RRO Technical Direction and Action Items 10-9-17

Water Resources
Enviromnental Quality
October 9, 2017
Ed Sullivan
Duke Energy
526 South Church Street
Mail Code EC 13K
Charlotte, North Carolina 28202
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
Subject: Technical Direction and Action Items, Raleigh Regional Office Meeting June 29, 2017
Dear Mr. Sullivan:
On July 13, 2017, the North Carolina Department of Environmental Quality's Division of Water
Resources (Division) received the meeting minutes from the June 29, 2017, Raleigh Regional Office
(RRO) meeting. As part of the process agreed upon to facilitate completion of the site assessments
and corrective action plans, the Division provides the following summary of technical direction and
action items discussed during the meeting:
Program -Wide Issues
o The Division has stated the position that, for a background sample collected within 60
days of the previous sample, this sample will not be acceptable due the potential for
auto -correlation. However, the Division will consider samples collected less than 60
days from the previous samples if Duke Energy provides rational for including them
(such as flow velocity calculations) with limited assumptions.
■ Action Items
o Cape Fear Steam Electric Plant
■ RRO agreed that compliance well CMW-5 may be replaced. Duke Energy will
need to provide documentation of the change for the NPDES permit.
■ The groundwater sampling results from the MW-24 cluster will help determine
if the horizontal and vertical extent is adequately delineated in this general
location.
■ Duke Energy indicated that, due to the purchase of some railroad property, the
compliance boundary should be changed accordingly. Duke Energy should
submit this request along with any relevant information to the Division for
review and approval.
■ Duke Energy shall continue to collect additional background soil samples to
add to the dataset. Duke Energy shall confirm the locations with the RRO
before proceeding.
o Mayo Steam Electric Plant
■ MW-11BR can be removed from the background dataset. MW-I1BR will
continue to be monitored for water levels.
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

• MW-16BR does not need to be replaced since pH levels were between 7 and 8
during the last four sampling events.
• RRO requests Duke Energy to provide boring logs and well construction forms
be supplied for consideration of a new background location near the FGD
basin.
• RRO requests Duke Energy to provide a recommendation for which new
well(s) will replace the abandoned MW-7D and MW-7BR.
• Duke Energy indicated that the four additional data gap wells (MW-18D, MW-
18BR, MW-19D, and MW-19BR) have been added to the Interim Monitoring
Plan (IMP). Please sample these wells quarterly and they will be included in
the revised IMP to be provided by the Division at the end of September.
• Duke Energy shall continue to collect additional background soil samples to
add to the dataset. Duke Energy shall confirm the locations with the RRO
before proceeding.
■ SB-2 and SB-3 shall not be used in background calculations as a precaution
since there was some confusion with the interpretation of the boring logs.
o Roxboro Steam Electric Plant
• ABMW-1, ABMW-2 and ABMW-7 shall be used for water levels only.
• ABMW-2BR and MW-413R may be used for monitoring water quality if pH
and turbidity levels remain below threshold criteria (i.e., pH below 8.5,
turbidity below 10 NTUs).
■ Fractured bedrock flow determination in the area of Woodland Elementary
School will be critical due to the potential receptor if not serviced with a water
line.
• Duke Energy shall continue to collect additional background soil samples to
add to the dataset. Duke Energy shall confirm the locations with the RRO
before proceeding.
• RRO will not consider data from MW-13, MW-16 or MW-17 as applicable for
background determinations due to the locations between or near ash basins.
If you have any questions, please feel free to contact Eric Rice (Raleigh Regional Office) at (919) 791-
4200, or Steve Lanter (Central Office) at [phone].
Sincerely,
on Risg d, Section Chief
Water Quality Regional Operations Section
Division of Water Resources
cc: RRO WQROS Regional Office Supervisors
WQROS Central Office Copy