HomeMy WebLinkAboutNC0003433_Seep Corrective Action Plan Amendment_20220831 4 '.
(' DUKE James Wells
Vice President
ENERGY® Environmental,Health and Safety
Programs&Environmental Sciences
526 South Church Street
Charlotte,NC 28202
(980)373-9646
August 24, 2022 RECEIVED
Richard Rogers Ati6 3 1 2022
NC DEQ-Director of Water Resources
1617 Mail Service Center NCDEQIDWRINPDES
Raleigh, NC 27699-1617
Bob Sledge
NC DEQ-Division of Water Resources
1617 Mail Service Center
Raleigh,NC 27699-1617
Subject: Report Under Special Order by Consent—EMC SOC WQ S 19-001
Duke Energy Progress, LLC—Cape Fear Steam Station
NPDES Permit NC0003433
Seep Corrective Action Plan amendment
Dear Messrs. Rogers and Sledge:
On behalf of Duke Energy Progress, LLC (DEP), I am submitting to you the Cape Fear steam
station Seep Corrective Action Plan amendment as required by Section 2.) b.7) of the subject
Special Order by Consent (SOC). The report summarizes how remaining seeps will be managed
in a manner sufficient to protect public health, safety, and welfare, the environment, and natural
resources.
Please direct any questions concerning this submittal to Shannon Langley at(919) 546-2439 or
shannon.langley@duke-energy.com.
As required by the SOC,I certify under penalty of law that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who
manage the system, or those persons directly responsible for gathering the information, the information
submitted is, to the best of my knowledge and belief true, accurate, and complete. I am aware that there
are significant penalties for submitting false information, including the possibility of fine and imprisonment
for knowing violations.
Sincerely,
Jams Wells
Vice resident, Environmental, Health & Safety
Programs and Environmental Sciences
Duke Energy
Messrs.Rogers and Sledge
Cape Fear Seep Corrective Action Plan amendment
Page 2
Attachment
Cape Fear steam station 2022 Seep Corrective Action plan Amendment
CC: Joyce Dishmon/FileNet, Duke Energy via email
John Toepfer, Duke Energy via email
John Stamas,Duke Energy via email
Matt Hanchey, Duke Energy via email
Shannon Langley,Duke Energy via email
Scott Vinson—NC DEQ
3800 Barrett Drive
Raleigh,NC 27609
, f s
synTerra Science & Engineering Consultants
synterracorp.com
SEEP MANAGEMENT PLAN
AMENDMENT TO THE CORRECTIVE ACTION PLAN
CAPE FEAR STEAM ELECTRIC PLANT
EMC SOC WQ 519-001
500 CP&L ROAD
MONCURE, NORTH CAROLINA 27559
AUGUST 2022
PREPARED FOR
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1
Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
EXECUTIVE SUMMARY
SynTerra prepared this Seep Management Plan Amendment to the Corrective Action Plan (CAP)
(SynTerra, 2016) pertaining to the Cape Fear Steam Electric Plant (Cape Fear or Site)to describe
plans for the management of identified seeps in a manner that protects public health, safety,
and welfare; the environment; and natural resources.This amendment to the CAP was
prepared on behalf of Duke Energy Progress, LLC (Duke Energy). Corrective action beyond the
planned closure of the ash basins may not be necessary for the seeps at Cape Fear.
Special Order by Consent (SOC) WQ S19-001, approved on January 27, 2020, addresses the
management of seeps during the process of basin closure under the Coal Ash Management Act
of 2014, North Carolina General Statutes 130A-309.200 through 130A-309.231, and the federal
Coal Combustion Residuals (CCR) Rule, 40 CFR Parts 257 and 261. Section 2.b.7 of the SOC
states:
No later than August 31, 2022, (60 days following the submittal of the Seep
Characterization Report for the Facility), Duke Energy shall submit a complete
and adequate proposed amendment to the groundwater Corrective Action Plan
and/or Closure Plan as appropriate for the Cape Fear Facility describing how any
seeps identified in the Seep Characterization Report will be managed in a manner
that will be sufficient to protect public health, safety, and welfare, the
environment, and natural resources...
The Seep Characterization Report(SynTerra, 2022) identified five non-dispositioned seeps at
four locations associated with the 1963 and 1985 ash basins (presented below by associated
source area)that require a management plan:
1963 Ash Basin
• 5-15—Seep characterization analytical results indicate that total arsenic, hardness, and
total dissolved solids (TDS) concentrations are greater than North Carolina
Administrative Code (NCAC), Title 15A, Subchapter 02B, Surface Water and Wetland
Standards (02B) standards. However, quarterly SOC monitoring data collected at
instream monitoring location Downstream Cape Fear River (located downstream of seep
S-15 discharges) indicate that SOC Attachment B constituents are less than their
respective 02B standards and that flows from the minor area of seepage have no
detected influence on water quality within the Cape Fear River.The flow rate at S-15 has
remained relatively stable based on inspection observations. However, closure activities
related to the 1963 ash basin, including removal of CCR and associated interstitial ash
pore water, is anticipated to reduce or cease seep flow because those activities would
reduce the hydraulic head upgradient of S-15.
• S-16/5-18—Seep characterization analytical results indicate that arsenic (total and
dissolved), hardness, nickel (total and dissolved), sulfate,TDS, and zinc (dissolved)
concentrations are greater than 02B standards. Like 5-15, quarterly SOC monitoring data
August 2022 Page ES-1
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Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
collected at instream monitoring location Downstream Cape Fear River (located
downstream of seep S-16/S-18 discharges) indicate that SOC Attachment B constituents
are less than their respective 02B standards and that flows from the minor area of
seepage have no detected influence on water quality within the Cape Fear River.The
flow rate at S-16/S-18 has remained relatively stable based on inspection observations.
As with 5-15, closure activities related to the 1963 Ash Basin, including removal of CCR
and associated interstitial ash pore water, is anticipated to reduce or cease seep flow
because those activities would reduce the hydraulic head upgradient of the seeps.
1985 Ash Basin
• S-07—Seep characterization analytical results indicate that hardness, sulfate, and TDS
concentrations are greater than 02B standards. However, quarterly SOC monitoring data
collected at instream monitoring location of unnamed tributary (UT) Cape Fear River#2
(located downstream of seep S-07 discharges) indicate that all SOC Attachment B
constituents are less than their respective 02B standards, except hardness. Hardness
concentrations observed in the downstream SOC location indicate a decrease by half of
what is observed at S-07 and are less than the interim action level of 600 milligram per
liter (mg/L) established in the SOC. Other constituents (sulfate and TDS) detected at
S-07 at concentrations greater than applicable 02B standards were not detected at
concentrations greater than applicable 02B standards downstream at UT Cape Fear
River#2 indicating that contribution of flow from S-07 may not be the source of the
hardness concentration at UT Cape Fear River#2 and that flows from the minor area of
seepage have no detected influence on water quality within the unnamed tributary.The
flow rate at S-07 has remained relatively stable based on inspection observations.
However, flow is anticipated to be reduced or cease once the 1985 ash basin is
excavated, which would include removal of interstitial water within the CCR, thus
reducing the hydraulic head within the basin upgradient of the seep.
• S-08—Seep characterization analytical results indicate that hardness concentrations are
greater than 02B standards. However, quarterly SOC monitoring data collected at
instream monitoring location UT Cape Fear River#2 (located downstream of seep S-08
discharges) indicate that all SOC Attachment B constituents are less than their
respective 02B standards, except hardness. Hardness concentrations observed in the
downstream SOC location indicate decreased concentrations compared to those
observed at S-08 and are less than the interim action level of 600 mg/L established in
the SOC.The flow rate at S-08 has remained relatively stable based on inspection
observations. However, flow is anticipated to be reduced or cease once the 1985 ash
basin is excavated which would include removal of interstitial water within the CCR, thus
reducing the hydraulic head within the basin upgradient of the seep.
Duke Energy continues to implement ash basin closure and corrective action activities that
affect groundwater seepage in a manner that is protective of public health, safety, and welfare;
the environment; and natural resources.
August 2022 Page ES-2
Project:00.0060.17
Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
Completed, ongoing, and planned corrective action and closure activities include:
Year Closure or Corrective Action Activity
2017-2019 1978 and 1985 ash basins decanting
2019-ongoing 1978 and 1985 ash basins dewatering
December 2020 Excavation of 1985 ash basin began and is ongoing
September 2021 Excavation of 1956 ash basin began and is ongoing
Fall 2022 Excavation of the 1963/1970 ash basins is planned to begin
2022 Submit Groundwater Corrective Action Plan Update
2020—2029 Dewatering,excavation,and closure of the ash basins
Evaluation of constituent concentrations at seep locations using the Mann-Kendall trend test
demonstrates predominantly stable and decreasing trends.This evaluation indicates that the
system has been geochemically stable prior to, and since, implementation of ash basin closure
activities.
Based on findings from seep characterization (SynTerra, 2022), the following corrective action
strategies are planned to manage the remaining non-dispositioned seeps.
1963 Ash Basin
S 15 Closure of the 1963 ash basin will reduce the source of CCR constituents in the seep.Additional
corrective action for this location is not anticipated.
Closure of the 1963 ash basin will reduce the source of CCR constituents in the seeps.These
S-16/S-18 seeps are currently being addressed with a treatment system that captures flow from those
seeps as well as S-17 and 5-19.Additional corrective action for this location is not anticipated.
1985 Ash Basin
S 07 and S 08 1985 ash basin excavation will reduce the source of CCR constituents at these locations.
Additional corrective action for these locations is not anticipated.
Non-dispositioned seeps are scheduled to be monitored as required by the SOC until
termination of the SOC by the Division of Water Resources (DWR), or no later than August 31,
2023. Upon termination of the SOC, continued (effectiveness) monitoring of remaining non-
dispositioned seep locations is recommended until closure of the associated ash basin is
complete, or until a seep is dry for two consecutive sampling events, or sample data from two
consecutive sampling events indicate ash basin constituent of interest (COI) concentrations are
less than 02B standards. Seeps would be monitored on a semiannual basis consistent with the
nearby groundwater monitoring network to correlate changing water quality and geochemical
conditions. Seeps would be analyzed for constituents within the approved groundwater interim
monitoring plan (IMP). It is anticipated that seep monitoring would be discussed and new data
would be evaluated in Annual Groundwater and Surface Water Monitoring Reports.
August 2022 Page ES-3
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Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
TABLE OF CONTENTS
SECTION PAGE
EXECUTIVE SUMMARY 1
1.0 INTRODUCTION 1-1
1.1 Background 1-1
1.2 Purpose and Scope 1-2
1.3 Previous Reporting 1-2
2.0 OVERVIEW OF SEEPS PROPOSED FOR MANAGEMENT 2-1
2.1 Seeps Associated with the Ash Basins 2-1
3.0 PROPOSED SEEP MONITORING PLAN
3-1
3.1 Seeps Associated with the Ash Basins 3-1
3.2 Nature and Extent of Source Related Constituents and Seeps 3-1
3.3 Ash Basin Closure and Corrective Action 3-3
3.4 Mann-Kendall Trend Test Analysis 3-3
3.5 Seep Corrective Action Strategy 3-4
3.6 Seep Monitoring 3-5
4.0 REFERENCES 4-1
LIST OF FIGURES
Figure 1-1 Site Location Map
Figure 2-1 Existing Seep Locations and Inspection Areas
Figure 3-1 Proposed Seep Dispositional Status and Locations
Figure 3-2 Conceptual Site Model - Boron
LIST OF TABLES
Table 2-1 Seep Status Summary
Table 3-1 Seep Characterization Sampling Results—February 2022
LIST OF APPENDICES
Appendix A SOC WQ 519-001
Appendix B Mann-Kendall Trend Test Analysis, August 2022
August 2022 Page I
Project:00.0060.17
Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
LIST OF ACRONYMS
02B North Carolina Administrative Code,Title 15A, Subchapter 02B, Surface
Water and Wetland Standards
02L North Carolina Administrative Code,Title 15A, Subchapter 02L, Groundwater
Standards
Cape Fear/Site Cape Fear Steam Electric Plant
CAP Corrective Action Plan
CCR coal combustion residual
COI constituents of interest
CWEC Cooling water effluent channel
DWR Division of Water Resources
Duke Energy Duke Energy Progress, LLC
µg/L micrograms per liter
mg/L milligrams per liter
NCAC North Carolina Administrative Code
NCDEQ North Carolina Department of Environmental Quality
NPDES National Pollutant Discharge Elimination System
PPA Power production area
SOC Special Order by Consent
TDS total dissolved solids
UT Unnamed tributary
WOS Waters of the State
WOTUS Waters of the United States
August 2022 Page ii
Project:00.0060.17
Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
1.0 INTRODUCTION
SynTerra prepared this Seep Management Plan Amendment to the Corrective Action Plan (CAP)
(SynTerra, 2016) pertaining to the Cape Fear Steam Electric Plant (Cape Fear or Site)to describe
plans to manage identified seeps in a manner that protects public health, safety, and welfare;
the environment; and natural resources.This amendment to the CAP was prepared on behalf of
Duke Energy Progress, LLC (Duke Energy). Corrective action beyond the planned closure of the
ash basins may not be necessary for seeps at Cape Fear.
1.1 Background
Special Order by Consent (SOC) WQ S19-001, approved on January 27, 2020, addresses
management of seeps at the Site during the process of basin closure under the Coal Ash
Management Act of 2014, North Carolina General Statutes 130A-309.200 through 130A-
309.231, and the federal Coal Combustion Residuals (CCR) Rule, 40 CFR Parts 257 and 261.
The SOC is provided in Appendix A.
Five ash basins have been used to retain and settle ash sluice water generated from coal
combustion at the Plant and are referenced using the date of construction: 1956, 1963, 1970,
1978, and 1985 (Figure 1-1).The 1956, 1963, 1970, and 1978 ash basins have not received ash
in decades. Sluicing to the most recently active ash basin, the 1985 ash basin, ceased in 2012.
The Cape Fear ash basins have been operated under a National Pollution Discharge Elimination
System (NPDES) Permit issued by the North Carolina Department of Environmental Quality
(NCDEQ) Division of Water Resources (DWR).
The cooling water effluent channel (CWEC), located in the central portion of the Site, originates
and flows south from the former power production area (PPA) and between the 1978 and 1985
ash basins.The CWEC, which divides the Site topographically and hydraulically, extends to an
unnamed tributary (UT) of the Cape Fear River, which continues for approximately 7 miles
flowing toward the Cape Fear River downstream of Buckhorn Dam. In 2017, approximately
1,500 feet of the CWEC was filled in from the former PPA to the former cooling towers. Since
power is no longer produced at the Plant, water is no longer pumped from the former PPA to
the CWEC.The channel now receives stormwater runoff from a limited area and permitted
wastewater. Flow within the channel is low with no visible current and is affected by the Cape
Fear River stage.The channel is approximately 40 feet wide in the vicinity of the ash basins.
Decanting (removal) of free water from the 1978 and 1985 ash basins commenced in early April
2017 with the redirection of wastewater inflows from the ash basins into a physical-chemical
treatment system designed to meet the requirements of NPDES permit NC0003433. Decanting
was completed in November 2019. Dewatering of ash pore water began in November 2019 and
is ongoing. Excavation of the 1985 ash basin began in September 2020 while excavation of the
1956 ash basin began in 2021. Excavation of the 1963 and 1970 ash basins to begin in fall 2022.
An ash reprocessing facility is located southeast of the 1985 basin for beneficial reuse of the
excavated CCRs.
August 2022 Page 1-1
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Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
A seep remediation system was installed to capture flow from seeps S-16 through 5-19 along
Fear River. Flow is captured and channeled into a single
the Cape ea engineered channel lined with p g
high density polyethylene, filled with limestone and surrounded by riprap. Flow within the
channel passes through a magnesium oxide reaction box for treatment prior to discharge at a
single point in the vicinity of the original S-18 area before discharging into the Cape Fear River.
The system has been effective at capturing flow from each seep as flow no longer emerges at
the original seep locations. Seep samples are collected after the system prior to discharging into
the Cape Fear River.
A site location map is provided on Figure 1-1.
