Multi ID#'s_Direction CA Other Primary Secondary Sources CAMA Sites_20170913

Water Resources
Environmental Quality
September 8, 2017
Ed Sullivan
Duke Energy
526 South Church Street
Mail Code EC 13K
Charlotte, North Carolina 28202
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
Subject: Technical Direction Regarding Other Primary and Secondary Sources at Duke Energy
Coal Ash Facilities
Dear Mr. Sullivan:
The purpose of this letter is for the North Carolina Department of Environmental Quality (DEQ) to
provide Duke Energy with technical direction regarding assessment and corrective action for sources
of groundwater and soil contamination at the 14 coal ash facilities. The Coal Ash Management Act of
2014 (CAMA) provides requirements for the assessment and abatement of soil and groundwater
contamination associated with coal combustion residuals (CCR) surface impoundments. Title 15A of
the North Carolina Administrative Code Subchapter 02L (02L) provides requirements for the
assessment and abatement of soil and groundwater contamination associated with any release.
DEQ recognizes that CAMA implements strict deadline requirements for milestone assessment,
corrective action, and closure events for the CCR surface impoundments. However, Duke Energy is
also bound by the rules and requirements of the North Carolina General Statutes and 02L to address
all contamination resulting from site activities. Therefore, Duke Energy must ultimately address soil
and groundwater contamination resulting from all primary and secondary sources at the coal ash
facilities, not just the CCR surface impoundments. Other primary sources include CCR storage areas,
raw coal piles, and structural fills. Secondary sources include all residual soil and groundwater
contamination resulting from the primary sources.
DEQ understands that Duke Energy's primary focus of the upcoming Comprehensive Site Assessment
(CSA) and Corrective Action Plan (CAP) Reports will be assessment and remediation of the CCR
impoundments. With this understanding, DEQ will allow Duke Energy to address remediation and
closure of the CCR surface impoundments on a separate timeline than the remediation of other primary
and secondary sources. However, it should be noted that when the DEQ approves a CSA or CAP for
a site that only addresses the CCR surface impoundments, potential revisions to these documents may
be necessary to address contamination contributed by other primary and secondary sources resulting
from site activities.
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 at the Central Office, at (919) 807-
6444.
Sincerely,
uc u..�
S. y ' merman, P.G., Director
Division of Water Resources
cc: Regional Office Supervisors
WQROS Central File Copy