2017_07_12 Response to Aug 25 DEQ Ltr on Perf Mon Plan

I DUKE
ENtRGYn
P-al D,-�a:itah
Senior Vice -President
Environmental, HealtR & 5arety
5z'o 5outn cr,urcrl street
Iaa;1 comma EC3xP
cnano„e, lac 2o202
s80-373-twu8
September 12, 2017
Mr. Jay Zimmerman
Division of Water Resources
Forth Carolina Department of En�;runmental Quality
1611 Mail Service Center
Raleigh, North Carolina 4169s- la i i
Subject: Response to August 25, 2017 Letter on Revised Performance Monitoring Plan
Dear Mr. Zimmerman:
Duke Energy has reviewed the Department's second set of comments on Dake's Permanent
Water Supply (H66.j0) vvater i reatment System Performance Monitoring Plan. In general,
the Departments cemme„ts Mvere incorporated into the document with the fvllvwing
clarifications or isxceptions:
• Duke will be installing UV Sterliizom on all systems as an added safety measure.
However, if a well is contaminated .with fecal celifen„ bacteria from a septic system or
other scarce, the UV Sterili4ar does not provide sufficient treatment alone.
• The Performance Monitoring Plan has bean revised to state that water samples will De
submitted -Tor testing by approved EPA Methods. Labcratcriea shall be North Carolina
certified for the cu,st;taenta being analysed and atili sing methods capable of
achieving reporting levels to or below the assvciatetl performance standards.
Reference to the Safe Drinking Water Act ha,,u been removed from the documant
since the standard that Doke Energy is beii g held to for the water treatment systems
is the performance stantlanas and not associated with the US EPA Safe Drilnking
Water Act.
Sodom 3.0, Sample Collection Procedures, was substantially revised as requested by
the Department. There were two areas where Duke is requesting that the word
'°should : remains in the plan, as these are best practices and net ragairments for
proper sample collection:
oAs much as practical, sample car itainers shcald be pre -labeled prior to
sariipling to facilitate sample collection and ensure proper labeling. There may
be instances rrhuru the sample c;-,,,tainer will be labeled by the water
treatment veridur while they are on -location.
o Prier to the installation uf the water treatment systems. a raw water sample
needs to be collected. Section 3.0 states: "ideally, raw water samples should
be collected from a tap or spigot located at or near the well head or pump
hvasa and before the water supply is introduced into any storage tanRs or
treatment units.`- This is to cover the initial sample. A pre-treatment sampling

pVrt Y.ill be In.7tallod in QII .7yotGTs tV facilitate the cullo ,tium of a ra., ,.ato
sample after the system is installed.
• Section 3.2 included the pruvisiun of using a secondary cuntaine, to transfer samples
from spigots with low grountl clearance. since ipe systems will Oe installed whM
sampling ports that are easily acceaaible, the p, uvisii-in of u3ing a secondary container
was intended fur situations occurring daring initial site visits where existing plumbing
required collection from spigots with low ground clearance. Duke Energy also does
nut recummend sampling with a secondary ve550 ul kla5 there is , iv ether optiui,.
• Clarifications have been made tu- Section 2.2, Section 3.2, Section 4.0, Sactiun 5.0
and Table , to address the Department's comments on tflese sections.
• Duke Energy plans on offering antler Me counter reverse osmosis tRQ) systems as a
fil lal treatment moa5uurc for puint-cf-use vvater supply for drinking aind cocking for
cutmarners who are on a sodium -restricted diet.
Regarding the Department's a55ertiun that "the prvpased t, eatme, it sysrms may catase the
water w berme mare corrasiva thin it otherwise would be,"Duke Energy believes that the
systems being propcacd ..ill pruvidc a benefit ,.ith reepout tz; curru5ivity. Thu metj-vrity of rave
water samples collected frm humeuwners' wells have demnstrated that their water is
alreauy corrosive, witfl pR values generally less than 6.5 standard units (SU). The treatment
syatums being installed will include cumpunants t-v neutralLu pH to within the required
performance standard (6.5 - 8.o SU). Thus_ the treatment systems will result In water that is
less corrosive than it would otherwiov have boon.
Duke Energy also llas concern witfl a requirement to enter households for the purpose of
aampling at the tap. Routine aampling at taps is incu, i515tunt with the Safe Dril king Water
Act, which requires samplir Ig at the tap for only a small number of homes being served by a
regulated system. Duke Energy respectfully regnuata that this expuctati-vn be rescinded.