1.2 Purpose and Scope
As required in Section 2.b.7 of the SOC, this Seep Management Plan Amendment to the CAP
describes the plan to manage seeps identified in the Seep Characterization Report (SynTerra,
2022) in a manner that will protect public health, safety, and welfare; the environment; and
natural resources.The Seep Characterization Report evaluated seeps based on physical status,
chemical composition, and jurisdictional determination.To be considered for corrective action
in this Seep Management Plan, a seep must:
1) Be non-dispositioned
2) Constitute, or flow to Waters of the State (WOS) or Waters of the United States
(WOTUS)
3) Exhibit constituent concentrations that are greater than applicable North Carolina
Administrative Code (NCAC),Title 15A, Subchapter 028, Surface Water and Wetland
Standards (02B)
1.3 Previous Reporting
Detailed descriptions of previous Site SOC assessments and characterizations are documented
in the following:
• Comprehensive Site Assessment Report—Cape Fear Steam Electric Plant—SynTerra,
September 2015
• Corrective Action Plan Part 1—Cape Fear Steam Electric Plant—SynTerra, December
2015
• Corrective Action Plan Part 2—Cape Fear Steam Electric Plant—SynTerra, February 2016
• Comprehensive Site Assessment Supplement 1—Cape Fear Steam Electric Plant—
SynTerra, September 2016
• Surface Water Evaluation to Assess 15A NCAC 02B .0200 Compliance for
Implementation of Corrective Action Under 15A NCAC 02L .0106 (k) and (I)—SynTerra,
February 2020
August 2022 Page 1-2
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Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
• 2020 Annual Seep Report, Cape Fear Steam Electric Plant—SynTerra, April 2021
• 2021 Annual Seep Report, Cape Fear Steam Electric Plant—SynTerra, April 2022
• Comprehensive Site Assessment Update, Cape Fear Steam Electric Plant—SynTerra,
December 2020
• Final Seep Report, Cape Fear Steam Electric Plant—SynTerra, April 2022
• Seep Characterization Report, Cape Fear Steam Electric Plant—SynTerra,June 2022
August 2022 Page 1-3
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Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
2.0 OVERVIEW OF SEEPS PROPOSED FOR MANAGEMENT
According to the SOC, there were 23 identified non-constructed seeps associated with the ash
basins. Of those 23 non-constructed seeps, 10 seeps (S-01, S-02, S-03, S-06, S-10, S-11, S-12, S-
13, S-14, and S-23) were dispositioned at the issuance of the SOC. Eight seeps (S-04, S-05, S-09,
S-17, S-19,S-20, S-21, and S-22) were proposed to be dispositioned in the Seep Characterization
Report(SynTerra, 2022). Five non-constructed seeps remain non-dispositioned. Seep
descriptions and statuses are provided in Table 2-1. The remaining non-dispositioned seeps
identified in the SOC are described below.
2.1 Seeps Associated with the Ash Basins
The following non-dispositioned seeps are depicted on Figure 2-1:
1963 Ash Basin Seeps
• S-15—Seep characterization analytical results indicate that total arsenic, hardness, and
TDS concentrations are greater than 02B standards. However, quarterly SOC monitoring
data collected at instream monitoring location Downstream Cape Fear River(located
downstream of seep S-15 discharges) indicate that SOC Attachment B constituents are
less than their respective 02B standards and that flows from the minor area of seepage
have no detected influence on water quality within the Cape Fear River.The flow rate at
S-15 has remained relatively stable based on inspection observations. Closure activities
related to the 1963 ash basin, including removal of CCR and associated interstitial ash
pore water, is anticipated to reduce or cease seep flow because those activities would
reduce the hydraulic head upgradient of S-15. Excavation of the 1963 ash basin to begin
in fall 2022.
• S-16/S-18—Seep characterization analytical results indicate that arsenic (total and
dissolved), hardness, nickel (total and dissolved), sulfate,TDS, and zinc (dissolved)
concentrations are greater than 02B standards. Like S-15, quarterly SOC monitoring data
collected at instream monitoring location Downstream Cape Fear River (located
downstream of seep S-16/S-18 discharges) indicate that SOC Attachment B constituents
are less than their respective 02B standards and that flows from the minor area of
seepage have no detected influence on water quality within the Cape Fear River.The
flow rate at S-16/S-18 has remained relatively stable based on inspection observations.
As with S-15, closure activities related to the 1963 ash basin, including removal of CCR
and associated interstitial ash pore water, is anticipated to reduce or cease seep flow
because those activities would reduce the hydraulic head upgradient of the seeps.
Excavation of the 1963 ash basin to begin in fall 2022
Page 2-1
August 2022 Pa 8
Project:00.0060.17
Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
1985 Ash Basin Seeps
• 5-07—Seep characterization analytical results indicate that hardness, sulfate, and TDS
concentrations are greater than 02B standards. However, quarterly SOC monitoring data
collected at instream monitoring location UT Cape Fear River#2 (located downstream of
seep S-07 discharges) indicate that all SOC Attachment B constituents are less than their
respective 02B standards, except hardness. Hardness concentrations observed in the
downstream SOC location indicate a decrease by half of what is observed at S-07 and
are less than the interim action level of 600 mg/L established in the SOC. Other
constituents (sulfate and TDS) detected at 5-07 at concentrations greater than
applicable 02B standards were not detected at concentrations greater than applicable
02B standards downstream at UT Cape Fear River#2, indicating that contribution of
flow from S-07 may not be the source of the hardness concentration at UT Cape Fear
River#2 and that flows from the minor area of seepage have no detected influence on
water quality within the unnamed tributary. The flow rate at S-07 has remained
relatively stable based on inspection observations. However, flow is anticipated to be
reduced or cease once the 1985 ash basin is excavated, which would include removal of
interstitial water within the CCR, thus reducing the hydraulic head within the basin
upgradient of the seep. Excavation of the 1985 ash basin began in fall 2020.
• S-08—Seep characterization analytical results indicate that hardness concentrations are
greater than 02B standards. However, quarterly SOC monitoring data collected at
instream monitoring location UT Cape Fear River#2 (located downstream of S-08
discharges) indicate that all SOC Attachment B constituents are less than their
respective 02B standards, except hardness. Hardness concentrations observed in the
downstream SOC location are less than that observed at S-08 and are less than the
interim action level of 600 mg/L established in the SOC.The flow rate at S-08 has
remained relatively stable based on inspection observations. However, flow is
anticipated to be reduced or cease once the 1985 ash basin is excavated, which would
include removal of interstitial water within the CCR, thus reducing the hydraulic head
within the basin upgradient of the seep. Excavation of the 1985 ash basin began in fall
2020.
August 2022 Page 2-2
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Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress,LLC
Moncure, North Carolina
3.0 PROPOSED SEEP MONITORING PLAN
3.1 Seeps Associated with the Ash Basins
With concurrence from NCDEQ DWR on seep jurisdictional and dispositional status and upon
termination of the SOC, effectiveness monitoring of the five non-dispositioned seeps (S-07, S-
08, S-15, S-16, and S-18) is recommended until closure of the associated ash basin is complete,
or until a seep is dry for two consecutive sample events, or sample data from two consecutive
sampling events indicate ash basin constituent of interest (COI) concentrations are less than
02B standards. Seeps proposed for disposition within the Seep Characterization Report and
non-dispositioned seeps are depicted on Figure 3-1.
pp g
Duke Energy continues to implement ash basin closure activities to reduce groundwater
seepage. Source control is the primary remedy for managing seeps associated with the ash
basins. Source control is conducted in a manner that is protective of public health, safety, and
welfare; the environment; and natural resources. Completed and ongoing ash basin closure
activities, implemented by Duke Energy, are detailed in Section 3.3.The nature and extent of
identified seeps, effects of ash basin closure, and details about proposed monitoring are
discussed in the following subsections.
3.2 Nature and Extent of Source Related Constituents and Seeps
Based on groundwater data collected through May 2020, COIs associated with the ash basins
include (SynTerra, 2020):
• Beryllium • Iron • Strontium
• Boron • Manganese • Sulfate
• Cobalt • Molybdenum • Total dissolved solids (TDS)
Of those COls, boron, sulfate, and TDS are SOC Attachment B surface water constituents with
02B standards or in-stream target values.
Boron analytical results greater than groundwater background concentrations represent the
extent of affected groundwater(Figure 3-2). Because boron is non-reactive and mobile in
groundwater, it has been identified as a leading-edge indicator and is representative of the
overall plume that contains other COls greater than comparison criteria [02L standard or
background concentrations, whichever is greater]. Boron concentrations found in groundwater
at the 1963 and 1985 ash basins are discussed below.
August 2022 Page 3-1
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Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
1963 Ash Basin
The extent of affected groundwater associated with the 1963 ash basin is limited to a small
area downgradient of the basin and south of seep S-15, between the waste boundary and
the Cape Fear River(Figure 3-2). Groundwater in the area of the 1963 ash basin area
generally flows west toward the Cape Fear River.
1985 Ash Basin
The extent of affected groundwater associated with the 1985 ash basin is mostly limited to
an area beneath the basin, except for a small area that extends to the east beyond the waste
boundary(Figure 3-2). Groundwater in the area of the 1985 ash basin generally flows
southeast toward the unnamed tributary.
The most recent seep sampling event (February 2022) was evaluated in the Seep
Characterization Report (SynTerra, 2022), and results are presented in Table 3-1.The non-
dispositioned seeps that were proposed to be dispositioned in the Seep Characterization Report
(S-04, S-05, S-09, S-17, S-19, S-20, S-21, and S-22) exhibited insufficient flow to collect a sample.
A summary of non-dispositioned seep analytical results pertaining to seeps with SOC
Attachment B constituent concentrations greater than 02B standards during the February 2022
sampling event is provided in the following table:
I Seep 02B
Constituent Concentration Additional Information
Locations Standard
Hardness 100 302 No human health or aquatic life concern with
(mg/L) increased hardness.
Sulfate(µg/L) 250 270 Instream monitoring in UT Cape Fear#2,
downstream of S-07 seep discharges,
S-07 indicates that sulfate and TDS concentrations
are less than their 02B standards and that
TDS(mg/L) 500 548 flows from the minor area of seepage have no
detected influence on water quality within
the unnamed tributary.
S-08 Hardness(mg/L) 100 207 No human health or aquatic life concern with
increased hardness.
No human health or aquatic life concern with
Hardness(mg/L) 100 416 increased hardness.
Instream monitoring in the Cape Fear River
Arsenic(µg/L) 10 40.3 downstream of the Site seep discharges
5-15 (Downstream Cape Fear River)indicates that
SOC Attachment B constituents are less than
their respective 02B standards and that flows
TDS(mg/L) 500 729 from the minor area of seepage have no
detected influence on water quality within
the Cape Fear River.
August 2022 Page 3-2
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Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
Seep 02B
Constituent Concentration Additional Information
Locations Standard
No human health or aquatic life concern with
Hardness(mg/L) 100 1280 increased hardness.The water hardness
standard is an aesthetic standard.
Total Arsenic(µg/L) 10 15.9
Dissolved Arsenic 150 162
(µg/L)
S-16 Dissolved Arsenic
(includes 150 162 Instream monitoring in the Cape Fear River
potential
(µg/L) downstream of the Site seep discharges
flow Nickel(µg/L) 25 174 (Downstream Cape Fear River)indicates that
contribution SOC Attachment B constituents are less than
from S 18) Dissolved Nickel 168 181 their respective 02B standards and that flows
(µg/L) from the minor area of seepage have no
detected influence on water quality within
Sulfate(mg/L) 250 1400 the Cape Fear River.
TDS(mg/L) 500 2190
Dissolved Zinc 382 386
(µg/L)
Notes:
ug/L—micrograms per liter
mg/L—milligrams per liter
TDS—total dissolved solids
3.3 Ash Basin Closure and Corrective Action
Duke Energy continues to implement ash basin closure and corrective action activities that
provide seep management by the reduction in hydraulic head in upgradient areas and
reduction in source contribution, plus surface water protection at the Site. Completed, ongoing,
and planned corrective action and closure activities include:
Year Closure or Corrective Action Activity
2017-2019 1978 and 1985 ash basins decanting
2019-ongoing 1978 and 1985 ash basins dewatering
December 2020 Excavation of 1985 ash basin began and is ongoing
September 2021 Excavation of 1956 ash basin began and is ongoing
Fall 2022 Excavation of the 1963/1970 ash basins is planned to begin
2022 Submit Groundwater Corrective Action Plan Update
2020—2029 Dewatering,excavation,and closure of the ash basins
3.4 Mann-Kendall Trend Test Analysis
The Mann-Kendall trend test (Appendix B) was performed to analyze how constituent
concentrations at seep locations have changed over time. The Mann-Kendall trend test
August 2022 Page 3-3
Project:00.0060.17
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Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
evaluates data over time to develop a statistical conclusion that pertains to trends —
increasing, decreasing, or stable — of a constituent concentration.Trend analysis results and
time versus concentration plots for all parameters outlined in the SOC are presented in
Appendix B.Trend analysis results for constituents greater than 02B standards are presented
below.
Mann-Kendall trend test results for non-dispositioned seeps associated with the ash basins
were evaluated. Results of the Mann-Kendall trend test indicate the following:
• Arsenic (total concentration)—Trends could not be analyzed for arsenic in two of four
non-dispositioned seeps (S-07 and S-08) due to greater than 50 percent non-detects of
arsenic concentrations. No trends were identified in two out of four seeps (5-15 and
S-16). No identified trends are indicative of generally stable conditions.
• Total hardness—Statistically significant increasing trend for total hardness was
identified in one seep (S-15). No trends were identified in three seeps (S-07, S-08, and
S-16). No identified trends are indicative of generally stable conditions.
• Nickel -Statistically significant increasing trend for nickel was identified in one seep
(S-08). No trends were identified in three seeps (5-07, 5-15, and S-16). No identified
trends are indicative of generally stable conditions.
• Sulfate -Statistically significant decreasing trend for sulfate was identified in one seep
(S-16). No trends were identified in three seeps (S-07, 5-08, and S-15). No identified
trends are indicative of generally stable conditions.
• Total Dissolved Solids (TDS) -Statistically significant decreasing trend for TDS was
identified in one seep (S-16). No trends were identified in three seeps (5-07, S-08, and
S-15). No identified trends are indicative of generally stable conditions.
Overall, the results of the Mann-Kendall trend test indicate that the system has been
geochemically stable since the implementation of ash basin closure with constituent
concentrations remaining stable or decreasing over time.The Mann-Kendall Trend Test
Analysis report is provided in Appendix B.
3.5 Seep Corrective Action Strategy
To be considered for corrective action, a seep must:
1) Be non-dispositioned
2) Constitute, or flow to WOS or WOTUS
3) Exhibit constituent concentrations that are greater than applicable 02B surface water
standards
August 2022 Page 3-4
Project:00.0060.17
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Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress,LLC
Moncure, North Carolina
Five non-constructed seeps have been identified based on the criteria above. Based on findings
from Seep Characterization Report (SynTerra, 2022), the following corrective action strategies
are planned to manage the remaining non-dispositioned seeps.
Seep Corrective Action Strategy
1963 Ash Basin
Closure of the 1963 ash basin to reduce the source of CCR constituents in the seep.Additional
S-15 corrective action for this location is not anticipated. Excavation of the 1963 ash basin is planned
for Fall 2022.
Closure of the 1963 ash basin to reduce the source of CCR constituents in the seeps.These seeps
are currently being addressed with a treatment system that captures flow from those seeps as
S 16/5 18 well as S-17 and S-19.Additional corrective action for this location is not anticipated. Excavation
of the 1963 ash basin is planned for Fall 2022.
1985 Ash Basin
1985 ash basin excavation to reduce the source of CCR constituents at these locations.
5-07 and S-08 Additional corrective action for these locations is not anticipated. Excavation of the 1985 ash
basin began in September 2020.
As described in Section 3.3, ash basin closure and corrective action activities are underway or
planned. Based on those activities and the findings presented in the Seep Characterization
Report (SynTerra, 2022) and in this Seep Management Plan, with DWR concurrence on seep
dispositional status, corrective action beyond the planned closure activities may not be
necessary.
3.6 Seep Monitoring
Non-dispositioned seeps are scheduled to be monitored as required by the SOC until
termination of the SOC by DWR, or no later than August 31, 2023. Upon termination of the SOC,
continued (effectiveness) monitoring of remaining, non-dispositioned seep locations is
recommended until closure of the associated ash basin is complete, or until a seep is dry for
two consecutive sampling events, or sample data from two consecutive sampling events
indicate ash basin COI concentrations are less than 02B standards. Seeps would be monitored
on a semiannual basis consistent with the nearby groundwater monitoring network to correlate
changing water quality and geochemical conditions. Seeps would be analyzed for constituents
within the approved groundwater interim monitoring plan (IMP). It is anticipated that seep
monitoring would be discussed and new data would be evaluated in Annual Groundwater and
Surface Water Monitoring Reports.
August 2022 Page 3-5
Project:00.0060.17
Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
4.0 REFERENCES
NCDEQ(2020).Special Order by Consent EMC SOC WQ 519-001. North Carolina Department of
Environmental Quality. Charlotte, NC.January 27, 2020.
SynTerra (2015). Comprehensive Site Assessment Report—Cape Fear Steam Electric Plant,
September 2015.
SynTerra (2015). Corrective Action Plan Part 1 —Cape Fear Steam Electric Plant, December 2015.
SynTerra (2016). Corrective Action Plan Part 2—Cape Fear Steam Electric Plant, February 2016.
SynTerra (2016). Comprehensive Site Assessment Supplement 1 —Cape Fear Steam Electric
Plant, September 2016.
SynTerra (2020). Surface Water Evaluation to Assess 15A NCAC 02B .0200 Compliance for
Implementation of Corrective Action Under 15A NCAC 02L.0106 (k) and (I)—SynTerra,
February 2020
SynTerra (2020). Comprehensive Site Assessment Update—Cape Fear Steam Electric Plant,
December 2020.
