HomeMy WebLinkAboutltr to Draovitch re GW Corrective Action Plans_20170602Water Resources
Environmental Quality
June 2, 2017
Paul Draovitch
Senior Vice President
Environment, Health, and Safety
Duke Energy
526 South Church Street
Charlotte, North Carolina 28202
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
Re: Groundwater Corrective Action Plans — Evaluation of Remedial Alternatives:
Allen, Belews Creek, Cliffside/Rogers, Marshall, Mayo, and Roxboro
Dear Mr. Draovitch,
. The North Carolina Department of Environmental Quality ("DEQ"), pursuant to CAMA
and 15A NCAC 02L, has determined that Duke Energy's Comprehensive Site Assessments
("CSAs") and Groundwater Corrective Action Plans ("CAPs") must be updated for all facilities.
While DEQ will provide additional, more detailed, technical guidance regarding what will be
required in these updated CSAs and CAPs, the purpose of this letter is (1) to address certain
aspects of the updated CAPs for the coal ash facilities that have not been designated by CAMA
as intermediate or high priority and have not been designated by Duke Energy for beneficiation
(i.e., Allen, Belews Creek, Cliffside/Rogers, Marshall, Mayo, and Roxboro) and (2) to provide a
schedule for submission of the updated CSAs and CAPs for these facilities.
More specifically, in the updated CAPs for these facilities, Duke Energy must provide
an evaluation of a range of source control options, including cap -in-place, complete excavation,
and hybrid(s) that include partial excavation. Further, Duke Energy must identify any
additional remedial actions (e.g., including but not limited to grout curtains, slurry walls, pump -
and -treat) needed to ensure compliance with CAMA, 15A NCAC 2L and 15A NCAC 2B, and
Duke Energy's evaluation of options must be expanded as necessary to include these additional
remedial actions. The specific hybrid(s) options that must be analyzed will be determined on a
site -by -site basis.
-5---Nothing Compares :-,-
State of North Carolina I Environmental Quality
1611 Mail Service Center I Raleigh, North Carolina 27699-1611
919-707-9000
Paul Draovitch
June 2, 2017
Page 2
The timeline for the submission of the updated CSAs and CAPS for these sites is as
follows:
Timeline
Item
• Submittal of updated Comprehensive Site Assessments
9 Submittal of updated Corrective Action Plans
Due Date
V set of 3 due October 31, 2017
2nd set of 3 due January 31, 2018
1 st set of 3 due March 31, 2018
2"d set of 3 due June 30, 2018
A separate letter will be sent outlining additional technical needs as well as timelines for
the facilities designated by CAMA as either high or intermediate priority.
Should you have any questions please call me at (919) 707 9027.
Sincerel
S. ay man, P.G.