Please let me know if you Have any questions witfl tale information provided above or with the
rcviacd Perfurrnancc Mu,,itvring Plan (attached).
Sinter y,
Paul Draovitcfl
SGnicr Vice President
Environmental. Health & Safety
Enclosed: PeRormance Monitoring Plan, September 12, 2017
cc: Shelia Holeman, Assistant Secretary, MCDEQ
Debra Watts, NCDEQ
Eric Smith, NCDEQ

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ENERGY
Permanent Water Supply - Water Treatment Systems
Performance Monitoring Plan
1.0 PROGRAM DESCRIPTION
1.1 Background
In compliance with N.C. Gen. Stat. 130A-309-21 (c1), House Bill 630 (1-113630), also referred to as the Coal
Ash Management Act (CAMA), Duke Energy will be installing whole house filtration (treatment) systems
on drinking water supply wells located inside the % mile radius of Duke Energy owned coal combustion
residuals impoundment compliance boundaries when either the well owner selects the treatment
system option or when connection to municipal water supply is technically or cost prohibitive.
The water treatment systems being installed for compliance with HB630 are robust systems, customized
based on an evaluation of each individual well's analytical characteristics. Duke Energy's testing of the
system technologies on multiple groundwater wells indicates that the technologies to be utilized on the
eligible wells will provide constituent removal efficiencies capable of meeting the North Carolina
Department of Environmental Quality's (NCDEQ) performance standards.
1.2 Scope
To ensure that the treatment systems function properly and provide water quality that meets the
performance standards set forth by NCDEQ, this Performance Monitoring Plan will establish
performance sampling frequencies, verification criteria, and corrective action, if required.
Duke Energy will collect initial samples of the untreated well water prior to installation of treatment
equipment. Analytical results from these samples, along with results obtained during sampling that
occurred in 2015, where available, will be reviewed by the treatment system companies. Although most
treatment systems will consist of "standard" components, additional components and/or specialty
resins will be added if analytical results indicate they are required to meet performance standards.
Records of installed equipment, equipment maintenance, operational issues, if any, and performance
analytical results will be maintained for each installed treatment system.
Water samples will be submitted for testing by approved EPA Methods. Laboratories shall be North
Carolina certified for the constituents being analyzed and utilize methods capable of achieving reporting
levels to or below the associated performance standards. Treated water will be collected after
equipment installation and during the annual maintenance for laboratory testing. Additional samples
may be collected during the year (e.g., during salt deliveries or call outs) if visual inspections of the
system(s) and/or field analytical tests indicate that the system may not be performing properly.
Additional information on how the system will be maintained and when samples will be taken is
provided in Section 2.0. Sample collection methods are provided in Section 3.0.
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Note: Well contamination from biological sources (e.g. Fecal Coliform) are not removed/treated by the
treatment systems being installed for compliance with HB 630. However, if the experienced treatment
system contractors observe possible biological contamination during periotic maintenance inspections,
the home owner will be informed so they can take appropriate action.
1.3 Data Quality Objectives
The overall quality assurance (QA) objective is to ensure that data of known and acceptable quality are
provided. All measurements will be made so as to yield results that are representative of the media and
conditions measured. All data will be calculated and reported in units consistent with those of other
agencies and organizations to allow data comparability.
Detection limits for the water analyses are generally specified by the analytical methods. Appropriate
methods have been selected to meet applicable standards for groundwater quality. Instances may
occur, however, in which the condition of the sample precludes attainment of the desired detection
limits for various parameters either because of matrix interference or high analyte concentrations
requiring sample dilution. The laboratory(s) will provide sufficient documentation with each data
package to allow reviewers of the data to be aware of encountered analytical anomalies.
2.0 PERFORMANCE VERIFICATION AND MAINTENANCE
Note: During the first year of operation, in order to demonstrate performance reliability, laboratory
samples will be collected during each scheduled maintenance/salt delivery visit.
2.1 Initial Treated Water Sample
Following installation of treatment equipment, a sample of raw, untreated water and treated water will
be collected for analytical testing by an independent laboratory, certified by the state for North Carolina
for drinking water analysis. The raw water sample will be collected at the well head if possible and
before any treatment equipment. The treated water sample will be collected from a sampling port
located after all treatment equipment and prior to the treated water entering the residential plumbing.
Analysis results, when received from the laboratory, will be compared to NCDEQ approved performance
standards. If any performance standards are not achieved in the treated water, corrective action(s) will
be initiated (see Section 4.0). Bottled water delivery will continue until verification that the treatment
system is meeting performance standards.
