NC0004961_RBSS CAP Part I_Appx A_Final_20151116

Appendix A
Regulatory
Correspondence

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A 4
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NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
August 13, 2014
CERTIFIED MAIL 7004 2510 0000 3651 1168
RETURN RECEIPT REQUESTED
Paul Newton
Duke Energy
526 South Church Street
Charlotte, NC 28202
Subject: Notice of Regulatory Requirements
Title 15A North Carolina Administrative Code (NCAC) 02L .0106
14 Coal Ash Facilities in North Carolina
Dear Mr. Newton:
Chapter 143, North Carolina General Statutes, authorizes and directs the Environmental
Management Commission of the Department of Environment and Natural Resources to protect
and preserve the water and air resources of the State. The Division of Water Resources (DWR)
has the delegated authority to enforce adopted pollution control rules.
Rule 15A NCAC 02L .0103(d) states that no person shall conduct or cause to be conducted any
activity which causes the concentration of any substance to exceed that specified in 15A NCAC
02L .0202. As of the date of this letter, exceedances of the groundwater quality standards at 15A
NCAC 02L .0200 Classifications and Water Quality Standards Applicable to the Groundwaters
of North Carolina have been reported at each of the subject coal ash facilities owned and
operated by Duke Energy (herein referred to as Duke).
Groundwater Assessment Plans
No later than September, 26 2014 Duke Energy shall submit to the Division of Water Resources
plans establishing proposed site assessment activities and schedules for the implementation,
completion, and submission of a comprehensive site assessment (CSA) report for each of the
following facilities in accordance with 15A NCAC 02L .0106(g):
Asheville Steam Electric Generating Plant
Belews Creek Steam Station
Buck Steam Station
Cape Fear Steam Electric Generating Plant
Cliffside Steam Station
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Phone: [phone] Internet: www.ncdenr.gov
An Equal Opportunity 1 Affirmative Action Employer— Made in part by recycled paper

Mr. Paul Newton
August 12, 2014
Page 2 of 3
Dan River Combined Cycle Station
H.F. Lee Steam Electric Plant
Marshall Steam Station
Mayo Steam Electric Generating Plant
Plant Allen Steam Station
Riverbend Steam Station
Roxboro Steam Electric Generating Plant
L.V. Sutton Electric Plant
Weatherspoon Steam Electric Plant
The site assessment plans shall include a description of the activities proposed to be completed
by Duke that are necessary to meet the requirements of 15A NCAC 02L .0106(g) and to provide
information concerning the following:
(1) the source and cause of contamination;
(2) any imminent hazards to public health and safety and actions taken to mitigate
them in accordance to 15A NCAC 02L .0106(f);
(3) all receptors, and significant exposure pathways;
(4) the horizontal and vertical extent of soil and groundwater contamination and all
significant factors affecting contaminant transport; and
(5) geological and hydrogeological features influencing the movement,. chemical, and
physical character of the contaminants.
For your convenience, we have attached guidelines detailing the information necessary for the
preparation of a CSA report. The DWR will review the plans and provide Duke with review
comments, either approving the plans or noting any deficiencies to be corrected, and a date by
which a corrected plan is to be submitted for further review and comment or approval. For those
facilities for which Duke has already submitted groundwater assessment plans, please update
your submittals to ensure they meet the requirements stated in this letter and referenced
attachments and submit them with the others.
Receptor Survey
No later than October 14t', 2104 as authorized pursuant to 15A NCAC 02L .0106(g), the DWR is
requesting that Duke perform a receptor survey at each of the subject facilities and submitted to
the DWR. The receptor survey is required by 15A NCAC 02L .0106(g) and shall include
identification of all receptors within a radius of 2,640 feet (one-half mile) from the established
compliance boundary identified in the respective National Pollutant Discharge Elimination
System (NPDES) permits. Receptors shall include, but shall not be limited to, public and private
water supply wells (including irrigation wells and unused or abandoned wells) and surface water
features within one-half mile of the facility compliance boundary. For those facilities for which
Duke has already submitted a receptor survey, please update your submittals to ensure they meet
the requirements stated in this letter and referenced attachments and submit them with the others.
