NC0005363_Plan of Action_20161115

Richard E. Baker, Jr.
Director
EHS-CCP Environmental Programs
526 S. Church Street
Mail Code: EC13K
Charlotte, NC 28202

1

Belinda Henson
North Carolina Department of Environmental Quality
Fayetteville Regional Office
225 Green Street, Suite 714, Fayetteville, NC 28301-5095

Subject: Duke Energy Progress, LLC
W. H. Weatherspoon Plant Requested Plan of Action
Wayne County

Dear Ms. Henson:

This letter responds to the North Carolina Department of Environmental Quality’s (DEQ’s)
November 3, 2016 (see Attachment A) request for a Plan of Action (Plan) to address potential
releases from the cooling pond as a result of the historic flooding caused by Hurricane Matthew
at the Weatherspoon Plant.

Overview and Timeline of Events

The cooling pond at Weatherspoon plant is bordered on the west by the Lumber River, and on
the east and south by Jacob Swamp (see Attachment B). The NPDES permit for the plant
authorizes a single discharge point (Outfall 001) from the cooling pond to the Lumber River.
According to the permit, “this discharge is permitted only in cases caused by extreme rainfall;
where unavoidable to prevent loss of life, severe property damage, or damage to the cooling
pond structure; or maintenance activities”. In the event of a discharge, the permit requires Duke
Energy to provide verbal notification within 48 hours after the discharge event, and a written
notification within 10 days of the discharge. The permit also requires wastewater monitoring and
sampling in the event of a discharge. A brief timeline of events is as follows:

 On October 8, 2016, historic flooding associated with Hurricane Matthew caused Jacob
Swamp to swell beyond its banks. As a result, floodwaters from the swamp overtopped
the adjacent dam crest and entered the cooling pond. The floodwaters eventually
caused a discharge from the cooling pond emergency overflow structure, located at
NPDES outfall 001.
 October 9, 2016 – floodwaters from Jacob Swamp continued to enter the cooling pond.
Duke Energy staff manually opened the discharge gate, which is also part of the
engineered discharge structure at outfall 001, to more quickly draw down the level of the
pond. Duke Energy then made verbal notification to the NC Division of Emergency
Management that a cooling pond release had occurred at Weatherspoon.
 October 10, 2016- Duke Energy collected wastewater samples, as required by the
NPDES permit.

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 October 10, 2016 - Duke Energy requested that NCDEQ authorize the addition of
several 6 inch diesel pumps to supplement the discharge from the cooling pond into the
Lumber River, in order to more quickly draw down the level of the pond.
 October 11, 2016 - the Department of Environmental Quality approved Duke Energy’s
request to discharge additional wastewater with the supplemental pumps.
 October 18, 2016 – Duke Energy submitted the 10- day written follow-up as required by
the NPDES permit.
 October 24, 2016 – the cooling pond level returned to normal operating levels and Duke
Energy closed the discharge structure, ceasing the wastewater discharge.
 November 10, 2016- The October 2016 DMR, which included sample results from the
discharge event, was submitted via the eDMR system.

Plan of Action

The responses below tie directly to NC DEQ’s November 3, 2016 request for a Plan of Action to
address impacts from Hurricane Matthew. As further described below, no additional responses
to Hurricane Matthew are planned.

1) Estimate on type and amounts of ash or cenospheres released

No ash or cenosphere material was released from the cooling pond.

