Letter to DEQ April 2019 Response for Asheville, Roxboro and Belews Optimized IMP_20180425

DUKE
ENERGY
April 25, 2018
North Carolina Department of Environmental Quality
Division of Water Resources
Attn: Mr. Jon Risgaard
Chief - Animal Feeding Operations and Groundwater Section
1636 Mail Service Center
Raleigh, NC 27699-1636
410 S. Wilmington Street.
Raleigh, NC 27601
Mailing Address
Mail Code NC 15
Raleigh, NC 27601
919-546-7863
Subject: Department of Environmental Quality (DEQ) April 4, 2019 Letter — Optimized Interim
Monitoring Plans (IMP)
Dear Mr. Risgaard:
Duke Energy is in receipt of the above -referenced letter from the Department of Environmental Quality
(DEQ) regarding the Optimized Interim Monitoring Plans (IMP) for our 14 coal-fired facilities. The DEQ
letter is in response to the Duke Energy submittal dated March 20, 2019. The DEQ reviewed and approved
the Optimized IMPs for 11 of the 14 facilities but requested response to 3 facilities. Below we include the
DEQ text from the April 4, 2019 letter in italic font along with the Duke Energy response in normal font.
Asheville —Wells EXT-D and MW-8BR were moved from the quarterly sampling to water level only. Please
provide justification for this change.
Well MW-8BR was listed as 'water level only' on the IMP received from DEQ dated June 29, 2018 (Quarter
3) and Quarter 4 dated September 28, 2018. Well EXT-D was not listed on either Quarter 3 nor Quarter 4
IMP. Both of these locations are open bore holes that do not produce sufficient water to be a viable
groundwater monitoring well. Therefore, MW-8BR and EXT-D should remain 'water level only' as listed
on the Duke Energy submittal to DEQ dated March 20, 2019.
Belews Creek — Wells AB-1BRD, AB-2BR, AB-2BRD and AB-3BRD were removed from quarterly sampling.
Please provide justification for this change.
Roxboro — Wells ABMW-7BRLL, MW-01BRL, MW108BRL, MW-205BRL and MW-208BRL were removed
from quarterly sampling. Please provide justification for this change.
The response for Belews Creek and Roxboro is similar as the wells listed for these two facilities are still in
the installation phase. The wells were completely removed from the IMP update Duke Energy submitted
on March 20, 2019 so that there is no confusion in regards to wells that are sampled for analytical
data. Well development has been recently completed and initial sampling will occur in the near
future. Analytical data from initial sampling will be analyzed, in addition to well water production
capability, to determine if each well is viable and should be entered into the CAMA assessment
program. Upon completion of the new well evaluations, Duke Energy will submit a revised IMP to the
appropriate DEQ Regional Office, with supporting data for any well that is determined not viable for
groundwater analysis. As Duke Energy stated in the March 20, 2019 letter, if the well is viable it will be

April 25, 2019
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added to the CAMA assessment program to be sampled quarterly (at a minimum) for the full CAMA
parameter list.
Therefore, Duke Energy requests that DEQ finalize Tables 2.2 (Asheville), 2.3 (Belews Creek) and 2.12
(Roxboro) that were submitted as attachments to our March 20, 2019 letter. If you have any questions
or need any clarification regarding the information provided, feel free to contact me at
[e-mail] or at 919-546-7863 at your convenience.
Respectfully submitted,
10 oepfer,
L66d Engineer, Duke Energy EHS CCP
Waste & Groundwater Programs
cc (via email): Mr. Ted Campbell — DEQ Asheville Regional Office
Mr. Eric Rice - DEQ Raleigh Regional Office
Ms. Shuying Wang — DEQ Winston-Salem Regional Office
Mr. Eric Smith and Steve Lanter — DEQ Central Office
Mr. Ed Sullivan - Duke Energy
Ms. Bryson Sheetz Allison — Duke Energy
Ms. Kim Witt — Duke Energy
Ms. Melonie Martin — Duke Energy
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