WQ0000020 Aville Arpt Correspondence 1-'09 - 11-'14

John Elnitsky
Senior Vice President
DUKE _ Ash Basin Strategy
ENERGY, 550 South Tryon Street
DEC 22C
Charlotte,NC 28202'
Mailing Address;
P.O.Box 1321
Charlotte,NC 28201
0:704.382.4371
November 13, 2014 o�c$o7 �spr®tn
ry
John E. Skvarla, III
Secretary #OV 13
2O1
North Carolina Department of Environment& Natural Resources
Mailing: 1636 Mail Service Center 0eportrnent
217 W. Jones Street 4nNarurQi ,s�p�R7sg1
Raleigh, NC 27699-1636
Dear Secretary Skvarla:
As requested in the letter from the North Carolina Department of Environment and Natural Resources
(NC DENR)to Duke Energy dated August 13, 2014, Duke Energy is submitting the attached Coal Ash
Excavation Plans for Riverbend Steam Station, Dan River Steam Station, L.V. Sutton Electric Plant, and
Asheville Steam Electric Generating Plant.
In general,these Excavation Plans cover the first 12— 18 months (Phase 1) of ash basin excavation
activities, including site preparation, ash basin preparation,the initiation of basin dewatering, and ash
removal from the basins. These plans will normally be updated and submitted to NC DENR annually or
earlier as required by Subsequent Phase(s). These plans also represent the activities necessary to
satisfy the requirements outlined in Sections 3(b) and 3(c) Subparagraph 1&2 of the Coal Ash
Management Act of 2014.
Each Excavation Plan details what Duke Energy considers to be the necessary permits to begin work or
facilitate subsequent phases of work. Integral to the success of the Excavation Plans is the timely receipt
of permits, including industrial stormwater, National Pollutant Discharge Elimination System, landfill,
structural fill and mine reclamation permits where applicable.
The objective of these excavation efforts is to achieve ash basin closure in a reasonable, prudent, and
cost effective manner. The initial phases of these Excavation Plans will incorporate off-site transportation
and disposition options, which are generally more costly than the utilization of on-site, lined landfills. Initial
use of offsite solutions is necessary for the Company to meet the deadlines prescribed in the Coal Ash
Management Act of 2014 for High Priority sites.Timely receipt of landfill permits will enable the Company
to expeditiously transition from more costly off.-site storage locations at sites where these landfills are
practical.
We are prepared'to implement these Excavation Plans upon receipt of NC DENR written approval of
these plans and necessary permits.
cer
p
n Elnitsk
Senior Vice President
is
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1

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Compliance Inspection Report
Permit: WQ0000020 Effective: 02/17/06 Expiration: 02/28/15 Owner: Duke Energy Progress Inc
SOC: Effective: Expiration: Facility: Duke Energy Progress Ash Distribution Program
County: Unknown 410 S Wilmington St
Region: Central
Raleigh NC 27601
Contact Person: William J Thacker Title: Phone: [phone]
Directions to Facility:
From Interstate 26 East take the Long Shoals Rd.Exit. Turn left onto Long Shoals Rd.and go approximately 1 mile to facility
entrance on the right.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 09/30/2014 Entry Time: 01:30PM Exit Time: 02:30PM
Primary Inspector: Edward M Williams Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503 Exempt)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Sampling Storage Transport
(See attachment summary)
Page: 1

Permit: WQ0000020 Owner-Facility:Duke Energy Progress Inc
Inspection Date: 09/30/2014 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Ash from the facility is currently being transported to Asheville Airport to be used as fill. Records appear to be in good
order.
Page: 2

permit: WQ0000020 Owner-Facility:Duke Energy Progress Inc
Inspection Data: 09/30/2014 Inspection Type:Compliance Evaluation Reason for Visit: Routine
T(Le Yes No NA NE
Land Application ❑
Distribution and Marketing
Record Keeping Yes No NA NE
Is GW monitoring being conducted,if required? ❑ ❑ 0 ❑
Are GW samples from all MWs sampled for all required parameters? ❑ ❑ 0 ❑
Are there any GW quality violations? ❑ ❑ N ❑
Is GW-59A certification form completed for facility? ❑ ❑ N ❑
Is a copy of current permit on-site? 0 ❑ ❑ ❑
Are current metals and nutrient analysis available? 0 ❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters? N ❑ ❑ ❑
a. TCLP analysis? ❑ ❑ ❑
b. SSFA(Standard Soil Fertility Analysis)? ❑ ❑ 0 ❑
Are PAN balances being maintained? ❑ ❑ 0 ❑
Are PAN balances within permit limits? ❑ ❑ 0 ❑
Has land application equipment been calibrated? ❑ ❑ 0 ❑
Are there pH records for alkaline stabilization? ❑ ❑ 0 ❑
Are there pH records for the land application site? ❑ ❑ E ❑
Are nutdent/crop removal practices in place? ❑ ❑ 0 ❑
Do lab sheets support data reported on Residual Analysis Summary? 0 ❑ ❑ ❑
Are hauling records available? 0 ❑ ❑ ❑
Are hauling records maintained and up-to-date? E ❑ ❑ ❑
#Has permittee been free of public complaints in last 12 months? 0 ❑ ❑ ❑
Has application occurred during Seasonal Restriction window? ❑ ❑ 0 ❑
Comment:
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion ❑
Anaerobic Digestion ❑
Alkaline Pasteurization(Class A) ❑
Alkaline Stabilization(Class B) ❑
Compost ❑
Drying Beds ❑
Other ❑
Comment:
Page: 3

Permit: WQ0000020 Owner-Facility:Duke Energy Progress Inc
Inspection Date: 09/30/2014 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Sampling Yes No NA NE
Describe sampling:
Several samples are taken from the pile then composited in a plastic bag and sent out for analsys.
Is sampling adequate? ❑ ❑ ❑
Is sampling representative? 0 ❑ ❑ ❑
Comment:
Tr'ansDort Yes No NA NE
Is a copy of the permit in the transport vehicle? ❑ ❑ ❑
Is a copy of the spill control plan in the vehicle? ❑ ❑ M ❑
Is the spill control plan satisfactory? * ❑ ❑ ❑
Does transport vehicle appear to be maintained? ❑ ❑ M ❑
Comment:
Page: 4

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvaria, III
Governor Secretary
September 9, 2014
David D.Wilson
Geotrack Technologies Inc.
3620 Pelham Road, PMB #292
Greenville, SC 29615
RE: Monitoring Well Modification Response
Ash Distribution Permit WQ0000020
Asheville Airport CCB Structural Fill Project
Buncombe County, NC
Dear Mr.Wilson,
In your September 5, 2014 letter,you propose a.number of modifications to existing
monitoring"wells associated with_th"e Asheville Airport CCB structural fill. It is our
understanding that several existing groundwater wells associated with compliance
monitoring are impinging on the airport's runway realignment project. More specifically,the
final runway grade requires the abandonment of one-monitoring well,raising another
monitoring well by approximately 5 feet, and lowering two other monitoring wells by
approximately 2 - 5 feet.
It has been proposed that Area 4 monitoring well MW-1 be abandoned because of its
proximity to the runway realignment project and the fact that it is not a part of the compliance
monitoring well network. The Asheville Regional Office has no objections to abandoning this
well. Please adhere to well abandonment requirements outlined in 15A NCAC 02C .0113 and
submit the well abandonment form (GW-30) once the work has been completed. The well
abandonment form can be found at httl2:-I-112ortal.ncdenr.org/web/wq/aps/Ml2ro/rePorting-
forms.
It has,been proposed that Area 4 monitoring well MW-9 be raised by approximately 5 feet.
The 2-inch well casing will be protected by an inner 8-inch PVC casing and an outer precast
concrete pipe.When the runway project is at final grade both annular spaces will be grouted.
The annular space between the outer PVC pipe and the concrete pipe will be filled with
cementitious material such as high-slump concrete or flowable fill. The well modifications as
proposed are acceptable to the Asheville Regional Office with the exception that no fly ash,
other coal combustion byproducts, or other wastes may be used in any grout (15A NCAC 02C
.0107). Please adhere to the well construction rules outlined in 15A NCAC 02C .0108 and
resubmit a well construction form (GW-1) once the work has been completed. The well
construction form can be found at http://aortal.ncdenr.org/web/wq/aps/g_Lrpro/reportingm
forms.
Water Quality Regional Operations—Asheville Regional Office
2090 U.S.Highway 70,Swannanoa,North Carolina 28778
Phone:[phone] FAX:[phone]
Internet:http://portal.ncdenr.org/webtwq
An Equal Opportunity 1 Affirmative Action Employer

David D.Wilson
September 9,2014
Page 2 of 2
It has been proposed that Area 4 background monitoring well MW-1A and Area 3
monitoring well MW-1 be lowered by approximately 2 -5 feet. Initially,the protective casing
and concrete pad will be removed followed by the removal of soil, grout, and casing to the
desired elevation. Both wells will be converted to a flush-mounted protective casing. The well
modifications as proposed are acceptable to the Asheville Regional Office. Please adhere to the
well construction rules outlined in 15A NCAC 02C .0108 and resubmit a well construction
form (GW-1) once the work has been completed.The well construction form can be found at
http://portal.ncdenr.org./web/wq./aps/gwpro/reporting-forms.
Regional inspectors may elect to be present during the well modifications. Please notify the
Asheville Regional Office at least forty-eight (48) hours in advance of the site work.You can
contact me at [phone] or [e-mail].
Sincerely,
Brett verty OU
Asheville al Office
John Toepfer-Duke Energy Progress
Norman Divers-Charah Inc.
Michael Reisman-Asheville Regional Airport

EOT]L ACK
Technologies, Inc..
3620 Pelham Road, P 13#292 PhOlIC: 864-329-0013
Greenville,SC 29615-3044 FAX: [phone]
September 5, 2014 -
Mr. Brett Laverty �srR OfWater� ,.
NC Department of Environment and Natural Resources
2070 US 70 Hwy.
Swannanoa,NC 28778-8211 SEP - 5 2014
Re; Revised Monitoring Well Modification Request water Quality Regional Operations
Asheville Regional Airport, Area 3 and Area 4 Asheville Rae Tonal Office
Buncombe County,NC
GeoTrack Project No. 10-2626E-N
3
Ladies and Gentlemen:
E
4
Thank you for meeting with the Asheville Airport construction team on Wednesday. As a result
of those conversations, and additional information obtained concerning the proposed
construction,we hereby submit a revised request for monitoring well modification.
Area 4, Well MW-7: As a result of recent observations of the construction in progress near
MW-7, we have concluded that relocating the well is not necessary. We will install additional
cautionary barriers, such as additional bollards and/or caution flagging, to alert the contractors of
the well. No physical changes to the actual well structure are currently anticipated, and it can
remain a part of the compliance sampling program.
Area 4, Well MW-I,: It was mutually decided that this well should be abandoned due to its
proximity to the new construction and the fact that the well is not currently used. The well will
be abandoned by removing surface hardware and grouting the casing using tremie methods, in
accordance with NCDENR requirements.
Area 4, Well MW-9: The proposed grades in this vicinity will be raised approximately 5 feet.
We request permission to raise the well in height as described in our previous submittal and as
described below. The concept of the modification will be as previously described; minor
changes to the proposed process have been included to enhance the stability of the outer,
manhole structure.
f
The existing protective casing and concrete pad will be carefully removed, and excavation will
be performed to expose the cement/bentonite grout column to a depth at least one foot below the
top of the undamaged, intact column. A Schedule 40 PVC casing at least 8 inches in diameter
will be placed over the well pipe to below the top of the intact grout column. The concrete pad
will extend at least two feet outside the outer PVC casing to ensure continuity of the grout,
i
3

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Monitoring Well Modification Request,Asheville Airport Area 3 and Area 4 GeoTrack Project No. 10-2626E-N
provide lateral stability of the assembly, and anchor a protective manhole structure discussed
below.
Precast concrete pipe (i.e. a manhole structure) will initially be placed around the above well
assembly. The purpose of the manhole will be to protect the exposed well piping from
inadvertent equipment impacts during fill placement, to achieve relatively vertical well assembly,
and to provide a form against which the fill can be placed and compacted. The manhole will be a
m,`of"T inches it diameter and it will be progressively constructed, as described above,
rin�,4z_6 35'66f'secrions, a ead of the fill surface.
Tfhe,,;top two, of th grout column, the base of the larger PVC casing, and the manhole
structure will be completely surrounded with concrete, inside and out, in a manner that anchors
the bases of allipin a d allows access to eventually place continuous grout from the intact
69lia i Ih6' side of the outer PVC casing to near final grade.
New, 2-inch PVC well pipe will initially be connected to the top of the well using a slip
connector and stainless steel screws (a threaded joint is not expected to be present). At
subsequent (higher)joints, if needed, both the inner, 2-inch casing and the outer PVC casing,will
be incrementally extended in sections, ahead of the fill surface,using factory-threaded sections.
When the well/manhole assembly and surrounding new fill is at final grade, the annular space
\ between the 2-inch well and the outer PVC casing will be grouted using tremie methods as
required for conventional well installation. The annular space between the outer PVC casing and
the manhole will be filled with similar cementitious material such as high-slump concrete or
flowable fill. The manhole fill will extend to the final ground surface elevation, and an above-
ground g P g ;
N
round locking protective casing will be anchored into the concrete inside of the manhole.
The proposed modifications are shown pictorially in Schematic B (revised). Since the outer
grade will be raised only about 5 feet, only one or two manhole casings are expected to be
needed, depending on the amount of excavation required to expose the grout column, and precise
final grades. I
Area 3, Well MW-l: This well is located in an area that must be lowered (excavated)
approximately 5 feet to the proposed final grade. We request permission to lower the well and '
reconstruct the protective assembly to accommodate the excavation.
To lower the well, the protective casing and concrete pad will be removed. Then the surrounding
soil will be excavated to at least two feet below final grade, and the soil column will be carefully
hand-excavated to expose the intact grout column. The grout and well pipe will be removed to
the desired elevations, and a new protective casing will be secured to the well using concrete, as
shown in Schematic C. We understand that a flush-mounted protective casing will be required at
that location.
i
r
Page 2

Monitoring Well Modification Request,Asheville Airport Area 3 and Area 4 GeoTrack Project No. 10-2626E N
Area 4, Well MW-IA: Recently provided information indicates this well will need to be
lowered on the order of 2 to 5 feet (to be established by the contractor's surveyor). We request
permission to modify the well, when needed, as described above for MW-1 (Area 3) and
Schematic C.
All of the proposed modifications will be performed under supervision of a certified well driller.
Well records will be prepared and signed to document the modifications.
We again request approval at your earliest convenience. Please call if you need any additional
information or have questions about this submittal.
Respectfully submitted,
GeoTrack Technologies, Inc.
David D. Wilson,P.E. j
Senior Engineer
CC Charah,Inc.
9
Attachments
i
Page 3
I
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LOCKING PROTECTIVE CASING
AP" ANHOLE SECTIONS (TYP.)
PROPOSED
GROUND SURF.
p= NEW 2"WELL CASING
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DIMENSIONS APPROXIMATE 3620 PELHAM RD,PMB0292 ASHEVILLE AIRPORT,AREA 4 GREENVILLE,SC 29615-5044 ASHEVILLE,NC B
864-329-0013 GEOTRACK PROJ.NO.10.2626A-N

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GREENVILLE,SC 29615-5044 ASHEVILLE AIRPORT,ASHEVILLE,NC
864-329-0013 GEOTRACK PROJ:NO.10-2626A-N

I L
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory, John E. Skvarla, III
Governor Secretary
June 16, 2014
John R. Toepfer
Duke Energy Progress, Inc.
410 S.Wilmington Street/NC14
Raleigh, NC 27601
RE: Response to comments from Duke Energy Progress dated February 18, 2014
concerning the Asheville Airport engineered fill project-Area 3 development
Dear Mr. Toepfer,
The Asheville Regional Office of the Division of Water Resources (DWR) acknowledges
receiving a response to our review comments dated October 23, 2013.Additional comments
and questions are given in the bulleted items below:
m In your letter,you state that all future water quality data pertaining to leachate or CCB
contact water within the open cells will be submitted beginning with the April 2014
groundwater monitoring results. Please submit all past and future water quality data
pertaining to the contact water within CCB structural fill areas 3 and 4.
0 In your letter,you state that it is well documented in the scientific literature that
chloride can be responsible for a false positive result for thallium. Based on
conversations with our own DWR laboratory, chloride levels must be significantly
elevated before any polyatomic interference can take place. Do you have additional
evidence that suggests chloride concentrations as low as 3 mg/l may be a source of
analytical interference with regards to thallium? Please submit any pertinent scientific
literature that supports your position.
m According to 15A NCAC 02T.1204 (d)(2),new and expanding [CCB] structural fill sites
must describe and explain site specific engineering or institutional controls proposed
to prevent adverse impacts to public health and the environment.The composite liner
system for CCB areas 3 and 4 is designed to significantly restrict infiltrating
precipitation and limit the release of CCB leachate. The composite liner system,while
restrictive, cannot be considered entirely impervious. Therefore,limited solute
transport modeling was conducted by GTI to demonstrate the performance of the
composite liner system and its ability to protect groundwater quality at nearby
regulatory and water supply receptors.
The ARO previously provided comments regarding Geotrack Technologies Inc. (GTI)
groundwater modeling results where the 90% concentrations for several analytes
Water Quality Regional Operations—Asheville Regional Office
2090 U.S.Highway 70,Swannanoa,North Carolina 28778
Phone:[phone] FAX:[phone]
Internet:http://portal.ncdenr.org/webtwq
An Equal Opportunity 1 Affirmative Action Employer

Duke Energy Progress-Asheville
June 16,2014
Page 2 of 3
were higher at the compliance boundary than the review boundary for three different
modeled geometries. The ARO requested a more detailed description of the IWEM
model's "prediction error" or alternatively, further analysis that includes a greater
number of Monte Carlo realizations. GTI responded by performing additional ground
water modeling (January 30, 2014) to reflect conditions more specific to the area.The
modeled geometry included receptors at the review boundary (62 feet), compliance
boundary (165 feet), and an offsite water supply well (240 feet). Please note that the
distance given for the modeled review boundary is not midway between the waste and
compliance boundaries as defined by 15A NCAC 02L.0108.
The conceptual model of groundwater flow in the Blue Ridge and Piedmont regions of
North Carolina is essentially a two-part system consisting of regolith or weathered
rock and the underlying fractured bedrock. In many locations,the regolith includes a
.transition zone above the fractured bedrock consisting of coarse fragments of partially
weathered bedrock.According to technical documents,the IWEM model is designed for
relatively simple groundwater flow systems in which flow is dominated by a regional
gradient.The model may not be appropriate for sites associated with fractured
bedrock, heterogeneous aquifers, non-uniform thickness of water bearing zones, or
sites with significant seasonal variations in water table elevation. Please provide a
detailed discussion as to why the IWEM model is appropriate for this location.
In the "no liner" scenario, GTI does not adequately address potential problems with the
model's performance. In one instance,there is a slight increase in modeled
concentrations for arsenic and barium from the compliance boundary to the water
supply receptor. GTI responds by saying the no liner scenario is unrealistic for this site
and that predicted arsenic and.barium concentrations follow a more logical reduction
in the other two liner scenarios. The suggestion of ignoring one set of modeling results
for another is not a viable answer.Another observation is an almost complete lack of
attenuation for any constituent in the "no liner" scenario. It is our understanding that
the greatest influx of CCB leachate to the unsaturated/saturated zone modules occurs
in the "no liner" scenario. It seems unrealistic that little to no depletion of the leachate
constituents occur as a result of dispersion, diffusion, or sorption processes.
In the "clay liner" scenario,the modeled concentration for chromium increases from
the review to the compliance boundary. Similarly,the modeled concentrations for
boron, iron, and sulfate increase from the review to the compliance boundary in the
"composite liner" scenario. In both scenarios, GTI ignores problematic trends based
solely on the fact that the predicted concentrations are below analytical detection.
After it has been demonstrated that the model is producing consistently reliable
results, it is suggested that sensitivity analyses be conducted to determine which
variables are the most critical to the modeled solute transport.
An attempt was made by GTI to address performance issues with the IWEM model.
They suggest that default infiltration rates combined with the relatively low subsurface
hydraulic conductivities result in theoretical ground water mounding.According to

Duke Energy Progress-Asheville
June 16,2014
Page 3 of 3
their interpretation,this mounding dilutes modeled concentrations near the CCB fill
and less so as the mounding dissipates with distance.According to technical
documents,the unsaturated zone (1-D) and saturated zone (3-D) modules are separate
domains computationally linked through continuity of flow and constituent
concentration across the water table directly underneath the waste management unit
(WMU). Groundwater mounding due to high infiltration rates may occur in the
unsaturated zone module and is represented by increased head values at the top of the
aquifer. The actual saturated zone module is based on the assumption of a constant
saturated thickness and the only direct effect of ground-water mounding is to increase
simulated ground-water velocities. In other words,the module does not simulate the
actual physical increase in the thickness of the saturated zone.
GTI concludes by saying, "while the results indicate [for the composite liner scenario]
small increases in concentrations of certain compounds with distance from the fill, all
of the computed concentrations can be considered essentially zero" and "thus,we
conclude that the modeling demonstrates that the proposed liner system is protective
of the environment."According to technical documents,the mass of constituents
leached from the WMU is directly proportional to the infiltration rate of the various
liner scenarios. There is no discussion as to the fate of leachate mass once it enters the
unsaturated/saturated zone modules.
Modeling is an important component of the project given the close proximity of
receptors to the CCB waste boundary. To this end,the Division would like to see a more
robust conceptual model,a model.that is producing consistently reliable results, and a
sensitivity analysis of key variable affecting the predictive results.Along with this,the
Division would like to see a description of the model limitations and any associated
implications regarding its use for the Asheville Airport CCB structural fill project.
Please feel free to contact me if you have any questions regarding our review comments. I can
be reached at [phone] or [e-mail].
Sincerely
J
f,
Br t Lav
Water Quality Regional Operations Section
Asheville Regional Office
Jon Risgaard-DWR Raleigh

r DI 11/E - Duke Energy Progress,'Inc.
V 1� .
.... .. .
- -
Wilmington- : ee
. . . Raleigh,N 2 7601:ENERGY,:: - -
PROGRESS:.:
. .. RECEIVED
Division of Water Resources:
February 18,2014: - - --
.... . ::.: FEB 2'0.: 2014
North:Carolina:Department'of Environment
and.Natural Resources,,Division of Water Resources
Water Cluality RegionalOperations
Aquifer Protection*Section—Asheville.Regional Office Asheville Re ional.Offl e
2090 US Highway 70 ::. " "
Swanna.n:oa;NC 28778
Attention: Brett:Laverty
.... .
-- .RE:. .. Response.to Comments—D E N R Letter dated October:23,-:2013.:
Asheville Engineered Fill-Project—Area 3 Development .
Dear Mr.:Laverty:
We'are.writing in-response.to.comments:ma'de on.the subject project by the Aquifer Protection Section:
For ease in review, below we have referenced the.letter and comment.madejollowed by.our response
for-your'reviiew and consideration. :, : .
Letter:dated.October 23,2013: :: .
1.: CCP leachate n'Area1V and possibly.AreaIll is/will be pumped and hauled by.1/LS-of-South Carolina
to:their industrial waste.watertreatment plant:located in Mauldin,SC. DWR is requesting.a letter"
rom.VLS o.South Carolinas p eci rcall a reein to accept the CCP.leachate and veri icatron:that the
f .... .. . f .... .P. f Y 9 .9 P ... f Y
are authorized to operate an industrial wastewater treatment facility. Please.provide a total volume
- ... - .
of:CCPleachate that has.been-pumped and hauled-to date:'
Response: Attached is the information-requested on VLS of-South:Carolina to operate an industrial: '
wastewater treatment facility and.letter to accept.CCP.leachate from.the Asheville Airport CCP.filIs., The
quantity of leachate pumped and hauled since inception-through December.17,2013 from-Area.IV is
42.82 million gallons.. Since-December.13,2013,Area 1V began discharge into the MSD sewer system::
The-' uantity of leachate discharged from then.through January.2014 was approximately 3.48 million. : : ::.:
. .
gallons`(0.58.MG phase I/IA 8i 2.90 MG phase II):-The'semi-annual groundwater analytical results.
submittal will:include leachate discharged to the:MDSsince January 2014:
2: - The Metropolitan Sewerage District(MSD)of Buncombe County recently issued an industrial. . =
discharge permit to allow.the CCP leachate to be-discharged to their public sewer system from both
Area IV and Area—ill: Please rovide a letter ram MSQs eci icall a reein :to accept the CCP =
P f P f Y 9 9
-:: leachate ad a copy of the industrial.discharge authorization.:.: .
Response:-Attached.is-the letter authorization from t e MSD.

Laverty Letter
February 18,2014
3. In order for DWR to monitor the condition of the ash post-placement,please provide all existing and
future records pertaining to leachate water quality assessment, discharge and disposal for all CCP fill
areas. Please identify whether the leachate is discharged to MSD(i.e.flow volume)or any pump and
haul contractor. This data can be submitted to DWR on the same schedule as the submittal of
groundwater analytical results.
Response: The above data includes the volume of leachate generated to date along with where it was
discharged (either MSD or VLS of South Carolina). The future data will be submitted along with the
semi-annual groundwater analytical results. The next sampling event is scheduled for April 2014 for all
three structural fills.
4. DWR had previously requested further explanation of the groundwater modeling results,specifically
those instances where the calculated 90%concentrations for several analytes is higher at the
compliance boundary as compared to the review boundary. The explanation provided in Duke's
September 16,2013 response fails to satisfactorily explain these calculatioins and therefore, a more
detailed response or expanded calculation is warranted. While DWR agrees that overall, the design
of the ash containment structure appears protective,it is difficult to ensure compliance with permit
condition 1.5. if the constituent concentrations as modeled indicate an increasing trend away from
the waste boundary. This is especially relevant in Area Ill where active water supply wells are
located within 300 feet of the structural fill. The DWR is requesting a more detailed description of
the model's 'prediction error'or alternatively,further analysis that includes a greater number of
realizations as your response comment suggests.
Response: Please see the attached information from Geotrack Technologies, Inc.dated January 30,
2014 responding to DENR's questions on modeling for Area III.
5. During the hydrologic investigation for Area Ill, thallium was detected in monitoring well MW6 at a
concentration above the standards found in NCAC 2L.0200. Duke's September 16th response
indicates that Pace Analytical Services, Inc. (was Prism Laboratory)suggests that chloride can
interfere with thallium analysis thus implying that the interferences can result in a false positive
result. However, other onsite monitoring wells had higher chloride concentrations without
detections of thallium. Please provide additional documentation and explanation, if available,
regarding all thallium detections.
Response: Duke Energy laboratory personnel reviewed the data package from Prism Laboratory for the
thallium result at well MW6. After a thorough review of the data package for MW6,the report does not
give Duke Energy laboratory personnel any indication that the thallium result for well MW6 was a false
positive. All of the quality control data looks to be within normal parameters-the calibration looks
acceptable but the response is low, however this may be typical of that particular lab's ICP thallium
response. The matrix spikes and blanks look acceptable and there are no signs of carryover. Chloride
was also present in this well at a concentration of 3 mg/I. It is well documented in the scientific
literature that chloride can cause false positive results for thallium. It is therefore not unreasonable to
2

` Laverty Letter
February 18,2014
think the thallium result for MW-6 could potentially be biased high. It should also be pointed out that
the thallium analysis for MW6 was completed by EPA Method 6010C,which is an ICP-AES
method. Several articles present in the scientific literature indicate a potential high bias for thallium
analysis completed by this method. The more appropriate methodology for thallium analysis would be
EPA Method 6020,which is ICP coupled with a mass spectrometer(ICP-MS).
6. Our previous letter highlighted the need for an operations and maintenance plan for the CCP
structural fills as required by 15A NCAC 02T.1208. Your comments largely addressed the
institutional controls being put in place during the design and construction phases. What is lacking is
a concise understanding of the long-term maintenance needs at all of the structural fill sites. Please
provide a detailed O&M plan that outlines the post-construction care of the Asheville Airport
structural fill project(all areas). The plan should address the following topics:
1. Party responsible for long-term maintenance,
2. Inspection frequency and reporting for all CCP fill areas is to include, but not be limited to:
visual inspection of all slopes underlain by CCPs, monitoring well structural integrity,
drainage pathways, and cover crop. Report and repair any signs of erosion and breaches in
fill and liner, keep slopes clear of woody debris, maintain drainage features, and maintain
cover crop. Report any day-lighting of CCPs. Report any planned construction activities that
will occur atop areas filled with CCPs prior to those activities.
3. Protection of liners during the runway expansion project;and,
4. A quality assurance plan for groundwater monitoring.
We include the citation from the 2T regulations and our response after.
15A NCAC 02T.1208 OPERATION AND MAINTENANCE PLAN
An Operation and Maintenance Plan shall be maintained for all CCP management programs. The plan
shall:
(1)describe the operation of the program and any associated wastewater treatment systems and
equipment in sufficient detail to show what operations are necessary for the program to function and
by whom the functions are to be conducted;
The ash ponds(wastewater treatment units)at the Asheville Plant operate under an existing NPDES
permit. This permit describes the operation of the ash ponds and these ash ponds are maintained in
operating order by Asheville Plant personnel. To facilitate removal of ash from the ash ponds for
transport to the Airport,ash is removed from the active potion of the ash ponds and stacked in upland
areas of the ash ponds. The stacking allows excess water to drain from the ash. After a period of time
to dewater, ash is placed into dump trucks which are then covered for the trip to the Airport. Prior to
leaving the Plant,the trucks travel through a wheel wash system.
Area I,Area IV and just under construction Area III CCP fills at the Asheville Airport operate under an
Erosion &Sediment Control (E&SC) permit held by the Asheville Airport. The E&SC permit is in
3

Laverty Letter
February 18,2014
operation until there is sufficient vegetative cover over the constructed areas. While the E&SC permit is
in operation,there are required inspections of the construction areas, including after sized rain events.
Once the E&SC permit expires, the Asheville Airport will complete quarterly walkdowns of the three
structural fill areas. The walkdowns will look for signs of erosion and repairs will be completed by the
Airport as necessary. The Airport, as the land owner, is required per 15A NCAC 04B .0113 to install
and/or maintain all necessary permanent erosion and sediment control measures.
These quarterly walkdowns will observe the various groundwater monitoring wells for structural
integrity,drainage pathways and erosion gullies. The areas will be periodically mowed to prevent
intrusion from woody vegetation. The Airport will keep records of these quarterly inspections. If these
inspections observe any exposed liners or ash, Duke Energy Progress will be notified prior to completion
of repairs by the Airport.
Area I structural fill is proposed to be developed with future hangars and pavement while Area IV and
Area III structural fills are proposed to be developed by a future taxiway. The Airport will notify Duke
Energy Progress prior to beginning any construction in areas underlain by CCPs. The Airport will also
notify Duke Energy Progress if any liner or CCPs are encountered during construction in areas underlain
by CCPs. The top of CCPs have been delineated by as-built surveys and will be provided by the Airport to
construction contractors to prevent excavation into the CCPs during construction activities.
(2) describe anticipated maintenance of wastewater treatment systems and equipment that are
associated with the program;
The ash ponds (wastewater treatment units)at the Asheville Plant are maintained by Asheville Plant
personnel to operate within the NPDES permit limits. There are no wastewater treatment systems at
the Asheville Airport associated with the three structural fill areas. As stated above,the Asheville
Airport holds the E&SC permits while construction is underway and required by regulation to maintain
the construction areas once the E&SC permits have been closed.
(3) include provisions for safety measures including restriction of access to the site and equipment, as
appropriate;
The Asheville Plant ash ponds are fenced to prevent unauthorized access. The Asheville Airport property
is also fenced to prevent unauthorized access.
(4)include spill control provisions including:
(a)response to spills including control, containment, and remediation and
(b)contact information for program personnel,emergency responders, and regulatory agencies;and
If there is a transportation spillage of CCPs between the Plant and the Airport, Duke Energy Progress will
be immediately notified. Either the hauler or Duke Energy Progress will make any required notifications
to regulatory agencies. The spilled ash will be excavated and the impacted area returned to pre-spillage
conditions by the hauler.
4

Laverty Letter
February 18,2014
The proper operation of the ash ponds(wastewater treatment units) prevent the spillage of ash at the
Plant while E&SC permits at the Airport prevent the spillage of ash off the Airport site.
(5)describe the sampling and analysis protocol used to ensure that the program complies with this
Section and any issued permits.
Duke Energy Progress completes all required sampling and analysis stated in permit WQ0000020 and/or
required by DENR. At the Asheville Plant, a monthly representative ash sample is obtained from the
current stockpile being worked and is analyzed for the parameter list contained in permit WQ0000020.
One of these samples is also analyzed for the TCLP 8 RCRA metals per permit WQ0000020.
Separate from permit WQ0000020, DENR has required groundwater monitoring around all three
structural fills at the Asheville Airport. Duke Energy Progress will sample the groundwater monitoring
wells two times per year(April & November)for the parameter list specified in the DENR letter dated
November 14, 2013 (see attachement). The results will be submitted to DENR and include leachate
disposal figures and all water quality data collected as part of the IVISD discharge agreement. Duke
Energy Progress utilizes the low flow sampling methodology and groundwater sampled will be
submitted to a North Carolina certified laboratory for analysis.
The DENR letter dated November 14, 2013 includes the correct groundwater monitoring well identifiers
for Area I and Area IV structural fills. However,the well identifiers for Area III structural fill are not
correct. The well identifiers for Area III are review boundary wells MW-1, MW-2, MW-3, MW-4, MW-5,
MW-6 and MW-7 along with background well MW-1A. This background well is the present background
well for Area IV and will also be utilized as the background well for Area III.
Access to the groundwater monitoring wells will be maintained by the Asheville Airport.
7. According to 15A NCAC 02T.1204, you are responsible for providing a site plan that includes the
location of all wells(including usage and construction details if available),streams(ephemeral,
intermittent, and perennial),springs, lakes,ponds, and other surface drainage features within 500 ft.
of the CCPs use boundary.
Response: Please see attached sheet 3-E1 which has been updated to include the information required
within 500 feet of the CCP boundary for Area III.
8. DWR requested the relocation of monitoring wells MW3, MW4, and MW6. The new locations for
MW3 and MW6 are acceptable. The addition and location of MW7 is also acceptable. It is
understood that site conditions prevented the movement of MW4. The current location of MW4 is
acceptable.
Response: noted. The wells have been installed and pre-CCP placement Area III groundwater
monitoring results will be shared with DENR once the results have been received. Groundwater
5

Laverty Letter
February 18,2014
monitoring at Area III will then proceed to semi-annually at the same frequency as that for Area I and
Area IV(April& November).
We trust the above response to comments provide the DWR with the information requested. If you
require any additional information or have any further questions, please do not hesitate to contact us.
SincerelyeToe*pferPE
Jo
Lead Environmental Specialist
Attachments: VLS of South Carolina permits and acceptance letter
MSD permit and acceptance letter
Plan sheet 3-E1
Risgaard Letter dated November 14, 2013
Geotrack Technologies, Inc. response dated January 30, 2014
cc: Tim Smart, PE—Duke Energy
Laurie Moorhead—Duke Energy
Norman Divers—Charah, Inc.
Michael Reisman—Asheville Airport
Asheville Regional Airport
61 Terminal Drive,Suite 1
Fletcher, NC 28732
6

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Well No. Northing lEasting Top/Casing Top/Caslng Ground Elev, Well No. Northing Easting Ground Elev-
'� 1 636,990.92 943,37L66 2129.13 2126.1 1 634,03&33 943,84631 :2166.8
2 636,416.87 943,223.12 2126.18 2123.7 2 634850.87 943,516.93 -2146.2
3 635,955.70 943,213.95 2129.95 2327.3 3 635,543.10 943,340.49 .213&0
4 635,019.27 943,502.92 '2147.77 2145.1 4. 63B4O12.91 943;103.76 .2114.0
5 635,36L55 943,656.98 2143.34 21410 5 :636,552.27 943,232.40 2=2
W 6 635,030.54 944,077.34 2135.41 2133.0 6 636,754.26 943,253.15 2127.7
7 634,162.3fi 944,08171 2146.38 2143.9 7 637.021:22 943,196.71 212GO
8 633,504.46 144,271,51 2149.53 2146.8 REVIEW BOUNDARY WELLS CMW'0 HAVE BEEN APPROVED
9 634,043.51 944,298.29 214L74 2139.1 BY DE14R FOR CONSTRUCTION AND SITE MONITORING.
10 636,347.14 943,458.95 2133.94 2130.9
'NOTES:
BACKGROUND WATER QUALITY FOR AREA 3 SHALL BE DETERMINED
USING SAMPLING DATA FROM EXISTING UPGRADIENT WELLS FROM
AREA 4 OR AREA 1 AS DETERMINED BY PEG
o EXISTING WELL LOCATIONS SHOWN WERE USED FOR SITE ASSESSMENT
AND HAVE BEEN ABANDONED AS REQUIRED FOR CONSTRUCTION.
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1. SURVEY DATA PROVIDED BY NOVA DIGITAL SYSTEMS, INC.
DATED DECEMBER 11, 2009. SUPPLEMENTAL SURVEYING
PROVIDED BY WNC ENGINEERS & SURVEYORS, PLLC.
2. ALL STREAM IMPACTS AND WETLANDS IDENTIFIED IN THE
ENVIRONMENTAL ASSESSMENT PHASE OF THE PROJECT
WILL BE MITIGATED IN ACCORDANCE WITH THE APPROVED
MITIGATION PLAN WITH THE US ARMY COE AND
.7 1 J NCDENR-DWQ PRIOR TO ANY WORK. REFERENCE
APPROVED MITIGATION PLAN WITH THE NC-EEP DATED
12/20/2012.
PLAN LEGEND Z a
3. RESEARCH OF WELL RECORDS INDICATE THAT THERE ARE (3 a
NO PUBLIC OR PRIVATE WATER SUPPLY WELLS WITHIN Z
GROUNDWATER CONTOURS 100' OF THE PROPOSED CCB WASTE BOUNDARY. U)
(SEASONAL HIGH) La
4. THIS PLAN INDICATES THE CCB LIMITS PROPOSED AS 0
(*Gw AREA 3 OF THE ENGINEERED FILL SCHEDULED FOR THIS go
SITE ASSESSMENT GW MONITORING SITE AND THE COMPLIANCE AND REVIEW BOUNDARIES
WELL LOCATIONS GIN MONITORING(ABANDONED) SHON ARE SPECIFIC TO AREA 3 ONLY.
mw PROPOSED 5. GROUWNDWATER QUALITY MONITORING SHALL BE L6 U)
WELL LOCATIONS PERFORMED IN ACCORDANCE WITH PERMIT NO.
W00000020 GRANTING PERMISSION FOR THE REUSE OF BEFORE YOU DIG
COAL COMBUSTION BYPRODUCTS AS ENGINEERED FILL
LIMITS OF CCB PLACEMENT MATERIAL. STOP au 3=
(ANCHOR TRENCH LIMITS) CALL 800 632-4949
w__
N NE—CALL CENTER
6. ALL MONITORING WELLS SHALL 13E EXTENDED TO AUGER -CIT'OS THE LAW
lew EX PRIVATE WATER SUPPLY REFUSAL AS DETERMINED BY THE GEOTECHNICAL 0 1-
WELL LOCATIONS ENGINEER IN A MANNER SUFFICIENT TO SAMPLE 0 ow
GROUNDWATER FROM THE "TRANSITION" ZONE. EACH L6 U)
WELL WILL BE DEVELOPED TO PROVIDE AN ADEQUATE
COLUMN OF WATER NECESSARY FOR SAMPLING C5 1U6
PURPOSES.
ISO 0 75 ISO 300 600 14 ul NC)
SCALE: 1"—150'
F N M ISSUE DATE: JANUARY 24, 2013
'-s T REVISIONS
NO' DATE DESCRIPTION
1. 27R17-2013 _.V_��d pe,wmments ft=M,IhA
PI...A roved and ...d for ConstrucU..
3. 1 5/13/2013 1 Revised per comments fromARAA..
4. SZ,30 2013 1 Ro,lse/7011 AMM

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North Carolina Department of Environment and Natural Resources
Division of Water Resources
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
November 14,2013
Mr.David Mitchell—Director Environmental-Air&Waste/CCR
Duke Energy Progress,Inc.
526 South Church Street
Mail Code EC13K
Charlotte,NC 28202
Subject: Permit No.WQ0000020
Duke Energy Progress,Inc.
Distribution of Ash Residuals
Statewide
Dear Mr.Everett:
The Division of Water Resources(Division)has updated its database to reflect the company name
change request from Carolina Power & Light Company, d/b/a Progress Energy Carolinas, Inc. (Progress
Energy)to Duke Energy Progress,Inc.received May 6, 2013.
Based on discussion from a September 30, 2013 meeting with Duke Energy Progress, Inc.
representatives, additional information related to the structural fill projects and groundwater monitoring
requirements is included with this letter. The Division believes that the current permit contains language
that is inconsistent with current North Carolina Administrative Code, and further clarification is needed to
ensure that Duke Energy Progress is aware of the expectations of their distribution program.
The concerns and expectation expressed in our letter to Duke Energy Corporation dated April 21,
2010 (attached), can be expanded to include permit WQ0000020 as well. It is the Division's intent to
include with the next issued permit an accounting of the structural fill sites and incorporation of the
requirements of 15A NCAC 02T .1204. The attached table provides a listing of the three permitted
structural fill projects Duke Energy Progress has reported to the Division to-date, their CCP sources for
each site, the estimated size, groundwater monitoring well names, project status, and other locational
information. A second table includes the monitoring requirements established by the Ashville Regional
Office pursuant to Section III. 1. of the subject permit.
To ensure that proper operation and maintenance practices are occurring at the structural fill sites,
please update your operation and maintenance plan as need to include at a minimum visual inspection of
all slopes underlain by ash fill, monitoring well structural integrity, drainage pathways, and cover crop. It
is expected that Duke Energy Progress will report and repair any signs of erosion and breaches in fill and
liner, report any day-lighting of CCPs, keep slopes clear of woody debris, maintain drainage features,
maintain cover crop, etc.
RECEIVE®
WATER PERMITTING SECTION y a�013
1636 Mail Service Center,Raleigh,North Carolina 27699-1636 1 L
Location:512 N.Salisbury St.,Raleigh,North Carolina 27604
Phone:[phone] FAX:[phone] Asheville Regional Office
Internet:http://Portal ncdenromlweb/wo/aps
P► uifer Protection
An Equal Opportunity 1 Affirmative Action Employer

If you need any ado nal information concerning this matter, ise contact me or Cho4ttic..:
McDaniel by telephone at(919) 807-6337 or via e-mail at [e-mail].
Sincerely,
Jon 'sgaard,
Non-Discharge Permitting Unit
cc: John R. Toepfer,P.E.—Duke Energy Progress,Inc. (410 S.Wilmington Street/PEB14,Raleigh,NC 27601)
Iy,andon=Davidson Ahsheville,Regional-Office;=WaterLLQuahtty Regional:Operation Section
Permit File WQ0000020

Approved Structural Fill Sites—Duke.Progress Energy _ Permit Number: WQ000
Estimated Site Location
Source-Generating Distribution Groundwater Project Status*
Site Facility Structural Fill Project County Amount Recipient of the ash Monitoring Wells
(tons)*
Latitude Longitude
Area 1 -Asheville Regional Charah Inc./ MW1A-Al
Asheville Plant MW2A-Al
1 Airport General Aviation Buncombe 732,408 Asheville Airport 35.445561 -82.541978 Completed
(ponded ash) MW4A-Expansion,Asheville Authority
MW5-Al
MWl -A3**
MW2-A3**
Asheville Plant Area 3-Asheville Regional Charah Inc./ MW3-A3**
2 Airport General Aviation Buncombe 1,300,000 Asheville Airport 35.443409 -82.547168 MW4-A3** In progress
(ponded ash) Expansion,Asheville Authority MW5-A3**
MW6-A3**
MW7—A3**
MW1A-A4
MW2-A4
Asheville Plant Area 4-Asheville Regional Charah Inc./ MW5-A4
3 Airport General Aviation Buncombe 2,000,000 Asheville Airport 35.428536 -82.541947 MWSD-A4 In progress
(ponded ash) Expansion,Asheville Authority MW6-A4
MW7-A4
MW9-A4
* Current information as of October 30,2013.
**Monitoring wells locations and numbering are contingent on approval by the Division's Asheville Regional Office.

