(-, DUKE 

ENERGY4P 

June 24, 2014 

VIA UPS OVERNIGHT 

Ronald Jordan 

US EPA 

EPA West Building/Connecting Wing, Room 6233-W 

1301 Constitution Avenue, NW 

Washington DC 20004 

Subject: Miami Fort Station - Supplemental Information Request 

Mr. Ron Jordan: 

Environmental Services 

Duke Energy 

526 South Church Street 

Charlotte, NC 28202 

Mail 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 the 

data and the lab reports and a document was included with 20 questions regarding the data. The 

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 additional lab 

analysis reports. Duke began to obtain the needed information and answers immediately after 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 of 4.34 ug/L with a RL of 2 and a DL of 1. 

Corrections have been applied to the "USEPA Analytical Data Table MFS 5_28_14". 

2. Provide additional lab reports for the arsenic data you submitted (see question #5 of the 

attached file). 

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 

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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 Attorney 

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-detect 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 some of the arsenic data may have been analyzed 

at labs that are not certified. If so, please specify which data this applies to. 

Answer: The contracted research firm modified the preparation of samples in the field prior to 

shipment using EPRI "Method Al-Reagent and Slurry Sampling" this applies to arsenic 

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 the 

research firm and do not match the lab report. 

5. Please provide the lab report for the mercury result of 343 ng/L on 11/2/10. 

Answer: Ref question BC (from 5/8/14) 343 ng/l is a UWAG report and is one of three 608 

samples taken on 11/2/10. The other lab report with NPDES samples analyzed by Test 

America was provided previously. The analytical data sheet has been updated. 

11/2/10 OHEPA NPDES Permit 608 effluent sample 248 ng/l 

11/2/10 OHEPA NPDES Permit 608 effluent duplicate sample 254 ng/l 

11/2/10 UWAG Sp/it of USEPA Sample 343 ng/l 

The first two samples were averaged together {248+254)/2 =251 ng/l) for the 

DMR data which was also used in the UWAG comments 

6. Confirm whether the mercury result of 0.5 ng/L on 4/2/13 is non-detect (see question #12 of the 

attached file). 

Answer: It is non-detect. A"<" symbol has been added to the analytical data table. 

7. Please provide the lab report for total mercury on 9/1/09 and 9/21/09 (see question #14 of the 

attached file). 

Answer: These are included in the second issue of lab reports. 

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DUKE 

ENERGY4D 

Environmental Services 

Duke Energy 

526 South Church Street 

Charlotte, NC 28202 

Mail Code EC13K I POB 1006 

Charlotte, NC 28201-1006 

8. Confirm the dilution factor calculations for outfall 601 on 9/3/13 for units 7 & 8 (see question #18 

of the attached file). 

Answer: 40,000 Dilution Factor is correct. The 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 correct values. 

9. Please provide the additional lab reports for the mercury data you submitted (see question #20 

of the attached file). 

Answer: 18 lab reports with mercury analysis have been provided. 

If EPA has any question specific to the data submitted, please contact Nathan Craig, Duke Energy, 526 

South Church St., Charlotte, NC 28202. Telephone: 704-382-9622. Email: nathan.craig@dukeenergy.com. 

;~:: t. 

Nathan Craig J 

Senior Environmental Specialist 

Enclosure: Compact Disk (CD) 

1 Excel File "USE PA Analytical Data Table MFS 5_28_14 EPA Info Updates 

43 PDF Lab Report Files. 

CC: Julie Ezell 

Richard Baker 

John Velte 

Jennifer Stenger 

Brandon Delis 

Bill Kennedy 

Joe Potts 

Pat Coyle 

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