
approved by the DEQ Dam Safety Program
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 6 of 19

Perrnit NC0001422
A. (5.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
005)
[15A NCAC 02B .0400 et seq., 02B 0500 et seq ]
Beginning with the commencement of this discharge and lasting until expiration, the Permittee is
authorized to discharge from Internal Outfall 005 (Combined Cycle Plant - ultrafilter water
treatment system filter backwash, closed cooling water cooler blowdown, Reverse
Osmosis/Electrodeionization system reject wastewater, and other low volume wastewater) to
the Effluent Channel Such discharges shall be limited and monitored' by the Permittee as
specified below -
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location
Flow, MGD
Daily
Pump Logs or
similar
Influent or
Effluent
Oil and Grease
15 0 mg/L
20.0 mg /L
2/Month
Grab
Effluent
Total Suspended Solids
30.0 mg/L
100 0 mg/L
2/Month
Grab
Effluent
pH
6 0 < pH < 9.0
2/Month
Grab
Effluent
Notes:
1. No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system See Special
Condition A (23 )
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (6.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
006)
[15A NCAC 02B 0400 et seq, 02B 0500 et seq.]
Beginning with the commencement of this discharge and lasting until expiration, the Permittee is
authorized to discharge from Internal Outfall 006 (Combined Cycle Plant - low volume
wastewater including the Heat Recovery Steam generator blowdown and auxiliary boiler
blowdown) to the Effluent Channel Such discharges shall be ]united and monitored' by the
Permittee as specified below.
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location
Flow, MGD
Daily
Pump Logs or
similar
Influentor
r
Oil and Grease
15 0 mg/L
20 0 mg/L
2/Month
Grab
Effluent
Total Suspended Solids
30 0 mg/L
100 0 mg/L
2/Month
Grab
Effluent
pH
6 0 < pH < 9.0
2/Month
Grab
Effluent
Notes:
1 No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system. See Special
Condition A. (23 )
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 7of19

Pennit NCO001422
A. (7.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
007)
[15A NCAC 02B .0400 et seq, 02B 0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from Internal Outfall 007 (stormwater flows from the closure
activities for coal-fired units, separate from stormwater outfalls SWO01 through SWO07) to the
Effluent Channel Such discharges shall be limited and monitored2 by the Permittee as specified
below:
EFFLUENT
LIMITS
MONITORING REQUIREMENTS
CHARACTERISTICS
Monthly
Daily
Measurement
Sample
Sample
Average
Maximum
Fre uency
Type
Location
Flow, MGD
or similar
Weekly
Pump Logs
Effluent
Grab
Effluent
Total Suspended
30.0 mg/L 100.0 mg/L
or similar
Grab
Oil and Grease
15 0 mg/L
20 0 mg/L
Monthly
Grab
Effluent
Total Suspended
30 0 mg/L
100 0 mg/L
Monthly
Grab
Effluent
Solids
Total Arsenic, µ L
Quarterly
Grab
Effluent
Total Selenium, µ L
Quarterly
Grab
Effluent
Nitrate/nitrite as N,
mg/L
Quarterly
Grab
Effluent
Total Mercury') ng/L
Quarterly
Grab
Effluent
Notes:
1. The facility shall use EPA method 1631E
2. No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system See Special
Condition A. (23 ).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (8.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
009 )
[15A NCAC 02B 0400 et seq, 02B 0500 et seq ]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from Internal Outfall 009 (low volume wastes from a new
simple cycle combustion turbine) to the Effluent Channel Such discharges shall be limited and
monitored' by the Permittee as specified below:
EFFLUENT
LIMITS
MONITORING REQUIREMENTS
CHARACTERISTICS
Monthly Daily
Average Maximum
Measurement
Frequency
Sample
Tye
Sample
Location
Flow, MGD
Weekly
Pump Logs
Effluent
or similar
Oil and Grease
15.0 m L 20 0 mg/L
Monthly
Grab
Effluent
Total Suspended
30.0 mg/L 100.0 mg/L
Monthly
Grab
Effluent
Solids
pH
6.0 < pH < 9.0
2/Month
Grab
Effluent
Notes:
1
No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system. See Special
Condition A (23 ).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 8 of 19

Pen -nit NC0001422
A. (9.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall
008)5,7
[15A NCAC 02B 0400 et seq , 02B 0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge to Sutton Lake from Outfall 008 (from internal wastewater
outfalls 005, 006, 007, and 009, and internal stormwater outfalls SWO01 through SW007)
Such discharges shall be limited and monitored6 by the Permittee- AS 1-1—,
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement Sample
Frequency a
Sample
Location'
Flow, MGD
Daily
Estimate
or pump
logs
Effluent
Temperature OC
Dail
Grab
Effluent
Temperature 1,2, OC
Dady/Weekly
Grab
Instream
Oil and Grease
15 0 m L
20 0 mg/L
Monthly
Grab
Effluent
Total Suspended Solids
30 0 m L
100 0 mg/L_
Monthly
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN , mg/L
Monthly
Grab
Effluent
Dissolved Oxygen, mg/L
Monthly
Grab
Effluent
pH
6 0 < pHs 9 0
Daily
Grab
Effluent
Total Phosphorus, mg/L
Monthly
Grab
Effluent
Chronic Toxiclty3
Quarterly
Grab
Effluent
Total Mercury4, n L
Quarterly
Grab
Effluent
Total Arsenic, µ L
Quarterly
Grab
Effluent
Total Selenium, µ L
Quarterly
Grab
Effluent
Total Copper, µ L
Quarterly
Grab
Effluent
Total Zinc, µ L
Quarterly
Grab
Effluent
lY O LC S"•
1 Instream 1000 feet from outfall. The facility is allowed 12 months from the effective date of
the permit to begin daily instream temperature monitoring The time is allowed for the
facility to budget, design, and install the automatic monitoring station. In the interim, the
instream temperature monitoring shall be conducted on a weekly basis
2 The receiving water's temperature shall not be increased by more than 2.8°C above ambient
water temperature and in no case exceed 32°C. The limit is not being implemented until
further notice (Please see A. (26.))
3 Chronic Toxicity Limit (Cenodaphnia dubia at 90%); Part I, Condition A (21 )
4 The facility shall use EPA method 1631E
5. The facility shall install a screen or a barrier at the end of the Effluent Channel to minimize
fish migration into the Channel. The design of the screen/barrier shall be submitted to the
Division for approval no later than 6 month from the effective date of the permit The
screen/barrier shall be installed no later than 6 months after Division approval
6. No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system See Special
Condition A (23 )
7 The facility shall submit EPA Form 2C for Outfall 008 as soon as practicable, but no later
than 180 days from the effective date of this permit.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 9 of 19

Permit NC0001422
A. (10.) ACUTE TOXICITY LIMIT (QUARTERLY)- OUTFALL 001
[15A NCAC 02B .0200 et seq.]
The permittee shall conduct acute toxicity tests on a monthlu basis using protocols defined in the
North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute
Toxicity In A Single Effluent Concentration" (Revised -July, 1992 or subsequent versions). The
monitoring shall be performed as a Fathead Minnow (1cmephales promelas) 24 hour static test The
effluent concentration at which there may be at no time significant acute mortality is 90% (defined
as treatment two in the procedure document) Effluent samples for self-monitoring purposes must
be obtained during representative effluent discharge below all waste treatment.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR -1) for the month in which it was performed, using the parameter
code TGE6C. Additionally, DWR Form AT -2 (original) is to be sent to the following address:
Attention. North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1623 Mail Service Center
Raleigh, North Carolina 27699-1623
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no
later than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/ physical
measurements performed in association with the toxicity tests, as well as all dose/response data
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfectson of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT)
test form indicating the facility name, permit number, pipe number, county, and the month/year of
the report with the notation of "No Flow" in the comment area of the form. The report shall be
submitted to the Environmental Sciences Section at the address cited above.
Should any test data from either these monitoring requirements or tests performed by the North
Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit
may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE, Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring,
A. (11.) GROUNDWATER MONITORING, WELL CONSTRUCTION, AND
SAMPLING
The permittee shall conduct groundwater monitoring to determine the compliance of this NPDES
permitted facility with the current groundwater Standards found under 15A NCAC 2L .0200. The
monitoring shall be conducted in accordance with the Sampling Plan approved by the Division.
A. (12.) STRUCTURAL INTEGRITY INSPECTIONS OF ASH POND DAMS
The facility shall meet the dam design and dam safety requirements per 15A NCAC 2K
A. (13.) BEST MANAGEMENT PRACTICES PLAN
The Permittee shall continue to implement a Best Management Practices (BMP) Plan to control the
discharge of oils and the hazardous and toxic substances listed in 40 CFR, Part 117 and Tables II
Page 10 of 19

Pelmit NC0001422
and III of Appendix D to 40 CFR, Part 122, and shall maintain the Plan at the plant site and shall
be available for inspection by EPA and DWR personnel.
A. (14.) INTAKE SCREEN BACKWASH
Continued intake screen backwash discharge is permitted without limitations or monitoring
requirements
A. (15.) NO DISCHARGE OF PCBs
As specified by 40 CFR 423 13 (a), there shall be no discharge of polychlorinated biphenyl
compounds such as those commonly used for transformer fluid
A. (16.) BIOCIDE CONDITION
The permittee shall not use any biocides except those approved in conjunction with the permit
application The permittee shall notify the Director in writing not later than ninety (90) days prior
to instituting use of any additional biocide used in cooling systems which may be toxic to aquatic
life other than those previously reported to the Division of Water Resources. Such notification shall
include completion of Biocide Worksheet Form 101 and a map locating the discharge point and
receiving stream. Completion of a Biocide Worksheet 101 is not necessary for the introduction of a
new biocide into an outfall currently being tested for toxicity.
A. (17.) FISH TISSUE MONITORING NEAR ASH POND DISCHARGE — OUTFALL
001, and OUTFALLS 002/004
The facility shall conduct fish tissue monitoring at two locations (Sutton Lake and Cape Fear River)
annually and submit the results with the NPDES permit renewal application. The objective of the
monitoring is to evaluate potential uptake of pollutants by fish tissue near the Ash Pond discharge
The parameters analyzed in fish tissue shall be arsenic, selenium, and mercury The monitoring shall
be conducted in accordance with the Sampling Plan approved by the Division After the plan is
approved by the Division, it will become an enforceable part of the permit.
A. (18.) CLEAN WATER ACT SECTION 316(B) `
The permittee shall comply with the Cooling Water Intake Structure Rule per 40 CFR 125.95 The
permittee shall submit all the materials required by the Rule with the next renewal
application.
A. (19.) ASH POND CLOSURE
The facility shall prepare an Ash Ponds Closure Plan in anticipation of the ash pond closure. This
Plan shall be submitted to the Division one month prior to the closure of the ash ponds
A. (20.) LOWER CAPE FEAR MODELING
The permittee may elect to conduct a water quality model of the dilution factor for Outfall 001,
Contingent upon EPA approval of the Lower Cape Fear Modeling and its results, the Reasonable
Potential Analysis will be conducted again and the permit limits will be based on the new flow
numbers established by the model
A. (21.) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY) — OUTFALLS
002, 004, 008
[15A NCAC 02B 0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to CeHodaphnia dubia at an effluent concentration of 90.0%.
The permit holder shall perform at a minimum, miarteriz� monitoring using test procedures outlined
in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010,
or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised- December 2010) or subsequent versions. The tests will be performed during the months
Page 11 of 19

Permit NC0001422
of February, May, August, and November. These months signify the first month of each three-
month toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be
obtained during representative effluent discharge and shall be performed at the NPDES permitted
final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or
ChV below the permit limit, then multiple -concentration testing shall be performed at a
minimum, in each of the two following months as described in "North Carolina Phase II
Chronic Whole Effluent Toxicity Test Procedure" (Revised -December 2010) or subsequent
versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR -1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally,
DWR Form AT -3 (original) is to be sent to the following address -
Attention North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1623 Mail Service Center
Raleigh, North Carolina 27699-1623
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than
30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/ physical measurements and
all concentration/response data, and be certified by laboratory supervisor and ORC or approved
designate signature Total residual chlorine of the effluent toxicity sample must be measured and
reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT)
test form indicating the facility name, permit number, pipe number, county, and the month/year of
the report with the notation of "No Flow" in the comment area of the form The report shall be
submitted to the Water Sciences Section at the address cited above
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Resources indicate potential impacts to the receiving stream, this permit may be
re -opened and modified to include alternate monitoring requirements or limits.
NOTE. Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival, minimum control organism reproduction, and appropriate environmental
controls, shall constitute an invalid test and will require immediate follow-up testing to be
completed no later than the last day of the month following the month of the initial monitoring
A. (22.) INSTREAM MONITORING
The facility shall conduct semiannual instream monitoring (1000 ft. upstream and 1000 ft
downstream of the Outfall 001, and 1000 ft from Outfall 004) for total arsenic, total selenium, total
mercury (method 1631E), total chromium, total lead, total cadmium, total copper, and total zinc. The
monitoring results shall be submitted with the NPDES permit renewal application
A. (23.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
(STATE ENFORCEABLE ONLY) [G S. 143-215.1(b)]
Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs)
and specify that, if a state does not establish a system to receive such submittals, then permittees
Page 12 of 19

Peine t NC0001422
must submit DMRs electronically to the Environmental Protection Agency (EPA) The Division
anticipates that these regulations will be adopted and is beginning implementation in late 2013
NOTE This special condition supplements or supersedes the following sections within Part II of
this permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.)
• Section D (6.)
• Section E (5 )
Reporting
Records Retention
Monitoring Reports
I. Reporting [Supersedes Section D. (2.) and Section E (5.) (a)]
Beginning no later than 270 days from the effective date of this permit, the permittee shall begin
reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge
Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month
and submitted electronically using eDMR The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet Until such time that the
state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation
(CROMERR), permittees will be required to submit all discharge monitoring data to the state
electronically using eDMR and will be required to complete the eDMR submission by printing,
signing, and submitting one signed original and a copy of the computer printed eDMR to the
following address.
NC DENR / DWR / Information Processing Unit
ATTENTION. Central Files / eDMR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the
facility being physically located in an area where less than 10 percent of the households have
broadband access, then a temporary waiver from the NPDES electronic reporting requirements
may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1,
1. 1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be
submitted to the mailing address above.
Requests for temporary waivers from the NPDES electronic reporting requirements must be
submitted in writing to the Division for written approval at least sixty (60) days prior to the date
the facility would be required under this permit to begin using eDMR Temporary waivers shall
be valid for twelve (12) months and shall thereupon expire At such time, DMRs shall be
submitted electronically to the Division unless the permittee re -applies for and is granted a new
temporary waiver by the Division
Information on eDMR and application for a temporary waiver from the NPDES electronic
reporting requirements is found on the following web page•
http•/ /portal.ncdenr.org/web/wq/admin/bog/ipu/edmr
Regardless of the submission method, the first DMR is due on the last day of the month
following the issuance of the permit or in the case of a new facility, on the last day of the month
following the commencement of discharge.
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Pelmit NC0001422
2. Signatory Requirements [Supplements Section B (11.1 (b) and supersedes Section B (11.1
t"
All eDMRs submitted to the permit issuing authority shall be signed by a person described in
Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in
Part II, Section B. (11 )(b) A person, and not a position, must be delegated signatory authority
for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system For more information on North
Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please
visit the following web page:
htt/portal ncdenr.org/web/wq/admin/boy/iDu/edmr
Certification Any person submitting an electronic DMR using the state's eDMR system shall
make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF
CERTIFICATION WILL BE ACCEPTED
"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 submittcng false information,
including the possibility of fines and imprisonment for knowing violations "
3. Records Retention [Supplements Section D. (6.))
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions These records or copies shall be maintained for a period of at least 3 years from
the date of the report This period may be extended by request of the Director at any time [40
CFR 122.411.
A. (24.) APPLICABLE STATE LAW (STATE ENFORCEABLE ONLY) [G.S 143-215.1(b)]
This facility shall meet the requirements of Senate Bill 729 (Coal Ash Management Act). This permit
may be reopened to include new requirements imposed by Senate Bill 729.
A. (25.) STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop and implement a Stormwater Pollution Prevention Plan (SPPP). The
SPPP shall be maintained on site unless exempted from this requirement by the Division. The SPPP
is public information The SPPP should also specifically and separately address deconstruction,
demolition, coal, and/or coal ash hauling or disposal activities The SPPP shall include, at a
minimum, the following items•
1. Site Overview The Site Overview shall provide a description of the physical facility and the
potential pollutant sources that may be expected to contribute to contamination of stormwater
discharges. The Site Overview shall contain the following,
(a) A general location map (USGS quadrangle map or appropriately drafted equivalent map),
showing the facility's location in relation to transportation routes and surface waters; the
name of the receiving waters to which the stormwater outfalls discharge, or if the discharge
is to a municipal separate storm sewer system, the name of the municipality and the
ultimate receiving waters, and accurate latitude and longitude of the points of stormwater
discharge associated with industrial activity The general location map (or alternatively the
site map) shall identify whether any receiving waters are impaired (on the state's 303(d) list
Page 14 of 19