Duke Progress Energy - Groundwater Monitoring Requirements Permit Number: WQ0000020
GROUNDWATER CHARACTERISTICS MONITORING REQUIREMENTS
PCS Code Parameter Description Frequency Measurement Sample Type Footnotes
61097 Antimony,Total(as Sb) 2 X year Grab
01002 Arsenic,Total(as As) 2 X year Grab
01007 Barium,Total(as Ba) 2 X year Grab
01022 Boron,Total(as B) 2 X year Grab
01027 Cadmium,Total(as Cd) 2 X year Grab
00940 Chloride(as.Cl) 2 X year Grab
01034 Chromium,Total(as Cr) 2 X year Grab
01042 Copper,Total(as Cu) 2 X year Grab
01045 Iron,Total(as Fe) - 2 X year Grab
01051 Lgad,Total(as Pb) 2 X year Grab
01055 Manganese,Total(as Mn) 2 X year Grab
71900 Mercury,Total(as Hg) 2 X year Grab
01067 . Nickel,Total(as Ni) 2 X year Grab
00620 Nitrogen,Nitrate Total(as N) 2 X year Grab
00400 pH 2 X year Field I
01147 Selenium,Total(as Se) 2 X year Grab
00095 Specific Conductance 2 X year Field I '
70300 Solids,Total Dissolved- 180 Deg.0 2 X year Grab
00945 Sulfate,Total(as SO4) 2 X year Grab
01059 Thallium,Total(As Tl) 2 X year Grab
82546 Water level, distance from measuring point 2 X year Calculated 1,2
01092 Zinc,Total(as Zn) 2 X year Grab
1. The measurement of water levels shall be made prior to purging the wells.The depth to water in each well shall be measured from the surveyed point on the top of the casing. The measurement of
pH and specific conductance shall be made after purging and prior to sampling for the remaining parameters.
2. The measuring points(top of well casing)of all monitoring wells shall be surveyed to provide the relative elevation of the measuring point for each monitoring well. The measuring points(top r
casing)of all monitoring wells shall be surveyed relative to a common datum.

rftDUKE �l E A V Duke Energy Progress,Inc.
410 S.Wilmington Street/NC14
ERGY® � Raleigh,NC 27601
��®GREss OCT 212013
As a V iile Regional Office
Aquifer PrOtOction
October 25, 2013
Ms. Chonticha McDaniel
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Land Application Unit
1636 Mail Service Center
Raleigh, NC 27699-1636
Subject: Duke Energy Progress, Inc. (Duke Energy)
Distribution of Ash Residuals Permit
Draft Permit No.WQ0000020
Dear Ms. McDaniel:
In April 2013, Duke Energy notified the Division of Water Resources(DWR)of a name change from
Progress Energy Carolinas, Inc.to Duke Energy Progress, Inc. The Land Application Unit was the only
program within DWR to issue an updated permit,or a draft permit, based upon the name change
request. Rather, for example,the Wastewater Branch, which issues NPDES wastewater permits, made
note of the name change in the electronic database and intends to update the affected permits upon
renewal. As such, Duke Energy requests that you rescind the draft permit No.WQ0000020 and
incorporate necessary updates, including the name change,at permit renewal. The draft permit
maintained the expiration date of February 28, 2015.
As requested during our meeting on September 30,2013,to discuss the proposed draft permit
WQ0000020, Duke Energy provides the following comments.
Page 1 of 10
• The permit should be issued to "Duke Energy Progress, Inc." Similarly, in the first sentence, add
", Inc. (Duke Energy Progress)".
• Duke Energy requests that the second and third sentences from the first paragraph be deleted:
"The use and disposal of ash residuals are regulated under Title 40 Code of Federal Regulations
Part 257.This permit does not exempt the Permittee from complying with the federal
regulations." Sluiced ash is a wastewater regulated by the NPDES program;therefore the reuse
of wastewater treatment residuals is not governed by solid waste regulations. Residuals
permitted under NPDES permits are exempt from the solid waste regulations, per§ 130A-290
(35)(b)(3):
"Solid waste"means any hazardous or nonhazardous garbage, refuse or sludge from a
waste treatment plant, water supply treatment plant or air pollution control facility,

a
I
McDaniel Letter
October 25,2013
domestic sewage and sludges generated by the treatment thereof in sanitary sewage
collection, treatment and disposal systems, and other material that is either discarded or is
being accumulated, stored or treated prior to being discarded, or has served its original
intended use and is generally discarded, including solid, liquid,semisolid or contained
gaseous material resulting from industrial, institutional, commercial and agricultural
operations, and from community activities. The term does not include:
a. Fecal waste from fowls and animals other than humans.
b. Solid or dissolved material in:
■ Domestic sewage and sludges generated by treatment thereof in sanitary
sewage collection, treatment and disposal systems which are designed to
discharge effluents to the surface waters.
■ Irrigation return flows.
■ Wastewater discharges and the sludges incidental to and generated by
treatment which are point sources subject to permits granted under Section 402
of the Water Pollution Control Act, as amended(P.L. 92-500), and permits
granted under 6.5. 143-215.1 by the Environmental Management Commission.
However, any sludges that meet the criteria for hazardous waste under RCRA
shall also be a solid waste for the purposes of this Article.
Condition I Schedules, Item 1
• Duke Energy requests a copy of the official Division forms referenced. "Permittee shall request
renewal of this permit on official Division forms."
• Duke Energy requests replacing the time period from "six months"to "180 days"to be
consistent with units of time elsewhere in the permit and to be consistent with other permitting
language.
Condition I Schedules, Item 2
• Duke Energy requests replacing the phrase "...for each structural fill site listed under the
Attachment B:"with "...for each currently-approved structural fill site:".
• Duke Energy requests confirmation that an updated site plan will not be required for the Sutton
Plant project. Duke Energy understands the requirement of rule 15A NCAC 02T.0105(d)to
submit updated site plans for approved structural fill sites if those plans were required as part of
the original submittal. Since the structural fill project with ash from the Sutton Plant was
completed between 2001 and 2003 under Permit WQ0000020 dated July 9, 1998, prior to the
codification of the 2T rules, Duke Energy believes the requirements of this condition does not
apply to this project.
Condition II Performance Standards, Item 1
• Duke Energy requests that the phrase "of the ash stockpile/storage areas or the ash reuse site"
be inserted following the wording"operation and maintenance" in the second sentence.
Condition II Performance Standards, Item 7
• Duke Energy requests that the first sentence be deleted and the second sentence be modified to
read: "The Permittee shall submit an application, including all required documentation as
required under 15A NCAC 02T.1204(d),for Division's approval prior to commencement of any
2

McDaniel Letter
October 25,2013
new or expanding structural fill sites." After approval,the Division would issue an "approval"
letter and the project would be covered under the issued permit, without reissuance.
Condition II Performance Standards, Item 8
• Duke Energy requests that the phrase "...listed in Attachment B..." be deleted and the word
"approved" be inserted before "structural fill sites...".
• Duke Energy requests that the word "permitted" in the second sentence be changed to
"approved".
• Duke Energy requests that the last sentence be modified to delete the reference to Attachment
B and instead insert"...will be included in the application for the site.".
Condition II Performance Standards, Item 9
• Duke Energy requests that the phrase"...listed in Attachment B..." be deleted and the word
"approved" be inserted before"structural fill sites...".
Condition III Operation and Maintenance Requirements, Item 3
• Duke Energy requests removal of wording"and NPDES treatment units"from line 2.
Condition IV Monitoring and Reporting Requirements, Item 5
• Duke Energy requests that"...each structural fill site listed under Attachment B..." be replaced
with "...each approved structural fill site...".
Condition IV Monitoring and Reporting Requirements, Item 7
• Duke Energy requests that for number"GW-59" be changed to "GW-59CCR" for consistency
with the report submits to NCDENR per NPDES wastewater permit requirements. See next
comment.
Condition IV Monitoring and Reporting Requirements, Item 8
• Duke Energy requests that the Land Application Unit utilize the format for information exchange
that has been established per the NPDES wastewater permit for groundwater results around our
ash basins. Duke Energy provides two copies of GW-59CCR to the Information Processing Unit
and one copy to the appropriate regional office. The laboratory results are not included, but
rather maintained onsite and available to DENR upon request. Therefore, Duke Energy requests
that the submittal form be changed to GW-59CCR and the phrase "...along with attached copies
of laboratory analyses..." be deleted.
Condition VI General Conditions, Item 5
• Duke Energy requests that the wording"...or method otherwise approved by the Director" be
added following the "This request shall be make on official Division forms, ..." For the
convenience of both parties,the Director approved the methodology used during the Progress
Energy Carolinas to Duke Energy Progress name change. This was not an ownership change
which would have required documentation of transference.
Attachment B:
• Duke Energy requests that Attachment B be removed. Approved projects, based on the
3

McDaniel Letter
October 25,2013
submitted application documents and approved sampling locations, are on file at your office.
Listing approved sites in the permit would require a new permit issuance for any subsequent
projects. Duke Energy recommends removing Attachment B and substituting language provided
in other comments.
• Otherwise, if Attachment B remains, Duke Energy requests that a footnote be added to the
attachment title to indicate that this attachment includes projects that were approved at time
of permit issuance. Subsequent approved projects are maintained in your files. The division
would provide a letter to Duke Energy acknowledging receipt, review and approval for each
subsequently submitted project. Thus,together with suggestions made in other comments,this
permit would not have to be reissued for each approved project.
• Otherwise, if Attachment B remains, Duke Energy requests the Sutton Plant structural fill project
be removed from Attachment B. This project was completed between 2001 and 2003 under
Permit WQ0000020 dated July 9, 1998 prior to the codification of the 2T rules.
• Otherwise, if Attachment B remains, Duke Energy requests that the information for Asheville
Area 3 Groundwater Monitoring Wells column be deleted. The groundwater wells numbering
and locations for this area have not been approved by the DENR Asheville Regional Office at this
time.
• Otherwise, if Attachment B remains, Duke Energy requests that columns"Total Distribution
Amount" and "Project Status" be deleted. This information may change during the permit term
and thus would be inaccurate.
Per our meeting on September 30, 2013 regarding the draft permit, Duke Energy reiterates our concern
that structural fills were removed from the draft permit language. As the draft is currently proposed,
Duke Energy will be required to seek approval and permit modification for each structural fill project. All
of Duke Energy's reuse of ash besides that of structural fills are uses that are deemed permitted per 15A
NCAC 02T.1203. Should DWR remove DEP's authorization to perform future structural fills and require
that each site receive specific approval,then it calls into question the need for Duke Energy to hold an
ash reuse permit.
Please direct Distribution of Ash Residuals Permit correspondences to John Toepfer at Duke Energy
Progress,410 South Wilmington Street—NCRH-14, Raleigh, NC 27601. You may contact me at 919-546-
7863 with any questions concerning this subject. Thank you for the opportunity to provide comments to
the proposed draft permit.
Sincerely,
John Toepfer, P.E.
Senior Environmental Specialist
4

McDaniel Letter
October 25,2013
cc: Robin Bryson—Duke Energy
Landon Davidson—Asheville Regional Office Aquifer Protection Section
Y !f ty Asheville Regional Office Aquifer Protection Section
Toya Ogallo—Duke Energy
Jon Risgaard—DENR Land Application Unit
Allen Stowe—Duke Energy
5

FILIE
-At--
N CDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
October 23, 2013
John R. Toepfer, P.E.
Duke Energy Progress
410 S. Wilmington Street/PEB14
Raleigh, NC 27601
RE: Response to comments from Duke Energy Progress dated September 6, 2013
concerning the Asheville Airport Engineered Fill Project—Area III Development
Dear Mr. Toepfer:
The Asheville Regional Office of the Division of Water Resources (DWR) acknowledges receiving
a response to our review comments dated August 6, 2013. We have provided additional
questions and comments, in the bulleted paragraphs below. Please note that some comments
include requirements applicable to all structural fill areas at this site:
• CCP leachate in Area IV and possibly Area III is/will be pumped and hauled by VLS of
South Carolina to their industrial wastewater treatment plant located in Mauldin, SC.
DWR is requesting a letter from VLS of South Carolina specifically agreeing to accept the
CCP leachate and verification that they are authorized to operate an industrial
wastewater treatment facility. Please provide a total volume of CCP leachate that has
been pumped and hauled to date.
• The Metropolitan Sewerage District (MSD) of Buncome County recently issued an
industrial discharge permit to allow the CCP leachate to be discharged to their public
sewer system from both Area IV and Area III. Please provide a letter from MSD
specifically agreeing to accept the CCP leachate and a copy of the industrial discharge
authorization.
• In order for DWR to monitor the condition of the ash post-emplacement, please provide
all existing and future records pertaining to leachate water quality assessment,
discharge and disposal for all CCP fill areas. Please identify whether the leachate is
discharged to MSD (i.e.,flow volume) or any pump and haul contractor. This data can be
WATER QUALITY REGIONAL OPERATIONS SECTION
North Carolina Division of Water Quality—Asheville Regional Office
2090 U.S.Highway 70,Swannanoa,N.C. 28778
Phone[phone]
FAX [phone]
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer

Duke Energy Progress-Asheviiie
October 23, 2013
Page 2 of 3
submitted to DWR on the same schedule as the submittal of groundwater analytical
results.
• DWR had previously requested further explanation on the groundwater modeling
results, specifically those instances where the calculated 90%concentrations for several
analytes is higher at the compliance boundary as compared to the review boundary.The
explanation provided in Duke's September 16, 2013 response fails to satisfactorily
explain these calculations and therefore, a more detailed response or expanded
calculation is warranted. While DWR agrees that overall,the design of the ash
containment structure appears protective, it is difficult to ensure compliance with
permit condition 1.5 if the constituent concentrations as modeled indicate an increasing
trend away from the waste boundary. This is especially relevant in Area III where active
water supply wells are located within 300 feet of the structural fill. The DWR is
requesting a more detailed description of the model's 'prediction error' or alternatively,
further analysis that includes a greater number of realizations as your response
comment suggests.
• During the.hydrologic investigation for Area III,thallium was detected in monitoring well
MW6 at a concentration above the standards found in NCAC 2L .0200. Duke's
September 16th response indicates that Pace Analytical Services, Inc. suggests that
chloride can interfere with thallium analysis thus implying that the interference can
result in a false positive result. However, other onsite monitoring wells had higher
chloride concentrations without detections of thallium. Please provide additional
documentation and explanation, if available, regarding all thallium detections.
• Our previous letter highlighted the need for an operation and maintenance plan for the
CCP structural fills as required by 15A NCAC 02T.1208. Your comments largely
addressed the institutional controls being put in place during the design and
construction phases. What is lacking is a concise understanding of the long-term
maintenance needs at all of the structural fill sites. Please provide a detailed 0&M plan
that outlines the post-construction care of the Asheville Airport structural fill project (all
areas). The plan should address the following topics:
1. Party responsible for long-term maintenance,
2. Inspection frequency and reporting for all CCP fill areas is to include, but not be
limited to: visual inspection of all slopes underlain by CCPs, monitoring well
structural integrity, drainage pathways, and cover crop. Report and repair any
signs of erosion and breaches in fill and liner, keep slopes clear of woody debris,
maintain drainage features, and maintain cover crop. Report any day-lighting of
CCPs. Report any planned construction activities that will occur atop areas filled
with CCPs prior to those activities.
3. Protection of liners during the runway expansion project; and,

ru ke Enuke Energy Progress-Ashe
October 23,2013
Page 3 of 3
4. A quality assurance plan for groundwater monitoring.
• According to 15A NCAC 02T.1204, you are responsible for providing a site plan that
includes the location of all wells (including usage and construction details if available),
streams (ephemeral, intermittent, and perennial), springs, lakes, ponds, and other
surface drainage features within 500 ft. of the CCPs use boundary.
• DWR requested the relocation of monitoring wells MW3, MW4, and MW6.The new
locations for MW3 and MW6 are acceptable. The addition and location of MW7 is also
acceptable. It is understood that site conditions prevent the movement of MW4. The
current location of MW4 is acceptable.
Please contact me if you have any questions regarding our review comments. I can be reached
at [phone] or [e-mail].
Sincerely,
J �
i
Br tt Laverty ,
W ter Quality..Regional Operations Section
Ashe 'He-R gional Office
cc: Jon Risgaard—DWR Raleigh

DUKE�/ Duke Energy Progress,Inc.
410 S.Wilmington-Street.
ENERGY Raleigh,NC 27601
PROGRESS` '
RECEDED
OCT. 15 2013
OctOber_10, 2013 rzs v.I 'o i®r nal Office:
Mr.-Brett Laverty .
North.Carolina Department of Natural"Re.sources
Asheville Regional Office'—.Division of Water Resources
2090 u.S. Highway 70:
Swannanoa, NC 28778
Subject: Duke Energy Progress Inc. DEP
Asheville Airport Structural Fill Project-Area 1V Fill Leachate Analysis
Dear Mr. Laverty:
As requested by the Division of Water Resources,_ Duke Energy Progress,..Inc., is by this..letter` .
transmitting atone-time analysis of leachate from each phase of the.Asheville Airport Area IV Structural
Fill. Project. Enclosed are. the laboratory results from Pace. Analytical Services, Inc., and a table .
summarizing .the 'results. Besides the routine semi-annual groundwater sampling< events, it is our
understanding that the final submittal of information to the Division'for Area IV structural-fill will be the
Construction Quality Assurance.(CQA) report and.Project Certification.from the Engineer of Record and .
the Quality-Assurance Manager. If there are any questions.regarding Area IV structural fill, please
contact me at 919-546-7863.
Sincer�
Jo oepfer, P.
Senior Environmental Specialist
cc: Ed Sullivan-Duke Energy
Tony Mathis--Duke Energy
Laurie Moorhead—Duke Energy
Norman Divers--Charah, Inc:

Laverty Letter
October 10,2013
Area IV Asheville,Airport Structural Fill=Leachate Analysis
Parameter Phase I/IA Phase 2 PQL
Antimony(ug/I) <5 11.8 5
Arsenic.(ug/1) : <10 83.5 10
Barium (ug/l) 116 5.4. 5
Boron (ug/I) 2350 51.30 50
Cadmium (ug/I) <1 <1 1
Chloride (mg/1) 21.5. 12 1
Chromium (ug/I) <5 <5 5
Copper(ug/1) <5 <5- -5
Irori(ug/I) 1120 120 50
Lead (ug/I) <5 -<5: 5 .
Manganese(ug/1) _ 2080 200 . 5
Mercury(ug%I) <0.2 - <0.2 : 0.2
Nickel (ug/I) <5 . <5 5
Nitrate (as N) (mg/1) . 0.051 <0.02 0.02
Selenium (ug/I) <10 36.5 10
Sulfate (mg/1) 236 348 100
Thallium (ug/1) <10 <10 10
Zinc(ug/I) 26.3
<10 10.
TDS (mg/1) 854 867 25
pH (S.U.) 7.3. 7.9 N/A
PQL-Practical Quantitation Limit
ug/I-micrograms per liter
mg/I-milligrams per liter
S.U.•-Standard Units
2

® P ialytical Services,Inc. Pace Analytical Ser Inc. Pace Analytical Services,Inc.
aceAnalytical 205 East Meadow Road-Suite 2225 Rivempe Dr. 9800 Kincey Ave. Suite 100
www.pacdabs.com Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] [phone] [phone]
October 10, 2013
Mr. Norman Divers
Charah
303 Forest Bay Court
Belmont, NC 28012
RE: Project: AAA4 9/12
Pace Project No.: 92171970
Dear Mr. Divers:
Enclosed are the analytical results for sample(s) received by the laboratory on September 12, 2013.
The results relate only to the samples included in this report. Results reported herein conform to the
most current TNI standards and the laboratory's Quality Assurance Manual, where applicable, unless
otherwise noted in the body of the report.
Analyses were performed at the Pace Analytical Services location indicated on the sample analyte
page for analysis unless otherwise footnoted.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
/,, 2
Tom Williams
[e-mail]
Project Manager
Enclosures
ems ~ REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
�� without the written consent of Pace Analytical Services,Inc.. Page 1 of 18

0 lnalytical Services,Inc. Pace Analytical Se_-___-j,Inc. Pace Analytical Services,Inc.
acema/Xical 206 L-ast Meadow Road-Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
www.paceiabs.com Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] [phone] [phone]
CERTIFICATIONS
Project: AAA4 9/12
Pace Project No.: 92171970
Asheville Certification IDs
2225 Riverside Dr.,Asheville,NC 28804 North Carolina Wastewater Certification#:40
Florida/NELAP Certification#:E87648 South Carolina Certification#:99030001
Massachusetts Certification#:M-NC030 West Virginia Certification#:356
North Carolina Drinking Water Certification#:37712 Virginia/VELAP Certification#:460222
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
without the written consent of Pace Analytical Services,Inc.. Page 2 of 18

e P nalytical Services,Inc. Pace Analytical Sei Inc. Pace Analytical Services,Inc.
aceAnalytical 205 East Meadow Road-Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
www,pacelabs ccom Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] [phone] [phone]
SAMPLE SUMMARY
Project: AAA4 9/12
Pace Project No.: 92171970
Lab ID Sample ID (Matrix Date Collected Date Received
92171970001 PHASE 2 LEACHATE Water 09/12/13 13:00 09/12/13 14:00
92171970002 PHASE 111A LEACHATE Water 09/12/13 13:20 09/12/13 14:00
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
without the written consent of Pace Analytical Services,Inc.. Page 3 of 18

® 1 Lnalytical Services,Inc. Pace Analytical Se__.___,Inc. Pace Analytical Services,Inc.
acemalytical 205 East Meadow Road-Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
www.pacelabs.com Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] [phone] [phone]
SAMPLE ANALYTE COUNT
Project: AAA4 9/12
Pace Project No.: 92171970
Analytes
Lab ID Sample ID Method Analysts Reported
92171970001 PHASE 2 LEACHATE EPA 200.7 JDA 14
EPA 245.1 MTS 1
SM 2540C MDW 1
EPA 9040 AES2 1
EPA 300.0 SAE 2
EPA353.2 DMN 3
SM 4500-CI-E DMN 1
92171970002 PHASE 1/1A LEACHATE EPA200.7 JDA 14
EPA 245.1 MTS 1
SM 2540C MDW 1
EPA 9040 AES2 1
EPA 300.0 SAE 2
EPA353.2 DMN 3
SM 4500-CI-E DMN 1
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
without the written consent of Pace Analytical Services,Inc.. Page 4 of 18

® 1 analytical Services,Inc. Pace Analytical Se ,Inc. Pace Analytical Services,Inc.
aceAnalytical 205 East Meadow Road-Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
www.pacelabs.com Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 2807E
[phone] [phone] [phone]
ANALYTICAL RESULTS
Project: AAA4 9/12
Pace Project No.: 92171970
Sample: PHASE 2 LEACHATE Lab ID: 92171970001 Collected: 09/12/13 13:00 Received: 09/12/13 14:00 Matrix:Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
200.7 MET ICP Analytical Method:EPA 200.7 Preparation Method:EPA 200.7
Antimony 11.8 ug/L 5.0 1 09/13/13 11:15 09/13/13 21:30 7440-36-0
Arsenic 83.5 ug/L 10.0 1 09/13/13 11:15 09/13/13 21:30 7440-38-2
Barium 54.0 ug/L 5.0 1 09/13/13 11:15 09/13/13 21:30 7440-39-3
Boron 5130 ug/L 50.0 1 09/13/13 11:15 09/13/13 21:30 7440-42-8
Cadmium ND ug/L 1.0 1 09/13/13 11:15 09/13/13 21:30 7440-43-9
Chromium ND ug/L 5.0 1 09/13/13 11:15 09/13/13 21:30 7440-47-3
Copper ND ug/L 5.0 1 09/13/13 11:15 09/13/13 21:30 7440-50-8
Iron 120 ug/L 50.0 1 09/13/13 11:15 09/13/13 21:30 7439-89-6
Lead ND ug/L 5.0 1 09/13/13 11:15 09/13/13 21:30 7439-92-1
Manganese 200 ug/L 5.0 1 09/13/13 11:15 09/13/13 21:30 7439-96-5
Nickel ND ug/L 5.0 1 09/13/13 11:15 09/13/13 21:30 7440-02-0
Selenium 36.5 ug/L 10.0 1 09/13/13 11:15 09/14/13 15:25 7782-49-2
Thallium ND ug/L 10.0 1 09/13/13 11:15 09/13/13 21:30 7440-28-0
Zinc ND ug/L 10.0 1 09/13/13 11:15 09/13/13 21:30 7440-66-6
245.1 Mercury Analytical Method:EPA 245.1 Preparation Method:EPA 245.1
Mercury ND ug/L 0.20 1 09/13/13 17:05 09/16/13 20:18 7439-97-6
2540C Total Dissolved Solids Analytical Method:SM 2540C
Total Dissolved Solids 867 mg/L 25.0 1 10/08/13 13:46 H1
9040 pH Analytical Method:EPA 9040
pH 7.9 Std.Units 0.10 1 09/16/13 15:35 H6
300.0 IC Anions 28 Days Analytical Method:EPA 300.0
Fluoride 0.54 mg/L 0.50 1 09/16/13 19:23 16984-48-8
Sulfate 348 mg/L 100 50 09/17/1311:02 14808-79-8
353.2 Nitrogen,NO2/NO3 unpres Analytical Method:EPA 353.2
Nitrogen,Nitrate ND mg/L 0.020 1 09/12/13 22:09
Nitrogen,Nitrite ND mg/L 0.020 1 09/12/13 22:09
Nitrogen,NO2 plus NO3 ND mg/L 0.020 1 09/12/13 22:09
4500 Chloride Analytical Method:SM 4500-CI-E
Chloride 12.0 mg/L 1.0 1 09/17/13 20:43 16887-00-6
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
Date:10/10/2013 11:55 AM without the written consent of Pace Analytical Services,Inc.. Page 5 of 18

® F' -.?nalytical Services,Inc. Pace Analytical Sei. oo,Inc. Pace Analytical Services,Inc.
aceAnalytical 205 East Meadow Road-Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
www.pacelabs.com Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] [phone] [phone]
ANALYTICAL RESULTS
Project: AAA4 9/12
Pace Project No.: 92171970
Sample: PHASE 1NA LEACHATE Lab ID: 92171970002 Collected: 09/12/13 13:20 Received: 09/12/13 14:00 Matrix:Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
200.7 MET ICP Analytical Method:EPA 200.7 Preparation Method:EPA 200.7
Antimony ND ug/L 5.0 1 09/13/13 11:15 09/13/13 21:33 7440-36-0
Arsenic ND ug/L 10.0 1 09/13/13 11:15 09/13/13 21:33 7440-38-2
Barium 116 ug/L 5.0 1 09/13/13 11:15 09/13/13 21:33 7440-39-3
Boron 2350 ug/L 50.0 1 09/13/13 11:15 09/13/13 21:33 7440-42-8
Cadmium ND ug/L 1.0 1 09/13/13 11:15 09/13/13 21:33 7440-43-9
Chromium ND ug/L 5.0 1 09/13/13 11:15 09/13/13 21:33 7440-47-3
Copper ND ug/L 5.0 1 09/13/13 11:15 09/13/13 21:33 7440-50-8
Iron 1120 ug/L 50.0 1 09/13/13 11:15 09/13/13 21:33 7439-89-6
Lead ND ug/L 5.0 1 09/13/13 11:15 09/13/13 21:33 7439-92-1
Manganese 2080 ug/L 5.0 1 09/13/13 11:15 09/13/13 21:33 7439-96-5
Nickel ND ug/L 5.0 1 09/13/13 11:15 09/13/13 21:33 7440-02-0
Selenium ND ug/L 10.0 1 09/13/13 11:15 09/14/1315:28 7782-49-2
Thallium ND ug/L 10.0 1 09/13/13 11:15 09/13/13 21:33 7440-28-0
Zinc 26.3 ug/L 10.0 1 09/13/13 11:15 09/13/13 21:33 7440-66-6
245.1 Mercury Analytical Method:EPA245.1 Preparation Method:EPA245.1
Mercury ND ug/L 0.20 1 09/13/13 17:05 09/16/13 20:21 7439-97-6 M1
2540C Total Dissolved Solids Analytical Method:SM 2540C
Total Dissolved Solids 854 mg/L 25.0 1 10/08/13 13:49 H1
9040 pH Analytical Method:EPA 9040
pH 7.3 Std.Units 0.10 1 09/16/13 15:35 H6
300.0 IC Anions 28 Days Analytical Method:EPA 300.0
Fluoride 0.64 mg/L 0.50 1 09/16/13 19:55 16984-48-8
Sulfate 236 mg/L 100 50 09/17/13 11:35 14808-79-8
353.2 Nitrogen,NO2/NO3 unpres Analytical Method:EPA 353.2
Nitrogen,Nitrate 0.051 mg/L 0.020 1 09/12/13 22:14
Nitrogen,Nitrite ND mg/L 0.020 1 09/12/13 22:14
Nitrogen,NO2 plus NO3 0.061 mg/L 0.020 1 09/12/13 22:14
4500 Chloride Analytical Method:SM 4500-CI-E
Chloride 21.5 mg/L 1.0 1 09/17/13 20:44 16887-00-6
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
Date:10/10/2013 11:55 AM without the written consent of Pace Analytical Services,Inc.. Page 6 of 18

I ® F _, nalytical Services,Inc. Pace Analytical Sei Inc. Pace Analytical.Services,Inc.
CeAnalytical 205 East Meadow Road-Suite A 2226 Riverside Dr. 9800 Kincey Ave. Suite 100
wwwpeelabscam Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] [phone] [phone]
QUALITY CONTROL DATA
Project: AAA4 9/12
Pace Project No.: 92171970
QC Batch: MERP/5583 ,Analysis Method: EPA 245.1
QC Batch Method: EPA 245.1 Analysis Description: 245.1 Mercury
Associated Lab Samples: 92171970001,92171970002
METHOD BLANK: 1046752 Matrix: Water
Associated Lab Samples: 92171970001,92171970002
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Mercury ug/L ND 0.20 09/16/1319:38
LABORATORY CONTROL SAMPLE: 1046753
Spike LCS LCS %Rec
Parameter Units Cone. Result %Rec Limits Qualifiers
Mercury ug/L 2.5 2.4 98 85-115
MATRIX SPIKE&MATRIX SPIKE DUPLICATE: 1046754 1046755
MS MSD
92171299001 Spike Spike MS MSD MS MSD %Rec Max
Parameter Units Result Cone. Cone. Result Result %Rec %Rec Limits RPD RPD Qual
Mercury ug/L ND 2.5 2.5 2.6 2.6 104 104 70-130 0 20
MATRIX SPIKE&MATRIX SPIKE DUPLICATE: 1046756 1046757
MS MSD
92171970002 Spike Spike MS MSD MS MSD %Rec Max
Parameter Units Result Cone. Cone. Result Result %Rec %Rec Limits RPD RPD Qual
Mercury ug/L ND 2.5 2.5 1.4 1.3 58 52 70-130 10 20 M1
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced,except in full,
Date:10/10/2013 11:55 AM without the written consent of Pace Analytical Services,Inc.. Page 7 of 18

Q/�,�,y' ® I' ,nalytical Services,Inc. Pace Analytical SeL......Inc. Pace Analytical Services,Inc.
c?CeA(Ic� ICBi! 205 East Meadow Road-Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
vnvwpacelaica Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] [phone] [phone]
QUALITY CONTROL DATA
Project: AAA4 9/12
Pace Project No.: 92171970
QC Batch: MPRP/14182 Analysis Method: EPA200.7
QC Batch Method: EPA200.7 Analysis Description: 200.7 MET
Associated Lab Samples: 92171970001,92171970002
METHOD BLANK: 1046626 Matrix: Water
Associated Lab Samples: 92171970001,92171970002
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Antimony ug/L ND 5.0 09/13/13 21:03
Arsenic ug/L ND 10:0 09/13/13 21:03
Barium ug/L ND 5.0 09/13/13 21:03
Boron ug/L ND 50.0 09/13/13 21;03
Cadmium ug/L' ND 1.0 09/13/13 21:03
Chromium ug/L ND 5.0 09/13/13 21:03
Copper ug/L ND 5.0 09/13/13 21:03
Iron ug/L ND 50.0 09/13/13 21:03
Lead ug/L ND 5.0 09/13/13 21:03
Manganese ug/L ND 5.0 09/13/13 21:03
Nickel ug/L ND 5.0 09/13/13 21:03
Selenium ug/L ND 10.0 09/13/13 21:03
Thallium ug/L ND 10.0 09/13/13 21:03
Zinc ug/L ND 10.0 09/13/13 21:03
LABORATORY CONTROL SAMPLE: 1046627
Spike LCS LCS %Rec
Parameter Units Conc. Result %Rec Limits Qualifiers
Antimony ug/L 500 495 99 85-115
Arsenic ug/L 500 494 99 85-115
Barium ug/L 500 482 96 85-115
Boron ug/L 500 473 95 85-115
Cadmium ug/L 500 480 96 85-115
Chromium ug/L 500 474 95 85-115
Copper ug/L 500 484 97 85-115
Iron ug/L 5000 4820 96 85-115
Lead ug/L 500 483 97 85-115
Manganese ug/L 500 481 96 85-115
Nickel ug/L 500 487 97 85-115
Selenium ug/L 500 445 89 85-115
Thallium ug/L 500 476 95 85-115
Zinc ug/L 500 501 100 85-115
MATRIX SPIKE&MATRIX SPIKE DUPLICATE: 1046628 1046629
MS MSD
92171227001 Spike Spike MS MSD MS MSD %Rec Max
Parameter Units Result Conc. Conc. Result Result %Rec %Rec Limits RPD RPD Qual
Antimony ug/L ND 500 500 518 513 103 102 70-130 1 20
Arsenic ug/L ND 500 500 521 519 104 104 70-130 0 20
Barium ug/L 38.9 500 500 526 522 97 97 70-130 1 20
REPORT OF LABORATORY ANALYSIS
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a /+ r® I ,analytical Services,Inc. Pace Analytical Sei Inc. Pace Analytical Services,Inc.
aceAnalytical 205 East Meadow Road-Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
WWWpacelabs.com Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] [phone] [phone]
QUALITY CONTROL DATA
Project: AAA4 9/12
Pace Project No.: 92171970
MATRIX SPIKE&MATRIX SPIKE DUPLICATE: 1046628 1046629
MS MSD
92171227001 Spike Spike MS MSD MS MSD %Rec Max
Parameter Units Result Conc. Conc. Result Result %Rec %Rec Limits RPD RPD Qual
Boron ug/L 1100 500 500 1560 1550 94 91 70-130 1 20
Cadmium ug/L ND 500 500 486 487 97 97 70-130 0 20
Chromium ug/L ND 500 500 478 474 96 95 70-130 1 20
Copper ug/L ND 500 500 485 482 97 96 70-130 1 20
Iron ug/L 55.5 5000 5000 4880 4860 97 96 70-130 1 20
Lead ug/L ND 500 500 488 487 98 97 70-130 0 20
Manganese ug/L 67.3 500 500 548 545 96 95 70-130 1 20
Nickel ug/L ND 500 500 486 486 97 97 70-130 .0 20
Selenium ug/L ND 500 500 507 505 101 101 70-130 0 20
Thallium ug/L ND 500 500 472 473 94 95 70-130 0 20
Zinc ug/L ND 500 500 509 506 101 101 70-130 1 20
MATRIX SPIKE&MATRIX SPIKE DUPLICATE: 1046630 1046631
MS MSD
92171906001 Spike Spike MS MSD MS MSD %Rec Max
Parameter Units Result . Conc. Conc. Result Result %Rec %Rec Limits RPD RPD Qual
Antimony ug/L 2.6J 500 500 568 566 113 113 70-130 0 20
Arsenic ug/L 6.2J 500 500 580 577 115 114 70-130 0 20
Barium ug/L 21.9 500 500• 541 550 104 106 70-130 2 20
Boron ug/L 76.7 500 500 601 600 105 105 70-130 0 20
Cadmium ug/L ND 500 500 530 528 106 106 70-130 0 20
Chromium ug/L ND 500 500 503 500 101 1.00 70-130 1 20
Copper ug/L 2.3J 500 500 540 538 108 107 70-130 1 20
Iron ug/L 171 5000 5000 5170 5270 100 102 70-130 2 20
Lead ug/L ND 500 500 508 507 102 101 70-130 0 20
Manganese ug/L 17.0 500 500 520 518 101 100 70-130 0 20
Nickel ug/L 3.3J 500 500 513 513 102 102 70-130 0 20
Selenium ug/L ND 500 500 ND 462 0 92 70-130 20 M1
Thallium ug/L ND 500 500 479 477 96 95 70-130 1 20
Zinc ug/L 22.2 500 500 552 560 106 108 70-130 1 20
REPORT OF LABORATORY ANALYSIS
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® I analytical Services,Inc. Pace Analytical Se6....,Inc. Pace Analytical Services,Inc.
aceAnalytical 205 East Meadow Road-Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
,www.pacelabscom Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] [phone] [phone]
QUALITY CONTROL DATA
Project: AAA4 9/12
Pace Project No.: 92171970
QC Batch: WET/27479 Analysis Method: SM 2540C
QC Batch Method: SM 2540C Analysis Description: 2540C Total Dissolved Solids
Associated Lab Samples: 92171970001,92171970002
METHOD BLANK: 1061733 Matrix: Water
Associated Lab Samples: 92171970001,92171970002
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Total Dissolved Solids mg/L ND 25.0 10/08/13 13:43
LABORATORY CONTROL SAMPLE: 1061734
Spike LCS LCS %Rec
Parameter Units Conc. Result %Rec Limits Qualifiers
Total Dissolved Solids mg/L 250 250 100 80-120
SAMPLE DUPLICATE: 1061735
92171970001 Dup Max
Parameter Units Result Result RPD RPD Qualifiers
Total Dissolved Solids mg/L 867 872 1 20 H1
REPORT OF LABORATORY ANALYSIS
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0 P nalytical Services,Inc. Pace Analytical Sei Inc. Pace Analytical Services,Inc.
aceAnalytical 205 East Meadow Road-Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
www.pacelabs.com Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] (82B)254-7176 [phone]
QUALITY CONTROL DATA
Project: AAA4 9/12
Pace Project No.: 92171970
QC Batch: WET/27145 Analysis Method: EPA 9040
QC Batch Method: EPA 9040 Analysis Description: 9040 pH
Associated Lab Samples: 92171970001,92171970002
SAMPLE DUPLICATE: 1047925
92171896001 Dup Max
Parameter Units Result Result RPD RPD Qualifiers
pH Std.Units 7.1 7.0 1 20 D6,H6
REPORT OF LABORATORY ANALYSIS
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® 1 malytical Services,Inc. Pace Analytical Se—�..,Inc. Pace Analytical Services,Inc.
aceAnalytical 205 East Meadow Road-Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
www.pacelabo.com Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] [phone] [phone]
QUALITY CONTROL DATA
Project: AAA4 9/12
Pace Project No.: 92171970
QC Batch: WETA/16449 Analysis Method: EPA 300.0
QC Batch Method: EPA 300.0 Analysis Description: 300.0 IC Anions
Associated Lab Samples: 92171970001,92171970002
METHOD BLANK: 1046760 Matrix: Water
Associated Lab Samples: 92171970001,92171970002
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Fluoride mg/L ND 0.50 09/16/1315:36
Sulfate mg/L ND 2.0 09/16/1315:36
LABORATORY CONTROL SAMPLE: 1046761
Spike LCS LCS %Rec
Parameter Units Conc. Result %Rec Limits Qualifiers
Fluoride mg/L 5 4.9 97 90-110
Sulfate mg/L 20 19.0 95 90-110
MATRIX SPIKE&MATRIX SPIKE DUPLICATE: 1046762 1046763
MS MSD
92171568001 Spike Spike MS MSD MS MSD %Rec Max
Parameter Units Result Conc. Conc. Result Result %Rec %Rec Limits RPD RPD Qual
Fluoride mg/L 0.67 5 5 56.9 56.2 1125 1111 90-110 1 20 M6
Sulfate mg/L 104 20 20 99.1 98.7 -22 -24 90-110 0 20 M6
REPORT OF LABORATORY ANALYSIS
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e F nalytical Services,Inc. Pace Analytical Ser Inc. Pace Analytical Services,Inc.
aceAnaIX cal 205 East Meadow Road-Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
www..pacdabs.com Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] [phone] [phone]
QUALITY CONTROL DATA
Project: AAA4 9/12
Pace Project No.: 92171970
QC Batch: WETA/16439 Analysis Method: EPA 353.2
QC Batch Method: EPA 353.2 Analysis Description: 353.2 Nitrate+Nitrite,Unpres.
Associated Lab Samples: 92171970001,92171970002
METHOD BLANK: 1046356 Matrix: Water
Associated Lab Samples: 92171970001,92171970002
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Nitrogen,Nitrate mg/L ND 0.020 09/12/13 21:59
Nitrogen,Nitrite mg/L ND 0.020 09/12/13 21:59
Nitrogen,NO2 plus NO3 mg/L ND 0.020 09/12/13 21:59
LABORATORY CONTROL SAMPLE: 1046357
Spike LCS LCS %Rec
Parameter Units Cone. Result %Rec Limits Qualifiers
Nitrogen,Nitrate mg/L 2.5 2.5 99 90-110
Nitrogen,Nitrite mg/L 1 0.97 97 90-110
Nitrogen,NO2 plus NO3 mg/L 2.5 2.5 99 90-110
MATRIX SPIKE&MATRIX SPIKE DUPLICATE: 1046360 1046361
MS MSD
92171855004 Spike Spike MS MSD MS MSD %Rec Max
Parameter Units Result Cone. Cone. Result Result %Rec %Rec Limits RPD RPD Qual
Nitrogen,Nitrate mg/L 0.047 2.5 2.5 2.3 2.4 92 92 90-110 0 20
Nitrogen,Nitrite mg/L ND 1 1 0.92 0.93 92 92 90-110 1 20
Nitrogen,NO2 plus NO3 mg/L 0.047 2.5 2.5 2.3 2.4 92 92 90-110 0 20
REPORT OF LABORATORY ANALYSIS
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® P -analytical Services,Inc. Pace Analytical Se. Inc. Pace Analytical Services,Inc.
aceMalXical 205 East Meadow Road-Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
www.pacelahs.com Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] [phone] [phone]
QUALITY CONTROL DATA
Project: AAA4 9/12
Pace Project No.: 92171970
QC Batch: WETA/16482 Analysis Method: SM 4500-CI-E
QC Batch Method: SM 4500-CI-E Analysis Description: 4500 Chloride
Associated Lab Samples: 92171970001,92171970002
METHOD BLANK: 1048911 Matrix: Water
Associated Lab Samples: 92171970001,92171970002
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Chloride mg/L ND 1.0 09/17/13 20:34
LABORATORY CONTROL SAMPLE: 1048912
Spike LCS LCS %Rec
Parameter Units Cone. Result %Rec Limits Qualifiers
Chloride mg/L 20 19.7 98 90-110
MATRIX SPIKE&MATRIX SPIKE DUPLICATE: 1048913 1048914
MS MSD
92171568001 Spike ' Spike MS MSD MS MSD %Rec Max
Parameter Units Result Conc. Conc. Result Result %Rec %Rec Limits RPD RPD Qual
Chloride mg/L 292 20 20 298 299 30 38 75-125 1 20 M6
MATRIX SPIKE&MATRIX SPIKE DUPLICATE: 1048915 1048916
MS MSD
92171568003 Spike Spike MS, MSD MS MSD %Rec Max
Parameter Units Result Conc. Conc. Result Result %Rec %Rec Limits RPD RPD Qual
Chloride mg/L 64.1 20 20 80.9 81.1 84 85. 75-125 0 20
REPORT OF LABORATORY ANALYSIS
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e F nalytical Services,Inc. Pace Analytical Sei Inc. Pace Analytical Services,Inc.
aceAnalytical 205 East Meadow Road-Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
www.peceleWom Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] [phone] [phone]
QUALIFIERS
Project: AAA4 9/12
Pace Project No.: 92171970
DEFINITIONS
DF-Dilution Factor,if reported,represents the factor applied to the reported data due to changes in sample preparation,dilution of
the sample aliquot,or moisture content.
ND-Not Detected at or above adjusted reporting limit.
J-Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL-Adjusted Method Detection Limit.
PRL-Pace Reporting Limit.
RL-Reporting Limit.
S-Surrogate
1,2-Diphenylhydrazine(8270 listed analyte)decomposes to Azobenzene.
Consistent with EPA guidelines,unrounded data are displayed and have been used to calculate%recovery and RPD values.
LCS(D)-Laboratory Control Sample(Duplicate)
MS(D)-Matrix Spike(Duplicate)
DUP-Sample Duplicate
RPD-Relative Percent Difference
NC-Not Calculable.
SG-Silica Gel-Clean-Up
U-Indicates the compound was analyzed for,but not detected.
N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for
each analyte is a combined concentration.
Acid preservation may not be appropriate for 2-Chloroethylvinyl ether,Styrene,and Vinyl chloride.
Pace Analytical is TN accredited.Contact your Pace PM for the current list of accredited analytes.
TNI-The NELAC Institute.
WORKORDER QUALIFIERS
WO:92171970
Ill This report was revised and reissued on October 10,2013.
ANALYTE QUALIFIERS
D6 The relative percent difference(RPD)between the sample and sample duplicate exceeded laboratory control limits.
H1 Analysis conducted outside the EPA method holding time.
H6 Analysis initiated outside of the 15 minute EPA recommended holding time.
M1 Matrix spike recovery exceeded QC limits. Batch accepted based on laboratory control sample(LCS)recovery.
M6 Matrix spike and Matrix spike duplicate recovery not evaluated against control limits due to sample dilution.
REPORT OF LABORATORY ANALYSIS
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® P Analytical Services,Inc. Pace Analytical Se.'_.___,Inc. Pace Analytical Services,Inc.
acemalXical 205 East Meadow Road-Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
-wmpecelabs.cam Eden,NC 27288 Asheville,NC 28804 Huntersville,NC 28078
[phone] [phone] [phone]
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Project: AAA4 9/12
Pace Project No.: 92171970
Analytical
Lab ID Sample ID QC Batch Method QC Batch Analytical Method Batch
92171970001 PHASE 2 LEACHATE EPA 200.7 MPRP/14182 EPA 200.7 ICP/12909
92171970002 PHASE 4/1A LEACHATE EPA 200.7 MPRP/14182 EPA 200.7 ICP/12909
92171970001 PHASE 2 LEACHATE EPA245.1 MERP/5583 EPA245.1 MERC/5408
92171970002 PHASEI/IA LEACHATE EPA245.1 MERP/5583 EPA245.1 MERC/5408 .
92171970001 PHASE 2 LEACHATE SM 2540C WET/27479
92171970002 PHASE 111A LEACHATE SM 2540C WET/27479
92171970001 PHASE 2 LEACHATE EPA 9040 WET/27145
92171970002 PHASE 1/1ALEACHATE EPA9040 -WET/27145
92171970001 PHASE 2 LEACHATE EPA 300.0 WETA/16449'
92171970002 PHASE 1/1A LEACHATE EPA 300.0 WETA/16449
92171970001 PHASE 2 LEACHATE EPA 353.2 WETA/16439
92171070002 PHASE 1/1A LEACHATE EPA 353.2 WETA/16439
92171970001 PHASE 2 LEACHATE SM 4500-CI-E WETA116482
92171970002 PHASE IMA LEACHATE SM 4500-CI-E WETA/16482 '
REPORT OF LABORATORY ANALYSIS
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CHAIN-OF-CUSTODY/Analytical Request Document
m The Chain-of-Custody is a LEGAL DOCUMENT.All relevant fields must be completed accurately.
Ice
Analytical.
l www.paClabs.com
Section A Section B Page: of
Section C
q Required j
Required Client Informa0on: Re fired Project Information: Invoice Information
Company: Report Toi Pfa'nG Attention: ,1 6 7 2 9 f 5-
m.y1
Address: Copy To: Company Name: ,^
�2ECtULATOF�1fAGENCY _ _ _
Address:, NPDES r- GROUND WATER. r.;• DRINKING WATER
Email Purchase Order No.: Pace Quote
l J"' O Reference: [� UST r RCRA {— OTHER
Fax Project Name:� Pace Project Manger.
Requested Due DateITAT: Project Number. Pace.Profile#: STgTE
i�egi[ested dn�lysts Filtered ijYlt�) '
Section D Matra Codes g z,
RequlredClientInformation MATRIX/coDE 'a' 'o - COLLECTED R(ESEN8fIV9S Y /
Drinking Water DW U a
Water WT A -
Waste Water WW a m COMPOSITE COMPOSITE U F ASI�Q �► �
Product P STarxrEN
Orcrue (/p b
Solusolid SL o
SAMPLE ID Oil Pe wa �? W v n �� 1NQ Se.
(A-Z,0-9/:) Air AR S
a w a d. v :. L. , �.
Sample IDS MUST BE UNIQUE Tissue TS O O r i-. d
Other OT'. 'U r Z Z
a d to
Coco 0 s c>
N' DATE. TIME DATE TIME' C. : O = _ _. Z Z MO yu tY- ';'Pace Proj ct NaJ b I.D.
S ewC
77 00 3 J'Z . j f
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ADDITIONALCUMMENTS;= YtELiN4l11SHE BY%APFILITION DATE 7iME /)G EPTED �AFI°IL1(1TION D TE TIME ` SAMPLE CONDITIONS
ar
� SAMPGERNAME AaD SIGNATURE - � ;� _ o o.. �c c
v PRINT Name of SAMPLER: g ci y z
0 ORIGINAL �"'' a m 1-9 a�
0o SIGNATURE of SAMPLER: DATE Signed F I O m
(MMIDDlYY): w w
'Important Nate:By signing this form you are accepting Pace's NET 30 day payment terms and agreeing to late charges of 1.5%per month fo ny Invoices not paid within 30 diTs. F-ALL-0-020rev.07,15-May-2007

❑ 'nent.Name Sample`Condifion Upon•- ,u1ment'Revised:June 4,2013
Receii .} SOUR Page 1 of 2
„��a «. Document No Issuin_Authontles:
F=ASV=CS-003-rev.11 Pace Asheville Quali Office '
lent,Name:.
Where Received: HuntersvilleAsheville Fl. Eden Raleigh
Courier(Circle):, Fed Ex UPS USPS CI�Kj-• Commercial Pace Other
Custody.Seal on Cooler/Box.Present: yes Z no Seals intact: Fj• yes ' no
Packing Material: Bubbl;!Gg
Wrap Bubble Bags None Other
Circle Thermometer Used:1 - 30265963 Type of Ice: Blue None Zamples on ice,cooling process has begun
un#2-80344039
Temp Correction Factor: Add/S tra 0 r . C
Corrected Cooler Temp.: d C. Biological Tissue is.Frozen: Yes No N/A Date and`Initials of person exarpiningi
contents
Temp should be above freezing to 6°C Comments::
3
Chain of Custody Present: es ONO ❑N/A 1.
Chain of Custody Filled Out: es. ONO. ❑N/A 2.
Chain of Custody Relinquished: es..❑No ON/A.3.
Sampler Name&Signature on GOC: ;Rf. ❑NO' ON/A--4.
Samples Arrived within Hold Time: es ❑No ❑wA 5,
$hort'Hold Tithe Analysis(<72hr):• es ONO ❑wA 6. c ti
Rush Turn Around Time Requested: ❑Yes UK. ❑wA: 7.
Sufficient Volume: Yes ONO ❑N/A 8.
Correct Containers Used: ^es ONO ❑N/A 9.
-Pace Containers Used: .8Yes ONO' ❑N/A
Containers Intact: Yes ONO ❑N(A 10.
Filtered volume received for Dissolved tests 'Dyes ONO Ier 1A 11.
Sample Labels match COC: , . Yes ONO" ❑N/A 12.
-includes date/time/ID/Analysis Matrix:
All containers needing preservation have been checked. ZYes ONO ❑N/A 13.
All containers needing preservation are found to be in ONO ❑N/A
compliance with EPA recommendation.
exceptions: VOA, colifonn,TOC,O&G,WI-DRO(water) ❑Yes ONO
Samples checked for dechlorination: ❑Yes ONO 6A 14.
Headspace in VOA Vials >6mm): ❑Yes ONO N/A 15.
Trip Blank Present: ❑Yes ONO �%1A 16.
Trip Blank Custody Seals Present ❑Yes ONO C A
Pace Trip Blank Lot#(if purchased):
Client Notification/Resolution: Field Data Required? Y. / N
Person Contacted: Date/Time:
Comments/Resolution:
SCURF Review: Date: f l WO# � 921-71970
SRF'Review: Date: `�
Note: Whenever there is a discrepancy.affecting Norfh Carolina
compliance samples,a copy of this form will be sent to the North II I II'I I III IL.I`II�I IIh
Carolina DEHNR Certification Office(Le out of hold,incorrect ! 92171970
preservative,out of temp,p,incorrect containers) .. ... . _-, .-,
Page'18 of 18.

