Multi ID#'s_Clarification on Excavation Plan Submittals 10-31-17_20171031

Water Resources
Environmental Quality
October 31, 2017
Paul Draovitch
Senior Vice President
Environmental, Health & Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, North Carolina 28202
Subject: Clarification on Excavation Plan Submittals
Dear Mr. Draovitch:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
Per the "Coal Combustion Residuals Surface Impoundment Closure Guidelines for Protection of
Groundwater" dated November 4, 2016,
A stand-alone Excavation Soil Sampling Plan (Plan) generated for closure of a CCR
surface impoundment shall be developed to ensure the proposed excavation design is
comprehensive enough in scope to meet the performance standards for closure. This Plan
shall be submitted to DEQ as part of an Excavation Plan, with details to show how the
sample analytical results and related modeling will incorporate the data collected as part
of the final overall closure plan for approval, as dictated by §130A-309.214.
It is the Department of Environmental Quality's (DEQ) position that the Excavation Plan and the
Excavation Soil Sampling Plan be submitted to DEQ Pdor to excavation activities. To date, DEQ
has received Excavation Plans for the following facilities:
Facility
Surface Impoundments and Other Areas
Date of Plan
Covered
Asheville Steam Electric Plant
1964 Ash Basin and 1982 Ash Basins
December 2016
*James E. Rogers Energy
Units 1-4
March 2, 2017
Complex
Dan River Combined Cycle
Primary Ash Basin, Secondary Ash Basin,
December 2016
Station
Intermediate Dike and Ash Stacks
Riverbend Steam Station
Ash Basis System, Ash Stack, and Cinder
December 2016
Pit and Other Identified Ash Storage Areas
L. V. Sutton Energy Complex
1971 Ash Basin, 1984 Ash Basin, and Lay
December 2016
of Land Area
*Plans submitted on September 11, 2015 and October 7, 2015 included Unit 5.
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

Per House Sections 3.(a) and 3.(b) of Bill 630 (Coal Ash Management Act), the Cape Fear Steam
Electric Plant, H. F. Lee Energy Complex, and W. H. Weatherspoon Power Plant surface
impoundments shall be closed no later than August 1, 2028, and fully excavated. The Buck
Combined Cycle Station has been identified by Duke Energy to be fully excavated and the coal
combustion residuals used for beneficial reuse. Therefore, prior to commencing excavation
activities at these facilities, DEQ requests submittal of an Excavation Plan and Excavation Soil
Sampling Plan. If excavation activities have already commenced at these (or any other) facilities,
submit these plans as soon as practical.
Excavation Plan and Excavation Soil Sampling Plans shall also be submitted to DEQ's Division
of Waste Management (DWM). If DEQ or DWM requires excavation of ash at any other facilities,
Duke Energy shall also submit these plans prior to commencement of excavation activities.
If you have any questions, please feel free to contact Steve Lanter (Central Office) at (919) 807-
6444.
Sincerely,
S. Jay immerman,P.G., Director
Division of Water Resources
cc: WQROS Regional Office Supervisors
WQROS Central File Copy