Letter to Mr. Draovitch_20170113

..y
Environmental
Quality
January 13, 2017
Paul Draovitch
Senior Vice President
Environment, Health, and Safety
Duke Energy
526 South Church Street
Charlotte, North Carolina 28202
RE: Approval of Water Supply Plans
Dear Mr. Draovitch:
ROY COOPER
Governor
WILLIAM G. ROSS, JR.
Acting Secretan,
The Department of Environmental Quality (DEQ) has reviewed the information and proposal
submitted by Duke Energy on December 7 and 15, 2016, pursuant to N.C. Gen. Stat. § 130A-
309.211(c 1), in reference to the provision of permanent water supplies to households in
proximity to coal combustion residuals impoundments owned by Duke Energy. Based upon the
Findings of Fact (Attachment A), DEQ approves the proposal, subject to -the following
limitations:
1. Approval of the proposed Water Supply Plan does not relieve Duke Energy from
compliance obligations or permitting requirements under any other applicable state or
federal laws or regulations.
2. This letter does not constitute approval of the performance standards for contaminant
removal for proposed water treatment systems (filtration systems). DEQ will consult
with the Department of Health and Human Services with respect to appropriate
performance standards for contaminant removal and may revise such standards as
necessary to ensure a safe drinking water supply.
3. This letter does not constitute approval of the capability or design specifications of any
proposed water treatment system. Any such system must be designed to consistently
meet the required performance standards for contaminant removal. Duke Energy is
responsible for periodic maintenance of the system and shall submit for DEQ's approval
a performance monitoring plan for each system installed.
----Nothing Compares`-,,.
State of North Carolina I Environmental Quality
1611 Mail Service Center I Raleigh, North Carolina 27699-1611
919-707-9000

4. With respect to the Allen Steam Station, the determination of whether to provide water
treatment devices for community supply wells operated by Aqua North Carolina, Inc.,
interconnect the distribution system to another public water supply system, or relocate the
wells, is deferred pending further negotiation between DEQ, Duke Energy, and Aqua
North Carolina, Inc.
5. Duke Energy has proposed a compliance boundary for purposes of identifying
households located within one-half mile of the compliance boundary. This letter does not
address whether the location of the compliance boundary proposed by Duke Energy
complies with North Carolina regulations that establish the location of compliance
boundaries for regulatory purposes, including remediation. However, because DEQ
anticipates at this time that Duke Energy's proposed compliance boundary errs on the
side of covering more households, DEQ accepts the proposed compliance boundary for
the limited purpose of approving the Water Supply Plan. In the event Duke Energy
proposes expansions of a compliance boundary at any facility, it must resubmit a water
supply plan for the facility at which the compliance boundary is proposed to be
expanded.
6. In the event the analysis or evaluation of existing or future site investigations or modeling
demonstrates that contamination from the facility is expected to reach any water supply
wells for households not covered by the Water Supply Plan approved herein, Duke
Energy must comply with N.C.G.S. § 130A-309.211(c1)(ii) and submit to DEQ a plan to
provide such households with permanent replacement water supplies in accordance with
N.C.G.S. § 130A-309.211(c1) and in compliance with all applicable laws and
regulations.
7. As required by N.C. Gen. Stat. § 130A-309.211(c 1), Duke Energy must notify all
residents identified in the approved plan by April 15, 2017, of their eligibility for
establishment of a permanent water supply. Duke Energy must also provide DEQ with
updated data regarding which households elect to receive a water treatment system in lieu
of connection to public water supplies. As stated in the letter dated September 22, 2016,
from DEQ to Duke Energy, DEQ agreed that the threshold for cost -prohibition was an
acceptable planning value for purposes of the initial proposed plan. However, based on
site -specific factors and conditions, any determination as to whether connection to a
public water supply for a particular household would be cost -prohibitive is subject to
change.
8. Any modifications to the Water Supply Plan approved herein must be provided to DEQ
for evaluation and approval.
I remind you that N.C. Gen. Stat. § 130A-309.21 I (c 1) requires that, on or before April 15, 2017,
Duke Energy must notify all residents identified in the approved plan of their eligibility for
establishment of a permanent water supply. Additionally, absent an extension of time under the
terms of the statute, permanent water supplies for each household must be established by
October 15, 2018. 'Nothing Compares
State of North Carolina I Environmental Quality
1611 Mail Service Center I Raleigh, North Carolina 27699-1611
919-707-9000