DUKEDuke Energy Progress
ENERGY® 410 S.Wilmington Street
Raleigh, NC 27601
PROGRESS
September 16, 2013
North Carolina Department of Environment and Natural Resources
Asheville Regional Office
Division of Water Resources Aquifer Protection Section
Attn: Brett Laverty
2090 US Highway 70
Swannanoa, NC 28778
RE: Response to Comments on DENR Letters dated 8/6/2013 and 8/14/2013
Asheville Airport Engineered Fill Project—Area 3 Development
Dear Mr. Laverty:
We are writing in response to comments received from the Aquifer Protection Section in letters dated
August 6 and 14, 2013 regarding the Asheville Airport Engineered Fill Project—Area 3 Development. For
ease in review,we reference the letter and comment,followed by our response.
Letter dated August 6.2013:
1. According to 15A NCAC .02T .1204 (d), information shall be provided to the Division that
describes and explains site specific engineering or institutional controls proposed to prevent
adverse impacts to public health and the environment. Please submit a project narrative or
summary that addresses the estimated ash volume, project timeline, proposed uses for the
project, conceptual design of the fill, measures to prevent impacts to public health and the
environment, proposed groundwater monitoring plan, and protection measures to be
implemented between the closure of the fill and further development of the site and.
-The property where the engineered fill (Area III) has been designed is owned by the Asheville Regional
Airport Authority (ARAA). The coal combustion- product (CCP) engineered fill will offset the use-of
natural earthen material totaling approximately 930,723 cubic yards(or 1.3 million tons)and provide for
the development of a new taxi-way and additional commercial development. The CCP fill consists of a
mixture of fly ash and bottom ash obtained from the Duke Energy Progress, Inc. (DEP)-Asheville Steam
Electric Plant. The engineered fill will be constructed and operated by Charah, Inc., an experienced
contractor selected by the ARAA and DEP.
�. RECEIVED
i
SEP 17
Asheville Regional office www.duke-energy.com
Aquifer Protection

l
Laverty 2 September 16,2013
The engineered fill is designed to encapsulate the ash with an HDPE liner, cover and side-slopes that are
sealed. While the ash fill is being constructed, water that comes in contact with CCP is directed to a
leachate collection system which is over the HPDE liner system. The leachate is conveyed to a series of
two grit collection chambers. Presently, the leachate collected in Area IV is pumped and hauled for
disposal by VLS of South Carolina to their industrial wastewater treatment plant located in Mauldin,SC.
In the near future, the disposal of the leachate in Area IV will change. The Metropolitan Sewerage
District (MSD) of Buncombe County recently issued an industrial discharge permit to allow the contact
water to be discharged to their public sewer system and the sewer connection construction for Area IV
is currently underway. It is anticipated that the majority of the leachate for Area III will also be
discharged directly to the MSD system. This method of disposing of the contact water will continue for
the duration of the construction of the engineered fill projects until the CCPs have reached optimum
moisture condition and contact water discharge ceases. The time frame for this to occur is anticipated
to be 6 months to 1 year after the construction completion of the engineered fill project.
Even after connection to the MSD system, it is anticipated that the pump and haul of the contact water
will be required from time to time. VLS of South Carolina would continue to provide this service on an
as needed basis.
The engineered fill will be inspected and monitored throughout construction for construction quality
assurance and compliance with all applicable regulations, the engineering plans, and all DEP and ARAA
permit conditions. Water quality will be monitored both during construction and years after completion
through a network of groundwater monitoring wells. Construction of the project will begin in June 2013
with completion expected to occur on or before August'2015. Upon completion, the ARAA will begin
development of the new taxiway project providing the airport with an additional runway for airport
operations. Using as-built surveys and managing the 6-foot thick soil cap through construction of the
taxiway improvements will maintain the integrity of the encapsulated CCPs.
2. Upon reviewing the engineering drawings, it is not clear, particularly in the cross sections,
whether the cap design includes an HDPE liner over the entire structural fill. Please provide
clarification.
The cross sections are shown for informational purposes and the liner was not actually drawn for clarity.
The details show a 40 mil HDPE (Detail, Sheet 3-5.0) enveloping the limits of the engineered fill with the
cap tied into the anchor trench for the base liner system (Detail H, Sheet 3-11.0). The engineered fill is
completely encapsulated by HDPE flexible membrane liners along the bottom,top and side-slopes of the
CCP fill.
3. The hydrologic report on page 12 states "groundwater was present within about a 1 foot of the
ground surface in Borings B-14 and B-16." The cross section A-A on plans 3-6.0 shows excavation
of the watershed divide in and around B-14 and B-16. Please explain how the 2 foot vertical
separation between the base of the structural fill and the seasonal high water table will be met

Laverty 3 September 16,2013
as required in 15A NCAC 02T .1206 and please specifically address the observation of
groundwater within 1 foot of the ground surface in B-14 and B-16.
The cross sections are offset slightly from the locations of borings B-14 and B-16, so that the ground
surface in the cross section is not depicting the conditions at the boring locations. Both of the
referenced borings were performed at relatively low elevations near the surface stream, where fill is
planned to achieve base grades. The Base Grading Plan indicates there will actually be between 5 (B-14)
and 6 feet (B-16) of separation between the measured groundwater elevations and the base grades of
the engineered fill. The relationships between the borings and the base grades are more clearly shown
in Figure 2 of the hydrologic report, which has the boring locations plotted against the base grades (i.e.
Engineered Fill Grade at B-14 = 2127.7, groundwater elevation at B-14 = 2122.0, difference is 5.7';
Engineered Fill Grade at B-16=2133.0,groundwater elevation at B-16=2127,difference is 6').
In addition, B-14 was performed in close proximity to surface. water measuring point SW-3, which
depicts a water elevation nearly 8 feet below the base grade. After construction of the base grades and
installation of specific physical measures intended to control the groundwater levels (i.e. an underdrain
or French drain in the stream channel), the permanent groundwater level is expected to remain at or
below the elevations indicated at SW-3.
It should be remembered that water levels in borings are less reliable and possibly less accurate than
those from equilibrated wells. Also, the surface water (stream)levels are thought to be more accurate
than the water levels in B-14 and B-16, and therefore are used in defining the water table for the
•engineered fill design.
4. Upon reviewing the groundwater modeling results, it was observed that the 90% concentration
calculated for many analytes is higher at the compliance boundary than at the review boundary
which is closer to the CCB source. Please provide an explanation for this discrepancy.
We attribute the apparent discrepancies between the concentrations at the review and compliance
boundaries to normal prediction errors within the analytical tool. The'project geometry discussed in the
hydrological report is a separate analysis that is computationally independent of the other computer
runs. That is, for each geometric problem set-up, the Industrial Waste Management Evaluation (IWEM)
model analyzed 10,000 random Monte Carlo realizations and computed. the 90% concentration. based
on those realizations. The differences in the results are .believed to be the result of the small, but
present, error in the random nature of the realizations. Analyzing a greater number of realizations
within each geometric analysis would be expected to result in greater convergence in the 90%
concentrations (i.e. narrower confidence intervals) and might reduce or eliminate the apparent
discrepancies. The concept of the confidence intervals and prediction errors of the Monte Carlo
realizations is discussed in some detail in the technical manuals for the IWEM method and particularly in
the technical manual for the EPA's companion model, EPA's Model for Leachate Migration with
Transformation Products(EPACMTP).

Laverty 4 September 16,2013
It is notable.that in all cases where the apparent discrepancies occurred, the results were consistent in
terms of the overall decision-making process. For each affected chemical constituent, the analysis
indicated that the analyzed liner scenario was either protective for both the review and compliance
boundaries or not protective for both boundaries. Thus, additional program refinement would likely not
change the overall modeling conclusions.
Also, the majority of'the discrepancies were for the composite lined condition, where the computed
90% concentrations are very low (near zero on a practical basis), and the concentrations were a very
small fraction of the respective regulatory standards(RGC's). Thus, prediction errors inherent within the
analytical model are insignificant relative to the overall decision-making assessment.
5. The groundwater model assumes a depth to groundwater of 8 feet below land surface. Yet table
3 in the hydrologic report indicates at least 4 areas(borings) where the water table is less than 8.
feet below,the land surface. How does this affect the modeling results?
The IWEM'model, while rigorous in its computational theory, relies on several singular input values that
must be averaged or selected as representative of the overall geometry. The model requires simplifying
what are actually variable groundwater depths into a single input depth. While the depth to
groundwater is less than eight feet at several locations, the depth to groundwater greatly exceeds eight
feet at several other locations. Eight feet was selected as being representative, but conservative within
the overall geometric scheme(i.e.shallower than average).
GeoTrack performed a few un-reported models to attempt to evaluate the model's sensitivity to the
changes in depth to groundwater'(4 to 8 feet below land surface). We have found that minor variations
in the depth to groundwater obviously change the computed concentrations, but the overall conclusions
are the same. That is, multiple model runs indicate similar results relative to the feasibility of an un-
lined, clay lined, and composite lined facility.
6. Thallium was present at monitoring well W6 at a concentration above the applicable standard.
Please provide an explanation of this result.
The groundwater sample results (shown below) were collected in order to characterize the site
conditions prior to placement of the ash fill in Area III and have since been abandoned. The referenced
analyses were.total analyses, meaning the samples were not filtered in either the field or the laboratory,
per North Carolina groundwater regulations. No correlation between turbidity or chloride and thallium
concentrations appears evident. Of all wells sampled at the site, half had higher turbidity results than
MW-6 yet thallium concentrations were below detection limit at all the wells with the higher turbidity.
Well MW-2 had a higher chloride concentration and well MW-8 had a similar chloride concentration yet
both of these wells had thallium concentrations below detection limits. It is noteworthy that no ash was
encountered in the installation of well MW-6 and that Pace Analytical Services, Inc., when consulted,
indicated that chloride can interfere with thallium analysis. Well MW-6 was located near a stormwater
discharge from the ARAA existing runway, perhaps suggesting chloride,exposure from de-icing activities.

Laverty 5 September 16,2013
Partial Groundwater Results for Area III Structural Fill
Well/Parameter Date Sampled Turbidity(NTU) Chloride(mg/1) Thallium(ug/1)
MW-1 2/20/13 19.8 1.5. <10
MW-2 2/18/13 337 4.2 <10
M W-3 2/18/13 11 1.7 <10
MW-4 2/19/13 1.2 1.4 <10
MW-5 2/19/13 3.2 1.7 <10
MW-6 2/18/13 8.9 3 74
MW-7 2/19/13 9.3 1.8 <10
MW-8 2/20/13 15.1 2.5 <10
MW-9 2/19/13 3.1 2.2 <10
M W-10 2/20/13 214 1.6 <10
z Please be aware that 15A NCAC 02T .1204 (fJ requires the permittee to comply with the
provisions of 15A NCAC 02L.01OZ
The compliance and review boundaries have been established around the perimeter of the CCP fill and
are shown on Sheet 3-2.0. The site, has been deed restricted (attached) and Sheet 3-2.0 shows the
location of the proposed groundwater monitoring wells at the review,boundary.
8. Please be aware that 15A NCAC 02T.1208 requires and operation and maintenance plan. Please
include information describing how the structural fill and liner system will be protected during
future development activities at the site. Additionally, please provide a plan that will allow DWR
to track the maintenance of the fill prior to and during final development(e.g., installation of the
runway).
The development of the engineered fill project has been integral to the development plans for the new
taxiway project for the ARAA coordinating finished. grades and elevations With new infrastructure
associated with the airport improvements. A 6-foot thick soil layer separating the engineered fill cap
systems and subgrade improvements from any intrusive efforts that are planned for the airport
infrastructure construction has been provided. In addition,the airport will place more earthen materials
across the limits of the taxiway improvements whereby increasing the vertical separation of the taxiway
infrastructure from the engineered fill cap system.
Additionally, as-built surveys locating the soil subgrade system, liner system and the cap will be
performed and provided to the airport for use in the construction of the taxiway. The location of the
engineered fill critical components will be maintained throughout construction of the airport's
improvements with subsequent inspections and notification as needed should any intrusion to the
systems occur.

Laverty 6 September 16,2013
9. Please provide specific information that satisfies compliance with 15A NCAC 02L .0107 (f).
According to the rule, if the permittee is not the Owner of the land within the compliance
boundary then the current Owner will be required to execute and file in the register of deeds in
the county in which the land is located, an easement running with the land which contains:
• Either a notice of permit, including the permit number, a description of the type of
permit, address and telephone number of the permitting agency; or a reference to a
notice of the permit with book and page number of its recordation if such notice is
required to be filed by the statute
• Prohibits the construction and operation of water supply wells within the compliance
boundary, and,
• Reserves the right to the permittee and the State to enter on such property within the
compliance boundary for groundwater monitoring and remediation purposes.
The appropriate Statement of Structure Fill has been executed by the Greater Asheville Regional Airport
Authority and has been recorded at the Buncombe County Register of Deeds office (see attached),
reference Deed Book 5132, Pages 463-467.
10. The engineering plans (3-2.0) state, "research of well records indicates that there are no public
or private water supply wells within 100 feet of the proposed CCB waste boundary". According
to 15A NCAC 02T .1204 (d), the site plans or maps shall be provided to the Division by the
applicant depicting the location, orientation, and relationship of the CCP's use site's features
including: the location of all wells (including usage and construction details if available), within
500 feet of the CCP's use boundary. You need to submit well receptor survey that satisfies the
conditions of this rule.
All known public and private water supply wells have been identified on Sheet 3-2.0. It is our
understanding per our meeting on August 15, 2013 that DWR would be performing a well receptor
survey and advising DEP and the ARAA on its findings.
11. The engineering plans identify monitoring well MW-1 as a possible background well. This
monitoring well will be located down gradient from the structural fill and therefore not
acceptable to represent background water quality. You may elect to choose a more appropriate
up gradient location or utilize existing background wells associated with areas 1 and 4.
As discussed in the aforementioned meeting on August 15, 2013, DEP will utilize the existing background
groundwater well associated with CCP fill Area IV as the background well for CCP fill Area III.

' Laverty 7 September 16,2013
12. The DWR would request that monitoring wells MW-3, MW-4 and MW-6 be relocated. The
preferred areas will be discussed with Duke Progress Energy at the upcoming site meeting.
As discussed at the August 15, 2013 meeting, the location of groundwater well IVIW-4 is set given the
construction of the sediment basin and subsequent drainage and erosion control devices necessary for
the engineered fill and future taxiway development projects. The location of groundwater wells MW-3
and MW-6 can be relocated within a possible 10-15 foot radius of the current location as allowed by
drainage features and security fencing for the airport. DEP asks that DWR provide a preferred redline
location for these wells on the attached updated sheet 3-2.0.
13. All monitoring wells should be developed to bedrock refusal (i.e. screened within the transition
zone) and have an adequate supply of water for sampling. Monitoring well construction should
adhere to the rules outlined in 15A NCACA 02C.0108.
All groundwater monitoring wells will be developed to a point in which the geotechnical engineer has
established auger refusal with adequate screening to sample the transition zone. Each groundwater
monitoring well will be developed and screened to ensure adequate water production.
14. it appears that a leachate collection system is incorporated into the structural fill design. Please
provide detailed information on how the CCB leachate (and contact water) will be collected and
disposed of during and after construction.
For fill Area III, all contact water will be contained within the limits of the lined engineered fill and
conveyed from the fill to a series of two grit collection chambers. The grit collection chambers will be
connected to the MSD of Buncombe County public sewer system. MSD recently issued an industrial
discharge permit allowing the contact water to be discharged to their public sewer system and the
sewer connection construction is currently underway for fill Area IV. This method of disposing of the
contact water will continue for the duration of the construction of the engineered fill project until the
CCPs have reached optimum moisture condition and contact water discharge ceases. The time frame
for this to occur is anticipated to be 6 months to 1 year after the construction completion of the
engineered fill project.
Even after connection to the MSD system, it is anticipated that occasional pump and haul of the contact
water will be required from time to time. As described in Section 1 of this letter, VLS of South Carolina
would continue to provide this service on an as needed basis.

Laverty 8 September 16,2013'
15. Please submit a list of project personnel and their contact information.
Below please see the project contacts for the engineered fill project as requested. The contacts are
provided by affiliated company:
Duke Energy:
Tim Smart, PE,,Byproducts Marketing Manager John Toepfer, P.E.,Sr. Environmental Specialist
Office: 704:382.9616 Office: 919.546.7863
Mobile: [phone] Mobile: [phone]
[e-mail], [e-mail]
Laurie Moorhead, Environmental Specialist—Asheville Plant
Office:828.687.5240
Mobile:[phone]
[e-mail]
Charah, Inc.:
Matt Winfree, PMP,Operations Manager Michael Johnson,Site Manager
Office: 502.245.1353 Office:502.245.1353
Mobile: [phone] Mobile: [phone]
mwinfree @charah.com [e-mail]
Norman Divers, Engineering and Environmental Manager
Office:704.472.3919
Mobile: [phone]
[e-mail]
Letter dated August 14,2013:
1. There is a discrepancy in the details with respect to cover soil thickness of 2'or 4'. Section "A"on
plan sheet 3-5.0 has 4'of cover, were as Section "C"on plan sheet 3-10.0 has 2'of cover and the
CQC spec's in section 4.50 Vegetative Cover reference 24"J.
This is a required reference based on the contract minimum cover requirement between Charah and the
ARAA. By contract, Charah is required to provide a minimum of 24" or 2' of soil cover across the slopes
of the engineered fill project which is why the details and CQC specifications call for a minimum of 2'.
After reviewing the project in conjunction with the plans for the new taxiway project and infrastructure,
the ARAA required 4' soil cover. Therefore,the engineering design as designated on the project closure
plan (sheet 3-5.0) specifies 4' of soil cover. There is no discrepancy noted within the project principals
and 4' of soil cover will be placed on all side-slopes for Area III structural fill.

Laverty 9 September 16,2013
2. Plan sheet 3-11.0, detail "8"shows the HDPE pipe penetration thru the base liner system and
illustrates boot detail for the 60 mil HDPE and how it is to be constructed. There is no reference
to the geosynthetic clay liner or how it is to be penetrated or repaired;
This item is covered in the manufacturer's recommendations and documented in the field. The GCL
layer is cut around the pipe penetration'and loose bentonite is placed and spread a minimum of 6 inches
all around the pipe penetration, both under and between the GCL and the HDPE liner.
3. There is a discrepancy in the cap liner thickness. Section "H"on the plan sheet 3-11.0 indicates
30 mil HDPE, but plan sections on plan sheets 3-10. "C"and 3-5.0 "A"indicate 40 mil HDPE.
The cap HDPE liner thickness is 40 mil and the detail noting 30 mil has been revised.
4. Who/Whom is providing the overall certification of the project (i.e. grades met with respect to
SHWT/HDPE base liner and cap installed, tested, repaired per plans and specs, etc.) Please
provide the DWR with a,copy of the certification information.
The design Engineer of Record for Area III structural fill is Franklin S. Craig, PE. The materials testing
certification, including daily observation reporting, along with construction quality assurance will be the
responsibility of the Quality Assurance Manager, GeoTrack Technologies, Inc for Area III structural fill.
Project certification documents will be completed and provided to the ARAA and DEP upon completion
of Area III structural fill. DEP will provide DENR a copy of the final CQA documentation and project
certification for Area III structural fill.
5. The plans do not indicate a minimum cover thickness of coal ash over the HDPE liner, i.e. 3'or 4'
of ash minimum under the tracks,for travel across the cell(s);
Operations of the engineered fill require a minimum lift of 3' of CCPs to be placed as a "bridge" lift
across the liner system to allow for construction traffic. The initial bridge lift does not have a significant
compaction requirement given it is considered a protective lift or cover across the liner system.
6. It would be desirable to have either the geo-composite run completely under the washed#57
stone column and 8" HDPE leachate pipe or have a rub sheet under the stone column/pipe for .
protection of the HDPE(in conjunction with the 12 oz. geotextile fabric). This is the most critical
area of the liner system and if caution is not taken during the placement of the coal ash in this
area, damage to the base liner can occur if sudden stops or turns of tracked equipment take
place during the initial lift of ash across the cell(s);
This concern was considered during the design of Area IV and we appreciate the concept. We actually
found during the construction of Area IV that this design functioned very well and without any issues.
As such,we believe that maintaining this design for Area III fill is prudent.

o
' Laverty 10 September 16,2013
7. Will the contractor (or liner sub) be required to submit a GCL panel layout drawing prior to
installation for approval by the design engineer?,-
The means and methods for proper shingling or lapping the GCL is documented in the project
specifications and is monitored and documented by the Quality Assurance Manager (QAM) during
installation. No GCL panel layout is required for this project.
S. Will the contractor(or liner sub)be required to submit a HDPE panel layout/seaming drawing for
the base liner system prior to installation for approval by the design engineer?,-
The Liner installer does provide a panel layout for the HDPE liner system identifying the seaming
patterns and methods for liner installation in radiuses and corners for approval by the QAM and the
Engineer of Record (EOR) prior to installation.
9. Will the contractor(or liner sub)be required to submit an asbuilt drawing of the HDPE base liner
and HDPE cap liner indicating locations of test samples, seam repairs and type of membrane
repairs made to the panels (i.e. extrusion spot welds, pinhole repair, intersection of panels
extrusion welds, etc.)?.
The.Construction Surveyor develops as-built surveys for all of the conditions noted in this comment and
more with submission for approval to the QAM and the EOR. This information is compiled in the final
project certification document which is signed by both the QAM and FOR and submitted to the ARAA
and DEP.
We trust the above response to comments provide the DWR with the information requested. If you
require any additional information or have any further questions, please do not hesitate to contact us.
Sincerely, 4
John R.Toepfer, P.E.
Senior Environmental Specialist
Attachments: Recorded Statement of Structural Fill
Updated Construction Plans
cc: Tim Smart, P.E.—Duke Energy
Laurie Moorhead—Duke Energy
Charah Team

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dorkflowa 0000180893-0001
eunoombe Countv. NC
Drew Reisinger Reaister of Deeds
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STATEMENT OF STRUCTURAL FILL FACILITY
STATE OF NORTH CAROLINA
COUNTY OF BUNCOMBE
The undersigned Greater Asheville Regional Airport Authority(the"Authority`),in accordance with the provisions of N.C.Gen.StaL
§130A -294 and 15A N.CJLC.138.1707,acknowledges that it is a body corporate and politic originated and created underthe laws of the State
of North Carolina fnr the purpose of maintaining,operating,regulating and improving the Asheville Regional Airport, including certain real
property located in Limestone Township,Buncombe County,North Carolina.
Authority further acknowledges that coal combustion by-products, specifically ponded ash, will be beneficially utilized as
structural or engineered fill beneath portions of the Property more particularly described on Exhibit A attached hereto and incorporated herein by
reference.The volume of coal combustion by-products so utilized is estimated to be approximately 899,300 cubic,yards or 1,30D,000 tons: If
appricabie,this"Statement of Structural Fill will be amended within ninety(90)days after completion of the project if the actual volume of coal
combustion by-products-utilized on the Property is materially different than the volume set forth above.
It is also acknowledged by the undersigned Carolina Power&Light Company d/b/a Progress Energy Carolinas,Inc("PEC),that the
source of the coal combustion by-products was the PEC Asheville Steam Electric Power Plant PEC is also the holder of Permit WQOODW20,
Distribution of Residual Solids(503:Enempt),issued by the North Carolina Department of Environment and Natural Resources,Dnvision of Water
Quality,Aquifer Protection Section(the"Diivision!),1636 Mail Service Center,Raleigh,NC 27699-1636,[phone].
The Property is considered to be an individually-permitted ash use site by the Division and therefore a"compliance boundary",as
specified by regulations in 15A NCAC 2L(Le.,"Groundwater Classifications and Standards")must be established at either 250 feet from the ash
boundary or 50 feet within the Property boundary,whichever is closest to the ash boundary. Furthermore,a"review boundary'must be
established around the Property midway between the compliance boundary and the perimeter of the ash boundary..
in accordance with the requirements of 15A N.C.A.C.138.1707(d),when real property with more than 1,000 cubic yards of-coal
combustion byproducts is sold,leased,conveyed or transferred in any manner,the deed or other instrument of transfer shall contain in the
description section in no smaller type than used in the body of the deed or instrument a statement that coal combustion.byproducts have
been used as fill material on the property.No water supply well shall be constructed or operated within the compliance boundary of said fill. PEC
and the State reserve the right to access the compliance boundary of said fill for the purposes of groundwater monitoring and/or
remediation and the Authority hereby expressly grants such r ghtVof access.and ingress/egress to each of PEG and the State for the purposes
hereof,if and to the extent that such grant may be necessary.Access for ingress/egress to each of PEC and the State for the purposes hereof is
conditioned upon all airport security and access requirements
Exhibits to be attached Prior to Recordinw.
EKHIBrr A-Metes and Bounds Legal Description and/or Survey of Fill Areas
EXHIBIT B-1-Depiction of Fill Areas

IN WITNESS'WHEREOF,Authority and PES have caused this Statement of Structural Fill Facility to be signed in their names,,by each duly
authorized,officer.
OR
piffiRs NSA*
By.-
Name: �tti:+ i�Sr.�krs
Trtie casc��t�8
This tl' . day of 2M Zc t
Carolina Power&iightCompany .
d/b/a Progress Energy Carolinas,Inc::
,Tide: Opftbaft
This -// day of.MA e •293e.?&/3
Notary-era tietriirer�i�orr�az `r. ortr°oil%
stateof .A/Dr ih b SDI is ry, Countyof o rnh[-
on ,T►/(u I S-- a..D( S before me F I f tr-t N /i s 1A1 all personally
appeared,_ I L 0- w 'KJ e i L,, y-'! personalty known tom (or proved tome on the basis of satisfactory evidence)to
be the person(s)whose name(s)Ware subscribed to the within instrument and acknowledged to me that he/she/they executed the same in
his/her/their authorizedcapacity(les)and that by his/her/their signature(s)on the instrumentthe.person(s),or the entity upon behalf ofthe
person(s)acted,executed the instrument WITNESS my hand and official seal.
srgnat ELLEN HEYWOOD
Nditf•PUBLIC.
HENDERSON COUN fl(,.NC
MY CpmmissionFxAiras 5-1o.2 1Q
Notary-Carolina Power&Lieht Comganyd/b/a Progress Enerev Carolinas,Inc.
State of A4094- t 69Re Tina County of ee—WtdLkA
Cm / d before me, i e personally appeared,
q jtX Q n cr2 tis j D tl e i•dub personally known tome(or proved to me on the basis of ifsfactory evidence)to be the
person(s)whose name(s)Ware subscribed to the within instrument and acknowledged to me that he/sre/dW executed the same in
his/her/their authorized capacity(ies),and that by his/her/therrsignature(s)on the instrument the person(s),orthe entity upon behalf ofthe
person(i)acted,exeolted the instrument ESS my hand and official seed.
Signature: J��-r.= — �#p.na�lnayq��4
Q _"'yi•
• t:
r NOTAA .�
s 0,
r

LEGAL DESCRIPTION
'EXHIBIT"A"
All bearings referenced herein are Oased on North Carolina State Plane NAD 83 North.The description is
referenced to monument AVLA located at;the Asheville Regional Airport at State Plane Coordinates N
634827.90 and E 944,33085.
A certain area of land located in (Buncombe County, North Carolina described as follows:
Beginning at a point with North Carolina State Plane Coordinates of N 636,976.20, E 943,396.35;
thence with the following calls: S23"13'53"E a distance of 255.61;thence S25"27'47"E a distance of
226.56;thence S18036'42"E a distance of 197.85';thence S40"14'26"E a distance of 82.77; thence
S22041'58"E a distance of 33.96;thence with a curve turning to the right with an arc length of
54.19',with a radius of. 35.99',with a chord bearing of S20o25'46"W,with,a chord length of 49.21,;.
thence S70"01'43"W a.distance of 178.13;thence S19`45'30"W a distance of 25.08';thence
S24"39'33'%a distance of 63.6.17;khence S23"17'3,V E a distance of 456.62;thence, S67*32'00'E a
distance of 38.01;thence N76048'32"E a distance of 94.49';thence with a curve turning to the
right with an arc length of 45.76 with a radius of 30.91',with a chord bearing of SW47'02"E,with
a chord length of 41.69',;thence Si5'26'24"E a distance of 62.65';thence S01*32'04"W a distance of
101.91%thence S17"48'36"E a distance of 636.80;thence S17°02'56"E a distance of 673.75';thence
S71"50'06"W a distance of 365.53'1 thence N20"16'50"W a distance of 302.73';thence with a curve
turning to the •left with an arc length of 339.76',with a radius of 1191.98',with a chord bearing of
N28°26'46"W,with a chord length�f 338.61',;thence N27"09'29"W a distance of 326.75;thence
N18'36'31"W a distance of 448.57;Ithence N20'30'40"W a distance of 842.68;thence N2639'31"W a
distance of 311.11 thence N1923'�1 O"W a distance of 119.58';thence with a curve turning to the right
with an arc length of 188.92,with a radius of 134.85',with a chord bearing of N20'44'28"E,with a chord
length.of 173.85'„thence N66'48'21'E.a distance of 62.04;thence with a curve turning to the left with
an arc length of 180.08',with a radips of 136.13',with a chord bearing of N28'54'32"E,with a chord
length of 167.23'„thence with a curve turning to the left with an arc length of 336.91',with a radius of
1367.00',with a chord bearing of N06"09'25"W,with a chord length of 336.06',;thence N13013'03"W a
distance of 195.02;thence N64"06'441"E a distance of 123.52'to the point of beginning containing 30.72
acres,more or less.,Area by coordinate computation.

Exhibit"B" \
I
i
560' 0' 500' 11000' \I
P.O.B. I
\. N:M,97620
RUEFM MXwou AMA I
L.r
r I
I S NOTT 8l MM ► G �
LOCAL FOR CAIIPLMM qff
�
APPLICABLE LAND'DEVBDP6EHi
W-GULA1iD1iS. I !�
I � �
LINE BEARING DISTANCE 6
L1 S 231353" E 255.61'
L2 S 25'27'47' E 226.56'
L3 S 18'36'42" E 197.85'
L4 S 40'14*26" E 82.77'
I.
LS S 22'41'58" E 33.96'
f .
L6 S 70'01'43' W 178.13'
L7 S 19'45'30' W 25.08'
LB S :24 39'33" E 636.17' I -
L9 S 2T17'34" E 456662'
LID S 6T32'00" E 38.01'
L11 N 76'48'32' E 94.49'
L12 S 1526*24" E 62.05'
1-13 S 01-32'04' W .101.91'
L14 S 17'48'36' E 636.80'
L15 S 17'02'56" 'E 673.75'
Li S 71'50'06' W 365.53'
L17 N 20'16'50' W 302.73'
3D.72 ACt�S
L1 B N 27'0929.' W 326.75'
1-1,9 N 18'36'31' W 448.57' `O
L20 N 20'30'40' W 842.68' `
L21 N 26'39'31" W 311.11'
L22 N 19'23'40' W 119.58,
L23 N 66'48'21' E 62.04'
L24 N 13*13'03" W 195.02'
L25 N 64.0641' E 123.52'
r
\ �16
CURVE RADIUS ARC LENGTH CHORD LENGTH CHORD BEARING DELTA ANGLE
C1 35.99' 64.19' 49.21' S 20'25'46' W 86'1529"
C2 30.91. 45.76' 41.59' S 60'47'02' E 84'48'51"
C3 1191.98' 339.76' 338.61' N 28'26'46' W 16,19,53" \
C4 134.85' 188.92' 173.85' N 20'44'28" E 80'16'1:6"
C5 " 136.13' 180.08' 167.23' N 28'S4'32' E 75'47'38"
C6 1367.00' 336.91'' 336.D6' N 0509.25 W 14 07 16 �\

Lr17:21 rl1( Y
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
August 14, 2013
John R. Toepfer, P.E.
Duke Energy Progress
410 S.Wilmington Street/PEB14
Raleigh, NC 27601
RE:Asheville Airport-Area 3 Structural Fill Review Comments Addendum
Dear Mr.Toepfer,
The Asheville Regional Office of the Division of Water Resources (DWR) received
additional comments from the central office pertaining to the latest phase (area 3)-of the
Asheville Airport coal ash structural fill project. Please consider this letter an addendum to
the original comments dated August 6, 2013.We offer these additional review comments to
ensure compliance with applicable regulations (15A NCAC 02T.1200) and your permit
(WQ000020) as well as provide further clarification for our review:
1. There is a discrepancy in the details with respect to cover soil thickness of 2' or 4'.
Section "A" on plan sheet 3 - 5.0 has 4' of cover,were as Section"C" on plan sheet 3
- 10.0 has 2' of cover and the CQC spec's in section 4.50 Vegetative Cover reference
24"•
2. Plan sheet 3 - 11.0, detail "B" shows HDPE pipe penetration thru the base liner
system and illustrates boot detail for the 60 mil HDPE and how it is to be
constructed.There is no reference to the geosynthetic clay liner (GCL) or how it is to
be penetrated or repaired;
3. There is a discrepancy in the cap liner thickness. Section"H" on plan sheet 3 - 11.0
indicates 30 mil HDPE,but plan sections on plan sheets 3 - 10.0 "C" and 3 - 5.0 "A"
indicate 40 mil HDPE;
AQUIFER PROTECTION SECTION
North Carolina Division of Water Resources—Asheville Regional Office
2090 U.S.Highway 70,SNannanoa,N.C. 28778-
Phone[phone]
FAX [phone]
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer

Duke Energy Progress
August 14, 2013 .
Page 2 of 2
4. Who/Whom is providing the.overall certification of the project (i.e.grades met with
respect to SHWT/HDPE base liner and cap installed,tested,repaired per plans and
specs, etc.); Please provide the DWR with a copy of the certification information.
S. The plans do not indicate a minimum cover thickness of coal ash over the HDPE
liner, i.e. 3' or 4' of ash minimum under the tracks, for travel across the cell(s);
6. It would be desirable to have either the geo-composite run completely under the
washed 57 stone column and 8" HDPE leachate pipe or have a rub sheet under the
stone column/pipe for protection of the HDPE (in conjunction with the 12oz
geotextile fabric).This is the most critical area of the liner system and if caution is
not taken during placement of coal ash in this area, damage to the base liner can
occur if sudden stops or turns of tracked equipment take place during the initial lift
of ash across the cell(s);
7. Will the contractor (or liner sub) be required to submit a GCL panel layout drawing
prior to installation for approval by the design engineer?;
8. Will the contractor (or liner sub) be required to submit a HDPE panel
layout/seaming drawing for the base liner system prior to installation for approval
by the design engineer?;
9. Will the contractor (or liner sub) be required'to submit an as-built drawing of the
HDPE base liner and HDPE cap liner indicating locations of test samples, seam
repairs and type of membrane repairs made to the panels (i.e. extrusion spot weld,
pinhole repair,intersection of panels extrusion weld, etc.)?.
Please contact me if you have any questions regarding our review comments. I can
be reached at [phone] or [e-mail].
Sincerely,
i9
Br tt Lave ty
Ashevi�p Regional Office
Agttifer Protection Section
Cc: Jon Risgaard-DWR Central Office APS

1
MCSEO"WR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E, Skvarla, III
Governor Director Secretary
August 6, 2013
John R.Toepfer, P.E.
Duke Energy Progress
410 S. Wilmington Street/PEB14
Raleigh, NC 27601
RE:Asheville Airport—Area 3 Structural Fill Comments
Dear Mr.Toepfer,
The Asheville Regional Office of the Division of Water Resources (DWR) has completed a
review of the hydrologic report and construction plans pertaining to the latest phase (area 3) of the
Asheville Airport coal ash structural fill project. We offer the following review comments to ensure
compliance with applicable regulations (15A NCAC 02T .1200) and your permit (WQ000020) as well
as provide further clarification for our review:
1. According to 15A NCAC 02T .1204 (d), information shall be provided to the Division that
describes and explains site-specific engineering or institutional controls proposed to prevent
adverse impacts to public health and the environment. Please submit a project narrative or
summary that addresses the estimated ash volume, project timeline, proposed uses for the
project, conceptual design of the landfill, measures to prevent impacts to public health and
the environment, proposed groundwater monitoring plan, and protection measures to be
implemented between the closure of the fill and further development of the site and.
2. Upon reviewing the engineering plans, it is not clear, particularly in the cross sections,
whether the cap design includes an HDPE liner over the entire structural fill. Please provide
clarification.
3. The hydrologic report on page 12 states, "groundwater was present within about 1 foot of
the ground surface in Borings B-14 and B-16. The cross-section A-A on plans 3-6.0 shows
excavation of the watershed divide in and around B14 and B16. Please explain how the 2
foot vertical separation between the base of structural fill and the seasonal high water table
will be met as required in 15A NCAC 02T .1206 and please specifically address the
observation of groundwater within 1 foot of the surface in B-14 and B-16.
Y
AQUIFER PROTECTION SECTION
North Carolina Division of Water Resources—Asheville Regional Office
2090 U,S,Highway 70,Swannanoa.N.C. 28778
Phone[phone]
FAX [phone]
Internet h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer

Duke Energy Progress—Ashevllle Airport
August 6,2013
Page 2 of 3,
4. Upon reviewing the groundwater modeling results, it was observed that the 90%
concentration calculated for many analytes is higher at the compliance boundary than at
the review boundary which is closer to the CCB source. Please provide an explanation for
this discrepancy.
5. The groundwater model assumes a depth to groundwater of 8 feet below land surface. Yet
table 3 in the hydrologic report indicates at least 4 areas (borings) where the water table is
less than 8 feet below the land surface, How does this affect the modeling results?
6. Thallium was present at monitoring well W6 at a concentration above the applicable
standard. Please provide an explanation of this result,
7. Please be aware that 15A NCAC 02T ,1204 (f) requires the permitte to comply with the
provisions of 15A NCAC 02L.0107.
,4.
8. Please be aware that 15A NCAC 02T .1208 requires an operation and maintenance plan.
Please include information describing how the •structural fill and liner system will be
protected during future development activities at the site. Additionally, please provide a
plan that will allow DWR to track the maintenance of the fill prior to and during final
development (e.g., installation of runway).
9. Please provide specific information that satisfies compliance with 15A NCAC 02L .0107 (f).
According to the rule, if the permittee is not the owner of the land within the compliance
boundary then the current owner will be required to execute and file in the register of
Deeds in the county in which the land is located, an easement running with the land which
contains:
• either a notice of the permit, including the permit number, a description of the type
of permit,•address and telephone number of the permitting agency; or a reference
I to a notice of the permit with book and page number of its recordation if such
notice is required to be filed by the statute.
• prohibits the construction and operation of water supply wells within the
compliance boundary; and
6 reserves the right to the permittee and the State to enter on such property within
t
the compliance boundary for groundwater monitoring and remedlation purposes.
10. The engineering plans (3-2.0) state, "research of well records indicates that there are no
public or private water supply wells within 100 feet of the proposed CCB waste boundary."
According to 15A NCAC 02T.1204(d), site plans or maps shall be provided to the Division by
the applicant depicting the location, orientation, and relationship of the CCPs use site's
features including: the location of all wells (including usage and construction details if

1
Duke Energy Progress—Asheville Airport
August 6,2013
Page 3 of 3,
available), within 500 feet of the CCPs use boundary. You need to submit well receptor
survey that satisfies the conditions of this rule.
11. The engineering plans identify monitoring well MW-1 as a possible background well. This
monitoring well will be located down gradient from structural fill and therefore not
acceptable to represent background water quality. You may elect to choose a more
appropriate up gradient location or utilize existing background wells associated with
structural fill areas 1 and 4.
12, The DWR would request that monitoring wells MW-3, MW-4 and MW-6 be relocated. The
preferred areas will be discussed with Duke Energy Progress at the upcoming site meeting.
13. All monitoring wells should be developed to bedrock refusal (i.e., screened within the
transition zone) and have an adequate supply of water for sampling. Monitoring well
construction should adhere to rules outlined in 15A NCACA 01' .0108.
14. It appears that a leachate collection system is incorporated into the structural fill design.
Please provide detailed information on how the CCB leachate (and contact water) will be
collected and disposed of during and after construction.
15. Please submit a list of project personnel and their contact information.
I look forward to meeting with you at the project site on August 15, 2013. Please contact me
if you have any questions regarding our review comments. I can be reached at [phone] or
[e-mail].
I
Sincerely,
4BrettL
Asheville Regional Office
Aquifer Protection Section

I
E NCDENR
? North Carolina Department of EWater nvironment and Natural Resources
Division of -Quality
Pat McCrory Charles Wakiid,'P;E, John.E. Skvarla, III
Governor Director Secretary
February 22, 2013
DWQ#: 07-1841 v5
i
Buncombe County
Asheville Regional Airport Authority i
Attn: Mr, Lew Bleiweis, Airport Director
61 Terminal Drive,Suite 1
Fletcher, NC 287-32
i
Subject: APPROVAL of 401 Water Quality Certification with Additional Conditions— i
MODIFICATION -
Asheville Airport Runway Rehabilitation Parallel Taxiway and Cargo Hold
Expansion (West) t
USACE Action ID. No. SAW-2010-00036
Dear Mr. Bieiweis: r
i
i
Attached hereto'iis a copy of Certification No. 3753 issued to Mr. Lew Bleiweis and Asheville
Regional Airport Authority, dated'February 19, 2013. This Certification replaces the
Certification issued to you on October 27, 2011 and February 19, 2013. In addition, you
should get any other federal', state or local permits,before you go ahead with your project
including(but not limited to) NPDES Stormwater Permit, Solid Waste,Sediment and Erosion i
Control, Dam Safety, Non-discharge and Water Supply Watershed regulations.
This Certification can be contested as provided'in Articles 3 and 4 of General Statute 150B by
filing a written petition for an administrative hearing to the'Office of Administrative Hearings.
You may obtain a petition form from the Office of Administrative Hearings at
http://www.ncoah.com/or call [phone] for information.
i
Within sixty(60)calendar days of receipt of this Certification, you must file the petition with the }
Office of Administrative Hearings. A petition is considered filed when the original and one (1) j
copy is received in the Office.of Administrative Hearings during normal office hours (Monday
through Friday between 8:0-0am and 5:00pm, excluding official state holidays).
I
t
r
The petition may be.faxed to the Office of Administrative Hearings at [phone], provided i
the original and one copy of the petition is received by the Office of Administrative Hearings-
within five (5) business days following the faxed transmission.
Wetlands,Buffers,Stonnwater—Compliance and Permitting(Webscape)Unit One
'1650 Detail Service Center,Raleigh,Norih Carolina 27699-1650
Location:512 N.Salisbury St.Raleigh,North Carolina 27604 1`t oI" �arolil`a
Phone:[phone] FAX:[phone]_�Customer Service:l•877-623-6748
intcrnet.a,."v.ncwaterquality.org

w
Asheville AirportRunway Rehabilitation Parallel
Taxiway and Cargo Hold Expansion(West)
Page 2 of 8
�., February 22,2013'
Mailing address for the Office of Administrative H"eari"ngs.
Office of Administrative Hearings
6714'Mail Service Center
Raleigh, NC 27699-6714
i
One (1)copy of the,petition must also be served to DENR
Lacy;Presnell, General Counsel
i
Department.of Environment and Natural Resources
1601 Mail Service Center
Raleigh, NC 27699-1601
Unless such a petition is filed,this Certification,shall be final and binding.
e
If we can be of further assistance, do not hesitate to contact us. l
i
i
Sincerely,
. i
Karen,Higgins,Supervisor z
W.etlan.ds;,Buffers, Stormwater—
Compliance&.Permitting Unit I
cc: Jeff Garnett, EPA,Sam Nunn Federal Center, 61 Forsyth Street SW,Atlanta, GA 30303
R. Clement Riddle, CEC, 224 South Grove Street, Suite F, Hendersonville, NC 28792(via Woo i
Tasha McCormick, U.S, Army Corps of Engineers, Asheville.Regulatory Field Office A
DWQ ARO 401 files
File,Copy
i
Filename:071841v5AshevilleAirportExpansion(Buncombe)401 ICA=
i
t

Asheville Airport nunway Rehabilitation Parallel
Taxiway and Cargo Hold Expansion(West)
Page 3 of 8
February 22,2013
NORTH CAROLINA 401 WATER QUALITY CERTIFICATION
THIS CERTIFICATION is issued in conformity with the requirements of Section 401 Public Laws 92-
500 and 95-217 of the United States and subject to the North Carolina Division of Water Quality
(Division)Regulations in 15 NCAC 02H :0500,to,Mr. Lew Bleiweis and--Asheville Regional Airport
Authority,who have authorization,to place fill within or otherwise impact 0:9 acres of
404/wetland and 1,796 linear feet of stream, as described within your application received by the
N.C. Division of Water Quality(Division) on June 14, 2011, by Public Notice issued by the USACE
on June 24, 2011 and received by the-DWQ_on June 24=.2011,and-by additional information
received on August 30, 2011, September 15, 2011,January 4, 2013 and February 11, 2013.
3
The application and supporting documentation provides adequate assurance that the proposed
work will not result in a violation of applicable Water Quality Standards and discharge
guidelines. Therefore,the State of North Carolina certifies that this activity will not violate the '
applicable portions of Sections 301, 302, 303, 306, 307 of PL 9;2-500 and PL 95-217 if conducted
in accordance with the application,the supporting documentation, and conditions hereinafter
set forth.
This approval is for the purpose and design that you described,in your application and as ;
described in.the Public Notice. If you change your project,you must notify us and you may be
required to send us a new application. If the property,is sold,.the new owner must be given a
copy of this Certification and approval_ letter and.is thereby responsible for complying with all
conditions. Any new owner must notify the Division and request the Certification be issued in
their name. If total fills for this project (now or in the future)exceed one acre of wetland or
150 Linear feet of stream, compensatory mitigation may be required as described in 15A_NCAC
02H .0506 (h). This approval requires.you to follow-the conditons,listed in the certification
below..
Conditions of Certification:
1. Impacts Approved
The following impacts are hereby approved as.long as all of the other specific and general
conditions of this Certification (or Isolated Wetland Permit) are met. No other impacts are
approved including incidental impacts:
Type of Impact Amount Approved(Units) Plan Location or Reference
404/Wetland 0.9 (acres) - Application
Stream 1,796 (linear feet) Application,
2. Compensatory Mitigation
Mitigation must be provided for the impacts as specified in the table below. We understand
that you wish to make payment to the Wetland and.Stream Restoration Funds administered
by the NC Ecosystem Enhancement Program (EEP) and to the Wash Creek Mitigation Bank
to meet this mitigation requirement. This has been determined by the Division to be a

Asheville Airport Runway Rehabilitation Parallel
Taxiway and Cargo Hold Expansion(West)
Page 4.of 8
February 22,2013
suitable method to meet the mitigation requirement. Until EEP and Wash Creek
Mitigation Bank receives and clears your check, no impacts specified in this Certification
shall occur.
For accounting purposes,this Certification authorizes payment into the Wetland and
Stream Restoration Funds and to Wash Creek Mitigation Bank to meet the following
compensatory mitigation requirement:
Type of Impact Compensatory Mitigation Required River and Sub-basin
Number
Phase#1—Cargo Area
404/Wetlands— 0 (acres) French
riparian Bro6d/06010105
Stream 1,225 (Linear feet) French
(perennial) Broad/06010105
i
Phase#2—Parallel Taxiway
f
404/Wetlands— 1.259 (acres) [0.359 acres was mitigated for in French
riparian Version 1,therefore 0.9 acres is required] Broad/06010105
Stream 571 (linear feet) [174 linear feet from EEP; French
(perennial) 397 linear feet from Wash Creek Mitigation Broad/06010105
Bank]
f
3. Stormwater Management j
Before any permanent impervious surface (i.e., building, roadway,taxiway;tarmac or other
similar surface) is installed as part of any phase of the project described in this certification,
the applicant must meet all of the following:
• The Stormwater. Management Plan (SMP) must be approved in writing by the City of
Asheville. A copy of the approval letter and approved SMP must be submitted to the
Division prior to installation of any impervious surface within the project site. If the
project is phased,then the approved SMP'for each phase must be submitted to the
Division prior to"installation of any impervious surfaces associated with that phase.
• The approved stormwater best management practices (BMPs).must be constructed
and operational before any permanent building or other structure is occupied or
becomes operational. If the project is phased,then the approved BMPs for each
future phase must be constructed and operational before any permanent building or
other structure associated with that phase is occupied or becomes operational.
• The approved SMP, phased or otherwise, as well as drainage patterns must be
maintained in perpetuity.
• The SMP may not be modified without prior written authorization from the SMP
approval authority.

