NC0000396_Comments_20180820

taIN DUKE Garry A.Whisnant
ENERGY® Plant General Manager
Asheville Steam Electric Plant
PROGRESS
Duke Energy Progress
Certified Mail: 7014 1820 0001 7891 4746 ASVL PLT X200 CP&L Dr
Arden,NC 28704
File: 12520B o 828-687-5201
f 828-687-5204
garry [e-mail]
August 20, 2018
Sergei Chernikov, Ph.D.
Division of Water Resources RECE1VE®/® NRJDWR
1617 Mail Service Center
Raleigh, NC 27699-1617 AUG 2 4 2018
Subject: Comments on the DRAFT NPDES Permit for Water Resources
Asheville Steam Electric Generating Plant Permitting Section
Permit No. : NC0000396
Buncombe County
Dear Dr. Chernikov:
Duke Energy Progress, LLC (Duke Energy) submits the following comments on the draft National
Pollutant Discharge Elimination System (NPDES) Permit and the NPDES Permit Fact Sheet for the
Asheville Steam Electric Generation Plant, issued for public comment by the North Carolina Department
of Environmental Quality ("NCDEQ") on July 22, 2018. Duke Energy appreciates NCDEQ"s efforts to
develop the Draft Permit, which address issues associated with surface impoundment decommissioning.
Duke Energy continues to work towards closing the Asheville surface impoundment (1964 ash pond) and
finalizing this wastewater permit is a critical step to advance that process by authorizing dewatering of the
interstitial water in the basin. Duke energy offers the following comments and requests for modification
and/or clarification on specific provisions of the Draft Permit and/or Fact Sheet:
1. On page 1 of 13 of the Fact Sheet, the "Applicant/facility Name;" is listed as Duke
Energy Progress, "Inc." Please change the name to the correct company name of
"Duke Energy Progress,LLC."
2. On page 2 of 13 of the Fact Sheet, ... the new plant is expected to begin power
production by the end of 2020, the coal-fired units will be shut-down by January 31,
2021. Please change the dates to 2019 and 2020 respectively.
3. On page 3 of 13 of the Fact Sheet, the flow volume for 64E0-01 toe drain was 0.33
MGD and the number was placed at 1 MGD for the RPA. According to Duke Energy
records the flow volume for 64E0-01 is approximately 0.033 MGD. Duke Energy
requests that this number be revised on the Fact Sheet as well as a recalculation of
the safety factor and potential increased flow in the RPA spreadsheet. It is not
appropriate to assign an assumed value of 1 million gallons to a measured flow of
0.033 MGD.
4. Duke Energy requests removal of all references to "Outfall 102"from the Fact
Sheet and the Permit. There is no outfall 102 at the site.

s
Comments on the DRAFT NPDES Permit for
Asheville Steam Electric Generating Plant
Permit No. : NC0000396
Buncombe County 2 of 3
5. On page 6 of 13 of the Fact Sheet, TOXICITY TESTING-Outfall 002. Please change
the Outfall to 001 as Toxicity Testing is not done at Outfall 002.
6. On pages 3 and 4 of 16 of the Draft Permit,Duke Energy request removal of
Footnotes 6 & 7,as the continuous monitoring of pH and TSS during dewatering is
not required based on downstream treatment prior to discharging through Outfall
001. This downstream treatment is designed to remove solids and adjust pH,if
necessary, to assure compliance with NPDES permit limits.
7. On page 3 of 16, footnote 5 of the Draft Permit reads "Therefore, if the effluent
measurement exceeds 50 NTU, the Permittee shall sample upstream and downstream
turbidity in the waterbody was not increased". Duke Energy interprets this to mean
sample in receiving stream within 24 hours of receipt of valid results. Duke
Energy also interprets this condition to mean the upstream and downstream sample
location for this condition coincides with the in-stream sample location found in
Section (A.10) of the permit. We request this be clarified in the permit texts as well.
8. On page 9 of 16 of the Draft Permit, Duke Energy request clarification on the
requirements in the event of a failed monthly Chronic Toxicity sample. The permit
texts references a quarterly sample requirement but the permit requires monthly
sampling.
9. On Page 11 of 16,the Draft Permit states, "The facility shall conduct monthly in-stream
monitoring (5,500 ft. upstream and 2,900 ft. downstream of the Outfall 001)." Duke
Energy requests that the upstream coordinates be changed to "approximately
35.4552 -82.5470 decimal degrees and downstream coordinates of approximately
35.5014, -82.5927. in decimal degrees. These suggested locations have been
historically sampled by Duke Energy and the locations in the draft permit language
present safety concerns.
Should you have any questions regarding this letter or require additional information, please contact Ms.
Tina Woodward at(704) 382-4585 or at [e-mail].
Sincerely,
(V
Garry hisnant
Plant Manager
Asheville Steam Electric Plant

4
Comments on the DRAFT NPDES Permit for
Asheville Steam Electric Generating Plant
Permit No. : NC0000396
Buncombe County 3 of 3
cc: DWR-Wastewater Permitting
Attn: Asheville Permit
1617 Mail Service Center
Raleigh,N.C., 27699-1617
Certified Mail: 7014 1820 0001 7891 4739