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Home My WebLink AboutNCS000574_Correspondence_20160229 Harty x sae►ts senior vice Prask bM DUKE ► Heats a say 526 Sw.0 antvM Sbaef Mal Gods E7lUP Ch&VVV;MC2M= (7"382-OW Electronic Submittal February 29, 2016 Mr. Bradley Bennett State of North Carolina Department of Environment and Natural Resources Stormwater Permitting 1612 Mail Service Center Raleigh, NC 276MI612 Subject: Cape Fear Steam Electric Plant Comments on Draft Industrial Stormwater Permit(No. NCS000574) Dear Mr. Bennett: With reference to the February 1, 2015 public notice, Duke Energy offers the following comments on the subject draft permit Cover Pane States'Duke Energy Carolinas, LLC'Is hereby authorized to discharge stormwater... This should say`Duke Energy Progress LLC'. Is hereby authorized to discharge stormwater... Part I Page 2 of 2 The location map Is labelled 'Duke Energy Progress, Inc'. This should be labelled as "Duke Energy Progress, LLC'. Part II Pace 4 of 14 Under item 6'Employee Tralning'Duke Energy utilizes computer based training for SPPP. In this process no signatures are obtained but the records of employee attendance are kept electronically. It is requested that the option to maintain records of employee training electronically be allowed instead of keeping signed records of training. Page 2 of 3 February 29, 2016 Letter to Mr. Bradley Bennett Part 11 Pace 7 of 13 Under the footnotes it discusses that SW-001 and SW-008 are not regulated as point source discharges because of staff observation on the site visit on November 12, 2014. Duke Energy requests that Outfall SW-008, be removed as a stommwater outfall and be placed In the facilities NPDES permit when new permit wastewater permit Is Issued. Part II Pace 8 of 13 Under Table 2 Monitoring Schedule it Is requested that the dates of the monitoring period be adjusted to reflect the effective date of the permit(e.g, Year 1 —Period 1 begin April 1. 2016). This will allow for any improvement needed to establish access areas for analytical monitoring. Part 11 Paae 10 of 14 Under Table 4 some of the benchmark values are very low. For Copper the benchmark value Is listed as 0.01 mgA. The Silver value Is listed at 0.0003 mgA. Plus for Silver the practical quantification level listed In the Fact Sheet is 0.001 mgA, which as noted In the Fact Sheet Is higher than the benchmark level. Could these two values be re- evaluated? The potential e)dsts that these parameters could be measured in stoma water run-off from the influence of background soil containing metals, Instead of an Industrial activity. Part 11 Pawl of 13 The second sentence of the second paragraph states, °Qualitative monitoring shall be performed quarterly as specified In Table 2...' It should state the following, °Qualitative monitoring shall be performed quarterly as specified in Table 5...' Part 11 Pace 12 of 13 Under Table 5. Monitoring Schedule it Is requested that the dates of the monitoring period be adjusted to reflect the effective date of the permit(e.g. Year 1 —Period i begin April 1,2016). This will allow for any improvement needed to establish access areas for visual monitoring. FACT SHEET Pace 1 The fadlity Information lists that facility name as Duke Energy Progress, Inc., Cape Fear Steam Electric Plant,the facility name should be Duke Energy Progress LLC., Cape Fear Steam Electric Plant.