Asheville Ali pui L Runway Rehabilitation Parallel
Taxiway and Cargo Hold Expansion(West)
Page S of 8
February 22,2013
4. Sediment and Erosion Control : -
Erosion and sediment control practices must be in full compliance with all specifications
governing the proper design;installation and operation and maintenance of'such Best
Management Practices and if applicable,.comply With the specific conditions and
requirements of the NPDES Construction,Stoemwater,Permit,issued to the site:
a. Design, installation, operation, and maintenance of the sediment and erosion
control measures must be such that they equal or exceed the requirements specified
in the most recent version of the North-Carolina Sediment and Erosion Control
Manual. The devices shall be maintained on all construction sites,'borrow sites, and ti
waste pile(spoil)projects, including contractor owned or leased borrow pits
associated with the project.. ?r
b. For borrow pit sites, the erosion and sediment control measures must be designed,
installed; operated, and maintained in accordance with the most recent version of
the North Carolina Surface Mining�Manual..
c. Reclamation measures and implementation must comply with the reclamation in
accordance with the requirements of the Sedimentation Pollution Control Act and
the Mining Act of 1971.
}
d. Sufficient materials required for.stabilization and/or,repair of erosion control
measures and stormwater routing and treatment,shall be on site at all times.
5. No waste,spoil, solids,or fill of any kind sha,l,l,occu.r in wetlands, waters, or riparian areas R
beyond,the footprint of the impacts depicted in the 404/401Permit Application. All
construction activities, including the design, installation, operation, and maintenance of
sediment and erosion control Best Management Practices, shall be performed so that no
violations of state water quality standards, statutes, or rules occur. Approved plans and
specifications for this project are incorporated by reference.and_ are enforceable parts of
this.permit.
6. Sediment and erosion control measures shall not be placed in wetlands or waters.
Exceptions to this condition require application submlttal.,to and written approval by the
Division. If placement of sediment and erosion control devices in wetlands and waters is y
unavoidable,then design and placement of temporary erosion control measures shall not
be conducted in a manner that may result in,dis-equilibrium of wetlands,stream beds, or
banks, adjacent to or upstream and downstream of the above structures. All sediment and {
erosion control devices shall be removed and the naturalgrade restored within two (2)
months of the date,that the Division of Land,Resources (DLR)or locally delegated program
has released the specific area within the project.
7. Construction Stormwater Permit NCG010000
An NPDES Construction Stormwater Permit is required for construction projects that disturb
one (1) or more acres of land. This Permit allows stormwater to be discharged during land

Asheville Airport rtunway Rehabilitation Parallel
Taxiway and Cargo Hold Expansion(West)
Page 6 of 8
February 22,2013
disturbing construction activities as stipulated in the conditions of the permit: If your
project is covered by this permit, full compliance with permit conditions including the
erosion&sedimentation control plan, inspections and maintenance,self-monitoring, record
keeping and reporting requirements is required.. A copy of4he general permit
(NCG010000), inspection log sheets, and other information may be found at
http:lZportal.ncdenr.org/web/­wci/­ws/su/"npdessw,#tab-w.
t
8. Culvert Installation
All work in or adjacent to stream waters shall be conducted in a dry work area. Approved
BMP measures from the most current version of NCDQT Construction and Maintenance
Activities manual --
(httpa%www.ncdot.org/doh/operations/BMP manual/download/BMP Manual.pdf).
such as sandbags, rock berms, cofferdams and other diversion structures shall be used to
prevent excavation in flowing water.
i
Culverts required for this project shall be installed in such a`manner that the original stream
profiles are not altered. Existing stream dimensions (including the cross section dimensions,
pattern, and longitudinal profile) must be maintained above and below locations of each
culvert. Culverts shall be designed and installed to allow for aquatic life movement as well as
to prevent head cutting of the streams. If any of the existing pipes are or become perched,
the appropriate stream grade'shall be re-establi"s6ed`or, if the pipes installed in a perched I
manner, the pipes shall be removed and re-installed correctly.
Culvert(s) shall not be installed in such a manner that will cause aggradation or erosion of the
stream up or down stream of the culvert(s). Existing stream`dimensions (including the cross
section dimensions, pattern and longitudinal profile)shall be maintained above and below
locations of each'culvert.
i
Placement of culverts and other structures in waters,,streams, and wetlands must be placed
below the elevation of the streambed by one foot for all culverts with a diameter greater than
48 inches, and 20 percent of the culvert diameter for culverts having a diameter less than 48
inches,to allow low flow passage of water and aquatic life. Design and placement of culverts
and other structures including temporary erosion control measures shall not be conducted in
a manner that may result in dis-equilibrium of wetlands or streambeds or banks, adjacent to
or upstream and down stream of the above structures. The applicant is required to provide
evidence that the equilibrium shall be maintained if requested in writing by DWQ.
The establishment of native,woody vegetation and other soft stream bank stabilization t
techniques must be used where practicable instead of rip rap or other bank hardening
methods. If rip-rap is necessary, it shall not be placed in the stream bed, unless specifically
approved by the Division of Water Quality.. i
Installation of culverts in wetlands must ensure continuity of water movement and be
designed to adequately accommodate high water or flood conditions.

Asheville A,�Nun t Runway Rehabilitation Parallel
Taxiway and Cargo Hold Expansion(West)
Page 7 of 8
February 22,2013
9. Protective Fencing
The outside buffer, wetland or water boundary and along the construction corridor within
these boundaries approved under this authorization shall.be clearly marked with orange
warning fencing(or similar.high-visibility material) for the areas that have been approved to
infringe within the buffer;"wetland or water"prior to any land disturbing activities.
I
10. Continuing Compliance
Mr. Lew Bleiweis and Asheville Regional Airport Authority shall conduct construction activities
in a manner consistent with State water quality`standards (including any requirements
resulting from compliance with..sectio.n 303(.d);,.of Ae,_Clean_Water.Act)and any other__
appropriate requirements of State law and federal law. If the Division determines that such
standards or laws are not being met(including the failure to sustain a designated or achieved 3
use) or that State or federal law is being violated, or that further conditions are necessary to
assure compliance,the Division may reevaluate and modify this Certification to include
conditions appropriate to assure compliance with such standards and requirements in
accordance with 15A NCAC 02H .0507(d). Before modifying the Certification,the Division
shall notify Mr. Lew Bleiweis and Asheville Regional,Airport Authority and the U.S. Army Corps
t
of Engineers, provide public notice in accordance with 15A NCAC 02H .0503 and provide i
opportunity foe public hearing haccordance with 15A NCAC 02H .0504. Any new or revised
conditions shall be provided to Mr. Lew Bleiweis and Asheville Regional Airport Authority in
writing, shall be provided to the U.S. Army Corps of Engineers for reference in any Permit
issued pursuant to Section 404 of the Clean Water Act, and shall also become conditions of i
the.404 Permit for the project.
i
1.1. Deed Notifications
Deed notifications or,similar mechanisms shall be placed on all retained jurisdictional
wetlands, waters and protective buffers in order to assure compliance for future wetland,
water and buffer impact. These mechanisms shall be put in place at the time of recording of
the property, or of individual lots, whichever is appropriate.A sample deed notification can
be downloaded from the Wetlands, Buffers, Stormwater, Compliance and Permitting Unit
web site at: http: (pottal.ncdenr.brglweblwg/swp/`­ws/­4011,certsandpermitslapplvyforms.
The text of the sample deed notification may be modified as appropriate to suit to this
project.
12.The applicant and/or authorized agent shall provide a completed Certificate of Completion
Form to the DWQ Webscape Unit within ten days of project completion (available at:
http://portal.ncdenr.org/web/wgLswp/ws/401/certsandpermits/apply/forms),
13.This certification grants permission to the director, an authorized representative of the
Director,or DENR staff, upon the presentation of proper,credentials,to enter the property
during normal business hours.
i

° f Asheville Airy,—,.unway Rehabilitation Parallel
Taxiway and Cargo Hold Expansion(West)
Page 8 of 8
February22,2013
This approval to proceed with your proposed impacts or to conduct impacts to waters as
depicted in your application-shall expire upon expiration of the 404 or CAMA Permit.
This•the:220 day of February 2013
DIVISION.OF;WATER QUALITY
1-114Wr k- JI
i
CharlesWakild; R.E.
CW/kah/ijm
3753
I
i
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4

Compliance Inspection Report
Permit: WQ0000020 Effective: 02/17/06 Expiration: 02/28/15 Owner: Progress Energy Carolinas Inc
SOC: Effective: Expiration: Facility: Progress Energy Ash Distribution Program
County: Unknown PO Box 1551
Region: Asheville
Contact Person: Paula J Sims Title: Vice President-Fossil Ge Phone:
Directions to Facility:
From Interstate 26 East take the Long Shoals Rd. Exit. Turn left onto Long Shoals Rd.and go approximately 1 mile to facility entrance
on the right.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 09/25/2012 Entry Time: 10:00 AM Exit Time: 11:30 AM
Primary Inspector: Edward M Williams Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503 exempt)
Facility Status: ❑ Compliant Q Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Sampling
Storage Transport
(See attachment summary)
e
Page: 1

Permit: WQ0000020 Owner-Facility: Progress Energy Carolinas Inc
Inspection Date: 09/25/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WQ0000020 Owner-Facility: Progress Energy Carolinas Inc
Inspection Date: 09/25/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required? ❑ ❑ ❑ ❑
Are GW samples from all MWs sampled for all required parameters? ❑ ❑ ❑ ❑
Are there any GW quality violations? ❑ ❑ ❑ ❑
Is GW-59A certification form completed for facility? ❑ ❑ ❑ ❑
Is a copy of current permit on-site? a ❑ ❑ ❑
Are current metals and nutrient analysis available? 10 ❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters? ❑ ❑ ❑ ❑
a. TCLP analysis? a ❑ ❑ ❑
b. SSFA(Standard Soil Fertility Analysis)? 9 ❑ ❑ ❑
Are PAN balances being maintained? ❑ ❑ ❑ ❑
Are PAN balances within permit limits? ❑ ❑ ❑ ❑
Has land application equipment been calibrated? ❑ ❑ ❑ ❑
Are there pH records for alkaline stabilization? ❑ ❑ ❑ ❑
Are there pH records for the land application site? ❑ ❑ ❑ ❑
Are nutrient/crop removal practices in place? ❑ ❑ ❑ ❑
Do lab sheets support data reported on Residual Analysis Summary? 9 ❑ ❑ ❑
Are hauling records available? T❑ ❑ ❑
Are hauling records maintained and up-to-date? ET ❑ ❑ ❑
#Has permittee been free of public complaints in last 12 months? G_e_Q_('RaC'Q.� ❑ ❑ ❑ ❑
Has application occurred during Seasonal Restriction window? ❑ ❑ ❑ ❑
Comment:
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion ❑
Anaerobic Digestion ❑
Alkaline Pasteurization(Class A) ❑
Alkaline Stabilization (Class B) ❑
Compost ❑
Drying Beds ❑
Page: 3

Permit: WQ0000020 Owner-Facility: Progress Energy Carolinas Inc
Inspection Date: 09/25/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Other Cl
Comment:
Sampling Yes No NA NE
Describe am ling: \Q GJ Cdb� 5 dS` Itg
Aee
Is sampling adequate. -2 El n
Is sampling representative? Cl ❑ ❑
Comment:
Transport Yes No NA NE
Is a copy of the permit in the transport vehicle? p . D C) n 13
(1
Is a copy of the spill control plan in the vehicle? ❑ C1 0 11
Is the spill control plan satisfactory? ❑ Q ❑ ❑
Does transport vehicle appear to be maintained? 0 ❑ Cl 0
Comment:
Page: 4

Annual Report Review Class A Distribution
1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
• Was a certification form submitted? " �es
• Was distribution conducted during the reported year? 405
• How many dry tons were distributed?
• Were the distributions within the permitted amount? Q5
• Were recipients information listed? 2 S
• Did it indicate compliance? �Qg
• Was form complete? -kc 5
• Was it signed by the appropriate people? �@ S
2. Monitoring
• Were the analyses conducted at the required frequency? AeS
• Were the metals analyses reported on the Residual.Sampling Summary Form? ley
• Were the results reported in mg/kg? -j2 5
• Were the metals within ceiling concentration permit limits? b P ✓�; p Vie-I S
• Were the metals within monthly average concentration permit limits. 0
• If no,were the lab analyses attached? `(¢5
C�•Jdv� 1�`M�Ts .
• Were all the required parameters tested? it 5
• Was TCLP analysis conducted? ` #_S
• Were the TCLP contaminants within regulatory limits?
3. Pathogen and Vector Attraction Reduction A
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted?
• Did the form indicate the period of coverage,the residual class,and the pathogen reduction alternative and the
vector attraction reduction option used?
• Was the appropriate documentation to show pathogen and vector attraction reduction included in the report?
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503 or 2T?
4. General
• Was the report in the proper format? \(a S
• Were any parts of the annual report missing? Y.t 5,
• Was the report submitted on time? S

AA
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
Aquifer Protection Section
January 17, 2012
Alan Madewell
Senior Environmental Technical Specialist
Environmental Services
Progress Energy Carolinas, Inc.
410 S. Wilmington Street, PEB 4A
Raleigh, NC 27601
RE: Ash Distribution Program Permit No. WQ0000020
Asheville Airport Structural Fill Project—Phase II of Area IV
Buncombe County
Dear Mr. Madewell,
On October 3, 3011, the Division of Water Quality's Asheville Regional Office requested
additional information concerning Phase II of Area IV structural fill project at the Asheville
Airport in Buncombe County. The Division acknowledges receiving the requested information
(December 1, 2011) which includes a project narrative, environmental impact statement,
verification of regulatory setbacks and the proposed "clean closure" of the City of Asheville's
gun range in early 2012. This satisfies the informational requirements as outlined in 15A NCAC
02T .1204 (d).
Progress Energy Carolinas (PEC) proposes to sample and monitor the Area IV structural
fill project with a groundwater monitoring well network comprised of MW-1, MW-+2, MW-5,
MW6, MW7 and MW-9. The Division initially objected to the location of the background well
(MW-1 due to its location down gradient from the structural fill project. The alternative
' ocation you proposed for the background well (MW-IA) is further to the east and slightly up
gradient from the coal ash. This is an acceptable location for a background well.
One
AQUIFER PROTECTION SECTION—Asheville Regional Office(ARO) NorthCarohna
2090 U.S.70 Highway,Swannanoa,NC 28778-8211 )Vatumllff
Phone:[phone]\FAX:[phone]
Internet:www.ncwaterouality.org
An Equal Opportunity\Affirmative Action Employer

Page 2 of 2
One issue the Division finds problematic is the well depths for MW1, MW2, MWS, MW6
and MW7. According to Tim Silar of Silar Services Incorporated, these monitoring wells were
constructed primarily to monitor aquifer conditions in the upper regolith and do not fully
penetrate to the top of consolidated bedrock. The lower regolith or "transition zone" is an
important conduit for contaminant transport in the Blue Ridge and Piedmont Provinces.
Incomplete weathering in the lower regolith can create a zone of higher permeability and
increase groundwater flow along the interface with consolidated bedrock. It is the opinion of
the Division that the lower regolith or "transition zone" zone needs better representation in
your current monitoring well network. A meeting or conference call may be necessary to
resolve this issue.
If you should have any questions, please do not hesitate to contact me directly at (828)
296—4500 or at [e-mail].
Sincerely,
Brett Laverty
Hydrogeologist
Aquifer Protection Section
Asheville Regional Office
Cc: John Toepfer—Progress Energy Carolinas
Garry Whisnant—Progress Energy Carolinas
Laurie Moorhead—Progress Energy Carolinas
Michael Reisman—Asheville Regional Airport

C� Progress Energy -__- I L ill �-� �_
g gY
..
i �
E'�.r C 2 2ii a a ;
December 1,2011 q ( q
n;Fi
Mr.,Brett Laverty --
Hydrogeologist
North Carolina Department of Environment and Natural Resources
Asheville Regional Office
2090 U.S.70 Highway
Swannanoa, NC 28778-8211
RE: Asheville Structural Fill Project
Asheville Airport—Area IV
Carolina Power&Light Company d/b/a Progress Energy Carolinas, Inc.
Ash Distribution Program Permit No.WQ0000020
Dear Mr. Laverty:
Carolina Power & Light Company d/b/a Progress Energy Carolinas, Inc. (PEC) received your letter
dated October 3, 2011 which requested certain information regarding Phase II of Area IV structural
fill at the Asheville Airport. This letter responds to that request(DENR request in italics):
1. According to 15A NCAC 02T.1204 (d), information shall be provided to the Division of
Water Quality that describes and explains site-specific engineering or institutional controls
proposed to prevent adverse impacts to public health and the environment. Submit a
project narrative for Phase 11 that includes a general overview, timeline,footprint(acreage),
environmental impact statement and completed Phase 11 engineering construction plans.
Please note the Division (APS) would like the opportunity to review and comment on the
Phase 11 construction design.
The Asheville Airport Area IV structural fill project is divided into three distinct phases, Phase I,
Phase IA and Phase II. The overall fill footprint totals approximately 52.9 acres and will contain
more than 2 million cubic yards of coal combustion byproducts(fly ash and bottom ash). Phase
II itself is approximately 22.7 acres in size and will accommodate approximately 1.1 million tons
of coal combustion byproducts as fill (-777,000 cubic yards).
Phase I/IA is anticipated to be complete by May 2012. Construction of Phase II improvements
will begin in late 2011/early 2012 with coal combustion byproducts placement beginning in late
February 2012. Coal combustion byproducts placement in Phase II will continue to project
completion anticipated in July 2013.
The project design for Phase II is the same as incorporated into Phase I/IA. There will be a 60 mil
HDPE geomembrane used as a liner beneath the coal combustion byproducts fill. Above the
liner is a leachate collection system. The coal combustion byproducts fill will be covered by a 30
mil HDPE geomembrane and then by native soils ranging from 2 feet thick on sideslopes to 6
feet thick in flat areas.
Progress Energy Service Company,LLC
P.O.Box 1551
Raleigh,NC 27602

DENR ARO
December 1,2011
The enclosed compact disc contains the Environmental Assessment(EA)completed by the Asheville
Airport and the Phase II engineering construction plans. Also enclosed are two hard copies of the
Phase II engineering construction plans per your request.
2. Verify that the Phase 11 meets all applicable setbacks established in 15A NCAC 02T.1206.
These include setbacks from water supply wells streams (including those culverted), and
seasonal high water table.
All setbacks have been met. Please see the enclosed Hydrogeologic Assessment Report Asheville
Regional Airport Area IV completed by Silar Services, Inc. along with the engineering construction
plans for setbacks from the seasonal high groundwater table. The Airport has completed the
necessary permitting to take small areas of wetlands & streams within Phase II. There will be no
culvert as within fill Area I and therefore, no impact to the setback requirements for surface waters.
Please refer to Appendix B & H of the enclosed Environmental Assessment for the permitting
efforts completed by the Airport. The enclosed engineering construction plans show the closest
groundwater well is over 300 feet from the edge of fill for Area IV.
3. Submit a current list of project personnel and their contact information.
Scott Sewell,Vice President of Operations, Charah, Inc.
Phone: [phone]
Email: [e-mail]
Matt Winfree, Regional Manager, Charah, Inc.
Phone: [phone]
Email: [e-mail]
Rob Reynolds,Senior Coal Procurement Agent, PEC
Phone: [phone]
Email: [e-mail]
Laurie Moorhead,Senior Environmental Specialist,Asheville Plant, PEC
Phone: [phone]
Email: [e-mail]
Alan E. Madewell, Manager Environmental Energy Supply Carolinas, PEC
Phone: [phone]
Email: alan.madewell([e-mail]
Michael A. Reisman, Deputy Airport Director, Development&Operations
Phone: [phone]
Email: [e-mail]
4. If soils within the Asheville City gun range are to be disturbed during Phase 11 then an
environmental assessment should be completed prior to construction. The Division is
concerned that lead contamination could be present within the footprint of the gun range.
Contaminated soils are not recommended for use as a cover material. Please provide a
narrative on the condition of the gun range.
2

r
DENR ARO
December 1,2011
The City of Asheville owns the firing range and has agreed to vacate the firing range in early 2012.
The City of Asheville has committed to work through NC DENR to remediate the firing range to
'clean closure'. Please refer to Appendix B of the enclosed Environmental Assessment to a letter
dated March 28,2011 from Jeffrey B. Richardson,Assistant City Manager for the City of Asheville.
PEC will work with Charah and the Airport to ensure no 'impacted' soils are used as cover within
Area IV fill project. Per DENR Inactive Hazardous Sites Branch Preliminary Soil Remediation Goals
Table dated August 2011,the lowest established level for lead is for Protection of Groundwater at
270 mg/kg. No soils with lead concentrations at or above 270 mg/kg will be-used as cover soils in
Area IV fill project.
PEC proposed an alternative location for a background well for Area IV. The attached figure (E-1)
shows the proposed background well location. PEC proposes to install this background well along
with well PMW-9 upon your concurrence. These two wells along with review boundary wells MW-
2, MW-5(formerly known as PZ-4), MW-6 and MW-7 would complete the monitoring well network
for Area IV. The wells will be sampled in April and November for pH, temperature, water level,
specific conductivity, total dissolved solids, antimony, arsenic, barium, boron, cadmium,
chloride, chromium, copper, iron, lead, manganese, mercury, nickel, nitrate, selenium, sulfate,
thallium and zinc.
If you have any questions, please contact Mr.John Toepfer at 919-546-7863.
Sincerely
Alan E. Madewell
Manager—Environmental Energy Supply-Carolinas
AEM:jt
Enc: Compact Disc containing:
• Dept. of Transportation Finding of No Significant Impact(FONSI)/Record of
Decision,August 19, 2011
• Environmental Assessment for Asheville Regional Airport Runway
Reconstruction and New Parallel Taxiway, prepared by The LPA Group,August
2011 (4 pdf files)
• Engineering Construction Plans for Engineered Fill Area IV, Phase II, Franklin S.
Craig, P.E. Consulting Engineer, Issued for Construction September 22,2011, 15
sheets
• Hydrogeologic Assessment Report Asheville Regional Airport Area IV, prepared
by Silar Services, Inc.,April 2011
• Proposed Background Well (Figure E-1)
3

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AND 1A THAT LIE WITHIN THE LIMITS FOR PHASE 2 ARE SCALE: 1"=300'
ABANDONED WITH THE IMPLEMENTATION OF THIS PLAN.
3. GROUNDWATER QUALITY MONITORING SHALL BE ISSUE DATE: JUNE 30, 2011
PERFORMED IN ACCORDANCE WITH PERMIT NO. REVISIONS ❑�
WQW00020 GRANTING PERMISSION FOR THE REUSE OF REVISIONS
COAL COMBUSTION BYPRODUCTS AS ENGINEERED FILL Na Dn7E oEsaT�OoN
-NOT FOR CONSTRUCTION MATERIAL REMsm COMNE
N PURPOSES ONLY s e e 391 OEM BASED ON CLIENT COIIMENTB nEEII

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue. Coleen H. Sullins Dee Freeman
Governor Director Secretary
Aquifer Protection Section
October 3, 2011
Alan Madewell
Senior Environmental Technical Specialist
Environmental Services
Progress Energy Carolinas, Inc.
410 S.Wilmington Street, PEB 4A
Raleigh, NC 27601
RE: Ash Distribution Program Permit No.WQ0000020
Asheville Airport Structural Fill Project—Phase II of Area IV
Buncombe County
Dear Mr. Madewell,
On September 12, 2011,the Division of Water Quality's Asheville Regional Office received notice
that Progress Energy is moving forward with Phase II of Area IV structural fill project at the Asheville
Airport in accordance with your permit(WQ0000020)and 15A NCAC 02T.1200.
Based on our review of the materials submitted,the Division is requiring the following additional
information:
1. According to 15A NCAC 02T .1204 (d), information shall be provided to the Division of Water
Quality that describes and explains site-specific engineering or institutional controls proposed
to prevent adverse impacts to public health and the environment. Submit a project narrative for
Phase II that includes a general overview, timeline, footprint (acreage), environmental impact
statement and completed Phase II engineering construction plans. Please note the Division (APS)
would like the opportunity to review and comment on the phase II construction design.
2. Verify that phase II meets all applicable setbacks established in 15A NCAC 02T .1206. These
include setbacks from water supply wells, streams (including those culverted), and seasonal high
water table.
3. Submit a current list of project personnel and their contact information.
4. If soils within the Asheville City gun range are to be disturbed during phase II then an
environmental assessment should be completed prior to construction.The Division is concerned
that lead contamination could be present within the footprint of the gun range. Contaminated
AQUIFER PROTECTION SECTION—Asheville Regional Office(ARO)
2090 U.S.70 Highway,Swannanoa,NC 28778-8211 One 1.
Phone:[phone] FAX:[phone] NO1t11Carolina
Customer Service:1-877-623-6748
Internet:www.ncwaterguality.or-q
An Equal Opportunity 1 Affirmative Action Employer

soils are not recommended for use as a cover material. Please provide a narrative on the
condition of the gun range.
In your letter, you propose a groundwater monitoring network for the entire structural fill
project.(phases I, IA, and II).The groundwater monitoring network will include wells MW-1, MW-2, MW-
5, MW-6, MW-7 and MW-9. Monitoring wells will be sampled in April and November for the following
parameters:
• pH, temperature, water level, specific conductivity, total dissolved solids, antimony, arsenic,
barium, boron, cadmium, chloride, chromium, copper, iron, lead, manganese, mercury, nickel,
nitrate, selenium, sulfate, thallium, and zinc.
The list of monitoring parameters and frequency is acceptable to the Division but additional monitoring
wells may be required pending a review of the existing wells. The Division is specifically interested in
whether the monitoring wells are fully penetrating to the top of bedrock and screened within the
transition zone. In addition, monitoring well MW-1 is not an acceptable location for a background well
due to its proximity with Phase I of Area IV.You may propose a new background well location, utilize the
background well (MW4) for structural fill Area 1 or delay installation of a well until such time as a
comparative groundwater quality data point becomes necessary.
You also submitted a notarized deed restriction and plat map for structural fill Area IV (Phase I,
IA & II); which states that no water supply wells shall be constructed or operated within the compliance
boundary and that the state has access to the coal ash fill for necessary activities. You also state that the
deed restriction will be amended if the final coal ash tonnage exceeds 1 million tons. This satisfies the
property ownership requirements as outlined in 15A NCAC 02T.1204 (d).
The above-reference information is to be submitted prior to the mobilization of any coal ash
(Phase II). If you should have any questions, please do not hesitate to contact me directly at (828) 296—
4500 or at [e-mail].
Sincerely,
Brett Laverty
Hydrogeologist
Aquifer Protection Section
Asheville Regional Office
Cc: John Toepfer—Progress Energy
Laurie Moorhead—Progress Energy
Michael Reisman—Asheville Regional Airport

&40? Pro ner Progress Energy RE,E0EE V 2 0
­P 12 2W
September 8,2011
Mr.G.Landon Davidson, LG A hevillo- Fl4gional Office
jr
Regional Supervisor Aquifer Protection Section c 11;Q� a "'�Ciity3'9
- -
North Carolina Department of Environment and Natural Resources
Asheville Regional Office
2090 U.S.70 Highway
Swannanoa, NC 28778-8211
RE: Asheville Structural Fill Project
Asheville Airport—Area IV
Carolina Power&Light Company d/b/a Progress Energy Carolinas, Inc.
Ash Distribution Program Permit No.WQ0000020
Dear Mr. Davidson:
Carolina Power & Light Company d/b/a Progress Energy Carolinas, Inc. (PEC) recently decided to
continue forward into Phase II of Area IV structural fill project at the Asheville Airport. During prior
discussions between PEC and the DENR Asheville Regional Office, PEC let it be known that there
could be a lag time between completion of Phase I/IA and initiation of Phase Il: As such, PEC
discussed the possibility of installing groundwater monitoring wells at the review boundary for
Phase I/IA. Due to moving directly into Phase II in spring 2012 when Phase I/IA reaches capacity,
this will not be necessary. Rather, PEC proposes to monitor the groundwater at the review
boundary for the combined Phase I/IA and Phase II structural fill of Area IV.
The enclosed drawing shows the location of existing downgradient wells MW-2, MW-5 (formerly
known as PZ-4), MW-6 and MW-7. PEC proposes to monitor these wells along with well MW-9
(to be installed) to complete the downgradient well location network. Since existing wells MW-
4, MW-8 and MW-3 are not located at the review boundary, PEC proposes to no longer monitor
these wells.
The enclosed drawing shows the airport building restriction line (BLR). Airport regulations
prevent the installation of any feature, including a groundwater monitoring well, within the BLR
zone. These regulations make it extremely difficult to site a true background monitoring well for
the area IV fill project. As such, PEC proposes to monitor existing well MW-1 as the
sidegradient/background well.
PEC proposes to sample and monitor Area IV structural fill wells MW-1, MW-2, MW-5 (formerly
known as PZ-4), MW-6, MW-7 and MW-9 in April and November each year in conjunction with
the four wells around the Area I structural fill at the Asheville Airport. PEC proposes to monitor
the Area IV and Area I wells for the following parameters:
pH, temperature, water level, specific conductivity, total dissolved solids, antimony,
arsenic, barium, boron, cadmium, chloride, chromium, copper, iron, lead, manganese,
mercury, nickel rate,selenium, sulfate,thallium and zinc.
Progress Energy Sery ye
Company,
P.O.Box 1551
Raleigh,NC 27602

DENR ARO
September 8,2011
These parameters are consistent with those parameters that DENR DWQ requires PEC to
monitor around ash ponds. This list would include the addition of antimony, chloride and
thallium and delete nitrite, silver and total organic carbon from the list of parameters that are
now monitored around the fill at Area I.
Enclosed are the groundwater results for the monitoring completed prior to fill activities
beginning in Area IV. Wells PZ-1, PZ-2, PZ-3, PZ-4 (now known as MW-5), MW-1, MW-2 and
MW-3 were sampled in March 2010. These wells were installed in December 2009. Wells PZ-1,
PZ-2 and PZ-3 were abandoned in June 2010 while wells MW-4, MW-6, MW-7 and MW-8 were
installed in July 2010. After concurrence with the agency and installation of MW-9, all boring
logs,well construction records and well abandonment records will be submitted.
Also enclosed is the deed restriction for Area IV(Phases I, IA& II) where coal ash will be used as
fill. The deed restriction estimates the use of 1,000,000 tons. If necessary, the deed restriction
will be amended within 90 days after completion of Phase II if the quantity utilized is materially
different. The deed restriction states that no water supply wells shall be constructed or
operated within the compliance boundary around said coal ash fill and that the State has access
to the coal ash fill for necessary activities.
If you have any questions, please contact Mr.John Toepfer at 919-546-7863.
Sincerely,
Alan E. Madewell
Manager—Environmental Energy Supply-Carolinas
AEM.jt
Enc: Drawing E-1, Rev. 3 dated August 18, 2011
Statement of Structural Fill Facility(Deed Restriction)
March 2010 Groundwater Results
2

STATEMENT OF STRUCTURAL FILL FACILITY
STATE OF NORTH CAROLINA 7KP 12 26111
COUNTY OF BUNCOMBE
Asheville Regional Office
Aquifer ProtectionThe undersigned Asheville Regional Airport Authority(the"Authority"), in acc rdance witithe-pcov-lgle6s of N.C. Gen. Stat. § 130A.294 and 1SA N.C.A.C. 13B.1707, acknowledges that it is a municipal authority originated
and created under the laws of the State of North Carolina for the purpose of maintaining, operating, regulating and
improving the Asheville Regional Airport, including certain real property located in Limestone Township,
Buncombe County,North Carolina.
Authority further acknowledges that coal combustion by-products, specifically ponded ash, will be
beneficially utilized as structural or engineered fill beneath portions of the Property more particularly described on
Exhibit A attached hereto and incorporated herein by reference. The volume of coal combustion by.products so
utilized is estimated to be approximately 1,000,000 tons. If applicable, this Statement of Structural Fill will be
amended within ninety (90) days after completion of the project if the actual volume�bf coal combustion by-
products utilized on the Property is materially different than the volume set forth above.
it is also acknowledged by the undersigned Carolina Power & Light Company d/b/a Progress Energy
Carolinas, Inc. ("PEC"), that the source of the coal combustion by.products was the PEC Asheville Steam Electric
Power Plant. PEC is also the holder of Permit WQ0000020, Distribution of Residual Solids (503 Exempt), issued by
the North Carolina Department of Environment and. Natural Resources, Division of Water Quality, Aquifer
Protection Section(the"Division"),1636 Mail Service Center,Raleigh,NC 27699.1636,[phone].
The Property is considered to be an individually-permitted ash use site by the Division and therefore a
"compliance boundary", as specified by regulations in 15A NCAC 2L (Le., "Groundwater Classifications and
Standards")must be'established at either 250 feet from the ash boundary or 50 feet within the Property boundary,
whichever is closest to the ash boundary. Furthermore, a "review boundary" must be established around the
Property midway between the compliance boundary and the perimeter of the ash boundary.
In accordance with the requirements of 15A N.C.A.C. 13B .1707(d), when real property with more than
1,000 cubic yards of coal combustion byproducts is sold, leased,conveyed or transferred In any manner,the deed
or other instrument of transfer shall contain in the description section in no smaller type than used in the body of
the deed or instrument a statement that coal combustion byproducts have been used as fill material on the
property.No water supply well shall be constructed or operated within the compliance boundary of said fill. PEC and
the State reserve the right to access the compliance boundary of said fill for the purposes of groundwater
monitoring and/or remediation and the Authority hereby expressly grants such right of access and ingress/egress to
each of PEC and the State for the purposes hereof,if and to the extent that such grant may be necessary.

Exhibits to be attached prior to Recording:
EXHIBIT A-Metes and Bounds Legal Description and/or Survey of Fill Areas
EXHIBT B,1.Depiction of Fill Areas
IN WITNESS WHEREOF,Authority and PES have caused this Statement of Structural Fill Facility to be signed in
their names,by each duly authorized officer.
Asheville Regional Airport�Authority
ti
By:
Name:-Lf w 'AL Iwo r t
Title: A vt/aav, V�2�c iti2
This a912 day of 3w4- ,2010
j Notary—Asheville Regional AirportAuthoriW
State of North GnrO I j0 A. Countyof O vnt 0 fn &on_ G4abcr gf, JUN before me, t 11,1i1 qIj Wf pyJ personally appeared,
personally known to me(or proved to me on the basis of satisfactory
evidence)to be the person(s)whose name(s)is/are subscribed to the within Instrument and acknowledged to me that
he/she/they executed the same In his/her/their authorized capacity(les),and that by his/her/their signature(s)on the
Instrument the person(s),or the entity upon behalf of the person(s)acted,executed the instrument.WITNESS my hand and
official seal.
Signature:
F9LLEN HErOOD
NOTARY IC
IKINDERSON� qIr a 5_Q 2D 4

( Carolina Power&Light Company
l d/b/a Progress Energy Carolinas,Inc.:
By:
Alaunde (Sasha) Weintraub
;President- Fuels and Power Optimizatlor
This �'� day of Oc.'to kM- .2010
(Seal)
Notary—Carolina Power&Light Company d/b/a Progress Energy Carolinas Inc
State of NWIW 1r4 IMMA County of 1' AW
On 06VAL'R 7 020/0 .before me, JoAtriA ;-T SEpQs personally appeared,
AWAUN R (.5ASMA) MEMM-AgEt personally known to me(or proved to me on the basis of satisfactory
evidence)to be the person(s)whose name(s)is/are subscribed to the within instrument and acknowledged to me that
he/she/they executed the same In his/her/their authorized capacity(ies),and that by his/her/their signatures)on the
instrument the person(s),or the entity upon behalf of the person(s)acted,executed the instrument.WITNESS my hand and
official seal.
(� Signature:
(Seal) aIV
fP
�rcP�reArioN.SATE,• 8��3�a?a/y '':�� ••••'m
r o..
pa a :�
err. f •tea`�'�`',
'rj��'��ryN1i01111Lt1�ti;'�

P.O. .
N:631,4"'6"
E%5,078.543
C
500, 0' 500' 1,000' REFEREN E MO N UM ENT AVLA Cb
cp
CA
O
OP
0
�a
'AG
AND I AS NOT BEENN REMEUMFIED WEDDBBY
LOCAL GOVERNMENT AGENES) 51.73A ��
CY I CRES.
FOR COMPLIANCE Wf fl
APPLICABLE
LANDIODNS�OPM�
LINE BEARING DISTANCE �Ly
L1 S 35*44'17" E 668.84'
L2 S 23'20'30" E 183.11' �'Pa
( L3 S 18'05'03" E 888.8'4' G' n
L4 S 41'15'34" W 154.05:
L5 S 09'50'33" E 1274.25 90
L6 N 7253'33" E 293.80'
L7 S 21'29'39" E 276.68'
L8 S 18'56'32" E 274.63'
L9 S 78'25'24 W 310.58, C�
L10 N 55'55'50" W 464.46'
1-11 N 2T56'58" W 529.7,V
L12 N 18'08'52" W 259.23' ! o
L13 N 52'51'59" W 165.01' °
L14 N 43'13'06" W 446.37'
L15 N 42718*09" W 616.73' a
L16 N 34'26'48" E 471.85'
L17 N 15'40'08" W 237.08'
L18 N 13'39'27" W 248.79' �q
L19 N 54'41'22" E 74.4,V
CURVE RADIUS ARC LENGTH CHORD LENGTH CHORD BEARING DELTA ANGLE
C1 53.88' 48.77' 47.12' S OT5O'32" W 51'51'34"
C2 23.76' 20.51' 19.88' S 16'31'44" W 49'27'39"
C3 23.23' 31.61' 29.23' S 48'49'58' E 7T58'26"
C4 24.99' 42.24' 37.39' S 58'41'17 E 96'51'07"
C5 136.73' 88.32' 86.79' N 36'39'08" W 3T00'32"
C6 224.01' 306.53' 283.17' N 03'06'04" W 78'24'10
C7 153.75' 141.13' 136.23' N 60'44'38" E 5T35'38"
C8 154.46' 216.65' 199.32' N 46'51'36" E 80'21'49" EXHIBIT "B-1"
C9 197.72' 210.34' 200.56' N 16'49'04 E 60 57'09"

LEGAL DESCRIPTION
EXHIBIT'W
All bearings referenced herein are based on North Carolina State Plane NAD 83 North.The description is
referenced to monument AVLA located at the Asheville Regional Airport at State Plane Coordinates N
634,827.90 and E 944,330.85.
A certain area of land located in Buncombe County,North Carolina described as follows:
Beginning at a point with North Carolina State Plane Coordinates of N 631,425.693, E 945,078.543;
thence with the following calls: S.35°44'17"E. a distance of 668.84';thence S.23020'30"E. a distance of
183.11;thence S.18°05'03"E.a distance of 888.84';thence with a curve turning to the right with an arc
length of 48.76', with a radius of 53.88', with a chord bearing of S.07`50'32"W., with a chord length of
47.12',;thence S.41015'34"W. a distance of 154.05; thence with a curve turning to the left with an arc
length of 20.51', with a radius of 23.76', with a chord bearing of S.16"31'44"W., with a chord length of
19.88',;thence S.09°50'33"E. a distance of 1274.25';thence with a curve turning to the left with an arc
length of 31.62', with a radius of 23.23', with a chord bearing of S.48°49'58"E., with a chord length of
29.23',;thence N.72°53'33"E. a distance of 293.80;thence with a curve turning to the right with an arc
( length of 42.24', with a radius of 24.99', with a chord bearing of S.58"41'17"E., with a chord length of
37.39',; thence S.21°29'39"E. a distance of 276.68'; thence S.18056'32"E. a distance of 274.63; thence
S.78025'24'W.a distance of 310.58';thence N.55°55'50"W.a distance of 464.46;thence N.22056'58"W.
a distance of 529.74; thence N.18°08'52"W. a distance of 259.23'; thence with a curve turning to the
left with an arc length of 88.31,with a radius of 136.73',with a chord bearing of N.36"39'08"W.,with a
chord length of 86.79',;thence N.52051'59"W.a distance of 165.01';thence N.43013'06"W.a distance of
446.37;thence N.42'18'09"W..a distance of 616.73;thence with a curve turning to the right with an arc
length of 306.53,with a radius of 224.01',with a chord bearing of N.03"06'04"W.,with a chord length of
283.17',;thence N.34°26'48"E.a distance of 471.85';thence with a curve turning to the right with an arc
length of 141.13',with a radius of 153.75',with a chord bearing of N.60044'38"E.,with a chord length of
136.23',;thence with a curve turning to the left with an arc length of 216.64', with a radius of 154.46',
with a chord bearing of N.46051'36"E.,with a chord length of 199.32,;thence N.15"40'08"W.a distance
of 237.08;thence N.13'39'27"W. a distance of 248.79';thence with a curve turning to the right with an
arc length of 210.33',with a radius of 197.72,with a chord bearing of N.16049'04"E.,with a chord length
of 200.56',;thence N.54°41'22"E. a distance of 74.44`to the point of beginning containing 51.73 acres,
more or less.Area by coordinate computation.

