Duke Energy Letter 9-7-16

V DUKE
ENERGY®
Harry K. Sideris
Senior Vice -President
Environmental, Health & Safety
526 South Church Street:
Mail Code ECUP
Charlotte, North Carolina 28202
704-382-4303
September 7, 2016
RECEMO
Office of the Secretary
Mr. Donald R. van der Vaart, Secretary 9 2N
North Carolina Department of Environmental Quality
1601 Mail Service Center Departmenf of Environment
Raleigh, North Carolina 27699-1601 and Natural Resources
Subject: Submittal of Duke's proposed process to address water supply provisions of
HB630
Dear Secretary van der Vaart:
Thank you again for meeting with us to discuss this important matter. This letter and
attachments are intended to summarize our conversation, convey the process we plan to utilize
and request that you concur with our understanding and process so we can move forward with
the execution of this critical component of HB630 and provide our plant neighbors peace of
mind.
House Bill 630 provides a process for establishing a final impoundment risk classification of low,
as defined by the Coal Ash Management Act of 2014 and subsequently amended. This process
requires that Duke Energy:
1. Provide permanent alternative water to well owners within a half -mile of a coal ash
surface impoundment compliance boundary regardless of whether there is a known
impact to water quality from nearby ash basins; and
2. Has rectified any deficiencies identified by, and otherwise complied with the
requirements of, any dam safety order issued by the Department
Duke Energy and the DEQ agree that, while HB630 provides that well owners have a choice
between a municipal water connection and whole home treatment, there may be challenges of a
technical nature that present significant concerns regarding the quality of water in a municipal
line and/or render a municipal connection cost prohibitive. In such cases, a whole home
treatment system will be an appropriate alternative to ensure a permanent and high quality
water supply. Where whole home treatment is employed, systems will be installed and
reasonably maintained at Duke Energy's expense. Where well owners choose a municipal
connection, Duke Energy will be responsible for the construction and installation costs. Well
owners may also opt out of any provision of a permanent water supply.
HB630 requires Duke Energy to submit by Dec. 15, 2106 plans for the provision of permanent
water. DEQ agrees that submittal of plans on a site -by -site basis will result in the most
expeditious review. As such, Duke Energy will submit permanent water provision plans for the
sites as they are prepared, and DEQ will act to approve these plans within 30 days of submittal.

In addition to the permanent water provision, the legislation requires that Duke Energy provide
temporary water to all well owners within a half -mile of a coal ash surface impoundment. Duke
Energy is currently providing bottled water to approximately 400 well owners within 1,500 feet
and will offer bottled water deliveries to all well owners within a half -mile. Although wells
between 1,500 feet and a half -mile may be sampled, Duke Energy and the DEQ will rely on
previously issued Health Risk Evaluation (HRE) from the NC Department of Health and Human
Services to inform the quantity of water provided. These HREs have indicated that well water is
safe for all household uses except drinking and cooking. To that end, temporary water deliveries
will be limited to quantities appropriate for drinking and cooking. Furthermore, in some cases the
installation of a whole home treatment system may be a suitable alternative to bottled water
deliveries. Duke Energy will work with well owners to identify these opportunities.
If you have comments and/or questions, please direct them to me at 704-382-4303.
Sin e y,
Harry K. Sideris
Senior Vice -President
Environmental, Health & Safety
Enclosure: Sample Health Risk Evaluation
Proposed Process
Process Flowchart
xc: Tom Reeder, Asst. Secretary for the Environment

