NC0001422_Appdx D - Alternative Water_20200814

Corrective Action Plan Update August 2020
L.V. Sutton Energy Complex SynTerra
APPENDIX D
HB 630 PROVISION OF WATER SUPPLY
COMPLETION DOCUMENTATION

(� DUKE
ENERGY
August 10, 2018
Ms. Shelia Holman
Assistant Secretary for Environment
North Carolina Department of Environmental Quality
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
Subject: Sutton Station HB 630 Completion
Dear Ms. Holman:
Paul Draovitch
Senior Vice -President
Environmental, Health & Safety
526 South Church Street
Mail Code ECUP
Charlotte, NC 28202
980-373-0408
Duke Energy has been diligently working to fulfill the requirements of North Carolina House
Bill 630 (HB 630) since it was ratified July 1, 2016. As provided in G.S. § 130A-309.213(d)(1):
The Department shall classify an impoundment as low -risk if the impoundment owner satisfies
both of the following criteria:
a. Has established permanent water supplies as required for the impoundment pursuant
to G. S. 130A-309.21 1 (c 1).
b. Has rectified any deficiencies identified by, and otherwise complied with the
requirements of, any dam safety order issued by the Environmental Management
Commission for the impoundment pursuant to G.S. 143-215.32.
Completion of Provision of Permanent Water
On December 13, 2016, Duke Energy submitted the Permanent Water Supply Plan to
NCDEQ for the Sutton Steam Station, located in New Hanover County. The initial plan
identified 14 businesses as being eligible under the requirements of HB 630 and
recommended offering all businesses the option the installation of a water filtration system.
On January 17, 2017, NCDEQ conditionally approved the Permanent Water Supply Plan for
Sutton. Duke Energy contacted the eligible business owners with the identified options for a
permanent water solution.
On May 5, 2018, NCDEQ confirmed:
... that HB630 did not cover offices, businesses, schools or churches, and that Duke
Energy may elect to cover these entities located within the one-half mile radius of the
compliance boundary. Further, since the legislation did not cover these entities, the
compliance deadline therefore does not apply.
On July 3, 2018, the Department requested certain information in order to confirm that Duke
Energy had fulfilled the obligations of the Provision of Permanent Water under HB 630,
including:

• A signed statement from the public water supplier that households who selected public
water supply as their solution have been connected and are receiving public water;
• A signed statement from the public water supplier confirming connections to those
households within the one-half mile radius from the established compliance boundary
who were already connected to the public water system at the time that the HB 630
was passed;
• A signed statement from the filtration system vendor that households who selected a
filtration system as their solution are now receiving filtered/treated water;
• A copy of the returned selection card from households that opted out of a permanent
water solution; and
• A statement of the timeline of events and submittals that were received/not received for
non -responsive households
Enclosed is a spreadsheet showing the Sutton properties initially identified in the Proposed
Plans submitted to the Department in December 2016 and approved by the Department in
January 2017, with those properties identified as initially requiring a permanent water supply
being noted by a "true" in the column labeled "Included in Original DEQ Submittal."
If it was later determined that a property was not eligible under HB630, it is noted by the word
"false" in the "Eligible for HB630" column. Properties were later determined not to be eligible
because they were a business, a church, a school, already connected to the public water
supplier, or an empty lot. Empty lots may contain buildings such as barns, sheds or garages,
but do not contain a household structure.
If a household was connected to the public water supplier in the past, or if they were
connected by Duke Energy as part of HB630 to the public water supplier, confirmation has
been provided by the local public water supplier in Appendix A. Included in the confirmation
are homes that may not currently have an account with the public water supplier due to
delinquent payments, renovations, etc., but have had an account in the past.
If a household chose connection to a water filtration system under HB630, confirmation has
been provided by the water treatment vendor in Appendix B.
Appendix C contains copies of the "opt out" selection cards.
The timeline of events for non -responsive households, previously provided in a May 30, 2018
submittal to the Department, have been included in Appendix D.
Appendix E contains tax records for properties original identified as being eligible, but were
later determined not to be eligible because the buildings identified on the properties were not
households structures.
Appendix F contains a copy of the letters sent to homeowners who will be connected in the
future as their household has been impacted by hurricanes, fire, or by being demolished by
the homeowner after the date of the HB630. These future connections were approved in the
Department's May 8, 2018 letter.
2