1 �
SS Table 3
Groundwater Monitoring Analytical Summary-Monitoring Wells
Hydrogeologic Assessment Report
Asheville Airport-Fletcher,North Carolina
NCDENR
2L Standard PZ-1 PZ-2 PZ-3 PZ4 MW-1 MW-2 MW-3
Inorganic Analytes(ug/1) (ug(L)
Arsenic 10 1U I I I lU I I
Barium 700 24 28 17 31 50 33 31
Boron 700 25 U 25 U 25 U 25 U 25 U 25 U 25 U
Cadmium 2 0.1 U 0.1 U 0.1 U 0.1 U 0.1 U 0.17 0.17
Chromium 10 5 U 5 U 5 U 5 U 5 U 5 U_ 5 U
Copper 1000 1 U I U 1 U I U U U U
Iron 300 29 130 20 U 49 94 120 47
Lead 15 lU I I I I I I
Manganese 50 17 79 22 5 U 67 21 18
Nickel 100 5U 5U 5U 5U 5U 5U 5U
Selenium_ 20 1 U l U 1 U 1 U I U l U I U
Silver 20 lU I I I I I I
Zinc 1000 10 U 10 U IOU IOU 19 12 12
Mercury 1 0.1 U 0.1 U 0.1 U 0.1 U 0.1 U 0.1 U 0.1 U
General Chemistry(mg/1)
Nitrate 10 1.5 0.045 0.08 0.53 0.073 0.055 0.06
Nitrite 1 0.02 U 0.02 U 0.02 U 0.02 U 0.022 0.02 U 0.02 U
Sulfate 250 1.7 1 U 1.8 1 U 5.4 1.3 1 U
TDS NA 41 IOU 10 U 12 10 47 IOU
TOC NA 1.3 1.1 1 1 U 1.3 2.2 1 U
Field Parameters _
pH(su) NA 5.11 4.66 4.96 5.41 4.91 4.91 5.05
Conductivity(us/cm) NA 38 19 16 24 34 44 21
Temperature CC) NA 11.14 10.85 12.52 10.32 12.36 10.38 13.03
Notes:
Bold indicated compound detected
ug/L-micrograms per liter
mg/1-milligrams per liter
U-The analyte was not detected at or above the instrument detection limit
NA-Not Applicable
Samples collected in March 2010

_r NONRESIDENTIAL ONRESIDENTIAL WELL CONSTRUCTION RECORD 7
North Carolina Department of Environment and Natural Resources-Division of Rater Quality
WELL CONTRACTOR CERTIFICATION# 2580
1.WELL CONTRACTOR: d. TOP OF CASING IS 2.0 FT.Above Land Surface
JASON MANTAK "Top of casing terminated attar below land surface may require
Well Contractor(Individual)Name
a variance in accordance With 15A NCAC 2C.0118.
GEOLOGIC EXPLORATION, INC. e. YIELD(gpm): N/A METHOD OF TEST N/A
Well Contractor Company Name f. DISINFECTION:Type N/A Amount N/A
STREET ADDRESS 176 COMMERCE BLVD g. WATER ZONES(depth):
STATESVILLE NC 28625 From To From To
City or Town State Zip Code
From Tc From To
70( 4 )_ 872-7686 From To From To
Area code- Phone number 6. CASING: Thickness/
2.WELL INFORMATION: Depth Diam ter WeAt Material
at rial
SITE WELL ID#(if applicable) MW-1 From 0.0 To 20.0 Ft.2 INC
PVC
STATE WELL PERMIT#(if applicable)
From To Ft.
DWQ or OTHER PERMIT#(if applicable) From To Ft.
WELL USE(Check Applicable Box)Monitoring® Municipal/Public❑
7. GROUT: Depth Material Method
Industrial/Commercial❑ Agricultural❑ Recovery❑Injection❑
From 0.0 To 14.0 Ft Portland benlonite SLURRY
Irrigation❑ Other❑ (list use)
From To Ft.
DATE DRILLED 12/08/09 From To Ft.
8. SCREEN: Depth Diameter Slot Size Material
TIME COMPLETED AM❑ PM❑ From 20.0 To 50.0 Ft.2.0 in. .010 in. PVC,—
3.WELL LOCATION: From To Ft. in. in.
CITY: ASHEVILLE COUNTY BUNCOMBE From To—Ft. in. in.
WRIGHT BROTHERS WAY 28732 > 'p
9. SAND/GRAVEL PACK: i
(Street Name,Numbers,Community,Subdivision,Lot No.,Parcel,Zip Code) Depth Size Material ��
TOPOGRAPHIC/LAND SETTING: a '
From 18.0 To 50.0 Ft. 20-40 FINE SILICASgND
❑Slope ❑Valley ❑Flat ❑Ridge El Other m�
(check appropriate box) From To Ft.
LATITUDE May be in degrees, From To Ft.
minutes;seconds or M
LONGITUDE in a decimal format 10.DRILLING LOG t o F a
— — From To Formation Description- 3
Latitude/longitude source: ❑GPS ❑Topographic map 0.0 50.0 BROWN SILTY CLAY "°
(location of well must be shown on a USGS topo map and 3
attached to this form if not using GPS)
4.FACILITY-is the name of the business where the well is located.
FACILITY ID#(if applicable)
NAME OF FACILITY ASHEVILLE AIRPORT
STREET ADDRESS WRIGHT BROTHERS WAY
ASHEVILLE NC 28732 L ( e 9 2609
City or Town State Zip Code
CONTACT PERSON ASHEVILLE REGIONAL AIRPORT'
lnrormrtlon Processinu
MAILING ADDRESS 61 TERMINAL DRIVE
FLETCHER NC 28732 11.REMARKS:
City or Town State Zip Code BENTONITE SEAL FROM:14.0 TO 18.0 FEET
Area code- Phone number
5.WELL DETAILS: too EREBY CERTIFY THAT T IS WAS CONSTRUCTED IN ACCORDANCE WITH
15 CAC 2C,WELL C STR N STANDARDS,AND THAT A COPY OF THIS
a. TOTAL DEPTH: 50.0 FEET R D HAS BE THE WELL OWNER.
12/10/09
b. DOES WELL REPLACE EXISTING WELL? YES❑ NO 91 S NATURE OF CERTIFIED WELL CONTRACTOR DATE
c. WATER LEVEL Below Top of Casing: 22.0 FT. JASON MANTAK
(Use"+"if Above Top of Casing)
PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Submit the original to the Division of Water Quality within 30 days. Attn: Information Mgt., Form GW-1b
1617 Mail Service Center—Raleigh,NC 27699-1617 Phone No.[phone] ext 568. Rev.7/05

NONRESIDENTIAL"y Jm'� ONRESIDENTIAL WELL CONSTRUCTION RECORD
t V75
North Carolina Department of Environment and Natural Resources-Division of Water Quality
WELL CONTRACTOR CERTIFICATION# 2580
`�
1.WELL CONTRACTOR: d. TOP OF CASING IS 2.0 FT.Above Land Surface'
JASON MANTAK 'Top of casing terminated at/or below land surface may require
Well Contractor(Individual)Name
a variance in accordance with 15A NCAC 2C.0118.
GEOLOGIC EXPLORATION,INC. e. YIELD(gpm): NIA METHOD OF TEST NIA
Well Contractor Company Name f. DISINFECTION:Type NIA Amount N/A
STREET ADDRESS 176 COMMERCE BLVD g. WATER ZONES(depth):
STATESVILLE NC 28625 From To From To
City or Town State Zip Code From To From To
70( 4 )- 872-7686 From To From To
Area code- Phone number 6. CASING: Thickness/
2.WELL INFORMATION: Depth Diamer WIN Material
at rial
PVC
SITE WELL ID#(if applicable) MW-2 From 0.0 To 10.0 Ft.2 INCI SCFT4o
From To Ft.
STATE WELL PERMIT#(if applicable) From To Ft.
DWQ or OTHER PERMIT#(if applicable)
WELL USE(Check Applicable Box)Monitoring t7 Municipal/Public❑ 7. GROUT: Depth Material Method
Industrial/Commercial❑ Agricultural❑ Recovery❑ Injection p
From 0.0 To 4.0 Ft Portland benlonite SLURRY
Irrigation❑ Other❑ (list use)
From To Ft.
DATE DRILLED 12/08l09 From To. Ft.
8. SCREEN: Depth Diameter Slot Size -Material
TIME COMPLETED AM❑ PM❑ 10.0 30.0 2.0 .010 P
From To Ft. in. in. �_
3.WELL LOCATION: From To Ft. in. in. CDD
CITY: ASHEVILLE COUNTY BUNCOMBE From To Ft. in. in. > iTI
WRIGHT BROTHERS WAY 28732 4 _
9. SAND/GRAVEL PACK:
(Street Name,Numbers,Community,Subdivsion,Lot No.,Parcel,Zip Code) -x (iD �
Depth Size aterie)
TOPOGRAPHIC/LAND SETTING: Ml �„•
From 8.0 To 30.0 Ft. 20-40 FINE SILICA g D
❑Slope ❑Valley ❑Flat [:]Ridge ❑Other ;Q
e
(check appropriate box) From To Ft. ? 7y_�'
From To Ft. t t
May be in degrees, F
LATITUDE y �
minutes,seconds or 10.DRILLING LOG
k
LONGITUDE __ in a decimal format From To Formation Description
Latitude/longitude source: ❑GPS ❑Topographic map 0.0 15.0 BROWN SILTY CLAY
(location of well must be shown on a USGS topo map and 15.0 30.0 GRAY SILTY CLAY
attached to this form if not using GPS)
4.FACILITY-is the name of the business where the well is located.
FACILITY ID#(if applicable)
NAME OF FACILITY ASHEVILLE AIRPORT
STREET ADDRESS WRIGHT BROTHERS WAY
ASHEVILLE NC 26732 c17 ;j L6E
City or Town State Zip Code ca
CONTACT PERSON ASHEVILLE REGIONAL AIRPORT t' 1. IM
MAILING ADDRESS 61 TERMINAL DRIVE '°U/^-4iF
FLETCHER NC 28732 11.REMARKS: infoim fior Processing Unit
City or Town State Zip Code BENTONITE SEAL FROM 4.0 TO 8.0 FEET
U- -
Area code- Phone number
I DO REBY CERTIFY THWRN
AS CONSTRUCTED IN ACCORDANCE WITH
5.WELL DETAILS: I C 2C,WEL NDARDS,AND THAT A COPY OF THIS
a. TOTAL DEPTH: 30.0 FEET RE BEEN ELL OWNER.
12/10l09
b. DOES WELL REPLACE EXISTING WELL? YES❑ NO® SI ATURE OF CERTIFIED WELL CONTRACTOR DATE
c. WATER LEVEL Below Top of Casing: 14.0 FT. JASON MANTAK
(Use"+"if Above Top of Casing)
PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Submit the original to the Division of Water Quality within 30 days. Attn: Information Mgt., Form GW-1b
1617 Mail Service Center-Raleigh,NC 27699-1617 Phone No.[phone] ext 568. Rev.7/05

NON WELL CONSTRUCTION RECORD
:.
North Carolina Department of Environment and Natural Resources-Division of Water Quality
r==r-
-�_ � WELL CONTRACTOR CERTIFICATION# 2580
1.WELL CONTRACTOR: d. TOP OF CASING IS 2.0 FT.Above Land Surface'
JASON MANTAK `Top of casing terminated at/or below land surface may require
a variance in accordance With 15A NCAC 2C.0118.
Well Contractor(Individual)Name
GEOLOGIC EXPLORATION,INC. e. YIELD(gpm): N/A METHOD OF TEST N/A
Well Contractor Company Name f. DISINFECTION:Type N/A Amount N/A
STREET ADDRESS
176 COMMERCE BLVD g- WATER ZONES(depth):
From To From To
STATESVILLE NC 28625
From To From To
City or Town State Zip Code
70 - 872-7686( 4 } From To From To
Area code- Phone number 6. CASING: Thickness/
2.WELL INFORMATION: Depth Diameter WIN Material
From 0.0 To 10.0 Ft 2 INCH SC 40 PVC
SITE WELL ID#(if applicable) PZ-4
STATE WELL PERMIT#(if applicable) From To Ft.
From To Ft.
DWQ or OTHER PERMIT*(if applicable)
7. GROUT: Depth Material Method
WELL USE(Check Applicable Box)Monitoring® Municipal/Public❑
Industrial/Commercial❑ Agricultural❑ Recovery❑ Injection p
From 0•0 To 4'0 Ft. Portland bentonite SLURRY
Irrigation[] Other❑ (list use) From To Ft.
DATE DRILLED 12/08/09 From To Ft.
8. SCREEN: Depth Diameter Slot Size Material
TIME COMPLETED AM❑ PM❑ 10.0 25.0 2.0 .010 PVP
From To Ft. in. in.
3.WELL LOCATION: From To Ft. in. in.
CITY: ASHEVILLE COUNTY BUNCOMBE � —
From To Ft. in. in. In
WRIGHT BROTHERS WAY 28732
9. SAND/GRAVEL PACK:
(Street Name,Numbers,Community,Subdivision,Lot No.,Parcel,Zip Code) Depth Size Material I
TOPOGRAPHIC/LAND SETTING: From 8.0 To 25.0 Ft. 20-40 FINE SILIGA, N
❑Slope ❑Valley ❑Flat ❑Ridge ❑ Other €P3 trii
(check appropriate box) From To Ft.
t� spa
LATITUDE May be in degrees, From To Ft.
minutes,seconds or
LONGITUDE in a decimal format 10.DRILLING LOG pr
—— From To Formation Descriptioxh
Latitude/longitude source: ❑GPS ❑Topographic map 0.0 25.0 BROWN SILTY CLAY
(location of well must be shown on a USGS topo map and
attached to this form if not using GPS)
4.FACILITY-is the name of the business where the well is located.
FACILITY ID#(if applicable)
NAME OF FACILITY ASHEVILLE AIRPORT
STREET ADDRESS WRIGHT BROTHERS WAY
ASHEVILLE NC 28732
City or Town State Zip Code •i -�
CONTACT PERSON ASHEVILLE REGIONAL AIRPORT _
MAILING ADDRESS 61 TERMINAL DRIVE oo�
FLETCHER NC 28732 11.REMARKS: AAfATEK CJUt-,i-!I Y 6t:u 1'10 N
City or Town State Zip Code BENTONITE SEAL FROM 4.0 TO 8.dIF'�Ti;�tion Processina Unit
Area code- Phone number
I DO HEREBY CERTIFY THAT THIS WELL WW CONSTRUCTED IN ACCORDANCE WITH
5.WELL DETAILS: 15A NCJ4 2C,WELL CONST CTI N DARDS,AND THAT A COPY OF THIS
a. TOTAL DEPTH: 25.0 FEET REco AS BEEN P D E WELL OWNER.
12/10/09
b. DOES WELL REPLACE EXISTING WELL? YES❑ NO® SIG URE OF CERTIFIED WELL CONTRACTOR DATE
c. WATER LEVEL Below Top of Casing: 5.0 FT. SON MANTAK
(Use"+"if Above Top of Casing)
PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Submit the original to the Division of Water Quality within 30 days. Attn:Information Mgt., Form GW-1b
1617 Mail Service Center—Raleigh,NC 27699-1617 Phone No.[phone] ext 568. Rev.7/05

0 1$
X f':
;i�`,;�����.,��:�-•�� NONRESIDENTIAL WELL CONSTRUCTION RECORD L;
(� l° North Carolina Department of Environment and Natural Resources-Division of Water Quality
WELL CONTRACTOR CERTIFICATION# 2580
1.WELL CONTRACTOR: d. TOP OF CASING IS 2.0 FT.Above Land Surface*
JASON MANTAK *Top of casing terminated al/or below land surface may require
Well Contractor(Individual)Name a variance in accordance with 15A NCAC 2C.0118.
GEOLOGIC EXPLORATION,INC. e. YIELD(gpm): N/A METHOD OF TEST N/A
Well Contractor Company Name f. DISINFECTION:Type N/A Amount N/A
STREET ADDRESS 176 COMMERCE BLVD g. WATER ZONES(depth):
STATESVILLE NC 28625 From To From To
City or Town State Zip Code From To From To
70( 4 )- 872-7686 From To From To
Area code- Phone number 6. CASING: Thickness/
2.WELL INFORMATION: Depth Diameter Weiaht Material
SITE WELL ID#(if applicable) PZ-2 From 0.0 To 10.0 Ft 2 INCH SCH 40 PVC
STATE WELL PERMIT#(if applicable) From To Ft.
From To Ft.
DWQ or OTHER PERMIT#(if applicable)
WELL USE(Check Applicable Box)Monitoring® Municipal/Public❑ 7. GROUT: Depth Material Method
Industrial/Commercial❑ Agricultural❑ Recovery❑Injection❑ From 0.0 To 4.0 Ft. Portland bentonite SLURRY
Irrigation❑ Other❑ (list use) From To Ft.
DATE DRILLED
12/07/09 From To Ft.
8. SCREEN: Depth Diameter Slot Size Material
TIME COMPLETED AM❑ PM❑ 10.0 30.0 2.0 .010 PVC
3.WELL LOCATION:
From To Ft. in, in.
ASHEVILLE BUNCOMBE From To Ft. in. in.
CITY: COUNTY From To Ft. in. in.
WRIGHT BROTHERS WAY 28732
(Street Name,Numbers,Community,Subdivision,Lot No.,Parcel,Zip Code) 9. SAND/GRAVEL PACK:
Depth SIZE Material
TOPOGRAPHIC/LAND SETTING:❑Slope ❑Valley ❑Flat ❑Ridge ❑ Other From 8.0 To 30.0 Ft, 20-40 FINE SILICA SAND(check appropriate box) From To Ft.
LATITUDE May be in degrees, From To Ft. ,
minutes,seconds or 10.DRILLING LOG
LONGITUDE in a decimal format From To Formation Description Q
Latitude/longitude source: ❑GPS ❑Topographic map 0.0 10.0 ORANGE CLAY CTt
(location of well must be shown on a USGS topo map and 10.0 50.0 ORANGE SILTY CLAY IN-)
attached to this form if not using GPS)
-a
4.FACILITY-is the name of the business where the well is located.
FACILITY ID#(if applicable)
NAME OF FACILITY ASHEVILLE AIRPORT
STREET ADDRESS WRIGHT BROTHERS WAY g
ASHEVILLE NC 28732 n �-r f , sa '
City or Town State Zip Code Onn
CONTACT PERSON
ASHEVILLE REGIONAL AIRPORT � 009
MAILING ADDRESS 61 TERMINAL DRIVE trt'if r z�ti I ION
FLETCHER NC 28732 11.REMARKS:
inform ion Processing Unit
City or Town State .. Zip Code BENTONITE SEAL FROM-4.0 TO 8.0 FEET
U-
Area code- Phone number
5.WELL DETAILS: I DO HEREBY CERTIFY THAT THIS W WAS CONSTRUCTED IN ACCORDANCE WITH
15A. CAC 2C,WELL C STR STANDARDS,AND THAT A COPY OF THIS
a. TOTAL DEPTH:
30.0 FEET R RD HAS BE VI THE WELL OWNER.
12/10/09
71
b. DOES WELL REPLACE EXISTING WELL? YES❑ NO ElS NATURE OF CERTIFIED WELL CONTRACTOR DATE
c. WATER LEVEL Below Top of Casing: 15-0 FT, JASON MANTAK
(Use"+"if Above Top of Casing) PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Submit the original to the Division of Water Quality within 30 days. Attn: Information Mgt., Form Gw-1b
1617 Mail Service Center—Raleigh,NC 27699-1617 Phone No.[phone] ext 568. Rev.7/05

NON
OIV RESIDENTIAL WELL CONSTRUCTION RECORD "
13 1
rq f t� North Carolina Department of Environment and Natural Resources-Division of Water Quality
°! WELL CONTRACTOR CERTIFICATION# 2580
1.WELL CONTRACTOR: d. TOP OF CASING IS 2.0 FT.Above Land Surface'
JASON MANTAK 'Top of casing terminated at/or below land surface may require
Well Contractor(Individual)Name
a variance in accordance with 15A NCAC 2C.0118.
GEOLOGIC EXPLORATION,INC. e. YIELD(gpm): N/A METHOD OF TEST N/A
Well Contractor Company Name f. DISINFECTION:Type N/A Amount N/A
STREET ADDRESS 176 COMMERCE BLVD g. WATER ZONES(depth):
STATESVILLE NC 28625 From To From To
City or Town State Zip Code From To From To
70( 4 )- 872-7686 From To From To
Area code- Phone number 6. CASING: Thickness/
2.WELL INFORMATION: Depth Diameter Wei ht Material
PZ-1
SITE WELL ID*(if applicable) From 0.0 To 20.0 Ft.2 INCH SC1�40 PVC STATE WELL PERMIT#(if applicable) From To Ft.
From To Ft.
DWQ or OTHER PERMIT#(if applicable)
WELL USE(Check Applicable Box)Monitoring® Municipal/Public❑ 7• GROUT: Depth Material Method
Industrial/Commercial p Agricultural❑ Recovery❑ Injection❑
From 0.0 To 12.0 Ft Portland bentonile SLURRY
Irrigation❑ Other❑ (list use) From To Ft.
DATE DRILLED 12/07/09
From To Ft.
8. SCREEN: Depth Diameter Slot Size Material
TIME COMPLETED AM❑ PM❑ 20.0 50.0 2.0 .010 PVC
From To Ft. in. in.
3.WELL LOCATION: From To Ft. in. in.
CITY: ASHEVILLE COUNTY BUNCOMBE From To Ft.—in. in.
WRIGHT BROTHERS WAY 28732
9. SAND/GRAVEL PACK:
(Street Name,Numbers,Community,Subdivision,Lot No.,Parcel,Zip Code) Depth Size Material
TOPOGRAPHIC/LAND SETTING: From 16.0 To 50.0 Ft. 20-40 FINE SILICA SAND
❑Slope ❑Valley ❑Flat ❑Ridge ❑ Other From To Ft.
(check appropriate box)
LATITUDE
May be in degrees, From To Ft.
minutes,seconds or 10.DRILLING LOG
LONGITUDE _ _ in a decimal format From To Formation Description
Latitude/longitude source: ❑GPS ❑Topographic map 0.0 50.0 BROWN SANDY SILTY CLAY
(location of well must he shown on a USGS topo map and
attached to this form if not using GPS)
4.FACILITY-is the name of the business where the well is located.
FACILITY ID#(if applicable)
NAME OF FACILITY ASHEVILLE AIRPORT RECEIVED
STREET ADDRESS WRIGHT BROTHERS WAY
c�
ASHEVILLE NC 28732
City or Town State Zip Code
CONTACT PERSON ASHEVILLE REGIONAL AIRPORT J Inf c srm��inn Nrncessincl Unit
MAILING ADDRESS 61 TERMINAL DRIVE
FLETCHER NC 28732 11.REMARKS:
City or Town State Zip Code BENTONITE SEAL FROM 12.0 TO 16.0 FEET
U- •
Area code- Phone number
5.WELL DETAILS: I DO HEREBY RTIFY THAT THIS ELLrARDS,
STRUCTED IN ACCORDANCE WITH
15A'CAC 2 L CONS AND THAT A COPY OF THIS
a. TOTAL DEPTH: 50.0 FEET RECORD HA D NER.
12/10/09
b. DOES WELL REPLACE EXISTING WELL? YES❑ NO El SIGNAT E OF CERTIFIED WELL CONTRACTOR DATE
c. WATER LEVEL Below Top of Casing: 18.0 FT. JASON MANTAK
(Use"+"if Above Top of Casing) PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Submit the original to the Division of Water Quality within 30 days. Attn: Information Mgt:,; Form GW-1b
1617 Mail Service Center—Raleigh,NC 27699-1617 Phone No.[phone] ext 668. '''�
Rev.7lOS

1 r ONREmDENTIAL WELL CONSTRUCTION RECORD
'1 North Carolina Department of Environment and Natural Resources-Division of Water Quality 3,
WELL CONTRACTOR CERTIFICATION# 2580
1.WELL CONTRACTOR: d. TOP OF CASING IS 2.0 FT.Above Land Surface'
JASON MANTAK 'Top of casing terminated at/or below land surface may require
Well Contractor(Individual)Name a variance in accordance With 15A NCAC 2C.0118.
GEOLOGIC EXPLORATION,INC. e. YIELD(gpm): N/A METHOD OF TEST N/A
Well Contractor Company Name f. DISINFECTION:Type N/A Amount N/A
STREET ADDRESS
176 COMMERCE BLVD g. WATER ZONES(depth):
STATESVILLE NC 28625 From To From To
City or Town State Zip Code From To From To
70( 4 )- 872-7686 From To From To
Area code- Phone number 6. CASING: Thickness/
2.WELL INFORMATION: Depth Diameter Wei❑ht Material
PZ-3 From 0.0 To 20.0 Ft.2 INCH SCR40 PVC
SITE WELL ID#(if applicable)
From To Ft.
STATE WELL PERMIT#(if applicable)
DWQ or OTHER PERMIT#(if applicable) From To Ft.
WELL USE(Check Applicable Box)Monitoring® Municipal/Public❑
7. GROUT: Depth Material Method
Industrial/Commercial❑ Agricultural❑ Recovery❑ Injection❑
From 0.0 To 14.0 Ft Portland benlonite SLURRY
Irrigation❑ Other❑ (list use)
From To Ft.
DATE DRILLED 12/08/09 From To Ft.
8. SCREEN: Depth Diameter Slot Size Material
TIME COMPLETED AM❑ PM❑ From 20.0 To 40.0 Ft.2.0 in. .010 in PVC
3.WELL LOCATION: From To Ft. in. in.
CITY: ASHEVILLE COUNTY BUNCOMBE From To Ft. in. in.
WRIGHT BROTHERS WAY 28732 5r
9. SAND/GRAVEL PACK: CD
(Street Name,Numbers,Community,Subdivision,Lot No.,Parcel,Zip Code) Depth Size Material < ,
TOPOGRAPHIC/LAND SETTING: From 18.0 To 40.0 Ft. 20-40 FINE SILICA 1D
❑Slope ❑Valley ❑Flat ❑Ridge ❑ Other From To Ft. W
(check appropriate box)
LATITUDE May be in degrees,
From To Ft. n �
minutes,seconds or 10.DRILLING LOG C3 m
LONGITUDE __ in a decimal format From To Formation Descript@fl E
Latitude/longitude source: ❑GPS ❑Topographic map 0.0 40.0 BROWN SILTY CLAY C)
(location of well must be shown on a USGS topo map and
attached to this form if not using GPS) CD
4.FACILITY-is the name of the business where the well-is located.
FACILITY ID#(if applicable)
NAME OF FACILITY ASHEVILLE AIRPORT
STREET ADDRESS WRIGHT BROTHERS WAY
ASHEVILLE NC 28732
City or Town State Zip Code L)U- zoug
CONTACT PERSON ASHEVILLE REGIONAL AIRPORT.
MAILING ADDRESS 61 TERMINAL DRIVE lfforrnstiel'i2reC�iSriR=1 Init
FLETCHER NC 28732 11.REMARKS:
City or Town State Zip Code BENTONITE SEAL FROM 14.0 TO 18.0 FEET
Area code- Phone number
5.WELL DETAILS: I DO HEREBY CERTIFY THAT THIS W AS CONSTRUCTED IN ACCORDANCE WITH
15%9�w
STANDARDS,AND THAT A COPY OF THIS
a. TOTAL DEPTH: 40.0 FEET REE WELL OWNER.
12/10109
b. DOES WELL REPLACE EXISTING WELL? YES❑ NO® SI ATURE OF CERTIFIED WELL CONTRACTOR DATE
c. WATER LEVEL Below Top of Casing: 17.0 FT. JASON MANTAK
(Use"+"if Above Top of Casing)
PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Submit the original to the Division of Water Quality within 30 days. Attn:Information Mgt., Form GW-1b
1617 Mail Service Center—Raleigh,NC 27699-1617 Phone No.[phone] ext 568. Rev.7/05

r 1 NONRESIDENTIAL
�•°��` WELL CONSTRUCTION RECORD
0 y North Carolina Department of Environment and Natural Resources-Division of Water Quality
WELL CONTRACTOR CERTIFICATION# 2580
1.WELL CONTRACTOR: d. TOP OF CASING IS 2.0 FT.Above Land Surface-
JASON MANTAK 'Top of casing terminated at/or below land surface may require
Well Contractor(Individual)Name
a variance in accordance with 15A NCAC 2C.0118.
GEOLOGIC EXPLORATION, INC. e. YIELD(gpm): N/A METHOD OF TEST N/A
Well Contractor Company Name f. DISINFECTION:Type N/A Amount N/A
STREET ADDRESS 176 COMMERCE BLVD g. WATER ZONES(depth):
STATESVILLE NC 28625 From To From To
City or Town State Zip Code
From To From To
70( 4 )- 872-7686 From To From To
Area code- Phone number 6. CASING: Thickness/
2.WELL INFORMATION: Depth Diameter WIN Material
SITE WELL ID#(if applicable) MW-3
From 0.0 To 15.0 Ft.2 INCH SCI�40 PVC
STATE WELL PERMIT#(if applicable) From To Ft.From To Ft.
DWQ or OTHER PERMIT#(if applicable)
WELL USE(Check Applicable Box)Monitoring® Municipal/Public❑
7. GROUT: Depth Material Method
Industrial/Commercial❑ Agricultural❑ Recovery❑Injection❑
From 0.0 To 9.0 Ft. Portland bentonite SLURRY
Irrigation❑ Other❑ (list use) From To Ft.
DATE DRILLED 12/08/09
From To Ft.
8. SCREEN: Depth Diameter Slot Size Material
TIME COMPLETED AM❑ PM❑ 15.0 35.0 2.0 .010 PVC
From To Ft. in. in.
3.WELL LOCATION: From To Ft. in. in.
CITY: ASHEVILLE COUNTY BUNCOMBE From To Ft. in. in.
WRIGHT BROTHERS WAY 28732
9. SAND/GRAVEL PACK: �
(Street Name,Numbers,Community,Subdivision,Lot No.,Parcel,Zip Code) Depth Size Material
TOPOGRAPHIC/LAND SETTING: From 13.0 To 35.0 Ft. 20-40 FINE SILICA SAND
[]Slope ❑Valley ❑Flat ❑Ridge ❑ Other
' (check appropriate box)
From To Ft. CUI
LATITUDE May be in degrees, From To Ft. .
minutes,seconds or 10.DRILLING LOG
LONGITUDE _ _ in a decimal format From To Formation Description
Latitude/longitude source: ❑GPS ❑Topographic map 0.0 10.0 ORANGE SILTY CLAY
(location of well must be shown on a USGS topo map and 10.0 20.0 GRAY SILTY CLAY
attached to this form if not using GPS) 20.0 35.0 YELLOW SILTY CLAY
4.FACILITY-is the name or the business where the well is located.
FACILITY ID#(if applicable)
NAME OF FACILITY ASHEVILLE AIRPORT -- . - ,
ED
STREET ADDRESS WRIGHT BROTHERS WAY I1EC
ASHEVILLE NC 28732 tJ
City or Town State Zip Code i.
cairn Unit
CONTACT PERSON ASHEVILLE REGIONAL AIRPORT lntorl'r�tri r�'�s
MAILING ADDRESS 61 TERMINAL DRIVE
FLETCHER NC 28732 11.REMARKS:
City or Town State Zip Code BENTONITE SEAL FROM 9.0 TO 13.0 FEET
U-
Area code- Phone number
5.WELL DETAILS: I DO HE BY CERTIFY THAT HIS S CONSTRUCTED IN ACCORDANCE WITH
15A N 2C,WELL CO UC TANDARDS,AND THATA COPY OF THIS
a. TOTAL DEPTH:
35.0 FEET RECO S BEEN 1 WELL OWNER.
12/10/09
b. DOES WELL REPLACE EXISTING WELL? YES❑ NO 91 SIGP TURE OF CERTIFIED WELL CONTRACTOR DATE
c. WATER LEVEL Below Top of Casing: 11.0 FT. ASON MANTAK
(Use"+"if Above Top of Casing) PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Submit the original to the Division of Water Quality within 30 days. Attn:Information Mgt., Form GW-1b
1617 Mail Service Center-Raleigh,INC 27699-1617 Phone No.[phone] ext 568. Rev.7/05

Nvly RESID ;
ENTIAL WELL CONSTRUC'FION RECORD
/, North Carolina Department of Environment and Natural Resources-Division of Water Quality
WELL CONTRACTOR CERTIFICATION#f 3098
1.WELL CONTRACTOR: d. TOP OF CASING IS 3.0 FT.Above Land Surface
JOHNNY BURR "Top of casing terminated at/or below land surface may require
Well Contractor(Individual)Name a variance in accordance With 15A NCAC 2C.0118.
GEOLOGIC EXPLORATION,INC. e. YIELD(gpm): N/A METHOD OF TEST N/A
Well Contractor Company Name f. DISINFECTION:Type N/A Amount N/A
STREET ADDRESS 176 COMMERCE BLVD g. WATER ZONES(depth):
STATESVILLE NC 28625 From To From To
City or Town State Zip Code From To From To
70( 4 )- 872-7686 From To From To
Area code- Phone number 6. CASING: Thickness/
2.WELL INFORMATION: Depth Diamer WeAt Material
SITE WELL ID#(if applicable) MW-6 From 0.0 To 15.0 Ft.2 INCI SC 40 PVC
STATE WELL PERMIT#(if applicable) From To Ft.
From To Ft.
DWQ or OTHER PERMIT#(if applicable)
WELL USE(Check Applicable Box)Monitoring® Municipal/Public❑
7. GROUT: Depth Material Method
Industrial/Commercial❑ Agricultural❑ Recovery❑ Injection❑
From 0.0 . To 10.0 Ft Portland benlonile SLURRY
Irrigation[] Other❑ (list use) From To Ft.
DATE DRILLED 07/01/10-07/02/10 From To Ft.
8. SCREEN: Depth Diameter Slot Size Material
TIME COMPLETED AM❑ PM❑ From 15.0 To 30.0 Ft 2.0 in ,010 in. PVC
3.WELL LOCATION: From To Ft. in. in.
CITY: ASHEVILLE COUNTY BUNCOMBE From To Ft. in. in.
WRIGHT BROTHERS WAY 28732 9. SAND/GRAVEL PACK:
(Street Name,Numbers,Community,Subdivision,Lot No.,Parcel,Zip Code) Depth Size Material
TOPOGRAPHIC/LAND SETTING:
From 13.0 To 30.0 Ft. 20-40 FINE SILICA SAND
❑Slope ❑Valley ❑Flat ❑Ridge ❑ Other
From To Ft.
(check appropriate box)
May be in degrees, From To Ft.
LATITUDE '
minutes,seconds or 10.DRILLING LOG
LONGITUDE _ _ in a decimal format From To Formation Description
Latitude/longitude source: ❑GPS ❑Topographic map 0.0 3.0 ORANGE ROCKY SANDY CLAY
(location of we#must be shown on a USGS topo map and 3.0 10.0 TAN/ORANGE SILTY CLAY
attached to this form if not using GPS) 10.0 30.0 TAN/BROWN SANDY CLAY
4.FACILITY-is the name of the business where the well is located.
FACILITY ID#(if applicable)
NAME OF FACILITY ASHEVILLE AIRPORT
STREET ADDRESS WRIGHT BROTHERS WAY
ASHEVILLE NC 28732
City or Town State Zip Code
CONTACT PERSON ASHEVILLE REGIONAL AIRPORT -
MAILING ADDRESS 61 TERMINAL DRIVE
FLETCHER NC 28732 11.REMARKS:
City or Town State Zip Code BENTONITE SEAL FROM 10.0 TO 13.0 FT
U-
Area code- Phone number
5.WELL DETAILS: I DO HEREBY CERTIFYTHATTHIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH
15A NCAC 2C,WELL CONSTRUCTION STAyQARDS,AND THAT A COPY OF THIS
RECOQUIDED TO THE 1L OWNER
a. TOTAL DEPTH: 30.0 FEET ,. - q
07/07
b. DOES WELL REPLACE EXISTING WELL? YES p NO 91 ` kT -DATE
�SIGNATUREb1=CERTIFIED V' 1'_CD TR
c. WATER LEVEL Below Top of Casing: 15.0 FT. JOHNNY BURR i
(Use"+"if Above Top of Casing) t "{"FI_ F v�r F.-F,�'
JI PRINTED NAME OF PERSON':CbNSTPRUCTING-THEVELL
P
Submit the original to the Division of Water Quality within 30 days. Attn:Information MgtAI' tL 20 tt, Form G11b
1617 Mail Service Center-Raleigh, NC 27699-1617 Phone No.[phone] ext 668. Rev.710
to

4
r NONRESIDENTIAL WELL CONSTRUCTION RECORD
I
i ;: North Carolina Department of Environment and Natural Resources-Division of Water Quality
WELL CONTRACTOR CERTIFICATION# 3098
1.WELL CONTRACTOR: d. TOP OF CASING IS 3.0 FT.Above Land Surface'
JOHNNY BURR .'Top of casing terminated at/or below land surface may require
Well Contractor(Individual)Name a variance in accordance with 15A NCAC 2C.0118.
GEOLOGIC EXPLORATION,INC. e. YIELD(gpm): N/A METHOD OF TEST N/A
Well Contractor Company Name f. DISINFECTION:Type N/A Amount N/A
STREET ADDRESS 176 COMMERCE BLVD g. WATER ZONES(depth):
From To From To
STATESVILLE NC 28625
City or Town State Zip Code From To From To
70( 4 )_ 872-7686 From To From To
Area code- Phone number 6. CASING: Thickness/
2.WELL INFORMATION: Depth Diameter W iqht Material
SITE WELL ID#(if applicable) MW-7 From 0.0 To 15.0 Ft.2 INCH S�K40 PVC
STATE WELL PERMIT#(if applicable)
From To Ft.
DWQ or OTHER PERMIT#(if applicable)
From To Ft.
WELL USE(Check Applicable Box)Monitoring ElMunicipal/Public❑ 7. GROUT: Depth Material Method
Industrial/Commercial❑ Agricultural❑ Recovery p Injection❑
From 0.0 TO 10.0 Ft Portland bentonite SLURRY
Irrigation❑ Other❑ (list use)
From To Ft.
DATE DRILLED 07/01/10-07/02/10 From To Ft.
8. SCREEN: Depth Diameter Slot Size Material
TIME COMPLETED AM❑ PM❑ From 15.0 To 25.0 Ft.2.0 in. .010 in. PVC
3.WELL LOCATION: ° From To Ft. in. in.
CITY: ASHEVILLE COUNTY BUNCOMBE From To Ft. in. in.
WRIGHT BROTHERS WAY 28732 9. SAND/GRAVEL PACK:
(Street Name,Numbers,Community,Subdivision,Lot No.,Parcel,Zip Code) Depth Size Material
TOPOGRAPHIC/LAND SETTING:
From 13.0 To 25.0 Ft, 20-40 FINE SILICA SAND
❑Slope ❑Valley ❑Flat ❑Ridge ❑ Other
From To Ft.
(check appropriate box)
LATITUDE May be in degrees, From To Ft.
minutes,seconds or 10.DRILLING LOG
LONGITUDE _ _ in a decimal format From To Formation Description
Latitude/longitude source: ❑GPS ❑Topographic map 0.0 3.0 ORANGE ROCKY SANDY CLAY
(location of well must be shown on a USGS topo map and 3.0 10.0 TAN/ORANGE SILTY CLAY
attached to this form if not using GPS) 10.0 25.0 TAN/BROWN SANDY CLAY
4.FACILITY-is the name of the business where the well is located.
FACILITY ID#(if applicable)
NAME OF FACILITY ASHEVILLE AIRPORT -
STREET ADDRESS WRIGHT BROTHERS WAY
ASHEVILLE NC 28732 (_ _
City or Town State Zip Code
CONTACT PERSON ASHEVILLE REGIONAL AIRPORT
MAILING ADDRESS 61 TERMINAL DRIVE
FLETCHER NC 28732 11.REMARKS:
City or Town State Zip Code BENTONITE SEAL FROM 10.0 TO 13.0 FT
U-
Area code- Phone number
5.WELL DETAILS: I DO HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH
15A NC 'C 2 -WELL CONSTRUCTION ST.N ARDS,AND THAT A COPY OF THIS
25.0 FEET RECD IDEDTOTH LOWNER.
a. TOTAL DEPTH: ,. r'
:1. . a "y 07/07/10
b. DOES WELL REPLACE EXISTING WELL? YES❑ NO® I.,
IGNATUR 'F CERTIF„IED,-ffl .L Cd 1T .__--___pA_T_E.
c. WATER LEVEL Below Top of Casing: 15.0 FT. JOHNNY BURR
(Use"+"if Above Top of Casing)
PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Submit the original to the Division of Water Quality within 30 days. Attn: Information Mgt.dRJ1L 2 6 2%Ia Form GWj1b
1617 Mail Service Center-Raleigh, NC 27699-1617 Phone No.[phone] ext 568. Rev.7/05

1 V trry RESIDENTIAL WELL CONSTRUC y RECORD 32 54 d 2
j(_'r North Carolina Department of Environment and Natural Resources-Division of Water Quality
M1
WELL CONTRACTOR CERTIFICATION# 3098
1.WELL CONTRACTOR: d. TOP OF CASING IS 3.0 FT.Above Land Surface'
JOHNNY BURR 'Top of casing terminated at/or below land surface may require
Well Contractor(Individual)Name
a variance in accordance With 15A NCAC 2C.0118.
GEOLOGIC EXPLORATION,INC. e. YIELD(gpm): N/A METHOD OF TEST N/A
Well Contractor Company Name f. DISINFECTION:Type N/A Amount N/A
STREET ADDRESS 176 COMMERCE BLVD g. WATER ZONES(depth):
STATESVILLE NC 28625 From To From To
City or Town State Zip Code From To From To
70( 4 )- 872-7686 From Tc From To
Area code- Phone number 6. CASING: Thickness/
2.WELL INFORMATION: Depth Diamer WeAt Material
SITE WELL ID#(if applicable) MW-4 From 0.0 To 15.0 Ft. 2 INCI SC 40 PVC
STATE WELL PERMIT#(itapplicable)
From To Ft.
From To Ft.
DWQ or OTHER PERMIT#(if applicable)
WELL USE(Check Applicable Box)Monitoring E Municipal/Public❑ 7. GROUT: Depth Material Method
Industrial/Commercial❑ Agricultural❑ Recovery❑ Injection❑
From 0.0 To 10.0 Ft Portland bentonile SLURRY
Irrigation❑ Other❑ (list use)
From To FIL
DATE DRILLED 07/01/10-07/02/10 From To Ft.
8. SCREEN: Depth Diameter Slot Size Material
TIME COMPLETED AM❑ PM❑ From 15.0 To 30.0 Ft 2.0 in .010 in. PVC
3.WELL LOCATION: ° From To Ft. in. in.
CITY: ASHEVILLE COUNTY BUNCOMBE From To Ft. in. in.
WRIGHT BROTHERS WAY 28732 9. SAND/GRAVEL PACK:
(Street Name,Numbers,Community,Subdivision,Lot No.,Parcel,Zip Code) Depth Size Material
TOPOGRAPHIC/LAND SETTING:
From 13.0 To 30.0 (=t. 20-40 FINE SILICA SAND
❑Slope ❑Valley ❑Flat ❑Ridge ❑ Other
From TO Ft.
(check appropriate box)
LATITUDE May be in degrees, From To Ft.
minutes,seconds or 10.DRILLING LOG
LONGITUDE _ _ in a decimal format From TO Formation Description
Latitude/longitude source: ❑GPS ❑Topographic map 0.0 3.0 ORANGE ROCKY SANDY CLAY
(location of well must be shown on a USGS topo map and 3.0 10.0 TAN/ORANGE SILTY CLAY
attached to this form Ynot using GPS) 10.0 30.0 TAN/BROWN SANDY CLAY
4.FACILITY-is the name of the business where the well is located.
FACILITY ID#(if applicable)
NAME OF FACILITY ASHEVILLE AIRPORT
STREET ADDRESS WRIGHT BROTHERS WAY
r
ASHEVILLE NC 28732
City or Town State Zip Code
CONTACT PERSON ASHEVILLE REGIONAL AIRPORT
MAILING ADDRESS 61 TERMINAL DRIVE
FLETCHER NC 28732 11.REMARKS:
City or Town State Zip Code BENTONITE SEAL FROM 10.0 TO 13.0 FT
Area code- Phone number
5.WELL DETAILS: I DO HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH
15A NCAC2C,WELL CONSTRUCTION STAN RDS.AND THAT A COPY OF THIS
30.0 FEET RECOFRD 'AS�EEN PROVIDED TO THE pl°OWNER.
a. TOTAL DEPTH: +1 � - �`� '•',,
07/07/10
b. DOES WELL REPLACE EXISTING WELL? YES❑ NO E S(ONATURE CERTIFIED fN L` TRA _.D9TE
c. WATER LEVEL Below Top of Casing: 15.0 FT. JOHNNY BURR I' €V-7 ' J r t }
(Use"+"if Above Top of Casing)
PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Al 2 6 MCI �
Submit the original to the Division of Water Quality within 30 days. Attn:Information Mgt., Form GW-lb
1617 Mail Service Center-Raleigh,NC 27699-1617 Phone No.[phone] ext568• Rev..7f05

srn, a
j..J \�' ]�] D �j, s lj Alt
` 1 �vl v RESIDENTIAL WELL CONSTRUL-iItUN RECORD
North Carolina Department of Environment and Natural Resources-Division of Water Quality
=¢= WELL CONTRACTOR CERTIFICATION# 3098
1.WELL CONTRACTOR: d. TOP OF CASING IS 3.0 FT.Above Land Surface-
JOHNNY BURR 'Top of casing terminated allor below land surface may require
Well Contractor(Individual)Name a variance in accordance with 15A NCAC 2C.0118.
GEOLOGIC EXPLORATION,INC. e. YIELD(gpm): N/A METHOD OF TEST N/A
Well Contractor Company Name f. DISINFECTION:Type N/A Amount NIA
STREET ADDRESS 176 COMMERCE BLVD g. WATERZONES(depth):
STATESVILLE NC 28625 From Tc From To
From To From To
City or Town State Zip Code
70( 4 )- 872-7686 From Tc From To
Area code- Phone number 6. CASING: Thickness/
2.WELL INFORMATION: Depth Diameter Wai�cht Material
SITE WELL ID#(if applicable) MW-8 From 0.0 To 15.0 Ft. 2 INCH S 40 PVC
STATE WELL PERMIT#(if applicable)
From Tc Ft.
DWQ or OTHER PERMIT#(if applicable) From To Ft.
WELL USE(Check Applicable Box)Monitoring® Municipal/Public❑
7. GROUT: Depth Material Method
Industrial/Commercial❑ Agricultural❑ Recovery❑ Injection❑
From 0.0 To 10.0 Ft Portland bentonite SLURRY
Irrigation❑ Other❑ (list use) From To Ft.
DATE DRILLED 07/01/10-07l02/10 From Tc Ft.
8. SCREEN: Depth Diameter Slot Size Material
TIME COMPLETED AM❑ PM❑ From 15.0 To 30.0 Ft 2.0 in .010 in PVC
3.WELL LOCATION: From To Ft. in. in.
CITY: ASHEVILLE COUNTY BUNCOMBE From To Ft. in. in.
WRIGHT BROTHERS WAY 28732 9. SAND/GRAVEL PACK:
(Street Name,Numbers,Community,Subdivision,Lot No.,Parcel,Zip Code) Depth Size Material
TOPOGRAPHIC/LAND SETTING:
From 13.0 To 30.0 Ft. 20-40 FINE SILICA SAND
❑Slope ❑Valley [-]Flat ❑Ridge ❑ Other From To Ft.
(check appropriate box)
LATITUDE May be in degrees, From Tc Ft.
minutes,seconds or 10.DRILLING LOG
LONGITUDE __ in a decimal format From To Formation Description
Latitude/longitude source: ❑GPS ❑Topographic map 0.0 3.0 ORANGE ROCKY SANDY CLAY
(location of well must be shown on a USGS topo map and 3.0 10.0 TAN/ORANGE SILTY CLAY
attached to this form if not using GPS) 10.0 30.0 TAN/BROWN SANDY CLAY
4.FACILITY-is the name of the business where the well is located.
FACILITY ID#(if applicable)
NAME OF FACILITY ASHEVILLE AIRPORT "
STREET ADDRESS WRIGHT BROTHERS WAY
r
ASHEVILLE NC 28732
City or Town State Zip Code
CONTACT PERSON ASHEVILLE REGIONAL AIRPORT
MAILING ADDRESS 61 TERMINAL DRIVE
FLETCHER NC 28732 11.REMARKS:
City or Town State Zip Code BENTONITE SEAL FROM 10.0 TO 13.0 FT
U-
Area code- Phone number
5.WELL DETAILS: I DO HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH
15A NUDAC',,E
ELL CONSTRUCTION STA RDS,AND THAT A COPY OF THIS
30.0 FEET QEN PRO EDTOTHE OWNER.
a. TOTAL DEPTH: -• 07/07/10
b. DOES WELL REPLACE EXISTING WELL? YES❑ NO El SIGNATUREIOF'CERTIFIED WELI1 C6NTitACr6g DATE
c. WATER LEVEL Below Top of Casing: 15.0 FT. JOHNNY BURR
(Use"+"if Above Top of Casing)
PRINTED NAME OFSPERSON'CONSTRU.CTINOITz E4F HELL
1 �
Submit the original to the Division of Water Quality within 30 days. Attn:Info 4 atiomMgtjJP f Form Gvu-1b
1617 Mail Service Center-Raleigh, NC 27699-1617 Phone No.[phone] ext 968. Rev.7/05t¢`
10
fflc