`fn DUKE
ENERGY:
Procedure for provision of permanent water supply to NC ash basin neighbors
Purpose
The purpose of this procedure is to ensure compliance with the water supply provisions outlined
in HB630, specifically the requirement for Duke Energy to offer a permanent replacement water
supply to plant neighbors within 1/2 mile of the established compliance boundary of an ash basin
by October 15, 2018.
Standards
• Options that will be offered to plant neighbors will include connection to the local
municipal water supply (municipality) and/or the installation and maintenance of water
filtration systems. Neighbors will also be given the option to opt out of either choice and
remain on unfiltered well water.
■ Duke Energy's recommendations will give preference to permanent replacement of
water supplies that connect plant neighbors to public water lines.
In order to ensure high water quality on a public water supply line, technical
considerations and other operational challenges will be evaluated as part of any decision
to extend a water line.
NCDEQ will make the final determination whether a connection to a public water supply
would be cost -prohibitive. However, Duke Energy proposes that waterlines should be
offered over filtration only if the cost is less than $35,000 per household. This standard
equates to 5X the cost of filtration. The analysis will be based on installation costs only,
but costs for monthly water usage and maintenance will be provided to show total
impact.
Customers who select a filter system will also receive periodic, long-term maintenance
by a qualified vendor as required under LAMA. Duke Energy will pay for the
maintenance at no cost to the customer.
Duke Energy will not cover the expenses associated with monthly water usage for
customers who select a waterline as specified under CAMA.
The selected filter system(s) will produce water that meets appropriate water quality
standards.

Process (see attached flowchart)
It Duke Energy will submit an initial recommendation for each plant to NCDEQ, including
the number of households, nearest connection point to public water, technical and
operational considerations to ensure water quality is maintained on the public line,
projected costs, and other information. Each plant's plan will be submitted as the
evaluation is completed, with all plans being submitted no later than December 15, 2016.
DEQ will approve the individual plans within 30 days of submittal. Once each plan is
approved by NCDEQ, Duke Energy will educate eligible neighbors at each plant site and
identify their preferences. All plant neighbors will be made aware of the final approved
recommendation no later than April 15, 2017.
If a plan is not approved by NCDEQ, Duke Energy will submit a revised plan within 30
days of notification by NCDEQ.
Based on community feedback, including the number of neighbors who have chosen the
different options made available to them, Duke Energy will submit a final
recommendation for each site to NCDEQ. Final recommendations may differ from the
initial plan if technical and operational challenges arise that would jeopardize the water
quality from a municipal line or if the plan is no longer cost-effective including changes
based upon the number of households selecting municipal water.
Once a final recommendation is approved by NCDEQ, Duke Energy will finalize
agreements with neighbors and proceed with implementation.
Duke Energy will keep NCDEQ informed of implementation progress, including the
status of federal, state and/or local permits that are needed to execute the approved
plan and the availability of local government resources, such as limitations on water
supply capacity and staffing limitations for permitting and construction activities.
If the Oct. 15, 2018 deadline appears to be in jeopardy for water line installation due to
the factors stated above, Duke Energy will recommend to NCDEQ that an extension of
one year be granted for installation. An extension recommendation may include a
contingency plan for those neighbors affected by the delay (i.e. temporary filtration
system) until the water lines can be completed.
K

Permanent Water Supply Process
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North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
June 1, 2015
CERTIFIED MAIL 70141200 00015707
RETURN RECEIPT REQUESTED
AL6R
Donald R. van der Vaart
Secretary
Subject: Resampling Results of Water Supply Well Sampling and Health Risk Evaluation
101 Mitchell Street, Belmont, NC 280.12
Dear Well Owner:
As part of the groundwater assessment conducted in accordance with N.C. Session Law 2014-
122, the North Carolina Department of Environment and Natural Resources (DENR) requested
that, at a minimum, all water supply wells within 1,000 feet of each coal ash waste facility's
boundary be sampled.
On May 13, 2015, pace Analytical Services, Inc. resampled the well(s) per recommendation by
the N. C. Department of Health and Human Services (DHHS) of the initial sampling results and
Health Risk Evaluation.
A complete copy of the laboratory sample results are attached for your review. The table below ,
provides a comparison: of the lab results with the groundwater standards. North Carolina's
groundwater standards are calculated to protect your groundwater as a source of drinking water,
The standards prohibit contamination that would create a threat to human health.
well Constituent Result 15A NCAC 2L .0202
Groundwater Standard
In addition to the constituents for which the state has a groundwater standard, some constituents we
tested for have an Interim Maximum Allowable Concentration. This, means that studies have
estimated their potential impact to human health but that a groundwater standard has not been
established. For a discussion of any of these constituents that are in your well, see your Health Risk
Evaluation provided by the DHHS.
It should also be noted that many of the constituents that were tested may be naturally occurring
and/or unrelated to coal ash ponds. Work is currently underway to determine their source and extent.
1611 Mail Service Center, Raleigh, North Carolina 27699-1611
Phone: [phone] Internet; h#tpJ/www.ncwater.org1
An E4ual OpperWily IAffirrnaVve Acfion Employer— Made in Part by recycled paper

