IMP-SW Sampling Clarification Letter_20180530

Water Resources
Environmental Quality
May 30, 2018
Paul Draovitch
Senior Vice President
Environmental, Health & Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, North Carolina 28202
Subject: Interim Monitoring Plans and Surface Water Sampling Clarification
Dear Mr. Draovitch:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
The North Carolina Department of Environmental Quality (DEQ) would like to clarify the
agency's position concerning surface water sampling with respect to the Interim Monitoring Plans
(IMPS) at the 14 coal ash facilities. The IMPs that DEQ updates quarterly currently provide
direction for Duke Energy to conduct groundwater monitoring only. The IMP cover letters state
that surface water sampling is expected to continue per the May 1, 2017 letter from DEQ to Duke
Energy. However, the May 1, 2017 letter states,
Due to ongoing internal discussions regarding DEQ's position on surface water sampling,
the attached [IMPs] only contain references to groundwater monitoring locations. Once
a final internal position has been determined, DEQ may elect to provide Duke Energy with
surface [water] sampling locations to incorporate into the revised [IMPs].
Since the May 1, 2017 letter did not specify surface water monitoring locations, it was DEQ's
intent that surface water sampling would not be a part of the facility IMPs until a final position
was developed. It should be noted that the recently approved surface water evaluation plans for
certain facilities does not constitute a final position on a surface water monitoring program. With
the upcoming IMPs for the 3rd quarter of 2018, DEQ will revise the wording in the cover sheet to
help avoid confusion.
DEQ may elect to require establishment of surface water monitoring program in the future related
to the ongoing IMPs or corrective action performance monitoring. Therefore, DEQ does not
currently require Duke Energy to perform routine surface water monitoring as part of the IMPs.
-`"Nothing Compares ---%,
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

If you have any questions, please feel free to contact Steve Lanter (Central Office) at (919) 807-
6444.
Sincerely,
Jon Ri. gaard, Section Chief
Division of Water Resources
cc: WQROS Regional Office Supervisors
WQROS Central File Copy