Multi ID#'s_Revised Conditional Approval Add Areas Assessment_20161202

Water Resources
ENVIRONMENTAL QUALITY
PAT MCCRORY
Goremor
DONALD R. VAN DER VAART
Secretary
wy a 1�' .Ii�1 RN-114-35—MM
Director
December 2, 2016
Mr. Harry Sideris
Senior Vice President
Environment, Health, and Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, NC 28202
Subject: Correction to the Conditional Additional Site Assessment Approvals
James E. Rogers Energy Complex (Formerly Cliffside Steam Station)
NPDES Permit NC0005088 — Rutherford and Cleveland Counties
Roxboro Steam Electric Plant
NPDES Permit NC0003425 — Person County
W. H. Weatherspoon Power Plant
NPDES Permit NC0005363 — Robeson County
Dear Mr. Sideris:
On November 22, 2016, the North Carolina Department of Environmental Quality (DEQ) sent a
letter to your attention regarding the subject facilities in which an error was noted on page 3 in the
next to last paragraph. This letter is a corrected version that supersedes the before -mentioned letter
dated November 22, 2016.
On August 18, 2016, the DEQ received the proposed plans to conduct additional assessment
activities for the subject facilities per our request letter dated July 8, 2016. Based on a review of
the plans and other information received by DEQ Regional Office staff, conditional approval of
the plans is granted. DEQ's approval is contingent upon the following site specific conditions:
James E. Rogers Energy Complex
In the groundwater assessment report that will be provided following this investigation,
please include the AMEC Foster Wheeler ash sampling results (map and tabular data).
• If monitoring well data indicate exceedances of the 15A NCAC 02L groundwater
standards, notify DEQ's Asheville Regional Office immediately so that deeper wells may
be located and installed expeditiously. The deeper well(s) would be needed to determine
the vertical extent of groundwater contamination.
State of North Carolina I Environmental Quality I Water Resources
1611 Mail service Center I Raleigh, North Caroliva 27699-1611
919 707 90/10

• DEQ concurs with the proposed boring/well locations, of which six are ash -related and one
is background.
• DEQ concurs with the sample depth intervals for purposes of Unified Soil Classification
System descriptions.
Please revise the soil/ash sampling requirements as follows. For each of the six ash -related
boring locations, a lab analysis (constituents are listed in Table 2) should be conducted for
all sampled depth intervals that contain visual evidence of ash. If 4 or more intervals
contain ash, conduct a lab analysis only on the shallowest ash interval, the deepest ash
interval, and a composite of the remaining ash intervals, for a total of three ash lab analyses.
DEQ concurs with the 5 -foot minimum thickness criterion to determine when to analyze
variations in ash type (fly or bottom).
For soil sampling and lab analysis at each of the six ash -related boring locations, DEQ
concurs with the two proposed sample intervals: 2 feet below the ash/soil interface and 8
to 10 feet below the ash/soil interface.
• For SPLP analysis at each of the six ash -related boring locations, please conduct an analysis
on
o a) the sampled ash interval with the highest concentration of arsenic, selenium, and
strontium among all sampled ash intervals at that location, and
o b) a sample composited from the two sampled soil intervals at that location.
For soil sampling and analysis at the background boring location, please collect:
o a) one shallow soil sample at a depth that approximates the general depth of most
of the shallow soil samples from the other six borings,
o b) one deeper soil sample at a depth that approximates the general depth of most of
the deeper soil samples from the other six borings, and
o c) one SPLP sample that is a composite of the shallow and deeper intervals in a)
and b) above.
Please revise Section 2.2.3 to read that if inaccessible from the bank, a boat should be used
to collect three surface water samples upstream, adjacent to, and downstream of the AOIs.
These samples should be collected immediately adjacent to the bank during conditions that
approximate low or baseflow to the maximum extent possible and at least 5 days after a
previous rain event of any magnitude. Contact DEQ's Asheville Regional Office if this
request becomes difficult to meet based on weather conditions. Antecedent rainfall (prior
5 days and prior 48 hours) should be provided, along with its measurement location, as a
footnote in surface water results table.
Roxboro Steam Electric Plant
In the groundwater assessment report that will be provided following this investigation,
please identify on a map all private supply wells within a'/z mile radius of an assumed
compliance boundary around the study area, monitor well locations, any areas of wetness,
and surface water features.

DEQ recommends additional monitoring wells to be installed in each water -bearing
hydrostratigraphic unit at a nested well location south east of existing well MW-12BR.
• DEQ recommends relocating any proposed sampling point locations where insufficient
sediment recovery is an issue.
W. H. Weatherspoon Power Plant
In the groundwater assessment report that will be provided following this investigation,
please identify on a map all private supply wells within a 'h mile radius of an assumed
compliance boundary around the study area, monitor well locations, any areas of wetness,
and surface water features.
DEQ recommends moving the proposed sample location JC -1 to the drainage feature
before it enters the creek (coordinates N 34.5902, W 78.9660)
In response to your "Proposed Waste and Compliance Boundaries" letter dated August 19, 2016, DEQ
cannot approve the proposed revised compliance boundary locations for the subject facilities at this time.
DEQ will provide correspondence and direction regarding this issue in the near future.
Submit the findings of the site assessments for each subject facility as a groundwater site
assessment report. The respective site assessment reports shall include figures, tables, cross-
sections, and maps in a manner that provides an interpretation of site conditions. In each report,
include a map that shows all private supply wells, monitoring well locations, any areas of wetness,
and surface water features within a'/2 mile radius of a previously established compliance boundary
around the study area. Reports submitted in a data summary format will not be approved as an
acceptable documentation of findings. Submit site assessment reports for each facility by March
31, 2017.
Please begin implementing these plans immediately to include the conditional items listed. For general
questions, contact Steve Lanter at [phone]. For more specific questions, please contact our
Regional staff listed below:
• James E. Rogers Energy Complex: Ted Campbell at [phone]
• Roxboro Steam Electric Plant: Eric Rice at [phone]
• W. H. Weatherspoon Power Plant: Kent White at [phone]
Sincerely,
e
S. Jay2immerman, P.G., Director
Division of Water Resources
cc: ARO, FRO, & RRO WQROS Regional Supervisors and Assistant Supervisors
WQROS Central File Copy