If DENR determines that groundwater standards in your well have been exceeded and that a coal ash
pond is the source, state law requires that the utility provide you with an alternative water supply.
The DHHS, Division of Public Health, Epidemiology Section, Occupational and Environmental
Epidemiology Branch (OEEB) has evaluated the well sample results. DHHS has provided the
attached Health Risk Evaluation for the sample results from each well(s) sampled at the referenced
property.
If your attached Health Risk Evaluation includes a recommendation that your water not be used for
drinking or cooking, please note that the recommendation was made using a statistical risk threshold
of one additional case of cancer in a population of 1 million people who were exposed at that level
over a lifetime. For non -cancer health effects, DHHS relied on a daily lifetime exposure limit. It is
also important to recognize that your well water has been determined to meet all the criteria of the
federal Safe Drinkibg Water Act for public drinking water.
We understand the importance of this matter to you and also the complexity of this letter. We,
together with DHHS, are available to discuss the results and meet with you to answer any
questions to assure that all of this information is explained clearly and completely.
For questions regarding the Health Risk Evaluation, please contact N.C. DHHS, OEEB at 919-707-
5900. For questions about the on-going site assessments, please contact Debra Watts at 919- 807-
6338, or you can refer to our website at: hgp://portal.ncdenr.org/web/wA/water-test-resident info.
Sincerely,
D& 3-
4
Debra J. Watts, Supervisor
Animal Feeding Operations and Groundwater Protection Branch
Division of Water Resources .
Attachments: Analytical Results
Health Risk Evaluation(s)
Cc: Ed Sullivan - Duke Energy, Mail Code EC 13K, Post Office Box 1006, Charlotte, NC
28201-1006
Andrew Pitner, MRO WQROS
Gaston County Health Department
Dr. Mina Shehee, PhD — NCDHHS-DPH-Epidemiology Section-OEEB (1912 Mail Service
Center, Raleigh, North Carolina 27699-1912)
WQROS Central Office — File Copy

Jho 1 Water 'Information
.." and Use Recommendations
oldeparhnent
hvslih and
'' ""�� For Inorganic Chemical Contaminants
County: ( Name.
Sample ID #: F___i 6 iZ Address:
Sample Date: -13 — 1 S City:
TEST RESULTS ANIS USE RECOMMENDATIONS
E+ The following substance(s) exceeded the North Carolina Health Screening Level, and may result in an
increased health risk.* In order to reduce or eliminate this increased health risk, the North Carolina
Division of Public Health recommends that your well water not be used for drinking and cooking.
However, it may be used for washing, cleaning, bathing and showering. While this recommendation
represents the maximum in health protection, your well would still meet all the criteria of the federal Safe
Drinking Water Act for public drinking water sources.
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2. Q Sodium levels exceed the U.S. Environmental Protection Agency's (USEPA) Health Advisory Level for
sodium of 20 mg/L, The North Carolina Division of Public Health recommends that only individuals on
no or low sodium restricted diets not use this water for drinking or cooking. It may be used for washing,
cleaning, bathing, and showering.
3. © Re -sampling is recommended in months,
4. ❑ Re -sample for lead and /or copper. Take a first draw, 5 minute, and 15 minute sample inside the house
(preferably the kitchen) and if possible a first draw, 5 minute and a 15 minute sample at the well head to
determine the source of the lead and/or copper.
This form is applicable only to drinking water wells tested as specified by Session Law 2014-1225 (Senate Bill
729) 130A-309.209
For further information, please contact the Occupational and Environmental Epidemiology Branch at 919-707-
5900
*At 0.07 jig of hexavalent chromium in drinking water, the lifetime cancer risk for an adult is one -in -one million. At this level of risk, one additional case of cancer is
projected in a population of one million people exposed to hexavalent chromium over their lifetime. A daily lifetime exposure to vanadium that exceeds 03 ltg/L may
result in an increased non -cancer health risk
Revised April 2015