Multi ID#'s_Additional Assessment Extension Request_20170127

gT DUKE
ENERGY
January 27, 2017
Mr. S. Jay Zimmerman, Director
rJivision of Water Resuar=s
North Carolina Department of EnvirotImerRal Quality
1611 Mail Service Center
Raleigh, North Carulina 27699-1611
En;IrenT® ,t -l. RaaItn 6 Sti tvtr
50 south Cnurcrl street
IVUI r-vaa EC13K
Charlotte, North Carolina zszvz
Subjuct: Extensio,, Ragaest - Additional Slte Asaeasments
James E. rtagers Energy Complex (formerly Cliffaide Steam Station)
NPDES Permit NC0005088 - Rutherford and Cleveland Counties
Roxboro Steam Electric Plant
NPDES Permit NC0003425 - Person County
W.H. Waaltherspoun Power Pia, it
NPDES Permit NC0005363 - Rvbazon County
Dear Mr. Zimmerman.
On August 18, 2015. Dake Energy (Duke) submitted Work Pla,,s fu. additional asscssmcnt
activities at the Jamul E. Rogers Energy Comple,& (Rogers), Ruxbum Steam Electric Plant
(RuAbu,u), and W.H. Weatherspuun (Weatherspoon) Power Plant. On November 23, (ruJsud
December z, 0 l t3) DuRe received North Carolina Di,lw ,n of Environmental Ucallty Divisiun of
Water Rvuoa us3 (DWR) approval to the Additional Site Assessment Approvals for those three
facilities noting a repoRing doe date of Larch 31; 2017.
On November 30, 2016 in a mustiny wash DWR Regional office personnel, Duke made DWR
aware that permitting ana constructability of monitoring vvulla would likely extend the 5vhedole5
for assusamunt beyond the March 31, 2017 date specified in the November « letter.
With this lutter, Duke requests a 60 -day mduri3icn for the Additional Site Assessment Plans at
Rm,buru aT,d Weatherspoon, and an extens;un antiI after ash removal is complete at Rogers.
The extension request for these sites is outlined in more detail balu.Y:
The arca ruquuated fur additional assessment at Rogers i5 an ash area across the
Broad River near the Unit 5 swuchyard. This area Ras tentatively been scheduled ro
begin excavation in the second quarter of 2017 pending r-cusipt of necessary permits.
Wella installed in the area of eAuavatiun would seed to be abanaaned prior to beginning
excavation resulting in reinstallation of most of the wells. Duku requests that installation
of the additional site aasessmant wells be postponed until completion of ash removal
from the area acts the Brad River. Dake intenas to propose an alternate schedale
ante there is more clarity on the completion date of ash uemuval. Preliminary
dlsoassiuraa have uLoarred with Asheville Regional Oiiice on this topic.

Mr. S. Jay Zimmerman. Director
January 2 t, zo
Page 2
RoAbor Steam Electric Plant
Work Plan Schedule
Section 8.17 Proposed Schedule of the York plan noted that field work would
begin appruximataiy 45 days following final NCDEQ approval with the CSA
Report submitted 60 days after receipt and validati%n of analytical data. The
prvposetl schedule accounted for permitting and asaassmenr of data obtained
during the site assessment. The schedule submitted in the Work Plan .as
aggressive with any alterations leading to the potential submittal Uf an incomplete
report.
• Additional r noniror ing well location
The Correctiun to the Additional Site Assessriient Approvals requested one
additional monitoring well cluster at a location southeast of MW-12BR. Dake
noted that the requested lucat;on ,was likely an error with rhe actual location
south,.eat of MW-12BR. Clarification for well cluster location was directed to
NCDEQ an November ei, e-016. uonfirmati%n of final cluster location was
received from NCDEw on Da4ember 1, 2016.
• Permit Requirement
he area of diaturbance for the 7 wall cluster IOcaiions is greater than 1 acre and
ther-ufur a requires an Erosion and Seaiment Control (E&SC) Permit frim NCDEQ
Division of band uuality. The initial E&SC permit application was submitted on
November 30, 2016 with a revision for the additional well cluster submitted on
Dece, , iber 6, c0 113. Clearing and creation of mrd-.aya/pads cannot begin until
the E&SC permit is recei.ad.
• Feasibility of compressed schetlule
Installation of accesa rads/pads and utility clearance will begin upon receipt of
E&SC permit. However, the work is weather -dependent .,ith driller mobilit-ation
not anticipates until approximately two weeks after Start of work with clearing ant]
road/pad inataliation continuing as well installation begins.
o Well installation and development - appmAmately 2 to 3 weeks
o Collection of gmaadwater and other media samples - approximately 1
week
o Analytical analysis - approx;matuly 3 to 4 weeks
a Data „alidativn of analytical rvabultb - approximately i week
o Report develcprinent and review - appru.imataly 4 wasks
Weatherowgun Poweraro it
• Work Plan Schedule
Sortion 8.0 P,opused Schedule of the work plan noted that fiuid work Yyoald
begin approximately 45 days follu.-ing final NCDEu approval with the CSA
Report submitted 60 days after receipt and validation of analytical data. The
propc5ed schadule accounted for permitting and assessment of data obtained
daring the site assessment. The schedule 5abn,itted in the work plan was
aggrussiye .,ith any alterations leading to the potential submittal of an incomplete
comprehensive report.

Mr. S. Jay Zimmerman, Director
Jai mary 27, 20
Page 3
Permit Requirement
The installation of ai, ..ella e, i the couliny pond dam required Darn Safety .York
Plan approval by the NC Division of Energy, Mineral, and Oand Resources.
Approval was received on Januaiy 12, 2017. Aligni,ig drilling resources could
not begin until this appru-Yal was received.
Feasibility of Compressed Schedul-W
The follu..ing estimated durations beginning on the receipt date of the Dam
Safety approval will move completion beyond the March 31, 2017 report date
specified in the -Currectium tv the Additional Site Assessment Appru„als" letter:
o Well installation and development - appruximately 2 to 3 wccks
o Collection of ground..ateu and other media samples - approximately 1
week
o Analytical analysis - approximately 3 to 4 weeks
o Data validation of analytical resalts - approximately i week
o Report davelopment and review - approximately 4 weeks
If you have comments and/or ganstiur,a, please direct them to me at 980-373-3719.
Sincerely,
D. Edwin M. SulliYan
Director, Waste and Groundwater Programs
Environmental, Health, & Safety
Lu NCDEu (electrnic): Eric Rice - NCDEu Raleigh Regional Office
Ted Campbell - NCDEQ Asheville Regional Office
Kent White - MCDE4r Fayuttuville Regional Ottice
Steve Lanter - NCDEU Raleigh
Eric Smith - NCDEQ Raleigh
Cu Duke (elemronic): Ryan Czup
Kimberlee Wirt