HomeMy WebLinkAboutDuke Energy Performance Standards_20170614Water Resources
Environmental Quality
June 14, 2017
Paul Draovitch
Senior Vice President
Environmental, Health & Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, North Carolina 28202
Subject: Permanent Alternate Water Supply Response
Dear Mr. Draovitch,
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
In the Proposed Permanent Alternate Water Supply Plans (Plans) for all fourteen (14) facilities
submitted to DEQ in December 2016, Duke Energy proposed the following performance standards
for the whole house filtration systems:
"The performance standard for the water treatment system is also the Federal MCLs
except for those constituents identified in 2015 as having potential health concerns:
arsenic, hexavalent chromium, cobalt, iron, lead, manganese, sulfate and vanadium. For
these constituents, the performance standard will be either one-half of the MCL, or the
appropriate state standard, whichever is more protective. "
The Coal Ash Management Act (CAMA) requires restoration of groundwater to conform with the
requirements of 15A NCAC 02L. DEQ requests performance standards to be the 15A NCAC 02L
groundwater standards (21- Standards). If there is not a 2L Standard, the proposed Interim
Maximum Allowable Concentration (IMAC) shall be used (see Table 1: Performance Standards).
In the case of hexavalent chromium where there is no specific 2L Standard or IMAC, the value for
Total Chromium (10 micrograms per liter) shall be used.
The following table shows the parameters and their associated 2L Standard or IMAC that shall be
used as performance standards.
State of North Carolina I Environmental Quality I Division of Water Resources
Water Quality Regional operations Section
1636 Mail Service Center I Raleigh, North Carolina 27699-1636
919-707-9129
Table 1: Performance Standards
Parameter
2L Standard
IMAC
Alkalinity
Aluminum
Antimony
1 µg/L
Arsenic
10 µg/L
Barium
700 µg/L
Beryllium
4 µg/L
Bicarbonate
Boron
700 µg/L
Cadmium
2 µg/L
Calcium
Carbonate
Cobalt
1 µg/L
Chromium
(total)
10 µg/L
ZChromium,
(hexavalent)
Copper
1 mg/L
Iron
300 µg/L
Parameter
2L Standard
IMAC
Lead
15 µg/L
Magnesium
Manganese
50 µg/L
Molybdenum
Mercury
1 µg/L
Nickel
100 µg/L
pH
6.5-8.5Su
Potassium
-
Selenium
20 µg/L
Sodium
Strontium
'Thallium
2 µg/L
Total Dissolved
S01ids
500 mg/L
'Vanadium
10 µg/L
Zinc
I mg/L
Chloride
250 mg/L
mg/L = milligrams per liter
Su = standard units
µg/L = micrograms per liter
'These IMAC values are proposed and are currently under rule review. Previously approved Oct. 1, 2010
IMAC for Thallium = 0.2 ug/l, and for Vanadium = 0.3 ug/l
2This value corresponds to the 2L Standard for total chromium which was based on the assumption that all
chromium present is in the hexavalent form.
We recognize these values differ from the health advisory levels that are provided by the North
Carolina Department of Health and Human Services (DHHS). It is DEQ's intent that when
establishing future groundwater standards, DEQ will seek comment from the Science Advisory
Board (SAB), where medical and scientific professionals will look at these standards in a more
holistic manner before they are adopted. It is our hope that using this approach will further ensure
that appropriate groundwater standards are established.
Required Actions: Prior to installation, Duke Energy shall provide, at a minimum, whole house
filtration system design specifications, manufacture specifications, location for sampling,
frequency of monitoring, and maintenance and monitoring schedules based on the above required
performance standards. It may be necessary for Duke Energy to notify all eligible households and
provide them the opportunity to reevaluate which permanent alternate water system they prefer
given the required performance standards.
If you have any questions regarding any information provided, please feel free to contact Debra
Watts at 919-807-6338.
Sincerely,
S. Zimmerman, P.G., Director
Division of Water Resources
cc: WQROS Regional Office Supervisors
WQROS Central File Copy
Mina Shehee (DHHS, Division of Public Health,
Occupational and Environmental Epidemiology)