Performance Monitoring Plan Comments_20170720

Water Resources
Environmental Quality
July 20, 2017
Paul Draovitch
Senior Vice President
Environmental, Health & Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, North Carolina 28202
Subject: Performance Monitoring Plan (June 27, 2017) Comments
Dear Mr. Draovitch:
ROY COOPER
Governor
MICHAEL S. REGAN
secretary
S. JAY ZIMMERMAN
Director
The North Carolina Department of Environmental Quality (DEQ) has received and reviewed the
"Performance Monitoring Plan" letter dated June 27, 2017. DEQ offers the following comments
regarding the subject letter.
Section 2.1: Initial Treated Water Sample
• Duke Energy states, "Following installation of treatment equipment, a sample of treated
water will be collected for analytical testing by an independent laboratory, certified by the
state for North Carolina for drinking water analysis. "
o DEQ Comment: DEQ will require Duke Energy take a sample of raw water (prior
to filtration system) during the initial sampling event and each subsequent
performance monitoring sampling event. These results will also be submitted to
the various parties as noted in the Performance Monitoring Plan.
Section 4.0: Corrective Action
Duke Energy states, "If equipment inspections indicate equipment is not operating
properly or if analytical results indicate performance issues during the maintenance
inspections described in Section 2.0, the water treatment company will initiate corrective
action. "
o DEQ Comment: There appears to be two potential scenarios to address: (1) the
performance standards have been exceeded and (2) the parameter analytical results
are trending upward and approaching the performance standards. Duke Energy
should clearly indicate what constitutes a "performance issue" and the
recommended corrective actions based on the scenarios including timeframes for
the corrective actions.
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

Duke Energy states, "Corrective action may range from more frequent regeneration of
resin beds to installation of additional equipment. The water treatment company will
inform Duke Energy of adjustments to installed equipment and confer with Duke before
installing additional or replacing existing components. If more than minor adjustments
are made, a treated water sample will be collected for laboratory analysis. "
o DEQ Comment: As a part of the corrective actions for the scenarios mentioned
above, Duke Energy must include a provision to provide alternate water (i.e. bottled
water) to the affected household (or households) until the problems are resolved.
Section 5.0 Report Submittal
• Duke Energy states several times, "Analytical results will also be sent to the homeowner
for their records. "
o DEQ requests that Duke Energy provide a copy of any reports generated for a
treatment system to the homeowner and not just the analytical results. DEQ also
requires Duke Energy to maintain copies of all records and analytical results.
Duke Energy states, "Results for any system not meeting performance standards will be
reported to NCDEQ within 15 days of receiving the laboratory report along with a report
of corrective actions initiated. Analytical results will also be sent to the homeowner for
their records. "
o DEQ Comment: The household(s) should be notified within 24 hours if their
system is not meeting performance standards. Again, Duke Energy must make
provisions for alternate water (i.e. bottled water) to any household (or households)
if their system does not meet performance standards. Alternate water should be
provided within 24 hours of discovery of system performance issues and should
continue to be provided until the performance issues are resolved.
Other Comment
• Please provide a description of how the system backwash will be disposed. Please note
that our current rules require a permit for any discharge of wastewater to surface water or
the land surface.
DEQ is requesting resolutions to the comments above by August 4, 2017. The resolutions should
be incorporated in a revised Performance Monitoring Plan. If you have any other questions, please
contact Debra Watts at [phone].
Ton Ris#&rd, Section Chief
Water Quality Regional Operations Section, Division of
Water Quality
cc: WQROS Regional Office Supervisors
WQROS Central File Copy