Belews Creek Gypsum Pad Assessment Plan Comments 6-24-19

ROY COOPER
Governor
MICHAEL S. REGAN
secretary
LINDA CULPEPPER
Director
Paul Draovitch
Senior Vice President
Environmental, Health & Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, North Carolina 28202
NORTH CAROLINA
Environmental Quality
June 24, 2019
Subject: Gypsum Pad Assessment Work Plan Comments — Belews Creek Steam Station
Dear Mr. Draovitch:
On May 24, 2019, the North Carolina Department of Environmental Quality Division of Water
Resources (Division) received the proposed Gypsum Pad Assessment Work Plan for the Belews
Creek Steam Station. The Division has reviewed and hereby approves the proposed assessment
activities under the condition that the following items are addressed as part of the plan
implementation and the results reported in the comprehensive site assessment concerning the
subject area.
• The soil and groundwater characterization should include both the Gypsum Pad and
Gypsum Storage areas. Therefore, in order to properly evaluate the numbers and locations
of the proposed monitoring wells, the footprints of both the Gypsum Storage Area and
Gypsum Pad should be clearly indicated on Figure 1. Components and associated features
should also be labeled including the extent of any liners.
• Verify FGD residue stored on the Gypsum Pad was limited to gypsum. If FGD residue
other than gypsum was stored, please provide a characterization.
• Data should also be collected from each proposed well to evaluate hydraulic parameters
such as hydraulic conductivity and flow velocity in the area.
If applicable, the results should also be incorporated into the updated CAP's revised geochemical
and groundwater fate and transport models. If the results of the modeling show current or future
impacts to groundwater and/or surface water from this area, then appropriate remedial strategies
shall be proposed in the CAP.
North Carolina Department of Environmental Quality I Division of Water Resources
M E 512 North Salisbury Street 1 1636 Mail Service Center I Raleigh, North Carolina 27699-1636
=fir" orW"a 919.707.9000

If you have any questions, please contact Shuying Wang (Winston-Salem Regional Office) at
[phone] or Steve Lanter (Central Office) at [phone].
Sincerely,
on Ris d, Chief
Anima Feeding Operations and Groundwater Section
cc: WSRO WQROS Regional Office
WQROS Central File Copy