NC0003417_Comments_20181130

411IN DUKE HF Lee Energy Complex
ENERGY® Duke Energy Progress
1199 Black Jack Church Road
Goldsboro,NC 27580
November 30,2018
Ms.Teresa Rodriquez
Division of Water Resources
1617 Mail Service Center RECE1
Raleigh, NC 27699-1617 ®/DE�j�/®�/R
VE
DEC 0 5 2018
Subject: Comments on the DRAFT NPDES Permit for HF Lee Energy Complex eater Resources
Permit No. NC0003417
Permitting
Section
Wayne County
Dear Ms. Rodriquez:
Duke Energy Progress, LLC (Duke Energy) submits the following comments on the draft National
Pollutant Discharge Elimination System Permit for the HF Lee Energy Complex (HF Lee), issued for public
comment by the North Carolina Department of Environmental Quality("NCDEQ") on November 2, 2018.
Duke Energy appreciates NCDEQ's efforts to develop the Draft Permit. Duke Energy continues to work
toward closing HF Lee's surface impoundments, and finalizing this wastewater permit is a critical step to
advance that process by authorizing dewatering from the ash basins. Duke Energy offers the following
comments and requests for modification and/or clarification on specific provisions of the Draft Permit:
1) Supplement to Permit Cover Sheet—Outfall 003 lists no flow limit for this outfall. However,
Section A. (6) Effluent Limitations and Monitoring Requirements (Wastewater Pond-Outfall
003) has a monthly average flow limit of 0.5 MGD. Duke Energy requests the monthly
average flow limit of 0.5 MGD be removed to be consistent with the supplement to permit
cover sheet that lists no flow limitation.
2) Page 8 of 27 A. (3)—Duke Energy requests that the sample type for Total Kjeldahl nitrogen,
total phosphorus, Chronic Toxicity,total hardness,total arsenic,total cadmium,total
copper,total lead,total barium,total selenium, and nitrate/nitrite be changed from
composite to grab,to be consistent with the sample type at other outfalls in this permit,and
other Duke Energy permits.
3) Page 9 of 27 A. (4) Note 2.—Note 2. Requires Duke Energy to contact the Neuse River Water
and Sewer Authority in the event of a discharge from the outfall. Duke Energy believes the
water intake for the Neuse River Water and Sewer Authority's facility in La Grange, N. C. is

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approximately 52 river miles from Outfall 002. Duke Energy believes this note should
reference contacting the City of Goldsboro,which is much closer to the site, as it has in past
permits.
4) Page 9 of 27 A. (4)and Page 11 of 27 A. (5)—Duke Energy requests that the sample type for
flow at each of these outfalls be changed from "pump logs" to"estimate" as it has been in
past permits for this facility at Outfall 002. There is no pumping associated with the
discharge of wastewater from either of these outfalls. Both of these outfalls discharge via
overflow spillway.
5) Page 9 of 27 A. (4) and Page 11 of 27 A. (5)—Duke Energy requests that the reference to
sanitary waste water in the outfall description be removed. Sanitary waste water is no
longer discharged to the cooling pond. The sanitary waste water treatment system that
previously discharged to the cooling pond has been removed from service.
6) - Page 13 of 27 A. (6)—The Division has placed a flow limit on the discharge of Outfall 003 to
the Neuse River. Duke believes this flow limit is a typographical error. As stated previously
in comment#2 the supplement to permit cover sheet lists no flow limit for this outfall.
Duke Energy requests the monthly average flow limit of 0.5 MGD be removed to be
consistent with the existing permit for this outfall and the supplement to permit cover
sheet.
7) Page 20 of 27 A. (14)—Duke Energy requests that clarifying language be added that confirms
the total nitrogen baseline allocation is allotted to the facility and not limited to Outfall 001.
8) Page 22 of 27 A. (21)—Requires Duke Energy to perform instream monitoring upstream of
Outfall 002 at the railroad bridge. Duke Energy notes that new Outfall 004,the ash
beneficiation plant, is located upstream of the railroad bridge. Duke Energy suggests that
the upstream monitoring location be moved to the bridge over the Neuse River on Ferry
Bridge Road.
Duke Energy welcomes any further discussion on our comments or the draft permit. If you have any
questions, please contact Steve Cahoon at 919.546.7457 or at [e-mail].
Sincere)
c.i
Jeff ine
Manager, Lee Plant