Finally, approval of this plan is subject to changes resulting from the selection by the residents of
water supply options, and force majeure incidents preventing the implementation of the plan as
approved which are beyond the reasonable control of Duke Energy.
Please feel free to contact Jon Risgaard (919.807.6458; [e-mail]) or Debra
Watts (919.807.6338; [e-mail]) if you have any questions.
Sincerel ours,
-el
Ja i erman
Director, Division of Water Resources
cc: Secretary William G. Ross, NCDEQ
Sam M. Hayes, General Counsel, NCDEQ
Craig A. Bromby, Deputy General Counsel, NCDEQ
Tom Reeder, Assistant Secretary, NCDEQ
Kathleen Waylett, Senior Deputy Attorney General, NCDOJ
Encl. Attachment A -Findings of Fact
------'Nothing Compares.-.
State of North Carolina I Environmental Quality
1611 Mail Service Center I Raleigh, North Carolina 27699-1611
919-707-9000

Attachment A
Finding of Facts for:
Riverbend
Sutton
Allen
Belews Creek
Cape Fear
Dan River
Marshall
Roxboro
Weatherspoon
Asheville
Buck
Cliffside
Lee
Mayo

Findings of Fact Pursuant to N.C. Gen. Stat. § 130A-309.211(c 1)
Water Supply Plan for Riverbend Steam Station
1. Duke Energy timely submitted to the Department of Environmental Quality a
Permanent Water Supply Proposal (the "Plan") for Riverbend Steam Station in Gaston
County.
2. The Plan identified no households within 1/2 mile of a compliance boundary proposed
by Duke Energy in connection with facilities at the Riverbend Steam Station.
3. Locations were not provided as there were no eligible households identified.
4. Approximate costs per household for connection to a public water supply and/or
installation of water treatments systems were not provided as there were no eligible
households identified.
5. Duke Energy had not completed in the proposed plan the delineation of areas in which
contamination resulting from constituents associated with the presence of a coal
combustion residuals impoundment is expected to migrate, as demonstrated by
groundwater modeling and hydrogeologic, geologic, and geotechnical investigations of
the site. This work is ongoing. To the extent that the completed modeling and
investigations show contamination migrating to areas beyond areas presently proposed
for the provision of permanent water supplies at this facility, Duke Energy shall submit
a revised water supply plan for the facility.

Findings of Fact Pursuant to N.C. Gen. Stat. § 130A-309.211(c 1)
Water Supply Plan for L. V. Sutton Energy Complex
1. Duke Energy timely submitted to the Department of Environmental Quality a
Permanent Water Supply Proposal (the "Plan") for L. V. Sutton Energy Complex in
New Hanover County.
2. The Plan identified 14 households within 1/2 mile of a compliance boundary proposed
by Duke Energy.
3. Locations for each of the 14 households and the proximity of the household location to
connection point to the public water supply were precisely provided.
4. The Plan proposed to provide to 14 households a permanent source of water supply by
installation of a water treatment system on the basis that connection to a public water
supply would be cost prohibitive. Duke Energy will provide periodic required
maintenance for the water treatment system.
5. Approximate costs per household for installation of water treatments systems were
provided. The approximate cost per household for installation of a water treatment
system is $7,000 to $10,000.
6. Duke Energy had not completed in the proposed plan the delineation of areas in which
contamination resulting from constituents associated with the presence of a coal
combustion residuals impoundment is expected to migrate, as demonstrated by
groundwater modeling and hydrogeologic, geologic, and geotechnical investigations of
the site. This work is ongoing. To the extent that the completed modeling and
investigations show contamination migrating to areas beyond areas presently proposed
for the provision of permanent water supplies at this facility, Duke Energy shall submit
a revised water supply plan for the facility.