SynTerra (2021). 2020 Annual Seep Report, Cape Fear Steam Electric Plant—SynTerra, April
2021.
SynTerra (2022). 2021 Annual Seep Report, Cape Fear Steam Electric Plant—SynTerra, April
2022.
SynTerra (2022). 2022 Final Seep Report—Cape Fear Steam Electric Plant. April 2022.
SynTerra (2022). Seep Characterization Report—Cape Fear Steam Electric Plant,June 2022.
August 2022 Page 4-1
Project:00.0060.17
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Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
FIGURES
s y Te rra
Science & Engineering Consultants
t
.
t
DEEP RIVER 1956 ASH BASIN
n ♦. WASTE BOUNDARY
• I
-( / •$' FORMER COAL PILE AREA
I
$s . �t ' 1985ASHBASIN a
I WASTE BOUNDARY
FORMER PRODUCTION AREA • w- •-..,
• Iic
I ••1
� ` ASH BASIN
`. /COMPLIANCE BOUNDARY
• •
1963 ASH BASIN • ,•
WASTE BOUNDARY / • `�;��\\
• • ' SASH BENEFICIATION PLANT
• • ♦ .
1970 ASH BASIN_' ♦ 1978 •
ASH BASIN
WASTE BOUNDARY •f- WASTE BOUNDARY
t•••V DUKE ENERGY PROGRESS
' •. .. .. PROPERTY BOUNDARY
-; `_.
• 1
I ■
ii
•/ .
. �
• ,...".. • ,
`•j•. • .
•N \\ •
•
"
• ••
1\it tt •.. .. /
NOTES: �•
`,
1.WATER FEATURES DEPICTED WITHIN WASTE BOUNDARIES OF THE ASH BASINS ON THE ♦•
2019 USGS TOPOGRAPHIC MAP DO NOT REPRESENT CURRENT CONDITIONS. /
2.2019 USGS TOPOGRAPHIC MAP,MONCURE QUADRANGLE,USGS ID:35079-E1 OBTAINED •
FROM THE USGS NATIONAL MAP VIEWER AT •
https://viewer.nationalmap.gov/basiC/. X •
f'DUKE CHATHAM FIGURE 1-1
e ENERGY COUNTY SILA LAMENON MAP
SEEP MANAGEMENT PLAN AMENDMENT TO THE CORRECTIVE
PROGRESS 0, WINSTON-SALEM MICRACTION PLANCAPE FEAR STEAM PLANT
RALEIGN
1 0 'N,
�= AM . • . MONCURE,NORTH ELECTRIC L
• 111111
CHARLOTTE�� � DRAWN BY:C.DAVIS DATE 05/02/2019 GRAPHIC SCALE
REVISED BY:L FOREMAN DATE 07/29/2022 loco o i000 2 000
A y.,,,.1Ten..� I ) CHECKED BVE.YURKOICH DATE 07/29/2022
,�f ' �-•�rd APPROVED BY:E.VURKOVICH DATE 07/29/2022 ON FEET)
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'I ; /:,
I ,
•
a-
fl °' LEGEND
,
-. ,. •—� .. ..4,q, • NON-CONSTRUCTED SEEP
`� 'i C, _ - • DISPOSITIONED SEEP
- -
4' •y'+ :" ", ,.- 17 SOC SAMPLE LOCATION(APPROXIMATE)
I (I
1 : / FORMER COOLING WATER - -� .� ®SPECIAL ORDER BY CONSENT(SOC)INSPECTION AREA
' "' .., EFFLUENT CHANNEL "`_': „' . _>. ., ASH BASIN WASTE BOUNDARY
e -;�,.` • DUKE ENERGY PROGRESS PROPERTY BOUNDARY
(
i .� = - :" WETLAND(AMEC NRTR)
-Y- DITCH(AMEC NRTR)
1 ., - 1 w" Cry....' t"'^ E•45 ': . -!~ STREAM(AMEC NRTR)
•
I - M ES.
- ,"•:-.?, S-11 rr 1.SEEP LOCATIONS ARE APPROXIMATE AND ARE DESCRIBED IN SPECIAL ORDER BY
• { 'T J • `, - `• 2 .I • CONSENT EMC SOC WO S14U01.
i. l- I , \ .. u • ', �.. .../ I 2.SOC-SPECIAL ORDER BY CONSENT
% _ -- • 3.THE WATERS OF THE US DELINEATION HAS NOT BEEN APPROVED BY THE
HI All{ f_I - US ARMY CORPS OF ENGINEERS AT THE THE OF THE MAP CREATNSTHESMAP IS
• 1 '''.*,,, ' HII/(l:ei I.a I ;" WETLAND USEDFOR JURISOICTIONIE WEREINTINEPFRO ST THE
N ) - -' �`�.`_• WETLANDS AND STREAMS BOUNDARIES WERE OBTAINED FROM STREAM AND
'., - r- ' \ WETLAND DELINEATION CONDUCTED BY AMEC FOSTER WHEELER ENVIRONMENTAL
till • AND INFRASTRUCTURE,INC.MAY 2015.
t: 'I .• .
`. - - a.ALL BOUNDARIES ARE APPROXIMATE.
, ,,, 1,' 5.CAPE FEAR PLANT PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY
r 1`` ' 11 if/T l F HAW, PROGRESS.
\-\••..• �•.J •`. i--`--J 8.AERIAL PHOTOGRAPHY OBTAINED FROM GOGGLE EARTH PRO ON MAY 21.2018.
` ) • ! AERIAL WAS COLLECTED ON FEBRUARY 1B,2018.
_ ;, •,., (,if`IEAR ~ . ,. I.DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE
- -,- 7 IIIVLi2 .r - v .,<ci i LANE COORDINATE SYSTEM FOPS J2G0(NAD83).
c DUKE GRAPHIC SCALE FIGURE 2-1
T�ENERGY vs a [ 425 EXISTING SEEP LOCATIONS AND INSPECTION AREAS
PROGRESS SEEP MANAGEMENT PLAN AMENDMENT TO THE
• DATE O1/2B�n2 MONCURE,NORTH CAROLINA
T
PRAWN BYB MCGANN 001 CORRECTIVE ACTION PLAN
syr� REVISED
Ea nee L.
FOREMAN
DATE. CAPE FEAR STEAM ELECTRIC PLAN
MANAGER ERICH R O C
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•
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_
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I IEi
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t
I ; j
r
�, , t__.: LEGEND
\ ® DISPOSITIONED SEEP
t • O NON-CONSTRUCTED SEEP
Eri SOC SAMPLE LOCATION(APPROXIMATE)
i _-- __ • -'- ASH BASIN WASTE BOUNDARY
i —- DUKE ENERGY PROGRESS PROPERTY BOUNDARY
WETLAND(AMEC NRTR)
- -►- DITCH(AMEC NRTR)
{ -- 1 —0— STREAM(AMEC NRTR)
. I`-„ NOTES.
•
J ' I 1.SEEP LOCATIONS ARE APPROXIMATE AND ARE DESCRIBED IN SPECIAL ORDER BY
•• .\ CONSENT EMC SOC WO S19-001.
e
• - Y" „5 "' 2.SOC•SPECIAL ORDER BY CONSENT
3.
I
1 U ARRAYHE CORS PS THE USIEERNATTIHNE TIME
NOOF THE N THE MAP RDVEO THIS
Y THE
I a L�I NOT ARMY SED OF JURISDICTIONAL
DETERMINATION CREATION.
HE MAP IS
•� NOTLA D USEDNDFOR AISIBOUNDA IE WERE PURPOSES.OBTAINETHE
i—' \ WETLANDS STREAMS BOU B WERE OFOSTER FEEL STREAM ENVIRONMENTAL
- •• � WETLAND DELINEATION CONDUCTED BY AMEC FOSTER WHEELER ENNRONMENTr3L
•• -��- ��� „ ::- -� AND INFRASTRUCTURE,INC.MAV 2015.
a.ALL BOUNDARIES ARE APPROXIMATE.
1 I AP,,I..1 R) 5.CAPE FEAR PLANT PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY
,\ - l •� PROGRESS.
.�...
-• DOWNSTREAM •.` .• ,a- 6.AERIAL PHOTOGRAPHY OBTAINED FROM GOGGLE EARTH PRO ON MAY 21.2018.
\ CAPE FEAR ".• •'� "` „„„,,;:w AERIAL WAS COLLECTEOON FEBRUARY 18.2m B.
RIVER "•..
• • ._ TUS COO DINBEES SYSTEM
WITHSA PROJECTION OF NORTH CAROLINA STATE
PLANE COORDINATE SYSTEM MS 32001NAD83).
n DUKE RAPHICSCALE FIGURE 3-1
ENERGY <_ — u„rEErI Two PROPOSED SEEP DISPOSITIONAL STATUS AND
PROGRESS LOCATIONS
- DRAWN BY B MCWNN wneOS,w/AO.0 SEEP MANAGEMENT PLAN AMENDMENT TO THE
ECKE99..LYURAwIw DATEo/2Tiso» CORRECTIVEACTION
KM.BY LFOREMar• DM omno22 PLAN
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9I9ASN I
•l- EASW 1 y.' ++ • SEEPS WITH STABLE BORON CONCENTRATION TREND
i ( ^`- • SEEPS WITH DECREASING BORON CONCENTRATION TREND
FORMER COOLING WATER ( APPROXIMATE EXTENT OF AFFECTED GROUNDWATERAFLUENT CHANNEL I : I. ASH BASIN WASTE BOUNDARY
•I • • DUKE ENERGY PROGRESS PROPERTYBOUNDARY
- -- DITCH(AMEC NRTR)
•1 , a - STREAM(AMEC NRTR)
•
5UDJ `. NOTES
((([^^^ 1.SEEP LOCATIONS ARE APPROXIMATE AND ARE DESCRIBED IN SPECIAL ORDER BY
• CONSENT EMC SOC WO S19-001.
•.
/ 2.THE WATERS OF THE US DELINEATION HAS NOT BEEN APPROVED BY THE
• r � IUS ARMY CORPS OF ENGINEERS AT THE TIME OF THE MAP CREATION.THIS MAP IS
\ ' \ _ _ NOT TO BE USED FOR JURISDICTIONAL DETERMINATION PURPOSES.THE
• _ _ 1 WETLANDS AND STREAMS BOUNDARIES WERE FOSTER OFROM STREAM AND
/ - - \ AND INFOSTRUCTTION CON DUCTED BY AMEC FOSTERWHEELERENWRONMENTAL
•\ • \ i•�` I. AND INFRASTRUCTURE,INC.MAY 2015.
�... \ *� 3.ALL BOUNDARIES ARE APPROXIMATE.
_ •.CAPE FEAR PLANT PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY
e'\ •' •-, • PROGRESS.
5.AERIAL PHOTOGRAPHY OBTAINED FROM GOOGLE EARTH PRO ON MAY 21,2018.
•3. \ • '• 3 AERIAL WAS COLLECTED ON FEBRUARY 18.2018
`
8.DRAWING HAS BEEN SET WITH A PROJECTION OF NORM CAROLINA STATE
PLANE COORDINATE SYSTEM FIRS 3200(NAD83).
\ T.EXTENT OF AFFECTED GROUNDWATER BASED ON BORON CENTRAL TENDENCY
'��• VALUES OF THE DATA SET BETWEEN FEBRUARY 2019 AND MAY 2020.DATA WERE
y3 PRESENTED IN THE 2020 COMPREHENSIVE SITE ASSESSMENT UPDATE ISYNTERRA.
2020).
'DUKE GRAPHIC SCALE
A2s aTs 9so FIGURE 3-2
ENERGY CONCEPTUAL SITE MODEL-BORON
PROGRESS �D� SEEP MANAGEMENT PLAN AMENDMENT TO THE
DRAENSEDDV LW u EFOREMAN W MCGANN E'D/29/1919
E:7/29/2022 CORRECTIVE ACTION PLAN
alECNED RV ""RoacH DAM ov2s 2022 CAPE FEAR STEAM ELECTRIC PLANT
APPROVED vUNO. DATE OT/29/M22
synT d PROJECT MANAGER.ETANCYCH MONCURE,NORTH CAROLINA
wsynterraCOrD.EOm
Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
TABLES
•
synTena
Science& Engineering Consultants
' TABLE 2-1
SEEP STATUS SUMMARY
SEEP MANAGEMENT PLAN AMENDMENT TO THE CORRECTIVE ACTION PLAN
CAPE FEAR STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS,LLC,MONCURE,NC
Associated Receiving Seep Source Area Waterbody Description•#* SOC Monitoring
Intermittent seep in grassy area northwest of 1985 ash basin.Any flow
S-01** 1985 Ash Basin Shaddox Creek drains to former stormwater pipe with outfall to the north of the power Dispositioned per SOC
line right of way.Flows to Shaddox Creek.
Seepage around former sluice pipes at northwest corner of 1985 ash Dispositioned per SOC
S-02** 1985 Ash Basin Shaddox Creek basin.Area has been repaired and the seep has been dispositioned. P
Low volume,intermittent seep to flat,grassy area between northwest
5-03** 1985 Ash Basin Shaddox Creek end of 1985 ash basin and CP&L Drive.Flow drains toward S-01,and Dispositioned per SOC
from there to Shaddox Creek.
Unnamed tributary to Seep from the base of the north side of the 1985 ash basin.Seep flows Proposed to be
S-04 1985 Ash Basin Pdispositioned
Shaddox Creek into an unnamed tributary to Shaddox Creek.
Discharge from French drain collection system located north of 1978
Effluent channel flowing to ash basin.Discharge is to a ditch flowing east to the NPDES permit Proposed to be dispositioned
S-OS 1978 Ash Basin NPDES permit outfall 007 effluent channel.This non-constructed seep flows to a portion of the P p
NPDES wastewater treatment system.
Two small seeps located along the western bank of the canal by the
5-06•• 1978 Ash Basin Effluent channel flowing to 1978 ash basin where rip rap has been placed.Flows to NPDES permit Dispositioned per SOC
NPDES permit outfall 007 effluent channel(outfall 007).This non-constructed seep flows to a
portion of the NPDES wastewater treatment system.
Location of discharge from stormwater pipes collecting seepage along
Effluent channel flowing to west side of the 1985 ash basin.Discharge from pipes is to a marshy
S-07 1985 Ash Basin NPDES permit outfall 007 area with drainage to NPDES permit effluent channel.This non- Non-dispositioned
constructed seep flows to a portion of the NPDES wastewater
treatment system.
Discharge from canal collecting flow from seeps and low-lying areas on
Effluent channel flowing to the southwest side of the 1985 ash basin.Discharge is to the NPDES Non-dispositioned
S-08 1985 Ash Basin NPDES permit outfall 007 P
permit effluent channel.This non-constructed seep flows to a portion of
the NPDES wastewater treatment system.
Intermittent seep in low-lying area southwest of the 1985 ash basin.
Unnamed tributary to Cape
S-09 1985 Ash Basin Flow drains towards a wetland area with drainage to an unnamed Proposed to be dispositioned
Fear River
tributary to the Cape Fear River.
Stagnant area of wetness at base of southeast corner of the 1985 ash
5-10** 1985 Ash Basin Unnamed tributary to Cape basin.Collected seepage and runoff would flow from depression to a Dispositioned per SOC
Fear River wetland area with drainage to an unnamed tributary to the Cape Fear
River.
Small seep in riprapped depression adjacent to a stormwater outfall.
Effluent channel flowing Any flow would be towards a shallow ditch to the NPDES permit
5-11** 1985 Ash Basin Dispositioned per SOC
NPDES permit outfall 007 effluent channel.This non-constructed seep would flow to a portion of
the NPDES wastewater treatment system.
5-12* 1978 Ash Basin Wetlands Ponded seepage area downslope of the southeast corner of the 1978 Dispositioned per SOC
ash basin.From sampling results-No CCR Impacts
Seepage area in a circular depression downslope of the southwest
5-13** 1978 Ash Basin Wetlands corner of the 1978 ash basin and the southeast side of the 1970 ash Dispositioned per SOC
basin.Drainage flows to the southeast.
5-14•' 1970 Ash Basin Unnamed tributary to Cape Seep to a small depression in flat area south of the 1970 ash basin.Area Dispositioned per SOC
Fear River is connected to a ditch flowing southwest to the Cape Fear River.
5-15 1963 Ash Basin Cape Fear River Seep from the west side of the 1963 ash basin,emerging beyond lower Non-dispositioned
access road and flowing to the Cape Fear River.
Seep adjacent to the Cape Fear River near the northwest corner of the S-16 1963 Ash Basin Cape Fear River Non-dispositioned
1963 ash basin.Flow is treated prior to discharge to the river via pipe.
Area of wetness adjacent to the Cape Fear River near the northwest
S-17 1963 Ash Basin Cape Fear River Proposed to be dispositioned
corner of the 1963 ash basin.
Page 1 of 2
' TABLE 2-1
SEEP STATUS SUMMARY
SEEP MANAGEMENT PLAN AMENDMENT TO THE CORRECTIVE ACTION PLAN
CAPE FEAR STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS,LLC,MONCURE,NC
Seep Associated Receiving Description*" SOC Monitoring
Source Area Waterbody
Low flow seep adjacent to the Cape Fear River near the northwest
S-18 1963 Ash Basin Cape Fear River corner of the 1963 ash basin.Flow is treated prior to discharge into the Non-dispositioned
river via pipe.
