# ( -, DUKE ENERGY 4P

June 24, 2014 VIA UPS OVERNIGHT Ronald Jordan US EPA EPA West Building/Conn ectin g Win g , R o om 6233 -W 1301 Constitution Ave nue, NW Washington DC 20004 Subject: Miami Fort Station - Supplemental Information Request Mr
. Ron Jordan: Envi ronmental Services Duke Energy 526 South Church Street Charlotte, NC 28202 Ma il Code EC13K I POB 1006 Charlotte, NC 28201-1006

On January 27, 2014, US EPA submitted to Duke Energy a Supplemental Information Request seeking data related to Duke Energy's comments on US EPA's Proposed Effluent limitation Guidelines and Standards for Electric Power Generation Point sources (78 FR 34432). Two compact discs (CD) were sent via FED-EX on March 28, 2014. A follow up email was sent by US EPA on May 8, 2014 requesting a conference call to clarify some of th e data and the lab reports and a document was included with 20 questions regarding the data. Th e conference call was held on May 15, 2014 and all 20 questions were addressed. Several of the questions required additional follow up by Duke to investigate the discrepancies' and obtain the add itional l ab analysis reports . Duke began to obtain the needed information and answers immediately aft e r the call
. A follow up email was sent by US EPA on June 11, 2014 inquiring on the status of the information. Questions were included in the email and are answered below
. 

### 1. Confirm whether the research lab result for arsenic of 4.34 ug/L on 6/28/11 is a J-value. 

### Answer : Ref Question 2b (from 5/8/11). The 4
. 34 ug/L is a reportable value and not a J -value. The 6/28/11 lab report showed a measured value of4.34 ug/L with a RL of2 and a DL of 1
. Correct ions have been applied to the "USEPA Analytical Data Table MFS 5_28_14". 2
. Provide add i tional lab report s for the arsenic data you submitted (see question #5 of th e attached fil e ). 

### Answer: Ref Question 5 (from 5/8/11) 28 lab reports with arsenic analytical data have been provided. Note some reports contain both mercury and arsenic data as well as other analytes. Please note, four different laboratories analyzed the sample collected on 5/8/2013. The laboratory reports reference Belews Creek; however, the Client ID contains MF, which stands for Miami Fort. The reference to Belews Creek is a project reference, not a Page 

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# DUKE 

# ENERGY . Environmental Services Duke Energy 526 South Church Street Charlotte, NC 28202 Mail Code EC13K I POB 1006 Charlotte, NC 28201-1006 

### station sample reference. At this time, Duke has not been able to obtain UWAG Attorn e y Client Confidential Reports 7/12/2010, 7/13/2010, 7/14/2010, 7/15/2010, 7/16/2010, 9/28/2010, 11/2/2010, 1/14/2011 3
. For arsenic data on 7 /31/12 and 8/1/12, the data submitted with comments show non - detect at 10 ppb, while the spreadsheet provided in response to EPA's data request shows non - dete c t at 20 ppb. Please confirm which RL is correct. 

### Answer: The <20 ug/l reporting limit previously shown was incorrect. Corrections have been applied to the Analytical Data Spreadsheet. Also see additional comment in Question #4 below
. 4
. As I recall , during the call Duke staff suggested som e of the arsenic data may have been analyze d at l abs that a re not certified. If so, please specify which data this applies to . 

### Ans wer: Th e contracted research firm modified the preparation of samples in the field prior to shipm ent using EPRI "Method Al-Reagent and Slurry Sampling" this applies to arseni c samples 7/31/12, 8/1/12, 8/8/12, and 8/9/12. Therefore the results shown on the Analytical Data Table are multiplied by the appropriate "Sampling" dilution factor calculated by th e research firm and do not match the lab report. 5
. Pl ea se provid e the lab report for the mercury result of 343 ng/L on 11/2/10. 

### Ans wer : Ref ques tion BC (from 5/8/14) 343 ng/l i s a UWAG report and is on e of th re e 608 samples taken on 11/ 2

/10
. The other lab re port with NPDES sampl es analy ze d by T es t America was provid ed previously. The analytical data sheet has been updat ed
. 11/2/10 OHEPA NPD E S Permit 608 effluent sample 248 ng/l 11/2/10 OHE PA NPD E S P ermit 608 e ffluent duplicate sample 254 ng/l 11/2/10 UWAG Sp/it of USEPA Sample 343 ng/l The fir st two samples were av eraged together {248+2 5 4)/2 = 25 1 ng/l) for th e DMR data which was also used in th e UWAG comments 6. Confirm wheth e r th e m e rcury result of 0
. 5 n g /L on 4/2/13 is non -detect (see qu estion #12 of th e attached file)
. 

### Answer : It is non -det ect. A"<" s ymbol has been add ed to the analyt ical data table
. 7. Please provid e the lab report for total m e rcury on 9/1/09 and 9/21/09 (see question #14 of the attached fil e). 

### Answer : Th ese are i ncluded in the second i ss ue oflab reports.
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# DUKE 

# ENERGY 4D Envi ronmental Servi c es Duke Energy 526 South Church Street Charlotte, NC 28202 Mail Cod e EC13K I POB 1006 Charlotte, NC 28201-100 6 8. Confirm the dilution factor calculations for outfall 601 on 9/3/13 for units 7 

### & 8 (see question #18 of the attach ed file). 

### Answer: 40,000 Dilution Factor is correct. Th e lab checked their records and found that 2 dilutions were performed (400 on 9/13/13 during the sample preparation, and 100 on 9/14/13 just prior to running the sample)
. The total dilution would be 40,000
. The spreadsheet has been updated with the corr ect values. 9. Please provide the additional lab reports for th e m e rcury data you submitted (see question #20 of the attach e d file). 

### Answer : 18 lab reports with mercury analy sis have been provided. If EPA has any que s tion specific to the data submitted, pl ea se contact Nathan Cra ig, Duke En e rgy, 52 6 South Church St., Charlotte, NC 28202. Telephon e: 704-382-9622
. Email: nathan.craig @ dukeenerg y .com .

# ;~:: 

# t.
N athan Craig 

# J Senior Environmenta l Sp e ci a li s t

Enclosure : Compact Disk (CD) 1 Exce l F il e "US E PA An a lytical Data Table MFS 5_28_14 EPA Info Upd at es 43 PD F Lab R e port F il es . CC: Julie Ezell Richard Bake r John Velte Jennifer Ste n ge r Brandon De li s Bill K e nn e dy Joe Potts Pat Coyl e

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