W Progress Energy
a �P i�� � ]. 2U►�
Certified Mail: 7009 0080 0001 2486 2443
. ®dice
File Pt.: 12570-A May 27,2011 ` � �� 01 W1
Mr. G. Landon Davidson
NC DENR Asheville Regional Office
2090 U.S. 70 Highway
Swannanoa,NC 28778
RE: Carolina Power& Light Company d/b/a Progress Energy Carolinas, Inc.
Asheville Steam Electric Plant, Buncombe County
Notification: Truck Accident&Resultant Coal Ash Spillage
Ash Reuse Permit WQ0000020
Dear Mr. Davidson:
Progress Energy Carolinas, Inc. (PEC) commenced a structural fill project (Area IV) with
Asheville Steam Electric Plant coal ash at the Asheville Regional Airport last fall. To
move coal ash between the plant and airport, covered dump trucks are utilized. On May
24, 2011 at approximately 11:30 am, a dump truck loaded with coal ash tipped and
spilled its contents along Glenn Bridge Road. A telephone notification to the Asheville
Regional Office was completed within 24 hours of the accident per Condition III.7.e of
the above-referenced permit.
PEC has contracted with Charah, Inc. for the movement of coal ash between the plant and
the airport site, specifying that Charah is owner of coal ash once it is undergoing
transportation. Therefore, Charah investigated the truck accident and completed the
attached Incident Investigation Form. In response to this accident, on May 26, 2011
Charah conducted a safety stand down with all truck drivers to remind them of speed,
seat-belt usage, lane usage, weight requirements and truck maintenance. In addition,
Charah will evaluate an alternate truck route.
Please contact Ms. Laurie Moorhead at 828-687-5240 if you have any questions
regarding this truck accident.
'ncer 1 ,
rr✓ Garry A. Whisnant
Asheville Plant Manager
Attachment
Progress Energy Carolinas,Inc.
Asheville Plant
200 CP&L Drive
Arden,NC 28704

Oncident Investigation Form®
FORMA , s
Date of Incident Time I Day of Week Shift Yes No
-! 4/2011 11:30 ❑S ❑M HT ❑W ❑T OF ❑S 01 02 ❑3 Damage H ❑
p' AM Injury H ❑
®, • b
Name: Micky Fender Address: 103 Caprice Lane
Age: 52 1 Phone: [phone] Fletcher, NC 28732
Job Title: Truck Driver I Supervisor Name: John Hamilton
Length of Employment at Company: Unknown I Length of Employment at Job: Since haul started
Employee Classification: ❑Full Time ❑Part Time HContractor ❑Temporary
®`' H Bruising ❑ Dislocation ❑ Other s ecif Inured Part of Body:
❑ Strain/Sprain H Scratch/Abrasion ❑ Internal Arm (requiring stitches
❑ Fracture ❑ Amputation ❑ Foreign Body Remarks: Back
H .Laceration/Cut ❑ Burn/Scald ❑ Chemical Head/Neck
e Name and Address of Treating Physician or Facility:
First Aid Mission Hospital
Emeraency Room 509 Biltmore Avenue
Dr.'s Office Asheville, NC 28801-4601
Hos italization
:DAMAGED • '
Property, Equipment, or Material Damaged Describe Damage
Truck Cab roof was cut open to remove the driver. Other visible
damage includes broken front axle springs, severe cab
damage, broken windshield, front end damage.
Property/Ditch Truck lost its load on the property requiring the area to be
excavated and sod placed. Ditch line required restructuring
1 and replacement of 6' culvert.
® •
Describe what happened (attach photographs or diagrams if necessary)
Micky Fender(Hamilton Hauling)was operating Hamilton truck HH-18. The truck was loaded and in route to the airport fill
site traveling on Glenn Bridge Rd. Mr. Fender stated that he saw a large tow truck coming out on Galacia Court.When he
looked back an oncoming car was crowding the center line and he felt he had to ease to the right where the pavement was
broken in order to miss the oncoming car. Mr. Fender stated he was hauling his 8th load of the day on the same route
(normally 15 loads per day) and he knew the deteriorated section of the road was present and stated that he gripped the
heel tight to drive through it. He remembered being jerked and hitting the ditch. His next memory was of the truck on its
side. State troopers reported the truck ran 146 feet from time of leaving roadway till overturning the truck. Officer issued a
citation to the driver for lane violation.
'ROOTc Apply)
m
Improper work technique ® Poor workstation design or layout ❑ 1 Lack of written procedures or policies ❑
Safety rule violation ❑ Con ested work area 91 Safetv rules not enforced ❑
Improper PPE or PPE not used H Hazardous substances ❑ 1 Hazards not identified ❑
Operating without authority ❑ Fire or explosion hazard ❑ PPE unavailable ❑
Failure to warn or secure ❑ Inadequate ventilation ❑ Insufficient worker training ❑
Operating at improper speeds ❑ Improper material storage ❑ Insufficient supervisor training ❑
By-passing safety devices ❑ Improper tool orequipment ❑ Improper maintenance ❑
Guards not used ❑ Insufficient knowledge of job ❑ Inadequate supervision ❑
Improper loading or placement ❑ Slippery conditions ❑ Inadequate job planning H
Improper lifting ❑ Poor housekeeping ❑ Inade uate hiring practices ❑
Servicing machinery in motion ❑ Excessive noise ❑ Inadequate workplace inspection ❑
_Horseplay ❑ Inadequate guarding.of hazards ❑ Inadequate equipment ❑
C .)rug or alcohol use ❑ Defective tools/e ui ment ❑ Unsafe design or construction ❑
Unnecessary haste ❑ Insufficient lighting, ❑ Unrealistic scheduling ❑
Unsafe act of others H Inadequate fall protection ❑ Poor process design ❑
Form:SAF002
Updated 0111

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� T .�� Incident Report
T_
a
Report Number: 201101115
Incident Type: Spill(Oil, Chemical, non-sewage) On-Site Contact:
Category: Incident First/Mid/Last Name: Gerry Brucker
Incident Started: 05/24/2011 Company Name: Charah
County: Buncombe Phone: [phone]
City: Pager/Mobile Phone: / [phone]
Farm#:
Responsible Party:
Reported By:
Owner: Asheville Airport First/Mid/Last Name: Shannon Langley
Permit: Company Name:
Facility: Asheville Airport Address: 410 S Wilmington St
First Name:
Middle Name: City/State/Zip: Raleigh NC 27602
Last Name: Phone: [phone]
Address PO Box 807 Pager/Mobile Phone: / [phone]
City/State/Zip: Fletcher NC 28732
Phone:
Material Category: Estimated Qty: UOM Chemical Name Reportable Qty.lbs. Reportable Qty. kgs.
Other 44000 pounds
DD:MM:SS Decimal Position Method: Map interp by digital or man.extraction
Latitude: +35°27'31" 35.458600 Position Accuracy: Nearest Second
Longitude: --82°32'05" -82.534700 Position Datum: Unknown
Location of Incident: Glenn Bridge Road near Asheville Airport
Address: 290 Glenn Bridge Rd
City/State/Zip Arden NC 28704
Report Created 06/03/11 09:41 AM Page 1

Cause/Observation: Directions:
On the morning of May 24,2011,a dump truck hauling U.S.Highway 26 east to exit 40(191/280).Turn left onto highway 280.At
approximately 22 tons of coal ash overturned at 290 Glenn the next intersection,turn left on Rockwood Road.At the next
Bridge Road in Arden,NC.The dump truck was moving coal ash intersection,turn left on Glenn Bridge Road.The site is approximately
from the Progress Energy Asheville Steam Generating Plant to 500 feet on right.
the Asheville Airport coal ash structural fill site 4.Much of the
coal ash came to rest in dry drainage ditch in front of the
residence at 290 Glenn Bridge Road.
Action Taken: Comments:
The contractor(Charah)for the Asheville Airport coal ash I was on site the afternoons of May 24 and May 25.A backhoe and
structural fill sit 4 responded quickly and was on site(upon my several dump trucks were onsite during the intial visit.They(Charah)
arrival)with a backhoe and dump trucks removing all of the coal appeared to be removing all traces of coal ash and some underlying soil
ash.The contractor went as far as removing the subsoil beneath and hauling it to the structural fill site.The site was dry with no
the coal ash.The contractor also put down new sod and new precipitation during the succeding 24 hours.I returned the next day and
riprap in the drainage ditch.The Charah site manager in charge workers(Charah)were onsite laying down fresh sod and trees.All traces
of the cleanup was Gerry Brucker. of coal ash have been removed with fresh rip rap within the ditch to
control site runoff.Pictures are available.
Incident Questions:
Did the Material reach the Surface Water? No Conveyance:
Surface Water Name?
Did the Spill result in a Fish Kill? No Estimated Number of fish?
If the Spill was from a storage tank indicate type. (Above Ground or Under Ground)
Containment? Yes
Cleanup Complete? Yes
Water Supply Wells within 1500ft: Unknown Groundwater Impacted : No
Event Type Event Date Due Date Comment
Incident closed
Requested Additional Information
Referred to Regional Office-Primary Contact
Report Entered 2011-05-26 04:53:00
Report Created 06/03/11 09:41 AM Page 2

Incident Start 2011-05-24 03:29:00
Report Received 2011-05-24 03:29:00
Standard Agencies Notified:
Agency Name Phone First Name M.I. Last Name Contact Date
Other Agencies Notified:
Agency Name Phone First Name M.I. Last Name Contact Date
DWQ Information:
Report Taken By: Report Entered By: Regional Contact:
Brett Laverty Brett Laverty
Phone:
Date/Time: 2011-05-24 03:29:00 PM 2011-05-26 04:53:00 PM
Referred Via: Phone
Did DWQ request an additional written report?
If yes,What additional information is needed?
Report Created 06/03/11 09:41 AM Page 3

n A HU
NCDENR
i North Carolina Department of Environment and Natural Resources
I
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director . Secretary
- _ - - AQUIFER_PROTECTION
September 24, 2010
Alan Meadwell
Senior Environmental Technical Specialist
Environmental Services
Progress Energy Carolinas, Inc.
410 S. Wilmington Street, PEB 4A
Raleigh, NC 27601
Subject: Asheville Structural Fill Project
Area 4 Phase 1 and 1A Plan Review Only
Progress Energy Ash Distribution Program
Permit No. WQ0000020
Buncombe County
Dear Mr. Meadwell:
On September 14, 2010, the Division of Water Quality's, Asheville Office received Progress Energy's plans for
application of ash structural fill at the Asheville Airport in accordance with your permit (WQ0000020) and 15A NCAC 02T
.1200. Specifically, the plans are for structural fill to be located in area 4 and include phases 1 and IA.
Based upon our review of the materials submitted, the Division is requiring the following additional information
necessary to process the application:
1. According to 15A NCAC 02T .1204 (d), information shall be provided to the Division of Water Quality that
describes and explains site-specific engineering or institutional controls proposed to prevent adverse impacts to
public health and the environment. Submit a project narrative that includes a general overview, timeline, footprint
(acreage) and estimated ash volume by project phase, environmental impact statement, groundwater monitoring
plan for both the interim and post-construction periods, and describe how the integrity of the structural fill/liner
will be maintained during airport expansion and ultimately as an airport runway;
2. To demonstrate compliance with Permit Condition IV.1.a.ii., property Ownership Documentation of the site where
the CCPs are to be used shall be provided to the Division. This documentation shall consist of: legal
documentation of ownership or an easements meeting the requirements of 15A NCAC 02L .0107 (f) as required
by permit.;
3. Submit a list of project personnel and their contact information;
4. The general notes of the plans state to "refer to technical specifications for the materials and construction
requirements including the construction quality assurance (QA) and control program testing requirements".
Please submit a copy of this document to the Aquifer Protection Section (APS);
5. Upon project completion, please submit a complete copy of the post construction QA documentation;
6. Based on the plans, there doesn't appear to be a drainage layer between the compacted soil layer and compacted
fly ash (closure cap section). Please describe why such a layer would not be necessary. Additionally, please
provide a brief description of the cover (that top most, exposed layer above compacted soil fill) that will be used
both temporarily and long-term including drainage patterns;
7. The Division recommends that in lieu of a leachate pipe that penetrates the liner (at the boot), a vertical
sump/pump system (traditional subtitle D style leachate collection system) be used to collect structural fill
leachate;
AQUIFER PROTECTION SECTION—Asheville Regional Office(ARO)
2090 U.S.70 Highway,Swannanoa,NC 28778.8211
Phone:[phone] l FAX:[phone]
Customer Service:1-877-623-6748 NonfthCarolina
Internet www.ncwaterauality.org
An Equal Opportunity 1 Affirmative Action Employer ���������

Progress Energy/Asheville Airport �J
Page 2/2
September 24, 2010
8. According to 15A NCAC 2T .0200, a pump and haul permit (industrial wastewater) will be required for collection
and disposal of wastewater from the lechate system;
9. Please notify the Division when the leachate collection system can be inspected;
10. Please submit all currently available data (e.g., water levels) from onsite wells or piezometers. This information
will be used to verify the seasonal high water table as shown on the plan;
11. The two 1,500 gallon grit chambers appear to only be associated with phase 1A based on the plans submitted;
please describe the method of leachate collection/storage during Phase 1 construction. Also, please provide
information describing how the leachate storage volume was calculated and how the storage tanks will be
maintained to prevent overfilling;
12. The Division will require a onetime analysis of the leachate as each phase nears completion. A list of analytes is
given below. All analytical results will be submitted to this office;
13. Please identify all water supply wells within a 1500 foot radius of the project site through a door-to-door survey.
This should include the residence (655 Old Fanning Bridge Road) near Westfield Road and the utility building
located directly across Bolston Highway (SR 280/191), which is owned by the Warrior Golf Management LLC;
14. The Division believes the interim phase wells (PMW-1, 2, 3 and 4) are necessary to install and monitor given the
potential longevity of the complete (phase 1, 1A and 2) installation. All monitoring wells should be developed to
bedrock refusal (transition zone) and have an adequate supply of water for sampling. In order to avoid
suspended sediments, all monitoring wells should be properly developed prior to sampling. Surface water
monitoring sites will be established at the confluence of two ephemeral streams draining the project area;
15. Ground and surface water monitoring is to begin following completion of Phase 1. Wells and streams are to be
sampled within 6 months of phase I completion with analytical results submitted to this office. Data collected at
each monitoring site should include the following field parameters and analytes: arsenic, barium, boron,
cadmium, chloride, chromium, copper, fluoride, lead, manganese, mercury, nickel, nitrate, nitrite, pH, selenium,
silver, specific conductivity, sulfate, temperature, total dissolved solids (TDS), total suspended solids (TSS), total
organic carbon, water level, and zinc;
16. Soil assessment is necessary prior to disturbing any material in the [phase 2] shooting range area. If prior soil
assessment for lead has been performed, please submit this information to APS;
17. The landowner where the ash is applied and compliance boundary established shall within 90 days of completion
of phase 1, comply with 15A NCAC 2L .0107(f); and,
18. Updated construction plans and a project meeting will be required before the start of phase 2 construction.
The above-referenced information is to be submitted prior to placing any ash. If you should have any questions,
please do not hesitate to contact me directly at 828.296.4680 or Brett Laverty at 828-296-4681.
Sincerely,
G. Landon Davidson, LG
Regional Supervisor Aquifer Protection Section
cc: Jon Risgaard-APS ND CO
Director—Asheville Airport
AQUIFER PROTECTION SECTION—Asheville Regional Office(ARO)
2090 U.S.70 Highway,Swannanoa,NC 28778-8211
Phone:[phone] FAX:[phone]
Customer Service:1-877-623-6748 NorthCarohna
Internet:www.ncwaterguality.org
An Equal Opportunity\Affirmative Action Employer Natura!!il

41W-
Compliance Inspection Report
Permit: WQ0000020 Effective: 02/17/06 Expiration: 02/28/14 Owner: Progress Energy Carolinas Inc
SOC: Effective: Expiration: Facility: Progress Energy Ash Distribution Program
County: Unknown PO Box 1551
Region: Asheville
Contact Person: Paula J Sims Title: Vice President-Fossil Ge Phone:
Directions to Facility:
From Interstate 26 East take the Long Shoals Rd. Exit. Turn left onto Long Shoals Rd. and go approximately 1 mile to facility entrance
on the right.
Systemt lass ifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 09/16/2010 Entry Time: 10:00 AM Exit Time: 11:30 AM
Primary Inspector: Edward M Williams Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type:Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503 exempt)
Facility Status: ❑ Compliant Q Not Compliant
Question Areas:
Miscellaneous Questions N Record Keeping Sampling
(See attachment summary)
Page: 1

Permit:WQ0000020 Owner-Facility: Progress Energy Carolinas Inc
Inspection Date: 09/16/2010 Inspection Type:Compliance Evaluation Reason for Visit:Routine
Inspection Summary:
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required? n n n n
Are GW samples from all MWs sampled for all required parameters? n n n n
Are there any GW quality violations? ❑
Is GW-59A certification form completed for facility? ❑ n n
Is a copy of current permit on-site? 9 n Q n
Are current metals and nutrient analysis available? n n n n
Are nutrient and metal loading calculating most limiting parameters? M n n n
a. TCLP analysis? Ili n n n
b. SSFA(Standard Soil Fertility Analysis)? n n n n
Are PAN balances being maintained? n n 41
Are PAN balances within permit limits? n n 9i n
Has land application equipment been calibrated? n n on n
Are there pH records for alkaline stabilization? n n n
Are there pH records for the land application site? n n on n
Are nutrient/crop removal practices in place? ❑ n UA ❑
Do lab sheets support data reported on Residual Analysis Summary? n n n
Are hauling records available? a n ❑ n
Are hauling records maintained and up-to-date? 1 I1 n n n
#Has permittee been free of public complaints in last 12 months? �; ¢ e p4< n n n n
Has application occurred during Seasonal Restriction window? n n ❑ n
Comment:
Sampling Yes No NA NE
De crib sa pling:
TQ G�cry U r�rz
Is sampling adequate? n n n n
Is sampling representative? 9 ' ❑ n ❑
Comment:
Page: 2

�I
NCD►ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly laves Perdue Ooleen H.Sullins Dee Freen ar,,
Governor Director Secretary
Aquifer Protection Section
May 26, 2010
Garry A. Whisnant
Asheville Plant Manager
Progress Energy Carolinas, Inc.
200 CP&L Drive
Arden, NC 28704
RE; Asheville Airport Structural Fill Project
Split Sampling Data
Dear Mr. Whisnant,
The initial monitoring event (November 2009) for the Asheville Regional Airport's_coal
ash structural fill indicated one or more monitoring wells exceeding groundwater quality
standards (15A NCAC 2L. 0202)for iron, manganese, and/or lead. The Division's response was
to observe sample collection and to split samples during the winter monitoring cycle. The
purpose of this letter is to inform you of our findings and to highlight additional action items that
will need to be addressed.
Brett Laverty (NCDWQ), Laurie Moorhead (PEC), and Marie Swann (Pace Analytical)
were present during the March 9, 2010 field activities. Mr. Swann was responsible for well .
purging and compliance sample collection. Split samples were collected by Mr. Laverty and
shipped to the Division of Water Quality laboratory for analysis. Samples were collected from a
common sampling bucket and split into unfiltered and filtered samples. The filtered sample was
created using a 45 micron glass microfiber filter and syringe.
The most obvious impediment to good data collection is the issue of turbidity and the
subsequent problem of matrix interference, which refers to sample characteristics that may
interfere with laboratory analysis. It was observed that all four monitoring wells are affected by
turbidity to varying degrees (Photo 1). This condition is primarily a result of poor well
construction and/or poor well development. It is recommended that all monitoring wells be
properly developed before the next monitoring cycle. Recommended monitoring well
development methods include pumping, overpumping, bailing, and backwashing. When properly
executed, these methods create a graded filter pack with progressively finer outer layers to help
filter out sediments. The construction of a new .monitoring well(s) may be necessary if well
development methods fail to reduce the levels of turbidity.
one
VoithCarolintt
Awtrrrrllly
North Carolina Division of Water Quality—Asheville Regional Office 2090 U.S.Hichway 70 Swannanoa.NC 28778 Phase(828)_96-.5W
Aquifer Protection Section FAX (82S)2119-7043
Customer Smice 1-877-623-6748
Internet h2o.enr-state.nems

Page 2
Another observation is the manner in which the monitoring wells are purged prior to
sampling. The current method consists of removing an unknown quantity of water until field
readings (i.e. temperature, pH, & specific conductivity) are sufficiently stable. Aquifer Protection
Section (APS) recommends initially calculating the volume of water standing in the well followed
by the removal of three well volumes or until pH, temperature, and conductivity vary by no more
+ 10%for successive volumes.
Analytical.results indicate measurable concentrations of aluminum, arsenic, barium,
boron, copper, iron, magnesium, manganese, nickel, nitrate, sodium, and zinc. Iron and
manganese were the only constituents detected above groundwater quality standards (15A
NCAC 2L. 0202). Incidentally, iron and manganese had the highest relative percent difference
between unfiltered samples, which is most likely due to the high turbidity levels. More
importantly, filtered samples indicate iron concentrations below groundwater quality standards in
three of the monitoring wells.
In summary, the Asheville Regional Office (ARO) is recommending that all monitoring
wells be properly developed before the next monitoring cycle. Until the turbidity issue is properly
addressed, it may be advantageous to document turbidity and/or total suspended solid
concentrations during each monitoring event. It is also recommended that the methodology for
well purging be updated to include a minimum of three well volumes followed by stable field
parameters (i.e. pH, temperature, and conductivity).
The Division appreciates your prompt attention in making the necessary changes to your
groundwater monitoring program. Please contact me if you have any questions or concerns. I
can be reached at [phone] or brett.lavertyC&.ncdenr.gov.
Sincerely,
l ,'Y lac.�..
Brett Laver£
Hydrogeologist
Aquifer Protection Section
Asheville Regional Office
Cc:
Laurie Moorhead-Progress Energy Carolinas, Inc
�4�

Page 3
Photo 1: Sample collection at monitoring well MW-4A.
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Page 4
Table 1: Water quality results for Asheville Structural Fill Project, March 9, 2010
Well'Site n sSampled By (Un).Filtered Arsenic Barium Boron Cadmium-, Chromium Fz°
2L Groundwater Limit 0.010 " 0.7 0.7 0.00175 :0101
Pace Ana al PQL 0.005 0.005, 0.05 0.001 0.005
.°D1NQ PQl_ .. _ 0.00 . 0.010 s . `° 0.001 ' 0.01
Units z mg/l,
Mark Swan OF < 0.005 0.022 0.068 < 0.001 < 0.005
Brett Laverty OF < 0.002 0.018 **NA < 0.001 < 0.01
MW-1A Brett Laverty *F 0.0025 0.012 **NA < 0.001 < 0.01
*"*Relative.Percent Difference .: , ° : 20.0O%
Mark Swan OF < 0.005 0.022 0.071 < 0.001 < 0.005
Brett Laverty OF < 0.002 0.021 **NA < 0.001 < 0.01
MW-2A Brett Laverty *F 0.002.3 0.021 **NA < 0.001 < 0.01
***Relative­Percent Difference 4.7%
Mark Swan OF < 0.005 0.053 0.067 < 0.001 < 0.005
Brett Laverty OF < 0.002 0.050 **NA < 0.001 < 0.01
MW-4A Brett Laverty *F 0.0042 0.057 **NA < 0.001 < 0.01
***Relative Percent Difference 6.8/o '
Mark Swan OF < 0.005 0.049 0.067 < 0.001 < 0.005
Brett Laverty OF < 0.002 0.044 **NA < 0.001 < 0.01
MW-5 Brett Laverty *F < 0.002 0.042 **NA < 0.001 < 0.01
***Relative Peraent'Difference �_ R- 10.8%a �
*F-samples filtered with a Whatman®45 micron glass microfiber filter
**NA- Not Analyzed
***Relative Percent Difference -Comparison is between unfiltered samples

Page 5
Table 1: Water quality results for Asheville Structural Fill Project, March 9, 2010
W Iron Lead Manganese X"I",
"'0.' fGO-
rQ '-'wP-' Y%j
1.411
:
Pace.Anal"yticalP�QL 0000005
4 ;
0
'
-0 06 01 OW O
N
Units'
Mark Swan OF < 0.005 0.783 < 0.005 0.033 0.00000134
MW-1A Brett Laverty OF < 0.002 0.370 < 0.01 0.027 < 0.0002
Brett Laverty *F < 0.002 0.190 < 0.01 0.012 < 0.0002
***FZelative Percent V
-Di 6re,-cp�'-' A "4�I� '0
Mark Swan OF < 0.005 0.301 < 0.005 0.020 < 0.0000005
Brett Laverty OF < 0.002 --0.220 < 0.01 0.019 < 0.0002
MW-2A Brett,Laverty *F < 0-002 0.072 < 0.001 0.018 < 0.0002
RelativeF'ercent
Mark Swan OF < 0.005 '2.03 < 0.005 8.06 0.000145
Brett Laverty OF 0.007 -7.60 < 0.01 5.40 < 0.0002
MW-4A Brett Laverty *F 0.004 -3.00 < 0.01 8.00 < 0.0002
***Relative Percent Difference;`Mark Swan OF < 0.005 1.41 < 0.005 0.166 0.00000856
MW-5 Brett Laverty OF 0.002 0.110 < 0.01 0.130 < 0.0002
Brett Laverty *F 0.002 < 0.05 < 0.01 0.120 < 0.0002
E.
`-
***Relative "Off1( 5 T7 pont 2
*F-samples filtered with a Whatman®45 micron-glass microfiber filter -
**NA-Not Analyzed
***Relative Percent Difference -Comparison between unfiltered samples

Page 6
Table 1: Water quality results for Asheville Structural Fill Project, March 9, 2010
Well Site Sampled By (Un) Filtered -`Nickel Nitrate` Nitrite Selenium,; Silver
m L`Grounduvater Limit �e 0.1
�10 , . 1 0.02- n 0..01750
2
_ _
F a Pace,Analytical PQL 0.005 :0.1" 0.1
D1flIQ PQL 0.01:' 0.02 0.�01 0.005 0.005, .
rrigLl
Units..
Mark Swan OF < 0.005 < 0.1 < 0.1 < 0.01 < 0.005
MW-1A Brett Laverty OF < 0.01 **NA **NA < 0.005 < 0.005
Brett Laverty *F < 0.01 **NA **NA < 0.005 < 0.005
*_**Relative PercentDifference `
Mark Swan OF < 0.005 < 0.1 < 0.1 < 0.01 < 0.005
Brett Laverty OF < 0.01 **NA **NA < 0.005 < 0.005
MW-2A Brett Laverty *F < 0.01 **NA **NA < 0.005 < 0.005
Relative Percent Difference,�
Mark Swan OF 0.005 0.36 < 0.1 < 0.01 < 0.005
Brett Laverty OF < 0.01 **NA **NA < 0.005 < 0.005
MW-4A Brett Laverty *F < 0.01 **NA **NA < 0.005 < 0.005
Relative`Percent Difference
Mark Swan OF < 0.005 3.00 < 0.1 < 0.01 < 0.005
Brett Laverty OF < 0.01 **NA **NA < 0.005 < 0.005
MW-5 Brett Laverty *F < 0.01 **NA **NA < 0.005 < 0.005
***Relative Percent-Difference< °
*F—samples filtered with a Whatman®45 micron glass microfiber filter
**NA— Not Analyzed
***Relative Percent Difference — Comparison between unfiltered samples

Page 7
Table 1: Water quality results for Asheville Structural Fill Project, March 9, 2010
Well Site Sampled By (Un) Filtered eE Sulfate €° Zinc Aluminum Magn°esiurn Sodiurrif -
A
, -S
2L Groundwater:°Lirriit 250 1 05
Pace:Analytical`PQL 5 0 0.1
DWQ PQLx; 2 0.01 " O.QS .0.01 0 1
Units"
Mark Swan OF
< 5 < 0.01 **NA **NA **NA
MW-1A Brett Laverty OF **NA < 0.01 0.340 1.50 2.50
Brett Laverty *F **NA < 0.01 0.270 1.40 2.60
- Relative Percen t,,Diff6rence°
Mark Swan OF < 5 0.013 **NA **NA **NA
MW-2A Brett Laverty OF **NA < 0.01 0.110 1.40 1.60
Brett Laverty *F **NA < 0.01 0.098 1.40 1.70
**Relative Percent Difference.
Mark Swan OF < 5 0.017 **NA **NA **NA
MW-4A Brett Laverty OF **NA 0.020 2.90 1.10 0.84
Brett Laverty *F **NA 0.021 1.20 1.30 1.40
***Relative Percent`Difference 16.26% °
�.
Mark Swan _ OF < 5 0.022 **NA **NA **NA
MW-5 Brett Laverty OF **NA 0.018 0.160 2.00 1.70
Brett Laverty *F **NA 0.019 0.082 2.00 1.80
***Relative Percent Difference t 0%:
*F—samples filtered with a Whatman° 45 micron glass microfiber filter
**NA— Not Analyzed
***Relative Percent Difference—Comparison between unfiltered samples

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H.Sullins Dee Freeman
Governor Director ' Secretary
November 03, 2009
Gary A.Whisnant
Manager, Asheville Steam Plant
Progress Energy Carolinas, Inc.
200 CP&L Drive
Arden, NC 28704
Subject: Review of Progress Energy Asheville Steam Electric Plant 2008 Mercury and Selenium Monitoring of Fish
in the French Broad River Report, NPDES Permit No. NC0000396
Environmental Sciences Section staff(Jeff DeBerardinis) have reviewed the document: "Mercury and Selenium
Monitoring of Fish in the French Broad River Buncombe County, North Carolina"as it relates to NPDES Permit
NC0000396 (A.(1). Effluent Limitations and Monitoring Requirements and A.(12) Fish Tissue Sampling). The report was
received by the Environmental Sciences Section on October 06, 2009.
There have been no obvious shifts in the selenium and mercury concentrations in fish in the French Broad River near the
Asheville Steam Electric Plant with respect to pre-and post-operation of the Flue Gas Desulfurization (FGD) system
which became operational in December 2005. All selenium concentrations in 2009 were well below the North Carolina
Department of Health and Human Services(NCDHHS)criterion of 10 pg/g (parts per million). Upon reviewing Progress
Energy's 2006—2009 reports,the pattern of mercury exceedances(equal to or greater than the NCDHHS criterion of 0.4
pg/g) at the three monitoring stations does not seem to have changed. In 2009, the sampling location upstream from the
plant had the majority of the mercury exceedances. Because some of the mercury concentrations in fish in this section of
the river continued to exceed the state's action level, these data are being forwarded to Dr. Ken Rudo of the North
Carolina Department of Health and Human Services. .
If you have any questions, please do not hesitate to contact me or my staff.
Yours truly,
�y
Jay Sauber
Acting Chief, Environmental Sciences Section
cc: Jeff Deberardinis, Environmental Sciences Section
Roger Edwards,Asheville Regional Office
Eric Fleek, Environmental Sciences Section
Jeff Poupart, Surface Water Protection Section
Ken Rudo, North Carolina Department of Health and Human Services
Bryn H. Tracy, Environmental Sciences Section
1621 Mail Service Center,Raleigh,North Carolina 27699-1621, One
Location:4401 Reedy Creek Road,Raleigh,North Carolina 27607 N01 hCa.TO11Ila.
Phone:[phone] FAX:[phone] Customer Service:1.877-623.674B '/y��l/�
Internet:http:llh2o.enr.state.nc,us/esbl �/a'�alK6
An Equal Opportunity 1 Affirmative Action Employer

STATION: 3439000 LATITUDE: 35.14222
STATION DESCRIPTION: French Broad River at Rosman LONGITUDE: -82.82389
COUNTY: Transylvania BASIN: 040301
mg/Kg
Date Species DWQ# Length(mm) Weight(g) Hg As Cd Crt Cu Ni Pb Zn Se TI
10/17/1991 BRB 91-4446 231 178 0.07 <.50 <,1.0 <.25 0.35 <.50 <.50 5.5 <.50
10/17/1991 GRH 91-4443 363 502 0.22 <0.50 <.10 0.33 0.56 <50 <.50 8.4 <50
10/17/1991 RBS 91-4445 187 135 0.29 <.50 <.10 <.25 0.22 <.50 <.50 7.2 <,50
10/17/1991 SMB 91-4444 278 287 0.7S <.50 <.10 <.25 0.28 <.50 <.50 5.7 <.50
8/12/1997 BRB 97-7485 175 84 0.22 <1.0 <0.1 <0.25 <7.1 <0.50 <0.50 3.5
8/12/1997 BRT 97-7468 196 79 0.05 <1.0 <0.1. <0.25 2.8 <,).50 <0.70 37
8/12/1997 GRH 97-7473 272 205 0.1.5 <1.0 <0.1. <0.25 <0A0 <0.50 <0.50 6.8
8/12/1997 GRH 97-7474 285 234 0,17 <1.0 <0.1 <0.25 <0.1.0 <0.50 <0.50 5.7
8/12/1997 GRH 97-7475 300 333 0.15 <1.0 <0.1 <0.25 <0.10 <0.50 <0.50 3.2
8/12/1997 GRH 97-7476 350 513 0.06 <1.0 <0.1 <0.25 <0.10 <0.50 <OS0 2.8
8/12/1997 GRH 97-7477 365 452 0.69 <1.0 <0.1 <0.25 <0.10 <0.50 <0.50 5.0
'8/12/1997 GRH 97-7479 368 569 0.39 <1.0 <0.1 <0.25 <0.10 <0.50 <0.50 5.2
8/12/1997 GRH 97-7478 372 503 0.46 <1..0 <0.1 <0.25 <0A0 <0.50 <0.50 5.5
8/12/1997 GRH 97-7481 399 763 0.73 <1.0 <0.1. <0125 <0.10 <0.50 <0. o 7.0
8/12/1997 GRH 97-7480 400 699 0.63 <1.0 <0.1 <0.25 <0.10 <0.50 <0.50 7.0
8/12/1997 RBS 97-7482 133 45.7 0.24 <1.0 <0.1 <0.25 <0.10 <0.50 <0.50 9.1
8/12/1997 RBS 97-7483 150 76.6 0.26 <1.0 <0.1 <0.25 0.17 <0.50 <0.50 11
8/12/1997 RBS 97-7484 161 126.5 0.50 <1.0 <0.1 <0.25 <0A <0.50 <0.50 9.5
8/12/1997 RBT 97-7469 216 95 0.05 <1.0 <0.1 <0.25 <0.10 <0.50 <0.50 18
8/12/1997 RBT 97-7470 251 155 0.04 <1.0 <0A <0.25 <110 <0,50 <0.50 6.2
8/12/1997 RBT 97-7471 288 248 0.04 <1.0 <0,1 <0,25 <0,10 <0,50 <Mo 5.2
8/12/1997 RBT 97-7472 335 329 0.12 <1.0 <0,1 <0.25 <0,10 <9.50 <0,50 3.8
8/12/1997 SMB 97-7467 177 175 0.15 <1.0 <0.1 <0.25 0.47 <0.50 <0.50 16
Page 1 of 8

STATION: 3451500 LATITUDE: 35.56556
STATION DESCRIPTION: French Broad River at Asheville LONGITUDE: -82.57139
COUNTY: Buncombe BASIN: 040302
mg/Kg
Date Species DWQ# Length(mm) Weight(g) Hg As Cd Crt Cu Ni Pb Zn Se TI
9/14/1990 BKB 90-4306 254 252.2 0,06 <.50 <.10 <.25 0.38 <.50 <.50 6.2 <.50
9/14/1990 C 90-4300 375 786.8 0.04 <.50 <,10 0.48 2.6 <.50 0.65 12 0.63
9/14/1990 CHC 90-4305 303 278.6 0.15 <.50 <,10 <.25 0.6 <.50 <,50 9.2 <.50
9/14/1990 LMB 90-4303 282 439.8 0.25 <,50 <A0 <,25 0.21 <.50 <.50 5.8 <.50
9/14/1990 RBS 90-4302 169 85.3 0A.0 <.50 <.10 <.25 0.3 <.50 <.50 15 <.50
9/14/1990 RHS 90-4301 372 620.1 0.06 <,50 <.10 0.4 1.7 <.50 <.50 1.3 <,50
9/14/1990 SMB 90-4304 237 200.6 0.22 <,50 <.10 <.25 1.3 <.50 <,50 7.4 <.50
Page 2of8

STATION: 3453500 LATITUDE: 35.79528
STATION DESCRIPTION: French Broad River at Marshall LONGITUDE: -82.68306
COUNTY: Madison BASIN: 040304
mg/Kg
Date Species DWQ# Length(mm) Weight(g) Hg As Cd Crt Cu Ni Pb Zn Se TI
9/23/1981 NHO 81-408 201 93.2 0.04 OAK (50K 0.50K 0.67 1..OK 1..tiK 15
9/23/1981 RBS 81-981 110 26.8 0,04 0.5K 0.5K 0.68 1.1 1.0K i.OK 29
9/9/1985 BRH 85-2381 406 845 0.18 0.10K O.25K 0.34 0.50K 0.89 9.7
10/15/1985 BRH 85-2387 360 543 0.06 0.10K 0.25K 0.48 0.50K 0.50K 17
10/15/1985 BRH 85-2386 384 600 0.11 0.10K 0.25K 0.43 01.50K 0.50K 19
10/15/198S BRH 85-2384 388 803 0.11 0:10K 0.25K 0.3 030K 0.50K 7.7
10/15/1985 BRH 85-2385 388 678 0.1.2 0,10K 0.25K 0.26 030K 0.50K 7.2
10/15/1985 BRH 85-2382 404 909 OA6 0,10K 0.25K 0.33 01.50K ,).50K 7.8
10/15/1985 BRH 85-2383 404 771.5 0,113 0.10K 0.251< 0.86 050K 0.50K 20
10/15/1985 BRH 85-2401 424 981 0.21 0.10K 0.25K 0.39 0.50K 0.50K 9.7
10/15/1985 NHO 85-2392 262 206 0.10 0.12 0.25K 0.43 0.50K 0.50K 15
10/15/1985 NHO 85-2390 264 224 0.1.5 0.10K 0.25K 0.29 0.50K O.SOK 10
10/15/1985 NHO 85-2391 271 224 0.09 0.1.0K 0,25K 0.42 0.50K 0.50K 15
10/15/1985 NHO 85-2389 292 277.3 0.1.5 0.10K 0.25K 0.31 0.50K 0.509 15
10/15/1985 NHO 85-2388 365 667 (MI. 0.10K 0.2.5K 0.41 0.501L 0.5CK 7.8
10/15/1985 RBS 85-2400 154 66.4 0.05 0.10K 0.25K 0.51 0.50K 0.50K 21
10/15/1985 RBS 85-2399 174 95.4 0.0S 0.10K 0.25K 0.43 0.50K 0.50K 23
10/15/198S RBS 85-2397 186 124.8 0.04 0.10< 0.25< 0.17 0.50K 0.50K 17
10/15/1985 RBS 85-2395 191 145 0.06 0.10K 0.25K 0.14 0.50K 0.50K 7.6
10/15/1985 RBS 85-2396 193 123 0.09 0.10K 0.25K 0.16 0.50K 0.50K 13
10/15/1985 RBS 85-2398 196 134 0A1 0,10K 0.25K 0.32 0.50K 0.50K 20
10/15/198S SMB 85-2394 140 37 0.06 0.1.0K 0.215 K 0.3 0.50K 0.50K 19
10/15/1985 SMB 85-2393 265 266 0.14 0.10K 0.25K 0.22 0.50K 0.50K 6.9
8/28/1986 NHO 86-2548 181 61.5 0.04 0.17 0.25K 0.51 0.50K 0.50K 6.8
8/28/1986 NHO 86-2546 268 208 0.15 0.10K 0.25K 0.31 0.50K 0.50K 1.8
8/28/1986 NHO 86-2545 290 260 0.09 0.10K 0.25K 0.14 0.50K 0.50K 4.7
Page 3 of 8

STATION: 3453500 LATITUDE: 35.79528
STATION DESCRIPTION: French Broad River at Marshall LONGITUDE: -82.68306
COUNTY: Madison BASIN: 040304
mg/Kg
Date Species DWQ# Length(mm) Weight(g) Hg As Cd Crt Cu Ni Pb Zn Se TI
8/28/1986 NHO 86-2547 300 264 0.31 0.45 0.25K 0.42 0.50K 0.50K 3
8/28/1986 RBS 86-2543 175 94 0.1.3 0,10K 0.25K 0.2 0.50K 0.50K 1.4
8/28/1986 RBS 86-2544 175 90 0.31-1 0.10K 0.25K 0.54 0.50K 0.50K 15
8/28/1986 RBS 86-2542 204 130 0.10 0.10K 0.25K 0.22 0.50K 0.50K 1.8
8/28/1986 SMB 86-2541 140 26.5 0.03 0.10K 0.25K 0.26 0.50K 0.50K 4.4 ,
8/28/1986 SMB 86-2540 221 121 0.10 0,10K 0.25K 0.39 0.50K 0.50K 12
8/28/1986 SMB 86-2538 290 260 0.23 0.10K 0,25K 0.61 0.50< 0.50K 3.2
8/28/1986 SMB 86-2539 380 732 0.19 0.10K 0.25K 0.19 0.50K 0.50K 11
Page 4 of 8

STATION: DWQPT-7 LATITUDE: 35.89444
STATION DESCRIPTION: French Broad River at Hot Springs LONGITUDE: -82.82306
COUNTY: Madison BASIN: 040304
mg/Kg
Date Species DWQ# Length(mm) Weight(g) Hg As Cd Crt Cu Ni Pb Zn Se TI
10/17/1991 BKB 91-4448 301 510 0.07 <.50 <.1.0 <.25 0.38 0.65 <.50 4.2 <.50
10/17/1991 CHC 91-4449 334 399 0.12 <.50 <.10 <.25 0.81 <.50 <.50 4.9 <.50
10/17/1991 RBS 91-4450 179 125 0.07 0.5 <.10 0.34 0.24 <.50 <.50 7.4 <.50
10/17/1991 RHS 91-4447 417 996 0.10 <.50 <.10 0.32 0.61 <.50 <.50 9.8 <,50
10/17/1991 SMB 91-4451 309 420 0.16 <.50 <.10 <.25 1.8 <.50 <30 5.8 <.50
8/13/1997 BKS 97-7458 256 237 0.13 <1.0 <0.1 <0.25 0.15 <O.SO <0.50 10
8/13/1997 C 97-7451 531 2194 0.13 <1.0 0.82 <0.25 2.5 <0.50 <0.50 35
8/13/1997 C 97-7453 550 2316 0.12 <1-0 0.20 <0.25 1.8 <13.50 <01 @ 45
8/13/1997 C 97-7452 570 2349 0.15 <1.0 1.9 <0.25 3.6 <0.50 <0.50 50
8/13/1997 CHC 97-7464 303 217 0.14 <1.0 <0.1 <0.25 0.20 <0.50 <0.50 4.4
8/13/1997 CHC 97-7466 366 489 0.14 <1.0 <0.1 <0.25 0.17 <0.50 <0.50 3.7-
8/13/1997 CHC 97-7465 369 413 0.25 <1.0 <0.1 <0.25 0.26 <0.50 <0.50 5.5
8/13/1997 FHC 97-7463 266 197 0.18 <1.0 <0.1 <0.25 0.25 <0.50 <0.50 3.7
8/13/1997 GRH 97-7459 294 310 0.15 <1.0 <0.1 <0.25 0.10 <0.50 <0.50 3.5
8/13/1997 GRH 97-7460 308 340 0.21. <1.0 <0,1 <0.25 0.85 <0.50 <0.50 7.1
8/13/1997 GRH 97-7461 327 475 0.23 <1.0 <0.1 <0.25 0.31 <0.50 <0.50 7.1
8/13/1997 GRH 97-7462 338 460 0.24 <1.0 <0.1 <0.25 0.20 <0.50 <0.50 5.6
8/13/1997 - QUB 97-7454 466 1268 0.18 <1.0 <0.1 0.36 0.71 <0.50 <0.50 11
8/13/1997 SBU 97-7455 393 810 0.07 <1.0 <0.1 <0.25 0.45 <0.50 <0.50 12
8/13/1997 SMB 97-7457 270 280 0.28 <1.0 <0.1 <0.25 0.23 <OSO <0.50 4.9
8/13/1997 WE 97-7456 543 1373 0.32 <1.0 <0.1 <0.25 0.29 <0.50 <0.50 8.9
Page 5 of 8

STATION: FBR001 LATITUDE: 35.13972
STATION DESCRIPTION: West Fork French Broad River above US-64 near Rosman LONGITUDE: -82.85083
COUNTY: Transylvania BASIN: 040301
mg/Kg
Date Species DWQ# Length(mm) Weight(g) Hg As Cd Crt Cu Ni Pb Zn Se TI
10/18/1984 RBT 84-1931 109 10.1 0.07 0.10K 0.25K 0.81 O.SOK 0.50K
10/18/1984 RBT 84-1932 251 162 0.11 0.10K 0.25K 0.6 0.50K 0.50K 9.8
10/18/1984 RBT 84-1933 255 189 0.13 0.10K 0.25K 0.78 0.50K 0.50K 6.8
Page 6 of 8