Area of wetness adjacent to the Cape Fear River near the northwest
S-19 1963 Ash Basin Cape Fear River Proposed to be dispositioned
corner of the 1963 ash basin.
S-20 1956 Ash Basin Haw River Area of wetness at the river bank of the Flaw River downslope from the Proposed to be dispositioned
northwest side of the 1956 ash basin.
5-21 1956 Ash Basin Haw River Area of wetness at the river bank of the Haw River downslope from the Proposed to be dispositioned
northwest side of the 1956 ash basin.
S-22 1956 Ash Basin Shaddox Creek Area of wetness at the creek bank of Shaddox Creek downslope from Proposed to be dispositioned
the north side of the 1956 ash basin.
Effluent channel flowing to An area along the toe of the west side of the 1985 ash basin where
5-23** Dispositioned Ash Basin NPDES permit outfall 007 storm water occasionally ponds and drains toward S-07. positioned per SOC
Prepared by:WI Checked by:CS
Notes;
•Location previously investigated as a seep.Monitoring has not indicated the presence of coal combustion residuals.
••Seep dispositioned via repair and/or non-flowing condition to potentially reach Waters of the U.5.,or other,as noted.
•••Some descriptions have been updated from the original text found in the SOC Attachment A table for accuracy and currency.
The information provided in this table,except for the"Notes From Inspection"column,was derived from Special Order by Consent WO 519-001 Attachment A.
NA-not applicable
NPDES-National Pollutant Discharge Elimination System
SOC-Special Order by Consent
it
Page 2 of 2
TABLE 3-1
SEEP CHARACTERIZATION SAMPLING RESULTS-FEBRUARY 2022
SEEP MANAGEMENT PLAN AMENDMENT TO THE CORRECTIVE ACTION PLAN
CAPE FEAR STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS,LLC,MONCURE,NC
Field Parameters Total Concentration
Specific Dissolved Oxidation
Analytical Parameter pH Temperature Reduction Turbidity' Arsenic Barium Boron' Bromide Cadmium Calcium Chloride Chromium Copper Fluoride Hardness
Conductance Oxygen' Potential
Reporting Units 5.U. DegC µmhos/cm mg/L mV NTUs pg/L pg/L pg/L mg/L pg/L mg/L mg/L pg/L pg/L mg/L mg/L
15A NCAC 02B(Class B,WS-IV) 100
Sample Sample
Location ID MediaLatitude longitude Collection Analytical Results
Date
UT Cape Fear River#1 Water 3558330 -79.03750 2/15/2022 6.2 9 137 8.44 114 42.3 <1 61 82 <0.5 <0.1 6.19 15 1.19 4.14 <0.5 28.6
UT Cape Fear River#2 Water 35.58250 -79.04000 2/15/2022 7.0 10 410 13.51 117 16.3 <1 13 1060 0.53 <0.1 32.5 13 <1 <2 <0.5 145 1
Downstream Cape Fear River Water 3558056 -79.04861 2/15/2022 7.5 8 170 12.07 16 16 <1 23 <50 0.12 <0.1 8.69 22 <1 s <2 <0.1 35.9
Upstream Haw River Water 35.60194 -79.05028 2/15/2022 7.5 7 204 12.29 55 19.1 <1 27 <50 0.21 <0.1 9.25 31 <1 <2 <0.1 37.6
Upstream Deep River Water 35.59722 -79.05472 2/15/2022 7.5 9 125 11.55 53 19.0 <1 19 <50 <0.1 <0.1 7.9 13 <1 2.16 <0.1 33.1
Upstream Shaddox Creek Water 35.59611 -79.04389 2/15/2022 6.5 7 175 6.59 102 46.7 <1 48 <50 0.11 <0.1 9.25 30 <1 <2 <0.1 37.5
Downstream Shaddox Creek Water 35.59917 -79.05000 2/15/2022 7.3 7 200 11.07 56 22 <1 30 <50 0.2 <0.1 9.19 31 <1 <2 <0.1 37.5
5-07 Water 35.58993 -79.04357 2/16/2022 7.0 7 728 5.61 122 14.3 <1 14 6460 2 <0.1 65.3 22 <1 <2 <0.5 302
5-08 Water 35.58585 -79.04267 2/16/2022 7.2 6 527 14.81 125 4.4 <1 54 3180 1 <0.1 42.2 16 <1 5.2 <0.5 207
5-15 Water 35.58889 -79.05137 2/15/2022 7.0 15 1049 5.61 124 17.7 86 1330 1A <0.1 119 35 <1 <2 <0.5 416
S-16 Water 35.59039 -79.05142 2/15/2022 6.5 13 1890 6.15 -13 4.8 21 739 <2 0.783 411 4.6 <1 <2 <2
Notes:
_ -Blue highlighted cells indicate concentration greater than applicable conservative 15 NCAC 02B(Class B,WS-IV)standards.
15A NCAC 02B(Class 8,WS-IV)-15A NCAC Subchatpter 02B Section.0200 Standard for Class B,WS-IV Surface Waters
'Dissolved oxygen and turbidity are not required parameters per SOC Attachment B.
'Boron and Thallium standards represent in-stream target values.
'Mercury standard of 0.012 pg/L represents a chronic value.
'Selenium standard of 5 pg/L represents a chronic value.
'Dissolved arsenic standard of 150 pg/L represents a chronic value.
'Dissolved chromium standard of 11 µg/L represents a chronic value specific to dissolved chromium(VI).Dissolved chromium(III)standards are hardness-dependent and presented in the seep characterization report.Dissolved chromium concentrations from the February 2022 sampling event represent total dissolved chromium concentrations.
<-Concentration not detected at or greater than the adjusted reporting limit.
pg/L-micrograms per liter NA-not available or not analyzed
µmhos/cm-mkromhos per centimeter NCAC-North Carolina Administrative Code
Deg C-degrees Celsius NE-not established
Ex-oxidation reduction potential NM-not measured
HD-Hardness-dependent calculated standard(see Table 3) ng/L-nanograms per liter
M-Matrix spike/matrix spike dup failure. NTU-Nephelometric Turbidity Units
mg/L-milligrams per liter S.U.-standard units
mg-N/L-milligrams nitrogen per liter 50C-Special Order by Consent -
Page 1 of 2
TABLE 3-1
SEEP CHARACTERIZATION SAMPLING RESULTS-FEBRUARY 2022
SEEP MANAGEMENT PLAN AMENDMENT TO THE CORRECTIVE ACTION PLAN
CAPE FEAR STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS,LLC,MONCURE,NC
Total Concentration(Continued) Dissolved Concentration
Total Total Arsenics Cadmium Chromium' Copper Lead Nickel Zinc
Analytical Parameter Lead Magnesium Mercury' Nickel Nitrate., Oil and Selenium° Sulfate Thallium' Dissolved Suspended Zinc
Nitrite Grease Solids Solids (0.45µ) (0.45p) (0.45p) (0.45p) (0.45µ) (0.45p) (0.45µ)
l Reporting Units pg/L mg/L ng/L RA mg-N/L mg/L pg/L mg/L pg/L mg/L mg/L pg/L pg/L pg/L µg/L pg/L µg/L µg/L pg/L
15ANCAC 028(Class c,W5-IV) ' •.jA: :;, rn
Sample Sample
Location ID Media Latitude Longitude Collection Analytical Results
Date
,UT Cape Fear River#1 Water 35.58330 -79.03750 2/15/2022 1.46 3.18 7.7 3.12 0.62 M <5 <1 23 <0.2 116 17 193 <1 <0.1 <1 <2 <0.2 1.67 8.74
UT Cape Fear River#2 Water 35.58250 -79.04000 2/15/2022 <0.2 15.4 1 1.58 <0.02 <5 <1 130 <0.2 301 5 <5 <1 <0.1 <1 <2 <0.2 1.48 <5
Downstream Cape Fear River Water 35.58056 -79.04861 2/15/2022 0A36 3.44 2.38 <1 0.55 <5 <1 10 <0.2 115 7.1 <5 <1 <0.1 <1 <2 <0.2 <1 <5 '
Upstream Haw River Water 35.60194 -79.05028 2/15/2022 0.395 3.53 1.85 1.12 0.45 <5 <1 13 <0.2 136 8.5 <5 <1 <0.1 <1 <2 <0.2 1 <5
Upstream Deep River Water 35.59722 -79.05472 2/15/2022 0.455 3.26 3.51 <1 0.63 <5 <1 7.7 <0.2 98 3.6 <5 <1 <0.1 <1 <2 <0.2 <1 <5
Upstream Shaddox Creek Water 35.59611 -79.04389 2/15/2022 0.931 3.49 4.82 1.15 0.17 <5 <1 13 <0.2 142 9 6.59 <1 <0.1 <1 <2 <0.2 <1 <5
-
Downstream Shaddox Creek Water 35.59917 -79.05000 2/15/2022 0.545 3.52 3.5 1.15 039 <5 <1 14 <0.2 128 12 5.23 <1 <0.1 <1 <2 <0.2 <1 <5
S-07 Water 35.58993 -79.04357 2/16/2022 <0.2 33.7 <0.5 4.73 0.07 <5 <1 1N4. <0.2 548 <2.5 <5 <1 <0.1 <1 <2 <0.2 4.71 <5 -
S-08 Water 35.58585 -79.04267 2/16/2022 <0.2 24.6 0.726 7.09 0.15 <5 <1 170 <0.2 394 <2.5 15.9 <1 <0.1 <1 3.38 <0.2 6.42 13.7
S-15 Water 35.58889 -79.05137 2/15/2022 <0.2 29.1 <0.5 4.53 0.05 <5 <1 230 <0.2 6.3 <5 22.1 <0.1 <1 <2 <0.2 4.07 <5
5-16 Water 35.59039 -79.05142 2/15/2022 <0.2 62.2 <0.5 - 0.03 <5 <1 _2.35 32 354 0.813 <1 <2 <0.2
Created by:RR Checked by c15
Notes:
-Blue highlighted cells indicate concentration greater than applicable conservative 15 NCAC 0213(Class B,WS-IV)standards.
154 NCAC 028(Class B,WS-IV)-154 NCAC 5ubchatpter 028 Section.0200 Standard for Class B,WS-IV Surface Waters
'Dissolved oxygen and turbidity are not required parameters per SOC Attachment B.
'Boron and Thallium standards represent in-stream target values.
'Mercury standard of 0.012 pg/L represents a chronic value.
'Selenium standard of 5 pg/L represents a chronic value.
'Dissolved arsenic standard of 150 pg/L represents a chronic value.
`Dissolved chromium standard of 11 pg/L represents a chronic value specific to dissolved chromium(VI).Dissolved chromium(III)standards are hardness-dependent and presented in the seep chacaterixation report.Dissolved chromium concentrations front the February 2022 sampling event represent total dissolved chromium concentrations.
<-Concentration not detected at or greater than the adjusted reporting limit
pg/L-micrograms per liter NA-not available or not analyzed
pmhos/cm-micromhos per centimeter NCAC-North Carolina Administrative Code
Deg C-degrees Celsius NE-not established
Ee-oxidation reduction potential NM-not measured
HD-Hardness-dependent calculated standard(see Table 3) ne/L-nanograms per liter
M-Matrix spike/matrix spike dup failure. NTU-Nephelometric Turbidity Units
mg/L-milligrams per liter S.U.-standard units
mg-N/L-milligrams nitrogen per liter SOC-Special Order by Consent
Page 2 of
Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
APPENDIX A
SOC WQ S19-001
411,
synTerra
Science & Engineering Consultants
ROY COOPER �Y `3
Governor
MICHAEL S. REGAN '
Secretary •�'"""
aw
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
January 27,2020
Mr.Paul Draovitch, Senior Vice President EHS
Duke Energy
526 S. Church Street
Mail Code EC3XP
Charlotte,NC 28202
Subject: SPECIAL ORDER BY CONSENT
SOC No. S19-001
Duke Energy Progress,LLC
Cape Fear Plant
NPDES Permit NC0003433
Chatham County
Dear Mr. Draovitch:
Attached for your records is a copy of the Special Order by Consent(SOC) approved by the
Environmental Management Commission and signed by the Director of the Division of Water
Resources on January 27, 2020.
The terms and conditions of the SOC are in full effect, including those requiring submittal of
written notice of compliance or non-compliance with any schedule date. The following items are
brought to your attention as they pertain to the terms and conditions of the SOC:
• upfrontpenalty is due no later than February28, 2020.
Payment of the e a
p tY
• Monitoring performed per the terms of the SOC shall commence during the current calendar
quarter(January -March),with results submitted to DWR no later than April 30,2020.
Subsequent monitoring and reporting shall occur as specified in the SOC.
• Submittal of the first quarterly progress report shall be due on April 30, 2020.
Pursuant to North Carolina General Statute 143-215.3D,water quality fees have been revised to
include an annual fee for activities covered under a Special Order by Consent. Duke Energy will
be subject to a fee of$500.00 on a yearly basis while under the Order. The initial fee payment
shall be paid no later than February 28,2020. Future annual fee invoicing will be done on an
annual basis along with the invoicing for other Duke Energy SOCs.� S, North Carolina Department of Environmental Quality I Division of Water Resources
�J1 512 North Salislwry Strut Ibl7 Mail Service Center I Raleigh North Carolina 27ti99 iM7
/'f 919.707.9000
Mr. Paul Draovitch
S 19-001 Transmittal
p. 2
If you have any questions concerning this matter, please contact Bob Sledge at(919) 707-3602.
Sincerely,
Linda Culpepper
Attachment
cc: SOC File
ec: Raleigh Regional Office—DWR/Water Quality Regional Operations
DWR Laserfiche Files
Shannon Langley—Duke Energy
Sara Janovitz—EPA Region 4
Jeff Poupart—DWR/WQPS
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF CHATHAM
IN THE MATTER OF )
NORTH CAROLINA ) SPECIAL ORDER BY CONSENT
NPDES PERMIT NC0003433 )
) EMC SOC WQ S19-001
HELD BY )
DUKE ENERGY PROGRESS,LLC )
Pursuant to the provisions of North Carolina General Statutes(G.S.) 143-215.2, this Special
Order by Consent covering seeps from the coal ash basins at the Cape Fear Facility,is entered
into by Duke Energy Progress, LLC,hereinafter referred to as Duke Energy, and the North
Carolina Environmental Management Commission, an agency of the State of North Carolina
created by G.S. 143B-282, and hereinafter referred to as the Commission. Duke Energy and the
Commission are referred to hereafter collectively as the"Parties."
1. Stipulations: Duke Energy and the Commission hereby stipulate the following:
a. This Special Order by Consent("Special Order")addresses issues related to the
elimination of seeps(as defined in subparagraphs e, f,and g below)from Duke
Energy's coal ash basins during the separate and independent process of basin
closure under the Coal Ash Management Act, G.S. 130A-309.200 through 130A-
309.231 ("CAMA") and the Federal Coal Combustion Residuals Rule,40 CFR
Parts 257 and 261. The Environmental Protection Agency first directed
permitting authorities to consider potential impacts on surface water of seeps from
earthen impoundments in 2010. At that time,Duke Energybegan dis
cussions
with the North Carolina Department of Environmental Quality("the
Department")regarding seeps at multiple Duke Energy facilities, including
identifying certain seeps in permit applications and providing data to the
Department regarding seeps. In 2014,Duke Energy provided a comprehensive
evaluation of all areas of wetness and formally applied for NPDES permit
coverage of all seeps. Since 2014, Duke Energy has performed periodic
inspections and promptly notified the Department of new seeps and sought
NPDES permit coverage where appropriate. On March 4, 2016,the Department
issued Notices of Violation("NOVs")to Duke Energy related to seeps.
EMC SOC WQ S 19-001
Duke Energy Progress, LLC
p. 2
Pursuant to CAMA,Duke Energy is required to decant and dewater its coal ash
basins as part of the closure process. Decanting(i.e.,removal of the free water on
the surface of the coal ash basin)has been completed at the Cape Fear Facility's
coal ash basins. Dewatering (i.e. removal of sufficient interstitial water) of the
Cape Fear Facility's coal ash basins will be required before the ash basins can be
closed. Removal of remaining coal ash wastewater through dewatering is
expected to substantially reduce or eliminate the seeps. In order to accomplish
this goal of substantially reducing or eliminating seeps, this Special Order affords
certain relief to Duke Energy related to the non-constructed seeps (as defined in
subparagraphs f and g below), while Duke Energy completes activities associated
with closure of the ash basins. After completion of dewatering activities for a set
period of time,for any remaining seeps, Duke Energy must take appropriate
corrective action as specified more fully below.
b. Duke Energy has been issued a North Carolina NPDES permit for operation of an
existing wastewater treatment works at the following, former, coal fired electric
generation facility:
Permit Issuance Receiving Water
Facility Number County Date for Primary
Outfall
Cape Fear NC0003433 Chatham 12/21/2018 Cape Fear River
c. All coal fired electric generation infrastructure has been removed from the Cape
Fear Facility and Duke Energy no longer conducts any generation of electricity at
the site. However, five ash basins exist upon its premises,making it subject to the
provisions of this Special Order.
d. Wastewater treated at coal-fired electric stations includes water mixed with ash
produced through the combustion of coal for the steam generation process. Ash is
controlled and collected through the use of water, creating a slurry that is
conveyed to impoundments or basins with earthen dike walls. In the ash basin,
the solids separate from the liquid portion,with the resulting supernatant
discharged under the terms of the NPDES permit.
