Presentation_Lee sml Rev3_

COAL COMB USTION RESID UAL IMPO UNDMENT
RISK CLASSIFICATIONS
March 2016
Collaboration between:
Division of Water Resources
Division of Waste Management
Division of Energy, Mineral and Land Resources
Department of Environmental Quality

COAL COMB USTION RESID UAL IMP UNDMENT
RISK CLASSIFICATIONS
Background:
• Under the Coal Ash Management Act (CAMA) of 2014, all coal ash
impoundments in North Carolina are required to be closed.
• The deadlines for closure depend on the classification of each
impoundment as low, intermediate, or high.
• CAMA required the Department of Environmental Quality (DEQ) to make
available to the public a summary of the initial draft proposed
classifications in December 2015, and a full report in January 2016.
• These draft proposed classifications are based on the information
available to the department as of January 2016 and are posted on the
departments website, local library, and health department.
• The draft proposed risk classification for the H.F Lee Energy Complex is
Intermediate.
• Following completion of the public meetings and the submission of
comments, the Department will consider the comments and develop final
proposed classifications.
Department of Environmental Quality
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COAL COMB USTION RESID UAL IMP UNDMENT
RISK CLASSIFICATIONS
After the release of the summary of the initial draft proposed classifications,
CAMA requires the following process:
• DEQ must make available a written declaration that is a detailed report
explaining the methodology and technical approach used to evaluate the
available data and subsequently develop the resulting proposed draft risk
classification for each impoundment.
• Publish a summary of the detailed report in the local newspapers.
• Make the report available to the local health director and accessible at the
local library.
• A public meeting in each county with a coal ash facility.
• Consider all public comments and develop final proposed classifications.
Department of Environmental Quality
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COAL COMB USTION RESID UAL IMPO UNDMENT
RISK CLASSIFICATIONS
Closure Deadlines
• High risk impoundments: Dec. 31, 2019
• Closure plan due by Dec.31, 2016
• Intermediate risk impoundments: Dec. 31, 2024
• Closure plan due by Dec. 31, 2017
• Low risk impoundments: Dec. 31, 2029
• Closure plan due by Dec. 31, 2018
A

COAL COMB USTION RESID UAL IMP UNDMENT
RISK CLASSIFICATIONS
Four of Duke's 14 facilities are designated as high risk by the coal ash law.
Under CAMA, the department is required to consider the following factors,
at a minimum, in proposing classifications for the remaining 10 facilities:
1. Any hazards to public health, safety, or welfare.
2. Structural condition and hazard potential.
3. Proximity of surface waters to the impoundment
4. Information concerning the extent of soil and groundwater contamination.
5. The location and nature of all receptors and significant exposure pathways.
6. All factors influencing the movement of contaminants.
7. Consideration of coal combustion residuals in the impoundment.
8. Position in 100-year flood plain
9. Any other factor the department deems relevant to the establishment of risk.

COAL COMBUSTION RESIDUAL IMPOUNDMENT
RISK CLASSIFICATIONS
The department incorporated all of the preceding criteria into three primary
categories that were used to evaluate each impoundment:
• Structural Integrity
• Impact to Surface Water
• Impact to Groundwater
The draft classification process was iterative and took months to complete.
Recommendations regarding the impoundments were amended and
updated as additional scientific and technical information was received,
reviewed and verified.
Department of Environmental Quality

H. F. LEE ENER G Y COMPLEX RISK CLA SSIFI CA TION
Departme

H. F. LEE ENERGY COMPLEX RISK
CLASSIFICATION
Overall Draft Risk Classification
DEQ has proposed the risk classification for the Active Ash Pond, Polishing
Pond, Inactive Ash Pond #1, Inactive Ash Pond #2, and Inactive Ash Pond
#3 as INTERMEDIATE.
• Groundwater Key Factor: Based on the information received to date,
there appears to be no downgradient receptors located 1,500 feet
downgradient of the impoundment compliance boundary.
• Surface Water Key Factor: All of the impoundments at the facility are
located within the 100-year floodplain.
• Dam Safety Key Factor: The impoundments received a low or high risk
ranking before any repairs are made and a low risk rating once repairs are
made.
• Other factors and considerations associated with groundwater, surface
water, and dam safety were evaluated as part of the risk classification
process.
Department of Environmental Quality
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H. F. LEE ENERGY COMPLEX RISK
CLASSIFICATION
We will now receive public comments
To view additional information please visit www.deg.nc.gov
The public comment period will close on April 18, 2016
You may submit comments three ways, all weighted equally:
• Here orally and/or in writing
• Email to [e-mail]
• Postal mail to: N.C. Division of Water Resources, Groundwater Protection
Section, N.C. Department of Environmental Quality, Attn: Debra Watts,
1636 Mail Service Center, Raleigh, NC 27699-1611
Department of Environmental Quality
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