NCDEQ Submittal Extension_20200214

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� DUKE
ENERGY
February 14, 2020
Mr. Rick Bolich
North Carolina Department of Environmental Quality
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
Subject
Dear Mr. Bolich:
Paul Draovitch
Senior Vice President
Environmental, Health & Safety
526 S. Church Street
Mail Code: EC3XP
Charlotte, NC 28202
[phone]
Response to NCDEQ Letter Dated April 5, 2019 — Request for Report Submittal Extension
Duke Energy is in receipt of the above -referenced letter from the North Carolina Department of
Environmental Quality (NCDEQ) which specified due dates for various upcoming report submittals. As
we have discussed with you prior, the iterative nature of subsurface investigations proves difficult to
target a certain date until multiple rounds of data have been collected. As an example, another work
plan is under development for the coal pile assessment at Roxboro since horizontal delineation was not
achieved during the first two rounds of groundwater monitoring well installs. This has been a common
occurrence for these alternate source investigations (e.g. gypsums pads, coal piles, etc.). As such, the
present due date of March 31, 2020 for these Comprehensive Site Assessments is not achievable. The
table below incorporates the extension requested by Duke Energy along with the cutoff dates for data
collection to be incorporated into these CSAs.
Alternate Source Comprehensive Site Assessments — Proposed Schedule
Current
Current
Proposed
Proposed
Submittal
Data Cutoff
Submittal
Data Cutoff
Facility
Description
Date
Period
Date
Period
Allen
CSA for primary and secondary sources
not associated with impoundments
March 31,
Q4 2019
September
Q1 2020
(including the gypsum pad)
2020
1, 2020
Belews
CSA for primary and secondary sources
Creek
not associated with impoundments
March 31,
September
(including the structural fill, coal pile and
2020
Q4 2019
1, 2020
Q2 2020
gypsum pad)
Cliffside
CSA for primary and secondary sources
not associated with impoundments
(including the raw coal piles north of Unit
March 31,
Q4 2019
December
Q2 2020
6, Unit 6 area, switchyard ash disposal
2020
18, 2020
areas, and gypsum pile)
Mayo
CSA for primary and secondary sources
not associated with impoundments
March 31
Q4 2019
December
Q3 2020
(including the gypsum pad and coal pile)
2020
31 2020
Roxboro
CSA for primary and secondary sources
not associated with impoundments
March 31,
Q4 2019
March 31,
Q4 2020
(including the coal pile)
2020
2021

Duke Energy is also in receipt of the NCDEQ letter dated January 31, 2020 which discussed the potential
for streamlined site -specific Corrective Action Plans (CAPS) for the eight sites yet to submit CAPS. Five of
these eight sites have yet to submit updated CSAs. As the framework of these documents is under
discussion with the agency, it is not practical to prepare a document until the framework has been
agreed to. As such, the table below incorporates the extension requested by Duke Energy along with
the cutoff dates for data collection to be incorporated into these documents.
Updated CSAs and CAPs— Proposed Schedule
Current
Current
Proposed
Proposed
Submittal
Data Cutoff
Submittal
Data Cutoff
Facility
Description
Date
Period
Date
Period
Asheville*
Updated CSA for impoundments and
other primary and secondary sources
June 1, 2020
Q4 2019
December
Q2 2020
(including the raw coal pile)
1, 2020
Buck*
Updated CSA for impoundments and
other primary and secondary sources
Oc
2020 1'
Q12020
February 1,
Q2 2020
(including the former coal pile)
2021
Cape Fear*
Updated CSA for impoundments and
other primary and secondary sources
September
Q1 2020
December
Q2 2020
(including the former coal pile)
1, 2020
1, 2020
Dan River
Updated CAP for impoundments and
other primary and secondary sources
(including the former coal pile, former
July 1, 2020
Q1 2020
November
Q2 2020
CT area and construction warehouse
2, 2020
area)
H.F. Lee*
Updated CSA for impoundments and
other primary and secondary sources
October 1,
December
(including the former coal pile and lay
2020
Q2 2020
1, 2020
Q2 2020
of land area)
Riverbend
Updated CAP for impoundments and
other primary and secondary sources
May 1, 2020
Q4 2019
November
Q2 2020
(including the former coal pile)
2, 2020
Sutton
Updated CAP for impoundments and
other primary and secondary sources
(including the former ash disposal area,
May 1, 2020
Q4 2019
August 3,
Q1 2020
former process area, and former coal
2020
pile)
Weatherspoon*
Updated CSA for impoundments and
other primary and secondary sources
August 3,
(including the former coal pile and
June 1, 2020
Q4 2019
2020
Q1 2020
cooling pond)
*Updated CAP due six months after DEQ approval of Updated CSA

Duke Energy would be pleased to meet with you and your staff to discuss if additional information is
desired. Please contact Mr. Ed Sullivan at 980-373-3719 with any questions you have.
Sincerel ,
Paul Draovitc
Senior Vice President
Environmental, Health & Safety
cc: Ed Sullivan — Duke Energy
Scott Davies — Duke Energy
Kathy Webb — SynTerra Corp.
Jim Wells - Duke Energy
Matt Hanchey —Duke Energy