EMC SOC WQ S19-OOl
Duke Energy Progress,LLC
p. 3
e. The coal ash basins at the Cape Fear Facility are unlined,having no impermeable
barrier installed along their floors or sides. Earthen basins and dike walls are
prone to the movement of liquid through porous features within those structures
through a process known as seepage. The Cape Fear Facility exhibits locations
adjacent to, but beyond the confines of,the coal ash basins where seepage of coal
ash wastewater from the coal ash basins may intermix with groundwater,reach
the land surface(or"daylight"), and may flow from that area. Once such seepage
reaches the land surface, it is referred to as a"seep." Each of the seeps identified
at the Cape Fear Facility and addressed in this Special Order exhibit some
indication of the presence of coal ash wastewater. Both(a)confirmed seeps and
(b)areas identified as potential seeps that were later dispositioned, are identified
in Attachment A.
f. Seeps that are not on or within the dam structure or that do not convey wastewater
via a pipe or constructed channel directly to a receiving stream are referred to as
"non-constructed seeps." Non-constructed seeps at the Cape Fear Facility often
exhibit low flow volume and may be both transient and seasonal in nature, and
may, for example,manifest as an area of wetness that does not flow to surface
waters, a point of origin of a stream feature, or flow to an existing stream feature.
These circumstances of the non-constructed seeps make them difficult to discern,
characterize, quantify and/or monitor as discrete point source discharges. This
creates challenges in permit development and compliance monitoring because it is
difficult to accurately monitor for flow and discharge characterization. Non-
constructed seeps at the Cape Fear Facility present significant challenges to their
inclusion in NPDES permits as point source discharges, but they do cause or
contribute to pollution of classified waters of the State. Therefore,these non-
constructed seeps are addressed in this Special Order rather than in an NPDES
permit.
g. A subset of these non-constructed seeps at the Cape Fear Facility do not flow
directly to surface waters, but flow to some portion of an NPDES permitted
wastewater treatment system. In such instances, the seeps may be referenced in
the NPDES permit as contributing flow to a permitted outfall. Any non-
constructed seep that falls within this subset is identified in Attachment A by the
following statement in its description: "This non-constructed seep flows to a
portion of an NPDES wastewater treatment system."
h. Investigations and observations conducted by the Department and U. S. Army
Corps of Engineers staff have concluded that some seeps emanating from Duke
Energy's coal ash basins create and/or flow into features delineated as classified
waters of the State or Waters of the United States.
EMC SOC WQ S19-001
Duke Energy Progress,LLC
p.4
j. Collectively,the volume of non-constructed seeps is generally low compared to
the volume of permitted wastewater discharges at the Cape Fear Facility.
k. In 2014,Duke Energy conducted a survey of each coal-fired electric generation
station to identify potential seeps from the coal ash surface impoundments. Duke
Energy included all areas of wetness identified around the impoundments as
seeps,and submitted applications to include those seeps in NPDES permits.
Beginning in 2015, Duke Energy has implemented semi-annual surveys to
identify new seeps in the vicinities of the coal ash basins. Additional seeps have
been observed and documented during these surveys and reported to the
Department pursuant to a Discharge Identification Plan mandated by CAMA.
Additional investigation has determined that not all of areas identified in 2014 are
seeps, but each Duke Energy facility does have multiple seeps.
1. The Department issued a NOV to Duke Energy on March 4, 2016 for the seeps
that emanate from the unlined coal ash surface impoundments at the Cape Fear
Facility.
m. Non-constructed seeps create conditions such that certain surface water quality
standards may not consistently be met at all Duke Energy monitoring sites.
n. The presence of coal ash influenced water in the non-constructed seeps causes or
contributes to pollution of the waters of this State, and Duke Energy is within the
jurisdiction of the Commission as set forth in G.S. Chapter 143,Article 21.
o. A list of seeps identified in the vicinities of the coal ash surface impoundments at
the Cape Fear Facility, as well as their locations, and the bodies of water those
seeps may flow into (if applicable), can be found in Attachment A to this Special
Order.
p. Duke Energy must close the coal ash surface impoundments at all North Carolina
coal-fired electric generating stations in accordance with applicable requirements
set out in CAMA and the Federal Coal Combustion Residuals Rule,requirements
of which are independent of the resolution of seeps addressed in this Special
Order.
q. Decanting and dewatering of wastewater performed at Duke Energy's coal ash
basins is expected to eliminate or substantially reduce the seeps from the ash
basins at the Cape Fear Facility.
r. Since this Special Order is by consent,the Parties acknowledge that review of the
same is not available to the Parties in the N.C. Office of Administrative Hearings.
Furthermore,neither party shall file a petition for judicial review concerning the
terms of this Special Order.
EMC SOC WQ S 19-001
Duke Energy Progress,LLC
P. 5
2. Duke Energy, desiring to resolve the matters causing or contributing to pollution of the
waters of the State described above,hereby agrees to do the following:
a. Penalties
1) Upfront Penalty. As settlement of all alleged violations due to seepage at
the Cape Fear Facility,pay the Department, by check payable to the North
Carolina Department of Environmental Quality, a penalty in the amount of
$48,000, calculated based upon$6,000 each for eight non-constructed
seeps identified prior to January 1, 2015.
A certified check in the amount of$48,000.00 must be made payable to
the Department of Environmental Quality and sent to the Director of the
Division of Water Resources(DWR)at 1617 Mail Service Center,
Raleigh, North Carolina 27699-1617 by no later than thirty (30)days
following the date on which this Special Order is approved and executed
by the Commission, and received by Duke Energy.
No penalty shall be assessed for seeps identified after December 31,2014,
given Duke Energy's inclusion of seeps in permit applications and
compliance with the Discharge Identification Plan required under CAMA.
By entering into this Special Order, Duke Energy makes no admission of
liability,violation or wrongdoing. Except as otherwise provided herein,'
payment of the upfront penalty does not absolve Duke Energy of its
responsibility for the occurrence or impacts of any unauthorized
discharges in the area of the Cape Fear Facility that may be discovered in
the future, nor does the payment preclude DWR from taking enforcement
action for additional violations of the State's environmental laws.
' See especially paragraph 2(a)2 excepting newly identified seeps from future penalties under
certain conditions.
EMC SOC WQ S 19-001
Duke Energy Progress,LLC
p. 6
2) Stipulated Penalties. Duke Energy agrees that unless excused under
paragraph 5, Duke Energy will pay the Department,by check payable to
the North Carolina Department of Environmental Quality, stipulated
penalties according to the following schedule for failure to perform
activities described in paragraphs 2(b and c), or for failure to comply with
interim action levels listed in Attachment A.
Failure to meet a deadline in the Compliance $1,000.00/day for the first seven
Schedule in 2(b) of this Special Order days; $2,000.00/day thereafter
Failure to meet any other deadline in this $1,000.00/day for the first seven
Special Order days; $2,000.00/day thereafter
Exceedance of an interim action level listed in $4,500.00 per monitored exceedance
Attachment A
Monitoring frequency violations $1,000.00 per violation
Failure to submit, by the deadline set forth
herein,adequate amendments to groundwater
Corrective Action Plans or Closure Plans to $5,000.00 per day,to a maximum of
address all remaining seeps,through $1,000,000.00 per electric generating
corrective action as applicable under facility.
paragraph 2(b)(7) of this Special Order.2
As long as Duke Energy remains in compliance with the terms of this
Special Order,as well as CAMA and conditions of any approvals issued
thereunder,the Department shall not assess civil penalties for newly
identified seeps.
b. Compliance Schedule. Duke Energy shall undertake the following activities in
accordance with the indicated time schedule. No later than fourteen(14) calendar
days after any date identified for accomplishment of any activity, Duke Energy
shall submit to the Director of DWR written notice of compliance or
noncompliance therewith. In the case of compliance, the notice shall include the
date compliance was achieved along with supporting documentation if applicable.
In the case of noncompliance,the notice shall include a statement of the reason(s)
for noncompliance,remedial action(s)taken, and a statement identifying the
extent to which subsequent dates or times for accomplishment of listed activities
may be affected.
2 Failure to adequately implement any amended Corrective Action Plan or Closure Plan will be
handled in the normal course.
EMC SOC WQ S 19-001
Duke Energy Progress,LLC
P. 7
Duke Energy is required to comply with the requirements of G.S. § 130A-
309.216. Duke Energy has announced plans to construct an ash beneficiation
plant at the Cape Fear Facility capable of processing 300,000 tons of CCR
material per year.
1) The Coal Ash Management Act(G.S. § 130A-309.210(b))prohibited the
disposal of CCR into the basins at Duke Energy facilities where coal-fired
generating units were no longer producing CCR as of October 1,2014.
The coal-fired generating units at the Cape Fear Facility were retired in
October 2012.
2) Duke Energy began decanting at the Cape Fear Facility in January 2017.
Decanting at the Cape Fear Facility has been effectively completed and
water levels are being maintained in the basins.
3) Removal of interstitial water will be required in order to excavate the ash
for the purpose of beneficiation at the Cape Fear Facility. Duke Energy
will begin the process of removal of interstitial water from at least one of
the ash basins at the Cape Fear Facility by January 31, 2020 and continue
as needed to support the beneficiation plant described above.
4) Once the dewatering process is initiated at the Cape Fear Facility, within
(30)days after the end of each quarter, Duke Energy shall provide reports
on the status of dewatering work and other activities undertaken with
respect to excavation of each coal ash surface impoundment to DWR. The
quarterly reports are due by April 30, July 30, October 30, and January 30.
The reports are to be submitted as follows: one copy must be mailed to
DWR's Raleigh Regional Office Supervisor, 3800 Barrett Drive,Raleigh
NC 27609, and one copy must be mailed to the Water Quality Permitting
Program, Division of Water Resources, 1617 Mail Service Center, Raleigh
NC 27699-1617. The quarterly reporting requirement shall remain in
force until completion of two years of beneficiation operations.
EMC SOC WQ S 19-001
Duke Energy Progress,LLC
P.9
7) If by the date specified in subparagraph(6)above for the Cape Fear
Facility, any seeps have not been certified by the Director of DWR as
dispositioned(as described in subparagraph (5)above), Duke Energy shall
conduct a characterization of those seeps.3 Duke Energy shall submit a
report on the findings of these characterizations ("Seep Characterization
Report")to the Director of DWR no later than June 30, 2022. The Seep
Characterization Report must include all sampling data for each remaining
seep as well as Duke Energy's evaluation of the jurisdictional status of all
seeps at the Cape Fear Facility. The determination regarding whether a
surface water feature is a classified water of the State rests with DWR.
No later than August 31, 2022 (60 days following the submittal of the
Seep Characterization Report for the Facility), Duke Energy shall submit a
complete and adequate proposed amendment to the groundwater
Corrective Action Plan and/or Closure Plan as appropriate for the Cape
Fear Facility describing how any seeps identified in the Seep
Characterization Report will be managed in a manner that will be
sufficient to protect public health, safety, and welfare,the environment,
and natural resources. This proposed amendment will go to public
comment. Duke Energy shall submit documentation that the proposed
modification has been submitted to the appropriate division within the
Department that has authority for approving modification of the
groundwater Corrective Action Plan and/or Closure Plan. The content of,
and DEQ's review of,an amendment to a groundwater Corrective Action
Plan shall be consistent with Title 15A, Chapter 2L of the N.C.
Administrative Code (specifically including 2L.0106(h)-(o)). The
amendment to the Corrective Action Plan and/or Closure Plan shall be
implemented by Duke Energy in accordance with the deadlines contained
therein,as approved or conditioned by the Department. Failure by Duke
Energy to implement the amendment will be handled in the normal course
by the Department in accordance with its enforcement procedures (i.e.,
outside this Special Order).
3 If any seep is dispositioned between the time that the Final Seep Report is submitted and the
time the Seep Characterization Report is submitted, an analysis of the manner of disposition
must be included in the Seep Characterization Report, and Duke Energy must seek certification
of such a disposition from the Director of DWR. Only if such certification is received prior to
the due date of the proposed amendment described in paragraph 2(b)(7)may such a seep,
certified as dispositioned,be omitted from the proposed amendment.
EMC SOC WQ S19-001
Duke Energy Progress,LLC
p. 10
8) Termination of Special Order
This Special Order shall terminate on the later of the following dates:
• Certification that all seeps have been eliminated.
• 30 days following the approval of an amended groundwater
Corrective Action Plan and/or Closure Plan as appropriate(if an
amendment is submitted in compliance with subparagraph(7)
above).
For clarity, listed below is a summary of the timetable for the documents due in
accordance with the terms of this Special Order:
Document Due Date
Final Seep Report April 30, 2022
Seep Characterization Report June 30, 2022
Proposed amendment to groundwater
Corrective Action Plan and/or Closure August 31, 2022
Plan
c. Interim Action Levels.
1) Duke Energy shall perform monitoring of waters receiving flow from non-
constructed seeps in accordance with the schedules listed in Attachments
A and B, except as noted in paragraph 2(c)(2) below.
2) If the monitoring of any classified water of the State receiving flow from
seeps regulated by this Special Order indicates exceedance of any interim
action level established by the Special Order, Duke Energy shall increase
monitoring at that location from quarterly to monthly until concentrations
of monitored characteristics return to those observed at the initiation of the
Special Order. If any interim action level established by the Special Order
is exceeded by more than 20%in a single sampling event, or exceeded for
two (2)consecutive monitoring events, in addition to paying the
associated stipulated penalty, Duke Energy shall conduct a re-assessment
of the contributing seep(s), including, but not limited to,evaluation of
proposed remedial actions for treatment and/or control of the seep such
that impacts to the receiving waters are quickly mitigated. A report
compiling the findings of the re-assessment, including proposed remedial
actions, shall be provided to the Director of DWR within 60 days of any
applicable exceedance. Following its review,DWR shall notify Duke
Energy of its concurrence or disapproval of Duke Energy's proposed
remedial actions.
•
EMC SOC WQ S 19-001
Duke Energy Progress, LLC
p. 11
3) Upon the complete execution of this Special Order,with regard to non-
constructed seeps, interim action levels for the receiving waters (which are
minor tributaries)are hereby established as noted in Attachment A. The
interim action levels are site-specific. Duke Energy shall monitor at
approved sampling sites to ensure interim action levels are met. Interim
action levels shall remain effective in the designated surface waters until
the applicable termination date in paragraph 2(b)(8)is reached.
4) Monitoring associated with seeps covered by this Special Order is exempt
from the electronic reporting requirements associated with NPDES
permits. Results of monitoring required exclusively per the terms of this
Special Order shall be reported to the Director of DWR in a
spreadsheet/worksheet format agreed to by Duke Energy and DWR.
Monitoring data shall be submitted to the Director of DWR in a digital
format no later than 30 days following the end of each calendar quarter for
as long as the Special Order is in effect. Monitoring data shall be sent to
the following email address: desocdata@ncdenr.gov. Data from those
sites with monitoring required exclusively per the terms of the Special
Order will be posted on DWR's website to provide the public with the
opportunity for viewing.
3. Duke Energy will continue to operate its coal ash surface impoundments in such a
manner that their performance is optimized, and potential for surface waters to be
affected by seeps is minimized.
4. Duke Energy shall make available on its external website the NPDES permits,this
Special Order and all reports required under this Special Order for the Cape Fear Facility
no later than thirty (30)days following their effective or submittal dates.
5. Duke Energy and the Commission agree that the stipulated penalties specified in
paragraph 2(a)(2) are not due if Duke Energy satisfies DWR that noncompliance was
caused solely by:
a. An act of God;
b. An act of war;
c. An intentional act or omission of a third party,but this defense shall not be
available if the act or omission is that of an employee or agent of Duke Energy or
if the act or omission occurs in connection with a contractual relationship with
Duke Energy;
a
EMC SOC WQ S 19-001
Duke Energy Progress,LLC
p. 12
d. An extraordinary event beyond the Duke Energy's control, specifically including
any court order staying the effectiveness of any necessary permit or approval.
Contractor delays or failure to obtain funding will not be considered as events
beyond Duke Energy's control; or
e. Any combination of the above causes.
6. Failure within thirty (30) days of receipt of written demand by DWR to pay the stipulated
penalties, or challenge them by a contested case petition pursuant to G.S. 150B-23,will
be grounds for a collection action, which the Attorney General is hereby authorized to
initiate. The only issue in such an action will be whether the thirty(30) days has elapsed.
