Cliffside Soil and GW Assessment Addendum Comments 12-20-19

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Paul Draovitch
Senior Vice President
Environmental, Health & Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, North Carolina 28202
NORTH CAROLINA
Environmental Quality
December 20, 2019
Subject: Soil and Groundwater Assessment Addendum — Coal Pile — Comments
James E. Rogers Energy Complex (Formerly Cliffside Steam Station)
Dear Mr. Draovitch:
On November 27, 2019, the North Carolina Department of Environmental Quality (DEQ) Division
of Water Resources (Division) received the Soil and Groundwater Assessment Addendum — Coal
Pile for the James E. Rogers Energy Complex (Formerly Cliffside Steam Station). The Division
has reviewed and hereby approves the proposed assessment activities with the following
conditions:
If any well is planned to be moved more than —100 feet from its proposed location due, for
example, to utility obstructions, the Asheville Regional Office (ARO) requests to be
notified for concurrence with the alternate location.
Because the assessment report must both map and explain the distribution of elevated
Constituents of Interest in the coal pile area (e.g. SO4, TDS, Cl, As, CO, V, Fe, Mn, pH,
etc.) adequate horizontal and vertical data must be collected. While it appears that the
proposed locations are adequate for this purpose, the results may indicate a need for
additional data collection. Given the timeframe for the delivery of the assessment report
(March 2020), ARO requests that Duke Energy notify ARO shortly after the initial round
of sample results are available to indicate whether or not additional data are needed to
support the objectives of the assessment report. This will allow consensus to be reached
on content and schedule of additional field work and (or) deliverables.
• It is requested that, in addition to the field data of borings and wells, results of the fate and transport
modeling and relevant geochemical modeling be used to understand and explain the contaminated
groundwater system. For example, it is noted that areas of elevated arsenic (e.g. wells CCR-IB-
3S, CP-1D, and CP-4S/BRU) have not been explained. If results of the modeling show current or
North Carolina Department of Environmental Quality I Division of Water Resources
e&.Of _ F0 512 North Salisbury Street 1 1636 Mail Service Center I Raleigh, North Carolina 27699-1636
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future impacts to groundwater and/or surface water from this area, then appropriate remedial
strategies shall be proposed in the revised Corrective Action Plan.
If you have any questions, please contact Ted Campbell (Asheville Regional Office) at (828) 296-
4500 or Steve Lanter (Central Office) at [phone].
Sincerely,
..il�
Rick Bolich, L.G. Chief
Ground Water Resources Section
Division of Water Resources
cc: ARO WQROS Regional Office
GWRS Central File Copy