Peimrt NC0001422
of impaired waters) or if the site is located in a watershed for which a TMDL has been
established, and what the parameters of concern are.
(b) A narrative description of storage practices, loading and unloading activities, outdoor
process areas, dust or particulate generating or control processes, and waste disposal
practices. A narrative description of the potential pollutants that could be expected to be
present in the stormwater discharge from each outfall The narrative should also reference
deconstruction, demolition, coal, and/or coal ash hauling or disposal activities where
applicable.
(c) A site map drawn at a scale sufficient to clearly depict: the site property boundary; the
stormwater discharge outfalls; all on-site and adjacent surface waters and wetlands;
industrial activity areas (including storage of materials, disposal areas, process areas,
loading and unloading areas, and haul roads), site topography and finished grade; all
drainage features and structures; drainage area boundaries and total contributing area for
each outfall; direction of flow in each drainage area, industrial activities occurring in each
drainage area; buildings; stormwater Best Management Practices (BMPs), and impervious
surfaces The site map must indicate the percentage of each drainage area that is
impervious, and the site map must include a graphic scale indication and north arrow
(d) A list of significant spills or leaks of pollutants during the previous three (3) years and any
corrective actions taken to mitigate spill impacts.
(e) Certification that the stormwater outfalls have been evaluated for the presence of non-
stormwater discharges The permittee shall submit the first certification no later than
90 days after the effective date of this permit to the Stormwater Permitting Program
Central Office and shall re -certify annually that the stormwater outfalls have been
evaluated for the presence of non-stormwater discharges. For any non-stormwater
discharge identified, the permittee shall indicate how that discharge is permitted or
otherwise authorized The certification statement will be signed in accordance with the
requirements found in Part II, Standard Conditions, Section B, Paragraph 11.
Stormwater Management Strategy The Stormwater Management Strategy shall contain a
narrative description of the materials management practices employed which control or
minimize the stormwater exposure of significant materials, including structural and
nonstructural measures This strategy should also address deconstruction, demolition, coal,
and/or coal ash hauling or disposal activities where applicable The Stormwater Management
Strategy, at a minimum, shall incorporate the following -
(a) Feasibility Study A review of the technical and economic feasibility of changing the
methods of operations and/or storage practices to eliminate or reduce exposure of materials
and processes to rainfall and run-on flows Wherever practical, the permittee shall prevent
exposure of all storage areas, material handling operations, and manufacturing or fueling
operations. In areas where elimination of exposure is not practical, this review shall
document the feasibility of diverting the stormwater run-on away from areas of potential
contamination
(b) Secondary Containment Requirements and Records Secondary containment is required
for. bulk storage "of liquid materials; storage in any amount of Section 313 of Title III of the
Superfund Amendments and Reauthorization Act (SARA) water priority chemicals; and
storage in any amount of hazardous substances, in order to prevent leaks and spills from
contammating stormwater runoff A table or summary of all such tanks and stored
materials and their associated secondary containment areas shall be maintained. If the
secondary containment devices are connected to Stormwater conveyance systems, the
connection shall be controlled by manually activated valves or other similar devices (which
shall be secured closed with a locking mechanism) Any stormwater that accumulates in
the containment area shall be observed for color, foam, outfall staining, visible sheens and
Page 15 of 19

Permit NC0001422
dry weather flow, prior to release of the accumulated stormwater. Accumulated stormwater
shall be released if found to be uncontaminated by any material Records documenting the
individual making the observation, the description of the accumulated stormwater, and the
date and tune of the release shall be kept for a period of five (5) years. For facilities subject
to a federal oil Spill Prevention, Control, and Countermeasure Plan (SPCC), any portion of
the SPCC Plan fully compliant with the requirements of this permit may be used to
demonstrate compliance with this permit.
In addition to secondary containment for tankage, the permittee shall provide drip pans or
other similar protection measures for truck or rail car liquid loading and unloading stations.
(c) BMP Summary. A listing of site structural and non-structural Best Management Practices
(BMPs) shall be provided The installation and implementation of BMPs shall be based on
the assessment of the potential for sources to contribute significant quantities of pollutants
to stormwater discharges and on data collected through monitoring of stormwater
discharges. The BMP Summary shall include a written record of the specific rationale for
installation and implementation of the selected site BMPs. The BMP Summary should also
address deconstruction, demolition, coal, and/or coal ash hauling or disposal activities
where applicable The permittee shall refer to the BMPs described in EPA's Multi -Sector
Permit (MSGP) and Industrial Stormwater Fact Sheet for Steam Electric Power Generating
Facilities (EPA -833-F-06-030) for guidance on BMPs that may be appropriate for this site
The BMP Summary shall be reviewed and updated annually.
Spill Prevention and Response Procedures. The Spill Prevention and Response Procedures
(SPRP) shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. Facility personnel responsible for implementing the SPRP shall be
identified in a written list incorporated into the SPRP and signed and dated by each individual
acknowledging their responsibilities for the plan. A responsible person shall be on-site at all
times during facility operations that have increased potential to contaminate stormwater runoff
through spills or exposure of materials associated with the facility operations. The SPRP must
be site stormwater specific. Therefore, an oil Spill Prevention Control and Countermeasure plan
(SPCC) may be a component of the SPRP, but may not be sufficient to completely address the
stormwater aspects of the SPRP. The common elements of the SPCC with the SPRP may be
incorporated by reference into the SPRP.
4. Preventative Maintenance and Good Housekeeping Program. A preventative maintenance
and good housekeeping program shall be developed and implemented The program shall
address all stormwater control systems (if applicable), stormwater discharge outfalls, all on-site
and adjacent surface waters and wetlands, industrial activity areas (including material storage
areas, material handling areas,, disposal areas, process areas, loading and unloading areas, and
haul roads), all drainage features and structures, and existing structural BMPs.
The program shall establish schedules of inspections, maintenance, and housekeeping activities
of stormwater control systems, as well as facility equipment, facility areas, and facility systems
that present a potential for stormwater exposure or stormwater pollution where not already
addressed under another element of the SPPR Inspection of material handling areas and
regular cleaning schedules of these areas shall be incorporated into the program. Compliance
with the established schedules for inspections, maintenance, and housekeeping shall be
recorded and maintained in the SPPP The program should also address deconstruction,
demolition, coal, and/or coal ash hauling or disposal activities where applicable. The Good
Housekeeping Program shall also include, but not be limited to, BMPs to accomplish the
following.
(a) Minimize contamination of stormwater runoff from oil-bearing equipment in
switchyard areas,
(b) Minimize contamination of stormwater runoff from delivery vehicles and rail cars
arriving and departing the plant site;
Page 16 of 19

Permit NC0001422
(c) Inspect all residue -hauling vehicles for proper covering over the load, adequate gate -
sealing, and overall integrity of the container body. Repair vehicles as necessary;
and
(d) Reduce or control the tracking of ash and residue from ash loading and storage
areas,
5 Facility Inspections Inspections of the facility (including tanks, pipes, and equipment) and all
stormwater systems shall occur as part of the Preventative Maintenance and Good
Housekeeping Program at a minimum on a semi-annual schedule, once during the first half of
the year (January to June), and once during the second half (July to December), with at least 60
days separating inspection dates (unless performed more frequently than semi-annually)
6 Employee Training, Training programs shall be developed and training provided at a
minimum on an annual basis for facility personnel with responsibilities for, spill response and
cleanup, preventative maintenance activities, and for any of the facility's operations that have
the potential to contaminate stormwater runoff, The facility personnel responsible for
implementing the training shall be identified, and their annual training shall be documented by
the signature of each employee trained
7. Responsible Party The SPPP shall identify a specific position or positions responsible for the
overall coordination, development, implementation, and revision of the SPPP. Responsibilities
for all components of the SPPP shall be documented and position assignments provided
8. SPPP Amendment and Annual Update The permittee shall amend the SPPP whenever there is
a change in design, construction, operation, site drainage, maintenance, or configuration of the
physical features which may have a significant effect on the potential for the discharge of
pollutants to surface waters. All aspects of the SPPP shall be reviewed and updated on an
annual basis The annual update shall include:
(a) an updated list of significant spills or leaks of pollutants for the previous three (3)
years, or the notation that no spills have occurred (element of the Site Overview);
(b) a written re -certification that the stormwater outfalls have been evaluated for the
presence of non-stormwater discharges (element of the Site Overview),
(c) a documented re-evaluation of the effectiveness of the on-site stormwater BMPs (BMP
Summary element of the Stormwater Management Strategy).
(d) a review and comparison of stormwater sample analytical data to any applicable
limits or benchmark values (if applicable) over the past year.
If the Director notifies the permittee that the SPPP does not meet one or more of the minimum
requirements of the permit, the permittee shall have 30 days to respond. Within 30 days of
such notice, the permittee shall submit a time schedule to the Director for modifying the SPPP
to meet mmunum requirements The permittee shall provide certification in writing to the
Director that the changes have been made
SPPP Implementation. The permittee shall implement the Stormwater Pollution Prevention
Plan and all appropriate BMPs consistent with the provisions of this permit, in order to control
contaminants entering surface waters via stormwater. Implementation of the SPPP shall
include documentation of all monitoring, measurements, inspections, maintenance activities,
and training provided to employees, including the log of the sampling data and of actions taken
to implement BMPs associated with the industrial activities, including vehicle maintenance
activities Such documentation shall be kept on-site for a period of five (5) years and made
available to the Director or the Director's authorized representative immediately upon request.
A. (26.) TEMPERATURE LIMIT COMPLIANCE SCHEDULE- OUTFALL 008
The facility shall develop the plan for compliance with the State temperature standard and submit
the plan to the Division within 1 year from the effective date of the permit. The plan shall contain
Page 17 of 19

Permit NC0001422
milestones and the specific action items. After the plan is approved by the Division, it will become an
enforceable part of the permit
A. (27.) ADDITIONAL CONDITIONS AND DEFINITIONS
1 EPA methods 200 7 or 200 8 (or the most current versions) shall be used for analyses of all
metals except for total mercury
2. All effluent samples for all external outfalls shall be taken at the most accessible location
after the final treatment but prior to discharge to waters of the U S (40 CFR 122 410)).
3 The term low volume waste sources means wastewater from all sources except thouse for
which specific limitations are otherwise established in this part (40 CFR 423.11 (b)).
4. The term chemical metal cleaning waste means any wastewater resulting from cleaning any
metal process equipment with chemical compounds, including, but not limited to, boiler
tube cleaning (40 CFR 423 11 (c))
S The term metal cleaning waste means any wastewater resulting from cleaning [with or
without chemical cleaning compounds] any metal process equipment including, but not
limited to, boiler tube cleaning, boiler fireside cleaning, and air preheater cleaning (40 CFR
423.11 (d))
6 For all outfalls where the flow measurement is to be "estimated" the estimate can be done by
using calibrated V -notch weir, stop -watch and graduated cylinder, or other method
approved by the Division,
7. During normal operations removing of the free water above the settled wet ash layer shall
not involve mechanical disturbance of the ash
Page 18 of 19

Peima NC0001422
Appendix A.
Plan for Identification of New Discharges (attached).
Page 19 of 19

Duke Energy Progress, Inc.
L.V. Sutton Electric Plant
NPDES Permit NC00001422
2015 Permit Application Update
N
Dike;
0 500
1000
tdakeup
Meters
Pump
0 1000 2000 3000
I eet
Outfall 004
4
Sutton Cooling
2
Pond
/
New Ash Pond
(1984)
Outfall 002
Outfall 008 (approx) O/d Ash
on (1971)
Effluent Channel
to Cooling Pond
Internal
l�
U u tfa II Internal 009
(approx) Outfall 007
(approx
• Final (external) Outfalls
Cooling Pond
• Internal Outfalls
Withdrawal
Recirculating
Condenser
Cooling Water
Outfall 001
Release
CC Block
Internal Outfall 006
CC Block
Sutton Energy
Internal Outfall 005
Complex
f
NORTH CAROLINA
Attachment 1- Site Ma
L. V. Sutton Energy Complex
New Hanover County

0 Outfall 002
Outfall 008f IL Old Ash
(approx) Pond (1971)
Cooling Pond Internal
Outfall 009
(approx) Internal
Outfall 007
(approx)
Points of Interest:
• Outfall 001: Discharge from ash pond diverter structure to Cape Fear River
• Outfall 008: Comingled wastewater discharge through effluent channel
• Internal Outfall 009: Low volume waste from proposed "Fast Start" CT units
• Internal Outfall 007: Low volume wastes from WRB
• Internal SW -1: Stormwater drainage from parking lot/laydown area*
• Internal SW -2: Stormwater drainage from existing CT unit yard drainage*
• Internal SW -3: Stormwater drainage from parking lot*
• Internal SW -4: Stormwater drainage from switchyard area*
• Recirculating water discharge (RWD) from CC plant (comingled with internal outfalls 005
and 006)
• Internal SW -6: Spillway overflow from SW infiltration basin*
ISW-1
Note*: In many cases, only exempt SW is routed directly to the effluent channel. Stormwater from ISW-2
oil -containing areas is routed to the site oil/water separator.
NkomoT
X40
�. Outfall 001
L
ISW-3
ISW4 %AXISW-6
Internal Outfalls
005,006

