Allen_CoverLetterToSheliaHolman_20181115

DUKE
` ENERGY.
November 15, 2018
Ms. Sheila Holman
Assistant Secretary for Environment
North Carolina Department of Environmental Quality
1611 Mail Service Center
Raleigh, North Carolina 27699-1611
Paul ©raovitch
Senior Vice President
Environmental, Health & Safety
526 S. Church Street
Mail Code. SCUP
Charlotte, NC 28202
[phone]
Subject: Allen Steam Station ash basin closure options, groundwater model and community
impact analysis
Dear Ms. Holman:
Duke Energy is providing information in response to the North Carolina Department of
Environmental Quality's requests on September 13 and October 8, 2018, to submit preliminary
updates to the closure options analysis, groundwater modeling and community impact analysis
for the Allen Steam Station. These studies represent a key portion of the work the company has
performed to develop closure plans that balance a variety of considerations.
Duke Energy is committed to closing ash basins in ways that are safe, timely, environmentally
sound, and based on thorough science and engineering. In addition, effective closure plans are
site -specific and must ensure ash is managed in ways that continue to protect public health,
safety and the environment. Importantly, the planning process also considers how closure
choices may affect neighbors and communities.
After considering a number of potential closure options at Allen, four options were advanced for
detailed analysis: closure -in -place with ash closest to neighbors consolidated within the basin
footprint, a hybrid option with additional amounts of excavation similarly followed by
consolidation, and two closure -by -removal options with material going to an offsite landfill to be
determined, or a future on -site landfill in the basin footprint. Note that only the first three of those
four options were chosen for advanced analysis in groundwater modeling.
Based on a comprehensive assessment, Duke Energy will recommend at a later date either
closure -in -place or a hybrid closure plan to safely close the two Allen ash basins. We look
forward to input from regulators and interested stakeholders as we continue to evaluate safe
closure methods in a manner that protect people and the environment, while also minimizing
disruption to communities and managing cost.
North Carolina As a National Leader
To help ensure that the work done in North Carolina balances various considerations and
incorporates interdisciplinary perspectives, the company created the National Ash Management
Advisory Board (NAMAB) in 2014. This group of well -recognized experts in environmental
engineering, waste remediation, toxicology and other fields continues to provide ongoing
technical input and vet the various choices and tradeoffs inherent to any closure plan.

As previously stated, the enclosed documents represent key elements among the extensive
science and engineering being conducted by dedicated teams at Duke Energy and outside
experts, with ongoing input from NAMAB, to identify safe and smart basin closure plans for
remaining sites in North Carolina.
Groundwater Modeling
As multiple sources have validated, ash basins have not affected neighbors' drinking water
wells near the Allen Plant. For communities concerned that nearby well water could be affected
in the future, state lawmakers in 2016 passed legislation requiring the company to proactively
provide permanent drinking water sources. The company has connected eligible neighbors
within a half -mile of the Allen basins to municipal water supplies or provided them with
advanced, whole -home filtration systems, even though evidence demonstrates that ash basins
are not impacting them, and most neighbors' well water already met the appropriate
performance standards for the filter systems.
In addition to advanced planning for safe drinking water, the N.C. Coal Ash Management Act
(CAMA) outlines an elaborate process to monitor and study groundwater near ash basins. This
involves thousands of monitoring wells across the state and using those real -World data points
to develop site -specific models that seek to predict how groundwater will respond to various
closure scenarios. This process also involves several iterations of extensive groundwater
studies and developing proposed corrective action steps that will work in tandem with basin
closure as necessary to address groundwater impacts.
Based on extensive study, the company understands that groundwater at Allen moves slowly
and that coal ash impacts are very localized near the ash basin and generally on plant property.
In any closure scenario, the most effective step the company can take to improve groundwater
is to safely remove the free water from the ash basin. When predicting future groundwater
response at Allen, the models demonstrate that:
• Groundwater in the closure -in -place option reaches compliance with state standards
faster than excavation. Otherwise, the patterns of decreasing boron concentrations in
the modeled scenarios are generally similar.
• The simulations indicate there will continue to be no impact to drinking water wells.
Groundwater impacts will continue to be evaluated as the updated modeling expands to other
parameters.
The models do not include the effects of any additional groundwater remediation steps the
company may take in the future. As part of a separate state -directed process, the company will
submit corrective action plans that propose steps that can be taken where groundwater
necessitates additional or more timely improvement. In particular, the company will pursue
groundwater remedial actions where needed with a focus on any surface water or offsite
property impacts.
E