2) Assessments of the impoundments that include damage at the inactive basins complex
and loss of material at all impoundments
There are two impoundments at Weatherspoon plant: the ash pond and the cooling
pond. The ash pond is elevated to approximately 143 feet above mean sea level and
was not significantly affected by the hurricane. As a point of comparison, the operating
level for the cooling pond is at approximately 109 ft msl.
The structure of the cooling pond was not damaged as a result of the hurricane, however
there were two maintenance actions which were immediately identified for resolution
after the flooding of Jacob Swamp. The first item is that crushed stone was placed on
the access road along the crest of the berm to repair erosion that occurred as a result of
floodwaters entering the pond. The second item is that four downed trees along the
outer slope of the dam in Jacob Swamp were removed, and damage left by root balls
were repaired.
Additional assessments of the cooling pond revealed no significant structural issues.
No loss of material occurred from any of the impoundments at the Weatherspoon site.
3) If ash or cenospheres have been released, then sampling and/or monitoring
recommendations shall be part of this plan

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As previously noted above, no release of ash or cenospheres occurred. Therefore no
additional sampling and/or monitoring is necessary in response to Hurricane Matthew
impacts at the Weatherspoon site.

4) A description of past, ongoing and proposed actions in response to any releases and/or
the inundation of the cooling pond
As noted above, two maintenance items on the cooling pond dam were identified. Both
items have been completed.
With respect to the release of wastewater through the NPDES outfall, notification and
monitoring was performed as required by the permit. The wastewater monitoring results
have been reported on the October eDMR.

5) A list of any State or Federal permits that may be required to complete the plan

None required.

6) A timeline for completion of the assessment

No additional assessment activities are planned for the Weatherspoon site.

If there are any questions regarding this response, please contact Ms. Toya Ogallo via phone at
[phone] or via email at [e-mail].

Sincerely,

Richard E. Baker, Jr., P.E., PMP
Director, EHS-CCP Environmental Programs
Duke Energy

Attachments

Water Resources
ENVIRONMENTAL QUALITY
PAT MCCRORY
DONALD R. VAN DER VAART
S. JAY ZIMMERMAN
Do,, Iw
November 3, 2016
Mr. Harry Sideris
Senior Vice President
Environment, Health, and Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, NC 28202
Subject: Request for Plan of Action for the W. H. Weatherspoon Power Plant
Dear Mr. Sideris:
As a result of Hurricane Matthew and subsequent flooding in the vicinity of the W. H.
Weatherspoon Power Plant, inundation of the cooling pond structure has been documented at the
facility.
The North Carolina Department of Environmental Quality (DEQ) requests that Duke Energy
submit a Plan of Action (Plan) no later than November 15, 2016 to determine if there has been a
release, or a potential release, of coal ash or cenospheres from the cooling pond structure. The
Plan shall include:
• Estimates on type and amounts of ash or cenospheres released,
• Assessments of the impoundments that include damage at the cooling pond and loss of
any material at all impoundments,
• If ash or cenospheres have been released, then sampling and/or monitoring
recommendations shall be part of this Plan,
• A description of past, ongoing, and proposed actions taken in response to any releases
and/or the inundation of the cooling pond,
• A list of any State or Federal permits that may be required to complete the Plan, and
• A timeline for completion of the assessment.
Please note that in requesting the Plan, DEQ in no way has limited or foreclosed its options with
respect to further investigation or potential enforcement of any violations which may have
occurred at the W. H. Weatherspoon Power Plant.
Recognizing that any ongoing emergency operations as a result Hurricane Matthew remain the
priority, you may contact the DEQ Fayetteville Regional Office to extend the due date for
submitting the plan if needed.
State of North Carolina I Environmental Quality I Water Resources
1611 Mail service Center I Raleigh, North Carolina 27699-1611
919 707 9000

If you have other questions, please contact the DEQ Fayetteville Regional Office at (910) 433-
3300. You may also contact Eric Smith in the Water Quality Regional Operations Section at
919-807-6407.
cc:
Sincerely,
S. Jay Zi merman, P.G., Director
Division of Water Resources
FRO WQROS Regional Office Supervisor
WQROS Central File Copy
2 1 P a g e

Discharge
through
outfall
001
Attachment B- Schematic of Weatherspoon Plant
Please note that the arrows depicting the inflow of floodwaters from Jacob Swamp are intended to be
schematic. Floodwaters entered the cooling pond at multiple locations.