N
DENR/DWR
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
Major Modification
NPDES No. NC0001422
Facility Information
Applicant/ FaciliName: Duke Energy Progress, LLC/ L.V. Sutton Energy Complex
Applicant Address: 801 Sutton Steam Plant Road, Wilmington, NC 28401
Facility Address: same
Permitted Flow N/A
Type of Waste: 100 % Industrial
Facility/Permit Status: Major Modification Class
Countv: New Hanover
Miscellaneous
Receiving Stream:
Cape Fear River
(001), Sutton Lake
002, 004, 008
Regional Office:
WiRO
Stream Classification:
C Sw (001)
C (002, 004, 008)
SI: 18-(63)
Quad
J27SW
Castle Hayne
303(d) Listed?:
Yes
Impaired for D.O.
Ca e Fear River
Pem-it Writer:
Sergei Chemikov, Ph.D.
Subbasin:
030617 (CPF)
Date:
February 18, 2015
Drainage Area mit :
�y
�■1�■�"�
Summer 7Q10 (cfs)
Tidally influenced
(Outfall 001);
Lake (Outfalls
002, 004, and 008
30Q2 cfs :
See above
Average Flow cfs :
See above
IWC C/o):
100 all outfalls
Primary SIC Code:
PROPOSED PERMITTING ACTION
This is a request for a Major Modification to the NPDES wastewater permit. On November 5, 2014
the Duke Energy Progress was notified of the DENR decision to reclassify Sutton Lake (1100 acres)
to the "waters of the State". The reclassification necessitates the need to make modifications to the
existing NPDES permit. This Major Modification is being made to incorporate the required
changes to the permit. This modification also includes addition of the groundwater to the permit,
the groundwater is being withdrawn from the interceptor wells to prevent spread of the
contaminated plume outside of the compliance boundary. The facility will install 12 wells, each
yielding approximately 75 gpm, for an anticipated maximum flow rate of 900 gpm (1.3 MGD). All
water pumped from the extraction wells will be processed through a treatment system that
precipitates pollutants of concern, followed by solids removal. The treated wastewater will be
discharged through existing outfall 001.
SUMMARY
Duke Energy Progress Sutton Plant is a natural gas-fired 620 MW combined cycle generation facility.
The power block consists of two combustion turbine generators (each with a HRSG — heat recovery
steam generator) and one steam turbine generator. Historically, the facility operated 3 coal-fired units.
The coal-fired units were shut -down in the fourth quarter of 2013
Duke Energy Progress, Inc. - Sutton NC0001422
NPDES Major Modification
Page 1

The facility is regulated by federal effluent guidelines (40 CFR Part 423 — Steam Electric Power
Generating Point Source Category) — BPT/BAT
On February 11, 2015 the Wilmington Regional Office delineated the Effluent Channel at the Sutton
Energy Complex in accordance with the requirements of 15A NCAC 02B 0228 The new Outfall 008
was established to accommodate discharge from this outfall
Wastewater outfalls
Outfall 001 — cooling pond discharge, recirculated cooling water, non -contact cooling water,
groundwater, and treated wastewater from Outfall 004 (new ash pond) The new ash pond can
discharge directly to Sutton Lake through Outfall 004 or to Cape Fear River through Outfall 001 The
Outfall 001 is discharging through the mixing box that was set-up to concurrently discharge ash pond
wastewater and water from Sutton Lake
Outfall 002 — wastewater associated with the old ash pond May consist of low volume waste, yard
drains, oily waste treatment, ash sluice, and coal pile runoff Wastewater can be discharged to Sutton
Lake or to Cape Fear River through Outfall 001.
Outfall 004 — wastewater associated with the new ash pond May consist of low volume waste, yard
drains, oily waste treatment, ash sluice, and coal pile runoff Wastewater can be discharged to Sutton
Lake or to Cape Fear River through Outfall 001
Outfall 008- Primarily consists of recirculating cooling water from the Combined Cycle generation
unit, contains flows from internal outfalls 005, 006, 007, 009, and stormwater outfalls
Internal Outfall 005 — wastewater from the Combined Cycle generation unit
Internal Outfall 006 - wastewater from the Combined Cycle generation unit
Internal Outfall 007 — stormwater/wastewater flows from the closure activities for coal-fired units
Internal Outfall 009 — low volume wastes from a new simple cycle combustion turbine expected to
be online in 2017
Stormwater outfalls discharging to the effluent channel and then to Sutton Lake via Outfall 008
Internal Outfall SW001 — Runoff from the temporary laydown area and the parking lot
Internal Outfall SW002 — Runoff from the parking lot and Peaker Combustion Turbine area
Internal Outfall SW003 — Runoff from the parking lot
Internal Outfall SW004 — Pumped stormwater from the 115 Electrical Switchyard area
Internal Outfall SW005 — Discharge from the south wet detention basin
Internal Outfall SW006 — Discharge from the rip rap armored emergency spillway for the north
infiltration basin that treats stormwater from a parking lot and surrounding areas
Internal Outfall S` O07 — Runoff from the potential rail loading yard, rail spur, and truck roads
installed to transport coal ash from the site
Duke Energy Progress, Inc - Sutton NC0001422
NPDES Mayor Modification
Page 2

ASH POND DAMS
Seepage through earthen dams is common and is an expected consequence of impounding water
with an earthen embankment Even the tightest, best -compacted clays cannot prevent some water
from seeping through them Seepage is not necessarily an indication that a dam has structural
problems, but should be kept in check through various engineering controls and regularly monitored
for changes in quantity or quality which, over time, may result in dam failure
Currently, no seeps have been detected at the site
REASONABLE POTENTIAL ANALYSIS(RPA)-OUTFALL 001, OUTFALL 002, OUTFALL 004,
OUTFALL 008
The Division conducted EPA -recommended analyses to determine the reasonable potential for
toxicants to be discharged at levels exceeding water quality standards/EPA criteria by this facility
from outfalls 001, 002, 004 (Ash Ponds discharges) For the purposes of the RPA, the background
concentrations for all parameters were assumed to be below detections level The RPA uses 95%
probability level and 95% confidence basis in accordance with the EPA Guidance entitled
"Technical Support Document for Water Quality -based Toxics Control "
The long term discharge data on the EPA Form 2C was used, it was supplemented by the analysis of
the free standing water in both ash ponds and groundwater sampling results Since the highest available
values for each parameter was used, it is assumed that this RPA is applicable to all discharges that
represent coal ash contaminated water (outfalls 001, 002, 004) Calculations included As, Be, Cd,
Chlorides, F, Total Phenolic Compounds, Cr, Cu, CN, Pb, Hg, Mo, Ni, Se, Ag, Zn, Fe, Al, Ba, Sb and
Tl (please see attached) The historic flow of 12 84 MGD was used in the analysis, the groundwater
pumping volume of 13 MGD was added to the historic flow Although the RPA for Al exceeds the
allowable amount, the limit will not be added to the permit since North Carolina does not have Al
standard and approximately 89% of the surface water samples in the state exceeds the EPA
recommended criteria of 87 µg/L
The RPA analysis for Outfall 008 (effluent channel discharge) was not conducted due to the absence
of the monitoring data Most of the water in the effluent channel is cooling water and low volume
wastewater from the combined cycle facility
The proposed permit requires that EPA methods 200 7 or 200 8 (or the most current versions) shall
be used for analyses of all metals except for total mercury
MERCURY EVALUATION
The State of North Carolina has a state-wide mercury impairment The TMDL has been developed
to address this issue in 2012 The TMDL included the implementation strategy, both documents were
approved by EPA in 2012
The mercury evaluation was conducted in accordance with the Permitting Guidelines for Statewide
Mercury TMDL
Year
2012
2013
2015
Annual average
211
179
<50 0
concentration n /L
Maximum sampling
372
252
<50 0
result n /L
Duke Energy Progress, Inc - Sutton NC0001422
NPDES Mayor Modification
Page 3

Allowable mercury concentration for this facility is 12 0 ng/L Based on the EPA guidance, the
Division assumes that the annual average concentration for 2015 equals 25 0 ng/L This concentration
exceeds allowable concentration of 12 0 ng/L Therefore, based on the Permitting Gwdehnes for
Statewide Mercury TMDL, the effluent limits will be added to the permit
DEWATERING — OUTFALL 001
To meet the requirements of the Coal Ash Management Act of 2014, the facility needs to dewater
two ash ponds by removing the interstitial water and excavate the ash to deposit it in landfills The
facility's highest discharge rate from the dewatering process will be 2 1 MGD The facility submitted
data for the standing surface water in the ash ponds, interstitial water in the ash, and interstitial ash
water that was treated by filters of various sizes To evaluate the impact of the dewatering on the
receiving stream the RPA was conducted for the wastewater that will be generated by the dewatering
process To introduce a margin of safety, the highest measured concentration for a particular
parameter was used The RPA was conducted for As, Cd, Chlorides, Cr, Cu, F, Pb, Mo, Hg, Ni, Se,
Zn, Ba, Fe, Al, B, Sb, and Tl (please see attached)
TEMPERATURE LIMIT — OUTFALL 008
Since the Sutton Lake has been reclassified to the "waters of the State" on November 5, 2014, the
facility has to develop a strategy to meet the state temperature standard in Sutton Lake Potential
solutions include but are not limited to construction of a cooling tower, re-routing of the discharge
to the Cape Fear River, or securing a 316(a) variance
CWA SECTION 316(b1
The permittee shall comply with the Cooling Water Intake Structure Rule per 40 CFR 125 95 The
Division approved the facility request for an alternative schedule in accordance with 40 CFR
125 95(a)(2) The permittee shall submit all the materials required by the Rule with the next renewal
application
TOXICITY TESTING -OUTFALL 001, OUTFALL 002, OUTFALL 004, AND OUTFALL 008
Current Requirement Outfall 001 — Acute P/F @ 90% using Pimephales promelas
Recommended Requirement Outfall 001 — Acute P/F @ 90% using Pimephalespromelas
This facility has passed all toxicity tests during the previous permit cycle, please see attached
New Requirement Outfall 002/004/008 — Chronic P/F @ 90% using Cenodaphnaa dubia
For the purposes of the permitting, the long term average flow was used in conjunction with the
7Q10 summer flow to calculate the percent effluent concentrations to be used for WET
COMPLIANCE SUMMARY
During the last 5 years, the facility has exceeded limit 1 time, please see attached The limit violation was for
pH (Outfall 001)
PERMIT LIMITS DEVELOPMENT
• The temperature limits (Outfall 001 and Outfall 008) are based on the North Carolina water
quality standards (15A NCAC 2B 0200)
Duke Energy Progress, Inc - Sutton NC0001422
NPDES Mayor Modification
Page 4

• The limits for Oil and Grease and Total Suspended Solids (Outfall 001, Outfall 002, Outfall
004, Outfall 005, Outfall 006, Outfall 007, Outfall 008, and Outfall 009) are based on the
requirements in 40 CFR 423
• The pH limits (Outfall 001, Outfall 002, Outfall 004, Outfall 005, Outfall 006, Outfall 008,
and Outfall 009) are based on the North Carolina water quality standards (15A NCAC 2B
0200)
• The Whole Effluent Toxicity limit (Outfall 001, Outfall 002, Outfall 004 and Outfall 008) is
based on the requirements of 15A NCAC 2B 0500
• The Water Quality Based Effluent Limits for Total Iron, Total Arsenic, and Total Selenium
(Outfall 001, Outfall 002, and Outfall 004) are based on the results of the Reasonable
Potential Analysis
The Total Iron Limits are based on the water quality standard/EPA criteria of 10 mg/L for
Freshwater Aquatic Life The Total Arsenic Limits are based on the water quality
standard/EPA criteria of 50 0 4g/L for Freshwater Aquatic Life and on the water quality
standard/EPA criteria of 10 0 µg/L for Human Health The Total Selenium Limits are based
on the water quality standard/EPA criteria of 5 0 µg/L for Freshwater Aquatic Life
(chronic) and on the water quality standard/EPA criteria of 56 0 µg/L for Freshwater
Aquatic Life (acute)
The calculations are conducted in accordance with the EPA Guidance entitled "Technical
Support Document for Water Quahty-based Toxics Control " Please see attached RPA for
details
• The Water Quality Based Effluent Limits for Total Cadmium and Total Lead (Outfall 001)
are based on the results of the Reasonable Potential Analysis
The Total Cadmium Limits are based on the water quality standard/EPA criteria of 2 0 µg/L
for Freshwater Aquatic Life (chronic) and on the water quality standard/EPA criteria of 15 0
µg/L for Freshwater Aquatic Life (acute) The Total Lead Limits are based on the water
quality standard/EPA criteria of 25 0 µg/L for Freshwater Aquatic Life (chronic) and on the
water quality standard/EPA criteria of 33 5 4g/L for Freshwater Aquatic Life (acute)
The calculations are conducted in accordance with the EPA Guidance entitled "Technical
Support Document for Water Quahty-based Toxics Control " Please see attached RPA for
details
• The turbidity limit (Outfall 001) is based on North Carolina water quality standards (15A
NCAC 2B 0200)
• Mercury limit in the permit is based on the Permitting Guidelines for Statewide Mercury
TMDL
PROPOSED CHANGES
• The Clean `Plater Act Section 316(B) Special Condition was updated to reflect the new
regulations
• The turbidity limit was added to the permit (Outfall 001) to meet the state turbidity standard
per 15A NCAC 2B 0211(3) (k)
• The TRC limit was removed from the permit due to shut -down of the coal-fired generation
units (Outfall 001)
The Ash Pond Closure Special Condition was updated (please see A (19 ))
Duke Energy Progress, Inc - Sutton NC0001422
NPDES Mayor Modification
Page 5

• The Outfall 003 (Chemical Metal Cleaning) was eliminated from the permit due to shut-
down of the coal-fired generation units
• The new Outfall 008 (discharge from the effluent channel) was added to the permit This
outfall includes discharge from 4 internal wastewater outfalls, and 7 internal stormwater
outfalls
• The monitoring for ammonia nitrogen was eliminated from the permit due to the
discontinuation of the coal ash sluicing (Outfall 002 and Outfall 004)
• An internal Outfall 007 was added to the peanut to accommodate discharge from the West
Retention Basin This discharge includes the wastewater from closure activities associated
with the coal-fired units
• An internal Outfall 009 was added to the pemriit to accommodate low level wastewater
discharge from simple cycle turbine expected to be on line in 2017
• The Limits for Total Arsenic and Total Selenium were added to the permit (Outfall 002 and
Outfall 004) based on the results of Reasonable Potential Analysis
• The Limits for Total Lead and Total Cadmium were added to the peanut (Outfall 001) based
on the results of Reasonable Potential Analysis
• The Daily Maximum Water Quality Based Effluent Limit for Total Arsenic was corrected
(Outfall 001)
• A separate effluent page for the dewatering of the ash ponds (Outfall 001) was added to the
permit (Please see Special Condition A (2 ))
• The limits for Total Iron were added to the permit based on the results of Reasonable
Potential Analysis (Outfall 001, Outfall 002, and Outfall 004)
• The limits for Total Mercury were added to the permit based on the Permitting Guidelines for
Statewide Mercury TMDL (Outfall 001, Outfall 002, and Outfall 004)
• Monitoring for Total Zinc was added to Outfall 001 based on the results of Reasonable
Potential Analysis
• Monitoring for Total Copper and Total Zinc was added to the permit (Outfall 002 and
Outfall 004) based on the results of Reasonable Potential Analysis
• The Chronic Toxicity Limit was added to the permit (Outfall 002 and Outfall 004) due to the
re-classification of the Sutton Lake
• New internal outfalls for stormwater were added to the permit (SW001 through SW007)
• The Special Condition Fish Tissue Monitoring near Ash Pond Discharge has been updated
(please see A (17 ))
• The Special Condition Instream Monitoring was added to the permit (please see A (22 ))
• Proposed federal regulations require electronic submittal of all discharge monitoring reports
(DMRs) and specify that, if a state does not establish a system to receive such submittals,
then permittees must submit DMRs electronically to the Environmental Protection Agency
(EPA) The Division anticipates that these regulations will be adopted and is beginning
implementation
The requirement to begin reporting discharge monitoring data electronically using the NC
DWR's Electronic Discharge Monitoring Report (eDMR) internet application has been added
to the permit (Please see Special Condition A (23 ))
The Applicable State Law Special Condition was added to the permit to meet the requirements
of Senate Bill 729 (Coal Ash Management Act, Please see Special Condition A (24 ))
The Stormwater Pollution Prevention Plan Special Condition was added to the permit to
accommodate the new internal stormwater outfalls (Please see Special Condition A (25 ))
Duke Energy Progress, Inc - Sutton NC0001422
NPDES Mayor Modification
Page 6

