Duke Energy Coal Pile Assessment Plans - Response to Comments 5-15-18

May 15, 2018
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Mr. S. Jay Zimmerman, P.G., Director ti10 p R S Off 9S
Division of Water Resources, Central Of
North Carolina Department of Environmental Quality (NCDEQ)
1611 Mail Service Center
Raleigh, North Carolina 27699-1611
Paul Draovitch
Senior Vice President
Environmental, Health & Safety
526 S. Church Street
Mail Code: ECUP
Charlotte, NC 28202
[phone]
Subject: COAL PILE ASSESSMENT PLANS — RESPONSE TO COMMENTS
Allen Steam Station — Belmont, Gaston County, North Carolina 28012
Riverbend Steam Station — Mount Holly, Gaston County, North Carolina 28120
Dear Mr. Zimmerman:
In response to the letters received from NCDEQ on May 2, 2018 titled "Allen Steam Station Coal
Pile Assessment Work Plan Comments" and on May 4, 2018 titled "Riverbend Steam Station
Coal Pile Assessment Work Plan Comments," Duke Energy would like to respond to NCDEQ's
request to incorporate the data collected from the Coal Pile Assessment (CPA) wells into the
Corrective Action Plan (CAP) updates. Upon review of the well drilling timeline across the North
Carolina sites, Duke has concluded that incorporation cannot be accomplished if the CAP
updates are to be submitted in 2018. Well drilling among North Carolina sites will be ongoing
through July 2018 due to Coal Ash Management Act (CAMA) pumping tests and deep bedrock
wells, which are high priority work scopes to obtain data needed for the CAP groundwater
models. In addition to the required CAMA scope, there are also federal Coal Combustion
Residual (CCR) Rule wells that are currently tracking to be installed by mid -July 2018. These
drilling scopes will greatly strain regional drilling resources, as similar scopes are occurring at
various sites across the Duke Energy Carolinas fleet. For this reason, the CPA wells at Allen and
Riverbend cannot be installed and sampled prior to August 2018. In order to achieve two CPA
sampling events at 60 days apart plus 30 days to receive results from the laboratory, complete
and validated results cannot be available prior to November 2018. Final drafts of all 2018 CAPS
will already be completed by November, so this data would not be included. At this time, a CAP
due date has not been established for either Allen or Riverbend. If the CAP due date for these
sites is established as January 31, 2019 or later, we are confident that the CPA well data could be
included in the CAP.
If you have comments and/or questions, please direct them to me at 704-380-7171 or Ed
Sullivan, Director of Waste & Groundwater Programs, at 980-373-3719.
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Si ell
Paul Draovitch
Senior Vice -President
Environmental, Health & Safety
cc (via e-mail):
Eric Smith, NCDEQ-Central Office
Steve Lanter, NCDEQ-Central Office
Brandy Costner, NCDEQ-Mooresville Regional Office
Shuying Wang, NCDEQ-Winston-Salem Regional Office
Jim Wells, Duke Energy
Ed Sullivan, Duke Energy
John Toepfer, Duke Energy
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