Findings of Fact Pursuant to N.C. Gen. Stat. § 130A-309.211(c 1)
Water Supply Plan for Allen Steam Station
1. Duke Energy timely submitted to the Department of Environmental Quality a
Permanent Water Supply Proposal (the "Plan") for Allen Steam Station in Gaston
County.
2. The Plan identified 272 households (including those served by three community supply
wells operated by Aqua North Carolina, Inc.) within 1/2 mile of a compliance boundary
proposed by Duke Energy.
3. Locations for each of the 272 households and the proximity of the household location
to connection point to the public water supply were precisely provided.
4. The Plan proposed to provide to 271 households a permanent source of water supply
by connection to a public water supply (City of Belmont), including an interconnection
between facilities operated by the City of Belmont and Aqua North Carolina, Inc., or
offered the installation of a water treatment system. The Plan further proposed to
provide to one household a water treatment system on the basis that connection to a
public water supply would be cost prohibitive. Duke Energy will provide periodic
required maintenance for the water treatment system.
5. Approximate costs per household for connection to*- a public water supply and/or
installation of water treatments systems were provided. The approximate cost per
household for connection to a public water supply is $26,800. The approximate cost
per household for installation of a water treatment system is $7,000 to $10,000.
6. Duke Energy had not completed in the proposed plan the delineation of areas in which
contamination resulting from constituents associated with the presence of a coal
combustion residuals impoundment is expected to migrate, as demonstrated by
groundwater modeling and hydrogeologic, geologic, and geotechnical investigations of
the site. This work is ongoing. To the extent that the completed modeling and
investigations show contamination migrating to areas beyond areas presently proposed
for the provision of permanent water supplies at this facility, Duke Energy shall submit
a revised water supply plan for the facility.

Findings of Fact Pursuant to N.C. Gen. Stat. § 130A-309.211(c 1)
Water Supply Plan for Belews Creek Steam Station
1. Duke Energy timely submitted to the Department of Environmental Quality a
Permanent Water Supply Proposal (the "Plan") for Belews Creek Steam Station in
Stokes County.
2. The Plan identified 58 households within 1/2 mile of a compliance boundary proposed
by Duke Energy.
3. Locations for each of the 58 households and the proximity of the household location to
connection point to the public water supply were precisely provided.
4. The Plan proposed to provide to 58 households a permanent source of water supply by
installation of a water treatment system on the basis that connection to a public water
supply would be cost prohibitive. Duke Energy will provide periodic required
maintenance for the water treatment system.
5. Approximate costs per household for installation of water treatments systems were
provided. The approximate cost per household for installation of a water treatment
system is $7,000 to $10,000.
6. Duke Energy had not completed in the proposed plan the delineation of areas in which
contamination resulting from constituents associated with the presence of a coal
combustion residuals impoundment is expected to migrate, as demonstrated by
groundwater modeling and hydrogeologic, geologic, and geotechnical investigations of
the site. This work is ongoing. To the extent that the completed modeling and
investigations show contamination migrating to areas beyond areas presently proposed
for the provision of permanent water supplies at this facility, Duke Energy shall submit
a revised water supply plan for the facility.

Findings of Fact Pursuant to N.C. Gen. Stat. § 130A-309.211(c 1)
Water Supply Plan for Cape Fear Steam Electric Plant
1. Duke Energy timely submitted to the Department of Environmental Quality a
Permanent Water Supply Proposal (the "Plan") for Cape Fear Steam Electric Plant in
Chatham County.
2. The Plan identified 4 households within 1/2 mile of a compliance boundary proposed by
Duke Energy.
3. Locations for each of the 4 households and the proximity of the household location to
connection point to the public water supply were precisely provided.
4. The Plan proposed to provide to 4 households a permanent source of water supply by
connection to a public water supply (Chatham County) or offered the installation of a
water treatment system. Duke Energy will provide periodic required maintenance for
the water treatment system.
5. Approximate costs per household for connection to a public water supply were
provided. The approximate cost per household for connection -to a public water supply
is $19,000.
b. Duke Energy had not completed in the proposed plan the delineation of areas in which
contamination resulting from constituents associated with the presence of a coal
combustion residuals impoundment is expected to migrate, as demonstrated by
groundwater modeling and hydrogeologic, geologic, and geotechnical investigations of
the site. This work is ongoing. To the extent that the completed modeling and
investigations show contamination migrating to areas beyond areas presently proposed
for the provision of permanent water supplies at this facility, Duke Energy shall submit
a revised water supply plan for the facility.

