2017_01_27 Additional Assessment Extension Request

DUKE
ENERGY
January 27, 2017
Mr. S. Jay Zimmerman, Director
Division of Water Resources
North Carolina Department of Environmental Quality
1611 Ma-1 Service Center
Raleigh, North Carolina 27699-1611
Environmental, Health & Safety
526 South Church Street.
Mail Code EC13K
Charlotte, North Carolina 28202
Subject: Extension Request - Additional Site Assessments
James E. Rogers Energy Complex (formerly Cliffside Steam Station)
NPDES Permit NC0005088 - Rutherford and Cleveland Counties
Roxboro Steam Electric Plant
NPDES Permit NC0003425 - Person County
W.H. Wearherspoon Power Plant
NPDES Permit NC0005363 - Robeson County
Dear Mr. Zimmerman,
On August 18, 2016, Duke Energy (Duke) submitted Work Plans for additional assessment
activities at the James E. Rogers Energy Complex (Rogers), Roxboro Steam Electric Plant
(Roxboro), and W.H. Wearherspoon (Weatherspoon) Power Plant. On November 23, (revised
December 2, 2016) Duke received North Carolina Division of Environmental Quality Division of
Water Resources (DWR) approval to the Additional Site Assessment Approvals for these three
facilities noting a reporting due dare of March 31, 2017.
On November 30, 2016 in a meeting with DWR Regional office personnel, Duke made DWR
aware that permitting and constructability of monitoring wells would likely extend the schedules
for assessment beyond the March 31, 2017 date specified in the November 23 letter.
With this letter, Duke requests a 60-day extension for the Additional Site Assessment Plans at
Roxboro and Weatherspoon, and an extension until after ash removal is complete at Rogers.
The extension request for these sites is outlined in more det.il below:
James E. Rogers Energy Complex
• The area requested for additional assessment at Rogers is an ash area across the
Broad River near the Unit 5 switchyard. This area has tentatively been scheduled to
begin excavation in the second quarter of 2017 pending receipt of necessary permits.
Wells installed in the area of excavation would need to be abandoned prior to beginning
excavation resulting in reinstallation of most of the wells. Duke requests that installation
of the additional site assessment wells be postponed until completion of ash removal
from the area across the Broad River. Duke intends to propose an alternate schedule
once there is more clarity on the completion date of ash removal. Preliminary
discussions have occurred with Asheville Regional Oflice on this topic.

Mr. S. Jay Zimmerman, Director
January 27, 2017
Page 2
Roxboro Steam Electric Plant
• Work Plan Schedule
Section 8.0 Proposed Schedule of the work plan noted that field work would
begin approximately 45 days following final NCDEQ approval with the CSA
Report submitted 60 days after receipt and validation of analytical data. The
proposed schedule accounted for permitting and assessment of data obtained
during the site assessment. The schedule submitted in the Work Plan was
aggressive with any alterations leading to the potential submittal of an incomplete
report.
• Additional monitoring well location
The Correction to the Additional Site Assessment Approvals requested one
additional monitoring well cluster at a location southeast of MW-12BR. Duke
noted that the requested location was likely an error with the actual location
southwest of MW-12BR. Clarification for well cluster location was directed to
NCDEQ on November 27, 2016. Confirmation of final cluster location was
received from NCDEQ on December 1, 2016.
• Permit Requirement
The area of disturbance for the 7 well cluster locations is greater than 1 acre and
therefore requires an Erosion and Sediment Control (E&SC) Permit from NCDEQ
Division of band Quality. The initial E&SC permit application was submitted on
November 30, 2016 with a revision for the additional well cluster submitted on
December 6, 2016. Clearing and creation of roadways/pads cannot begin until
the E&SC permit is received.
• Feasibility of compressed schedule
Installation of access roads/pads and utility clearance will begin upon receipt of
E&SC permit. However, the work is weather -dependent with driller mobilization
not anticipated until approximately two weeks after start of work with clearing and
road/pad installation continuing as well installation begins.
a Well installation and development - approximately 2 to 3 weeks
o Collection of groundwater and other media samples - approximately 1
week
o Analytical analysis - approximately 3 to 4 weeks
a Data validation of analytical results - approximately 1 week
o Report development and review - approximately 4 weeks
W.H. Weathers oon Power Plant
• Work Plan Schedule
Section 8.0 Proposed Schedule of the work plan noted that field work would
begin approximately 45 days following final NCDEQ approval with the CSA
Report submitted 60 days after receipt and validation of analytical data. The
proposed schedule accounted for permitting and assessment of data obtained
during the site assessment. The schedule submitted in the work plan was
aggressive with any alterations leading to the potential submittal of an incomplete
comprehensive report.

Mr. S. Jay Zimmerman, Director
January 27, 2017
Page 3
Permit Requirement
The installation of six wells on the cooling pond dam required Dam Safety work
plan approval by the NC Division of Energy, Mineral, and Land Resources.
Approval was received on January 12, 2017. Aligning drilling resources could
not begin until this approval was received.
Feasibility of Compressed Schedule
The following estimated durations beginning on the receipt date of the Dam
Safety approval will move completion beyond the March 31, 2017 report date
specified in the "Correction to the Additional Site Assessment Approvals" letter:
o Well installation and development - approximately 2 to 3 weeks
o Collection of groundwater and other media samples - approximately 1
week
o Analytical analysis - approximately 3 to 4 weeks
o Data validation of analytical results - approximately 1 week
o Report development and review - approximately 4 weeks
If you have comments and/or questions, please direct them to me at 980-373-3719.
Sincerely,
D. Edwin M. Sullivan
Director, Waste and Groundwater Programs
Environmental, Health, & Safety
Cc NCDEQ (electronic): Eric Rice - NCDEQ Raleigh Regional Office
Ted Campbell - NCDEQ Asheville Regional Office
Kent White - NCDEQ Fayetteville Regional Office
Steve Lanter - NCDEQ Raleigh
Eric Smith - NCDEQ Raleigh
Cc Duke (electronic): Ryan Czop
Kimberlee Witt