7. Any non-constructed seeps causing or contributing to pollution of waters of the State
associated with the coal ash impoundments at Duke Energy's Cape Fear Facility, and
listed in Attachment A to this Special Order, are hereby deemed covered by this Special
Order. Any newly-identified non-constructed seeps discovered while this Special Order
is in effect, and timely reported to the Department per the terms of CAMA and this
Special Order, shall be deemed covered by the terms of the Special Order, retroactive to
the time of their discovery. Newly-identified non-constructed seeps must be sampled for
the presence of those characteristics listed in Attachment B to this Order. Newly-
identified non-constructed seeps found to be causing or contributing to pollution of the
waters of the State,with the effect of causing a violation of water quality standards in
surface waters not already referenced in the Special Order,may require modification of
the Special Order to address those circumstances.
8. Noncompliance with the terms of this Special Order is subject to enforcement action in
addition to the above stipulated penalties,including, but not limited to injunctive relief
pursuant to G.S. 143-215.6C or termination of this Special Order by the Director of DWR
upon ten(10)days' notice to Duke Energy. Noncompliance with the terms of this
Special Order will not be subject to civil penalties in addition to the above stipulated
penalties.
9. This Special Order and any terms or conditions contained herein,hereby supersede any
and all previous Special Orders, Enforcement Compliance Schedule Letters,terms,
conditions, and limits contained therein issued in connection with NPDES permit
NC0003433.
10. This Special Order may be modified at the Commission's discretion, provided the
Commission is satisfied that Duke Energy has made good faith efforts to secure funding,
complete all construction, and achieve compliance within the dates specified. In
accordance with applicable law, modification of this Special Order will go to public
notice prior to becoming effective.
11. Failure to pay the up-front penalty within thirty (30) days of execution of this Special
Order will terminate this Special Order.
EMC SOC WQ S 19-001
Duke Energy Progress,LLC
p. 13
12. In addition to any other applicable requirement,each report required to be submitted by
Duke Energy under this Special Order shall be signed by a plant manager or a corporate
official responsible for environmental management and compliance,and shall include the
following certification:
I certify under penalty of law that this document and all attachments
were prepared under my direction or supervision in accordance with
a system designed to assure that qualified personnel properly gather
and evaluate the information submitted. Based on my inquiry of the
person or persons who manage the system,or those persons directly
responsible for gathering the information,the information submitted
is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fine and
imprisonment for knowing violations.
13. This Special Order shall become effective in accordance with state law, and once
effective, Duke Energy shall comply with all schedule dates,terms, and conditions
herein.
EMC SOC WQ S 19-001
Duke Energy Progress,LLC
p. 14
This Special Order by Consent shall expire no later than August 31,2023.
For Duke Ener_ Progress, LLC:
�� -- t o/ c/t�
Pa Draovit • Date
Senior Vice President, Environmental,Health& Safety
For the North Carolina Environmental Management Commission:
r la? do, 0
Dr. A.'Stanley Meiburg, Chairman Date
NC Environmental Management Commission
Attachment A
519-001
Duke Energy Progress, LLC—Cape Fear Plant, p.1
Non-Constructed Seeps
See ID Approximate Location Receiving
P Receiving
Coordinates Description
Number P Waterbody Waterbody SOC Monitoring Interim Action Levels
Latitude Longitude Classification
Intermittent seep in grassy area northwest
of 1985 ash basin.Any flow drains to former
S-01** 35.5941 -79.0455 stormwater pipe with outfall to the north of Shaddox WS IV N/A—Seep N/A—Seep
the power line right of way. Flows to Creek Dispositioned Dispositioned
Shaddox Creek. I
Seepage around former sluice pipes at
S-02** 35.59328 -79.0445 northwest corner of 1985 ash basin.Area Shaddox WS-IV N/A—Seep N/A—Seep
has been repaired;seep eliminated. Creek Dispositioned Dispositioned
Low volume,intermittent seep to flat,grassy
area between northwest end of 1985 ash
S-03** 35.59251 -79.0457 basin and CP&L Drive.Any flow would drain Shaddox WS IV N/A—Seep N/A—Seep
toward S-01,and from there to Shaddox Creek Dispositioned Dispositioned
Creek.
Seep from the base of the north side of the UT to Instream
S-04 35.59301 -79.0428 1985 ash basin.Seep flows into an unnamed Shaddox WS-IV monitoring of No Interim Action
tributary(UT)to Shaddox Creek. Creek Shaddox Creek Levels
Discharge from French drain collection Effluent NPDES
system located north of 1978 ash basin. channel N/A—Not a monitoring of
Discharge is to a ditch flowing east to the flowing to Classified Outfall 007
S-05 35.59029 -79.0466 and/or Instream See page 5
NPDES permit effluent channel.This non- NPDES Surface
constructed seepflows to aportion of an monitoring of UT
permit Water to Cape Fear
NPDES wastewater treatment system. outfall 007
River(2)
Two small seeps located along the western Effluent
bank of the canal by the 1978 ash basin channel N/A—Not a
S 06** 35.58981 79.0454 where rip rap has been placed.Flows to flowing to Classified N/A—Seep N/A—Seep
NPDES permit effluent channel(outfall 007). NPDES Surface Dispositioned Dispositioned
This non-constructed seep flows to a portion permit Water
of an NPDES wastewater treatment system. outfall 007
*Location previously investigated as a seep. Monitoring has not indicated the presence of coal combustion residuals.
**Seep dispositioned via repair and/or non-flowing condition to potentially reach WOTUS,or other,as noted.
Monitoring shall be conducted at the approximate locations indicated on the attached site map.
All monitoring shall be conducted per the requirements found in Attachment 8 of this Order.
Attachment A
519-001
Duke Energy Progress, LLC—Cape Fear Plant, p.2
Seep ID Approximate Location Receiving
Coordinates Descri tion Receiving
Number p Waterbody Waterbody SOC Monitoring Interim Action Levels
Latitude Longitude Classification
Location of discharge from stormwater pipes NPDES
collecting seepage along west side of 1985 Effluent
channel N/A—Not a monitoring of
ash basin.Discharge from pipes is to a Outfall 007
S-07 35.58993 -79.0436 marshywith drainage flowing to Classified
area g to NPDES permit and/or Instream See page 5
effluent channel.This non-constructed see NPDES Surface
P permit Water monitoring of UT
flows to a portion of an NPDES wastewater to Cape Fear
treatment system. outfall 007
River(2)
Discharge from canal collecting flow from Effluent NPDES
seeps and low-lying areas on southwest side channel N/A—Not a monitoring of
of 1985 ash basin.Discharge is to the NPDES flowing to Classified Outfall 007
S-08 35.58585 -79.0427 and/or Instream See page 5
permit effluent channel.This non- NPDES Surface
constructed seep flows to a portion of an permit Water monitoring of UT
NPDES wastewater treatment system. outfall 007 to Cape Fear
River(2)
Intermittent seep in low-lying area —
southwest of 1985 ash basin.Any flow Instream
5-09 35.58594 -79.0398 moves toward a wetland area with drainage UT to Cape WS-IV monitoring of UT
See page 5
to an unnamed tributary to the Cape Fear
Fear River to Cape Fear
River. River(1)
Stagnant area of wetness at base of
southeast corner of 1985 ash basin.
S 10** 35.58581 79.0386 Collected seepage and runoff would flow UT to Cape N/A—Seep N/A—Seep
from depression to a wetland area with Fear River WS-IV
Dispositioned Dispositioned
drainage to an unnamed tributary to the
Cape Fear River.
Small seep in riprapped depression adjacent
to stormwater outfall.Any flow would be to Effluent
a shallow ditch to NPDES permit effluent channel N/A—Not a
S-11** 35.58501 -79.0412 channel.No flow observed during recent flowing to Classified N/A—Seep N/A—Seep
sampling events.This non-constructed seep NPDES Surface Dispositioned Dispositioned
would flow to a portion of an NPDES permit Water
wastewater treatment system. outfall 007
*Location previously investigated as a seep. Monitoring has not indicated the presence of coal combustion residuals.
**Seep dispositioned via repair and/or non-flowing condition to potentially reach WOTUS,or other,as noted.
Monitoring shall be conducted at the approximate locations indicated on the attached site map.
All monitoring shall be conducted per the requirements found in Attachment B of this Order.
Attachment A
S19-001
Duke Energy Progress, LLC—Cape Fear Plant, p.3
Approximate Location I -
Seep ID Receiving
Coordinates Receiving
Number Description Waterbody Waterbody SOC Monitoring Interim Action Levels
Latitude Longitude Classification _
' Ponded seepage area downslope of the
S-12* 35.5879 -79.0447 southeast corner of the 1978 ash basin. Wetlands WS-IV N/A—Seep N/A—Seep
From sampling results—No CCR Impacts. Dispositioned Dispositioned
Seepage area in a circular depression
downslope of the southwest corner of the
S 13** 35.58463 79.0474 1978 ash basin and the southeast side of the N/A—Seep N/A—Seep
1970 ash basin.Drainage appears to flow Wetlands WS IV
g pp Dispositioned Dispositioned
southeast.No flow observed during recent
sampling events.
Seep to a small depression in flat area south
of 1970 ash basin.Area is connected to a
S-14** 35.58244 -79.0478 ditch flowing southwest to the Cape Fear UT to Cape WS-IV N/A—Seep N/A—Seep
River.No flow observed during recent Fear River Dispositioned Dispositioned
sampling events.
Seep from the west side of the 1963 ash Cape Fear River
S 15 35.58889 79.0514 basin emerin beyond lower access road Cape Fear No Interim Action
g g y WS-IV instream
and flowing to the Cape Fear River. River Levels
monitoring
Seep adjacent to the Cape Fear River near Cape Fear River
S-16 35.59039 -79.0514 northwest corner of 1963 ash basin.Flow is Cape Fear No Interim Action
River WS-IV instream
partially treated prior to discharge via pipe. monitoring Levels
Area of wetness adjacent to the Cape Fear Cape Fear River
S-17 35.59054 79.0514 River near northwest corner of 1963 ash Cape Fear No Interim Action
River WS-IV instream
Levels
basin. monitoring
Recently identified,low flow seep adjacent
to the Cape Fear River near northwest Cape Fear Cape Fear River
S-18 35.59025 -79.0514 p WS-IV instream No Interim Action
corner of 1963 ash basin.Flow is partially River Levels
treated prior to discharge via pipe. monitoring
Area of wetness adjacent to the Cape Fear Cape Fear River
S-19 35.59042 -79.0514 River near northwest corner of 1963 ash Cape Fear No Interim Action
River WS-IV instream
basin. monitoring Levels
*Location previously Investigated as a seep. Monitoring has not indicated the presence of coal combustion residuals.
**Seep dispositioned via repair and/or non-flowing condition to potentially reach WOTUS,or other,as noted.
Monitoring shall be conducted at the approximate locations indicated on the attached site map.
All monitoring shall be conducted per the requirements found in Attachment B of this Order.
Attachment A
S19-001 -
Duke Energy Progress, LLC—Cape Fear Plant, p.4
Seep ID Approximate Location
Receiving
Coordinates Descri tion Receiving
Number p Waterbody Waterbody SOC Monitoring Interim Action Levels
Latitude Longitude Classification
Recently identified area of wetness at river I Haw/Cape Fear
5-20 35.59644 -79.0519 bank of the Haw River downslope from Haw River WS-IV River instream No Interim Action
northwest side of 1956 ash basin. monitoring Levels
Recently identified area of wetness at river Haw/Cape Fear
S-21 35.59794 -79.051 bank of the Haw River downslope from Haw River WS-IV River instream No Interim Action
northwest side of 1956 ash basin. monitoring Levels
Recently identified area of wetness at creek Instream
S-22 35.59899 -79.0488 bank of Shaddox Creek downslope from Shaddox No Interim Action
p Creek WS IV monitoring of Levels
north side of 1956 ash basin. Shaddox Creek
Effluent _. —._
channel N/A—Not a N/A—Seep
Seep along the toe of the west side of the contribution
5-23** 35.589 -79.042 1985 ash basin. Determined to be apart of flowing to Classified N/A—Seep
NPDES Surface analyzed in
Dispositioned
S-07 flow. NPDES Permit
permit Water
outfall 007 monitoring
*Location previously investigated as a seep. Monitoring has not indicated the presence of coal combustion residuals.
**Seep dispositioned via repair and/or non-flowing condition to potentially reach WOTUS,or other,as noted.
Monitoring shall be conducted at the approximate locations indicated on the attached site map.
All monitoring shall be conducted per the requirements found in Attachment B of this Order.
Attachment A
S19-001
Duke Energy Progress, LLC—Cape Fear Plant, p.5
Instream Monitoring
Description ReceivingWaterbodyReceiving Waterbody
Classification SOC Monitoring Interim Action Levels
Deep River
Upstream Background
& WS-IV Instream Monitoring of the Deep River and No Interim Action
Monitoring the Haw River
Haw River Levels
Instream Monitoring to
evaluate potential impacts Shaddox Creek WS IV Upstream&Downstream Monitoring of No Interim Action
from seeps Shaddox Creek Levels
Instream Monitoring to Hardness 600 mg/L
evaluate potential impacts UT to the Cape Fear River WS-IV Instream Monitoring of
UT to the Cape Fear River(#1 TDS 800 mg/L
from seeps p ) Sulfates 350 mg/L
Instream Monitoring to Hardness 600 mg/L
evaluate potential impacts UT to the Cape Fear River WS IV Instream Monitoring of
TDS 800 mg/L
from seeps UT to the Cape Fear River(#2)
Sulfates 350 mg/L
Instream Monitoring of the Cape Fear
River.
Downstream Monitoring to
evaluate potential impacts Cape Fear River WS-IV SOC monitoring location is the same as No Interim Action
from seeps described in condition A.(13.)of NPDES Levels
permit NC0003433 as Downstream Outfall
008.
*Location previously investigated as a seep. Monitoring has not indicated the presence of coal combustion residuals.
**Seep dispositioned via repair and/or non-flowing condition to potentially reach WOTUS,or other,as noted.
Monitoring shall be conducted at the approximate locations indicated on the attached site map.
All monitoring shall be conducted per the requirements found in Attachment B of this Order.
Cape Fear Plant — Water Quality Monitoring (North)
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Upstream — Deep River, Haw River & Shaddox Creek Downstream —Shaddox Creek
Cape Fear Plant — Water Quality Monitoring (South)
r 49411L iitr'
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1985 Ash Basin •
-a
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1978 Ash Basin
1963 Ash Basin
1970 Ash Basin
*
* 2
Downstream— Cape Fear River Instream — UT to Cape Fear River
SOC S19-001
Duke Energy Progress,LLC—Cape Fear Plant
Attachment B
Monitoring Requirements
The followingrepresents theparameters to be analyzed and reported at all monitoringlocations
p Y p
designated within this Special Order.
Parameter Reporting Units Monitoring
Frequency
TSS mg/L Annually
Oil and Grease mg/L Annually
pH Standard Units(s. u.) Quarterly
Fluoride pg/L Quarterly
Total Mercury ng/L Quarterly
Total Barium pg/L Quarterly
Total Zinc pg/L Quarterly
Total Arsenic pg/L Quarterly
Total Boron pg/L Quarterly
Total Cadmium pg/L
Quarterly
uarterl Y
Total Chromium pg/L Quarterly
Total Copper pg/L Quarterly
Total Thallium pg/L Quarterly
Total Lead pg/L Quarterly
Total Nickel pg/L Quarterly
Total Selenium pg/L Quarterly
Nitrate/Nitrite as N mg/L Quarterly
Bromides mg/L Quarterly
Sulfates mg/L Quarterly
Chlorides mg/L Quarterly
TDS mg/L Quarterly
Total Hardness mg/L Quarterly
Temperature °C Quarterly
Conductivity, pmho/cm pmho/cm Quarterly
Analyses of all monitoringconductedper the terms of this SOC shall conform to the requirements of 15A
Y 4
NCAC 2B .0505(e)(4)and(5); i.e.,standard methods and certified laboratories shall be used.
Seep Management Plan Amendment to the Corrective Action Plan
Cape Fear Steam Electric Plant—Duke Energy Progress, LLC
Moncure, North Carolina
APPENDIX B
MANN KENDALL TREND TEST ANALYSIS,
AUGUST 2022
d It.A dit.
synTerra
Science & Engineering Consultants
.