2.2 Salt Delivery Inspections
The major components of the treatment systems are comprised of ion exchange reactors that use a
brine solution to regenerate the resin bed. As part of the system maintenance, the treatment system
contractors will schedule periodic visits of no less than tri-annually to replenish the salt in the brine tank.
In addition to replenishing salt, the treatment system contractors will inspect the equipment to verify
that components are operating as designed and programed. Some field analytical methods may be used
to test that components are functioning correctly. Except during the first year of operation, samples will
not typically be collected for laboratory analysis unless there is an indication that the system is not
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functioning properly. Adjustments will be made if needed and corrective action initiated if necessary
(see Section 4.0).
2.3 Annual Maintenance
An annual maintenance visit will be scheduled by the treatment system contractor. The annual
maintenance will be more extensive than the salt delivery inspections. Maintenance may consist of
cleaning, sanitizing or replacement of resin beds based on system performance, replenishment of
expendable media, modification of programed routines on equipment, and field analytical methods to
check functionality of equipment.
Annual maintenance will also include collection of raw water and treated water for analytical testing by
an independent laboratory, certified by the state of North Carolina for drinking water analysis. Analysis
results will be compared to the performance standards in Table 1. If any performance standards are not
achieved in the treated water, corrective action(s) will be initiated (see Section 4.0).
2.4 Call Outs
Service telephone numbers will be posted with the treatment equipment for owners to call in the event
of equipment problems or concerns with operation. If call out service requires more than a "system
reset" or minor adjustments to programming, the water treatment company may schedule an additional
maintenance visit to correct issues and initiate corrective action if necessary (see Section 4.0).
3.0 SAMPLE COLLECTION PROCEDURES
3.1 Documentation
Thorough documentation of sample collection and identification is important to ensure the validity of
samples' corresponding analytical results.
Each installed system will be tagged with a unique identifier (example R02001) that will be utilized,
along with the physical address, for documenting installed equipment, analytical results, performance
evaluations, maintenance, etc.
Collected samples will be named using the unique identifier for the system along with additional
information to identify specific sampling points in the treatment process:
Example:
• R02001-RAW (untreated well water)
• R02001-P1 (Port 1— after softener)
• R02001-P2 (Port 2 — after dealkalizer)
• R02001-TW (treated well water at end of system)
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Notes:
• The treated water sample will be collected from the last test port on the treatment
system (e.g., after the last component of the treatment system but before point of entry
of the water into the home's piping).
• All sample locations will not be sampled for laboratory analysis. The intermediary ports
will be utilized for trouble shooting, if needed.
3.1.1 Sample Labels
Each sample container will have a label that clearly provides information identifying and describing the
sample. Sample labels shall provide the following information:
• Site Name
• Sample identification number/name
• Date and time collected
• Analysis type (metals, SO4, etc.)
• Preservatives
• Name or initials of sample collector
All information contained on sample labels must be consistent with information provided on the sample
Chain of Custody (COC).
As much as practical, sample containers should be pre -labeled prior to sampling to facilitate sample
collection and ensure proper labeling.
3.1.2 Chain of Custody (COC)
The Chain of Custody (Figure 1) tracks possession of samples from time of collection to delivery to the
laboratory, and clearly identifies which sample containers have been designated for each requested
parameter. The record includes the following types of information.
• Site Name
• Sample identification number/name
• Date and time of collection
• Number of containers
• Parameter requested for analysis
• Preservatives used
• Signatures of persons involved in the chain of possession
• Inclusive dates of possession
• Sample temperature (documented by lab personnel at sample receipt)
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3.1.3 Custody Seals
If samples are to be shipped to the laboratory by commercial courier services, custody seals will be
utilized on shipping containers.
Custody seals are placed over the closed opening of the shipping container making it impossible to open
the container without ripping the seal. Custody seals shall be used on each shipping container to
maintain the integrity of the sample custody process. Custody seals contain the signature of the person
responsible for packing the container and the date sealed.
3.1.4 Sample Custody, Shipment and Laboratory Receipt
A sample is in a person's custody if it is:
• In actual possession of the responsible person;
• In view, after being in physical possession;
• Locked so that no one can tamper with it, after having been in physical custody; or
• In a secured area, restricted to authorized personnel.
Handling of COC forms during sample transportation depends on the method of transport. If the
laboratory in within driving distance, the sample containers can be couriered to the laboratory. In this
case, the courier shall sign off on the COC. Commercial carriers will usually not accept responsibility for
handling and completing COCs. In this case, the COC is signed as relinquished by the responsible person
packing the container and the form is packed inside the shipping container (enclosed within a plastic
zipper —type bag) and the shipping container sealed per Section 3.1.3.
