NC0005088_Additional Site Assesment Required 2016_20160708

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PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
Water Resources
ENVIRONMENTAL QUALITY S. JAY ZIMMERMAN
Director
July 8, 2016
Mr. Harry Sideris
Senior Vice President
Environment, Health, and Safety RECEIVEDINCDEfDWK
Duke Energy
526 South Church Street JUL 0 8 2016
Mail Code EC3XP yam Quality
Charlotte,NC 28202 Permitting Section
Subject: Additional Site Assessment Required
James E. Rogers Energy Complex(Formerly Cliffside Steam Station)
NPDES Permit NC0005088—Rutherford and Cleveland Counties
Roxboro Steam Electric Plant
NPDES Permit NC0003425 —Person County
W. H. Weatherspoon Power Plant
NPDES Permit NC0005363 —Robeson County
Dear Mr. Sideris:
The North Carolina Department of Environmental Quality's Division of Water Resources(DWR)
requests Duke Energy (Duke) provide data and conduct additional site assessment as needed to
characterize the distribution of coal ash residuals (CCR) at confirmed and potential coal ash
disposal areas at the James E. Rogers Energy Complex, Roxboro Steam Electric Plant, and the
W.H. Weatherspoon Plant. Descriptions and approximate locations of these areas are provided
below.
The additional assessments shall be included as part of the on-going Comprehensive Site
Assessments (CSAs) for each of the subject facilities. Please be advised that these areas are to be
included in an updated Groundwater Assessment Plan (GAP) that conforms with the North
Carolina Department of Environment and Natural Resources Notice of Regulatory Requirements
letter dated August 13, 2014 and Comprehensive Coal Ash Management Act (CAMA). Site
activities shall follow the requirements under 15A NCAC 02L.0106(g). An assessment of surface
water quality for those areas that have impounded or flowing water shall also be conducted.
Area(s) of Wetness (AOW) related to these disposal areas should be assessed pursuant to CAMA .
§130A-309.212.
State of North Carolina I Environmental Quality I Water Resources
1611 Mail service Center I Raleigh,North Carolina 27699-1611
919 707 9000

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Additional Site Assessment Required
July 8, 2016
The results of the characterization conducted to date in addition to pertinent historical records and
detailed plans for additional site assessments must provide adequate detail to allow technical
review of the proposed actions shall be provided to the DWR. GAPs are due to the DWR Central
Office and the appropriate DWR Regional Office no later than August 19,2016. Results of related
investigations may be submitted as a CSA Addendum Report at a later date.
In addition to performing site assessment activities, facility site maps must be updated with the
revised waste boundaries and proposed compliance boundaries established according to 15A
NCAC 02L Section .0107. A letter requesting the approval of the new compliance boundaries
shall be submitted to the appropriate DWR Central Office later than August 19, 2016.
The following are background information and approximate locations of the identified areas at
each of the subject sites requiring additional assessment:
James E. Rogers Energy Complex
On November 16, 2015, Duke communicated orally to DWR that a historical coal ash disposal
area located was identified just north of the Broad River and west of the switchyard at the James
E. Rogers Energy Complex. Duke staff estimated the area to be approximately 3 acres in size, but
stated that the full extent of the area is unknown. The approximate location of the area is shown
below encircled. This area was not addressed in the Groundwater Assessment Plan (GAP),
Comprehensive Site Assessment (CSA) report, or Corrective Action Plans (CAPs) submitted to
DWR. Characterization of CCR within the footprint of this disposal area was confirmed by Duke;
however, no data related to this disposal area has been provided to DWR at this time.
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Additional Site Assessment Required
July 8, 2016
Roxboro Steam Electric Plant
Area 1 —This area was discovered by Duke and presented orally to DWR during a joint meeting
on January 14,2016. This area is located directly east of the East Ash Basin and was subsequently
named by DWR the "Unnamed Eastern Extension Basin" for purposes of prioritization ranking
according to the Coal Ash Management Act. This area shall also include the discharge canal that
runs north along the eastern side of the East Ash Basin. This area was not addressed in the GAP,
CSA report, or CAPs submitted to DWR. The approximate location of the area is shown below
encircled.
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Area 2 — This area is located directly south of the West Ash Basin and encompasses the three
"fingers" of the dammed watershed and the drainage canal that runs north along the west side of
the West Ash Basin. The drainage canal should be assessed for the presence of coal ash and surface
water standards. Based on site visits and information presented in the CSA and CAP reports,DWR
suspects that coal ash may be present in this area. This area was not addressed in the GAP, CSA
report, or CAPs submitted to DWR. The approximate location of the areas is shown below
encircled.
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Additional Site Assessment Required
July 8, 2016
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W. H. Weatherspoon Power Plant
Duke informed DWR orally at a joint meeting on October 21, 2015, that the cooling pond may
contain coal ash. Also, according to the CSA Report for the facility, the cooling pond is part of
the treatment process before the effluent is discharged through the NPDES outfall. This area was
not addressed in the GAP,CSA report,or CAPs submitted to DWR; however,Duke has stated that
an investigation is currently underway. The approximate location of the area is shown below
encircled.
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Additional Site Assessment Required
July 8, 2016
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If you have any questions, please feel free to contact Steve Lanter at(919) 807-6444.
Sincerely,
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S. # erman, P.G., Director
Division of Water Resources
cc: Landon Davidson—Asheville Regional Office Supervisor
Danny Smith—Raleigh Regional Office Supervisor
Belinda Henson—Fayetteville Regional Office Supervisor
Jeff Poupart, DWR Water Quality Permitting Section Chief
WQROS Central File Copy
51 Page