Findings of Fact Pursuant to N.C. Gen. Stat. § 130A-309.211(c 1)
Water Supply Plan for Dan River Combined Cycle Station
1. Duke Energy timely submitted to the Department of Environmental Quality a
Permanent Water Supply Proposal (the "Plan") for Dan River Combined Cycle Station
in Rockingham County.
2. The Plan identified one household within 1/2 mile of a compliance boundary proposed
by Duke Energy.
3. Location of the household and the proximity of the household location to connection
point to the public water supply were precisely provided.
4. The Plan proposed to provide the one household a permanent source of water supply
by connection to a public water supply (City of Eden) or offered the installation of a
water treatment system. Duke Energy will provide periodic required maintenance for
the water treatment system.
5. Approximate costs per household for connection to a public water supply were
provided. The approximate cost per household for connection to a public water supply
is $9,000.
6. Duke Energy had not completed in the proposed plan the delineation of areas in which
contamination resulting from constituents associated with the presence of a coal
combustion residuals impoundment is expected to migrate, as demonstrated by
groundwater modeling and hydrogeologic, geologic, and geotechnical investigations of
the site. This work is ongoing. To the extent that the completed modeling and
investigations show contamination migrating to areas beyond areas presently proposed
for the provision of permanent water supplies at this facility, Duke Energy shall submit
a revised water supply plan for the facility.

Findings of Fact Pursuant to N.C. Gen. Stat. § 130A-309.211(c 1)
Water Supply Plan for Marshall Steam Station
1. Duke Energy timely submitted to the Department of Environmental Quality a
Permanent Water Supply Proposal (the "Plan") for Marshall Steam Station in Catawba
County.
2. The Plan identified 127 households within V2 mile of a compliance boundary proposed
by Duke Energy.
3. Locations for each of the 127 households and the proximity of the household location
to connection point to the public water supply were precisely provided.
4. The Plan proposed to provide to 125 households a permanent source of water supply
by connection to a public water supply (City of Hickory) or offered the installation of
a water treatment system. The Plan further proposed to provide to two industrial
locations a water treatment system on the basis that connection to a public water supply
would be cost prohibitive. Duke Energy will provide periodic required maintenance
for the water treatment system.
5. Approximate costs per household for connection to a public water supply and/or
installation of water treatments systems were provided. The approximate cost per
household for connection to a public water supply is $23,400. The approximate cost
per household for installation of a water treatment system is $7,000 to $10,000.
6. Duke Energy had not completed in the proposed plan the delineation of areas in which
contamination resulting from constituents associated with the presence of a coal
combustion residuals impoundment is expected to migrate, as demonstrated by
groundwater modeling and hydrogeologic, geologic, and geotechnical investigations of
the site. This work is ongoing. To the extent that the completed modeling and
investigations show contamination migrating to areas beyond areas presently proposed
for the provision of permanent water supplies at this facility, Duke Energy shall submit
a revised water supply plan for the facility.

Findings of Fact Pursuant to N.C. Gen. Stat. § 130A-309.21 1 (c 1)
Water Supply Plan for Roxboro Steam Electric Plant
1. Duke Energy timely submitted to the Department of Environmental Quality a
Permanent Water Supply Proposal (the "Plan") for Roxboro Steam Electric Plant in
Person County.
2. The Plan identified 91 households within 1/2 mile of a compliance boundary proposed
by Duke Energy.
3. Locations for each of the 91 households and the proximity of the household location to
connection point to the public water supply were precisely provided.
4. The Plan proposed to provide to 91 households a permanent source of water supply by
installation of a water treatment system on the basis that connection to a public water
supply would be cost prohibitive. Duke Energy will provide periodic required
maintenance for the water treatment system.
5. Approximate costs per household for installation of water treatments systems were
provided. The approximate cost per household for installation of a water treatment
system is $7,000 to $10,000.
6. Duke Energy had not completed in the proposed plan the delineation of areas in which
contamination resulting from constituents associated with the presence of a coal
combustion residuals impoundment is expected to migrate, as demonstrated by
groundwater modeling and hydrogeologic, geologic, and geotechnical investigations of
the site. This work is ongoing. To the extent that the completed modeling and
investigations show contamination migrating to areas beyond areas presently proposed
for the provision of permanent water supplies at this facility, Duke Energy shall submit
a revised water supply plan for the facility.