STATION: FBR-016 LATITUDE: 35.25167
STATION DESCRIPTION: French Broad River at Patton Bridge LONGITUDE: -82.67889
COUNTY: Transylvania BASIN: 040302
mg/Kg
Date Species DWQt# Length(mm) Weight(g) Hg As Cd Crt Cu Ni Pb Zn Se TI
9/5/1990 ATS 90-4296 209 118.8 0.44 <.50 <.10 <.25 0.62 <.50 <.r.0 8.8
9/5/1990 C 90-4291 498 2046 0.21 <.50 <,10 0.26 3.8 <.50 <.50 170 0.67
9/5/1990 LMB 90-4294 177 74.8 0.37 <.50 <.10 <.25 2 1.6 <.50 6 0.96
9/5/1990 RBS 90-4292 178 103 0.17 <.50 <.10 <.25 0.13 <.50 <.50 8.6 0.63
9/5/1990 RKB 90-4293 157 78.3 0.56 <.50 <A0 <.25 0.15 <.50 <.50 4.9 1.1
9/5/1990 SMB 90-4295 220 150 0.32 <.50 <.10 <.25 2.S 0.67 <.SO 8.2 <.50
9/5/1990 WHC 90-4307 335 370 1.10 <,50 <.10 <.25 0.28 <.50 <.50 4.5 <,50
9/5/1991 RHS 91-4290 359 575 0.42 <.50 <.10 0.43 61 <.50 <,SO 14 0.74
Page 7 of 8

STATION: WRCFRBRDR08 LATITUDE: 35.89905
STATION DESCRIPTION: French Broad River near Hot Springs LONGITUDE: -82.83011
COUNTY: Madison BASIN: 040304
mg/Kg
Date Species DWQ# Length(mm) Weight(g) Hg As Cd Crt Cu Ni Pb Zn Se TI
9/24/2008 SMB 08-661 214 114 0.25
9/24/2008 SMB 08-666 263 211 0.17
9/24/2008 SMB 08-662 267 223 0.25
9/24/2008 SMB 08-664 267 219 0.22
9/24/2008 SMB 08-660 268 220 0.22
9/24/2008 SMB 08-667 273 234 0.20
9/24/2008 SMB 08-663 275 253 0.21
9/24/2008 SMB 08-668 287 273 0.19
9/24/2008 SMB 08-665 296 312 0.14
9/24/2008 SMB 08-658 372 726 0.37
9/24/2008 SMB 08-659 372 726 0.36
9/24/2008 SMB 08-671 377 709 0.39
9/24/2008 SMB 08-669 426 892 0.47
9/24/2008 SMB 08-670 426 892 0.45
Page 8 of 8

1 -
HCDENR
Borth Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
October 19, 2009
MS.PAULA J. SIMS, SENIOR VICE PRESIDENT—POWER OPERATIONS/PEB 12
CAROLINA POWER&LIGHT COMPANY D/B/A PROGRESS ENERGY CAROLINAS,INC.
POST OFFICE BOX 1551
RALEIGH,NORTH CAROLINA 27602
Subject: Permit Extension and Return of Renewal
Application
Permit No. WQ0000020
Carolina Power&Light Company
d/b/a Progress Energy Carolinas, Inc.
Progress Energy Ash Distribution Program
Distribution of Residual Solids (503 Exempt)
Wake County
Dear Ms. Sims:
On August 5, 2009, Session Law 2009-406, entitled "An Act to Extend Certain Government
Approvals Affecting the Development of Real Property Within the State," was enacted by the General
Assembly and signed into law. The Act, known as the Permit Extension Act of 2009, extends the
expiration date of certain government approvals and permits.
Non-discharge permit, WQ0000020, issued by the Division of Water Quality falls within the
scope of this Act and is therefore being extended until February 28, 2013. With this letter, the permit
renewal application received August 27, 2009 is being returned. Please note per your permit, a renewal
application must still be submitted six months in advance of the extended expiration date.
If you have any questions regarding this request, please contact Division staff at(919) 733-3221.
Thank you in advance for your cooperation.
Sincerely,
i
fJon sgaard
Aquifer Protection Section
Enc: Permit Renewal Application
AQUIFER PROTECTION SECTION
1636 Mail Service Center,Raleigh,North Carolina 27699-1636
Location:2728 Capital Boulevard.Raleigh,North Carolina 27604 e Phone:[phone] FAX 1:919-715-0588;FAX 2:919-715-60481 Customer Service:1-877-623-6748 OI 1 dI 0t 1II?c
Internet:www.ncwateroualih,.org
An Equal Opportunity 1 Affirmative Action Employer � �

i .
AL
HCDEHR r
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
ec: ui71=l Reg-ion Office- quafar �'ttecct7 ect4n
Fayetteville R gional 6114ee -A fifer Protection Section
Mooresville Regional Office-Aquifer Protection Section
Raleigh Regional Office-Aquifer Protection Section
Washington Regional Office -Aquifer Protection Section
Wilmington Regional Office-Aquifer Protection Section
Winston-Salem Regional Office-Aquifer Protection Section
Permit File WQ0000020
APS Notebook File
AQUIFER,PROTECTION SECTION
1636 Mail Service Center,Raleigh,North Carolina 27699-1636
Location:2728 Capital Boulevard,Raleigh,North Carolina 27604 One
Phone:[phone]\FAX 1:919-715-0588;FAX 2:919-715-60481 Customer Service:1-877-623-6748
Internet:www.ncwateraualitv.org
Norb Cap:olina
An Equal Opportunity,Affirmative Action Employer

NCDENRco
North.Carolina Department of Environment and Natural Resourcesp
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
AQUIFER PROTECTION
October 13, 2009
Paula J. Sims
Progress Energy Carolinas, Inc.
Post Office Box 1551
Raleigh, NC 27602
SUBJECT: September 17, 2009 Compliance
Evaluation Inspection
Progress Energy Carolinas, Inc.
Progress;Energy Ash Distribution Program
Permit No: WQ0000020
Buncombe County
Dear Ms. Sims:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection
that I conducted on September 17, 2009. The facility was found to be in Compliance with permit
WQ0000020.
Please refer to the enclosed inspection report for additional observations and comments. If
you or your staff has any questions, please call me at [phone].
Sinc /rely,
Ed Williams
Environmental Specialist
Enclosure
cc: Laurie Moorehead Senior Environmental Specialist Progress Energy Carolinas, Inc. 200 CP&L
Drive Arden NC 28704
APS Central Files
APS Asheville Files
AQUIFER PROTECTION SECTION—Asheville Regional Office(ARO)
2090 U.S.70 Highway,Swannanoa,NC 28778-8211
Phone:[phone] FAX:[phone] One
Customer Service:1-877-623-6748 NofthCarolina
Internet:www.ncwaterouality.om
An Equal Opportunity VAffirmative Action Employer

Compliance Inspection Report
Permit: WQ0000020 Effective: 02/17/06 Expiration: 02/28/11 Owner: Progress Energy Carolinas Inc
SOC: Effective: Expiration: Facility: Progress Energy Ash Distribution Program
County: Unknown PO Box 1551
Region: Asheville
Contact Person: Paula J Sims Title: Vice President-Fossil Ge Phone:
Directions to Facility:
From Interstate 26 East take the Long Shoals Rd. Exit. Turn left onto Long Shoals Rd. and go approximately 1 mile to facility entrance
n the ri ht.
System�lassifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 0911712009 Entry Time: 09:00 AM Exit Time: 11:00 AM
Primary Inspector: Edward M Williams Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type:Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503 exempt)
Facility Status: 10 Compliant Q Not Compliant
Question Areas:
EM Miscellaneous Questions Record Keeping ®Sampling
(See attachment summary)
Page: 1

Permit:WO0000020 Owner-Facility: Progress Energy Carolinas Inc
Inspection Date: 09/17/2009 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Ash is currently being hauled to airport to be utilized as fill. Follwing the complaint last year concerning the cenospheres
blowing off the pond and into the adjacent neighborhood,trees were planted to create a vegetated screen and
cenospheres are being skimmed off the pond surface more frequently.
Page: 2

Permit:WQ0000020 Owner-Facility:Progress Energy Carolinas Inc
Inspection Date: 09/17/2009 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Land Application ❑
Distribution and Marketing
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required? ❑ ❑ ® ❑
Are GW samples from all MWs sampled for all required parameters? ❑ ❑ ® ❑
Are there any GW quality violations? ❑ ❑ ® ❑
Is GW-59A certification form completed for facility? ❑ ❑ ® ❑
Is a copy of current permit on-site? ® Q ❑ ❑
Are current metals and nutrient analysis available? ® ❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters? ❑ ❑ 0 ❑
a. TCLP analysis? ® ❑. ❑ ❑
b. SSFA(Standard Soil Fertility Analysis)? ❑ ❑ ® ❑
Are PAN balances being maintained? ❑ ❑ ® ❑
Are PAN balances within permit limits? ❑ ❑ ® ❑
Has land application equipment been calibrated? ❑ ❑ ® ❑
Are there pH records for alkaline stabilization? ❑ ❑ ® Cl
Are there pH records for the land application site? ❑ Cl ® ❑
Are nutrient/crop removal practices in place? ❑ ❑ ® ❑
Do lab sheets support data reported on Residual Analysis Summary? ❑ ❑ ❑
Are hauling records available? ® ❑ ❑ ❑
Are hauling records maintained and up-to-date? ® ❑ ❑ ❑
#Has permittee been free of public complaints in last 12 months? ❑ ® ❑ ❑
Has application occurred during Seasonal Restriction window? ❑ ❑ ® ❑
Comment: Complaint concerning cenospheres blowing into adjacent neighborhood
and various other complaints
Sampling Yes No NA NE
Describe sampling:
grab samples collected at several points in the pile and pond,then composited for analysis
Is sampling adequate? ® ❑ ❑ ❑
Is sampling representative? ® ❑ ❑ ❑
Page: 3

Permit:WO0000020 Owner-Facility: Progress Energy Carolinas Inc
Inspection Date: 09/17/2009 Inspection Type:Compliance Evaluation Reason for Visit:Routine
Comment:
Page: 4

C Progress Energy to, g 9Y rT 15 0.
FAsh'WleRegionaloffjjc�^^ev
October 12, 2009 — --
Mr.G. Landon Davidson, LG
Regional Supervisor Aquifer Protection Section
North Carolina Department of Environment and Natural Resources
Asheville Regional Office
2090 U.S.70 Highway
Swannanoa, NC 28778-8211
RE: Carolina Power&Light Company d/b/a Progress Energy Carolinas, Inc.
Ash Distribution Program Permit No.WQ0000020
Asheville Steam Electric Plant Coal Ash Structural Fill Project
Dear Mr. Davidson:
Since our last submittal.to you under cover letter dated July 8, 2009 and our meeting on July 21,
2009,the Asheville Steam Electric Plant coal ash structural fill project at the Asheville Regional
Airport has changed. The Airport no longer plans to use coal ash as fill in Area 2. Rather,this
area will be filled with soil.
As such, we attach the latest project drawings dated September 2009. The drawings show the
updated review and compliance boundaries around Areas 1E and 1W along with the updated
locations of proposed groundwater monitoring wells.
However,the project design has not changed. This project has a geosynthetic clay liner(GCL)
with a permeability of 5 x 10-9 cm/sec placed under the entire Area 1 project area. We have also
designed a clay cap into Area 1. All side slopes will be covered by four feet of clay soil while the
flatter areas will be covered by six feet of clay soils. The clay soils have an approximate
permeability of 1.12 x 10-5 cm/sec. In addition, 73%of Areas 1E and 1W will be covered by
buildings and pavement.
The updated drawings show the proposed locations of four additional groundwater monitoring
wells. Wells MW-1A, MW-2A and MW-5 are proposed at the review boundary downgradient
from the fill. We propose to install well MW-4A at the review boundary upgradient from the fill.
Existing wells MW-2, MW-3 and MW-4, which were only used for monitoring groundwater
elevation, are scheduled for abandonment.
We propose to begin monitoring these four wells in fall 2009. Subsequent monitoring will be
two times per year(Spring, March/April and Fall, October/November). We will monitor these
wells for:
pH,temperature, water level, specific conductivity,total dissolved solids,total organic
carbon, arsenic, barium, boron, cadmium, chromium,copper, iron, lead, manganese,
Progress inerc ar ,r,asc�el, nitrate, nitrite, selenium,silver, sulfate and zinc.
C.
P.O.Box 1551
Raleigh,NC 27602

DENR ARO
October 12,2009
As part of our NPDES permit at our Asheville Steam Electric Plant,we perform surface water
sampling in the French Broad Riverjust north of the Airport site. As such, we do not propose
any additional surface water sampling.
As stated in the prior letter dated July 8, 2009,the Asheville Airport is in the process of adding,
through the Buncombe County Register of Deeds, a deed restriction to the property(Areas 1E &
1W)where coal ash is used as fill. The deed restriction will note that coal ash was used as fill in
this property in accordance with permit WQ0000020 dated February 17, 2006; no water supply
wells will be constructed or operated within the compliance boundary around said coal ash fill;
and the State will have access to the coal ash fill compliance boundary for groundwater
monitoring or remediation purposes.
If you have any questions on the updated project drawings or this structural fill project in
general, please contact Mr.John Toepfer at 919-546-7863.
Sincerely,
OF
Brenda E. Brickhouse
Director-Environmental, Health &Safety Services
BEB:jrt
Att: -Asheville Airport Project Drawings dated September 2009 by Vaughn Engineering
2

ProgressEnergy
CERTIFIED MAIL: 7007 1490 0004 8052 0607 October 1, 2009
File: 12520-A, 12520-B
Mr.Jimmy Overton (}
NCDENR—Division of Water Quality �� 1 Y
1617 Mail Service Center `` t CUP r
Raleigh, NC 27699-1617 � `S(lrr
Subject: Progress Energy Carolinas—Asheville Steam Electric Plant {��`, y it�
NPDES Permit No. NC0000396 0, Sc1� L J
2008 Mercury and Selenium Monitoring of Fish in the French Broad River
Dear Mr. Overton,
Enclosed please find the 2009 report of Nd,&r and Selenium Monitorin Fish in the French Broad
cur
River as required by permit NC0000396. If you have any questions please contact Shannon Langley at
[phone] or Laurie Moorhead at(828) 687-5240.
1 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person.or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. 1 am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations.
Regards,
A"A j
Garry A.Whisnant
Asheville Plant Manager
Enclosure
CI
OCT 0 6 20b�
Environmental Sciences Section
Progress Energy Carolinas,Inc.
Asheville Stearn Plant
200 f:HU Drive
Arden,NC 28704

i
Asheville Steam Electric Plant
NPDES Permit No. NC0000396
Mercury and Selenium Monitoring of Fish in the French Broad River
Buncombe County,North Carolina
Progress Energy Carolinas
Environmental, Health and Safety Services Section
September 2009

F
Table of Contents
Page
1.0 Introduction....................................................................................................................... 1
2.0 Study Site Description and Sampling Locations............................................................... 1
3.0 Target Species................................................................................................................... 1
4.0 Field Sampling Methods................................................................................................... 1
5.0 Laboratory Processing and Selenium Analysis................................................................. 2
6.0 Data Analysis and Reporting............................................................................................ 2
7.0 References......................................................................................................................... 7
List of Tables
Page
Table 1 Mercury and selenium concentrations in axial muscle of fish from the
French Broad River,June and July 2009.................................................................... 4
Table 2 Baseline mercury and selenium concentrations in axial muscle of fish from the
French Broad River,August and November 2004...................................................... 6
List of Figures
Page
Figure 1 French Broad River mercury and selenium monitoring locations .............................. 3
i

1.0 Introduction
Progress Energy Carolinas, Inc. (PEC), owns and operates the Asheville Steam Electric Plant
(Asheville Plant) located on the east side of the French Broad River in Buncombe County, Arden,
North Carolina. As required by the Asheville Plant's National Pollutant Discharge Elimination System
(NPDES)Permit No.NC0000396,monitoring mercury and selenium of fish in the French Broad River
began after Flue Gas Desulfurization (FGD) operations commenced in December of 2005. After the
required annual minimum 120 discharge days from Outfall 001 to the river,fish samples were collected
during summer of 2009. This data report is submitted to fulfill the monitoring program as required by
the NPDES permit.
2.0 Study Site Description and Sampling Locations
Fish were collected from three locations of the French Broad River (Figure 1). These locations
were adjaceni to the Asheville Plant discharge (Station DI), 6.2 kilometers upstream (Station UP)
and 10.8 kilometers downstream of the discharge (Station DN).
Ga l rr r�5
3.0 Target Species
The target species were black bass (primarily smallmouth bass), sunfish (redbreast/bluegill) and
black redhorse. Largemouth bass and rock bass were also collected at stations UP and DN to
supplement the predatory species due to low numbers of black bass in the catches. As
recommended by the U.S. Environmental Protection Agency (EPA) an attempt was made to limit
the smallest fish to 75% of the largest fish total length by species depending on availability
(U.S. EPA 1995).
4.0 Field Sampling Methods
Fish were collected using electrofishing according to PEC Biology Program Procedures Manual
(Procedure NR-00080), which is approved by the NCDWQ under PEC's North Carolina
Biological Laboratory Certification. Only live fish that showed little or no signs of deterioration
were retained for analysis. Ancillary fisheries data including species, number, total length (min),
and total weight (g) were also recorded.
1

Fish collected for mercury and selenium analysis were placed in a labeled (date, station, etc.) bag
and placed on ice until frozen. Each day following collection the fish were transferred to a freezer
on-site at the Asheville Plant.
Water quality data consisting of temperature, pH, dissolved oxygen, specific conductance and
turbidity were recorded daily at the surface at each sampling location. Other noteworthy
environmental conditions including river flow conditions and weather conditions were noted and
are available upon request.
5.0 Laboratory Processing and Mercury and Selenium Analysis
All fish samples were processed in the PEC's trace element laboratory according to procedure
NR-00107 Trace Element Monitoring Laboratory Procedure. The processed samples (lyophilized
left axial muscle) were analyzed for mercury and selenium in-house according to procedure CHE-
NGG-0044 Energy Dispersive Polarized X-ray Fluorescence Procedure. The remaining fish
carcasses were archived and will be kept at least two years in the event that re-analysis is needed.
6.0 Data Analysis and Reporting
Mercury and selenium concentrations (converted to µg/g fresh weight) in the fish muscle tissue
collected during 2009 are shown in Table 1. In addition to the length and weight of each fish,
the dry-to-fresh weight ratios are presented to convert the mercury and selenium concentrations
between either the dry or fresh weight values as desired. The 2004 baseline data are presented as
well for comparison purposes (Table 2). During 2009, seven fish at Station Up, two at Station
DI, and three fish collected at Station DN had mercury concentrations at or greater than the North
Carolina Health Directors Action Advisory Level of 0.4 µg/g fresh weight. All fish collected
were below the advisory level for selenium. No apparent shifts in mercury and selenium
concentrations in fish from pre-operation to post-operation of the Asheville FGD system were
detected.
2

i b
{ ti
ti
i 1 �Vq"1 .:a •� t �5....�
D
S S _ l Y�}E Alryk
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77
R \
4�
N r
3
N
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(f +fir 113 03 i 2 3 l
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Figure 1. French Broad River mercury and selenium monitoring locations.
3

Table 1. Mercury and selenium concentrations (fresh weight) in axial muscle of fish from the
French Broad River,June and July, 2009.
Fish Species Transect Month Length Weight Hg Se Dry-to-Fresh*
(mm) (g) (µg/g) (µg/g) Weight Ratio
Black redhorse UP June 455 1008 0.2 0.3 0.18
Black redhorse UP June 404 669 0.4 0.2 0.17
Black redhorse UP June 439 750 <0.2 0.2 0.19
Black redhorse UP June 430 988 0.3 0.3 0.16
Black redhorse UP June 448 984 0.3 0:3 0.20
Black redhorse UP June 435 796 0.3 0.2 0.19
Black redhorse UP June 435 992 0.3 0.3 0.19
Black redhorse UP June 402 701 0.7 0.2 0.20
Black redhorse UP June 424 760 0.3 0.2 0.25
Black redhorse UP June 390 532 0.3 0.2 0.19
Redbreast sunfish UP June 164 98 <0.1 0.3 0.21
Redbreast sunfish UP June 188 158 <0.2 0.5 0.21
Redbreast sunfish UP June 172 97 0.2 0.3 0.21
Redbreast sunfish UP June 172 124 0.2 0.6 0.21
Redbreast sunfish UP June 167 103 <0.1 0.8 0.21
Redbreast sunfish UP July 161 76 0.1 0.4 0.19
Redbreast sunfish UP July 178 101 <0.2 0.7 0.19
Redbreast sunfish UP July 155 81 <0.1 0.4 0.20
Redbreast sunfish UP July 196 140 0.1 0.2 0.20
Redbreast sunfish UP July 212 196 <0.2 0.3 0.21
Smallmouth bass UP June 248 189 <0.2 0.6 0.20
Smallmouth bass UP July 292 332 0.3 0.4 0.20
Smallmouth bass UP July 270 250 0.4 0.4 0.20
Smallmouth bass UP July 259 220 0.2 0.3 0.21
Smallmouth bass UP July 251 185 0.5 0.3 0.21
Smalhnouth bass UP July 237 156 0.4 0.4 0.19
Smallmouth bass UP July 249 184 0.3 0.4 0.20
Largemouth bass UP June 526 2275 0.7 0.4 0.19
Largemouth bass UP June 405 1090 0.4 0.2 0.20
Rock bass UP June 177 142 <0.1 0.2 0.20
Black redhorse DI June 467 1110 0.4 0.6 0.18
Black redhorse DI June 500 1275 0.3 0.1 0.22
Black redhorse DI June 453 1025 <0.2 0.3 0.20
Black redhorse DI June 438 879 <0.1 0.3 0.17
Black redhorse DI June 460 1100 <0.1 0.4 0.19
Black redhorse DI June 453 849 0.2 0.3 0.17
Black redhorse DI June 440 855 0.1 0.3 0.18
Black redhorse DI June 447 860 0.3 0.4 0.17
Black redhorse DI' June 407 704 0.4 0.4 0.19
Black redhorse DI June 392 530 <0.1 0.4 0.20
Redbreast DI June 162 75 <0.1 1.3 0.20
Redbreast DI June 180 104 <0.1 0.8 0.20
Redbreast DI June 172 82 <0.1 0.4 0.20
Redbreast DI June 176 112 <0.1 0.7 0.21
Redbreast DI June 155 84 <0.1 1.2 0.21
Redbreast DI June 153 68 <0.1 1.2 0.21
Redbreast DI June 150 65 <0.1 0.5 0.20
Redbreast DI July 171 99 <0.1 0.2 0.19
Redbreast DI July 159 76 0.1 0.4 0.19
Redbreast DI July 171 90 <0.1 1.0 0.19
Smallmouth bass DI June 265 242 0.2 0.5 0.20
Smallmouth bass DI June 237 175" <0.2 0.7 0.20
Smallmouth bass DI June 238 178 0.1 0.4 0.20
4

Fish Species Transect Month Length Weight Hg Se Dry-to-Fresh*
(mm) (g) (µg/g) (µg/g) Weight Ratio
Smallmouth bass DI June 214 141 0.2 0.3 0.20
Smallmouth bass DI June 267 222 0.2 0.7 0.20
Smallmouth bass DI June 236 188 <0.2 0.8 0.20
Smallmouth bass DI June 267 243 <0.2 0.2 0.19
Smallmouth bass DI June 214 130 <0.1 0.5 0.16
Smallmouth bass DI June 262 229 0.2 0.3 0.20
Smallmouth bass DI June 235 157 <0.2 0.3 0.20
Black redhorse DN June 432 876 <0.2 0.4 0.18
Black redhorse DN June 410 691 <0.1 0.6 0.18
Black redhorse DN June 438 878 0.1 0.5 0.18
Black redhorse DN June 452 987 0.3 0.5 0.18
Black redhorse DN June 446 968 0.3 0.5 0.19
Black redhorse DN June 420 752 0.2 0.4 0.17
Black redhorse DN July 497 1225 0.3 0.6 0.18
Black redhorse DN July 442 945 0.5 0.6 0.18
Black redhorse DN July 460 950 0.4 0.6 0.19
Black redhorse DN July 421 852 <0.1 0.6 0.20
Redbreast sunfish DN June 169 85 <0.1 0.6 0.21
Redbreast sunfish DN July 180 113 <0.1 0.5 0.19
Redbreast sunfish DN July 165 85 <0.1 0.6 0.20
Redbreast sunfish DN July 156 76 <0.1 0.5 0.21
Redbreast sunfish DN July 212 181 <0.1 0.4 0.18
Redbreast sunfish DN July 170 96 <0.1 0.5 0.18
Redbreast sunfish DN July 163 76 <0.1 0.5 0.18
Redbreast sunfish DN July 179 100 <0.1 0.6 0.19
Redbreast sunfish DN July 171 80 <0.2 0.6 0.19
Redbreast sunfish DN July 167 88 <0.1 0.5 0.19
Smallmouth bass DN June 237 191 <0.2 0.6 0.20
Smallmouth bass DN June 237 145 <0.1 0.6 0.20
Smallmouth bass DN July 301 305 <0.1 0.5 0.20
Smallmouth bass DN July 231 144 <0.1 0.7 0.21
Smallmouth bass DN July 280 242 <0.2 0.6 0.20
Smallmouth bass DN July 341 440 0.5 0.5 0.20
Smallmouth bass DN July 227 143 <0.1 0.7 0.21
Smallmouth bass DN July 212 172 0.3 0.6 0.19
Largemouth bass DN July 320 424 <0.1 0.6 0.18
Rock bass DN July 244 180 0.3 0.7 0.20
*To convert to a dry weight,divide the fresh weight concentrations by the dry-to-fresh weight ratio.
5

Table 2. Baseline mercury and selenium concentrations (fresh weight) in axial muscle of
fish from the French Broad River,August and November,2004.
Fish Species Locations Month Length Weight Hg Se Dry-to-Fresh*
(MM) (g) (µg/g) (µg/g) Weight Ratio
Smallmouth bass UP August 246 201 0.9 0.4 0.22
Smallmouth bass UP August 297 370 0.5 0.4 0.21
Smallmouth bass UP August 346 620 0.4 0.2 0.22
Smallmouth bass UP August 445 1,300 1.7 0.3 0.24
Smallmouth bass UP August 370 744 1.5 0.3 0.20
Redbreast UP August 172 106 <0.2 0.3 0.20
Redbreast UP August 160 87 0.3 0.2 0.20
Redbreast UP August 145 72 <0.3 0.4 0.30
Redbreast UP August 149 60 <0.2 0.3 0.21
Redbreast UP August 190 160 0.1 0.3 0.20
Black redhorse UP August 372 540 <0.1 0.3 0.21
Black redhorse UP August 380 550 <0.2 0.2 0.21
Black redhorse UP August 410 790 0.5 0.3 0.20
Black redhorse UP August 413 843 0.6 0.2 0.19
Black redhorse UP August 415 989 0.4 0.3 0.20
Black redhorse UP August 405 863 0.5 0.3 0.20
Largemouth bass DI August 475 1,725 0.7 1.2 0.21
Largemouth bass DI August 395 611 <0.2 1.5 0.20
Largemouth bass DI August 405 795 0.2 0.2 0.21
Smallmouth bass DI August 263 223 0.5 0.3 0.22
Smallmouth bass DI August 355 565 0.6 4.2 0.22
Smallmouth bass DI August 374 871 0.3 0.5 0.23
Smallmouth bass DI August 368 802 0.7 0.2 0.22
Smallmouth bass DI August 440 1,300 1.0 0.4 0.22
Redbreast DI August 136 52 <0.2 3.8 0.21
Redbreast DI August 183 108 <0.2 3.6 0.19
Redbreast DI August 164 80 0.2 0.6 0.20
Redbreast DI August 182 128 <0.2 0.7 0.19
Redbreast DI August 177 109 <0.2 0.6 0.20
Redbreast DI August 149 58 <0.2 0.7 0.20
Black redhorse DI August 375 618 <0.2 0.3 0.22
Black redhorse DI August 383 765 0.3 0.3 0.21
Black redhorse DI August 457 1,050 0.5 0.5 0.20
Black redhorse DI August 465 1,025 0.8 0.2 0.21
Black redhorse DI August 493 1,450 0.7 0.2 0.21
Black redhorse D1 August 475 1,200 0.4 0.8 0.20
Black redhorse DI November 410 745 <0.2 0.2 0.20
Smallmouth bass DN November 277 265 0.7 0.3 0.21
Smallmouth bass DN November 295 410 1.1 0.3 0.21
Smallmouth bass DN November 310 460 1.6 0.8 0.22
Smallmouth bass DN November 347 620 0.8 0.7 0.22
Smallmouth bass DN November 345 750 1.1 0.4 0.22
Bluegill DN August 135 59 <0.2 0.3 0.20
Redbreast DN August l62 66 0.3 0.8 0.20
Redbreast DN August 175 96 <0.2 0.7 0.22
Redbreast DN August 185 139 0.2 0.3 0.19
Redbreast DN August 198 156 <0.2 0.3 0.19
Redbreast DN August 273 324 0.5 0.2 0.21
Redbreast DN August 126 46 <0.1 0.4 0.20
Redbreast DN August 187 170 0.1 0.7 0.20
Redbreast DN August 198 154 <0.2 0.9 0.20
Redbreast DN August 198 154 <0.2 0.9 0.20
Redbreast DN August 198 154 <0.2 0.9 0.20
Redbreast DN August 135 59 <0.2 0.3 0.20
Black redhorse DN August 365 509 <0.2 0.5 0.20
Black redhorse DN August 356 518 0.1 0.3 0.20
Black redhorse DN August 375 651 <0.2 0.8 0.20
Black redhorse DN August 395 755 <0.2 0.5 0.20
Black redhorse DN August 388 810 0.5 0.4 0.21
Black redhorse DN August 423 910 <0.2 0.4 0.19
* To convert to a dry weight, divide the fresh weight concentrations by the dry-to-fresh weight ratio.
6

7.0 References
U.S. EPA. 1995. Guidance for assessing chemical contaminant data for use in fish advisories. Vol. 1.
Fish sampling and analysis. Second edition. EPA 823-R-95-007. United States Environmental
Protection Agency, Office of Water,Washington,DC.
7

FT
�Pro rasa Ener � 2GO9
9 9Y
July 8, 2009 Ad1(3viil R gicai?a ofific�
uifr Protein
Mr.G. Landon Davidson, LG
Regional Supervisor Aquifer Protection Section
North Carolina Department of Environment and Natural Resources
Asheville Regional Office
2090 U.S.70 Highway
Swannanoa, NC 28778-8211
RE: Carolina Power&Light Company d/b/a Progress Energy Carolinas,Inc.
Ash Distribution Program Permit No.WQ0000020
Asheville Steam Electric Plant Coal Ash Structural Fill Project
Dear Mr. Davidson:
Thank you for your letter dated March 17, 2009. As you are aware, Carolina Power& Light
Company d/b/a Progress Energy Carolinas, Inc. (PEC) is partnering with the Asheville Regional
Airport Authority(Airport) on the North General Expansion Project. The Airport has secured
permits from the Corps of Engineers and the Division of Water Quality to permanently impact
1,535 linear feet of perennial streams, 138 linear feet of intermittent streams and 0.359 acres of
wetlands to develop the North General Expansion Project. The design calls for the existing
stream to be routed through a 60-inch concrete reinforced pipe approximately 1,600 feet in
length. As a part of this development, our Asheville Steam Electric Plant coal ash will be utilized
in select portions of the project as structural fill.
PEC requested approval under letter dated December 23,2008 to use coal ash as fill within 50 feet
of this concrete pipe per condition 11.9.a.of our permit since the water flowing through this pipe is
considered surface water. This request was denied in your letter dated March 17, 2009. Due to
this denial,the project was redesigned to reflect that coal ash will not be used as fill within 50 feet
of the concrete pipe. Please note ap additional area of ash placement on the drawings designated
as"Area 2". Details on this area ar not yet available but we have included it for your information
and to show how this area affects the proposed compliance and review boundaries of the project
as well as the positioning of proposed groundwater monitoring wells.
Your letter dated March 17, 2009 also requested information from PEC. We note your request and
our response is below. Since we do not plan to proceed with the waiver request of the 50 foot
setback,some of your questions require no response. If you have any questions on the project
drawings or our response, please contact Mr.John Toepfer at 919-546-7863.
Sincerely,
Brenda E. Brickhouse
Director- Environmental, Health &Safety Services
BEB:jrt Att:-Asheville Airport Project Drawings dated June 30,2009 by Vaughn Engineering
Progress Energy Carolinas,Inc.
P.O.Box 1551
Raleigh,NC 27602

DENR ARO
July 8,2009
Response to DENR Letter Dated March 17,2009
Progress Energy Carolinas, Inc.
Requested Item Number 1
• The subject permit allows ash to be used as structural fill beneath structures and paved
surfaces where the concentration of metals in that ash may exceed the ceiling
concentrations and monthly average concentrations as listed in the table of Condition 5.
Based on your 2007 annual report, 14,025 tons of ash was distributed in December of
2007 in which the arsenic concentrations of all three samples exceeded the ceiling and
monthly concentrations. Please indicate on a site plan where ash exceeding these limits
was used if used at the Asheville Airport project. This will allow verification that this ash
was used in a manner consistent with the permit conditions. Additionally,the Division
believes the stream setback requirements specified in the permit are protective of
surface water standards where ash with higher metal concentrations (i.e., above the
ceiling concentration or monthly average concentration) are allowed to be used as
structural fill such as with this project;
Response
PEC utilized Asheville Steam Electric Plant coal ash as fill at the Asheville Airport in the areas on
the project drawings labeled as "Area 1E" and "Area 1W". Coal ash will also be used as fill in
"Area 2" as shown on the project drawings. Ash placement began in late 2007 and continues to
the present. The arsenic concentration in the coal ash exceeded the monthly average
concentration and/or ceiling concentration as detailed in our 2007 and 2008 annual reports.
Requested Item Number 2
• Approximately 300 feet downgradient of the north extent of the planned ash fill is a
residential community. The culverted stream, in which you are requesting reduced
setbacks to,flows through this community and residents appear to have easy access to
the stream. Numerous homes in this community are on water supply wells, some of
which may be bored wells extracting groundwater from the more-vulnerable, shallow
water table. The Division is concerned with the presence of numerous downgradient
(down-slope) receptors and therein, a higher potential exposure risk. The information
you have provided with your request does not address this major concern;
Response
PEC will not utilize coal ash as fill within 50 feet of the concrete pipe (culverted stream).
Therefore, no follow up is required for this item.
Requested Item Number 3
• Should engineering controls such as the geosynthetic liner, impervious surfaces, culvert,
etc. be compromised and leaching occur, there appears to be few if any viable remedial
or corrective measures to address a problem. Given the volume of ash fill proposed,
removal would not be an option. With limited corrective measure options available and
no contingency proposes,we cannot support a setback exemption;
1

DENRARO
July 8,2009
Response
PEC will not utilize coal ash as fill within 50 feet of the concrete pipe (culverted stream).
Therefore, no follow up is required for this item.
Requested Item Number 4
• Condition 11.5. of your permit allows use of ash exceeding these ceiling and monthly
average concentrations as structural fill only if overlain by impervious surfaces (e.g
. ��
building footprint, paved area, etc.) and used at individually permitted use sites.
According to permit Condition IV.1.a.,the Asheville Airport structural fill site is
considered individually-permitted by the Division. Permit Condition 11.5.a. exemption is
allowed at individually permitted sites as stipulated in Condition IV.1. which requires tl)�
establishment of a compliance and review boundary around ash use site located outside
the property boundary of the source-generating facility. Please establish a compliance
and review boundary in accordance with 15A NCAC 2L.0107(f)for the Asheville Airport
site including proposing locations of monitoring wells,surface water sampling, etc. This
monitoring is also being required by the Division through permit Condition IV.2.a.
Please provide documentation addressing this issue within 90 days; and,
Response
The Asheville Airport is in the process of adding, through the Buncombe County Register of
Deeds, a deed restriction to the property(Areas 1 &2)where coal ash is used as fill. The deed
restriction will note that coal ash was used as fill in this property in accordance with permit
WQ0000020 dated February 17, 2006; no water supply wells will be constructed or operated
within the compliance boundary around said coal ash fill; and the State will have access to the
coal ash fill compliance boundary for groundwater monitoring or remediation purposes.
We have installed four groundwater wells (MW1, MW2, MW3 and MW4) at the site for the
purpose of monitoring groundwater elevation. The groundwater elevations recorded at these
wells demonstrated compliance with our permit condition that restricts ash placement within
one foot of the seasonal high-water table (note also that groundwater flows in a northwest
direction). As wells MW2 and MW3 are located within the coal ash placement of Area 1E, the
wells are scheduled for abandonment.
We propose to install 3 additional piezometers (see Sheet 1 of 3) and monitor the groundwater
elevation in these three peizometers along with existing wells MW1 and MW4 for six months.
This will ensure that we place downgradient monitoring wells in the correct locations. Right
now, we propose to install wells MW1A, MW2A and MW5 at the review boundary
downgradient from the coal ash fill. Again, the exact location for these three downgradient
wells will not be known until February 2010. We will confirm the location of these three
downgradient wells with you prior to installation. These three downgradient wells along with
existing background well MW4 will comprise the groundwater monitoring wells for Areas 1&2.
We plan to monitor these three downgradient monitoring wells and one background monitoring
well two times per year(Spring, March/April and Fall, October/November) starting in Spring
2010. We will monitor these wells for:
2

DENR ARO
July 8,2009
pH,temperature,water level,specific conductivity,total dissolved solids,total organic carbon,
arsenic, barium, boron,cadmium, chromium, copper, iron, lead, manganese, mercury, nickel,
nitrate, nitrite, selenium,silver,sulfate and zinc.
As part of our NPDES permit at our Asheville Steam Electric Plant,we perform surface water
sampling in the French Broad River just north of the Airport site. As such,we do not propose
any additional surface water sampling. Sk►Dn'"� °
Condition 11.5. of the subject permit as written allows for use of CCPs exceeding a ceiling
concentration or monthly average concentration to be used as structural fill "...under a structure
or footprint of a paved road, parking lot,sidewalk,walkway, or similar structure." The permit
condition goes on to state that in addition to these uses being individually permitted sites, "the
permittee shall meet the performance standards stipulated in Condition I.S.to ensure that the
applicable surface water quality standards and groundwater quality standards are not
contravened." Condition 1.5 of the permit further allows for engineered solutions(such as liners
and caps)to prove that standards will not be contravened. I
This project has a geosynthetic clay liner(GCL)with a permeability of 5 x 10-9 cm/sec placed
under the entire Area 1 project area. We have also designed a clay cap into Area 1. All side
slopes will be covered byfour feet of clay soil while the flatter areas will be covered by six feet �.
of clay soils. The clay soils have a permeability of 1.12 x 10-5 cm/sec. We believe this meets the
requirements of the subject permit. In addition, 73.21%of Areas 1E and 1W will be covered by
buildings and pavement(impervious cover). The design of Area 2 is not yet complete but is
expected by August 2009. We will provide you with similar details of Area 2 at that time.
Requested Item Number 5
• While the Asheville Airport's 401 certification references the "non-discharge
requirements", Condition 12 of that permit offers further clarification and restriction by
stating that"no waste ash fill over waters".
Response
PEC will not utilize coal ash as fill within 50 feet of the concrete pipe (culverted stream).
Therefore, no follow up is required for this item.
3

REM V E®
Energy Progress Pro I,
�, g 9Y JU 0 9 2Ca9
CERTIFIED MAIL: 7006 0100 0003 6098 7517 Asheville Regional ®fflcq
Aquifer Protection
File Point: 12570-A, 12570-D une 8, 2009
Landon Davidson, Supervisor
NC Division of Water Quality,Aquifer Protection Section _
NCDENR Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Cenosphere Management Update
Progress Energy Asheville Plant Ash Distribution Program
Permit WQ0000020
Buncombe County
Dear Mr. Davidson,
In response to your request on March 3, 2009 for an update of options being considered for
cenosphere management at Asheville Steam Electric Plant, the following is provided.
• Asheville Plant evaluated alternative cenosphere harvesting areas along the ash pond but
has determined that the historical harvesting location is best suited due to multiple
advantages.
• Asheville Plant installed a natural, vegetative buffer(fir and pine tree barrier)between
the ash pond and the plant property boundary and is closely monitoring its condition. To
date the vegetation is remaining healthy and is showing signs of new growth.
• Asheville Plant will continue to collect cenospheres using the historical method of boat
and boom but is now closely monitoring the appearance of cenospheres in order to
harvest more frequently. Asheville Plant believes that the best way to control cenosphere
travel is to minimize the amount of cenospheres on the pond at all times.
We appreciate our responsibility to minimize cenosphere travel and take very seriously our role
to ensure that our ash pond maintenance and ash reuse activities do not contribute to air quality
degradation. To that end, we will remain diligent in our compliance with our ash reuse permit.
Should you wish to discuss our activities further, please contact Ms. Laurie Moorhead at
828/687-5240.
Sincerely,
Garry A. Whisnant, Plant Manager
Asheville Steam Electric Plant
Progress Energy Carolinas,Inc.
Asheville Steam Plant
200 CP&L Drive
Arden,NC 28704

3/30/2009
MICROW IO
LABORATORIES, INC.
Katherine Merritt March 30,2009
41 Aberdeen Drive PO#:M41 KW Soot
Arden,NC 28704 Job#:2606
Attention:Katherine Merritt
Ms.Meritt:
This report summarizes the findings on the single sample of dust and collected debris you submitted for analysis for
potential soot contamination and compositional analysis.
r
Methods:
A portion of the submitted tape was removed from the canister and sectioned.This section was then placed on a glass
slide,covered in optical immersion oil(n=1.515)and covered with a glass cover slip.This slide mount was then examined under
the PLM in order to document the optical characteristics of the materials present in the sample,as well as to estimate the relative
amounts of constituents present.An additional portion of tape,along with a small-dispersion of the settled dust from the interior
of the canister,was then placed on an aluminum mounting stub using double sided adhesive tape.This mount was then coated
with evaporated graphite,which improves imaging resolution and quality. The particles present on the surface of the tape were
then imaged and examined to document their morphology.EDX spectroscopy was used on select particles,as well as on large
areas of the sample mount to document the average composition of the material.An additional examination of the sample was
performed using a backscatter electron detector. Use of this detector highlights particles with varying densities, allowing for a
more discrete examination of particles with higher density.
a m
oFindings:
Please refer to the included photomicrographs and
spectra. The vast majority of the sample consisted of fine, ` I
hollow glass spheres, with some trace amounts of mineral ,
c� flakes, rust particles, and biological debris. The PLM 00 `
examination of this material showed clear, sometimes slightly
brown tinted translucent spheres and nearly spherical particles -.
often showing a centered void indicating a hollow interior.The
apparent thickness of the side walls showed variation from
3 -
sphere to sphere,but the interior void appeared to reflect around x
half of the diameter of the spheres.Additional particles appeared �� ,
to represent some feldspar and quartz mineral grains,trichomes
(plant leaf hairs),and some pollen grains.However,these other .x
articles are typical outdoor settled dust and represented less :
P t3P Pion
than one percent of the total sample volume from trace amounts
of resident material that was collected from the sampling surface.
The glass spheres were examined in the sample generally appeared to be smooth and almost completely spherical.
Some of the glass spheres showed some surface cratering,as well as occasional shot artifacts or elongation.Examination of both
MicroVision Laboratories,Inc. 187 Billerica Road,Chelmsford,MA 01824
Phone:[phone] Fax:[phone] Email:[e-mail]
www.MicroVisionLabs.com

• Page 2 3/30/2009
the average composition and the bulk of the glass spheres showed that they were primarily composed of aluminum and silicon
oxides, along with some amount of potassium, calcium;trace titanium and iron. This combination of elements is common in
aerosol formed glass spheres,both from blown glass and manufactured glass sphere applications,or from fossil fuel combustion
sources.
—Debris spheres ovemll
¢I
e �
., 7-
6-
0
$i
AI
1
a
K
.) •1 I' �1 _ e. ) 2 3 5 4 t 8 __,. s FO:
keV
Additional examination of the bulk of the sample using the backscatter electron detector revealed a small number of
particles of a considerably higher density than the glass spheres that comprised the majority of the sample debris. Backscatter
electrons (BSE) are electrons that are rejected and bounced directly back towards the beam source by nuclear interactions.
Imaging using these electrons therefore allows correlation of the.brightness of the imaged material with the atomic density of the
material.Using BSE images,bright particles representing higher density materials than the glass spheres were examined.Most
of the higher density spheres were iron or steel residue shot particles, representing molten metallic or rust particles. These
particles represented well under one percent of the examined spheres.
Two discrete particles were observed that represented even higher density materials than the iron spheres.One of these
particles consisted of a mixture of glass related elements with notable strontium,barium,and sulfur peaks.This material likely
represents a mixture of fused glass, silicate, and barium and strontium bearing minerals or other particles. The other notable
particle showed high concentrations of phosphorous, calcium, iron, as well as aluminum and silicon. There were also large
concentrations of the lighter rare earth elements,including lanthanum,cerium,and neodymium.Yttrium was also detected in this
sample, along with relatively small amounts of thorium and uranium. This combination of elements is very similar to some
naturally occurring minerals,though the spherical morphology of the particle suggests that the particle represents a heat fused or
melted agglomeration, and could represent a mixture of mineral phases or elemental sources. These heavy element bearing
particles were only observed in one field of view, in one instance, across more than a square inch of sample particulate
examined.These particles likely represent far less than even a hundredth of one percent of the total sample volume by number.
MicroVision Laboratories, Inc. 187 Billerica Road,Chelmsford,MA 01824
Phone:[phone] Fax:[phone] Email:[e-mail]
www.MicroVisionLabs.com

• Page 3 3/30/2009
iiV41.
MicroVisici
ate;
�w
♦• ',4I
'
T" Awl
C SJCV
la --Ba Ba Sphere.spx
1z
S
10
C
a.
s
4
C r.
AI e
z
a x K CaR ` Fe'
5"u, i`�, Sr
2,. .4,. _ 6 .. 8 ;lp 32 Ia :J. ;15."' 19 _20
keV
MicroVision Laboratories,Inc. 187 Billerica Road,Chelmsford,MA 01824
Phone:[phone] Fax:[phone] Email:[e-mail]
www.MicroVisionLabs.com

• Page 4 3/30/2009
ev
P -Porch Debrisspx
16 O
14
12
10
8
Ce
Nd
5
L
4
Al
lid 51
Ce U
z e Th Ca
Fe
Th U Y
2 4 6 8 10 12 14 16 18 20
k.V
Conclusion:
The vast majority of the particles examined appeared to represent hollow glass spheres.These spheres are most likely
residue of fly ash family particles generated from the combustion of fossil fuels. The small amount of metallic fragments and
iron spheres present in the sample are consistent with this potential source.The incidence of an extremely fine trace of rare earth
and heavy metal bearing particles likely represents trace mineral impurities in the source fuel mixture that have been
concentrated and fused into a glassy matrix. These particles were then mixed with the large amount of inert glass spheres and
deposited,in the same process that resulted in the dispersal of the fly ash.These heavy elements were only noted as an extreme
trace loading, and likely represent a very small component of the overall material being deposited. The presence of these
elements also suggests that there may be more relatively uncommon elements in other areas, present in low enough
concentrations that they were not represented in the sample volume examined.Examination of larger volumes of the material,
either with BSE/EDX direct examination,or potentially through bulk digestion or boride flux fusion and ICP or ICP/MS analysis
might allow for a more complete catalogue of any trace elements present.Examination of fallout material closer to the potential
source area might also allow for examination of particles that showed larger size;different morphology, or denser composition
than the particles examined at this site. This could lend insight into the pattern of distribution of materials from this potential
source.
Sincerely,
ralyst
el
is,
Laboratories,Inc.
MicroVision Laboratories, Inc. 187 Billerica Road,Chelmsford,MA 01824
Phone:[phone] Fax:[phone] Email:[e-mail]
www.MicroVisionLabs.com