All properties identified in the original Sutton submittal were businesses, therefore none are
eligible for a permanent water solution under HB 630. While the requested documentation
confirming Duke Energy's compliance with HB 630 is not applicable to businesses, Duke
Energy has provided the "opt out" card for two of the business for your files.
Request for Confirmation
As the original Coal Ash Management Act deems the Sutton coal combustion residuals surface
impoundments as "high -priority," requiring excavation, Duke Energy does not intend to seek
confirmation of a low -risk classification pursuant to G.S. § 130A-309.213(d)(1). However, based
upon the above information, Duke Energy respectfully requests that NCDEQ confirm that the
requirements set out in G.S. § 130A-309.211(c1) "Provision of Permanent Water Supply" for the
Sutton Steam Station are complete.
Sincere ,
Paul Draovit
Senior Vice President
Environmental, Health & Safety
Encl: Sutton HB 630 Provision of Permanent Water Supply Completion Documentation
3

Sutton Steam Station
HB630 Provision of Permanent Water Supply
Completion Documentation
August 10, 2018

Sutton HB630 Summary of Households
Facility
Sutton
Orig #
1
A..
3782
Included
Fredrickson Rd
in Original DEQ
Submittal
FALSE
ligible
HB630 -1.
FALSE
P",
Empty Lot
N/A
i
Empty Lot
Sutton
2
221
Sutton Lake Rd
TRUE
False - BCS
N/A - BCS
N/A - BCS
Sutton
3
218
Roymac Dr
TRUE
False - BCS
N/A - BCS
N/A - BCS
Sutton
4
3871
N 421 HWY
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
5
212
Transcom Ct
TRUE
False - BCS
N/A - BCS
N/A - BCS
Sutton
6
230
Sutton Lake Rd
TRUE
False - BCS
N/A - BCS
N/A - BCS
Sutton
7
235 (233)
Sutton Lake Rd
TRUE
False - BCS
N/A - BCS
N/A - BCS
Sutton
8
363
Metro Circle
FALSE
FALSE
Empty Lot
N/A
_
Empty Lot
Sutton
9
3601
Fredrickson Rd
TRUE
False - BCS
N/A - BCS
N/A - BCS
Empty Lot
Sutton
10
3535
Fredrickson Rd
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
11
364
Metro Circle
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
12
340
Metro Circle
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
13
3505
Fredrickson Rd
TRUE
False - BCS
Opt Out
Appendix C
Sutton
14
339
Metro Circle
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
15
310
Metro Circle
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
16
347
Metro Circle
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
17
307
Metro Cir
TRUE
False - BCS
N/A - BCS
N/A - BCS
Sutton
18
3901
N 421 HWY
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
19
3506
Fredrickson Rd
TRUE
False - BCS
Opt Out
Appendix C
Empty Lot
Sutton
20
249
Sutton Lake Rd
FALSE
FALSE
N/A - BCS
N/A
Other
Sutton
21
3405
Fredrickson Rd
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
22
323
Metro Circle
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
23
331
2 Metro Cir
TRUE
False - BCS
N/A - BCS
N/A - BCS
Sutton
24
315
Metro Circle
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
25
3813
421 Hwy N
TRUE
False - BCS
N/A - BCS
N/A - BCS
Sutton
26
3829
N 421 HWY
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
27
217
Sutton Lake Rd
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
28
3857
421 Hwy N
TRUE
False - BCS
N/A - BCS
N/A - BCS
Sutton
29
3875
N 421 HWY
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
30
207
Sutton Lake Rd
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
31
3515
N 421 HWY
FALSE
FALSE
N/A - BCS
N/A
Other
Sutton
32
3881
421 Hwy N
TRUE
False - BCS
N/A - BCS
N/A - BCS
Sutton
33
3327
Fredrickson Rd
FALSE
FALSE
N/A - BCS
N/A - BCS
Other
Sutton
34
201
Sutton Steam Plant Rd
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
35
4113, 4301
421 Hwy N
TRUE
False - BCS
N/A - BCS
N/A - BCS
Empty Lot
Sutton
36
4113, 4301
N 421 H+D15WY
FALSE
FALSE
N/A - BCS
N/A - BCS
Other
Sutton
37
4101
421 Hwy N
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
38
3941
N 421 HWY
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
39
4113
N 421 HWY
FALSE
FALSE
Empty Lot
N/A
Empty Lot
Sutton
40
4113
N 421 HWY
FALSE
FALSE
Empty Lot
N/A
Empty Lot
N/A - BCS: Not applicable, Business, Church and/or School (outside HB630) Page 1 of 1

