Revised Performance Plan and Technology Approval_20171011

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Water Resources
Environmental Quality
October 10, 2017
Paul Draovitch
Senior Vice President
Environmental, Health & Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, North Carolina 28202
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
Subject: Revised Performance Monitoring Plan and Whole -House Treatment System
Technology Conditional Approval
Dear Mr. Draovitch:
The North Carolina Department of Environmental Quality's Division of Water Resources
(Division) received and reviewed your Response to August 25, 2017 Letter on Revised
Performance Monitoring Plan dated September 12, 2017 and the Full Scale Implementation Data
submitted on October 3, 2017. The Division agrees with the comments and revisions provided,
and approve the Revised Performance Monitoring Plan as presented. The Division also approves
the use of the proposed whole -house treatment system technology.
The Division is still reviewing and assessing the Response to July 12, 2017 Letter dated August
31, 2017, as well as, inputs from external entities regarding installations of these systems at the
Asheville Steam Electric Plant, Belews Creek Steam Station, Mayo Steam Electric Plant, and
Roxboro Steam Electric Plant. The Division requests that Duke Energy delay the installations of
these systems until further notice at these four facilities. Otherwise, the Division approves Duke
Energy's plans to install the systems at the remaining facilities.
Considering the discussions regarding the backflush of the systems and the revised Sodium
Adsorption Ratio (SAR) Values from Water Professionals (Culligan) and Water Purification
Consultants received September 12, 2017, the Division has determined these systems produce a
wastewater of similar characteristics and volumes as is deemed permitted in accordance with 15A
NCAC 02T .0113. Therefore, the treatment systems provided by Duke Energy in accordance with
130A-309.211 (c1) are approved as presented in the Revised Performance Monitoring Plan. This
approval, however, is contingent on the following conditions:
Nothing in this approval allows the violation of any assigned surface water, groundwater,
or air quality standards. If such violation occurs, corrective measures will be required by
the Division. [15A NCAC 02T .0I 13(b)]
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

• Any discharge to surface waters from the disposal systems shall be reported in accordance
with 15A NCAC 02B .0506. [15A NCAC 02T .0113(c)]
The Director may determine that a disposal system should not be deemed to be permitted
and require the disposal system to obtain an individual permit or a certificate of coverage
under a general permit. This determination shall be made based on existing or projected
environmental impacts, compliance with the provisions of Rule, and the compliance history
of the facility owner. [15A NCAC 02T .0113(e)]
These systems shall be designed, operated and maintained to control the SAR of the
backflush water to ensure that the soil receiving the backflush water will not be adversely
effected. [15A NCAC 02T .0105(f)]
If you have any questions, feel free to contact Debra Watts at [phone].
Sincerely,
S. erman, P.G., Director
Division of Water Resources
cc: WQROS Regional Office Supervisors
WQROS Central File Copy