NCS000589_Weatherspoon ISW Update_20160812

r DUKE
ENERGY,
PROGRESS
August 12, 2016
Mr. Bradley Bennett
North Carolina Division of Energy Mineral and Land Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Duke Energy Progress, LLC
Weatherspoon Plant, Robeson County
Update to Industrial Storm Water Application
Dear Mr. Bennett,
W. H. Weatherspoon Plant
491 Power Plant Ad
Lumberton, NC 2B358
Mailing Address.
Kent Tyndall
L. V. Sutton Energy Complex
801 Sutton Steam Plant Rd
Wilmington, NC 28401
,D 910.341-4775
1 910.341-4790
In February 2016, Duke Energy Progress, LLC (Duke Energy) submitted an NPDES Industrial
Stormwater application for the Weatherspoon Plant. Although the former coal generating facility
at this location has been demolished, Duke Energy submitted this application in anticipation of
potential future industrial activity.
In that application, Duke Energy noted that two storm water outfalls (SW -2 and SW -3) were
sampled and characterized in a "Seep Monitoring Report" submitted as part of the NPDES
wastewater permit renewal. Duke Energy is aware that those storm water outfalls are
influenced by groundwater, and therefore did not certify that there are no known non-stormwater
contributions to these outfalls. Your office provided guidance that Duke Energy should evaluate
the outfalls in accordance with the permit description of "Allowable Nan-Stormwater Discharges"
and indicate whether the discharge meets the allowable criteria.
Allowable Non-Stormwater Discharges
This permit regulates stormwafer discharges. However, non-stomtwater discharges
which shall be allowed in the stormwater conveyance system include:
a. All other discharges that are authorized by a non-stormwafer NPDES permit.
b. Uncontaminated groundwater, foundation drains, air -conditioner condensate without
added chemicals, springs, discharges of uncontaminated potable water, waterline
and fire hydrant flushings, water from footing drains, flows from riparian habitats and
wetlands.
c. Discharges resulting from fire -fighting or fire -fighting training, or emergency shower
or eye wash as a result of use in the event of an emergency

Mr. Bradley Bennett
Weatherspoon Update to 15W Application
Page 2
Duke Energy has evaluated 2014-2016 data from outfalls SW -2 and SW -3 and performed a
comparison with 1) data collected from ash pond toe drains at the Weatherspoon Plant, as well
as 2) data collected from a background groundwater monitoring well located on the
Weatherspoon property. A summary of the data is provided in the following table. While there
is no definitive guide for determining whether groundwater samples are influenced by ash,
levels of boron and sulfate are often useful as indicator parameters of ash influence.
Boron has not been detected above laboratory reporting limits in the 10 samples collected from
the two storm water outfalls and average sulfate levels are below levels observed in the
background well and toe drains. Although levels of boron and sulfate are also low in the toe
drain samples, data for alkalinity, iron, arsenic, chromium, copper, and lead in the storm water
are notably different from the toe drain data and similar to background groundwater levels.
Table 1: Comparison of SW -2 and SW -3 Data
Pollutant
SW Outfall
Groundwater
Toe
Drain
H (s.u.)
6.97
4.16
6.5
Specific Conductance
37.13
165.20
600.08
Total alkalinity (mg/L
<10
<10
129.14
Bicarbonate (mg/L
<10
<10
129.14
Carbonate (mg/L
<10
<5
<10
Chloride (mg/L
3.30
14.16
38.46
Sulfate (mg/L
4.55
44.33
39.61
TDS (mg/L
30.14
114.67
288.77
TSS (m/L
9.00
15.88
113.00
Barium (mg/L
0.03
0.07
0.29
Boron (mg/L
<0.05
0.06
1.83
Calcium (mg/L
1.93
3.86
52.26
Iron (mg/L
0.47
0.55
264.00
Ma nesium m /L
0.74
1.94
10.52
Manganese (mg/L
0.01
0.02
0.45
Zinc (mg/L
0.02
0.02
0.01
Mercu (ng/L
1.03
<0.2
3.40
Antimony Sb (ug/L
<1
<1
<10
Arsenic As (ug/L
<1
1.13
102.17
Cadmium Cd (ug/L
<1
0.99
<10
Chromium Cr (ug/L
<5
2.27
154.01
Copper Cu (ug/L
<5
<5
162.72
Lead Pb (ug/L
<1
1.33
164.58
Molybdenum Ma (ug/L
<1
<1
<10
Nickel Ni ((ug/L
<5
1.22
20.98
Selenium Se (ug/L
<1
1.59
<10