Findings of Fact Pursuant to N.C. Gen. Stat. § 130A-309.211(c 1)
Water Supply Plan for W. H. Weatherspoon Power Plant
1. Duke Energy timely submitted to the Department of Environmental Quality a
Permanent Water Supply Proposal (the "Plan") for W. H. Weatherspoon Power Plant
in Robeson County.
2. The Plan identified 14 households within V2 mile of a compliance boundary proposed
by Duke Energy.
3. Locations for each of the 14 households and the proximity of the household location to
connection point to the public water supply were precisely provided.
4. The Plan proposed to provide to 7 households a permanent source of water supply by
connection to a public water supply (City of Lumberton) or offered the installation of
a water treatment system. The Plan further proposed to provide to seven households a
water treatment system on the basis that connection to a public water supply would be
cost prohibitive. Duke Energy will provide periodic required maintenance for the water
treatment system.
5. Approximate costs per household for connection to a public water supply and/or
installation of water treatments systems were provided. The approximate cost per
household for connection to a public water supply is $39,600. The approximate cost
per household for installation of a water treatment system is $7,000 to $10,000.
6. Duke Energy had not completed in the proposed plan the delineation of areas in which
contamination resulting from constituents associated with the presence of a coal
combustion residuals impoundment is expected to migrate, as demonstrated by
groundwater modeling and hydrogeologic, geologic, and geotechnical investigations of
the site. This work is ongoing. To the extent that the completed modeling and
investigations show contamination migrating to areas beyond areas presently proposed
for the provision of permanent water supplies at this facility, Duke Energy shall submit
a revised water supply plan for the facility.

Findings of Fact Pursuant to N.C. Gen. Stat. § 130A-309.211(c 1)
Water Supply Plan for Asheville Steam Electric Plant
1. Duke Energy timely submitted to the Department of Environmental Quality a
Permanent Water Supply Proposal (the "Plan") for Asheville Steam Electric Plant in
Buncombe County.
2. The Plan identified 40 households within 1/2 mile of a compliance boundary proposed
by Duke Energy.
3. Locations for each of the 40 households and the proximity of the household location to
connection point to the public water supply were precisely provided.
4. The Plan proposed to provide to 40 households a permanent source of water supply by
connection to a public water supply (City of Asheville) or offered the installation of a
water treatment system. Duke Energy will provide periodic required maintenance for
the water treatment system.
5. Approximate costs per household for connection to a public water supply were
provided. The approximate cost per household for connection to a public water supply
is $9,800.
6. Duke Energy had not completed in the proposed plan the delineation of areas in which
contamination resulting from constituents associated with the presence of a coal
combustion residuals impoundment is expected to migrate, as demonstrated by
groundwater modeling and hydrogeologic, geologic, and geotechnical investigations of
the site. This work is ongoing. To the extent that the completed modeling and
investigations show contamination migrating to areas beyond areas presently proposed
for the provision of permanent water supplies at this facility, Duke Energy shall submit
a revised water supply plan for the facility.

Findings of Fact Pursuant to N.C. Gen. Stat. § 130A-309.211(c 1)
Water Supply Plan for Buck Combined Cycle Station
1. Duke Energy timely submitted to the Department of Environmental Quality a
Permanent Water Supply Proposal (the "Plan") for Buck Combined Cycle Station in
Rowan County.
2. The Plan identified 189 within 1/2 mile of a compliance boundary proposed by Duke
Energy.
3. Locations for each of the 189 households and the proximity of the household location
to connection point to the public water supply were precisely provided.
4. The Plan proposed to provide to 188 households a permanent source of water supply
by connection to a public water supply (Salisbury Rowan Utilities) or offered the
installation of a water treatment system. The Plan further proposed to provide to one
household a water treatment system on the basis that connection to a public water
supply would be cost prohibitive. Duke Energy will provide periodic required
maintenance for the water treatment system.
5. Approximate costs per household for connection to a public water supply and/or
installation of water treatments systems were provided. 'The approximate cost per
household for connection to a public water supply is $26,200. The approximate cost
per household for installation of a water treatment system is $7,000 to $10,000.
6. Duke Energy had not completed in the proposed plan the delineation of areas in which
contamination resulting from constituents associated with the presence of a coal
combustion residuals impoundment is expected to migrate, as demonstrated by
groundwater modeling and hydrogeologic, geologic, and geotechnical investigations of
the site. This work is ongoing. To the extent that the completed modeling and
investigations show contamination migrating to areas beyond areas presently proposed
for the provision of permanent water supplies at this facility, Duke Energy shall submit
a revised water supply plan for the facility.

