NC0005363_Comments_20180712

DUKE
ENERGY®
PROGRESS
July 12, 2018
Certified Mail # 701-7260 6600 1260 8754 (2 copies)
Dr. Sergei Chernikov
North Carolina Division of Environmental Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Duke Energy Progress, LLC
Weatherspoon Plant
Comments on Draft NPDES Permit - NC0005363
Dear Dr. Chernikov,
W. H Weatherspoon Plant
491 Power Plant Rd
Lumberton, NC 28358
Mailing Address.
Kent Tyndall
L. V. Sutton Energy Complex
801 Sutton Steam Plant Rd
Wilmington, NC 28401
o 910.341-4775
f: 910 341-4790
RECEIVED/DENR/DWR
JUL IS 2018
Water Resources
Permitting Section
Duke Energy Progress, LLC has received the draft NPDES wastewater permit for the W.H.
Weatherspoon Plant. Duke Energy appreciates the opportunity to review the permit and has the
following comments on the draft. Our staff requests an opportunity to discuss these and any
other potential changes to the draft permit before it is finalized, and will contact your office to
schedule a meeting.
1. Historically, there was an "Outfall 002" in the Weatherspoon permit up until 2012. The
outfall was for a discharge of non -contact cooling water. To prevent confusion, Duke
Energy requests that the emergency spillway be renamed to "Outfall 003".
2. Outfall 001 and 002- BOD and fecal monitoring are included in the draft but there is no
domestic wastewater contribution to the cooling pond. Site domestic wastewater is
treated by a subsurface system located 40 feet away from the cooling pond. Duke
Energy requests that these conditions be removed. This correction would be consistent
with the hearing officer's report which states that domestic wastewater conditions will be
removed from the permit. Please note that in addition to the monitoring requirements in
Sections A(1) and A(2), there is also a footnote on p. 4 pertaining to `discharging'
domestic wastewater which does not apply.
3. Please note that on page 3, measurement units are missing for total mercury (ng/L),
naphthalene (ug/L), and total phenols (mg/L).
4. Section A(1) footnotes 6 and 7. As the Division is aware, the dewatering phase has
already commenced at Weatherspoon plant to support the excavation of CCR material
for reuse in the manufacture of cement. Therefore Duke Energy requests that these
footnotes be removed and the limits take effect upon issuance of the permit. Similarly,
the condition in A(3) on page 6 to provide notice prior to dewatering does not apply since
this stage has already commenced.
5. Footnotes 3 and 4 in Section A(3) require continuous TSS and pH monitoring. However
as discussed with Division staff, that condition is more appropriately applied to sites that
directly discharge to waters of the state. At Weatherspoon the ash basin discharges to
the cooling pond. The cooling pond is a properly permitted treatment unit that treats for
TSS and pH. The TSS and pH requirements at outfalls 001 and 001A are sufficient-

Duke Energy Progress LLC
Comments on Draft NPDES Permit NC0005363
Page 2 of 2
additional continuous monitoring on an internal outfall is not technically justified and
serves no environmental benefit.
6. In Section A(3), the condition about using a floating pump suction logically applies to
decanting bulk water, not dewatering. Duke Energy requests that this condition be
removed since there will be no decanting at Weatherspoon plant. At Weatherspoon
plant, ash basin wastewater is currently discharged to the cooling pond through the
existing riser structure.
7. The description at the top of Section A(3) specifically refers to water "leaking" and
"trickling" from the ash basin to the cooling pond. Since water leaking or trickling from
the basin to the cooling pond would be due to seepage or infiltration, Duke Energy
request that the footnote pertaining to representative sampling and low -flow conditions in
Section A(4) also be placed in section A(3).
8. Page A(4) requires daily flow monitoring on the toe drains, which discharge to the
cooling pond through internal outfall 115. Other Duke Energy NPDES permits do not
require redundant monitoring for constructed seeps that contribute to regulated outfalls.
Duke Energy believes that the limits for outfall 001 already contemplate this input and an
additional internal outfall is not justified. However if the Division is not willing to align this
permit with other permits at this time, Duke Energy requests the following:
a. Please change the flow monitoring frequency at 115A to quarterly to align with
the other sample requirements for this internal outfall.
b. The daily maximum oil and grease and TSS limits appear to have been reversed.
Please adjust in alignment with relevant regulations and/or Division guidance.
9. Section A(11) Instream Monitoring. The fact sheet for the permit states "The facility is
not regularly discharging wastewater to the Lumber River. Therefore, it is not required to
submit DMRs or conduct instream monitoring." Duke Energy requests that language
also be placed in Section A(11) to clarify that instream monitoring is not required if the
cooling pond has not discharged within the previous 12 months. As the Division is
aware, the cooling pond has only discharged twice within the past 19 years.
If there are any questions regarding the information provided in this letter, please contact Toya
Ogallo, Senior Environmental Specialist, at [phone] or Kent Tyndall, Environmental
Professional, at [phone]. These staff may also be reached via email at
[e-mail] or Kent.TyndalI @ Duke- Energy. com, respectively.
Sincerely,
Thomas Hanes
Station Manager - Weatherspoon Plant