Dan River Confirmation of Excavation Requirments 9-11-19

ROY COOPER
Governor
HCHAEL 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
September 11, 2019
Subject: Confirmation of Excavation Requirements for the Dan River Combined Cycle
Station Ash Basins
Dear Mr. Draovitch:
The purpose of this letter is to confirm excavation requirements are being met in the Dan River
Steam Station ash basins based on progress to date. On December 11, 2018, the North Carolina
Department of Environmental Quality (DEQ) received the Dan River Steam Station Coal Ash
Excavation Plan 2018 Update. Duke Energy was directed to follow the "Coal Combustion
Residuals (CCR) Surface Impoundment Closure Guidelines for Protection of Groundwater" -
November 4, 2016 in correspondence on that date.
On July 31, 2019, the North Carolina Department of Environmental Quality (DEQ) received the
CCR Visual Removal Verification Report — Dan River Steam Station. The DEQ has reviewed
documentation provided by Duke Energy to assess completion of closure requirements at the
subject basin. DEQ concurs that the visual confirmation data provided meets the overall objectives
of sample collection and analysis consistent with recommended technical direction outlined in
DEQ's CCR Surface Impoundment Closure Guidelines for Protection of Groundwater. However,
there are questions concerning documentation of some aspects of the data collection effort that
require clarification
• Documentation of the rationale for not collecting samples at grid locations BC-lE, BC-2E,
BC-6H, BC-7I, BC-8I, BC-10J, BC-12J, BC-13J, BC-15K to BC-24K, BC-25L, BC-27M,
BC-29K, BC-29L, and BC-29M is requested.
Soil analytical results shall be incorporated into the geochemical and transport models that will be
included in the upcoming Corrective Action Plan.
North Carolina Department of Environmental Quality I Division of Water Resources
_Q--�512 North Salisbury Street 1 1636 Mail Service Center I Ralelgh. North Carolina 27699-1636
=um"�+� /'� 919.707.9000

If you have any questions, please feel free to contact Shuying Wang (Winston-Salem Regional
Office) at (336)-776-9702 or Steve Lanter (Central Office) at [phone].
Sincerely,
Jim �ggson, Deputy Director
Division of Water Resources
Edw F. M ler III, P.E.
Chief, Solid Waste Section
Division of Waste Management
cc: WSRO WQROS Regional Office Supervisor (Electronic)
Ellen Lorscheider - Division of Waste Management
WQROS Central File Copy