The Temperature Limit Compliance Schedule Special Condition was added to the permit to
meet the temperature requirements at the new Outfall 008 (Please see Special Condition A
(26 ))
The Additional Conditions and Definitions Special Condition was added to the permit Please
see Special Condition A (27 )
The following requirement was added to Outfall 002, Outfall 004, and Outfall 008 No later
than 180 days from the effective date of this permit, the facility shall submit EPA Form 2C
CHANGES IN THE DRAFT PERMIT
The following modifications to the Tiny Draft Permit were implemented based on public comments
received during public hearing process, Division's staff recommendations included in the Hearing
Officer Report (October 6, 2015), EPA comments, and Duke Energy comments
1) The limits for Oil and Grease and TSS were added to Outfall 001
2) The monitoring frequency for all parameters in the effluent was increased to Weekly (Outfall
001 — normal operation), with an exception of Whole Effluent Toxicity
3) The transfer of wastewater from Old Ash Pond to New Ash Pond and Outfall 001 was
authorized
4) The requirements to minimize fish migration up the Effluent Channel were modified
(Outfall 008)
5) The Total Aluminum limits were removed from Outfall 001, Outfall 002, and Outfall 004
since North Carolina does not have Al standard and approximately 89% of the surface water
samples in the state exceeds the EPA recommended criteria of 87 µg/L
6) The requirement to limit drawdown rate to 1 foot/week (unless approved by DEQ) were
added to Outfall 001, Outfall 002, and Outfall 004
7) The groundwater was added to the list of the waste streams discharged through Outfall 001
8) The following requirement was added to Outfall 002, Outfall 004, and Outfall 008 The
following requirement was added to Outfall 002, Outfall 004, and Outfall 008 The facility
shall submit EPA Form 2C as soon as practicable, but no later than 180 days from the
effective date of this permit
9) The Technology Based Effluent Limits for Total Arsenic, Total Selenium, and Total
Mercury were eliminated (Outfall 001, Outfall 002, and Outfall 004) to meet the updated
requirement in 40 CFR 423
PROPOSED SCHEDULE
Draft Permit to Public Notice October 14, 2015 (est)
Permit Scheduled to Issue December 11, 2015 (est)
STATE CONTACT
If you have any questions on any of the above information or on the attached permit, please contact
Sergei Chernikov at [phone] or sergei chernikov@ncdenr gov
Duke Energy Progress, Inc - Sutton NC0001422
NPDES Mayor Modification
Page 7

Appendix C
Summary of Comments
(Written and Oral)
RECEI�EDINCDEQID�NR
SEP 2 6 2011
Water aUS' ty
permitting Section

�y, David
From: Linda Wagoner <[e-mail]>
Sent: Wednesday, June 21, 2017 10 22 AM
To: SVC_DENR.publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River. The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that.
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thank you.
Sincerely,
Linda Wagoner
47 Leader Circle
Imington, NC 28412

ay, David
From: Peter Beckley <pbeckley@msn com>
Sent: Wednesday, June 21, 2017 10:26 AM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that.
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thank you.
Sincerely,
Peter Beckley
Z Island Palms Dr
Vina Beach, NC 28428

ay, David
From:
Eric von Foerster <[e-mail]>
Sent:
Wednesday, June 21, 2017 10 33 AM
To:
SVC_DENR publiccomments
Subject:
Sutton Coal Ash Permits
Dear DEQ,
Please do not allow Duke Energy to pollute our waterways with toxic coal ash pollution Our community faces too many
uncertainties regarding the safety of our water Sutton Lake is an important fishing lake that many people depend on to
feed their families, with a long history of coal ash pollution problems. The permit would allow contaminated wastewater
to flow into the Cape Fear River by removing or weakening limits on arsenic, mercury, and other coal ash pollutants.
DEQ should require Duke Energy to stop its pollution.
The current permit as written would do little to protect our waterways Please strengthen the draft NPDES permit
Thank you
Sincerely,
Eric von Foerster
33 Oleander Dr
Wilmington, NC 28403

ay, David
From:
Robert Watson <bobs@ec rr.com>
Sent:
Wednesday, June 21, 2017 10.41 AM
To:
SVC_DENR publiccomments
Subject:
Sutton Coal Ash Permits
Dear DEQ,
Please do not allow Duke Energy to pollute our waterways with toxic coal ash pollution Our community faces too many
uncertainties regarding the safety of our water. Sutton Lake is an important fishing lake that many people depend on to
feed their families, with a long history of coal ash pollution problems. The permit would allow contaminated wastewater
to flow into the Cape Fear River by removing or weakening limits on arsenic, mercury, and other coal ash pollutants.
DEQ should require Duke Energy to stop its pollution
The current permit as written would do little to protect our waterways. Please strengthen the draft NPDES permit
Thankyou
Sincerely,
Robert Watson
1 Spring Branch Road
Wilmington, NC 28405

-- ay, David
From: Dustin Jones <dustin c.jones@gmail com>
Sent: Wednesday, June 21, 2017 10 38 AM
To: SVC_DENR publiccomments
Subject: Sutton Coal Ash Permits
Dear DEQ,
Please do not allow Duke Energy to pollute our waterways with toxic coal ash pollution Our community faces too many
uncertainties regarding the safety of our water Sutton Lake is an important fishing lake that many people depend on to
feed their families, with a long history of coal ash pollution problems. The permit would allow contaminated wastewater
to flow into the Cape Fear River by removing or weakening limits on arsenic, mercury, and other coal ash pollutants.
DEQ should require Duke Energy to stop its pollution.
The current permit as written would do little to protect our waterways Please strengthen the draft NPDES permit
Thank you.
Sincerely,
Dustin Jones
)5 Park Ave
Wilmington, NC 28403

ay, David
From: James Kapetsky <Jameskapetsky@gmail com>
Sent: Wednesday, June 21, 2017 11.05 AM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River. The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thank you
Sincerely,
James Kapetsky
--)6 Meadowlark Ln
t2
Wilmington, NC 28411
9106810522

ay, David
From: Caroline Branca <brancabiz@gmail com>
Sent: Wednesday, June 21, 2017 11.14 AM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River. The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thank you.
Sincerely,
Caroline Branca
"5 Indian Wells Way
Imington, NC 28411

ay, David
From: Robin Guerry <robin0383@gmail com>
Sent: Wednesday, June 21, 2017 1120 AM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River. The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that.
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways
Thank you
Sincerely,
Robin Guerry
—5 N Channel Maven Dr
Imington, NC 28409
9108052578

ay, David
From: Barbara Gray <[e-mail]>
Sent: Wednesday, June 21, 2017 11.29 AM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River. The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thank you
Sincerely,
Barbara Gray
"_ Forest Oaks Drive
uthport, NC 28461
9104576607

ay, David
From: Daniel George <herondang@gmail com>
Sent: Wednesday, June 21, 2017 1156 AM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that.
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thank you.
Sincerely,
Daniel George
40 Hickory Ln SE
nnabow, NC 28479
9103672154

ay, David
From: Susan Zimmer <sezgenie70@gmail com>
Sent: Wednesday, June 21, 2017 12 05 PM
To: SVC_DENR publiccomments
Subject: Sutton Steam Station Permits
Dear DEQ,
I am very concerned about the unacceptably weak draft permit at the Sutton Steam Station. As written, the draft
permits would weaken and remove current discharge limits for arsenic, mercury, and other coal ash pollutants from
Duke Energy's lagoons into Sutton Lake and the Cape Fear River. DEQ would allow Duke Energy to dump nearly 7 times
more toxic arsenic pollution from its coal ash lagoons into Sutton Lake and the Cape Fear River by dramatically
weakening the daily maximum limit in the existing permit.
Please strengthen protections for these important waters.
Thank you
Sincerely,
Susan Zimmer
47 Greensview Circle
Leland, NC 28451
9103992439

ay, David
From:
Al Davidson <plcdoc@gmail com>
Sent:
Wednesday, June 21, 2017 12 16 PM
To:
SVC_DENR publiccomments
Subject:
Sutton Coal Ash Permits
Dear DEQ,
Please do not allow Duke Energy to pollute our waterways with toxic coal ash pollution. Our community faces too many
uncertainties regarding the safety of our water. Sutton Lake is an important fishing lake that many people depend on to
feed their families, with a long history of coal ash pollution problems The permit would allow contaminated wastewater
to flow into the Cape Fear River by removing or weakening limits on arsenic, mercury, and other coal ash pollutants.
DEQ should require Duke Energy to stop its pollution.
The current permit as written would do little to protect our waterways. Please strengthen the draft NPDES permit.
Thankyou
Sincerely,
Al Davidson
2 Brookshire Lane
Wilmington, NC 28409

3y, David
From: donna madonna <[e-mail]>
Sent: Wednesday, June 21, 2017 12.25 PM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thank you.
Sincerely,
donna madonna
--D5 Northstar Place
mington, 28405

ay, David
From: Richard Knott < reknott24@g mail com>
Sent: Wednesday, June 21, 2017 12:37 PM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River. The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that.
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways
Thank you.
Sincerely,
Richard Knott
—1413 Myrtle Grove Rd
Imington, NC 28409
9105477873

ay, David
From: Christina Gallo <chrisJgallo@yahoo com>
Sent: Wednesday, June 21, 2017 12 57 PM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that.
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thank you.
Sincerely,
Christina Gallo
or- Carolina Shores Drive
Vina Shores, NC 28467
9105799459

ay, David
From: Jacquie Ott <jsueott@gmail com>
Sent: Wednesday, June 21, 2017 104 PM
To: SVC_DENR publiccomments
Subject: Sutton Coal Ash Permits
Dear DEQ,
Please do not allow Duke Energy to pollute our waterways with toxic coal ash pollution
Our community faces too many uncertainties regarding the safety of our water.
Sutton Lake is an important fishing lake that many people depend on to feed their families, with a long history of coal
ash pollution problems. The permit would allow contaminated wastewater to flow into the Cape Fear River by removing
or weakening limits on arsenic, mercury, and other coal ash pollutants.
DEQ should require Duke Energy to stop its pollution Immediately.
The current permit as written would do little to protect our waterways.
If you care about your children, grand babies and Pets, Please strengthen the draft NPDES permit
ank you.
Sincerely,
Jacquie Ott
412 Sumter Ave
Carolina Beach, NC 28428

ay, David
From: Cheryl McGraw <chrrlgrrl@gmail com>
Sent: Wednesday, June 21, 2017 127 PM
To: SVC_DENR publiccomments
Subject: Sutton Coal Ash Permits
Dear DEQ,
Please do not allow Duke Energy to pollute our waterways with toxic coal ash pollution. Our community faces too many
uncertainties regarding the safety of our water. Sutton Lake is an important fishing lake that many people depend on to
feed their families, with a long history of coal ash pollution problems The permit would allow contaminated wastewater
to flow into the Cape Fear River by removing or weakening limits on arsenic, mercury, and other coal ash pollutants.
DEQ should require Duke Energy to stop its pollution
The current permit as written would do little to protect our waterways Please strengthen the draft NPDES permit.
Thank you
Sincerely,
Cheryl McGraw
)4 Braxton Ct
Raleigh, NC 27606

ay, David
From: Randall Dail, Jr. <rod1972@atmc net>
Sent: Wednesday, June 21, 2017 1.38 PM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River. The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that.
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thank you.
Sincerely,
Randall Dail, Jr.
--91 Boverie St
illotte, NC 28470

,ay, David
From: Fred BJorkland <fbJorkland@twc com>
Sent: Wednesday, June 21, 2017 2 09 PM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that.
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thank you.
Sincerely,
Fred Bjorkland
'318A Louisa Lane
Imington, NC 28403

ay, David
From: Dr Fred Milano <milanofa@appstate edu>
Sent: Wednesday, June 21, 2017 2 59 PM
To: SVC_DENR publiccomments
Subject: Sutton Coal Ash Permits
Dear DEQ,
Please do not allow Duke Energy to pollute our waterways with toxic coal ash pollution Our community faces too many
uncertainties regarding the safety of our water. Sutton Lake is an important fishing lake that many people depend on to
feed their families, with a long history of coal ash pollution problems. The permit would allow contaminated wastewater
to flow into the Cape Fear River by removing or weakening limits on arsenic, mercury, and other coal ash pollutants.
DEQ should require Duke Energy to stop its pollution.
The current permit as written would do little to protect our waterways Please strengthen the draft NPDES permit.
Thank you.
Sincerely,
Dr Fred Milano
)0 Ashwood Drive
Leland, NC 28451

ay, David
From: Ronald Leuchs <ronald leuchs@gmail com>
Sent: Wednesday, June 21, 2017 3.01 PM
To: SVC_DENR publiccomments
Subject: Sutton Coal Ash Permits
Dear DEQ,
Please do not allow Duke Energy to pollute our waterways with toxic coal ash pollution. Our community faces too many
uncertainties regarding the safety of our water Sutton Lake is an important fishing lake that many people depend on to
feed their families, with a long history of coal ash pollution problems The permit would allow contaminated wastewater
to flow into the Cape Fear River by removing or weakening limits on arsenic, mercury, and other coal ash pollutants.
DEQ should require Duke Energy to stop its pollution.
The current permit as written would do little to protect our waterways Please strengthen the draft NPDES permit.
Thank you
Sincerely,
Ronald Leuchs
13 South Moorings Drive
Wilmington, NC 28405
9104436157

ay, David
From: Donna Wood <donnawwood@gmail com>
Sent: Wednesday, June 21, 2017 3 05 PM
To: SVC_DENR publiccomments
Subject: Sutton Steam Station Permits
Dear DEQ,
I am very concerned about the unacceptably weak draft permit at the Sutton Steam Station As written, the draft
permits would weaken and remove current discharge limits for arsenic, mercury, and other coal ash pollutants from
Duke Energy's lagoons into Sutton Lake and the Cape Fear River. DEQ would allow Duke Energy to dump nearly 7 times
more toxic arsenic pollution from its coal ash lagoons into Sutton Lake and the Cape Fear River by dramatically
weakening the daily maximum limit in the existing permit.
Please strengthen protections for these important waters.
Thank you.
Sincerely,
Donna Wood
3 Berwyn Rd
wilmington, NC 28409
9107998319

ay, David
From: Donna Wood <donnawwood@gmail com>
Sent: Wednesday, June 21, 2017 3 05 PM
To: SVC_DENR publiccomments
Subject: Sutton Steam Station Permits
Dear DEQ,
I am very concerned about the unacceptably weak draft permit at the Sutton Steam Station. As written, the draft
permits would weaken and remove current discharge limits for arsenic, mercury, and other coal ash pollutants from
Duke Energy's lagoons into Sutton Lake and the Cape Fear River. DEQ would allow Duke Energy to dump nearly 7 times
more toxic arsenic pollution from its coal ash lagoons into Sutton Lake and the Cape Fear River by dramatically
weakening the daily maximum limit in the existing permit.
Please strengthen protections for these important waters.
Thankyou
Sincerely,
Donna Wood
3 Berwyn Rd
wilmington, NC 28409
9107998319

