Compliance with CAMA Excavation and Closure_20191206

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Paul Draovitch
Senior Vice President
Environmental, Health & Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, North Carolina 28202
NORTH CAROLINA
Environmentetl Qunitty
December 6, 2019
Subject: Documentation of Compliance with the Coal Ash Management Act of 2014,
Session Law 2014-122, Section 3.(b), 3.(c)(1) and 3.(c)(2) Coal Ash Impoundment
Excavation and Closure, Riverbend Steam Station —Ash Basin 1 and Ash Basin 2
Dear Mr. Draovitch:
The North Carolina Department of Environmental Quality (DEQ) has reviewed submittals made
by Duke Energy concerning the coal ash impoundment excavation of Ash Basin 1 and Ash Basin
2 at the Riverbend Steam Station in Gaston County.
Per Section 3.(b) of the Coal Ash Management Act of 2014, Session Law 2014-122 (LAMA), the
Riverbend Steam Station was deemed high -priority and was required to close no later than August
1, 2019, and in conformance with Section 3.(c) of LAMA. Section 3.(c)(1) directs,
"Impoundments located in whole above the seasonal high groundwater table shall be dewatered.
Impoundments located in whole or in part beneath the seasonal high groundwater table shall be
dewatered to the maximum extent practicable." Section 3.(c)(2) states, in part, "All coal
combustion residuals shall be removed from the impoundments and transferred for (i) disposal in
a coal combustion residuals landfill, industrial landfill, or municipal solid waste landfill or (ii) use
in a structural fill or other beneficial use as allowed by law..."
Direction concerning information needed to demonstrate compliance with Part II Sections 3.(b)
and 3.(c) of CAMA closure requirements for the Riverbend facility and the other high -priority
sites was submitted by DEQ to Duke Energy in a letter dated January 22, 2019. The items listed
below were submitted by Duke Energy to DEQ to document compliance with the requirements of
referenced CAMA Sections:
• Riverbend Steam Station Coal Ash Excavation Plan 2018 Update. Submitted on December
11, 2018.
- North Carolina Department of Environmental Quality I Division of Water Resources
- e-o _ E Q 512 North Salisbury Street 1 1636 Mail Service Center I Raleigh, North Carolina 27699-1636
a*�a+r 919.707.9000

• Riverbend Steam Station, Gaston County, Notification of Completion of Part II, Section
3.(b)(2) of the Coal Ash Management Act of 2014 (Session Law 2014-122)(CAMA).
Submitted on March 21, 2019
• Coal Combustion Residuals (CCR) Visual Removal Verification Report Riverbend Steam
Station. Submitted on April 18, 2019.
• Response to DEQ Comments on CCR Visual Removal Verification Report Riverbend Steam
Station. Submitted on July 31, 2019.
• Email from John Toepfer to Eric Smith, Riverbend Confirmation ofLocations and Amounts
of Excavated CCR. Dated October 11, 2019.
Based on correspondence received by DEQ from Duke Energy, the dewatering and excavation of
both Ash Basin 1 and Ash Basin 2 were completed on March 16, 2019. Field verification of coal
ash removal met the objectives of sample collection and analysis consistent with the recommended
technical direction outlined in DEQ's CCR Surface Impoundment Closure Guidelines for
Protection of Groundwater. The final field excavation totals of the coal combustion residuals
transported from the facility for ultimate handling and the amounts, in tons, sent to each permitted
facility are documented as follows:
• Waste Management R&B Landfill, Homer, GA (15,762 tons)
• Duke Energy Marshall Steam Station, FGD and Industrial Landfills, (88,745 tons)
• Brickhaven Structural Fill, Chatham Co. NC (5,227,258 tons)
• Republic Services Charlotte Motor Speedway Landfill (19,543 tons, primarily asbestos
containing materials encountered during excavation)
• Duke Energy Cliffside (Rogers Energy Complex) Landfill, (3,143 tons)
Based on the documentation provided above, DEQ hereby concurs that Duke Energy has complied
with Sections 3(b) and 3(c) of CAMA with the exception of 3.(c)(3), which is still in progress.
Section 3(c)(3) states, "If restoration of groundwater quality is degraded as a result of the
impoundment, corrective action to restore groundwater quality shall be implemented by the
owner or operator as provided in G.S. 130A-309.20[9]."
Duke Energy is expected to comply with other closure requirements concerning groundwater
corrective action for the Riverbend Steam Station as required by CAMA and in conformance with
15A NCAC 02L Groundwater Rules, including development of Corrective Action Plans and
continued monitoring.
To address the pertinent closure requirements of CAMA (as amended in 2016) North Carolina
General Statute 130A-214(a)(4)(e) through (n), DEQ requests that Duke Energy provide a Closure
Report for the CCR impoundments (Ash Basin 1 and Ash Basin 2) by March 16, 2020. The
Closure Report shall include the following:
• A summary of closure activities to date and those planned in the context of project
milestones,

• As -built drawings and schematics along with the results of any engineering evaluations
and analyses for the closed impoundments,
• Final Plans for management of wastewater and storm water,
• A list of all State or Federal permits obtained or anticipated for impoundment closure,
• A description of the Post -Closure Monitoring and Care Plan,
• A proposed Final Monitoring Plan, and
• Updated cost estimates for closure and post -closure operations.
If you have any questions, please contact Steve Lanter (Central Office) at [phone].
Sincerely,
k6kBolich, L.G.
Chief, Ground Water Resources Section
Division of Water Resources
Sincerel
Edwardi�F. Mus ler III, P.E.
Chief, Solid Waste Section
Division of Waste Management
cc: MRO WQROS Regional Offices (electronic copy)
GWRS Central File Copy
Sheila Holman — DEQ (electronic copy)
George Eller — DEMLR (electronic copy)