Zimmerman 04-05-2018

(� DUKE
ENERGY
April 5, 2018
Mr. S. Jay Zimmerman, P.G.
Director, Division of Water Resources
North Carolina Department of Environmental Quality
1611 Mail Service Center
Raleigh, NC 27699-1611
Paul Draovitch
Senior Vice President
Environmental, Health & Safety
526 South Church Street
EC3XP
Charlotte, NC 28202
980.373.0408
RE: Response to DEQ Letter Dated September 8, 2017 - Technical Direction Regarding Other Primary
and Secondary Sources at Duke Energy Coal Ash Facilities
Dear Mr. Zimmerman:
Duke Energy (Duke) and the Department of Environmental Quality (DEQ) had a routine scheduled
telephone conference call on February 27, 2018. During this call, DEQ requested Duke provide a list of
potential primary sources of groundwater impacts at the 14 coal-fired sites in North Carolina that are
not subject to the groundwater assessment and corrective action provisions of the Coal Ash
Management Act (CAMA).
This topic was previously discussed in a letter to Duke Energy from DEQ dated September 8, 2017,
which lists other primary sources as "CCR storage areas, raw coal piles and structural fills". Secondary
sources are defined by the letter as "all residual soil and groundwater contamination resulting from the
primary sources". The letter further stated that "DEQ will allow Duke Energy to address remediation
and closure of the CCR surface impoundments on a separate timeline than the remediation of other
primary and secondary sources."
In reliance on the September 8, 2017 letter, Duke developed a plan for addressing other primary sources
in multiple stages over time. The first stage involves other primary sources located nearby to CCR
surface impoundments such that if there were any soil and groundwater contamination from the
primary sources, the impacts would be coincident with the CCR surface impoundments. These sources
are located in a way that corrective action targeted at a surface impoundment would also address any
plume associated with the other primary source. It is Duke's preference to investigate this group of
primary sources first, so that the information can be factored into an updated Corrective Action Plan for
the CCR surface impoundments. In fact, Duke has already submitted three such work plans to DEQ for
review and approval.
The second group involves other potential primary sources located such that a groundwater divide
and/or 'surface water' areas separate these potential primary sources from the CCR surface
impoundments. Assessment and corrective action around these sources will not affect corrective action
around the surface impoundments. These other potential primary sources can be investigated
independent of the CCR surface impoundments, so as to not impact the CAMA schedule, as stated in the
DEQ letter from September 8, 2017.
Duke has identified the following list of potential primary sources for investigation in the first stage due
to their positioning relative to surface impoundments:

Mr. Jay Zimmerman
April 5, 2018
Page 2
Site
Potential Primary Source(s)
Allen
Coal Pile*
Asheville
Coal Pile
Cape Fear
Coal Pile
Cliffside
Coal Pile & Gypsum Pile
Marshall
Coal Pile, Structural Fill & Gypsum Pile
Riverbend
Coal Pile*
Sutton
Former Processing Area
Weatherspoon
Coal Pile*
* Work plans already submitted to DEQ.
Please note the above table does not include CCR landfills or CCR structural fills under DEQ Division of
Waste Management jurisdiction, nor does the above table include petroleum impacts under another
DEQ division jurisdiction. If you have any questions or need any clarification regarding the information
provided, please contact Ed Sullivan at [e-mail] or 980-373-3719 at your
convenience.
Respectf Ily submi d,
Paul Draov'
Senior Vice President
Environmental, Health & Safety
cc: Mr. Ed Sullivan — Duke Energy
Ms. Kathy Webb — SynTerra