- - ay, David
From: Connie Zuback <conniezuback@gmail com>
Sent: Wednesday, June 21, 2017 3 39 PM
To: SVC_DENR publiccomments
Subject: Sutton Coal Ash Permits
Dear DEQ,
Please do not allow Duke Energy to pollute our waterways with toxic coal ash pollution. Our community faces too many
uncertainties regarding the safety of our water Sutton Lake is an important fishing lake that many people depend on to
feed their families, with a long history of coal ash pollution problems The permit would allow contaminated wastewater
to flow into the Cape Fear River by removing or weakening limits on arsenic, mercury, and other coal ash pollutants
DEQ should require Duke Energy to stop its pollution
The current permit as written would do little to protect our waterways Please strengthen the draft NPDES permit
Thank you.
Sincerely,
Connie Zuback
D2 Camellia Dr
wilmington, NC 28403

ay, David
From: Chase Hamilton <barrychasel7@gmail com>
Sent: Wednesday, June 21, 2017 3.47 PM
To: SVC_DENR publiccomments
Subject: Sutton Steam Station Permits
Dear DEQ,
I am very concerned about the unacceptably weak draft permit at the Sutton Steam Station. As written, the draft
permits would weaken and remove current discharge limits for arsenic, mercury, and other coal ash pollutants from
Duke Energy's lagoons into Sutton Lake and the Cape Fear River. DEQ would allow Duke Energy to dump nearly 7 times
more toxic arsenic pollution from its coal ash lagoons into Sutton Lake and the Cape Fear River by dramatically
weakening the daily maximum limit in the existing permit.
Please strengthen protections for these important waters
Thank you.
Sincerely,
Chase Hamilton
56 William Louis Drive
Wilmington, NC 28405

ay, David
From: Karen Langelier <klang4678@gmail com>
Sent: Wednesday, June 21, 2017 3 47 PM
To: SVC_DENR publiccomments
Subject: Sutton Steam Station Permits
Dear DEQ,
I am very concerned about the unacceptably weak draft permit at the Sutton Steam Station. As written, the draft
permits would weaken and remove current discharge limits for arsenic, mercury, and other coal ash pollutants from
Duke Energy's lagoons into Sutton Lake and the Cape Fear River. DEQ would allow Duke Energy to dump nearly 7 times
more toxic arsenic pollution from its coal ash lagoons into Sutton Lake and the Cape Fear River by dramatically
weakening the daily maximum limit in the existing permit
Please strengthen protections for these important waters.
Thank you.
Sincerely,
Karen Langelier
13A Saint Johns CT
Wilmington, NC 28403
6033406097

ay, David
From: Charles Rosenberg <charlesrosenberg22@gmail com>
Sent: Wednesday, June 21, 2017 4 01 PM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thankyou
Sincerely,
Charles Rosenberg
9 Meherrin Ln
Imington, NC 28403
4109634913

ay, David
From: Deborah Rosenberg <dlr001@me com>
Sent: Wednesday, June 21, 2017 4 02 PM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River. The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that.
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways
Thank you.
Sincerely,
Deborah Rosenberg
9 Meherrin
Imington, NC 28403
4438047345

ay, David
From: William St George <[e-mail]>
Sent: Wednesday, June 21, 2017 4 27 PM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways
Thankyou
Sincerely,
William St George
17 Camellia Dr
Imington, NC 28403

ay, David
From: Brett Little <bclittle0107@gmail com>
Sent: Wednesday, June 21, 2017 4.39 PM
To: SVC_DENR publiccomments
Subject: Sutton Coal Ash Permits
Dear DEQ,
Please do not allow Duke Energy to pollute our waterways with toxic coal ash pollution. Our community faces too many
uncertainties regarding the safety of our water. Sutton Lake is an important fishing lake that many people depend on to
feed their families, with a long history of coal ash pollution problems. The permit would allow contaminated wastewater
to flow into the Cape Fear River by removing or weakening limits on arsenic, mercury, and other coal ash pollutants.
DEQ should require Duke Energy to stop its pollution.
The current permit as written would do little to protect our waterways. Please strengthen the draft NPDES permit.
Thank you.
Sincerely,
Brett Little
11 Bennington Road
Fayetteville, NC 28303
9106245049

ay, David
From: Rhonda Tighe <tigheger@gmail com>
Sent: Wednesday, June 21, 2017 5 21 PM
To: SVC_DENR publiccomments
Subject: Sutton Coal Ash Permits
Dear DEQ,
Please do not allow Duke Energy to pollute our waterways with toxic coal ash pollution. Our community faces too many
uncertainties regarding the safety of our water. Sutton Lake is an important fishing lake that many people depend on to
feed their families, with a long history of coal ash pollution problems. The permit would allow contaminated wastewater
to flow into the Cape Fear River by removing or weakening limits on arsenic, mercury, and other coal ash pollutants.
DEQ should require Duke Energy to stop its pollution
The current permit as written would do little to protect our waterways. Please strengthen the draft NPDES permit
Thank you.
Sincerely,
Rhonda Tighe
01 W Yacht Dr
Oak island, NC 28465

ay, David
From: Nancy Sharp <nancysharp53@gmail com>
Sent: Wednesday, June 21, 2017 6 20 PM
To: SVC_DENR.publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that.
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thankyou
Sincerely,
Nancy Sharp
`-9 Holbrook Ave
Imington, NC 28412
9106126653

3y, David
From:
Mark Hurmence <Gocubsmark@aol com>
Sent:
Wednesday, June 21, 2017 7 58 PM
To:
SVC_DENR publiccomments
Subject:
Sutton Coal Ash Permits
Dear DEQ,
Please do not allow Duke Energy to pollute our waterways with toxic coal ash pollution. Our community faces too many
uncertainties regarding the safety of our water. Sutton Lake is an important fishing lake that many people depend on to
feed their families, with a long history of coal ash pollution problems The permit would allow contaminated wastewater
to flow into the Cape Fear River by removing or weakening limits on arsenic, mercury, and other coal ash pollutants
DEQ should require Duke Energy to stop its pollution
The current permit as written would do little to protect our waterways. Please strengthen the draft NPDES permit.
Thank you
Sincerely,
Mark Hurmence
B Spencer Farlow Drive
Carolina Beach, NC 28428
9104584040

ay, David
From: Sondra Vitols <vitols@mindspring com>
Sent: Thursday, June 22, 2017 7.48 AM
To: SVC_DENR publiccomments
Subject: Sutton Coal Ash Permits
Dear DEQ,
Please do not allow Duke Energy to pollute our waterways with toxic coal ash pollution Our community faces too many
uncertainties regarding the safety of our water. Sutton Lake is an important fishing lake that many people depend on to
feed their families, with a long history of coal ash pollution problems The permit would allow contaminated wastewater
to flow into the Cape Fear River by removing or weakening limits on arsenic, mercury, and other coal ash pollutants.
DEQ should require Duke Energy to stop its pollution.
The current permit as written would do little to protect our waterways. Please strengthen the draft NPDES permit.
Thank you
Sincerely,
Sondra Vitols
J8 Bald Eagle Lane
Wilmington, NC 28411

ay, David
From: Martin Hazeltine <mhazeltine@atmc net>
Sent: Thursday, June 22, 2017 7 56 AM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River. The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thankyou
Sincerely,
Martin Hazeltine
--14 Dunbar Dr
iset Beach, NC 28468
9105752546

ay, David
From: Taylor Hill <memai106on@yahoo com>
Sent: Thursday, June 22, 2017 1019 AM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thankyou
Sincerely,
Taylor Hill
-" Pinecrest Parkway
Imington, NC 28401
9106165364

iy, David
From: Julia Martinelli <Jdmartinelli222@yahoo com>
Sent: Thursday, June 22, 2017 1104 AM
To: SVC_DENR publiccomments
Subject: Sutton Steam Station Permits
Dear DEQ,
I am very concerned about the unacceptably weak draft permit at the Sutton Steam Station. As written, the draft
permits would weaken and remove current discharge limits for arsenic, mercury, and other coal ash pollutants from
Duke Energy's lagoons into Sutton Lake and the Cape Fear River. DEQ would allow Duke Energy to dump nearly 7 times
more toxic arsenic pollution from its coal ash lagoons into Sutton Lake and the Cape Fear River by dramatically
weakening the daily maximum limit in the existing permit.
Please strengthen protections for these important waters
Thank you.
Sincerely,
Julia Martinelli
18 Landing Drive, SW
Sunset Beach, NC 28468

ay, David
From: L Dawson<nutridoc@foodphysicsandbodydynamics com>
Sent: Thursday, June 22, 2017 11:10 AM
To: SVC_DENR publiccomments
Subject: Potential solution for Sutton Lake pollution treatments
Importance: High
Please check out Jack E. Barker and www.Innovativeh2o com Located In Colorado.
Call & Tell them I sent you They can help you discover a more affordable and safe method to treat the water.
May you and yours Be In Good Health,
Laura L Dawson, Dipl Ac, L Ac , CEO
Food Physics & Body Dynamics LLC
Schedule a meeting
Melaleuca. The Wellness Comoanv
Eniva Inc, Taking Wellness to the World
This e-mail message, and any attachments, is intended only for the use of the individual or entity identified in the alias address of this
message and may contain information that is confidential, privileged and subject to legal restrictions and penalties regarding its unauthorized
losuie and use Any unauthorized review, copying, disclosure, use or distribution is strictly prohibited If you have received this e-mail message
,rror, please notify the sender immediately by reply e-mail and delete this message, and any attachments, from your system Thank you

7/3/2017
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,ay, David
From: Marissa Blackburn <marissa [e-mail]>
Sent: Thursday, June 22, 2017 12.35 PM
To: SVC_DENR.publiccomments
Subject: Sutton Steam Station Permits
Dear DEQ,
I am very concerned about the unacceptably weak draft permit at the Sutton Steam Station. As written, the draft
permits would weaken and remove current discharge limits for arsenic, mercury, and other coal ash pollutants from
Duke Energy's lagoons into Sutton Lake and the Cape Fear River. DEQ would allow Duke Energy to dump nearly 7 times
more toxic arsenic pollution from its coal ash lagoons into Sutton Lake and the Cape Fear River by dramatically
weakening the daily maximum limit in the existing permit.
Please strengthen protections for these important waters.
Thank you
Sincerely,
Marissa Blackburn
.,,11 Dorrington Dr
Wilmington, NC 28412
4105047535

iy, David
From: Judy Husketh <Jwhusketh@yahoo com>
Sent: Thursday, June 22, 2017 2.59 PM
To; SVC_DENR publiccomments
Subject: Sutton Steam Station Permits
Dear DEQ,
I am very concerned about the unacceptably weak draft permit at the Sutton Steam Station. As written, the draft
permits would weaken and remove current discharge limits for arsenic, mercury, and other coal ash pollutants from
Duke Energy's lagoons into Sutton Lake and the Cape Fear River DEQ would allow Duke Energy to dump nearly 7 times
more toxic arsenic pollution from its coal ash lagoons into Sutton Lake and the Cape Fear River by dramatically
weakening the daily maximum limit in the existing permit.
Please strengthen protections for these important waters
Thank you.
Sincerely,
Judy Husketh
x.,30 Allen's lane
Wilmington, NC 28403

iy, David
From: Pamela Kesler <pskesler5@gmail com>
Sent: Thursday, June 22, 2017 6 58 PM
To: SVC_DENR publiccomments
Subject: Sutton Steam Station Permits
Dear DEQ,
I am very concerned about the unacceptably weak draft permit at the Sutton Steam Station. As written, the draft
permits would weaken and remove current discharge limits for arsenic, mercury, and other coal ash pollutants from
Duke Energy's lagoons into Sutton Lake and the Cape Fear River. DEQ would allow Duke Energy to dump nearly 7 times
more toxic arsenic pollution from its coal ash lagoons into Sutton Lake and the Cape Fear River by dramatically
weakening the daily maximum limit in the existing permit.
Please strengthen protections for these important waters
Thank you.
Sincerely,
Pamela Kesler
-Lj04White Memorial Church Rd
Willow Spring, NC 27592
9106125546

iy, David
From:
CapeFear Water Quality <waterqua I ity@capefearsurfrider org>
Sent:
Thursday, June 22, 2017 6.27 PM
To:
SVC_DENR publiccomments
Cc:
Kevin Piacenza, Mara Dias
Subject:
Waste Water Permitting Sutton
Regarding: Sutton Draft WW Permit NC # 0001422Duke Power, NC DEQ, Sutton Draft Permit Application
In light of all else occuring with point source contaminents in the Cape Fear River; considering that over a
quarter million people live directly downstream, I find it unacceptable that there can be any discharge of
industrial contaminent into the river. All of these products have known health risks at even "acceptable" levels.
The contaminents, particularly those allowed from Outfall 001 should be 100% contained on the property. It
boggles the mind that we attempt to regulate the manner in which we deliberatly poison ourselves.
Peter Gillman -Bryan
Water Quality Coordinator, Cape Fear Chapter, Surfrider Foundation

3y, David
From: Donna Maher <[e-mail]>
Sent: Thursday, June 22, 2017 9:30 PM
To: SVC_DENR publiccomments
Subject: Sutton Permits
Dear DEQ,
The current draft permit for Sutton drastically weakens and removes important protections. As written, the permit
would allow more arsenic, mercury, and other coal ash pollutants from Duke Energy's lagoons into Sutton Lake and the
Cape Fear River. The Clean Water Act prohibits a new discharge permit from weakening the pollution limits in the
existing permit, but DEQ is proposing to do exactly that
Please strengthen the proposed NPDES permits and require a strict limit on the discharges allowed in our waterways.
Thank you.
Sincerely,
Donna Maher
17 Forest View Circle
and, NC 28451

iy, David
From: Ogallo, LeToya Fields <Letoya Ogallo@duke-energy com>
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_permlt6-22 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 Ogallo I Environmental Specialist
Duke Energy NPDES Permitting and Compliance
410 South Wilmington Street, Raleigh NC 27601
o 919 546 6647 1 C 919 608 1793 1 f 919 546 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.
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 2 of 2
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.
S. 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.
7. 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 Letoya.Ogallo duke -energy cam or
• Mr Kent Tyndall, Environmental Professional for the L. V. Sutton Energy Complex Plant; phone
[phone] or e-mail Kent.TyndallPduke-energy.com.
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,
J."� �E 4tv�IL
Jesse E. Huntley, II
Station Manager

ay, David
From: Nick Torrey <ntorrey@selcnc org>
Sent: Thursday, June 22, 2017 5 47 PM
To: Zimmerman, Jay, SVC_DENR publiccomments, Lane, Bill F
Cc: Pat Dunlop
Subject: Sutton NPDES comments
Attachments: 2017-06-22 Sutton NPDES comments pdf
Mr. Zimmerman and Mr. Lane,
Attached please find comments from the Southern Environmental Law Center on behalf of Cape Fear River Watch on the
draft NPDES permit for Duke Energy's Sutton facility.
Thanks for your consideration,
Nick
Nicholas S Torrey
Staff Attorney
Southern Environmental Law Center
601 West Rosemary Street, Suite 220
Chapel Hill, NC 27516
—19) 967-1450
vw Southern Environment org

