NC0000396_Extension Request Approval_20170818

Water Resources
Environmental Quality
August 18, 2017
Ed Sullivan
Duke Energy
526 South Church Street
Mail Code EC13K
Charlotte, North Carolina 28202
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
Subject: Asheville Steam Electric Plant Interim Action Plan Schedule Updates — Request
for Extension of Milestone Dates
Dear Mr. Sullivan:
The North Carolina Department of Environmental Quality (DEQ) received your request for
extension of the deadlines for completing the interim actions at the Asheville Steam Electric Plant
letter dated July 28, 2017 (attached). DEQ is hereby approving the request for extension. DEQ
understands that, meeting the milestone dates is contingent upon several things including issuance
of NPDES permits, permitting through other agencies, and DEQ review and comment on
additional submitted Basis of Design reports.
In the letter, Duke assumes that DEQ will review and return comments to the Basis of Design
packages within 10 business days. Please note that there are no regulatory requirements for
timeframes to review these documents and that DEQ may require additional time to review and
provide comments. The proposed schedules do not anticipate additional submittals after comments
are received for the 100% Basis of Design. However, DEQ will review and may provide comments
on the 100% Basis of Design package, which may require additional submittal(s) to address any
concerns. If the anticipated milestone dates in this request are altered, please inform the DEQ
Asheville Regional Office and Central Office via email, documenting the reasons for any changes.
If you have any questions, please feel free to contact Ted Campbell (Asheville Regional Office) at
[phone] or Steve Lanter (Central Office) at 919-807-6444.
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

Sincerely,
Zmmerman, P.G., Director
Division of Water Resources
Attachment: Interim Action Plan Schedule Update —Asheville Steam Electric Plant letter from
Duke Energy dated July 28, 2017
cc: ARO WQROS Regional Office Supervisor
WQROS Central File Copy
Page 2 of 2

DUKE
ENERGYt
July 28, 2017
Mr. S. Jay Zimmerman, Director
Division of Water Resources
North Carolina Department of Environmental Quality
1611 Mail Service Center
Raleigh, North Carolina 27699-1611
Subject Interim Action Plan Schedule Update
Asheville Steam Electric Plant
Dear Mr. Zimmerman:
526 South Church Street:
Mail Code EC13K
Charlotte. North Carolina 26202
980.373.3719
In a letter dated March 28, 2017, DEQ documented acceptance of Duke Energy's milestone
schedules for the Accelerated Remediation sites submitted in February 2017. in that letter DEQ
stated that, "If the anticipated milestone dates in this request are altered, please inform the
appropriate DEQ Regional Office and Central Office via email, documenting the reasons for any
changes."
Duke Energy is providing the enclosed updated schedule for the Asheville project to formally
request schedule extension. The schedule has been adjusted for the following two items:
1) the extended DEQ review period for the 60% Basis of Design,
2) uncertainty with timing of NPDES permit modifications that are required to complete
start-up of the systems.
If you have comments and/or questions, please direct them to me at 980-373-3719.
Sincerely,
D. z.,.. vv .:,.,.
D. Edwin M. Sullivan, PE
Director —Waste & Groundwater Programs
Environmental, Health & Safety
Enclosure: Interim Action Plan Schedule updates — Asheville Steam Electric Plant
Cc: Jim Wells — Duke Energy

Enclosure
Asheville Steam Electric Plant
Interim Action Plan Schedule Update to DEQ July 28, 2017
• 30% Design Submitted to DEQ
• 60% Design Submittal to DEQ
(DEQ review comments received July 19, 2017)
• 100% Design Submittal to DEQ
Completed November 21, 2016
Completed March 17, 2017
October 4, 2017
• Final Regulatory Approvals for Construction October 27, 2017
(includes 100% BOD, Well Recovery, EBSC, etc. excludes NPDES Permit Modification)
• Begin Extraction Well and Treatment System Construction November 10, 2017
• NPDES Permit or DEQ Authorization Anticipated February 1, 2018
• Extraction Well and Treatment System Begin Operation February 14, 2018
Note: For scheduling purposes and as directed by DEO In the January 30, 2017 conference call, we assume DEQ will
review and return comments to the Basis of Design packages within 10 business days. Extraction Well and
Treatment System operation schedule is contingent upon receipt of the NPDES permit modification or other
DEQ authorization to direct the extracted groundwater into the ash basin on or before the anticipated date. The
current schedule does not anticipate additional submittals after comments are received for the 100% BOD (i.e.
any additional required submittals after 1000/6 BOD will delay the anticipated start date.)