If they do not meet these requirements, you must modify and resubmit the plans.

Mr. Paul Newton
August 12, 2014
Page 3 of 3
The results of the receptor survey shall be presented on a sufficiently scaled map. The map shall
show the coal ash facility location, the facility property boundary, the waste and compliance
boundaries, and all monitoring wells listed in the respective NPDES permits. Any identified
water supply wells shall be located on the map and shall have the well owner's name and
location address listed on a separate table that can be matched to its location on the map.
Failure to comply with the State's rules in the manner and time specified may result in the
assessment of civil penalties and/or the use of other enforcement mechanisms available to the
State.
We appreciate your attention and prompt response in this matter. If you have any questions,
please feel free to contact S. Jay Zimmerman, Water Quality Regional Operations Section Chief,
at [phone].
2hn
ierely,
E. Skvarla, III
Attachment enclosed
cc: Thomas A. Reeder, Director, Division of Water Resources
Regional Offices — WQROS
File Copy

August 12, 2014
GUIDELINES FOR COMPREHENSIVE SITE ASSESSMENT
This document provides guidelines for those involved in the investigation of
contaminated soil and/or groundwater, where the source of contamination is from:
■ Incidents caused by activities subject to permitting under G.S. 143-215.1
■ Incidents caused by activities subject to permitting under G.S. 87-88
■ Incidents arising from agricultural operations, including application of
agricultural chemicals, but not including unlawful discharges, spills or
disposal of such chemicals
Comprehensive Site Assessment (CSA)
NOTE: Regional Offices may request additional information in support of the CSA to aid
in their review and will not approve the CSA if any of the elements specified below have
not been included or have not been sufficiently addressed
Minimum Elements of the Comprehensive Site Assessment Report:
A. Title Page
• Site name, location and Groundwater Incident number (if
assigned) and Permit Number;
• Date of report;
• Responsible Party and/or permiee, including address and
phone number;
• Current property owner including address and phone
number;
• Consultant/contractor information including address and
phone number;
• Latitude and longitude of the facility; and
• Seal and signature of certifying P.E. or P.G., as appropriate.
B. Executive Summary
The Executive Summary should provide a brief overview of the pertinent
site information (i.e., provide sufficient information to acquaint the reader
with the who, what, when, where, why and how for site activities to date).
1. Source information:
Type of contaminants
2. Initial abatement/emergency response information.
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August 12, 2014
3. Receptor information:
•
Water supply wells;
•
Public water supplies (wells, surface water intakes);
•
Surface water bodies;
•
Wellhead protection areas;
•
Deep aquifers in the Coastal Plain physiographic region;
•
Subsurface structures; and
•
Land use.
4. Sampling/investigation results:
•
Nature and extent of contamination;
•
Maximum contaminant concentrations;
•
Site hydrogeology.
5. Conclusions
and recommendations.
C. Table of Contents
• First page number for each section listed.
• List of figures (all referenced by number and placed in a
single section following contents text).
• List of tables (all referenced by number and placed in a single
section following contents text).
• List of appendices.
D. Site History and Source Characterization
• Provide a history of property ownership and use. Indicate
dates of ownership, uses of the site, and potential sources of
contaminants.
• Discuss the source(s) of contamination, including primary
and secondary sources.
• For permitted activities, describe nature of activity, permitted
waste, application of all instances of
over-application/irrigation of wastes or water
• Summarize assessment activities and corrective actions
performed to date including emergency response, initial
abatement, primary and secondary source removal.
• Discuss geographical setting and present/future surrounding
land uses.
E. Receptor Information
Provide a site map showing labeled well locations within a

August 12, 2014
minimum of 1500 feet of the known extent of contamination.
Key to the table and maps described.
NOTE: As the known extent of contamination changes, the
receptor survey must be updated to reflect the change. This
applies throughout the Receptor Information section.