June 22, 2017
VIA EMAIL
Mr S. Jay Zimmerman, Director
N C. DEQ Division of Water Resources
1617 Mail Service Center
Raleigh, N.0 , 27699-1617
jay.zimmerman@ncdenr gov
publiccomments@ncdenr gov
Re: 2017 Draft NPDES Wastewater Permit — Sutton Plant, #NC0001422
Dear Mr. Zimmerman.
On behalf of Cape Fear River Watch, we submit the following comments on the draft
National Pollutant Discharge Elimination System ("NPDES") permit noticed for public comment
by the North Carolina Department of Environmental Quality ("DEQ"), Division of Water
Resources ("DWR"), which would significantly weaken the permit by allowing Duke Energy
Progress LLC ("Duke Energy") to discharge increased amounts of arsenic, mercury, and other
pollution into Sutton Lake and the Cape Fear River
Introduction
In numerous public hearings last year, thousands of citizens made it clear that the public
wants DEQ to protect North Carolina families from Duke Energy's coal ash pollution. Yet in the
current draft permit, DEQ bends over backwards to weaken limits on Duke Energy's pollution,
with no valid basis and when even Duke Energy itself has not asked for these changes.
DEQ's weakened limits on toxic metals and other pollutants are also inappropriate
because Duke Energy will be adding additional streams of coal ash contaminated wastewater to
the discharges from its coal ash lagoons The permit and its Fact Sheet contemplate Duke
Energy will route polluted groundwater and coal ash landfill leachate wastewater through these
outfalls, making it all the more important to maintain or strengthen the existing limits, not
drastically weaken them as DEQ is proposing to do.
Important Public Water Resources At Risk From DEQ's Actions
Sutton Lake is an extremely popular fishing location. It is frequented both by sport
fishermen and by subsistence fishermen, who catch fish that are eaten by themselves and their
families. See Mike Marsh, "Action Ramps Up at Sutton Lake," Raleigh News & Observer (Apr.
4, 2013) (describing the lake's parking lot as "full to overflowing" and quoting anglers drawn by
"fish that were good to eat.") The fishery at Sutton Lake is managed by the North Carolina
Wildlife Resources Commission with financial support from federal funds and grants from the

U S Fish and Wildlife Service's Sport Fish Restoration Program. These entities encourage the
public to fish at Sutton Lake and have renovated the boat ramps to provide greater public access.
The Cape Fear River is one of North Carolina's most important water resources. It flows
through Wilmington and is heavily used for fishing, recreation, and drinking water supplies.
People throughout the region, North Carolinians from throughout the state, and visitors to North
Carolina make use of its waters and consume fish from the river.
DEQ's treatment of Sutton Lake and the Cape Fear River also raises serious
environmental justice concerns Minority fishermen fish frequently in Sutton Lake and the Cape
Fear River The minority population in a half -mile, mile, 2 -mile and 3 -mile radius of Sutton
Steam Station is significantly higher than the state or county wide average. Executive Order
12898 specifically provides, with regard to subsistence fishing, that where an agency action may
affect fish, vegetation, or wildlife, that agency action may also affect subsistence patterns of
consumption and indicate the potential for disproportionately high and adverse human health or
environmental effects on low-income and minority populations. Executive Order 12898 § 4 —
401
1. DEQ Has Impermissibly Weakened the Pollution Limits in the Draft Permit
The Clean Water Act's NPDES permitting program is structured around progressive
improvements in pollution control over time. The Clean Water Act permit is a National
Pollutant Discharge Elimination System permit that is required to make progress towards
Congress's "national goal" of eliminating discharges of pollutants to waters of the United States.
33 U S C. §§ 1251(a)(1).
For this reason, the Clean Water Act includes anti -backsliding requirements to ensure
that the limits and conditions imposed new or modified NPDES permits for a facility are at least
as stringent as those in previous permits 33 U.S.C. § 1342(0); 40 C.F.R. § 122 44(1)(1)
("[W]hen a permit is renewed or reissued, interim effluent limitations, standards or conditions
must be at least as stringent as the final effluent limitations, standards, or conditions in the
previous permit ....").
In total disregard of this requirement, the draft permit impermissibly weakens the
established limits in the existing permit for the following coal ash pollutants:
• Arsenic — Arsenic is a known carcinogen that causes multiple forms of cancer in humans.
It is also a toxic pollutant, 40 C.F R § 401.15, and a priority pollutant, 40 C.F.R. Part 423
App'x A. Arsenic is also associated with non -cancer health effects of the skin and the
nervous system
DEQ's draft inexplicably weakens the limits for Outfalls 001 (both Decanting/Normal
Operation and Dewatering) and 004 from a daily maximum limit of 50 ug/L to 340 ug/L,
a nearly sevenfold increase in toxic arsenic pollution
2

The Fact Sheet offers no valid justification for this change. It states only that the increase
is supposedly "based on the updates to the North Carolina standards," and refers to the
arsenic limits as "water quality based effluent limitations " Fact Sheet at 5.
However, the existing permit contains technology-based limits on arsenic and other
pollutants that Duke Energy has accepted and is bound by. Indeed, Duke Energy has not
requested that the arsenic limits be weakened. In its application materials, Duke Energy
requests certain changes to the permit, but it does not ask for DEQ to weaken the arsenic
limits. Of course, a request from the applicant would not on its own justify such a
change, but the fact that Duke Energy has not even made the request simply highlights
the absurdity of DEQ weakening the permit for no reason. DEQ has no business
unilaterally weakening pollution limits that it has already imposed based on available
treatment technology— limits that Duke Energy accepts and is currently complying with,
and that protect the important fishing and water resources of Sutton Lake and the Cape
Fear River.
In addition, the arsenic limit in the draft permit makes no mathematical sense. The
permit purports to allow a daily maximum arsenic concentration of 340 ug/L and a
monthly average of 10 ug/L. The discharge is sampled weekly, so the monthly average
would be based on four samples. Thus, a single sample at the allowed daily maximum of
340 ug/L would exceed the entire monthly average limit by more than eight times (85
ug/L), even if the other three samples contained no arsenic. In other words, DEQ has not
only weakened the daily limit drastically, but also is proposing to negate the monthly
average limit for arsenic and render it meaningless.
To comply with the anti -backsliding requirements of the Clean Water Act, DEQ must
abandon this approach and maintain the current arsenic limits for these outfalls and also
apply the arsenic limits from the existing permit to Outfall 008
Mercury — Mercury is a well-known neurotoxicant and is listed as a toxic pollutant, 40
C F R § 401.15. It has the dangerous capacity to bioaccumulate, or build up in animal
tissue. When mercury leaches from coal ash into the soil or water, it is converted by
bacteria into methylmercury, an organic form that can be absorbed by small organisms
and the larger organisms that eat them. As it moves up the food chain, the concentration
of methylmercury increases. Mercury is particulary toxic to the developing nervous
system. Exposure during gestation, infancy, or childhood can cause developmental delays
and abnormalities, reduced IQ and mental retardation, and behavioral problems.
DEQ has entirely removed the mercury limits for decanting and so-called normal
operation of Outfalls 001, 002, and 004. Again, there is absolutely no valid basis for this
weakening of the permit, which violates the anti -backsliding requirement. The permit's
Fact Sheet states only that these limits were removed based on the results of an
undisclosed "Mercury Evaluation" that is not included with the permitting materials.
Fact Sheet at 5 Once again, Duke Energy has not requested that the mercury limits be
removed. The current permit contains valid limits based on existing, in-place treatment
technology, and Duke Energy has accepted and is complying with these limits There is

no justification for removing them and impermissibly weakening the permit If Duke
Energy is not expected to discharge mercury going forward, then it will have no trouble
complying with the limits. But there is no reason to remove them, especially given the
legacy of coal ash contamination of Sutton Lake and the Cape Fear River.
Lead — Lead is a very potent neurotoxicant that is highly damaging to the nervous
system Health effects associated with exposure to lead include, but are not limited to,
neurotoxicity, developmental delays, hypertension, impaired hearing acuity, impaired
hemoglobin synthesis, and male reproductive impairment. Importantly, many of lead's
health effects may occur without overt signs of toxicity. Lead is also classified by the
EPA as a "probable human carcinogen."
DEQ has removed the lead limit for decanting and normal operation of Outfall 001 into
the Cape Fear River In addition, DEQ has more than doubled the daily maximum limit
for dewatering from 33.8 ug/L to 75.4 ug/L. Once again, Duke Energy has not requested
this change and once again, there is no justification for it. The Fact Sheet states that the
change is based on a "Reasonable Potential Analysis" that is not part of the permit
materials. However, the limits in place now are being met with existing, in-place
treatment technology, and there is no justification for weakening them
In addition, DEQ's permit creates mathematical impossibilities. It purports to authorize a
daily maximum lead limit of 75.4 ug/L and a monthly average limit of 2.94 ug/L. Based
on the weekly samples contemplated in the permit, a single daily maximum sample of
75.4 ug/L would exceed the monthly average limit by over six times (18.9 ug/L), even if
all the other samples contained zero lead.
• Cadmium — Chronic exposure to cadmium, a toxic pollutant, 40 C.F R. § 401.15, can
result in kidney disease and obstructive lung diseases such as emphysema Cadmium
may also be related to increased blood pressure (hypertension) and is a possible lung
carcinogen. Cadmium affects calcium metabolism and can result in bone mineral loss
and associate bone loss, osteoporosis, and bone fractures.
DEQ has removed the cadmium limit from Outfall 001's decanting/normal operations
limits as well. Duke Energy has not requested this change and there is no justification for
removing this limit from the existing permit.
Iron — Iron can render water unusable by imparting a rusty color and a metallic taste and
causing sedimentation and staining. DEQ has removed the iron limit for Outfalls 001,
002, and 004. The Fact Sheet (p. 5) states that this change is based on "updates to the
North Carolina standards," but again, nothing in those water quality standards justifies
weakening the current limits based on existing technology that are in place in the current
permit.
0

2. DEQ Has Failed to Disclose an Updated Compliance Boundary
The groundwater rules direct that "[t]he [compliance] boundary shall be established by
the Director, or his designee at the time of permit issuance " 15A NCAC 02L 0107(c)
(emphasis added). Yet the draft permit as distributed to the public for comment includes no map
designating a compliance boundary for the Sutton facility. This is a critical omission.
The draft permit must include an updated compliance boundary to reflect the newly -
recognized status of Sutton Lake as a water of the State. Previous compliance boundary maps
have incorrectly drawn the compliance boundary extending into Sutton Lake and the old
streambed of Catfish Creek, a navigable water of the State The compliance boundary must be
redrawn so that it does not extend into these waters.
We raised this issue in our comments on the 2015 NPDES permit, yet DEQ still has not
made an updated compliance boundary map publically available, despite representing to the N.C.
Superior Court that it would do so in connection with new draft NPDES permits for Duke
Energy's coal ash sites. In a summary judgment hearing on December 19, 2016, counsel for
DEQ argued that the court should not make any determination about the location of compliance
boundaries at Duke Energy's coal ash sites because the boundaries would be determined — and
disclosed to the public — through the NPDES permitting process and would then be subject to
challenge through the administrative appeals process for those NPDES permits:
The compliance boundary, quote, "is established by the director or his designee at
the time of permit issuance." And that's important here because those are
currently being established in the [NPDES] process."
DEQ ... is charged with making decisions regarding compliance boundaries at
the time of permit issuance. And it is in the [NPDESJ permits [that] the
compliance boundaries are set by the director and when these decisions have
been made intervenors and other aggrieved persons are free to challenge those
provisions pursuant to the [Administrative Procedure] act ..."
See Excerpts from Summary Judgment Hearing Transcript (Dec. 19, 2016), attached as
Exhibit 1 (emphases added).
Instead — directly contrary to its representations to the Superior Court — DEQ has released
a draft NPDES permit with no compliance boundary map, I giving the public no idea of where
DEQ locates the compliance boundary in relation to Sutton Lake, and thus denying the general
public any opportunity to evaluate the boundary or comment on it as part of the required public
participation process In other words, DEQ is denying the public the opportunity to
meaningfully comment on this vital aspect of Duke Energy's coal ash wastewater treatment
system, and appears to have misrepresented its actions to the N.C. Superior Court.
1 As DEQ's Public Notice explains, DEQ posts its draft permits and related materials on a publicly -available
website, https //goo gl/3 Wt7MF For the Sutton permit, DEQ has posted the draft permit, a fact sheet, a public
notice, an outfalls map, and Duke Energy's renewal application None of these materials contains a compliance
boundary map.

3. DEQ Is Proposing to Further Weaken the Permit by Allowing Duke Energy to Use
Dilution to Meet the Effluent Limits
In addition to weakening numerous limits for toxic coal ash pollutants, DEQ's draft
permit also appears to allow Duke Energy to impermissibly dilute its ash pond discharges to the
Cape Fear River. Condition A(27)(2) of the current Sutton permit (A(28)(2) in the draft permit)
states, "All effluent samples for all external outfalls shall be taken at the most accessible location
after the final treatment but prior to discharge to waters of the U.S. (40 CFR 122.41(j))."
Similarly, other Duke Energy permits explain that ash basin discharge samples "shall be taken
prior to mixing with other waste streams." 'E g, 2009 Mayo NPDES Permit #NC0038377 at
A(3)-(4) (emphasis added).
The -Fact Sheet states that "Outfall 001 is discharging through the mixing box that was
set-up to concurrently discharge ash pond wastewater and water from Sutton Lake. The
compliance point for Outfall 001 is located within the mixing box."
By proposing to allow Duke Energy to measure compliance for Outfall 001 within this
mixing box, DEQ appears to be violating these common-sense sampling requirements that
prohibit dilution and sampling after discharge to waters of the United States. Sutton Lake is a
water of North Carolina and the United States, as DEQ recognizes in the Sutton permit, and
sampling the Outfall 001 discharge after mixing with Sutton Lake water is a violation of
Condition A(27) of the current permit. Duke Energy must comply with the effluent limits for
Outfall 001 prior to diluting its ash pond discharges with the jurisdictional water of Sutton Lake.
Thank you for your consideration of these comments.
cc- Bill Lane, DEQ General Counsel
Sincerely,
/s/ Nicholas S. Torrey
Nicholas S. Torrey
Staff Attorney
Frank S. Holleman III
Senior Attorney
Con

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STATE OF NORTH CAROLINA
COUNTY OF WAKE
STATE OF NORTH CAROLINA ex rel.
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENTAL QUALITY, DIVISION
OF WATER RESOURCES,
Plaintiff,
v.
IN THE GENERAL COURT OF JUSTICE
SUPERIOR COURT DIVISION
13 CVS 11032
ROANOKE RIVER BASIN ASSOCIATION,
SIERRA CLUB, WATERKEEPER ALLIANCE,
CAPE FEAR RIVER WATCH, INC., NEUSE
RIVERKEEPER FOUNDATION, AND WINYAH
RIVERS FOUNDATION,
Plaintiff -Intervenors,
V.
DUKE ENERGY PROGRESS, LLC,
Defendant. TRANSCRIPT
VOLUME 1 of 1
COUNTY OF MECKLENBURG
STATE OF NORTH CAROLINA ex rel.
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENTAL QUALITY, DIVISION
OF WATER RESOURCES,
Plaintiff,
CATAWBA RIVERKEEPER FOUNDATION, INC.,
APPALACHIAN VOICES, YADKIN RIVERKEEPER,
MOUNTAINTRUE, DAN RIVER BASIN ASSOCIATION,
ROANOKE RIVER BASIN ASSOCIATION, SOUTHERN
ALLIANCE FOR CLEAN ENERGY, AND WATERKEEPER
ALLIANCE,
Plaintiff -Intervenors,
V.
KE ENERGY CAROLINAS, LLC,
Defendant.
Jacqueline M. Sullivan, RPR, CRR
Official Court Reporter
13 CVS 14661

