NCS000589_Weatherspoon Duke Energy Comments_20161018

r' DUKE
ENERGY,
PROGRESS
October 18, 2016
Certified Mail # 7015 1520 0001 0801 5019 (2 copies)
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
Comments on Draft Permit NCS000589
Dear Mr. Bennett,
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
Duke Energy Progress, LLC has received the draft Industrial Stormwater Permit NCS000589 for
the W.H. Weatherspoon Plant. As an additional point of information for your staff as you review
and prepare this permit for finalization, please be aware that the active erosion and
sedimentation control plan for the demolition of the Weatherspoon plant was closed out this
year. Therefore the demolition of the former coal plant is fully complete and the former plant
area has been fully graded, seeded, and achieved final stabilization.
Duke Energy appreciates the opportunity to review the permit and has the following comments
on the draft.
Title Page- the ownership entity for Weatherspoon Plant is Duke Energy Progress,
LLC.
2. The draft permit includes a semi-annual monitoring requirement for PCBs.
According to the fact sheet, the rationale for the PCB monitoring requirement is that
"electrical equipment onsite prior to decommissioning may have contained PCBs,
which persist in the environment if ever released." However, as also noted by the
fact sheet and as acknowledged in previous industrial stormwater permit coverage,
the stormwater drainage area for the former coal plant flowed to the cooling pond
where it is comingled with wastewater and sampled at NPDES outfall 001. PCB
containing materials have never been stored in the drainage areas for outfalls SW -1,
SW -2 and SW -3. Therefore Duke Energy requests that the monitoring requirement
for PCBs be removed from the permit.

3. The draft permit requires semi-annual monitoring for TSS, pH, and Oil and Grease
during a period when the outfalls are not influenced by industrial activity. The
Stormwater Permitting unit has previously taken the regulatory position that these
three outfalls were only "active" when Duke Energy was engaged in the industrial
activity of transporting industrial materials (ash). Although the fact sheet states that
stormwater regulations also apply to "areas where industrial activity has taken place
in the past and significant materials remain and are exposed to storm water", the
draft permit materials acknowledge that stormwater from all of the former industrial
areas of the plant is conveyed to the cooling pond. Industrial areas, as defined by
the stormwater regulations do not drain to outfalls SW -1, SW -2 and SW -3. The only
time that condition changes is when Duke Energy is engaged in the activity of
moving ash. Therefore Duke Energy requests that no monitoring be required at
outfalls SW -1, SW -2 and SW -3 unless Duke Energy has begun the industrial activity
of removing ash from the plant site.
4. The draft permit requires that fish tissue sampling required under NPDES Permit
NC0005363 be submitted within 30 days of receiving results from the lab. Duke
Energy request that the reporting requirement for this condition align with the NPDES
wastewater permit, which requires that the data be submitted with the renewal
application.
5. Please clarify whether Part III, Section A requires that a SPPP be developed within
6 months after permit issuance, or "prior to the beginning of discharges from the
operation of industrial activity" (i.e. prior to transportation of ash).
If there are any questions, please contact either:
• Mr. Kent Tyndall, Environmental Professional for the W. H. Weatherspoon Plant;
phone [phone] or e-mail [e-mail]; or
• Ms. LeToya Ogallo, Environmental Specialist at our North Carolina Regional
Headquarters, phone [phone] or email [e-mail].
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,
1r
Jason V. Haynes
Station Manager