• In table format, list all water supply wells, public or private,
including irrigation wells and unused wells, (omit those that
have been properly abandoned in accordance with 15A
NCAC 2C .0100) within a minimum of 1500 feet of the known
extent of contamination. Note whether well users are also
served by a municipal water supply.
• For each well, include well number, well owner and user
names, addresses and telephone numbers, use of the well,
well depth, well casing depth, well screen interval, and
distance from source of contamination;
NOTE: It will often be necessary to conduct any or all of the
following in order to ensure reliability in a water supply well
survey.
o Call the city/county water department to inquire about
city water connections,
o Visit door-to-door (make sure that you introduce
yourself and state your purpose to residents prior to
examining their property) to obtain accurate
description of water usage, and if some residents are
not at home, ask surrounding neighbors who are
home about the water usage at those residences.
Even if a public water line is available, some
residents still use their well water and are not
connected to the public water system; and
o Search for water meters and well houses.
• Site map showing location of subsurface structures (e.g.,
sewers, utility lines, conduits, basements, septic tanks,
drain fields, etc.) within a minimum of 1,500 feet of the known
extent of contamination;
• Table of surrounding property owner addresses;
• Discuss the availability of public water supplies within a
minimum of 1,500 feet of the source area, including the
distance and location to the nearest public water lines and
the source(s) of the public water supply;
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August 12, 2014
• Identify all surface water bodies (e.g., ditch, pond, stream,
lake, river) within a minimum of 1,500 feet of the source of
contamination;
• Determine the location of any designated wellhead protection
areas as defined in 42 USC 300h-7(e) within a minimum of
1,500 feet of the source of contamination. Identify and
discuss the location of the water supply well(s) for which the
area was designated a wellhead protection area, and the
extent of the protected area. Include information about the
well owner, well -construction specifications (especially at
screened intervals), pumping rate and pumping schedule.
Information regarding designated wellhead. protection areas
may be obtained by contacting the Public Water Supply
Section at [phone];
• Discuss the uses and activities (involving possible human
exposure to contamination) that could occur at the site and
adjacent properties. Examples of such activities and uses
include but are not limited to use of a property for an office,
manufacturing operation, residence, store, school, gardening
or farming activities, recreational activities, or undeveloped
land;
• Determine whether the contaminated area is located in an
area where there is recharge to an unconfined or
semi -confined deeper aquifer that is being used or may be
used as a source of drinking water. Based on a review of
scientific literature on the regional hydrogeology and well
construction records and lithological logs for deeper wells in
the area, identify and describe the deep aquifers underlying
the source of contamination. Include information on the depth
of the deep aquifer in relation to the surficial saturated zone,
the lithology and hydraulic conductivity of the strata between
the surficial aquifer and the deeper aquifer, and the
difference in groundwater head between the surficial aquifer
and the deeper aquifer. Discuss the local and regional usage
of the deep aquifer and the draw down from major pumping
influences. Also, specify the distance from the source of
contamination to major discharge areas such as streams and
rivers. Cite all sources and references used for this
discussion.
NOTE: This requirement (last bullet) only pertains to
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August 12, 2014
contamination sources in the Coastal Plain physiographic region
as designated on a map entitled "Geology of !North Carolina"
published by the Department in 1985. However,
recharge/discharge, hydraulic conductivity, lithology, head
difference, etc. is also important information at mountains
and piedmont sites.
F. Regional Geology and Hydrogeology
Provide a brief description of the regional geology and hydrogeology. Cite
all references.
G. Site Geology and Hydrogeology
• Describe the soil and geology encountered at the site. Use
the information obtained during assessment activities (e.g.,
lithological descriptions made during drilling, probe surveys,
etc.). This information should correspond to the geologic
cross sections required in N. below; and
• Based on the results of the groundwater investigation,
describe the site hydrogeology, including a discussion of
groundwater flow direction, hydraulic gradient, hydraulic
conductivity and groundwater velocity. Discuss the effects of
the geologic and hydrogeological characteristics on the
migration, retardation, and attenuation of contaminants.