3.1.5 Treatment Company Documentation
During site visits, the treatment system company will evaluate installed equipment, record usage history
on the control head, replenish salt in the brine tank and performance other maintenance as needed.
Record of this work and other observations will be documented on the treatment company's forms and
copies furnished to Duke Energy.
3.2 Sample Collection (Performance Screening Samples)
During the first year of operation, in order to demonstrate performance reliability, laboratory samples
will be collected during each scheduled maintenance/salt delivery visit.
In subsequent years, laboratory samples will be collected:
• During the annual maintenance visit
• Following replacement of major components (ion exchange units) due to equipment failure
• For confirmation of a performance standard exceedance
• Following addition of new components to remedy upward trends of performance standards
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Samples of treated water collected for performance screening will be collected at a sample port after
the last piece of installed equipment but before entering into the homes' piping.
Ideally, raw water samples should be collected from a tap or spigot located at or near the well head or
pump house and before the water supply is introduced into any storage tanks or treatment units.
Installed systems will also contain a sample port located before any of the treatment components that
will be appropriate for collection of a raw sample.
Sample kits supplied by the laboratory will contain new, clean sample bottles, of the appropriate
material type and volume, with required preservatives, for analysis of the parameters listed in Table 1.
Sample locations shall be free of debris and attachments such as hoses or clamps, which must be
removed to allow for proper collection.
The following procedures will be utilized during sample collection:
• Proper personal protective equipment (PPE) (e.g., outer gloves) shall be worn and changed
between each sample location to reduce potential cross -contamination.
• The system shall be purged at full volume for a minimum of 5 minutes or until the water
temperature is constant.
• After sufficient purge, reduce flow rate to about a % inch diameter flow (i.e., the stream with
should resemble the width of a pencil.)
• Measure and record field measurements for pH, specific conductance, temperature, and
turbidity.
• Fill sampled containers directly from the port giving care not to overflow pre -preserved bottles.
If necessary, use a secondary container, such as a clean 8 oz. or similar size jar, to obtain and
transfer samples form spigots with low ground clearance.
• Wipe dry the outside of the bottle and complete required entries on the sample label.
• Complete all sample documentation and shipping forms and pack the sample container for
shipment, utilizing appropriate preservation requirements.
4.0 Corrective Action
Although the treatment system components are of high quality, given the number of installed systems
and the expected length of service, system components and/or treatment strategies may require
adjustments. If equipment inspections indicate equipment is not operating properly or if field analytical
results indicate performance issues during the maintenance inspections described in Section 2.0, the
water treatment company will initiate corrective action. Corrective action may range from more
frequent regeneration of resin beds to installation of additional equipment. The water treatment
company will inform Duke Energy of adjustments to installed equipment and confer with Duke before
installing additional or replacing existing components. If more than minor adjustments are made, a
treated water sample will be collected for laboratory analysis.
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The following are examples of minor adjustments that would not result in the need to collect a sample
for laboratory analysis:
• Resetting/adjusting the time of day clock
• Adjusting regeneration cycle due to a change in hardness
• Additions to or replacement of expendable media
• Changing a O-ring to correct leakage
The following represent corrective actions associated with several scenarios:
Scenario 1— Field analytical results indicate that system adjustments are needed
• The water treatment company will run field analytical methods during site visits to
determine if adjustments are needed to system components to optimize treatment. These
adjustments are better classified as operational adjustments than as corrective actions. An
example is adjusting the regeneration cycle.
Scenario 2 — Equipment Failure (Power Loss)
Power outages generally do not require service. The equipment memory will reset the programed
settings when power is restored and will run a regeneration cycle for an outage over four (4) hours. If
the system fails to restart upon restoration of power:
• Household will be able to still utilize the well.
• Household will need to contact the water treatment company.
• The water treatment company responds to property within 24-48 hours.
• Technician resets equipment and verifies proper operation.
Scenario 3 — Equipment Failure (damaged or faulty equipment)
• Equipment failure due to damaged or faulty equipment would be either communicated by
the household directly to the water treatment vendor or found during a scheduled
maintenance visit.
• Treatment company informs homeowner and Duke Energy of the equipment issues.
o Treatment company inspects and cycles equipment if possible, and utilizes field
analyses to test system operation, or
o Treatment company repairs or replaces failed equipment, and utilizes field analyses
to test system operation.
