Multi ID#'s_Accelerated Remediation Summaries Letter_20160328

Water Resources
ENVIRONMENTAL QUALITY
March 28, 2016
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Harry K. Sideris
Senior Vice President
Environmental, Health & Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, North Carolina 28202
Subject: Accelerated Remediation Summaries
PAT MCCRORY
DONALD R. VAN DER VAART
S. JAY ZIMMERMAN
I"„
Asheville Steam Electric Plant, Belews Creek Steam Station, H. F. Lee Energy
Complex, and L. V. Sutton Energy Complex
Dear Mr. Sideris:
Under the Settlement Agreement (Agreement) between the North Carolina Department of
Environmental Quality (DEQ) and Duke Energy signed on September 29, 2015, Duke Energy is
required to implement accelerated remediation at the subject facilities that demonstrated off-site
groundwater impacts. On February 17, 2016, DEQ received your Accelerated Remediation
Summaries for each subject facility. The subsequent review by Regional Office staff of the
Accelerated Remediation Summaries is summarized below and provides technical direction
regarding the path forward for corrective action. Responses to each of the items identified below
should be submitted by April 30, 2016 unless specified otherwise.
Asheville Steam Electric Plant
The Asheville Steam Electric Plant Accelerated Remediation Summary fails to clearly identify
the goals of the proposed remedial actions, how the proposed remedies relate to an accelerated
timeframe, or how these actions address off-site impacts. Two examples are as follows:
1) A gallery of extraction wells located immediately downgradient of the constructed
wetland that was proposed in the December 4, 2015 version of the Proposed Accelerated
Remediation to address off-site groundwater impacts was not included in the more recent
version of the Summary. There is no explanation given as to why a hydraulic capture
system was initially proposed or why plans are not included as part of the current
recommended action.
State of North Carolina I Environmental Quality I Water Resources
1617 Mail service Center I Raleigh, Nonh Carolina 27699-1617
919 707 9000

2) The scope of work provided in the February 17, 2016 Accelerated Remediation Summary
includes installing a water supply line to a group of Bear Leah Trail private residences,
conducting borehole geophysical surveys in abandoned water supply wells along the Bear
Leah Trail, removal of FGD water treatment wetlands, and dewatering the settling pond
at the facility. None of the proposed actions address the migration of impacted
groundwater beyond Duke Energy's property, which is the stated objective of the
Agreement.
A revised Accelerated Remediation Summary should be submitted to DEQ no later than April
30, 2016 and shall include:
• Clearly identified goals of the proposed remedial actions -- especially those that are
directly related to addressing off-site migration of impacted groundwater or control
thereof;
• A map of the areas to be addressed where isolated groundwater impacts have occurred
off-site;
• If extraction remains part of the proposed Summary, plans for an aquifer test in the
vicinity of the area where an extraction well gallery was proposed in December 4, 2015;
• Plans to assess potential hydraulic connection of the ash ponds and water supply wells
immediately west of the French Broad River; and
• A narrative clearly indicating how the proposed accelerated remediation is consistent
with 15A NCAC 2L .0 106, including citations to the relevant portions of the .0106 Rule.
Belews Creek Steam Station
The proposed actions presented in the Belews Creek Steam Station Accelerated Remediation
Summary was contingent on the purchase of property. Therefore, a timeline must be provided
for the property acquisition.
The following documents must be provided to DEQ no later than April 30, 2016:
A status report that provides details concerning the pending property purchase.
This must be provided in order to assess the viability of remedial action strategy no
later than April 30, 2016.
A report that summarizes the results of Comprehensive Site Assessment data gap
characterization effort.
An evaluation of potential off-site migration of impacted groundwater, including
any analyses of a hydraulic capture system, and an evaluation of the potential
contribution of the on-site landfills and structure fill to impacted groundwater at
and off-site of the facility.
If the adjacent off-site property cannot be acquired by April 30, 2016, then a revised interim plan
should be submitted with a reasonable timeline provided.

H.F. Lee Energy Complex
The H.F. Lee Energy Complex Accelerated Remediation Summary is conceptual and many
components proposed are contingent on the successful completion of other steps, including
obtaining permits. Contingency plans should be included in case components of the Summary
are not realized. The current Summary does not clearly identify the goals of the proposed
remedial actions, provide context of how they relate to an accelerated timeframe, or show how
these actions address off-site impacts.
Additional clarification of certain aspects of the Summary are needed in order to obtain corrective
action approval. Proposed property purchases to both the north and east of the facility is the main
focus of the proposed remedial action strategy; however, the results of the data gap wells,
evaluation of the hydraulic capture system, and the ability to obtain permits are also important
factors to consider.
A revised Accelerated Remediation Summary should be submitted to DEQ no later than April 30,
2016 and shall include:
• Clearly identified goals of the proposed remedial action -- especially those that are
directly related to addressing off-site migration of impacted groundwater;
• Detailed plans for an aquifer test to evaluate groundwater extraction via recovery
wells and a collection trench along the east side of the active basin;
• A status report that provides details concerning the pending property purchase and
related permits in order to assess the viability of remedial action strategy; and
• A summary report of Comprehensive Site Assessment data gap wells
characterization effort; an analysis of a hydraulic capture system; and an evaluation
of any mounding north of the facility.
If the adjacent off-site property cannot be acquired by April 30, 2016, then a revised interim plan
shall be shall be submitted with a reasonable timeline provided.
L.V. Sutton Energy Complex
Additional clarifications are needed to the L.V. Sutton Energy Complex Accelerated
Remediation Summary. These clarifications include 1) the status of the installation of an
alternate water supply line and subsequent abandonment of the two Cape Fear Public Utility's
public wells; 2) the status of bottled water provided to private businesses and residences in the
vicinity of the facility, and any plans for installation of alternate water supply lines to other
private businesses and residences in the study area, and (3) retrofitting of the proposed
groundwater extraction and treatment system to address potential groundwater contamination
migration and surface discharge at the following properties:
• ST Wooten, 230 Sutton Lake Road, Wilmington, NC;
• Ezzell Trucking, Inc., 235 Sutton Lake Road, Wilmington, NC; and
• LCH Holdings, LLC, 221 Sutton Lake Road, Wilmington, NC

The location of proposed alternate water supply lines and all supplied bottled water should be
provided on a map that contains relevant information.
While the overall technical approach presented in the Accelerated Remediation Summary is
acceptable, documentation to serve as a basis for approval should include:
• Results of any on-site aquifer tests used in preparation of the plans;
• Detailed engineering specifications, maps, and/or cross-sections of the proposed
remedial systems and treatment facilities;
• Predictive calculations, capture zone analyses, and/or models used to determine the
proposed effectiveness of the remedial systems;
• Monitoring plans that will be used to evaluate the effectiveness of the remedial
systems along with detailed operation and maintenance plans;
• A list of all permits needed to be obtained or modified through DEQ or other
state/federal agencies; and
• Timelines for construction, implementation, submittal of performance reports, and
other milestone events associated with the remedial systems.
We appreciate your attention and prompt response in this matter. If you have any questions, please
feel free to contact Steve Lanter at [phone].
Sincerely,
S. i merman, P.G., Director
Division of Water Resources
cc: Landon Davidson — ARO Regional Office Supervisor
David May — WARO Regional Office Supervisor
Jim Gregson — WIRO Regional Office Supervisor
Sherri Knight — WSRO Regional Office Supervisor
WQROS Central File Copy
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