H . Soil Sampling Results
Using figures and tables to the extent possible, describe all soil sampling
performed to date and provide the rationale for sample locations, number
of samples collected, etc. Include the following information:
• Location of soil samples;
• Date of sampling;
• Type of soil samples (from excavation, borehole, Geoprobe,
etc.);
• Soil sample collection procedures (split spoon, grab, hand
auger, etc.)
• Depth of soil samples below land surface;
• Soil sample identification
• Soil sample analyses;
• Soil sample analytical results (list any contaminant detected
above the method detection limit); and
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August 12, 2014
• Identify any sample analytical results that exceed the
applicable cleanup levels.
NOTE: Information related to H. above should correspond to the
sampling location and sampling results maps required in N. below.
I . Groundwater Sampling Results
Using figures and tables to the extent possible describe the groundwater
sampling performed to date and provide the rationale for sample locations
(based on source and contaminant type), number of samples collected,
etc. Include the following information:
• Location of groundwater samples and monitoring wells;
• Date of sampling;
• Groundwater sample collection procedures (bailer, pump,
etc.);
• Groundwater sample identification and whether samples
were collected during initial abatement, CSA, etc.;
• Groundwater sample analyses;
• Groundwater sample analytical results (list any contaminant
detected above the method detection limit; and
• Identify all sample analytical results that exceed 15A NCAC
2L or interim standards.
NOTE: Information related to 1. above should correspond to the
sampling location and sampling results maps required in N. below.
J. Hydrogeological Investigation
Describe the hydrogeological investigation performed including all
methods, procedures and calculations used to characterize site
hydrogeological conditions. The following information should be discussed
and should correspond to the maps and figures required below:
• Groundwater flow direction;
• Hydraulic gradient (horizontal and vertical);
• Hydraulic conductivity;
• Groundwater velocity;
• Contaminant velocity;
• Slug test results; *
• Aquifer test results;
• Plume's physical and chemical characterization; and
• Fracture trace study if groundwater in bedrock is impacted.
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August 12, 2014
* Check with the Regional Office prior to performing these tests
and study to see if necessary for the site.
K. Groundwater Modeling Results
Groundwater modeling or predictive calculations may be necessary at
some sites (source area proximate to surface water, source area located
within wellhead protection area or source area overlying semi -confined or
unconfined deeper Coastal Plain aquifer) to verify, based on site specific
hydrogeological conditions, whether groundwater contamination poses a
risk to receptors. For contamination shown to pose a risk to receptors,
groundwater modeling may be necessary to determine an appropriate
cleanup level for contaminated groundwater. Modeling should illustrate the
input data used to complete the model and will generally be required for
natural attenuation proposals (see Groundwater Modeling Policy at
http://portal. ncdenr.org/web/wq/aps/a-wr)ro/policy).
NOTE: Input data for models should be derived from site specific
information with limited assumptions or estimates. All assumptions and
estimated values including biodegradation rates must be conservative
(predict reasonable worst -case scenarios) and must be well documented.
L. Discussion
• Nature and extent of contamination, including primary and
secondary source areas, and impacted groundwater and
surface water resources;
• Maximum contaminant concentrations;
• Contaminant migration and potentially affected receptors
M. Conclusions and Recommendations
If corrective action will be necessary, provide a preliminary evaluation of
remediation alternatives appropriate for the site. Discuss the remediation
alternatives likely to be selected. Note that for impacts to groundwater
associated with permitted activities, corrective action pursuant to 15A
NCAC 2L .0106(k), (1) and (m) is not applicable, unless provided for
pursuant to 15A NCAC 2L .0106(c) and (e) or through a variance from the
Environmental Management Commission (EMC).
