Duke Revised Performance Monitoring Plans Comments_20170825

Water Resources
Environmental Quality
August 25, 2017
Paul Draovitch
Senior Vice President
Environmental, Health & Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, North Carolina 28202
Subject: Revised Performance Monitoring Plan Comments
Dear Mr. Draovitch:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
The North Carolina Department of Environmental Quality's Division of Water Resources
(Division) received the Revised Performance Monitoring Plan (RPMP) dated August 4, 2017. The
Division has performed an additional review of this document and offers the following comments:
• Section 1.2 (Page 2) — The RPMP states that, "Well contamination from biological sources
(e.g. Fecal Coliform) are not removed/treated by the treatment systems being installed for
compliance with HB 630." However, on page 10 of the original Performance Monitoring
Plan (June 27, 2017), it states that the treatment systems will consist of additional
components including a UV Sterilizer. Please confirm that UV Sterilizers will/or will not
be included on all treatment systems.
• Section 1.2 (Page 1) — The revised document states that labs certified for drinking water
analysis in North Carolina will be used. Safe Drinking Water Act (SDWA) certified labs
may not be the best labs for contaminants unregulated by the SDWA, or there may not be
certified labs that run unregulated samples. Duke Energy shall provide additional
information regarding how labs will be selected for contaminants not regulated under the
SDWA, and therefore, where there are no SDWA-certified labs.
• Section 3.0 — Please revise Section 3.0 to remove the word "should" and replace with the
words "must" or "shall."
• Section 3.2 (Page 5) — The Division is requiring raw water samples to be taken during each
sampling event. If a sample from the well head is not feasible, please make sure that the
filtration system installation system has a sampling tap be installed for collecting a raw
water sample.
• Section 3.2 (Page 5) — The RPMP states, "Samples of treated water collected for
performance screening will be collected at a sample port after the last piece of installed
equipment but before entering into the homes' piping." The proposed treatment systems
may cause the water to become more corrosive than it otherwise would be. Sampling for
contaminants other than copper and lead before the household plumbing is appropriate.
However, to be consistent with the SDWA, sampling for lead and copper shall be done at
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

the consumer tap using SDWA sampling techniques including the minimum 6-hour
stagnation time.
• Section 3.2 (Page 6) — The RPMP states, "Fill sampled containers directly from the port
giving care not to overflow pre -preserved bottles. If necessary, use a secondary container,
such as a clean 8 oz. or similar size jar, to obtain and transfer samples form spigots with
low ground clearance." Introduction of additional containers to takes samples is not
recommended. Where possible, the Division recommends that the systems be designed so
that the necessary sampling ports be installed that allow for samples to be collected directly
into the required sample containers.
• Section 4.0 — No indication is given of what actions are considered minor adjustments
which would not require a sample upon completion. Please provide examples which clarify
what activities lead to collection of a performance screening sample. Additionally,
corrective action is only indicated during the maintenance inspections, which depending
on interpretation of Section 2.2, may not include the two additional initial -year sampling
events that occur during salt deliveries. The document shall be revised to clarify that
corrective action occurs after any sampling results exceeds the filter performance
standards. Bottled water shall be provided to the affected home(s) during any corrective
action and until the system issues have been resolved.
• Section 5.0 — Please provide all reports and sample results to the Division in electronic
format only. Please email the reports to CA.water.testLa)ncdenr.gov. Indicate in the email
subject the Division Region that the report or results pertain to. All sample results should
also be provided on Microsoft Excel spreadsheets.
• General — It was indicated that these systems add sodium to the treated water. Duke Energy
shall consider alternative water filtration systems if the filtered water is expected to contain
more than 20,000 µg/L of sodium for consumers that are on sodium -restricted diets
(Department of Health and Human Services' Occupational and Environmental
Epidemiology Branch health goal).
• General: Please add Sulfate at 250 mg/L to the Performance Standards for the water
filtration systems.
If you have any questions, please contact Debra Watts at [phone].
Sincerely,
gJaai erman, P.G., Director
Division of Water Resources
cc: WQROS Regional Office Supervisor
WQROS Central File Copy