Findings of Fact Pursuant to N.C. Gen. Stat. § 130A-309.211(c 1)
Water Supply Plan for James E. Rogers Energy Complex
1. Duke Energy timely submitted to the Department of Environmental Quality a
Permanent Water Supply Proposal (the "Plan") for James E. Rogers Energy Complex
in Rutherford and Cleveland Counties.
2. The Plan identified 66 households within 1/2 mile of a compliance boundary proposed
by Duke Energy.
3. Locations for each of the 66 households and the proximity of the household location to
connection point to the public water supply were precisely provided.
4. The Plan proposed to provide to 64 households a permanent source of water supply by
connection to a public water supply (Grassy Pond Water Company) or offered the
installation of a water treatment system. The Plan further proposed to provide to two
households a water treatment system on the basis that connection to a public water
supply would be cost prohibitive. Duke Energy will provide periodic required
maintenance for the water treatment system.
5. Approximate costs per household for connection to a public water supply and/or
installation of water treatments systems were provided. The approximate cost per
household for connection to a public water supply is $39,000. The approximate cost
per household for installation of a water treatment system is $7,000 to $10,000.
6. Duke Energy had not completed in the proposed plan the delineation of areas in which
contamination resulting from constituents associated with the presence of a coal
combustion residuals impoundment is expected to migrate, as demonstrated by
groundwater modeling and hydrogeologic, geologic, and geotechnical investigations of
the site. This work is ongoing. To the extent that the completed modeling and
investigations show contamination migrating to areas beyond areas presently proposed
for the provision of permanent water supplies at this facility, Duke Energy shall submit
a revised water supply plan for the facility.

Findings of Fact Pursuant to N.C. Gen. Stat. § 130A-309.211(c 1)
Water Supply Plan for H. F. Lee Energy Complex
1. Duke Energy timely submitted to the Department of Environmental Quality a
Permanent Water Supply Proposal (the "Plan") for H. F. Lee Energy Complex in
Wayne County.
2. The Plan identified 42 households within 1/2 mile of a compliance boundary proposed
by Duke Energy.
3. Locations for each of the 42 households and the proximity of the household location to
connection point to the public water supply were precisely provided.
4. The Plan proposed to provide to 42 households a permanent source of water supply by
connection to a public water supply (Fork Township Sanitary District) or offered the
installation of a water treatment system. The Plan also recommends that one of Fork
Township Sanitary District's wells, located within the 1/2 mile boundary, be abandoned
and a new well installed at a location amenable to Fork Township Sanitary District.
Duke Energy will provide periodic required maintenance for the water treatment
system.
5. Approximate costs per household for connection to a public water supply were
provided. The approximate cost per household for connection to a public water supply
is $22,000.
6. Duke Energy had not completed in the proposed plan the delineation of areas in which
contamination resulting from constituents associated with the presence of a coal
combustion residuals impoundment is expected to migrate, as demonstrated by
groundwater modeling and hydrogeologic, geologic, and geotechnical investigations of
the site. This work is ongoing. To the extent that the completed modeling and
investigations show contamination migrating to areas beyond areas presently proposed
for the provision of permanent water supplies at this facility, Duke Energy shall submit
a revised water supply plan for the facility.

Findings of Fact Pursuant to N.C. Gen. Stat. § 130A-309.211(c 1)
Water Supply Plan for Mayo Steam Electric Plant
1. Duke Energy timely submitted to the Department of Environmental Quality a
Permanent Water Supply Proposal (the "Plan") for Mayo Steam Electric Plant in
Person County.
2. The Plan identified 22 households within 1/2 mile of a compliance boundary proposed
by Duke Energy.
3. Locations for each of the 22 households and the proximity of the household location to
connection point to the public water supply were precisely provided.
4. The Plan proposed to provide to 22 households a permanent source of water supply by
installation of a water treatment system on the basis that connection to a public water
supply would be cost prohibitive. Duke Energy will provide periodic required
maintenance for the water treatment system.
5. Approximate costs per household for installation of water treatments systems were
provided. The approximate cost per household for installation of a water treatment
system is $7,000 to $10,000.
6. Duke Energy had not completed in the proposed plan the delineation of areas in which
contamination resulting from constituents associated with the presence of a coal
combustion residuals impoundment is expected to migrate, as demonstrated by
groundwater modeling and hydrogeologic, geologic, and geotechnical investigations of
the site. This work is ongoing. To the extent that the completed modeling and
investigations show contamination migrating to areas beyond areas presently proposed
for the provision of permanent water supplies at this facility, Duke Energy shall submit
a revised water supply plan for the, facility.