Community Impact Analysis
In addition to relying on strong science and engineering, the company felt it was important to
consider various stakeholder interests and community impacts when developing its
recommended ash basin closure plans. In addition to its own research, which is included in the
comprehensive options analysis, the company relied on an outside consulting firm, Exponent, to
study the potential community impacts of various closure scenarios. Key take-aways include:
• All closure options evaluated would be protective of human and ecological health.
• Excavation to an off -site landfill causes the greatest disturbance to the community
compared to the other options.
• Closure -in -place would cause a net loss in ecological services (protection of biodiversity
and natural beauty), because a grass cap is less valuable habitat than open fields,
wetlands or forested areas. Although all options produce a net foss in environmental
services, hybrid closure would minimize those losses. Any net loss in ecological services
resulting from closure -in -place can be offset by reforestation of land parcels.
The community impact analysis does not compare greenhouse gas emissions from onsite and
offsite trucking activity; therefore, a supplemental analysis will be provided comparing the
impact of various closure options on greenhouse gases and other air emissions.
The results of the community impact analysis vary by site, but in all cases cap -in -place closure
may be performed without adversely impacting the community. In some cases, reforestation of
land parcels may be advisable to offset any net habitat losses.
Options Analysis
The company's options analysis considers the many aspects and tradeoffs related to basin
closure including environmental protection, schedule and the company's own analysis of
community impacts. In addition, as a regulated utility, Duke Energy is obligated to evaluate the
cost-effectiveness of the closure options. The company developed'a relative weighting and
scoring system with input from the NAMAB that was used to evaluate and score various closure
alternatives.
For Allen, key take-aways from the options analysis include:
• Closure -in -place is the least -cost approach compared to excavation, which is much more
expensive. For example, the capital cost of excavation with an onsite landfill could be
three times higher.
• The only option that would require ash transport on public roads would be excavation to
an offsite landfill, resulting in numerous truck trips per day.
• Regardless of the specific closure plan, trees will be removed along the western edge of
both basins, opening line of sight for traffic and residents along Highway 273/South Point.
Road and the adjoining neighborhood.
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• Closing the basins in place can be done in the least amount of time but would still be
challenging to complete before the CAMA deadline of 2029. Hybrid closure would
likewise be challenged to complete before the CAMA deadline. Neither excavation
option could be completed in time to meet the current CAMA or the latest CCR deadline
of 2034.
Ash reprocessing was not considered since installing a reprocessing unit to recycle ash for
concrete would significantly lengthen the closure timeline well beyond regulatory deadlines. A
unit would process about 400,000 tons a year and would take nearly 50 years to recycle all the
Allen material for concrete. This scenario would far exceed state and federal closure deadlines
and was not analyzed further.
The company's recommended closure approach across its North Carolina sites reflects a
science -based combination of excavating, capping in place and recycling ash for concrete and
other beneficial purposes. Duke Energy remains committed to safely closing ash basins and
welcomes input from DEQ and the public to best balance these various tradeoffs.
$iq6 ly,
C
Paul braovitc
Senior Vice resident
Environmental, Health & Safety
cc: Jim Wells, Duke Energy
Dave Renner, Duke Energy
Randy Hart, Duke Energy
Ed Mussler, DW M
Jon Risgaard, DWR
Andrew Brooks, DEMLR
Bill Lane, NCDEQ General Counsel
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