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Home My WebLink AboutMulti ID#'s_Schedule Updates–Request for Ext of Milestone Dates_20170328Water Resources Environmental Quality March 28, 2017 Paul Draovitch Senior Vice President Environmental, Health & Safety Duke Energy 526 South Church Street Mail Code EC3XP Charlotte, North Carolina 28202 ROY COOPER Governor MICHAEL S. REGAN Secretary S. JAY ZIMMERMAN Director Subject: Interim Action Plan Schedule Updates — Request for Extension of Milestone Dates Dear Mr. Draovitch: The North Carolina Department of Environmental Quality (DEQ) received your request for extension of the deadlines for completing the interim actions at the Asheville Steam Electric Plant, Belews Creek Steam Station, H. F. Lee Energy Complex, and the L. V. Sutton Energy Complex in your "Interim Action Plan Schedule Updates" letter dated February 17, 2017 (attached). DEQ is hereby approving the request for extension. DEQ understands that, meeting the milestone dates is contingent upon several things including issuance of NPDES permits, permitting through other agencies, and DEQ review and comment on additional submitted Basis of Design reports. In the letter, Duke assumes that DEQ will review and return comments to the Basis of Design packages within 10 business days. Please note that there are no regulatory requirements for timeframes to review these documents and that DEQ may require additional time to review and provide comments. The proposed schedules do not anticipate additional submittals after comments are received for the 100% Basis of Design. However, DEQ will review and may provide comments on the 100% Basis of Design package, which may require additional submittal(s) to address any concerns. If the anticipated milestone dates in this request are altered, please inform the appropriate DEQ Regional Office and Central Office via email, documenting the reasons for any changes. !`� Nothing Compares State of North Carolina I Environmental Quality I Division of Water Resources Water Quality Regional operations Section 1636 Mail Service Center I Raleigh, North Carolina 27699-1636 919-707-9129 If you have any questions, please feel free to contact Steve Lanter (Central Office) at 919-807- 6444. Sincerely, S. _y Zig nerman, P.G., Director Division of Water Resources Attachment: Interim Action Plan Schedule Updates letter from Duke dated February 17, 2017 cc: ARO WQROS Regional Office Supervisor WARO WQROS Regional Office Supervisor WIRO WQROS Regional Office Supervisor WSRO WQROS Regional Office Supervisor WQROS Central File Copy Page 2 of 2 f% DUKE e ENERGY. February 17, 2016 Mr. S. Jay Zimmerman, Director Division of Water Resources North Carolina Department of Environmental Quality 1611 Mail Service Center Raleigh, North Carolina 27699-1611 Subject: interim Action Plan Schedule Updates Asheville Steam Electric Plant 6elews Creek Steam Station H. F. Lee Energy complex L.V. Sutton Energy Complex Dear Mr. Zimmerman: 526 South Church Sueet Mal Code EC13K Charlotte. North Carchns 26702 960-3733719 Throughout the first half of 2016, Duke Energy, our consultants and Department of Environmental Quality (DEQ) staff held many discussions regarding the schedules associated With the implementation of accelerated remedlation at the facilities listed above. On July 22, 2016, Duke Energy received a letter from DEQ that stated, "The remedial system start-up dates for each facility shall be no later than March 31, 2017. if the start-up date cannot be met, Duke Energy shall submit in writing, no later than March 1, 2017, a request for extension of this date and documentation of why the date cannot be met." On September 30, 2016, Duke Energy submitted updated schedules to DEQ projecting completion dates beyond March 31, 2017. In follow-up conversations, including most recently on January 30, 2017, DEQ reiterated the direction that Duke Energy submit updated schedules in February 2017 to formally request an extension. Duke Energy is providing the enclosed updated schedules to formally request schedule extensions due in part to additional milestones requested by DEQ as well as the continued anticipation of NPDES permit modifications that are required to complete start-up of the systems. These schedules are contingent on receiving NPDES permits by the anticipated dates shown. If you have comments and/or questions, please direct them to me at 980-373-3719. Sincerely, D. Edwin M. Sullivan, PE Director— Waste & Groundwater Programs Environmental, Health & Safety Enclosure: Interim Action Plan Schedule Updates - Asheville Steam Electric Plant, Belem Creek Steam Station, H.F. Lee Energy Complex and L.V. Sutton Energy Complex 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 301h 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 aftertreatment 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% Boo 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 • NPDESPermit Anticipated i 60% Design Submittal to DEQ (Additional review required during January30`h 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 Welland 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 November 22, 2016 • 60% Design Submittal to DEQ (Additional review required during January 301h 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 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 forthe 100% BOD (i.e. any additional required submittals after 100% BOD will delay the anticipated start date.) EI