N. Figures
9 71/2 minute USGS topographic quadrangle map showing an area

August 12, 2014
within a minimum of a 1,500-foot radius of the source of
contamination and depicting the site location, all water supply wells,
public water supplies, surface water intakes, surface water bodies,
designated well head protection areas, and areas of recharge to
deeper aquifers in the Coastal Plain that are or may be used as a
source for drinking water;
Site map locating source areas, site boundaries, buildings, all water
supply wells within a minimum of 1,500 feet, named
roads/easements/right-of-ways, subsurface utilities, product or
chemical storage areas, basements and adjacent properties, scale
and north arrow;
At least two geologic cross sections through the saturated and
unsaturated zones intersecting at or near right angles through the
contaminated area using a reasonable vertical exaggeration.
Indicate monitoring well/sample boring/sample locations and
analytical results for soil samples. Identify the depth to the water
table. Provide a site plan showing the locations of the cross
sections;
■ Site map(s) showing the results of all soil sampling conducted.
Indicate sampling identifications, sampling depths, locations and
analytical results;
■ Site map(s) showing the results of all groundwater sampling
conducted. Indicate sampling locations, monitoring well
identifications, sample identifications, and analytical results;
Separate groundwater contaminant iso-concentration contour maps
showing total volatile organic compound concentrations, total
semi -volatile organic compound concentrations and concentrations
for the most extensive contaminant. Maps should depict the
horizontal and vertical extent. Contour line for applicable 2L
standard should be shown in bold;
■ Site map(s) showing the elevation of groundwater in the monitoring
wells and the direction of groundwater flow. Contour the
groundwater elevations. Identify and locate the datum (arbitrary
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August 12, 2014
1000, USGS, NGVD) or benchmark. Indicate the dates that water
level measurements were made. There should be one map for each
series of water level measurements obtained;
■ Groundwater contaminant iso-concentration contour cross-section;
and
■ Site map(s) showing the monitoring wells.
NDTE: If possible, use a single base map to prepare site maps using a
map scale of 9 inch = 40 feet (or a smaller scale for large sites, if
necessary). Maps and figures should include conventional symbols,
notations, labeling, legends, scales, and north arrows and should
conform to generally accepted practices of map presentation such as
those enumerated in the US Geological Survey pamphlet, "Topographic
Maps".
O. Tables
List all water supply wells, public or private, including irrigation wells
and unused wells, (omit those that have been properly abandoned
in accordance with 15A NCAC 2C .0100) within a minimum of 1500
feet of the known extent of contamination For each well, include the
well number (may use the tax map number), well owner and user
names, addresses and telephone numbers, use of the well, well
depth, well casing depth, well screen interval and distance from the
source of contamination;
List the names and addresses of property owners and occupants
within or contiguous to the area containing contamination and all
property owners and occupants within or contiguous to the area
where the contamination is expected to migrate;
■ List the results for groundwater samples collected including sample
location; date of sampling; sample collection procedures (bailer,
pump, etc.); sample identifications; sample analyses; and sample
analytical results (list any contaminant detected above the method
detection limit in bold); and
List for each monitoring well, the monitoring well identification
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August 12, 2014
numbers, date water levels were obtained, elevations of the water
levels, the land surface, top of the well casing, screened interval
and bottom of the well.
P Appendices
• Boring logs and lithological descriptions;
• Well construction records;
• Standard procedures used at site for sampling, field equipment
decontamination, field screening, etc.;
• Laboratory reports and chain -of -custody documents;
• Copies of any permits or certificates obtained, permit number,
permitting agency, and
• Modeling data and results;
• Slug/pumping test data; and
• Certification form for CSA
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August 12, 2014
DIVISION OF WATER RESOURCES
Certification for the Submittal of a Comprehensive Site Assessment
Responsible Party and/or Permittee:
Contact Person:
Address:
City: State: Zip Code:
Site Name:
Address:
City: State: Zip Code:
Groundwater Incident Number (applicable):
I, , a Professional Engineer/Professional Geologist
(circle one) for (firm or
company of employment) do hereby certify that the information indicated below is
enclosed as part of the required Comprehensive Site Assessment (CSA) and that
to the best of my knowledge the data, assessments, conclusions,
recommendations and other associated materials are correct, complete and
accurate.