• Treatment company collects raw and treated water samples for laboratory analysis.
• Duke Energy reviews historical raw water analysis results. If historical results indicate that
the untreated water exceeds the performance standards, bottled water will be provided for
potable use.
• A 48 hour rush will be placed on the laboratory analysis of the treated water results.
• If analysis results indicate compliance with performance standards, return to routine
scheduled maintenance.
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• If analysis results indicate exceedance of a performance standard, bottled water will be
provided until systems issues have been resolved.
Scenario 4 — Treated water laboratory analysis result(s) exceed performance standard
• Contact household within 24 hours of discovery with the results.
• Initiate a resample to verify that exceedance isn't due to sampling or laboratory error within
24-48 hours of discovery.
• A 48 hour rush will be placed on the laboratory analysis of the treated water results
• Duke Energy reviews historical raw water analysis results. If historical results indicate that
the untreated water exceeds the performance standards, bottled water will be provided for
potable use.
• If resampled analysis results indicate compliance with performance standards, return to
routine scheduled maintenance. If resampled analyses indicate continued exceedance of
performance standards, steps in Scenario 3 will be followed.
If the yearly scheduled laboratory analysis indicates an increasing trend in results, the treatment
company will adjust the system components to optimize treatment. This may include modifying the
regeneration cycle or replacement of resin.
5.0 Report Submittal
The analytical results for each system installed as part of HB630 will be submitted to NCDEQ. Reports
will be generated every other month during the time that the systems are being installed. The report
will include a table for each household, showing the date of the installation, the raw water analytical
results, the treated water results and comparison to NCDEQ approved performance standards.
Homeowners will also receive a copy of the report for their household(s).
During the initial year of operation, analytical reports of treated water will be submitted to NCDEQ every
other month as long as performance standards are being met. If performance standards are not met,
notification will be sent to the household(s) within 24 hours of receiving the laboratory report. See
Section 4, Scenario 4 for corrective action steps. Results for any system not meeting performance
standards will be reported to NCDEQ within 15 days of receiving the laboratory report. A report of
corrective actions and analytical results confirming return to compliance with performance standards
will be provided to the household and to NCDEQ.
After the initial year of operation, a report showing the analytical results from the annual maintenance
of the systems will be submitted to NCDEQ on a semi-annual basis (by July 31 for the period January to
June and by January 31 for the period of July to December). The report will include the date of the
annual maintenance and the treated water results. The report will also include any significant repairs to
the systems that occurred during the six month period and results from any samples collected during
the salt deliveries, if samples were required. Homeowners will also receive a copy of the report for
their household(s).
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All Reports will be provided to the Division in electronic format only, by email to,
[e-mail]. Email subject lines will include the Division Region that the report or results
pertain to and sample results will be provided in Microsoft Excel format.
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Performance Standards
Parameter
2L Standard
IMAC
Alkalinity
-
-
Aluminum
-
-
Antimony
-
1 µg/L
Arsenic
10 µg/L
-
Barium
700 µg/L
-
Beryllium
-
4 µg/L
Bicarbonate
-
-
Boron
700 µg/L
-
Cadmium
2 µg/L
-
Calcium
-
-
Carbonate
-
-
Cobalt
-
1 µg/L
Chromium
(total
10 µg/L
-
2Chromium,
hexavalent
Expressed as total
Chromium
Copper
1 mg/L
-
Iron
300 µg/L
-
Parameter
2L Standard
IMAC
Lead
15 µg/L
-
Magnesium
-
-
Manganese
50 µg/L
-
Molybdenum
-
-
Mercury
1 µg/L
-
Nickel
100 µg/L
-
pH
6.5-8.5 Su
-
Potassium
-
-
Selenium
20 µg/L
-
Sodium
-
-
Strontium
-
-
'Thallium
-
2 µg/L
Total Dissolved
Solids
500 mg/L
-
'Vanadium
-
10 µg/L
Zinc
1 mg/L
-
Chloride
250 mg/L
-
Sulfate
250 mg/L
-
NOTES:
mg/L = milligrams per liter
Su = standard units
µg/L = micrograms per liter
'These INIAC values are proposed and are currently under rule review. Previously approved Oct. 1, 2010
IMAC for Thallium = 0.2 ug/l, and for Vanadium = 0.3 ug/l
2The 2L Standard for total chromium is based on the assumption that all chromium present is in the
hexavalent form.
TABLE 1 NC DEQ Performance Standards (June 2017)
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