1 ,
0 ,
synTerra Science & Engineering Consultants
synterracorp.com
APPENDIX B
MANN-KENDALL TREND TEST ANALYSIS
CAPE FEAR STEAM ELECTRIC PLANT
AUGUST 2022
PREPARED FOR
., DUKE
ENERGY
PROGRESS
DUKE ENERGY PROGRESS,LLC
Appendix B-Mann-Kendall Trend Test Analysis
Cape Fear Steam Electric Plant, Duke Energy Progress, LLC
Moncure, North Carolina
TABLE OF CONTENTS
SECTION PAGE
1.0 THE MANN-KENDALL TREND TEST 1-1
2.0 TIME VERSUS CONCENTRATION PLOTS 2-1
3.0 MANN-KENDALL TREND TEST RESULTS 3-1
LIST OF FIGURES
Figure 1 Time versus Total Arsenic Concentration
Figure 2 Time versus Total Barium Concentration
Figure 3 Time versus Total Boron Concentration
Figure 4 Time versus Bromide Concentration
Figure 5 Time verses Total Cadmium Concentration
Figure 6 Time versus Chloride Concentration
Figure 7 Time versus Total Chromium Concentration
Figure 8 Time versus Total Copper Concentration
Figure 9 Time versus Fluoride Concentration
Figure 10 Time versus Hardness
Figure 11 Time versus Total Lead Concentration
Figure 12 Time versus Total Mercury Concentration
Figure 13 Time versus Total Nickel Concentration
Figure 14 Time versus Oil and Grease Concentration
Figure 15 Time versus pH
Figure 16 Time versus Total Selenium Concentration
Figure 17 Time versus Specific Conductance
Figure 18 Time versus Total Sulfate Concentration
Figure 19 Time versus Temperature
Figure 20 Time versus Total Thallium Concentration
Figure 21 Time versus Total Dissolved Solids Concentration
Figure 22 Time versus Total Suspended Solids Concentration
Figure 23 Time versus Total Zinc Concentration
LIST OF TABLES
Table 1 Sampling Locations and Constituents Included in Concentration over Time Plots
Table 2 Mann-Kendall Trend Analysis Results
August 2022 Page i
Project:00.0060.17
Appendix B-Mann-Kendall Trend Test Analysis
Cape Fear Steam Electric Plant, Duke Energy Progress, LLC
Moncure, North Carolina
1.0 THE MANN-KENDALL TREND TEST
Mann-Kendall trend tests were performed on available seep data associated with the ash
basins at the Cape Fear Steam Electric Plant.The Mann-Kendall trend test evaluates data over
time for monotonic trends, where monotonic indicates a trend that is solely increasing or
decreasing. Mann-Kendall is a useful trend test in that it is non-parametric and does not require
normal distribution of data.
To perform the Mann-Kendall trend test, data were processed as follows:
• Non-detects greater than regulatory values were removed. If a constituent does not
have a regulatory limit and there are multiple reporting limits, only the lowest reporting
limit was retained.
• Detects that were less than the reporting limit were treated at non-detects.
• Samples with pH greater than 10 standard units were removed.
Next, the data must meet the following requirements for a Mann-Kendall trend test to be
applicable:
• There must be at least four detect measurements.
• Non-detects must make up less than or equal to 50 percent of measurements.
In a Mann-Kendall trend test, each value is compared to the proceeding values to calculate
whether the value has increased, decreased, or stayed the same over time. These comparisons
are recorded as simply 1 (increasing), -1 (decreasing), or 0 (stayed the same).These
comparisons give an S value, where S indicates the type of trend. A negative S value indicates a
decreasing trend, and a positive S value indicates an increasing trend. Whether or not these
trends are statistically significant is dependent on the two-sided p value. A p value ranges from
0 to 1 and indicates whether the results are due to chance or the results are statistically
significant. Greater p values indicate a trend is not statistically significant, and a p value less
than 0.1 indicates a statistically significant trend.
All Mann-Kendall trend tests are performed in the program RStudio using the "Kendall"
package.
August 2022 Page 1-1
Project:00.0060.17
Appendix B-Mann-Kendall Trend Test Analysis
Cape Fear Steam Electric Plant, Duke Energy Progress, LLC
Moncure, North Carolina
2.0 TIME VERSUS CONCENTRATION PLOTS
Plots of concentration over time provide a visual representation of possible trends in the data.
Time versus concentration plots are presented as Figures 1 through 23. Plots are grouped by
constituent, and within the figure, a plot of concentration over time is displayed for each
location that has data for that constituent. Locations and constituents included in these plots
are presented in Table 1.
Trends from the Mann-Kendall tests are displayed on plots with colored borders representing
trend conclusions. Blue indicates no trend was present, green indicates a decreasing trend, gold
indicates an increasing trend, and no color indicates the constituent-location pair cannot be
analyzed for trends due to a lack of detect measurements. Detect measurements are shown as
a black point, and non-detect measurements are shown as an open circle.
TSS concentrations detected during the October 23, 2018 sampling event were anomalously
greater than concentrations from other previous and subsequent sampling events. This
indicates the suspended solids from turbidity within the sample likely caused concentrations of
other constituents to be detected at anomalously greater concentrations than what was
actually present at this location, at this time. Therefore, the samples from October 23, 2018 are
not likely representative of water quality conditions at S-15.
August 2022 Page 2-1
Project:00.0060.17
Appendix B-Mann-Kendall Trend Test Analysis
Cape Fear Steam Electric Plant, Duke Energy Progress, LLC
Moncure, North Carolina
TABLE 1
SAMPLING LOCATIONS AND CONSTITUENTS INCLUDED IN PLOTS
OF CONCENTRATIONS OVER TIME
Sampling Locations Constituents
5-07 Total Arsenic
S-08 Total Barium
S-15 Total Boron
S-16 Bromide
Total Cadmium
Chloride
Total Chromium
Total Copper
Fluoride
Hardness
Total Lead
Total Mercury
Total Nickel
Oil and Grease
- — pH
Total Selenium
Specific Conductance
Total Sulfate
Temperature
Total Thallium
Total Dissolved Solids
Total Suspended Solids
Total Zinc
August 2022 Page 2-2
Appendix B-Mann-Kendall Trend Test Analysis
Cape Fear Steam Electric Plant, Duke Energy Progress, LLC
Moncure, North Carolina
3.0 MANN-KENDALL TREND TEST RESULTS
Results of the Mann-Kendall trend tests are presented in Table 2. Mann-Kendall trend tests
were conducted for data pertaining to the 4 non-dispositioned seeps associated with the ash
basin.Trend analyses were completed for 92 location-constituent pairs using available seep
data that was collected between 2014 and 2022. For the other occurrences where trend
analysis could not be performed, either there are less than four detects, or the number of non-
detects is greater than the number of detects.The average percentage of non-detects for all
constituent-location pairs included in the Mann-Kendall trend test is 41 percent.
Locations not displayed in Table 2 are excluded due to having less than the minimum number
of samples required to run the "Kendall" package in RStudio. Location-constituent pairs with
less than four detects are included in Table 2 but cannot be analyzed for trends based on the
criteria in Section 1.0.
Out of the 92 constituent-location pairs that have trend conclusions, 20 are associated with the
following field parameters: pH, specific conductance,temperature, total dissolved solids, and
total suspended solids.Trends for these field parameters were evaluated for information but
are not included in percentages below. Of the 72 chemical constituent-location pairs that have
trend conclusions, 38 percent of constituent concentrations are stable or have statistically
significant decreasing trends (27 out of 72 constituent location pairs), 56 percent (40 out of 72)
of trends could not be analyzed due to greater than 50 percent non detects, and 6 percent (5
out of 72) of constituent concentrations have statistically significant increasing trends.
Overall,the results of the Mann-Kendall trend tests indicate a system that is geochemically
stable, with the majority of constituent concentrations remaining stable over time.
August 2022 Page 3-1
Project:00.0060.17
APPENDIX B-TABLE 2
MANN-KENDALL TREND ANALYSIS RESULTS
SEEP MANAGEMENT PLAN AMENDEMENT TO THE CORRECTIVE ACTION PLAN
CAPE FEAR STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS,LLC,MOCURE,NC
Number Percent Is Trend Analysis Two-Sided
Well ID Analyte of Samples Non-Detects Detects Non-Detects Applicable? P Value S Value Trend Conclusion
S-15 Arsenic 10 0 10 0 Yes 1.00E+00 - Stable,no significant trend
S-16 Arsenic 10 0 10 0 Yes 3.71E-01 - Stable,no significant trend
S-7 Arsenic 12 10 2 83 No - - Cannot Analyze for Trends
S-8 Arsenic 12 12 0 100 No - - Cannot Analyze for Trends
S-15 Barium 10 0 10 0 Yes 2.43E-01 - Stable,no significant trend
S-16 Barium 10 10 0 100 No - - Cannot Analyze for Trends
S-7 Barium 12 10 2 83 No - - Cannot Analyze for Trends
S-8 Barium 12 8 4 67 No - - Cannot Analyze for Trends
5-15 Boron 10 0 10 0 Yes 1.00E+00 - Stable,no significant trend
S-16 Boron 10 0 10 0 Yes 1.52E-01 - Stable,no significant trend
5-7 Boron 12 0 12 0 Yes 4.51E-01 - Stable,no significant trend
5-8 Boron 12 0 12 0 Yes 9.69E-04 -49 Statistically significant decreasing trend
5-15 Bromide 5 5 0 100 No - - Cannot Analyze for Trends
S-16 Bromide 4 4 0 100 No - - Cannot Analyze for Trends
5-7 Bromide 5 4 1 80 No - - Cannot Analyze for Trends
S-8 Bromide 5 5 0 100 No - - Cannot Analyze for Trends
5-15 Cadmium 10 10 0 100 No - - Cannot Analyze for Trends
S-16 Cadmium 10 3 7 30 Yes 1.73E-01 - Stable,no significant trend
S-7 Cadmium 12 11 1 92 No - - Cannot Analyze for Trends
S-8 Cadmium 12 10 2 83 No - - Cannot Analyze for Trends
S-15 Chloride 10 0 10 0 Yes 9.28E-01 - Stable,no significant trend
S-16 Chloride 10 0 10 0 Yes 1.23E-02 -29 Statistically significant decreasing trend
5-7 Chloride 12 0 12 0 Yes 9.44E-01 - Stable,no significant trend
5-8 Chloride 12 0 12 0 Yes 1.08E-01 - Stable,no significant trend
S-15 Chromium 10 9 1 90 No - - Cannot Analyze for Trends
S-16 Chromium 10 10 0 100 No - - Cannot Analyze for Trends
5-7 Chromium 12 12 0 100 No _ - - Cannot Analyze for Trends
S-8 Chromium 12 12 0 100 No - - Cannot Analyze for Trends
S-15 Copper 9 8 1 89 No - - Cannot Analyze for Trends
5-16 Copper 9 7 2 78 No - - Cannot Analyze for Trends
5-7 Copper 11 9 2 82 No - - Cannot Analyze for Trends
5-8 Copper 12 0 12 0 Yes 1.64E-02 36 Statistically significant increasing trend
5-15 Fluoride 9 1 8 11 Yes 1.42E-01 - Stable,no significant trend
S-16 Fluoride 4 0 4 0 Yes 1.00E+00 - Stable,no significant trend
5-7 Fluoride 10 6 4 60 No - - Cannot Analyze for Trends
5-8 Fluoride 11 8 3 73 No - - Cannot Analyze for Trends
5-15 Hardness 9 0 9 0 Yes 1.19E-02 25 Statistically significant Increasing trend
5-16 Hardness 10 0 10 0 Yes 1.52E-01 - Stable,no significant trend
5-7 Hardness 10 0 10 0 Yes 5.30E-01 - Stable,no significant trend
S-8 Hardness 10 0 10 0 Yes 3.23E-01 - Stable,no significant trend
Page 1 of 3
APPENDIX B-TABLE 2
MANN-KENDALL TREND ANALYSIS RESULTS
SEEP MANAGEMENT PLAN AMENDEMENT TO THE CORRECTIVE ACTION PLAN
CAPE FEAR STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS,LLC,MOCURE,NC
Well ID Analyte Number Non-Detects Detects Percent Is Trend Analysis Two-Sided S Value Trend Conclusion
of Samples Non-Detects Applicable? P Value
S-15 Lead 6 5 1 83 No - - Cannot Analyze for Trends
S-16 Lead 6 6 0 100 No - - Cannot Analyze for Trends
5-7 Lead 6 5 1 83 No - - Cannot Analyze for Trends
5-8 Lead 6 6 0 100 No - - Cannot Analyze for Trends
S-15 Mercury 9 5 4 56 No - - Cannot Analyze for Trends
S-16 Mercury 5 3 2 60 No - - Cannot Analyze for Trends
S-7 Mercury 11 2 9 18 Yes 3.50E-02 -28 Statistically significant decreasing trend
S-8 Mercury 11 1 10 9 Yes 4.36E-01 - Stable,no significant trend
S-15 Nickel 10 0 10 0 Yes 1.00E+00 - Stable,no significant trend
5-16 Nickel 10 0 10 0 Yes 2.10E-01 - Stable,no significant trend
5-7 Nickel 12 0 12 0 Yes 9.45E-01 - Stable,no significant trend
S-8 Nickel 12 0 12 0 Yes 6.41E-02 28 Statistically significant increasing trend
5-15 Oil and grease 9 9 0 100 No - - Cannot Analyze for Trends
S-16 Oil and grease 8 8 0 100 No - - Cannot Analyze for Trends
S-7 Oil and grease 7 7 0 100 No - - Cannot Analyze for Trends
5-8 Oil and grease 7 7 0 100 No - - Cannot Analyze for Trends
S-15 pH 10 0 10 0 Yes 4.61E-01 - Stable,no significant trend
S-16 pH 10 0 10 0 Yes 1.67E-03 36 Statistically significant increasing trend
•
5-7 pH 12 0 12 0 Yes 6.30E-01 - Stable,no significant trend
S-8 pH 12 0 12 0 Yes 9.45E-01 - Stable,no significant trend
S-15 Selenium 10 10 0 100 No - - Cannot Analyze for Trends
5-16 Selenium 10 10 0 100 No - - Cannot Analyze for Trends
5-7 Selenium 12 12 0 100 No - - Cannot Analyze for Trends
S-8 Selenium 12 12 0 100 No - - Cannot Analyze for Trends
S-15 Specific Conductance 10 0 10 0 Yes 3.18E-02 25 Statistically significant increasing trend
S-16 Specific Conductance 10 0 10 0 Yes 7.29E-03 -31 Statistically significant decreasing trend
5-7 Specific Conductance 12 0 12 0 Yes 6.31E-01 - Stable,no significant trend
5-8 Specific Conductance 12 0 12 0 Yes 5.37E-01 - Stable,no significant trend _
S-15 Sulfate 10 0 10 0 Yes 4.23E-01 - Stable,no significant trend
S-16 Sulfate 10 0 10 0 Yes 6.24E-03 -31 Statistically significant decreasing trend
•
S-7 Sulfate 12 0 12 0 Yes 2.29E-01 - Stable,no significant trend
5-8 Sulfate 12 0 12 0 Yes 5.46E-01 - Stable,no significant trend _
S-15 Temperature 10 0 10 0 Yes 3.68E-02 -24 Statistically significant decreasing trend
S-16 Temperature 10 0 10 0 Yes 4.21E-03 -33 Statistically significant decreasing trend
S-7 Temperature 12 0 12 0 Yes - 3.35E-02 -32 Statistically significant decreasing trend
S-8 Temperature 12 0 12 0 Yes 3.89E-03 -43 Statistically significant decreasing trend
S-15 Thallium 10 9 1 90 No _ - - Cannot Analyze for Trends _
S-16 Thallium 10 0 10 0 Yes 2.36E-03 _ 35 Statistically significant increasing trend
S-7 Thallium 12 11 1 92 No - - Cannot Analyze for Trends
5-8 Thallium 12 12 0 100 No - - Cannot Analyze for Trends
Page 2 of 3
APPENDIX B-TABLE 2
MANN-KENDALL TREND ANALYSIS RESULTS
SEEP MANAGEMENT PLAN AMENDEMENT TO THE CORRECTIVE ACTION PLAN
CAPE FEAR STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS,LLC,MOCURE,NC
Well ID Anal to Number Non-Detects Detects Percent Is Trend Analysis Two-Sided
y of Samples Non-Detects Applicable? P Value 5 Value Trend Conclusion
5-15 Total Dissolved Solids 10 0 10 0 Yes 7.18E-01 - Stable,no significant trend
S-16 Total Dissolved Solids 10 0 10 0 Yes 2.36E-02 -26 Statistically significant decreasing trend
S-7 Total Dissolved Solids 12 0 - 12 0 Yes 1.45E-01 - Stable,no significant trend
5-8 Total Dissolved Solids 12 0 12 0 Yes 3.04E-01 - Stable,no significant trend
S-15 Total Suspended Solids 10 2 - 8 20 Yes 4.71E-01 - Stable,no significant trend
5-16 Total Suspended Solids 9 1 8 11 _ Yes 3.43E-01 - Stable,no significant trend• _
S-7 Total Suspended Solids 12 3 9 25 Yes- - 5.28E-02 -29 Statistically significant decreasing trend _
S-8 Total Suspended Solids 12 6 6 50 _ Yes 3.37E-01 - Stable,no significant trend
•S-15 Zinc 10 8 2 80 No - - Cannot Analyze for Trends
5-16 Zinc 10 0 - 10 0 Yes 5.37E-03 -32 Statistically significant decreasing trend
•
S-7 Zinc 12 8 4 67 No - - Cannot Analyze for Trends
S-8 Zinc 12 4 8 33 Yes 6.32E-03 40 Statistically significant increasing trend
Prepared by:RSB Checked by:KHF
Notes:
Detection limits were adjusted in accordance with USEPA guidelines
To be analyzed for trends there must beat least 4 detects and less than or equal to 50%non-detects.