Appendix A:
Confirmation of Connection from Public Water Supplier
(N/A for Sutton — all businesses)

Appendix B:
Confirmation of Installation of Water Treatment System
(N/A for Sutton — all businesses)

Appendix C:
Opt Out Selection Cards

J
To be completed by well owner-
#19
Please select one of the following options as a permanent water
solution for your property and return this self-addressed card.
Refer to the enclosed letter for additional information.
Installation of Water Treatment System
-jar Opt Out Mr. Hansen Matthews
321 Windemere Rd.
Well Dwne Name Wilmington, NC 28405-4027
i y
ell Owner Signature Date
Well Address
3506 Fredrickson Rd
Wilmington, NC 28402
One vote per well address.
Reproduction or transfer of this selection card is strictly prohibited.
Sutton
f� DUKE
ENERGY®
F 2072 Duke Energy Corporation 163254 X2 1/12

To be completed b well owner: #13
P Y
Please select one of the following options as a permanent water
solution for your property and return this self-addressed card.
Refer to the enclosed letter for additional information.
r Installation of Water Treatment System
r w
Qpt Out
ei
------------
Wall �t�tivr7er dme —
P�_ _______� Z
— — Udie
Well Address
One vote per well address.
Reproduction or transfer of this selection card is strictly prohibited.
KE
� N E RGYe
1ST. ,

Appendix D:
Timeline of Events for Non -Responsive Households
(N/A for Sutton — all businesses)

Appendix E:
Properties / Connections HB630 Eligible Originally
But Later Determined Not to be Eligible
(Does not include Businesses, Churches, Schools)
(N/A for Sutton — all businesses)

Appendix F:
Future Connection Letters to Homeowners
(N/A for Sutton — all businesses)

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
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
October 12, 2018
Subject: Completion of Permanent Alternate Water Supply Requirements Under General
Statute 13 OA-3 09.211(c 1)
L. V. Sutton Energy Complex
Dear Mr. Draovitch:
On August 10, 2018, the North Carolina Department of Environmental Quality (DEQ) received a
request from Duke Energy for L. V. Sutton Energy Complex for confirmation of completion of
the permanent alternate water provision under the Coal Ash Management Act (CAMA) General
Statute (G.S.) 130A-309.211(cl). Based on our review of the submitted documentation, DEQ
hereby confirms that Duke Energy has satisfactorily completed the alternate water provision under
CAMA G.S. 130A-309.211(cl) at the Sutton facility.
Please note that, since Duke Energy is still in the process of submitting or finalizing the Corrective
Action Plan for the Sutton facility and the results of groundwater modeling have not yet been
received, DEQ reserves the right to determine that additional households are eligible and shall be
provided permanent alternate water solutions per G.S. 130A-309.211(cl) based on any new
information provided. Any future determination of additional eligible households by DEQ will not
affect this confirmation of Duke's compliance with the October 15, 2018 deadline in G.S. 130A-
309.211(cl). Further, this confirmation letter does not constitute a final classification for any
impoundment under G.S. 130A-309.213(d).
X-2A
.ter.} ■� Q Aj
North Carolina Department of Environmental Quality
217 West Jones Street 11601 Mail Service Center I Raleigh, North Carolina 27699-1601
919.707.8600

If you have any questions, please feel free to contact Debra Watts at [phone].
Sincerely,
Sheila Holman
Assistant Secretary for Environment
cc: Jessica Bednarcik, Duke Energy, 526 South Church Street, Mail Code EC 12J, Charlotte,
NC 28202
WQROS WIRO Supervisor
WQROS Central File Copy
North Carolina Department of Environmental Quality
217 West Jones Street 11601 Mail Service Center I Raleigh. North Carolina 27699-1601
919.707.8600