Duke Response to DEQ 6-2-17_20170816

(r� DUKE
ENERGY,
AUgUSt IS, LU1/
Mr. S. Jay Zimmerman, P.G.
uireCtor Division or water Resources
NoRh Carolina Depal tment of Environmental Quality
1611 Mail Service Center
Raieigll.IIC L/599-.0ju
RE: Response to DEQ Letter Dated June 2, 2017
"Groundwater Corrective AC[ion Plans — Evaluation of Remedial Alternatives
Allen, Belews Creek, Cliffside/Rogers, Marshall, Mayo and Roxboro"
Dear Mr. Zimmerman:
Paul Draovitcn
Senior Vice Pres cent
environmental, Health & Safety
525 5onzh CharcF1 Street
ECsxP
CRarlotte, K Lswz
v3[;.17:j.UU4V8
Duke Energy is in receipt of the above -referenced letter which identifies a proposed schedule for
updating Comprehensive Site Assessments (CSAs) and Corrective Actions Plans (OAPs) for six of Duke
Energy -s nacilides. Prior to ana3 anter receipt on this letter, Dune Energy personnel met with DEQ Central
Office and Regional Office personnel to discuss additional work DEQ believes is necessary to complete
the Updated Comprehensive Site Assessments. The last of these meetings took place on June 30, 2017.
With these meetings now concluded, Duke Energy is in a position to propose a schedule to DEQ based
on additional field work necessa. y. ThIz proposed schedule for the six facilities is as follows.
Updated CSAs Submitted to DEQ on October 31 2017 1" Set
DEQ to review and (assuming the Updated CSAs meet the pre -approved table of contents)
approve Updated Cams by January ;3i, cOi$.
Duke Energy to provide Updated CAPS to DEQ on July 31, 2018. (Should DEQ exceed the review
period, there would be a day -for -day extension to the Updated CAPS for each day approval is
aelaye0 Oeyontl January sl, LOls.)
DEQ to review and (assuming Updated CAPS meet the pre -approved table of contents) approve
Uptlatetl CAPS By OctoMer i1, LOls.
- Duke Energy will begin CAP implementation within 30 dayz, of DEQ's approval of the Updated
CAPS.
Updated 7 -ams submitted to DEQ on .,anuary s.L. Lops fLnd .3et]
DEQ to review and (assuming the Updated CCAs meet the pre -approved table of contents)
approve Opuate0 CSAS (iy April s0, L0jz.
Duke Energy to provide Updated CAPS to DEQ on October ax, L'vsa. (should VICE exceed the
review period there woul0 Be a Day -for -Clay extension to rMe OpDatetl CAPS For eocM day
approval is delayed beyond April 30, 2018.)
• DEQ to review an0 (assuming Op0ate0 CAPS meet Me pre-appro-;e0 t.5le or r_ontents) approve
Updated CAPS by Januar y 31, 2019.

Mr. jay cimmerman Eetter
August A, zuai
• DuRe Energy wily Begin tTr implementation witnin .s0 Days of DEQ's approval or the Dptlatetl
CAPS.
i Re aDove scMeOule Diners sligllily irons inat proposer 0, DMs June c letter in tRat it inclutles a 90 -Da r
DEQ review period. Duke Energy requests a review and approval of the Updated CSms by DEQ before
besinning preparation of the CAPs. This will ensure that the CAPs are prapared based on approved site
assessments. i Me scReOuie is similar to Mar IaiD out by CAIGIA, ana is consistent with Nas letter Datetl
July 14, 2017. In addition, the above schedule for Corrective Antion Plans aligns the timing of the
corrective action with the corrective action schedule in the federal CCR Rule.
Duke Energy proposes that Updated CSAs will be completed for the Belews Creek, Mayo and Roxboro
facilities in the 1s` Set. The 2"d Set would consist of the Allen, Cliffside and Marshall facilities. In addition
to those six sites_ Duke Energy intends to su0mit Uptlateo CSAs for toe four OigR priority sites on tRe
following schedule:
Ri—�erOena toctober 31, 2017)
Dan river_ Dutton (January i.L, zO.La)
Asheville (March 31, 2018)
The anticipated schedule for the four high priority sites may neeD to shift sligMily Due Eo aDDitionai rielD
work and the compressed schedule noted above. Duke Energy will provide DEQ an updated schedule
for Oese four MigM prior'ty sites in a Tew months once field work has commenczd and a submittal
schedule is more clear. It is Duke Energy's plan to follow a similar scnetlule to Elle one Descri0e0 a0ove
for the 1't Set and 2"d Set with 90 days provided for DEQ review of the Updated CSAs followed by 180
Days proviDea for preparation or ine 0(.0ated CAPS.
Duke Energy will propose a schedule in the future for the four remaining sites (Buck, Cape Fear, HF Lee,
anu vveaERerspoon faciiities). Ir you nave any geestions or need any clarification regardinu, the
information provided, please contan Ed aullivan at ed.sullivan aduke-ener .com or at 950-.5/5-ziiy at
your convenience.
esp ul y sub ted,
P ul Draovitch
-oenior vice Presicent
Environmental, Health & safety
CC' Mr. Ed Sullivan — Duke Energy
Pis. Kath,, Webb —SynTerra Corp.