Mr. Bradley Bennett
Weatherspoon Update to ISW Application
Page 3
Based on this evaluation of stormwater data, Duke Energy believes that it is able to certify the
stormwater outfalls SW -2 and SW -3 as containing only stormwater or "Allowable Non-
Stormwater Discharges", as required by your office. Duke Energy has attached to this letter a
signed Form 2F (page 2 of 3) to indicate certification of this requirement.
Duke Energy has also attached a $860.00 check for the correct stormwater permitting fee. The
previously submittal erroneously included an application fee for $3,440.
If there are any questions, please contact either:
• Mr. Kent Tyndall, Environmental Professional for the W. H. Weatherspoon Plant;
phone [phone] or e-mail Kent.T ndall@duke-ener .com; or
• Ms. LeToya Ogallo, Environmental Specialist at our North Carolina Regional
Headquarters, phone [phone] or email [e-mail].
Please direct all correspondence to Kent Tyndall via the mailing address shown above.
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. l am aware that there are significant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing
violations.
Sincerely,
Jason V. Haynes
Station Manager
Enclosures: EPA Form 2F, Page 2 — Storm Water Discharges Associated with Industrial
Activity
NPDES Storm Water Permit Fee - $860.00

Mr. Bradley Bennett
Weatherspoon Update to ISW Application
Page 4
CC Via email_
Anthony Locklear
LeToya Ogallo
Kent Tyndall

Continued from the Front
V. Narrative Description of Pollutant Sources
A For duh outlet ps - - an animals d su area (YnsAde ural or Ynpelaus euladn (ixkmrp paved areas and bulkfhq rad&) drained m the osdaa and an trim ret d to a tae wrtace r
Oak try No Moa
Outw
Aran d tmpervimn Surface
Tale Area Drs red
Oudal
Ares of bnpervlous Sutace
Taal Area Drained
Number
(Armrds WWII)
IPWMd. cards)
Number
fNOvine Wats I
mrovede weds
SW -1 0.76
acre
1 51 acre
SW 2 0.67
acre
2.22 acre
SW ] 0.07
acre
21 acre
B Provide a narretn a descrtptlon of slpagl=nl maleriela that am currently, or In the past three yeas have been treated, stored or disposed In a manner to auow exposue
to alarm water, method of treatment storage. or dispasd. pant and Pmaant materiels managememl pracbcaa employed to minimise contact by thus materials with
stain water runoff. materials loading and aCcese areas, and tine location, manner, and frequenty In which pealiddes, harbieWes, &all condltianara and farblWra ane
affiled
In general, storm water from the demolished farmer coal plant site 19 routed to the cooling pond and in included en rhe Ni -l__
permit application for the Weatherepoon Steam Electric Plant. The outfalls listed in this permit application are the only SW
autfalle that have been currently identified as direct point source discharges to surface waters.
This application is far the planned conveyance of coal ash along the plant accesq road. No materials are treated, stared
disposed of in the proximity of this road. No pesticides, herbicides, Poll :onditioners or fertilisers are applied to the
drainage area or the conveyance route.
C For each WM. provide Owl, - 11, and a description of existing structural and nonstn t2ural control measures to reduce pollutants In storm water tunalf: and a
dseoiptibn of the lreatt MI that Storm water nnueeivee, including the stltadlle and type of maintenance for control and beatment measures and the ultimate dLsposa'
of any solid or fluid wastes other than by dbchaive
Outlail
List Cedes from
Number
Treatment
Table 2F -t
SW 1 arasav7d roa3 side dierhas lead to sue fills. No existing control measures ar treatments 4 A
SW 2 Grossed road side ditches lead to cutfalls. No existing control measures or treatments 4 A
SW ] Groaned road side ditches lead to outfalls No existing control measures de treatment' 4 A
V. Nonstofmwater Discharge!
A. 1 certly under penalty of law hal the outfall(s) coveted by this application been lasted or evaluated for the presence of nonsdrrmwter discharges, and plat all
nonafamwaur disehemad from mesa autlegs) are Identified In eMhar an accolipanying Form 2C or From 2E Wocation for the autlall.
Name and Official THIS (type arpdo nature
Kent Tyndall, Site Environmental
B. Pmvids a demariplion of the method used the data of any testing. and the onsda drainage points that were diracly observed during a lest
IA
[. Significant Leaks or Spills
Provide eristlng Information ragarding the history of significant leaks or spits of toxic or harmrdous pollutants at the fadky in the last three years. Inducing the
approximalo date and location of the spill orleak, and the type and amount of materiel released
o the best of my knowledge, there have been nes leaks or spills of toxic or hazadroun pollutants an this access road within the
pant three years.
EPA Form 3510.21F (1.42) Page 2 of 3 Continue an Pegs 3