NC0003417_WARO Response_20161109

Environmental
Quality
November 9, 2016
Mr. Harry K. Sideris
Senior Vice President
Environmental, Health & Safety
Duke Energy
526 S. Church Street
Mail Code: EC3XP
Charlotte, North Carolina 28202
PAT MCCRORY
Govemor
DONALD R. VAN DER VAART
Secretary
JAY ZIMMERMAN
DWR Director
Subject: Plan of Action Review —Hurricane Matthew Response
H.F. l,ee Energy Complex
NPDES Permit No.: NC0003417
Wayne County
Dear Mr. Sideris:
On October 28, 2016, the Division of Water Resources Washington Regional Office
received Duke Energy's kequested Plan of Action document dated October 27, 2016. The Plan
of Action addresses information requested in the Division's letter dated October 21, 2016 due to
facility incidents resulting from Hurricane Matthew.
The report summarizes the cooling pond breach, triangular pond inundation, and inactive
ash basin incidents, along with actions taken in response to the incidents. Water quality
sampling efforts and data are also presented. A Sampling and Analysis Plan of Action is
recommended to further characterize any effects the incidents may have had on the Neuse River.
The following coinments are offered in response to the submitted Sampling and Analysis
Plan of Action:
Surface Water Sampling Schedule: Twice/Week on Tuesdays and Thursdays for three
additional weeks, ending on November 18, 2016.
• Sampling days (Tuesdays and Thursdays) are only separated by 2 days. To better
distribute sampling dates throughout the week, please amend the selected days to
provide better distribution over a seven day period (Monday/Thursday,
Tuesday/Friday, etc.) or provide additional clarification to support
Tuesday/Thursday dates.

• Sampling Conclusion Date (November 18, 2016) —Prior to suspending sampling
efforts on the specified date, available sampling data shall be evaluated to determine
whether any incidents occurring at the HF Lee Energy Complex have influenced
environmental quality in and along the Neuse River in the vicinity of the facility. A
request shall be made of the Division to suspend continued monitoring and
sampling efforts prior to taking such position. Such request shall be supported
through findings and conclusions of such efforts.
2. Surface Water Sampling (twice week)
• Discontinuing analysis of Priority Pollutants is approved.
• Expand analysis of metals sampling to include Aluminum, Boron, Barium and Total
Hardness. All metals shall be analyzed as both Total Metals and Dissolved Metals.
Please note the additional following comments regarding surface water sampling
activities.
With the adoption of the 2007-2014 NC Triennial Review Rules, instream Water
Quality Standards (WQS)'are dissolved and hardness dependent for lead, cadmium,
copper, and zinc. These metal samples shall be collected in the dissolved form along
with the stream Total Hardness so test results can be compared directly to the
instream WQS.
Expand monitoring and analysis of metals sampling to include both dissolved and
total phases of all metals as follows:
Aluminum, Antimony, Arsenic,
Beryllium, Boron, Cadmium,
Chromium, Copper, Iron,
Lead, Nickel, Selenium,
Silver, Thallium, Zinc,
Low-level Mercury, Total Hardness Barium
The aquatic life WQSs for Nickel, Arsenic and Acute Silver are dissolved; however,
the Total Nickel instream sample shall be compared to the Total Nickel Water
Supply WQS, the Total Arsenic instream sample shall be compared to the Total
Arsenic Human Health WQS, and the Total Silver instream sample shall be
compared to the Total Silver chronic aquatic life WQS.
• Expand monitoring to include field parameters (temperature, dissolved oxygen, pH,
conductivity, turbidity).

Screening Values
(150110 micrograms/L referenced for Dissolved Arsenic as Aquatic Life/Total
Arsenic as Human Health Screening Values; 5 micrograms/L referenced for Total
Selenium Aquatic Life Screening Value; 25 micrograms/L referenced for Total
Nickel Water Supply Screening Value; 0.06 micrograms/L referenced for Total
Silver Aquatic Life Screening Value
(Note arsenic aquatic life has increased but is a dissolved std.)
Laboratory analysis for all parameters shall utilize a Practical Quantitation Limit that
is indicative of laboratory capability and the analytical methodology. Raw lab data
shall be provided for all analysis identifying all detections and referencing Practical
Quantitation Limits and detection limits for performed analysis.
Sediment Sampling
• The provided report indicates that ash is most likely to settle in depositional areas
along the inside banks of river bends. Four sediment sampling locations are
identified (1 upstream; Ferry Bridge Rd wildlife boat ramp, 3 downstream; inactive
ash basin area, cooling pond breach area, Stevens Mill Bridge). Although sample
location DN 1 is in the vicinity of any potential release at the inactive ash basin
complex, it doesn't appear to be located in a significant river bend. Also, sample
location DN2 is depicted on the provided figure as being immediately below the
cooling pond breach.
Please provide additional clarification to support the proposed sediment sampling
locations, in light of provided narrative indicating deposition is likely to occur in low
energy environments along inside banks of river bends and with additional
consideration for river flow rates experienced during the hurricane flooding
conditions. `
Note, it may be practical to relocate DN2 further upstream to one of the bends along
the far eastern side of the cooling pond. You may also evaluate the feasibility and
benefit of adding an additional sampling location to the ones proposed.
A single sediment sampling event is proposed (unless findings indicate the need for
additional investigation). Please conduct a minimum of two rounds of sediment
sampling to address any potential variations in sampling and river conditions that
may be experienced on scheduled sampling dates.
Sediment Analyte List, Method Detection Limits, and Screening Levels (levels
provided for -Arsenic and Selenium)
Laboratory analysis for all parameters shall utilize a Practical Quantitation Limit that
is indicative of laboratory capability and the analytical methodology. Raw lab data
shall be provided for all analysis identifying all detections and referencing Practical
Quantitation Limits and detection limits for performed analysis.

Analytes shall be consistent with and include all metals that surface water samples
are analyzed for (proposed plus aluminum, boron, barium).
• Washington Regional Office staff shall be notified at least 72 hours (3 days) in
advance of scheduled sediment sampling to allow for coordinated split sampling
efforts with Division staff.
4. Water (chemistry) samples at sediment -water interface at UP, DNI, DN2, DN3
• Expand analysis to include field parameters (same as surface water samples)
• Ensure sample analytes are reflective of all metals and consistent with surface water
sampling analytes referenced above to include both dissolved and total phases of all
metals.
• One round of sampling is proposed. Please expand sampling events to two to
correspond with expansion of sediment sampling events referenced above.
Collection of Representative Coal Ash Sample from Inactive Ash Basin Complex
To better enable establishment of any potential correlation between pending findings and
source material from the inactive'ash basin complex, at least two representative coal ash
samples shall be collected from the inactive ash basin complex and characterized through
analysis. Selected sampling locations may be from areas identified where scouring and/or
sloughing may have, occurred and originate within a basin structure itself.
6. Reporting
• In addition to reporting analytical data in a tabular format, please ensure laboratory
reports are included with the final summary report
Prior to implementing the proposed Sampling and Analysis Plan of Action, please ensure
the items above are addressed and adequately resolved. You may coordinate with the
Washington Regional Office to resolve the above items. Please note that DEQ in no way has
limited or foreclosed its options with respect to further investigation or potential enforcement of
any violations which may have occurred at the H.F. Lee Energy Complex.
C!

Should you have any questions or additional information is needed, please contact me at
252-948-3939.
Si erely,
oo
David May, L.G., gi nal Supervisor
Division of Water ources
Water Quality Regional Operations Section
Washington Regional Office
cc: DEMLR— WaRO
WQROS Central Office