WS-5761_20688_G_O_20210601_Memo to File

MEMO
Guilford County Environmental Health - HERA
To: FILE
From: Jordan Lerew
Date: June 1, 2021
Re: Duke Power – Friendly Ave. MGP (#20688)
Comments: In a letter from Duke Power to the NCDWM-UST Section, dated March 20, 2000 Duke Power
summarizes their conclusions drawn from the site work completed as part of the CSA requested for
the UST release incident. In 1999, prior to the completion of the CSA, Duke Power completed the
excavation of 35,000 tons of contaminated soil related to contamination derived from the MGP
facility. Duke states, “As noted in the report [CSA] the soil sample analytical data indicates that all
contaminant concentrations attributable to the unregistered UST found during the remediation of the
MGP site are below the Industrial/Commercial Limits, and there is no free product at the site that is
attributable to the UST…There are no significant risks as a result of the UST caused contamination at
the site.”

Duke Power continues by stating, “Duke Power thinks a significant portion of the onsite groundwater
contamination resulted from non-UST sources. Because of the need to address all the site
groundwater, the continued investigation of the UST-causes groundwater contamination as a separate
incident on the site would not be productive. Duke Power would like to continue the entire site
remediation with regulatory oversight of the Special Remediation Branch; Division of Waste
Management regarding future site use, future use risk assessment, and associated deed restrictions.”

Review of UST and Superfund reports indicate the site’s dissolved-phase contaminant plume is
comprised of BTEX, naphthalene, and PAHs. MGP and UST sourced plumes are comingled. Since 2001,
Duke Power and submitted annual groundwater monitoring reports to NCDWM-Superfund in
accordance with their Remedial Action Plan.

In discussions with Doug Rumford, the Superfund’s incident manager for the site, he states the
release’s clean-up goals for groundwater are the 2L Standard unless the RP should request a NFA
under RBCA regulations. A copy of the email is attached.