(Each item must be initialed by the certifying licensed professional)
1. The source of the contamination has been identified. A list of all
potential
sources of the contamination are attached.
2. Imminent hazards to public health and safety have been identified.
3. Potential receptors and significant exposure pathways have been
identified.
4. Geological and hydrogeological features influencing the movement
of groundwater have been identified. The chemical and physical character of the
contaminants have been identified.
5. The CSA sufficiently characterizes the cause, significance and
extent of groundwater and soil contamination such that a Corrective Action Plan
can be developed. If any of the above statements have been altered or items not
initialed, provide a detailed explanation. Failure to initial any item or to provide
written justification for the lack thereof will result in immediate return of the CSA to
the responsible party.
(Please Affix Seal and Signature)
11

!� DuRe
ENERGY.
Uctober 9, 2U 1 h
Mi . To,,, Reeds
AssisLanL Secretary for the Environment
North Ca<ohiia Department of Environmental duality
IOU I Mail Service Center
Raleigh, North uarolina 27by9- I ou I
Subject: 9U Day Extension for Corrective Action Plans
Dear A3w3iana See,etary Reeder:
Flany R. Sideris
Senior Vice-Prebident
Environmental, Health & Safety
526 South Uhumh Street:
Mail Code EC3XP
CMallotte, rvortM Carolina 252u2
704-382-4303
Duke Energy is requesting a 9U day extension for submittal of the final Groundwater Corrective Action
Plans per Section 130A-309.209(b)(1) of the Coal Ash Management Act of 2014. This extension request
was discussed with NCDEQ technical statt on September 23 and with NCDEQ management on October
2. It i3 Duke Eue,gy'6 uude►standing based on tfiiese discussions wat NCDEQ would like to divide the
uAP scope into two pans with the tirst pit submitted on the orig*,nal due dates and the Secchid pater
aubu.►tied 90 days later. The following due dates are our understanding based on these discussions:
Plant Name
CAP Part I Due Date
CAP Part 2 Due Date
Weatherspoon Power Plant
November 3, 2015
February 1, 2016
HF Lee Energy Complex
November 3, 2015
February 1, 2016
L.V. Sutton Energy Complex
November 3, 2015
February 1, 2016
Dan River Steam Station
November 12, 2015
February 10, 2016
Rogers Energy Complex
November 16, 2015
February 14, 2016
Riverbend Steam Station
November 16, 2015
February 14, 2016
Allen Steam Station
November 21, 2015
February 19, 2016
Buck Steam Station
November 21, 2015
February 19, 2016
Asheville Steam Electric Plant
November 21, 2015
February 19, 2016
Cape Fear Plant
Mayo Steam Electric Power
Plant
December 1, 2015
February 29, 2016
December 1, 2015
February 29, 2016
February 29, 2016
Roxboro Steam Electric Plant
December 1, 2015
Marshall Steam Station —
Belews Creek Steam Station --
December 7, 2015
March 6, 2016
December g, 2015
March 7, 2016

UuKe Energy proposes that the Part 1 CAP reports (submitted 90 days after the uroundwater Assessment
Reports were submitted) include: backg -und ;nfoi niation, a bucf Summary uf the CSA find►ng5, a bl;ef
description of site geology and tiydrogeology, a summary of the previously completed receptor survey, a
description of 2L and 2B m%ceedance57 p►epo6ed 5;te-5pecif►e g►eundwater background concent►atiom, a
detailed description of the site conceptual model, and groundwater now and transport modeling. Part 2
would contain the re,ita;nde, of the CAP including the ►;5k asse5sinent, alternative methods for achieving
restoration, conceptual plans for recommended corrective actions, implementation schedule, and a plan
for future monitoiwg and eporting.
It you have comments and/or questions, please direct them to me at 704-392-4303.
Sincerely,
Harry K. Side,;5
Senior Vice-Yresidem
Enviioinnental, Health & Safety