Multi ID#'s_IAP Schedule Updates to DEQ 2017-0217_20160217

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"•. ENERGY:
February 17, 2016
Mr. S. Jay Zimmerman, Director
Divislai I ;-if Water Resources
North Carolina Department or Environmental Quality
113 1 j Mail Service C,nter
Raleigh, N-Wrth Carolina 27699-1611
Subject: Interim Action Plan Schedule Updates
A.heville Steam Electric Plant
Belewz Cj eek Steam Station
H.F. Lee Energy com,.lux
C. v, Sutton Energy Cumplex
Duar Mr. Zimmerman:
5A 50um CrluMM street
Mail C—do a EC13K
CWotte, ,yonn Caraina zazoz
n80-3r33i ra
Throughout the first Balt of 2016, Duke Energy, our consultants anti Department of
Environmental Quality (DEQ) staff held many discussions regarding the acheduIE5 associated
with the implementation of accelerated remediation at the facilitiz's listed abuva. On July 22,
2016, Dake Energy received a letter from DEQ that stated, "The remedial system start-up [laces
for each facility shall 13e no later than March 31, 2017. If the start-up date cannot be met, Duke
Energy sRali sul3mit in writing, ma later than March 1, 201 r, a request for ext.-rsion of this date
anti documentation of why the date cannot be met."
On September 30, 20 15, oulte energy submitted apdated schedules to DEQ projecting
completion nates Beyond March 31, 2017. In follow-up conversations, including most recently
on janaary 30, 2017, DEQ reiterated the dirction that DaRe Energy submit updated 5chedaleb
in February 2017 to fo, mally request an extension.
Dake Energy is providing tRe enclosed updated Schedules to formally request scRedule
extensions Clue in part tw additiunal milestones requested Izy DeQ as well as thU continued
anticipation of NPDES permit modifications tnat are required to complete start-up of the
systems. These schedules are contingent on receiving NPDES pan, its by the anticipates gates
shown.
If you Rave comments aFidlor questions, please direct them to me at 980-373-3719.
Sincerely,
D zz�'— "W
D. Edwin M. Sullivan, PE
Directo, - Waste & Gruunowater Programs
Environmental, r1ealth & Safety

Enclo5ors: Interim Action Plan Schedule upeates - Hsnevilie steam Electric Plant, B-wl-wv�o
Creek Steam Station, R.F. lee Energy Cuimplzx and L.V. Sutton Energy
Compex
Cc. Jim Wells - Duke Energy

Enclosure 1
Asheville Steam Electric Plant
Interim Action Plan Schedule Update to DEQ
February 17, 2017
30% Design Submitted to DEQ
60% Design Submittal to DEQ
(Additional review required during January 30th conference call with DEQ)
100% Design Submittal to DEQ
Final Regulatory Approvals for Construction
(includes 100% BOD, Well Recovery, E&SC, etc. excludes NPDES Permit Modification)
Begin Extraction Well and Treatment System Construction
NPDES Permit Anticipated
Extraction Well and Treatment System Begin Operation
November 21, 2016
March 24, 2017
June 16, 2017
July 10, 2017
July 24, 2017
September 1, 2017
October 27, 2017
Note: Asheville Steam Electric Plant has options after treatment of extracted groundwater; NPDES discharge at permitted outfall or discharge to
sanitary sewer system. Both options in close proximity to the area of groundwater extraction. For scheduling purposes and as directed by DEQ in the
January 30, 2017 conference call, we assume DEQ will review and return comments to the Basis of Design packages within 10 business days. Extraction
Well and Treatment System operation schedule is contingent upon receipt of the NPDES permit modification on or before the anticipated date. The
current schedule does not anticipate additional submittals after comments are received for the 100% BOD (i.e. any additional required submittals after
100% BOD will delay the anticipated start date.)

Enclosure 1
Belews Creek Steam Station
Interim Action Plan Schedule Update to DEQ
February 17, 2017
30% Design Submitted to DEQ
NPDES Permit Anticipated
60% Design Submittal to DEQ
(Additional review required during January 30th conference call with DEQ)
100% Design Submittal to DEQ
Final Regulatory Approvals for Construction
(includes 100% BOD, Well Recovery, E&SC, etc. excludes NPDES Permit Modification)
Begin Extraction Well and Treatment System Construction
Extraction Well and Treatment System Begin Operation
December 29, 2016
April 3, 2017
April 10, 2017
July 10, 2017
July 31, 2017
August 8, 2017
November 14, 2017
Note: For scheduling purposes and as directed by DEQ in the January 30, 2017 conference call, we assume DEQ will review and return comments to the
Basis of Design packages within 10 business days. Extraction Well and Treatment System operation schedule is contingent upon receipt of the NPDES
permit modification on or before the anticipated date. The current schedule does not anticipate additional submittals after comments are received for
the 100% BOD (i.e. any additional required submittals after 100% BOD will delay the anticipated start date.)

Enclosure 1
H.F. Lee Energy Complex
Interim Action Plan Schedule Update to DEQ
February 17, 2017
30% Design Submitted to DEQ
60% Design Submittal to DEQ
(Additional review required during January 30th conference call with DEQ))
NPDES Permit Anticipated
100% Design Submittal to DEQ
Final Regulatory Approvals for Construction
(includes 100% BOD, Well Recovery, E&SC, Wetlands, etc. excludes NPDES Permit)
Begin Extraction Well and Treatment System Construction
Extraction Well and Treatment System Begin Operation
November 22, 2016
February 27, 2017
May 1, 2017
June 8, 2017
June 29, 2017
July 10, 2017
October 31, 2017
Note: Wetlands permitting could significantly impact schedule shown. For scheduling purposes and as directed by DEQ in the January 30, 2017
conference call, we assume DEQ will review and return comments to the Basis of Design packages within 10 business days. Extraction Well and
Treatment System operation schedule is contingent upon receipt of the NPDES permit modification on or before the anticipated date. The current
schedule does not anticipate additional submittals after comments are received for the 100% BOD (i.e. any additional required submittals after 100%
BOD will delay the anticipated start date.)

Enclosure 1
L.V. Sutton Energy Complex
Interim Action Plan Schedule Update to DEQ
February 17, 2017
100% Design Submitted to DEQ
(includes 100% design package and well recovery permit application)
Well recovery permit approval received
Final Regulatory Approvals for Construction
(includes 100% BOD)
Begin Extraction Well and Treatment System Construction
Extraction Well and Treatment System Begin Operation
January 27, 2017
February 14, 2017
March 17, 2017
April 3, 2017
August 29, 2017
Note: L.V. Sutton Energy Complex NPDES permit already includes discharge from treatment of extracted groundwater via NPDES permitted outfall 001.
The current schedule does not anticipate additional submittals after comments are received for the 100% BOD (i.e. any additional required submittals
after 100% BOD will delay the anticipated start date.)
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