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ITITLE PAGE, con't.
Transcript of proceedings in the
General Court of Justice, Superior Court Division, Wake County,
North Carolina, at the December 19, 2016 Session, before the
Honorable Paul C. Ridgeway, Judge Presiding.
(APPEARANCES:
FRANCISCO J. BENZONI, ESQ.
HILL DAVIS, ESQ.
114 W. Edenton Street
Post Office Box 629
Raleigh, NC 27602-0629
On behalf of the Plaintiff
D.J. GERKEN, ESQ.
PATRICK HUNTER, ESQ.
FRANK HOLLOMAN, ESQ.
Southern Environmental Law Center
22 South Pack Square, Suite 700
Asheville, NC 28801-3494
On behalf of the Plaintiff -Intervenors.
NASH E. LONG, ESQ.
BRENT ROSSER, ESQ.
Hunton & Williams, LLP
Bank of America Plaza
Suite 3500
101 South Tryon Street
Charlotte, NC 28280
Jacqueline M. Sullivan, RPR, CRR
Official Court Reporter
P.O. Box 351
Raleigh, North Carolina 27602
[phone]
Jacqueline M. Sullivan, RPR, CRR
Official Court Reporter
2

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150
THE COURT: I have it.
MR. BENZONI: Tab three. This is for systems
individually permitted prior to December 1983, quote:
The compliance boundary is established at a
horizontal distance of five hundred feet from the waste
boundary or at the property boundary, whichever is closer to
the source.
And so in order to understand that specification,
because it's five hundred feet from the waste boundary, we've
got to look at the definition of "waste boundary," and the
waste boundary is defined as the perimeter of a permitted
waste disposal area, unquote, and that's the 150226.
One other important provision is 107(c), which
states:
The compliance boundary, quote, "is established by
the director or his designee at the time of permit issuance."
And that's important here because those are currently being
established in the MPSD process.
Those are going to form the backdrop of our
discussion one and two.
In the first issue intervenors maintain that the
compliance boundaries at the facilities must stop at the stop
river at Cliffside like Wiley and at end and Lake Gorman at
Marshall.
First they argued that Duke Energy's own
Jacqueline M. Sullivan, RPR, CRR
Official Court Reporter

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152
the statute says that and there's no reason for the Court to
offer interpretation of the plain -language statues. On the
contrary, the Supreme Court held in Carolina Light Power
Company verse City of Asheville: Wherever statutory language
is clear and unambiguous the Court does not engage in but
must apply the statute to.
Here there's no reason for judicial construction.
The statute is clear and plain and unambiguous on its face.
The issue here to DEQ is intervenors' attempt to apply the
law to a factual uncritical set of circumstances completion.
As noted, as DEQ it is charged with making decisions
regarding compliance boundaries at the time of permit
issuance. And it is in the MPDS permits of the compliance
boundaries are set by the director and when these decisions
have been made intervenors and other aggrieved persons are
free to challenge those provisions pursuant to the procured
administration act as some of the intervenors have in this
case with regards to the Marshall facility.
So DEQ respectfully requests that the Court refrain
from making any decisions. DEQ is charged with making those
decisions.
THE COURT: So on the one hand the statutes are
clear and need interpretation on the other hand that you saw
it should be this and that saying it should be something
else?
Jacqueline M. Sullivan, RPR, CRR
Official Court Reporter

June 22, 2017
VIA EMAIL
Mr. S. Jay Zimmerman, Director
N.0 DEQ Division of Water Resources
1617 Mail Service Center
Raleigh, N.C., 27699-1617
day zimmerman@ncdenr gov
publiccomments@ncdenr gov
Re: 2017 Draft NPDES Wastewater Permit — Sutton Plant, #NC0001422
Dear Mr. Zimmerman:
On behalf of Cape Fear River Watch, we submit the following comments on the draft
National Pollutant Discharge Elimination System ("NPDES") permit noticed for public comment
by the North Carolina Department of Environmental Quality ("DEQ"), Division of Water
Resources ("DWR" ), which would significantly weaken the permit by allowing Duke Energy
Progress LLC ("Duke Energy") to discharge increased amounts of arsenic, mercury, and other
pollution into Sutton Lake and the Cape Fear River.
Introduction
In numerous public hearings last year, thousands of citizens made it clear that the public
wants DEQ to protect North Carolina families from Duke Energy's coal ash pollution. Yet in the
current draft permit, DEQ bends over backwards to weaken limits on Duke Energy's pollution,
with no valid basis and when even Duke Energy itself has not asked for these changes.
DEQ's weakened limits on toxic metals and other pollutants are also inappropriate
because Duke Energy will be adding additional streams of coal ash contaminated wastewater to
the discharges from its coal ash lagoons. The permit and its Fact Sheet contemplate Duke
Energy will route polluted groundwater and coal ash landfill leachate wastewater through these
outfalls, making it all the more important to maintain or strengthen the existing limits, not
drastically weaken them as DEQ is proposing to do.
Important Public Water Resources At Risk From DEQ's Actions
Sutton Lake is an extremely popular fishing location. It is frequented both by sport
fishermen and by subsistence fishermen, who catch fish that are eaten by themselves and their
families. See Mike Marsh, "Action Ramps Up at Sutton Lake," Raleigh News & Observer (Apr.
4, 2013) (describing the lake's parking lot as "full to overflowing" and quoting anglers drawn by
"fish that were good to eat."). The fishery at Sutton Lake is managed by the North Carolina
Wildlife Resources Commission with financial support from federal funds and grants from the

U.S. Fish and Wildlife Service's Sport Fish Restoration Program These entities encourage the
public to fish at Sutton Lake and have renovated the boat ramps to provide greater public access.
The Cape Fear River is one of North Carolina's most important water resources. It flows
through Wilmington and is heavily used for fishing, recreation, and drinking water supplies.
People throughout the region, North Carolinians from throughout the state, and visitors to North
Carolina make use of its waters and consume fish from the river.
DEQ's treatment of Sutton Lake and the Cape Fear River also raises serious
environmental justice concerns Minority fishermen fish frequently in Sutton Lake and the Cape
Fear River. The minority population in a half -mile, mile, 2 -mile and 3 -mile radius of Sutton
Steam Station is significantly higher than the state or county wide average Executive Order
12898 specifically provides, with regard to subsistence fishing, that where an agency action may
affect fish, vegetation, or wildlife, that agency action may also affect subsistence patterns of
consumption and indicate the potential for disproportionately high and adverse human health or
environmental effects on low-income and minority populations. Executive Order 12898 § 4 —
401.
1. DEQ Has Impermissibly Weakened the Pollution Limits in the Draft Permit
The Clean Water Act's NPDES permitting program is structured around progressive
improvements in pollution control over time The Clean Water Act permit is a National
Pollutant Discharge Elimination System permit that is required to make progress towards
Congress's "national goal" of eliminating discharges of pollutants to waters of the United States.
33 U S.C. §§ 1251(a)(1)
For this reason, the Clean Water Act includes anti -backsliding requirements to ensure
that the limits and conditions imposed new or modified NPDES permits for a facility are at least
as stringent as those in previous permits. 33 U.S.C. § 1342(0); 40 C F R § 122 44(1)(1)
("[W]hen a permit is renewed or reissued, interim effluent limitations, standards or conditions
must be at least as stringent as the final effluent limitations, standards, or conditions in the
previous permit .. ")
In total disregard of this requirement, the draft permit impermissibly weakens the
established limits in the existing permit for the following coal ash pollutants.
Arsenic — Arsenic is a known carcinogen that causes multiple forms of cancer in humans.
It is also a toxic pollutant, 40 C.F R. § 401.15, and a priority pollutant, 40 C.F.R. Part 423
App'x A. Arsenic is also associated with non -cancer health effects of the skin and the
nervous system.
DEQ's draft inexplicably weakens the limits for Outfalls 001 (both Decanting/Normal
Operation and Dewatering) and 004 from a daily maximum limit of 50 ug/L to 340 ug/L,
a nearly sevenfold increase in toxic arsenic pollution.

The Fact Sheet offers no valid justification for this change It states only that the increase
is supposedly "based on the updates to the North Carolina standards," and refers to the
arsenic limits as "water quality based effluent limitations." Fact Sheet at 5
However, the existing permit contains technology-based limits on arsenic and other
pollutants that Duke Energy has accepted and is bound by. Indeed, Duke Energy has not
requested that the arsenic limits be weakened In its application materials, Duke Energy
requests certain changes to the permit, but it does not ask for DEQ to weaken the arsenic
limits. Of course, a request from the applicant would not on its own justify such a
change, but the fact that Duke Energy has not even made the request simply highlights
the absurdity of DEQ weakening the permit for no reason DEQ has no business
unilaterally weakening pollution limits that it has already imposed based on available
treatment technology — limits that Duke Energy accepts and is currently complying with,
and that protect the important fishing and water resources of Sutton Lake and the Cape
Fear River.
In addition, the arsenic limit in the draft permit makes no mathematical sense. The
permit purports to allow a daily maximum arsenic concentration of 340 ug/L and a
monthly average of 10 ug/L. The discharge is sampled weekly, so the monthly average
would be based on four samples. Thus, a single sample at the allowed daily maximum of
340 ug/L would exceed the entire monthly average limit by more than eight times (85
ug/L), even if the other three samples contained no arsenic In other words, DEQ has not
only weakened the daily limit drastically, but also is proposing to negate the monthly
average limit for arsenic and render it meaningless
To comply with the anti -backsliding requirements of the Clean Water Act, DEQ must
abandon this approach and maintain the current arsenic limits for these outfalls and also
apply the arsenic limits from the existing permit to Outfall 008.
Mercury — Mercury is a well-known neurotoxicant and is listed as a toxic pollutant, 40
C.F.R. § 401 15 It has the dangerous capacity to bioaccumulate, or build up in animal
tissue. When mercury leaches from coal ash into the soil or water, it is converted by
bacteria into methylmercury, an organic form that can be absorbed by small organisms
and the larger organisms that eat them. As it moves up the food chain, the concentration
of methylmercury increases. Mercury is particulary toxic to the developing nervous
system Exposure during gestation, infancy, or childhood can cause developmental delays
and abnormalities, reduced IQ and mental retardation, and behavioral problems.
DEQ has entirely removed the mercury limits for decanting and so-called normal
operation of Outfalls 001, 002, and 004. Again, there is absolutely no valid basis for this
weakening of the permit, which violates the anti -backsliding requirement. The permit's
Fact Sheet states only that these limits were removed based on the results of an
undisclosed "Mercury Evaluation" that is not included with the permitting materials
Fact Sheet at 5. Once again, Duke Energy has not requested that the mercury limits be
removed. The current permit contains valid limits based on existing, in-place treatment
technology, and Duke Energy has accepted and is complying with these limits. There is

no justification for removing them and impermissibly weakening the permit. If Duke
Energy is not expected to discharge mercury going forward, then it will have no trouble
complying with the limits. But there is no reason to remove them, especially given the
legacy of coal ash contamination of Sutton Lake and the Cape Fear River.
Lead — Lead is a very potent neurotoxicant that is highly damaging to the nervous
system. Health effects associated with exposure to lead include, but are not limited to,
neurotoxicity, developmental delays, hypertension, impaired hearing acuity, impaired
hemoglobin synthesis, and male reproductive impairment. Importantly, many of lead's
health effects may occur without overt signs of toxicity. Lead is also classified by the
EPA as a "probable human carcinogen."
DEQ has removed the lead limit for decanting and normal operation of Outfall 001 into
the Cape Fear River. In addition, DEQ has more than doubled the daily maximum limit
for dewatering from 33 8 ug/L to 75.4 ug/L Once again, Duke Energy has not requested
this change and once again, there is no justification for it The Fact Sheet states that the
change is based on a "Reasonable Potential Analysis" that is not part of the permit
materials. However, the limits in place now are being met with existing, in-place
treatment technology, and there is no justification for weakening them.
In addition, DEQ's permit creates mathematical impossibilities It purports to authorize a
daily maximum lead limit of 75.4 ug/L and a monthly average limit of 2 94 ug/L. Based
on the weekly samples contemplated in the permit, a single daily maximum sample of
75.4 ug/L would exceed the monthly average limit by over six times (18.9 ug/L), even if
all the other samples contained zero lead.
• Cadmium — Chronic exposure to cadmium, a toxic pollutant, 40 C F.R § 401.15, can
result in kidney disease and obstructive lung diseases such as emphysema. Cadmium
may also be related to increased blood pressure (hypertension) and is a possible lung
carcinogen. Cadmium affects calcium metabolism and can result in bone mineral loss
and associate bone loss, osteoporosis, and bone fractures.
DEQ has removed the cadmium limit from Outfall 001's decanting/normal operations
limits as well Duke Energy has not requested this change and there is no justification for
removing this limit from the existing permit.
Iron — Iron can render water unusable by imparting a rusty color and a metallic taste and
causing sedimentation and staining. DEQ has removed the iron limit for Outfalls 001,
002, and 004. The Fact Sheet (p. 5) states that this change is based on "updates to the
North Carolina standards," but again, nothing in those water quality standards justifies
weakening the current limits based on existing technology that are in place in the current
permit.
4

2. DEQ Has Failed to Disclose an Updated Compliance Boundary
The groundwater rules direct that "[t]he [compliance] boundary shall be established by
the Director, or his designee at the time of permit issuance." 15A NCAC 02L .0107(c)
(emphasis added). Yet the draft permit as distributed to the public for comment includes no map
designating a compliance boundary for the Sutton facility This is a critical omission
The draft permit must include an updated compliance boundary to reflect the newly -
recognized status of Sutton Lake as a water of the State. Previous compliance boundary maps
have incorrectly drawn the compliance boundary extending into Sutton Lake and the old
streambed of Catfish Creek, a navigable water of the State. The compliance boundary must be
redrawn so that it does not extend into these waters.
We raised this issue in our comments on the 2015 NPDES permit, yet DEQ still has not
made an updated compliance boundary map publically available, despite representing to the N.C.
Superior Court that it would do so in connection with new draft NPDES permits for Duke
Energy's coal ash sites Ina summary judgment hearing on December 19, 2016, counsel for
DEQ argued that the court should not make any determination about the location of compliance
boundaries at Duke Energy's coal ash sites because the boundaries would be determined — and
disclosed to the public — through the NPDES permitting process and would then be subject to
challenge through the administrative appeals process for those NPDES permits:
The compliance boundary, quote, "is established by the director or his designee at
the time of permit issuance." And that's important here because those are
currently being established in the [NPDES] process."
DEQ ... is charged with making decisions regarding compliance boundaries at
the time of permit issuance. And it is in the [NPDESJ permits [that] the
compliance boundaries are set by the director and when these decisions have
been made intervenors and other aggrieved persons are free to challenge those
provisions pursuant to the [Administrative Procedure] act... "
See Excerpts from Summary Judgment Hearing Transcript (Dec 19, 2016), attached as
Exhibit 1 (emphases added).
. Instead — directly contrary to its representations to the Superior Court — DEQ has released
a draft NPDES permit with no compliance boundary map, I giving the public no idea of where
DEQ locates the compliance boundary in relation to Sutton Lake, and thus denying the general
public any opportunity to evaluate the boundary or comment on it as part of the required public
participation process In other words, DEQ is denying the public the opportunity to
meaningfully comment on this vital aspect of Duke Energy's coal ash wastewater treatment
system, and appears to have misrepresented its actions to the N.C. Superior Court.
' As DEQ's Public Notice explains, DEQ posts its draft permits and related materials on a publicly -available
website, https //goo ,Rl/3 WtzNIF For the Sutton permit, DEQ has posted the draft permit, a fact sheet, a public
notice, an outfalls map, and Duke Energy's renewal application None of these materials contains a compliance
boundary map

