Duke_RequestAlternateAnalysis_20180531

Waste Management
ENVIRONMENTAL QUALITY
May 31, 2018
VIA EMAIL and FIRST CLASS MAIL
Mr. Paul Draovitch
Senior Vice President
Environmental, Health and Safety
Duke Energy
526 Church Street
Mail Code EC3XP
Charlotte, North Carolina 28202
Dear Mr. Draovitch:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
The Coal Ash Management Act (CAMA), Section 130A-309.214(a) (3), provides that at the
election of the Department of Environmental Quality ("Department"), a low -risk
impoundment can be closed by the total removal of the CCR, by removing the ash and
converting the impoundment into an industrial landfill, by installing a specific cap on the
impoundment, or by complying with the closure requirements of the federal CCR rule.
Section 130A-309.214(b)(3) directs the Department to hold a public meeting and explain
the proposed closure plan and alternatives.
Any environmental remediation project of the magnitude of impoundment closure requires
an analysis of potential closure alternatives as well as groundwater modeling. While the
final risk classification has not been determined for certain coal ash impoundments, we
understand that Duke has performed closure alternatives analyses. As the Department and
Duke are scheduled to discuss the Belews Creek closure on Friday, June 8th, please provide
to DEQ the closure alternatives analysis for Belews Creek, including key assumptions and
inputs, no later than June 7, 2018. Please also provide the modeling files and results of
modeling for Belews Creek to help the Department evaluate the relative success and
associated time frames of each closure alternative used in the closure alternatives analysis.
At this point, we do not require more than draft versions of this information.
In addition, please provide to DEQ all closure alternatives analysis reports and modeling
files, whether in draft or final form, for the other five potential low -risk sites by June 22,
2018.
State of North Carolina I Environmental Quality I Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919 707 8200

If there are any questions, please do not hesitate to contact me. You may also speak directly
to Ed Mussler at 919-707-8281.
Sincerely,
Sheila Holman
Assistant Secretary for the Environment
Cc: via email
Bill Lane, General Counsel
Francisco Benzoni, Assistant Attorney General
Ed Mussler, DWM
Jon Risgaard, DWR
Andrew Brooks, DEMLR
Dave Renner, Duke
Ed Sullivan, Duke
State of North Carolina I Environmental Quality I `Haste Management
217 West loves Street 11e46 Mail Service Center I Raleigh, North Carolina 27694-1646
9197078200