A P value less than 0.1 indicates a statistica1N significant trend.
A negative S value indicates a decreasing trend.
A positive S values indicates an increasing trend.
Page 3 of 3
Appendix B-Mann-Kendall Trend Test Analysis
Cape Fear Steam Electric Plant, Duke Energy Progress, LLC
Moncure, North Carolina
FIGURES
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--Detett • Data presented may include lab-Qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED DV•K.FERRI DATE:7/12/2022 SEEP MANAGEMENT PLAN
corresponding reporting limit.
Tme vs total arsenic plot for all locations with available data.Trends are denoted by the box color,if APPROVED an E.YURKOVICH DATE:B/1912022 APPENDIX 13
Stable,no trentls there is no color the data could not be analyzed for trends
-StatisticallySignifcantDecreavngTrend yZe PROJECT MANAGER:E.YURKOVICH MANN-KENDALLTRENDTESTANALYSIS
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—0—Non-detect • Data presented on concentration plots includes all sampling programs. ENERGY REVISED BY: DATE: TIME VERSUS TOTAL BARIUM CONCENTRATION
+Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERRI DATE:7/12/2022 SEEP MANAGEMENT PLAN
corresponding reporting limit.
• Tmevstotalhariumplotioralllocationswithavailabledata.Trendsaredenoted6ytheboxcolor,if APPROVED BY:E.yuRKOVICH DATEensno22 APPENDIX B
Stable,no[rends there is no color the data could not be analyzed for trends
Ill
-Statistically Significant Decreasing Trend y2e PRDJEGTMANAGER'E.YDRKOVICH MANN-KENDALL TREND TEST ANALYSIS
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LEGEND: NOTES: DUKE DRAWN BY:R.BADUM DATES/2)/2022 FIGURE 3
I Non-detect
• Data presented on concentration plots includes all sampling programs. ENERGY REwsEDsv: DATE: TIME VERSUS TOTAL BORON CONCENTRATION
+Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERRI DATE,7n2/2022 SEEP MANAGEMENT PLAN
corresponding reporting limit.
APPROVED BY:E.YURKOVICH DATE:8/19/2022 APPENDIX B
-Stable,no tre
• Time vs total boron plot for alllocations with available data.Trends are denoted by the box color,If there is no color the data could not be analyzed MANNKENDALL TREND TEST ANALYSIS
II
-Statistically Significant Decreasing Trend y2e PROJECT MANAGER:E.YURKOVICH
-Statistically Significant Increasing Trend Rg�t-micrograms per liter
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LEGEND: NOTES: 'DUKE DRAWN BY:R.BADDM DATE:&22/2022 FIGURE 4
1—0—Non-detect • Data presented on concentration plots indudes all sampling programs. ENERGY REwsEDBY: DATE: TIME VERSUS BROMIDE CONCENTRATION
—•—Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERRI DATE:7/12/2022 SEEP MANAGEMENT PLAN
corresponding reporting limit.
is vs bromide plot for all locations with available data.Trends are denoted by the bon color,If there APPROVED BY:E.YURKOVICH DATE:a/190022 APPENDIX B
-Stable,no trends color the data could not be analyzed for trends `� MANN-KENDALL TREND TEST ANALYSIS
•
-Statistically$ignif cant Decreasing Trend y PROJECT 1MNACER:E.YURKOVICH
-Statistically Significant Increasing Trend • HK/L-micrograms per liter
CAPE FEAR STEAM ELECTRIC PLANT
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S-7 S-8 S-15
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LEGEND: NOTES: I DUKE DRAWN BY:R.BADUM DATE'.B121/2022 FIGURE 5
—0-Non-detect • Data presented on concentration plots includes all sampling programs. ENERGY REVISED BY: DATE. TIME VERSUS TOTAL CADMIUMCONCENTRATION
♦-Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERRI DATE:111212022 SEEP MANAGEMENT PLAN
corresponding reporting limit.
Stable,no trends e-statistically Significant Decreasing Trend
Ti• me vs total Cadmium plot for all locations with available data.Trends are denoted by the box color,if APPROVED BY:E.YURKOVICN DATE:Bns/zo2z APPENDIX B
there is no color the data could not be analyzed for trends• 'eooIECT MANAGER:E.YDRKowcn MANN-KENDALL TREND TEST ANALYSIS
-Statistically Significant Increasing Trend Ng/L-m'crogramsperliter � r� CAPE FEAR STEAM ELECTRIC PLANT
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NOTES: I DUKE DRAWN BY:R.BADOM DATE:6letluoc2 FIGURE 6
—0—Non-dated • Data presented on concentration plots includes all oampling programs. ENERGY REVISED BY: DATE: TIME VERSUS CHLORIDE CONCENTRATION
- Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERRI DATE:7/11120 2 2 SEEP MANAGEMENT PLAN
corresponding reporting limit.
Ill • Sjno¢y5chloridep0tforalllocatlonswi[havailabletlata.Trendsaretlenotedbytheboxcolor,if[here APPROVED BY:E.YURKOVICH DATE:Bnsrm22 APPENDIX B
-Stable,no[rends color the data could not be analyzed for trends
-Statistically$ignifcan[Decreasing Trend y PROJECT MANAGER:E.YDRKOVICH MANN-KENDALL TREND TEST ANALYSIS
-Statistically Significant Increasing Trend • pg�L-mi<rogramsperliter CAPE FEAR STEAM ELECTRIC PLANT
No Color-Cannot Analyze for Trends synTerra www.synterracorp.com MONCURE,NORTH CAROLINA
S-7 S-8 S-15
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LEGEND: NOTES: / .i DUKE DRAWN BY:R.BADUM DATE:6127/2022 FIGURE 7
—0—Non-detect • Data presented onconcentration plots ndsdes all sampling programs. ENERGY REVISED DATE: TIME VERSUS TOTAL CHROMIUM CONCENTRATION
--Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERRI DATE:nt2rto22 SEEP MANAGEMENT PLAN
corresponding reporting limit.
• Time vs total chromium plot ton all locations with available data.Trends are denoted by the boa color, APPROVED BY:E.YURKOVICH DATE:BI1Br2022 APPENDIX B
-Stable,no trends if there is no color the data could not be analyzed for trends
Statistically Significant Decreasing TrendPI
yze PROJECT MANAGER:E.YURKOVICH MANN-KENDALL TREND TEST ANALYSIS
• Elevated TSS concentrations may have influenced increased constituent concentrations at S-15 during CAPE FEAR STEAM ELECTRIC PLANT
-Statistically Significant Increasing Trend the October 23,2018 sampling event
No Color-Cannot Analyze for Trends • pg/L-micrograms per liter synTerra www.synterrecorp.com MONCURE,NORTH CAROLINA
S-7 S-8 S-15
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LEGEND: NOTES: /DUKE DRAWN BY:R.BADOM DATE:6/27/2022 FIGURE 8
Non-detect • Data presented on concentration plots includes all sampling programs. ENERGY REVISED DV: DATE: TIME VERSUS TOTAL COPPER CONCENTRATION
Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.EERRI DATE 7/12/2022 SEEP MANAGEMENT PLAN
corresponding reporting limit.
Time vs total copper plot for all locations with available data.Trends are denoted by the box color,if APPROVED BY:E.VDRKOVICH DATE:8/19/2022 APPENDIX B
Statist,no trends there is no color the data could not be analyzed for trends
Ill
•
-Statistically Significant Decreasing Trend PROJECT MANAGER:E.YURKOVICH MAN N-KEN DALL TREND TEST ANALYSIS
-Statistically Significant Increasing Trend • Elevated TSS concentrations may have influenced increased constituent concentrations at S-SS during erg CAPE FEAR STEAM ELECTRIC PLANT
the October 23,2018 sampling event -'7. .
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LEGEND: NOTES: / ..,DUKE DRAWN BY:R.BADUM DATE:6/27/2022 FIGURE 9
-0-Non-detect • Data presented on concentration plots includes all sampling programs. 'ENERGY REVISED BY: DATE: TIME VERSUS FLUORIDE CONCENTRATION
-0-Deed • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the i'R OGRE SS CHECKED BY:K.FERRI DATE:]/12/2022 SEEP MANAGEMENT PLAN
corresponding reporting limit.
• is no
fluoride plot for all locations with available data.Trends are denoted by the boo color,if there APPROVED BY:E.YURKOVICH DATE:811912022 APPENDIX B
-Stable,no trends color the data could not be analyzed for trends
-Statistically Signifcan[DecreasingTrend y2e PROJECT MANAGER:E.YURKOVICH MANN-KENDALL TREND TEST ANALYSIS
li
-Statistically Significant Increasing Trend • pglL-microgramsperliter CAPE FEAR STEAM ELECTRIC PLANT
No Color-Cannot Analyze for Trends synTerra www.synterracorp.corn MONCURE,NORTH CAROLINA
•
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LEGEND: NOTES: (1 DUKE DRAWN BY:R.BADUM DATE:6/2)12022 FIGURE 10
—j—Non-detect • Data presented on concentration plots indudes all sampling programs. �'ENERGY REVISED DATE: TIME VERSUS HARDNESS
-11-Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS cNECKED BY:K.FERRI DATE:7n2/2o22 SEEP MANAGEMENT PLAN
corresponding reporting limit.
Sta61e,no trends • Time vs hardness plot for all locations with available data.Trends are denoted by the box color,if there APPROVED BY:E.YURKOVICH DATE:en912021 APPENDIX B
Statistically significant Decreasing Trend is no color the data could not be analysed for trends• ,PROJECT MANAGER:E.YURKOVICH MANN-KEN DALL TREND TEST ANALYSIS
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LEGEND: NOTES: eta.,DUKE DRAWN BY:R.BADUM DATE:6/27/2022 FIGURE 11
—0—Non-deteR • Data presented on concentration plots includes all sampling programs. ENERGY REAISEoev: DATE: TIME VERSUS TOTAL LEAD CONCENTRATION
-Al—Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERRI DATE:)/12/2022 SEEP MANAGEMENT PLAN
corresponding reporting limit.
APPROVED BY:E.YDRKOVICH DATE:B/19/2022 APPENDIX B
• Time vs total lead plot for all locations with available data.Trends are denoted by the box color,if
-Stable,no trends there is no color the data could not be analyzed far trends
RI
-StatisticallySignifcantDecreasingTrentl yze 'PROJECT MANAGER:E.vuRKOWCH MANN-KENDALL TREND TEST ANALYSIS
• Elevated TSS concentrations may have influenced increased constituent concentrations at S-1S during CAPE FEAR STEAM ELECTRIC PLANT
Statistically Significant Increasing Trend the October 23,2018 sampling event
No Color-Cannot Analyze for Trends • pg/L-micrograms per liter synTerra www.synterracorp.com MONCURE,NORTH CAROLINA
S-7 S-8 S-15
2e+00 - -- —
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LEGEND: NOTES: ebb.,DUKE DRAWN BY:R.BADUM DATE:6/27/2022 FIGURE 12
Non-detect • Data presented on concentration plots includes all sampling programs. `'ENERGY REwseo en DATE. TIME VERSUS TOTAL MERCURY CONCENTRATION
Non-detect
-0-Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the nROGR[.SS CHECKED BY:K.FERRI DATE 1112/2022 SEEP MANAGEMENT PLAN
corr reporting limit.
-Stable,no trends • Time Vs total mercury plot for all locations with available data.Trends are denoted by the box color,if APPROVED BY:E.VDRKOVICH DATE:B/19/2022 APPENDIX B
il
-Statistically Significant Decreasing Trend Crt
there is no color the data could not be analyzed for trends 0PROJECT MANAGER:E.vUoKovleH - MANN-KENDALL TREND TEST ANALYSIS
-StatisticallysignifcaetlncreasingTrend • Elevated TSS concentrations may have influenced increased consuentconcentrations at5-IS during CAPE FEAR STEAM ELECTRIC PLANT
the October 23,2018 sampling event
No Color-Cannot Analyze for Trends • pg/L-micrograms per liter synTerra WWW.synterracorp.com MONCURE,NORTH CAROLINA
r.
S-7 S-8 S-15
300 300 _. 300
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Non-detect • Data presented on concentration plots includes all sampling programs. ENERGY REVISED BY: DATE: TIME VERSUS TOTAL NICKEL CONCENTRATION
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corresponding reporting limit.
• Time us total nickel plot for all locations with available data.Trends are denoted by the box color,if APPROVED BY:E.VURKOVICH DATE:ansnozz APPENDIX B
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- Nan-detect • Data presented on concentration plots indudes all sampling programs. /ENERGY REVISED BY: DATE: TIME VERSUS OIL AND GREASE CONCENTRATION
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responding reporting limit.
II • Time vs total oil and grease for all locations with available data.Trends are denoted by the box color,if APPROVED BY:E.YURKOVICH DATE:8/19/2022 APPENDIX B
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-0-Nan-detect • Data presented on concentration plots includes all sampling programs. ' ENERGY REviSEDBY. DATE. TIME VERSUS pH
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responding reporting limit.
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• Data presented on concentration plots includes all sampling programs. V'ENERGY REAISEDBY: DATE: TIME VERSUS TOTAL SELENIUM CONCENTRATION
-0-Non-detect
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corresponding reporting limit.
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corresponding reporting limit.
• Time vs total sulfate plot for all locations with available data.Trends are denoted by the boo color,if APPROVED BY:E.YURKOVICH DATE:a/1912022 APPENDIX B
Istable,no trends there is no color the data could not be analyzed for trends MANN-KENDALL TREND TEST ANALYSIS
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Non-detect Data presented on concentration platsindudes all samplingprograms. 'ENERGY REVISED BY: DATE: TIME VERSUS TEMPERATURE
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LEGEND: NOTES: ,DUKE DRAWN BY:R.BADUM DATE:612J12o22 FIGURE 20
Non-detect • Data presented on concentration plots includes all sampling programs. ENERGY REVSEDBY: DATE: TIME VERSUS TOTAL THALLIUM CONCENTRATION
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-0-Non-detect • Data presented on concentration plots includes all sampling programs. ` ENERGY REVISED BY: DATE: TIME VERSUS TOTAL DISSOLVED SOLIDS CONCENTRATION
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LEGEND: NOTES: etilbDUKE DRAWN BY:R.BADUM DATE:6l2)12022 FIGURE 23
-0-Non-detect • Data presented on concentration plots includes all sampling programs. 7I ENERGY Revisco BY DATE: TIME VERSUS TOTAL ZINC CONCENTRATION
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EMC SOC WQ S 19-001
Duke Energy Progress,LLC
p. 8
5) Duke Energy shall conduct annual comprehensive surveys of areas down
gradient of the ash basins, identifying new seeps, and documenting the
physical characteristics of previously documented seeps. All
examinations of seeps must include identification of seeps by approximate
latitude and longitude and date-stamped digital photographs of their
appearance. A report summarizing the findings of the surveys,including a
section analyzing the effect decanting and dewatering of the basin(s)has
on seep flows, accompanied by copies of the photographs noted above
("Annual Seep Report"), shall be submitted to DWR in conjunction with
submittal of the April 30 quarterly reports noted in 2(b)(4) above. This
Annual Seep Report must list any seep that has been dispositioned(as
described below) during the previous year, including an analysis of the
manner of disposition. For purposes of this Special Order, "dispositioned"
includes the following: (1)the seep is dry for at least three consecutive
quarters; (2)the seep does not constitute, and does not flow to,waters of
the State or Waters of the United States for three consecutive quarters; (3)
the seep is no longer impacted by flow from any coal ash basin as
determined by the Director of DWR in accord with applicable law and
best professional judgment; or(4) the seep has been otherwise eliminated
(e.g., through an engineering solution). If a seep that has been
dispositioned through drying up reappears in any subsequent survey,such
a seep will no longer be deemed dispositioned and can be subsequently re-
dispositioned as specified above.
6) No later than April 30,2022 (90 days following the completion of two
years of dewatering operations at the Cape Fear Facility),and in the same
manner as in the annual surveys, Duke Energy shall conduct a
comprehensive survey of areas down gradient of ash basins at the Cape
Fear Facility, identifying new seeps, and documenting the physical
characteristics of previously documented seeps. All examinations of seeps
must include identification of seeps by approximate latitude and longitude
and date-stamped digital photographs of their appearance. A report
summarizing the findings of this survey, including a section analyzing the
effect decanting and dewatering of the basin(s)has had on seep flows,
accompanied by copies of the photographs noted above, shall be submitted
to the Director of DWR("Final Seep Report"). This Final Seep Report
must list any seep that has been dispositioned(as described in
subparagraph(5) above) during decanting, dewatering and CCR removal
or beneficiation processes,including an analysis of the manner of
disposition. The determination of whether a seep is dispositioned rests
with the Director of DWR. At,or at any time prior to, submission of the
Final Seep Report, Duke Energy shall seek formal certification from the
Director of DWR, certifying the disposition of any seep that Duke Energy
has characterized as dispositioned. Any seeps not certified as
dispositioned by the Director of DWR shall not be deemed as
dispositioned.