3. DEQ Is Proposing to Further Weaken the Permit by Allowing Duke Energy to Use
Dilution to Meet the Effluent Limits
In addition to weakening numerous limits for toxic coal ash pollutants, DEQ's draft
permit also appears to allow Duke Energy to impermissibly dilute its ash pond discharges to the
Cape Fear River. Condition A(27)(2) of the current Sutton permit (A(28)(2) in the draft permit)
states, "All effluent samples for all external outfalls shall be taken at the most accessible location
after the final treatment but prior to discharge to waters of the U.S. (40 CFR 122.410))."
Similarly, other Duke Energy permits explain that ash basin discharge samples "shall be taken
prior to mixing with other waste streams." Eg, 2009 Mayo NPDES Permit #NC0038377 at
A(3)-(4) (emphasis added)
The Fact Sheet states that "Outfall 001 is discharging through the mixing box that was
set-up to concurrently discharge ash pond wastewater and water from Sutton Lake. The
compliance point for Outfall 001 is located within the mixing box."
By proposing to allow Duke Energy to measure compliance for Outfall 001 within this
mixing box, DEQ appears to be violating these common-sense sampling requirements that
prohibit dilution and sampling after discharge to waters of the United States. Sutton Lake is a
water of North Carolina and the United States, as DEQ recognizes in the Sutton permit, and
sampling the Outfall 001 discharge after mixing with Sutton Lake water is a violation of
Condition A(27) of the current permit. Duke Energy must comply with the effluent limits for
Outfall 001 prior to diluting its ash pond discharges with the jurisdictional water of Sutton Lake.
Thank you for your consideration of these comments.
cc• Bill Lane, DEQ General Counsel
Sincerely,
/s/ Nicholas S. Torrey
Nicholas S. Torrey
Staff Attorney
Frank S Holleman III
Senior Attorney
rel

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STATE OF NORTH CAROLINA
COUNTY OF WAKE
STATE OF NORTH CAROLINA ex rel.
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENTAL QUALITY, DIVISION
OF WATER RESOURCES,
Plaintiff,
m
IN THE GENERAL COURT OF JUSTICE
SUPERIOR COURT DIVISION
13 CVS 11032
ROANOKE RIVER BASIN ASSOCIATION,
SIERRA CLUB, WATERKEEPER ALLIANCE,
CAPE FEAR RIVER WATCH, INC., NEUSE
RIVERKEEPER FOUNDATION, AND WINYAH
RIVERS FOUNDATION,
Plaintiff -Intervenors,
V.
DUKE ENERGY PROGRESS, LLC,
Defendant. TRANSCRIPT
............................. VOLUME 1 of 1
COUNTY OF MECKLENBURG
STATE OF NORTH CAROLINA ex rel.
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENTAL QUALITY, DIVISION
OF WATER RESOURCES,
Plaintiff,
CATAWBA RIVERKEEPER FOUNDATION, INC.,
PPALACHIAN VOICES, YADKIN RIVERKEEPER,
OUNTAINTRUE, DAN RIVER BASIN ASSOCIATION,
ROANOKE RIVER BASIN ASSOCIATION, SOUTHERN
LLIANCE FOR CLEAN ENERGY, AND WATERKEEPER
LLIANCE,
Plaintiff -Intervenors,
V.
DUKE ENERGY CAROLINAS, LLC,
Defendant.
Jacqueline M. Sullivan, RPR, CRR
Official Court Reporter
13 CVS 14661

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TITLE PAGE, con't.
Transcript of proceedings in the
General Court of Justice, Superior Court Division, Wake County,
North Carolina, at the December 19, 2016 Session, before the
Honorable Paul C. Ridgeway, Judge Presiding.
APPEARANCES:
FRANCISCO J. BENZONI, ESQ.
HILL DAVIS, ESQ.
114 W. Edenton Street
Post Office Box 629
Raleigh, NC 27602-0629
On behalf of the Plaintiff
D.J. GERKEN, ESQ.
PATRICK HUNTER, ESQ.
FRANK HOLLOMAN, ESQ.
Southern Environmental Law Center
22 South Pack Square, Suite 700
Asheville, NC 28801-3494
On behalf of the Plaintiff -Intervenors.
NASH E. LONG, ESQ.
BRENT ROSSER, ESQ.
Hunton & Williams, LLP
Bank of America Plaza
Suite 3500
101 South Tryon Street
Charlotte, NC 28280
Jacqueline M. Sullivan, RPR, CRR
Official Court Reporter
P.O. Box 351
Raleigh, North Carolina 27602
[phone]
Jacqueline M. Sullivan, RPR, CRR
Official Court Reporter
I

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150
THE COURT: I have it.
MR. BENZONI: Tab three. This is for systems
individually permitted prior to December 1983, quote:
The compliance boundary is established at a
horizontal distance of five hundred feet from the waste
boundary or at the property boundary, whichever is closer to
the source.
And so in order to understand that specification,
because it's five hundred feet from the waste boundary, we've
got to look at the definition of "waste boundary," and the
waste boundary is defined as the perimeter of a permitted
waste disposal area, unquote, and that's the 150226.
One other important provision is 107(c), which
states:
The compliance boundary, quote, "is established by
the director or his designee at the time of permit issuance."
And that's important here because those are currently being
established in the MPSD process.
Those are going to form the backdrop of our
discussion one and two.
In the first issue intervenors maintain that the
compliance boundaries at the facilities must stop at the stop
river at Cliffside like Wiley and at end and Lake Gorman at
24 1 Marshall.
25
'First they argued that Duke Energy's own
Jacqueline M. Sullivan, RPR, CRR
Official Court Reporter

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152
the statute says that and there's no reason for the Court to
offer interpretation of the plain -language statues. On the
contrary, the Supreme Court held in Carolina Light Power
Company verse City of Asheville: Wherever statutory language
is clear and unambiguous the Court does not engage in but
must apply the statute to.
Here there's no reason for judicial construction.
The statute is clear and plain and unambiguous on its face.
The issue here to DEQ is intervenors' attempt to apply the
law to a factual uncritical set of circumstances completion.
As noted, as DEQ it is charged with making decisions
regarding compliance boundaries at the time of permit
issuance. And it is in the MPDS permits of the compliance
boundaries are set by the director and when these decisions
have been made intervenors and other aggrieved persons are
free to challenge those provisions pursuant to the procured
administration act as some of the intervenors have in this
case with regards to the Marshall facility.
So DEQ respectfully requests that the Court refrain
from making any decisions. DEQ is charged with making those
decisions.
THE COURT: So on the one hand the statutes are
clear and need interpretation on the other hand that you saw
it should be this and that saying it should be something
else?
Jacqueline M. Sullivan, RPR, CRR
Official Court Reporter

•� DUKE
NERGY®
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 3414750
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.
1. 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.
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 2 of 2
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
7. 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 Letoya.Ogallo duke-energv.com or
Mr. Kent Tyndall, Environmental Professional for the L V. Sutton Energy Complex Plant, phone
[phone] or e-mail [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. eased 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 1 am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations.
Sincerely,
J_g� ,E N,. IL
Jesse E Huntley, II
Station Manager

-----Original Message -----
From: Frieda Hirschberg [mailto:[e-mail]]
Sent Friday, September 01, 2017 11.04 PM
To- SVC_DENR publiccomments <[e-mail]>
Subject. Don't let Duke Energy dump in our water
I am writing to oppose the North Carolina Department of Environmental Quality's proposal to permit
more pollution to flow into our waterways
It's been two years since the toxic spill in the Dan River, but coal -ash pits are still leaking. The Dan River
spill showed us dust how dangerous coal ash is — people across the state are still drinking bottled water
to protect their health It is irresponsible to allow Duke Energy to continue polluting our waterways with
toxic coal ash.
Put North Carolina's health and our environment ahead of polluters Don't give Duke Energy permits to
continue dumping toxic coal ash in our rivers and streams.
Name. Frieda Hirschberg
Email. friedasmail@email corn
Street- 2201 Alamar cy
City- Colfax
State: NC
Zipcode. 27235
Sent from my Whone

Oral Comment Summary
Speaker
Affiliation
General Comment(s)
Nick Torrey
SELC;
Removes and/or weakens limits for several parameters including arsenic, lead, mercury,
Cape Fear River Watch
cadmium; Clean Water Act prohibits weaker limits; Duke Energy did not request less stringent
limits, Groundwater Compliance Boundary not established or depicted, especially with regard
to Sutton Lake; Sutton Lake is waters of the state and should not be used to dilute discharge
John Elliot
Duke Energy
Time forfeited/yielded at speakers request (did not speak)
Veronica Carter
NAACP
Scope of permit should not be reduced through relaxed limits, especially given current issues
related to GenX; Sutton Lake used for recreational and subsistence fishing, area lacks
adequate postings/warnings about whether fish are safe for consumption; permit should
protect citizens; Flemmington community has experienced groundwater issues; Sutton Lake
should be protected as fish from the Lake serve as a food source for the community.

Appendix D
Hearing Registration Sheets

cj
"'E n
dR ;

PUBLIC HEARING NON -SPEAKER SIGN IN SHEET
-E. -�T R
;74
IP4
"05

DWR Staff in Attendance
L.V. Sutton Energy Complex - Public Hearing
Wilmington, NC; 6/22/2017
DWR Staff
Sergei Chernikov
Geoff Kegley
Morella King
David May
Teresa Rodriguez
Robert Tankard

Appendix E
Permit and Hearing Officer Overview
Provided At The Public Hearing

Public Hearing
L.V. Sutton Energy Complex
NPDES Permit NC0001422
June 22, 2017
Good Evening, my name is Dr. Sergei Chernikov and I write NPDES wastewater
permits in the Raleigh Central Office for the Division of Water Resources. Tonight
I will provide a brief overview of the draft NPDES permit for the L.V. Sutton Energy
Complex, NPDES permit number NC0001422.
Duke Energy has requested renewal of its NPDES wastewater permit with
modifications. The last permit modification was issued on December 3, 2015. Due
to the changes in the State and Federal rules and regulations, and changes at the
site this draft permit was developed to address current and future conditions and
activities. The discharge from this facility mainly consists of industrial wastewater.
The proposed permit includes 6 external outfalls, and 11 internal outfalls.
The external outfalls discharge to either Sutton Lake or a Cape Fear River, both are
classified as C -Swamp waters.
The main parameters of concern for this facility are temperature, Arsenic,
Selenium, Mercury, and other metals. To determine the need for a permits limit,
the Division of Water Resources conducted a Reasonable Potential Analysis. The
Reasonable Potential Analysis is the statistical analysis of the effluent data that has
been approved by the Environmental Protection Agency. Based on this analysis, the
Water Quality Based Effluent limits for Total Copper, Total Nickel, Chlorides, Total
Arsenic and Total Selenium have been added to the permit.
In addition, the proposed permit continues a requirement for physical -chemical
treatment of all wastewater generated during decanting and dewatering of ash
lagoons, it continues a requirement for Cape Fear River and Sutton Lake monitoring
for 10 parameters, it also continues requirements for groundwater monitoring, fish
tissue monitoring, dam safety inspections, and whole effluent toxicity monitoring.

This concludes my presentation regarding the subject draft NPDES permit. I will
now turn the hearing back over to Mr. David May.

Hearing Officer Presentation
June 22, 2017
PUBLIC HEARING — DRAFT NPDES PERMIT FOR
DUKE ENERGY PROGRESS, LLC TO
DISCHARGE TREATED INDUSTRIAL WASTEWATER AND STORMWATER
FROM THE L.V. SUTTON ENERGY COMPLEX
The public hearing will please come to order. Before we begin, I ask that everyone turn
off or silence all cell phones and pagers as a courtesy to the speakers.
My name is David May, and I have been appointed to serve as hearing officer for the
state Division of Water Resources. I am the supervisor of the Water Quality Regional
Operations Section in the division's Washington Regional Office
This hearing is being held pursuant § 130A-309.203 of the Coal Ash Management Act
of 2014 and under the authority of Title 15A of the North Carolina Administrative Code
Chapter 021-1.0111. In North Carolina, every individual who discharges wastewater or
stormwater to waters of the state is required to obtain a National Pollution Discharge
Elimination System, or NPDES, permit. The Environmental Protection Agency has
authorized the N.C. Department of Environment and Natural Resources to issue or deny
these permits.
This public hearing covers the renewal and permit modification of NPDES wastewater
permit NC0001422 covering the discharge of treated industrial wastewater and
stormwater from the L.V. Sutton Energy Complex to Sutton Lake and the Cape Fear
River in the Cape Fear River basin. The subject permit is held by Duke Energy
Progress, LLC. I will preside over this hearing to receive comments related to the
NPDES wastewater permit for the L.V. Sutton Energy Complex.
Page 1 of 4

The purpose of this hearing is to obtain public comment on the draft NPDES
wastewater permit for Duke Energy Progress, LLC's L.V. Sutton Energy Complex
located in New Hanover County.
A written record of these proceedings will be prepared by the hearing officer. For this
reason, the audio of this hearing is being recorded. Written comments received by the
end of today will also be included as part of the record. Written comments may be
submitted to pub Iiccomments gncdenr.gov with "Sutton" in the e-mail's subject line or
or the postal address of Wastewater Permitting, 1617 Mail Service Center, Raleigh, NC
27699-1617. The e-mail address and postal address may also be found at the
registration desk for tonight's meeting. Equal weight will be given to both written and
oral comments.
At this time, I would like to introduce representatives from the Department of
Environment and Natural Resources, as well as any elected officials that are present
tonight (registration desk staff will provide list of elected officials):
• DEQ/DWR
• DEQ/DWR
• DEQ/DWR
• DEQ/DWR
• DEQ/DWR
Page 2 of 4

I will now ask Sergei Chernikov from the Division of Water Resources to present
information concerning the draft NPDES wastewater permit.
PRESENTATION
That concludes our overview of the draft permit. Next we will hear from audience
members who have signed up to speak. When they have finished, if others in the
audience would like to comment, they will be given the opportunity to do so. To ensure
that we hear from all who wish to speak, there will be a four minute time limit for
providing comments. Staff will keep track of the time and raise a sign to indicate when
you have one minute left, 30 seconds left, and when your time is up. Please keep your
comments concise and limit them to tonight's subject. Comments that address specific
scientific or technical points of the draft permits will be most useful in our review
process. If possible, speakers are asked to provide a written copy of their comments.
Cross-examination, debates, or other discussion that is not related to the subject permit
matter will not be allowed. The hearing officer may ask questions for clarification. We
ask that everyone respect the right of others to speak without interruption. To ensure
that everyone has a clear view of the proceedings, we ask that you refrain from waving
signs inside the meeting area. If there are a lot of signs, we'll ask people to stand at the
beginning of the meeting so we can take photos of the signs as part of the hearing
record.
I will now call speakers in the order that they registered. To ensure that our records are
accurate, please clearly state your name and, if applicable, the organization you are
representing. In addition, we ask that you identify other associations you may have that
Page 3 of 4

have bearing on your input tonight. For example, if you are appearing on your own
behalf, but have obtained information from, or provided research to, another group that
is interested in this matter, please tell us. That will be useful when assessing the
information provided and comments made.
CALL ON SPEAKERS
Is there anyone else that would like to comment?
If you did not speak tonight, but would like to submit written comments, they will be
accepted through the end of today. Written comments should be submitted to the email
address or postal address found on the handout available at the registration desk.
Based on the public comments received and information submitted in the permit
applications, I will make recommendations to the director of the Division of Water
Resources regarding a final decision on whether to issue or modify the draft permit.
I would like to thank all of you for your attendance and interest tonight. This hearing is
adjourned.
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