1
NCDEN
North Carolina Department of Environment and-Natu.ral_l_esoau.rces
Division of Water QualityLAsheville
C E�M�E0
Beverly Eaves Perdue Coleen H. Sullins ee Freeman
Governor DirectorAPR 23 2Gi0 Secretary
April 21, 2009 Regional Office
P Prot®ctlon
MR.JOHN S.K.EENAN,VICE PRESIDENT-FOSSIL GENERATION/PEB 8
CAROLINA POWER&LIGHT COMPANY D/B/A PROGRESS ENERGY CAROLINAS,INC.
POST OFFICE BOX 1551
RALEIGH,NORTH CAROLINA 27602
Subject: Permit No. WQ0000020
Carolina Power& Light Company
d/b/a Progress Energy Carolinas,Inc.
Progress Energy Ash Distribution Program
Distribution of Residual Solids(503 Exempt)
Wake County
Dear Mr. Keenan:
This letter is intended to provide clarification on existing permit and State Administrative Code
requirements for the distribution of coal combustion products (CCP) as structural fill, and to request
additional information on structural fill activities. Non-discharge permit, WQ0000020, issued by the
Division of Water Quality on February 17, 2006 and effective until February 28, 2013, specifies the
condition under which Carolina Power & Light Company is allowed to distribute CCP. After review of
the existing permit language, and 15A NCAC 02T requirements for the distribution of CCP, the Division
felt that further clarification was needed to assure that Progress was aware of the expectations of their
distribution program.
Permit Condition II.3.b. specifies that structural/engineered fill (i.e., engineered fill that is properly placed
and compacted) for embankments, foundations, construction foundations, and for bases/sub-bases under a
structure or a footprint of a paved road, parking lot, sidewalk, walkway, or similar structure is approved
for distribution of bottom ash and fly ash. Furthermore, condition II.5.a. and II.9. provide specific
requirements for the use of CCP as structural fill, and condition IV I.a, provides an explanation of when
use sites are considered individually permitted. Structural fill is an allowable use for CCP as specified in
the permit; however, the permit fails to reiterate the permit application requirements for new and
expanding structural fill sites specified in 15A NCAC 02T 1204(d) and (f)as provided below:
15A NCAC 02T .1204 Application Requirements
(d)For new and expanding structural fill sites or sites where CCPs are used for bedding if the bedding
is applied at a depth greater than two feet underneath the structure: ,
(1) Site plans If required by G.S. 89C, a professional land surveyor shall provide location
information on boundaries and physical features not under the purview of other licensed
professions. Site plans or maps shall be provided to the Division by the applicant depicting the
location, orientation, and relationship of the CCPs use site's features including:
AQUIFER PROTECTION SECTION
1636 Mail Service Center,Raleigh,North Carolina 27699-1636
Location:2728 Capital Boulevard,Raleigh,North Carolina 27604 One
Phone:[phone] FAX 1:919-71 M588;FAX 2:919-715-60481 Customer Service:1-877-623-6748 NorthCarolina
Internet:www.ncwaterguality.org (!/�.iy,yams Slff
An Equal Opportunity 1 Affirmative Action Employer [TE

[Note: The North ___)lina Board of Examiners for Engineer- —A Surveyors has determined,
via letter dated December 1, 2005, that locating boundaries and physical features, not under the
purview of other licensed professions, on maps pursuant to this Paragraph constitutes practicing
surveying under G.S. 89C.].
(A) a scaled map of the site, with topographic contour intervals not exceeding 10 feet or 25
percent of total site relief and showing all site-related structures and fences within the site;
(B) the location of all wells (including usage and construction details if available), streams
(ephemeral, intermittent, and perennial), springs, lakes, ponds, and other surface drainage
features within 500 feet of the CCPs use boundary and delineation of the review and
compliance boundaries;
(C) setbacks as required by Rule .1206 of this Section; and
(D) site property boundaries within 500 feet of the CCPs use boundary.
(2)Information shall be provided to the Division that describes and explains site-specific
engineering or institutional controls proposed to prevent adverse impacts to public health and the
environment.
(3)Property Ownership Documentation of the site where the CCPs are to be used shall be provided
to the Division. This documentation shall consist of-
(A) legal documentation of ownership(i.e., contract, deed or article of incorporation);
(B) written notarized intent to purchase agreement signed by both parties, accompanied by a
plat or survey map; or
(C) easements specifically indicating the intended use of the property, as well as a plat or
survey map. Easements shall adhere to the requirements of 15A NCAC 02L .0107.
(f) A compliance boundary shall be established for all structural fill sites not subject to Rule .1203 of
this Section and the permittee shall comply with the provisions of 15A NCAC 02L .0107.
The original CCP distribution permit (WQ0000020) was issued prior to the adoption of the 02T .1200
rules' (September 1, 2006), however it is the Division's perspective that any new structural fill site
utilizing CCP after the adoption of the'02T rules must meet the 02T permitting requirements.
At this time, the Division requests that Carolina Power & Light Company submit a list of all existing
structural fill sites that have received.CCP under the authorization of permit WQ000020. At a minimum,
the list of sites shall specify the source and type of ash utilized, the dates of ash distribution, the name.of
the recipient of the ash, the amount of ash distributed, the anticipated total distribution per site, and the
anticipated fill completion date. The information shall be submitted no later than May 28t", 2010. If the
information cannot be obtained by the 28t", submit the information available and provide a recommend
date by which the remaining information can be gathered and provided to the Division.
If you have any questions regarding this request, please contact me at [phone]. Thank you in
advance for your cooperation.
Sin erel ,
Jon isgaard
Aquifer Protection Section
cc: John Toepfer,Post Office Box 1551 Raleigh,North Carolina 27602
Ashe �ilalelRe ,ianal®Bice-Aquife• �oteetion Section
Fayetteville Regional Office-Aquifer Protection Section
Mooresville Regional Office-Aquifer Protection Section
Raleigh Regional Office-Aquifer Protection Section
Washington Regional Office-Aquifer Protection Section
Wilmington Regional Office-Aquifer Protection Section
Winston-Salem Regional Office-Aquifer Protection Section
Permit File WQ0000020

Cd,-o 11"/_6s P
Annual Report Review Class A Distribution
1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
e Was a certification form submitted? Ye
® Was distribution conducted during the reported year? y e—s
® How many dry tons were distributed? e 83�q 3 o$
® -Were the distributions within the permitted.amount? N o
Were recipients information listed? Y�-S
® Did it indicate compliance? -y eS
0 Was form complete? yeS
® Was it signed by the appropriate people?1,6
2. Monitoring
a Were the analyses conducted'at the required frequency? yes
® Were the metals analyses reported on the Residual.Sampling Summary Form?YQS
o Were the results reported in mg/kg? y-e s
m Were the metals within ceiling concentration permit limits? NA list d
m Were the metals within monthly average concentration permit limits? N U-5 e
® If no,were the lab analyses attached?
o Were all the required parameters tested?y e.S
o Was TCLP analysis conducted? Yes
® Were the TCLP contaminants within regulatory limits?ye-5
3. Pathogen and Vector Attraction Reduction NP}
e Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted?
® Did'ihe form indicate the period of coverage,the residual class, and the pathogen reduction alternative and the
vector attraction reduction option used?
® Was the appropriate documentation to show pathogen and vector attraction reduction included in the report?
® Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503 or 2T?
4. General
® Was the report in the proper format? le's .
e Were any parts of the annual report missing?
® Was the report submitted on time?�.

Compliance Inspection Report
Permit: WQ0000020 Effective: 02/17/06 Expiration: 02/28/11 Owner: Progress Energy Carolinas Inc
SOC: Effective: Expiration: Facility: Progress Energy Ash Distribution Program
County: Unknown PO Box 1551
Region: Asheville
Contact Person: Paula J Sims Title: Vice President-Fossil Ge Phone:
Directions to Facility:
From Interstate 26 East take the Long Shoals Rd. Exit. Turn left onto Long Shoals Rd.and go approximately 1 mile to facility entrance
on the ri ht.
System-Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
24 hour contact name Laurie Moorehead Phone: [phone]
Related Permits:
Inspection Date: 03/23/2009 Entry Time: 11:00 AM Exit Time: 12:00 PM
Primary Inspector: Beverly Price Phone:[phone]
Secondary Inspector(s):
Reason for Inspection: Follow-up Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503 exempt)
Facility Status: ■ Compliant ❑ Not Compliant \
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page: 1

Permit:WQ0000020 Owner-Facility: Progress Energy Carolinas Inc
Inspection Date: 03/23/2009 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
This inspection was a follow-up to the on-site inspection conducted on 9/10/2008 and included a review of the 2008
Annual Report. No on-site visit. All data appeared to be complete and accurate.
Page: 2

MCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
AQUIFER PROTECTION
March 17, 2009
John Toepfer, P.E.
Senior Environmental Technical Specialist
Environmental Services
Progress Energy Carolinas, Inc.
410 S. Wilmington Street, PEB 4A
Raleigh, NC 27601
Subject: Progress Energy Request for Exemption to
Permit Condition II 9.a. —Setback from stream for ash
used as structural fill
Progress Energy Ash Distribution Program
Permit No. WQ0000020
Buncombe County
Dear Mr. Toepfer:
On December 29, 2008, the Division of Water Quality's, Asheville Office received Progress Energy's written
request for an exemption to Condition II (9)(a) of permit WQ0000020 that requires a 50 foot setback from any surface
water without prior approval from the Aquifer Protection Section when using ash for structural fill. Specifically, your
request is to use ash as structural fill over a culverted stream.
Based upon a review of your request along with supporting information, the Aquifer Protection Section is hereby
denying your request to reduce and effectively remove the stream setback requirement as specified in the subject permit
as well as Asheville Airport's 401 certification (DWQ #20071841)..Issues that were considered in this decision include but
were not limited to the following:
1.. The subject permit allows ash to be used as structural fill beneath structures and paved surfaces where the
concentration of metals in that ash may exceed the ceiling concentrations and monthly average concentrations as
listed in the table of Condition 5. Based on your 2007 annual report, 14,025 tons of ash was distributed in
December of 2007 in which the arsenic concentrations of all three samples exceeded the ceiling and monthly
average concentration. Based on the 2008 annual report, five out of the 12 ash samples exceeded the ceiling
concentration. Please indicate on a site plan where ash exceeding these limits was used if used at the Asheville
Airport project. This will allow verification that this ash was used in a manner consistent with the permit
conditions. Additionally, the Division believes the stream setback requirements specified in the permit are
protective of surface water standards where ash with higher metal concentrations (i.e., above the ceiling
concentration or monthly average concentration) are allowed to be used as structural fill such as with this
project;
2. Approximately 300 ft. downgradient of the northern extent of the planned ash fill is a residential community. The
culverted stream, in which you are.requesting reduced setbacks to, flows through this community and residents
appear to have easy access to the stream. Numerous homes in this community are on water supply wells, some
of which may be bored wells extracting groundwater from the more-vulnerable, shallow water table. The Division
is concerned with the presence of numerous downgradient (down-slope) receptors and therein, a higher potential
exposure risk. The information you have provided with your request does not address this major concern;
AQUIFER PROTECTION SECTION—Asheville Regional Office(ARO)
2090 U.S.70 Highway,Swannanoa,NC 28778-8211
Phone:[phone] FAX:[phone] One
Customer Service:1-877-623-6748 NoftKaxolina
Internet:www.ncwaterguality.org
An Equal Opportunity 1 Affirmative Action Employer ��t������✓

March 17, 2009
Page 2 of 3
3. Should the engineered controls such as the geosynthetic liner, impervious surfaces, culvert, etc. be compromised
and leaching occur, there appears to be few if any viable remedial or corrective measures to address a problem.
Given the volume of ash fill proposed, removal would not be an option. With limited corrective measure options
available and no contingency proposed, we can not support a setback exemption;
4. Condition II.5 of your permit allows use of ash exceeding these ceiling and monthly average concentrations as
structural fill only if overlain by impervious surfaces (e.g., building footprint, paved area, etc.) and used at
individually permitted use sites. According to permit Condition IV.(1)(a), the Asheville Airport structural fill site is
considered individually-permitted by the Division. Permit Condition II.5.a. exemption is allowed at individually
permitted sites as stipulated in Condition IVA. which requires the establishment of a compliance and review
boundary around ash use site located outside the property boundary of the source-generating facility. Please
establish a compliance and review boundary in accordance with 15A NCAC 2L .0107(f) for the Asheville Airport
site including proposing location of monitoring wells, surface water sampling,etc. This monitoring is also being
required by the Division through permit Condition IV.(2)(a). Please provide documentation addressing this issue
within 90 days; and,
5. While the Asheville Airport's 401 certification references the "non-discharge requirements", Condition 12 of that
permit offers further clarification and restrictions by stating that"no waste ash fill over waters".
If Progress Energy believes the concerns outlined above can be addressed, you may resubmit your request with
additional supporting documentation to include, but not limited to, information to address these topics:
1. Progress Energy is to provide additional information on how the estimated 6% of ash fill that will not be overlain
by building footprint or paved surface on this project will be addressed if that ash exceeds the concentrations
listed in the table within Condition 5.;
2. In order to evaluate any setback reduction request, you would need to: (1) Demonstrate that use of ash as
structural fill for this project within 50 ft. of the stream will provide equal or better protection of the waters of the
State; (2) Identify potential receptors including water supply wells within 1000 ft. downgradient of the fill area;
and, (3) Identify any remedial or corrective measures or strategy that would be available if ash constituents are
detected in surface or groundwater at the site. Your demonstration should include a risk assessment or analysis
for all potential exposure pathways and predict potential environmental impact should engineered controls fail;
3. The Division is requesting that you evaluate the cost-effectiveness of:(1) overlaying the ash fill with a 1x10-6
cm/sec geosynthetic clay liner to further reduce potential infiltration and subsequent leaching of ash constituents,
and (2) using a composite liner such as a 60 mil HDPE membrane with either an underlying geosynthetic clay
liner with a maximum hydraulic conductivity of 5x10-9 cm/sec, or a 3-foot compacted clay liner with a maximum
hydraulic conductivity of 1x10-7 cm/sec.;
4. From the available drawings, it is not clear the extent to which the underlain liner will `wrap' on the sides of the
fill area as well as at the upgradient portion, nearest the junction box;
5. Please specify the life expectancy of the culvert material and include any contingency plan for repairing the
culvert should it be necessary in the future;
6. Verification that the Asheville Airport Authority has submitted an application for modification of the existing 401
permit, specifically, Condition 12 to allow ash to be used as fill over a culverted stream; and,
7. The subject permit allows you, the permit holder, to request an exemption to the 50 ft. stream setback.
Conditions that would likely be included with any permission to encroach on the 50 ft. setback would include
groundwater (monitoring well and possibly water supply well) and stream monitoring at a minimum. Any long-
term monitoring to verify the performance of the engineered controls to protect surface and groundwater would
be the responsibility of Progress Energy and therein, any required corrective measures pursuant to 15A NCAC 2L
.0106(d). One alternative arrangement would be for Asheville Airport to apply for a permit pursuant to T15A
NCAC 02T .1204 and seek setback reductions through a variance. Please provide documentation as to any access
AQUIFER PROTECTION SECTION—Asheville Regional Office(ARO)
2090 U.S.70 Highway,Swannanoa,NC 28778-8211
Phone:[phone] FAX:[phone] One
Customer Service:1-877-623-6748 Nofth Carolina
Internet:www.ncwaterguality.org
An Equal Opportunity 1 Affirmative Action Employer v ' wwrallY

arch 17, 2009
Page 3 of 3
agreements, deed restrictions etc. between Progress Energy and the Asheville Airport in regard to this structural fill
project.
If you feel that the above-referenced items can be sufficiently addressed, please forward the supporting
documentation to APS ARO for additional review and reconsideration of your request. If you should have any questions,
please do not hesitate to contact me directly at 828.296.4680.
Sincerely,
C-D4 - _
G. Landon Davidson, LG
Regional Supervisor Aquifer Protection Section
cc: SWP ARO—Roger Edwards
Cyndi Karol!/John Dorny—401 certification DWQ
Jon Risgaard-APS ND CO
Director—Asheville Airport
AQUIFER PROTECTION SECTION—Asheville Regional Office(ARO)
2090 U.S.70 Highway,Swannanoa,NC 28778-8211
Phone:[phone] FAX:[phone] One
Customer Service:1-877-623-6748 NorthCarolina
Internet:www.ncwaterguality.orq ��}��l/���`/�
An Equal Opportunity I Affirmative Action Employer N�/ S

A •L ,
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
• March 3,2009 E
� ®
Ms. Brenda Brickhouse Me�� 0
Director of Environmental Health and Safe 5 22
Progress Energy Service Company, LLC
410 South Wilmington Street LASheville Regional of fece)
PEB 40a.adfc�P Prrafr�r�trq��
Raleigh, NC 27601
Dear Ms. Brickhouse:
Progress Energy and the Division of Water Quality have been in"discussions concerning your company's participation in a
voluntary utility industry groundwater monitoring program. The purpose of this monitoring as we understand it is to help
determine the environmental impact of coal ash storage in on-site ash ponds. Over the past two years, we have received
one or more reports containing data from six of your facilities that operate under NPDES permits:Ashville Steam, Cape
Fear Steam, Lee Steam, Mayo Steam, Sutton Steam, and Weatherspoon Steam Power Plants.
Although most of the data for parameters sampled did not exceed standards, all of the reports included some standard
exceedances or pH values outside the allowable range. Due to concern about the relevance of these exceedances, we
need additional information regarding well locations, parameter lists, and sampling schedules for the facilities involved.
Please submit the following additional information by April 30, 2009:
• A list of all North Carolina facilities, indicating which facilities are expected to submit voluntary groundwater
monitoring data at any point in the future. Include the pre-determined parameter list and sampling schedule
(months)for each participating facility.
• Maps for each facility that is performing voluntary monitoring.
o Include appropriate markings for property boundaries,water supply wells etc.
o Show locations of all monitoring wells associated with the permitted ash ponds(voluntary or permit
related wells) in relation to the Waste Boundary, Compliance Boundary, and Review Boundary, as
defined in 15A NCAC 2L.0102, .0107, and .0108 respectively.
0 Identify each well as a background or downgradient well as applicable.
o Show the location of any waste disposal areas and other potential sources of contamination at the site.
• Electronic copies in Excel of all data collected previously in the attached format. Submit future data in the same
format according to the pre-determined schedule. (Attached format can be provided electronically).
• Copies of well construction records(Form GW-1)for all voluntary monitoring wells.
• An evaluation of the groundwater standard exceedances at each facility to determine if the facility is in
compliance. Include the following:
o Well locations in relation to the Waste Boundary, Review Boundary, and Compliance Boundary.
o Determination of exceedances relative to groundwater quality standards.
o Planned action as a result of the exceedances. This should be done in accordance with the applicable
sections of 15A NCAC 2L .0106.
AQUIFER PROTECTION SECTION
1636 Mail Service Center,Raleigh,North Carolina 27699-1636
Location:2728 Capital Boulevard,Raleigh,North Carolina 27604 One
Phone:[phone]\FAX 1:919-715-0588;FAX 2:919-715-6048\Customer Service:1-877-623-6748 NorthCarolina
Internet:www.ncwaterouality.ora
Naturally
An Equal Opportunity\Affirmative Acton Employer

Ms.Brenda Brickhouse
Director of Environmental Health and Safety Page 2
Progress Energy Service Company, LLC
Your prompt attention to this matter will be appreciated. If you have questions concerning this request, please contact
Ms. Debra Watts at(919) 715-6699.
Sincerely,
Ted L. Bush Jr.4Cief
Aquifer Protection Section
Attachment
cc: Coleen H. Sullins
Chuck Wakild
Jeff-Po.upart, NPDES.
Regi na1 quif_er Protection 5'ection Supervisors
Debra Watts
Files

COAL ASH POND VOLUNTARY MONITORING DATA
.-7WA`-_
GWStandard
(Mg/Ij 0
Arsenic Barium Boron Cadmium l Chromium Copper Selenium iron IManganese l pH I zinc Lead Nitrate TDS Sulfate jAntimony Be Ilium Chloride Fluoride Mercury Nickel Nitrite Silver IThallium
Well Locatlon
Well relative to Sample collection
Compliance
Date(Year-Month)
Name Boundary(CB)IRW..
Boundary(Re) F
!MW# Year-Month
1Year-Month
MW# Year-Month
IYear-Month I

�r
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
AQUXFER PROTECTION
March 3, 2009
Gary Whisnant
Plant Manager—Asheville Steam Electric Plant
Progress Energy Carolinas, Inc.
200 CP&L Drive
Arden, North Carolina 28704
Subject: Progress Energy's Response to NOV
NOV-2009-PC-0049
Permit Condition II.7.
Progress Energy Ash Distribution Program
Permit No. WQ0000020
Buncombe County
Dear Mr.Toepfer:
On February 10, 2009, the Division of Water Quality's, Asheville Office received Progress Energy's written
response to the Notice of Violation (NOV) issued on January 22, 2009. We have reviewed your response carefully,
evaluating the written response as well as the substantive discussion of our meeting on January 29, 2009. Based on this
information, the Division believes that you have complied with the NOV and are making efforts toward a long-term
solution to prevent wind erosion and distribution of the cenospheres.
The subject letter cites multiple actions Progress Energy is taking and other actions that are being evaluated to
reduce or eliminate "cenosphere travel" from the harvesting site. The Division respectfully requests that you provide us
with an update of these evaluations including which options are being implemented as well as any changes in the
frequency or method of harvesting cenospheres onsite. We request an update within the next ninety (90) working days
outlining the progress of implementation of any or all of the options cited as well as an evaluation of the effectiveness of
the options.
Within the subject letter response as well as in the meeting, Progress Energy requests further consideration
regarding the basis of the NOV issued; specifically in question is the Division's application of Permit Condition II.7 to the
cenospheres originating from the ash pond. After further consideration and review, the Division believes that the
distribution permit applies to all the components of ash cited in the permit including cenospheres. The Division
understands that the ash pond is an NPDES treatment unit, as you state in the response letter, however, we feel this fact
does not exclude application of condition II.7. of the distribution permit to ash material stored there just prior to
distribution (ie, harvesting in the case of cenospheres).
If you should have any questions, please do not hesitate to contact me at 828.296.4500.
Sincere) ,_ _
G. Landon Davidson, LG
Regional Supervisor Aquifer Protection Section
AQUIFER PROTECTION SECTION—Asheville Regional Office(ARO)
2090 U.S.70 Highway,Swannanoa,NC 28778-8211
Phone:[phone] FAX:[phone]
Customer Service:1-877-623-6748 brie O 6I'111,
a
Internet:www.ncwaterouality.org jJ� �1 �T01
An Equal OpportunitylAffirma6veActi 'MN�N����

1
YYYY � M--)OVED
F�B 10 2609
Progress Energy Asho�11a0 R �a0 Office ,
CERTIFIED MAIL: 7006 0100 0003 6098 4813 A uifer protection �
File Point: 12570-A, 12570-D February 9, 2009
Landon Davidson, Supervisor
NC Division of Water Quality,Aquifer Protection Section
NCDENR Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject:Response to NO V-2009-PC-0049
Progress Energy Ash Distribution Program
Permit WQ00020
Buncombe County
Dear Mr. Davidson,
This letter is sent in response to your letter dated January 22, 2009. We appreciate your consideration of
the points raised herein and your willingness to meet with us on January 29, 2009 to discuss these issues.
As we have discussed with you, our staff has been in the process of taking several actions to try to
alleviate any dusting problems in the neighborhood adjacent to the plant's ash pond.
Our staff have a slightly different interpretation of the language of the subject permit and offer these ,
comments in support of that position. The structure cited in your letter as"an-ash-stoma"is, in fact,
an N-&DJ S-parm #ed te-waer�treatment-unit and,.therefore, not a storage/stockpile from the ash reuse
permit perspective. The plant collects ash from the boilers in hoppers and uses a water stream to sluice
the ash to the ash pond. In the ash pond,the sluice water is subject to equalization and neutralization and
the heavier ash is settled in the pond while lighter material such as cenospheres rise to the surface of the
pond. The overflow from the pond passes through a skimmer and is discharged as per the NPDES permit. _
Furthermore,the ash pond should be considered the"source of coal combustion byproducts"or the point
of origin,not a stockpile. It is our belief that since the accumulation in the wastewater treatment pond
does not constitute a distribution of ash for reuse the ash reuse permit conditions are not applicable and no
violation of the permit occurred.
Progress Energy Carolinas,Inc. as a company takes its commitment to protect the environment, comply
with regulatory requirements and maintain good community relations very seriously. As has been
presented to you previously via email and in discussions, below is some basic information about
cenospheres along with a list of actions that have been undertaken(prior to involvement of the DENR
regional office):
• Cenospheres are formed during the combustion process where silica melts and forms hollow
spheres as it falls(silica dioxide composition).
• Cenospheres are collected with ash and sluiced to the ash pond(a permitted NPDES wastewater
treatment unit)with water,where they eventually float to the top of the pond due to their hollow
nature.
• Cenospheres are harvested at Asheville Plant by Sphere One and used to make refractories,the
center of bowling balls,and other products.
Progress Energy Carolinas,Inc.
Asheville Steam Plant
200 CP&L Drive
Arden,NC 28704

S �
J
• Cenospheres are harvested by placing a boom on the top of the surface of the ash pond and
dragging it by boat to the edge of the pond where a crane with a bucket scoops up the
cenospheres and piles them on the side of the pond and then into a truck for hauling.
• In winter,the cenospheres can freeze on the top of the ash pond and become dry,thereby
becoming airborne in winds. Extended periods of sub-freezing weather halt any ability to harvest
cenospheres from the top of the pond.
• At Asheville Plant, cenospheres are physically harvested at the ash pond corner nearest the
property line which has been stripped of trees by the adjacent landowner,creating a wind tunnel
that facilitates wind travel from the pond onto neighboring property(Lake Julian Trails condos,
Aberdeen Drive).
• In the spring of 2008,Asheville Plant staff planted 10 Leland cypress trees at the property line to
create a wind screen;the trees,unfortunately, are dying and are planned for replacement in spring
2009.
• In mid-December 2008, Charah(the onsite contractor responsible for removing ash from the
active pond for the Asheville Airport structural fill project) applied mulch with a dust suppressant
product to the cenosphere-harvesting area in an effort to stabilize cenospheres at the harvesting
point. Rain removed the mulch and product; and Sphere One placed straw at the harvesting point
in early January 2009. Charah reapplied mulch and dust suppressant onto the harvesting area on
January 25,2009.
• In January,2009,with the extreme cold temperatures the region has faced along with strong
winds, cenospheres blew from the pond onto property at Lake Julian Trails. Staff of the
Asheville Plant and PE Corporate Environmental Services received a complaint from a neighbor
in the community and,in response,the plant staff visited Lake Julian Trails to assess the
situation. At the same time,2 Asheville Plant engineers investigated the"ash pond to consider
new methods of stabilizing the cenospheres on the pond during this period of extended sub-
freezing temperatures.
• Charah began utilizing a water truck to wet the cenospheres at the harvesting area. Charah also is
attempting to spray water with a water cannon onto the ash pond, itself,to wet the cenospheres.
We note that Charah attempted to do this on January 21,2009 but the strong winds would not
allow water spray to reach the cenospheres on the top of the pond. Charah was successful in
pouring water from the pond's edge directly,onto the frozen cenospheres,thereby keeping a layer
of ice over the cenospheres for the remainder of January,21,22 and 23.
• Asheville Plant staff directed Sphere One to stay onsite and begin harvesting cenospheres once.
the temperatures permitted. This activity has commenced since our initial discussions with you.
• Charah plans to apply mulch and dust suppressant product to areas in the cenosphere-harvesting
area once temperatures allow. In the meantime, Charah will continue with water applications as
noted above. Additionally, Charah is supplementing cenosphere removal with Sphere One..
In addition to the actions Asheville Plant staff have taken prior to the complaint you received, our staff
are vigorously evaluating additional alternatives and actions. Some of the things under evaluation
include:
• Asheville Plant is evaluating the establishment of an alternate harvesting area that has more wind
buffer to eliminate cenosphere travel from the harvesting site proper.
• Asheville Plant is evaluating other harvesting methods that might allow cenosphere collection in
areas that are hard to reach and that will allow a more consistent harvesting.
• Asheville Plant is evaluating wind break options at the existing harvesting area including natural
and constricted barriers.
• Asheville Plant is evaluating options to accomplish more frequent harvesting of cenospheres.

i
• Asheville Plant is working with our Community Relations Manager in an effort to develop
reasonable options as well as communicating these to the neighbors of Lake Julian Trails.
We hope that these detailed actions show the commitment we have to addressing this issue appropriately.
In light of the significant steps Asheville Plant staff have taken and the differing interpretations of the
provisions of the ash reuse permit,we ask that you reconsider the Notice of Violation issued against the
subject permit. This permit is applicable to several of our facilities throughout the State and, as we
discussed at our meeting in your office,we are concerned about the extent to which the interpretation
might be used with respect to operations at those facilities. Thank you for your consideration in
evaluating this request. I look forward to your reply. If you have any questions,please feel free to
contact Mr.John Toepfer at(919) 546-7863.
Sincerely,
JF�r� G�
Garry LA Whisnant,Plant Manager
Asheville Steam Electric Plant

-IN
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Image®2009 DigitalGlobe a ( � C1008 Goode
�Vi5-2T49.78"N. 82°32'30.29"W eley 2184(t , May 20,2006 Eye all 403511 0

EMSL Anal tical, Inc. 107 Haddon Avenue,Westrnont NJ 08108
.y Phone:[phone]
Attn.: Walt Hendrix EMSL Case No.: 360900115
Progress Energy Sample(s)Received: 1/23/09
200 CPL Drive Date of Analysis: 1/27/09
Arden,NC 28704 Date Printed: 1/28/09
O Reported By: E.Mirica
Phone: [phone] Fax: 828-687
- Laboratory Report -
-Preliminary report-
Material Identification
• For
Project: Cenosphere
Analyzed by: January 28,2009
Eugenia Mirica,Ph.D. Date
Senior Materials Scientist
QA/QC: I January 28,2009
John Newton Date
Laboratory Manager
Progress Energy-360900115-Page I of 7-

EMSL Analytical Inc. 107 Haddon Avenue,Westmont,NJ 08108
Phone:[phone]
Attn.: Walt Hendrix EMSL Case No.: 360900115
Progress Energy Sample(s)Received: 1/23/09
200 CPL Drive Date of Analysis: 1/27/09
Arden,NC 28704 Date Printed: 1/28/09
Reported By: E.Mirica
Phone: [phone] Fax: 828-687
Procurement of Samples and Analytical Overview:
The samples for analysis (bulk) arrived at EMSL Analytical's corporate laboratory in Westmont,NJ on
January 23, 2009. The package arrived in satisfactory condition with no evidence of damage to the
contents. The samples were submitted for the purpose of determining the individual components. The
samples reported herein have been analyzed using the following equipment and methodologies.
Methods&Equipment: Light Stereomicroscope(LM)
epi-Reflected Light Microscopy(RLM)
Polarized Light Microscopy(PLM)
Scanning Electron Microscopy(SEM)
Energy-dispersive X-Ray Spectrometry(EDX)
X-Ray Diffraction(XRD)
X-ray Fluorescence(XRF)
Thermogravimetry(TGA)
Progress Energy-360900115-Page 2 of 7-

E1VISL Anal tic(dl, I11C. 107 Haddon Avenue,Westmont,NJ 08108
y Phone:[phone]
Attn.: Walt Hendrix EMSL Case No.: 360900115
Progress Energy Sample(s)Received: 1/23/09
200 CPL Drive Date of Analysis: 1/27/09
Arden,NC 28704 Date Printed: 1/28/09
Reported By: E.Mirica
Phone: [phone] Fax: 828-687
Results and Discussion.-
Table 1: The components of sample"Off site sample A" as determined by compilation of all the methods
used in the analysis.
Sample Identification Components Concentration(%) LOQ(%)
Off site sample A CenosphereslFly ash 94 1
Quartz 3 1
Carbon(total) 2 1
Unidentified <1 1
The concentration of total carbon was determined by thermogravimetry(weight loss upon heating).
Cenospheres are lightweight, inert, hollow sphere filled with inert air or gas, typically produced as a
byproduct of coal combustion at thermal power plants. They have a ceramic composition with SiO2 and
A1203 as the main components.
Progress Energy-360900115-Page 3 of 7-

EMSL Analytical, Inc. 107 Haddon Avenue,Westmont,NJ 08108
.v Phone:[phone]
CN-
Attn.: Walt Hendrix EMSL Case No.: 360900115
Progress Energy Sample(s)Received: 1/23/09
200 CPL Drive Date of Analysis: 1/27/09
Arden,NC 28704 Date Printed: 1/28/09
Reported By: E.Mirica
Phone: [phone] Fax: 828-687
Table 2. Elemental composition expressed as elements (measured) and oxides (by stoichiometric
calculation)for sample"Off site sample A".
A LOD
Element Conc. (wt%) Oxide Conc. (wt%) ON
Si 23.6 Si02 50.5 0.0027
Al 15.7 A120 29.6 0.0080
K 4.70 CaO 5.66 0.0053
Fe 3.70 K20 5.30 0.0023
Ca 1.16 CaO 1.63 0.0039
S 0.783 S02 1.96 0.0031
Mg 0.769 Mg0 1.27 0.014
Ti 0.717 Ti02 1.20 0.0030
Na 0.285 Na20 0.385 0.011
Ba 0.139 BaO 0.155 0.0099
Sr 0.0456 Sr0 0.0539 0.0012
P 0.0395 P205 0.906 0.0033
Zr 0.0289 Zr02 0.0390 0.0014
Rb 0.0281 Rb20 0.0307 0.0033
Mn 0.0204 MnO 0.0264 0.0011
Cr 0.0170 Cr203 0.0249 0.0026
As 0.0070 As203 0.0078 0.000078
Y 0.0139 Y203 0.0176 0.0085
Zn 0.0082 Zn0 0.0102 0.0014
Ga 0.0028 Ga203 0.00371 0.0014
C+0 Balance C Balance N/A
The concentration of Cr in the table is total chromium present in the sample. The concentration of Cr+6
is shown in Table 4.
Progress Energy-360900 1 1 5-Page 4 of 7-

EMSL Analytical, Inc. 107 Haddon Avenue,Westmont,NJ 08108
.v Phone:[phone]
Attn.: Walt Hendrix EMSL Case No.: 360900115
Progress Energy Sample(s)Received: 1/23/09
200 CPL Drive Date of Analysis: 1/27/09
Arden,NC 28704 Date Printed: 1/28/09
Reported By: E.Mirica
Phone: [phone] Fax: 828-687
Table 3. The concentrations of crystalline silica (quartz, tridymite and cristobalite) in sample "Off site
sample.A".
Sample Identification Quartz Cristobalite Tridymite Quartz Cristobalite Tridymite
Concentration(%) Concentration(%) Concentration(%) LOD LOD LOD
Off site sample A 3.2 <LOD .<LOD 0.6 2.5 2.5
Table 4. The concentration of Cr+6 in sample"Off site sample A"-
Sample Identification Analyte Concentration LOQ(wt%))
Off siter sample A Cr+6 <LOQ 0.00048
Progress Energy-360900115-Page 5 of 7-

EMSL Anal tical Inc. 107 Haddon Avenue,Westmont,NJ 08108
y , Phone:[phone]
Attn.: Walt Hendrix EMSL Case No.: 360900115
Progress Energy Sample(s)Received: 1/23/09
200 CPL Drive Date of Analysis: 1/27/09
Arden,NC 28704 Date Printed: 1/28/09
Reported By: E.Mirica
Phone: [phone] Fax: 828-687
1 -
Figure 1. SEM image of the cenopheres found in sample"Off site sample A".
Progress Energy-360900115-Page 6 of 7-

a
EMSL Analytical, Inc. 107 Haddon Avenue,Westmont,NJ 08108
Phone:[phone] y
GN+
Attn.: Walt Hendrix EMSL Case No.: 360900115
Progress Energy Sample(s)Received: 1/23/09
200 CPL Drive Date of Analysis: 1/27/09
Arden,NC 28704 Date Printed: 1/28/09
Reported By: E.Mirica
Phone: [phone] Fax: 828-687
Descriptions&Definitions:
None Detected(ND)denotes the absence of an analyte in the subsample analyzed.Trace levels of the analyte
may be present in the sample below the limit of detection(LOD).
Limit of Detection(LOD):The minimum concentration that can be theoretically achieved for a given analytical
procedure in the absence of matrix or sample processing effects.Particle analysis is limited to a single
occurrence of an analyte particle in the sub-sample analyzed.
Limit of Quantitation(LOQ):The minimum concentration of an analyte that can be measured within specified
limits of precision and accuracy during routine laboratory operating conditions
Concentrations for bulk samples are derived from Visual Area Estimation(VAE)unless otherwise noted.Air
sample concentrations are calculated to particles per unit volume.
VAE technique estimates the relative projected area of a certain type of particulate from a mixture of particulate
by comparison to data derived from analysis of calibration materials having similar texture and particulate
content. Due to bi-dimensional nature of the measurements,in some cases the particle thickness could affect the
results.
The results are obtained using the methods and sampling procedures as described in the report or as stated in the published standard methods,and
are only guaranteed to the accuracy and precision consistent with the used methods and sampling procedures. Any change in methods and sampling
procedure may generate substantially different results. EMSL Analytical,Inc.assumes no responsibility or liability for the manner in which the
results are used or interpreted.Legally defensible reports require hand signatures.Reports with digital signatures are for email and other digital
distribution only.
Progress Energy-360900115-Page 7 of 7-

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p Beverly Eaves Perdue,Governor
- Dee Freeman,Secretary
r North Carolina Department of Environment and Natural Resources
RE
'< Coleen H.Sullins,Director
COPY Division of Water Quality
AQUIFER PROTECTION
January 22, 2009
CERTIFIED MAIL 7002 0460 0001 9699 5732
RETURN RECEIPT REQUESTED
John Toepfer, P.E.
Senior Environmental Technical Specialist
Environmental Services
Progress Energy Carolinas, Inc.
410 S. Wilmington Street
PEB 4A-
Raleigh, NC 27601
Subject: NOTICE OF VIOLATION
NOV-2009-PC-0049
Permit Condition 11.7.
Progress Energy Ash Distribution Program
Permit No. WQ0000020
Buncombe County
Dear Mr. Toepfer:
On January 22, 2009 staff from the Asheville Regional Office of the Division of Water Quality
responded to a complaint regarding ash deposition on property adjacent to Progress Energy's ash
storage pond. The investigation revealed that ash from the ash pond had blown and accumulated on
several properties (homes, cars and lawns) in the Lake Julian Trails housing development.
The facility was found to be in violation of Permit WQ0000020 for the following: Permit
Condition 11.7. states in part: Adequate provisions shall be taken to prevent wind erosion and surface
runoff from conveying ash from stockpile/storage areas onto adjacent property or into any surface
waters prior to distribution and use....
NNo ehCarolina
aturally
North Carolina Division of Water Quality—Asheville Regional Office 2090 U.S.Highway 70 Swannanoa,NC 28778 Phone[phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877-623-6748
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

l
Mr. Toepfer
January 22, 2009
Page Two
Please refer to the.enclosed Inspection Report for any additional observation and
comments.
To prevent further action, carefully review this violation and respond in writing to this office
within fifteen (15) working days of receipt of this letter. You should address the causes of
noncompliance and all actions taken to prevent the recurrence of similar situations. If you should
have any questions, please do not hesitate to contact Beverly Price at 828/296-4500.
Sincerel
1 f�
G. Landon Davidson, LG
Regional Supervisor
Aquifer Protection Section
Attachment
cc: Laurie Moorehead, Senior Environmental Specialist Progress Energy Carolinas, Inc. w/
attachment
APS Central Files w/ attachment
APS Enforcement w/ attachment
APS ARO Files

.. r �►av- aooq- PG- oo"
0�WA Incident Incident Report
a
Report Number: 200900179
Incident Type: . Complaint On-Site Contact:
Category: APS-Permitted Site First/Mid/Last Name: Laurie Moorehead
Incident Started: 01/20/2009 Company Name:
County: Unknown Phone: [phone]
City: Pager/Mobile Phone: /
Farm#:
Responsible Party: Reported By:
Owner: Progress Energy Carolinas Inc First/Mid/Last Name: Elissa Glover
Permit: WO0000020 Company Name:
Facility: Progress Energy Ash Distribut Address: 42 Aberdeen Dr -
First Name: Paula
Middle Name.: J City/State/Zip: Arden NC 28704
Last Name: Sims Phone: [phone]
Address PO Box 1551 Pager/Mobile Phone: /
Peb 8
City/State/Zip: Raleigh NC 27602
Phone:
Material Category: Estimated Qty: UOM Chemical Name Reportable Qty.lbs. Reportable Qty.kgs.
DD:MM:SS Decimal Position Method:
Latitude: Position Accuracy:
Longitude: Position Datum:
Location of Incident. 42 Aberdeen Drive
Address: 42 Aberdeen Dr
City/State/Zip Arden NC 28704
Report Created 01/22/09 01:40 PM Page 1

Cause/Observation: Directions:
Wind blown cenospheres from the ash storage pond at Progress Hwy 25 south in arden to Glenbridge Road.Continue on to New
Energy settled onto neighboring property(homes,cars,lawns). Rockwood Road,turn right at light. Continue to Lake Julian Trails#42.
Action Taken: Comments:
site visit 1/22/09.NOV issued to Progress Energy. Cenospheres from the ash storage pond were covering the ground,cars
and houses adjacent to Progress Energy ash pond.Laurie Moorhead
from Progress Energy was contacted and was already aware of the
problem. Progress was in the process of determining a cleanup plan for
the adjoining property. They were also pouring water on the ice that had
formed on the pond which allowed the cenospheres to build up. The
cenospheres are scheduled to be harvested as soon as the weather
allows.
Incident Questions:
Did the Material reach the Surface Water? Unknown Conveyance:
Surface Water Name?
Did the Spill result in a Fish Kill? No Estimated Number of fish? 0
If the Spill was from a storage tank indicate type. (Above Ground or Under Ground)
Containment? Unknown
Cleanup Complete? Unknown
Water Supply Wells within 1500ft: Unknown Groundwater Impacted : Unknown
Event Type Event Date Due Date Comment
Incident closed
Requested Additional Information
Report Entered 2009-01-22 01:16:34
Referred to Regional Office-Primary Contact 2009-01-21 10:00:00
Report Created 01/22/09 01:40 PM Page 2

AI •r
Incident Start 2009-01-20 08:50:00
Report Received 2009-01-20 08:50:00
Standard Agencies Notified:
Agency Name Phone First Name M.I. Last Name- Contact Date
Other Agencies Notified:
Agency Name Phone First Name M.I. Last Name ,; Contact Date
DWQ Information:
Report Taken By: Report Entered By: Regional Contact:
-• Landon Davidson Beverly Price Beverly Price -
Phone: .
Date/Time: 2009-01-20 08:50:00 AM 2009-01-22 01:16:34 PM 2009-01-21 10:00:00 AM
Referred Via: Phone Phone
Did DWQ request an additional written.report?
If yes,What additional.information is needed?
Report Created 01/22/09 01:40 PM Page 3

' ° 4
Permit:WQ0000020 Owner-Facility: Progress Energy Carolinas Inc
Inspection Date: 01/22/2009 Inspection Type:Complaint Reason for Visit:Complaint
Inspection Summary:
The investigation was a result of a complaint filed by Elisa Glover. Ms. Glover's property is adjacent to Progress Energy's
ash storage pond. The ash had blown onto adjacent property(cars, homes, lawns). Laurie Moorehead, Senior
Environmental Specialist with Progress was notified and was already aware of the problem. Progress Energy is in the
process of determining a cleanup plan for the adjoining property owners.
Type Yes No NA NE
Land Application
Distribution and Marketing fl
Record Keeping Yes No NA NE
Is GW monitoring being conducted,if required? ❑ 0 ■ ❑
Are GW samples from all MWs sampled for all required parameters? ❑ 11 ■ Cl
Are there any GW quality violations? Cl Q ■ Cl
Is GW-59A certification form completed for facility? Q ❑ ■
Cl
Is a copy of current permit on-site? Q ❑ ❑ ■
Are current metals and nutrient analysis available? ❑ ❑ ❑ ■
Are nutrient and metal loading calculating most limiting parameters? Cl 0 Cl ■
a. TCLP analysis? Q 0 ❑ ■
b. SSFA(Standard Soil Fertility Analysis)? ❑ ❑ ■
Are PAN balances being maintained? D Q ■ 0
Are PAN balances within permit limits? Q ❑ ■ n
Has land application equipment been calibrated? ❑ Cl ■
Are there pH records for alkaline stabilization? Cl ❑ ■ ❑
Are there pH records W the land application site? ❑ Q ■
Are nutrient/crop removal practices in place? 0 Q ■ Cl
Do lab sheets support data reported on Residual Analysis Summary? ❑ ❑ ■ 11
Are hauling records available? ❑ ❑ Cl ■
Are hauling records maintained and up-to-date? Cl ❑ ❑ ■
#Has permittee been free of public complaints in last 12 months? Q ■ Q 11
Has application occurred during Seasonal Restriction window? Q ❑ ■ ❑
Comment:
Page: 2

Compliance Inspection Report
Permit: WQ0000020 Effective: 02/17/06 Expiration: 02/28/11 Owner: Progress Energy Carolinas Inc
SOC: Effective: Expiration: Facility: Progress Energy Ash Distribution Program
County: Unknown PO Box 1551
Region: Asheville
Contact Person: Paula J Sims Title: Vice President-Fossil Ge Phone:
Directions to Facility:
From Interstate 26 East take the Long Shoals Rd.Exit. Turn left onto Long Shoals Rd.and go approximately 1 mile to facility entrance
on the ri ht.
System�lassifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
24 hour contact name John R Toepfer Phone: [phone]
24 hour contact name Laurie Moorehead Phone: [phone]
Related Permits:
Inspection Date: 01/22/2009 Entry Time: 09:30 AM Exit Time: 10:30 AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Complaint Inspection Type: Complaint
Permit Inspection Type: Distribution of Residual Solids(503 exempt)
Facility Status: ❑ Compliant S Not Compliant
Question Areas:
Miscellaneous Questions 0 Record Keeping
(See attachment summary)
Page: 1

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