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HomeMy WebLinkAboutNC0003433_Seep Corrective Action Plan Amendment_20220831 (3) 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 411 DUK ENEREGY PROGRESS DUKE ENERGY PROGRESS, LLC C%%%tttttttt!tH', t SF- i / •v: ;.�,:. �, . f� Evan Yurkovich .' p�Oo J � Project Manager .•4tQUr IC tttttt. Christopher Suttell, NC L.G. 2426 Senior Geologist 'Kr*� U i% Kathryn W. Webb Senior Peer Review L 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 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 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 Project:00.0060.17 r 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 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 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 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 • 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 Project:00.0060.17 f t 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 Project:00.0060.17 T t 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 Project:00.0060.17 r t 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 Project:00.0060.17 r 1 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 r s 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 r t 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 � S 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) www.synterracorp.com PROJECT MANAGER E YURKOVICH 4. ey,a. 4 I UP,{Olt RE1 Rj . L-.WNSTREA[I S'IAT)()OI, •- �.\ FRI--IN .1 A I ruv 11 LAM ' A• ,d ♦i ✓ Fl LEI RIVLRI 1 . ,�-•�: . 'BOA rl `., r UPSTREAM ," /`� •: :� SHAOOOX • '� " CREEK L 0 / ' '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 �,� PROJECT WWWS D[erracor•.DOIN • UPS WI AM] I HAW RIVER ++ff DOWNS I RL.AM hh SHADDOX CRTEK - LIPS IRIAM //I" •\. �� "� ✓'�10* � --� DTI I,RIYFM / �• • ,' di, • � UPSTR -` /I# Gb •I _ • CREEK ^•. —_ _ ,/' I IEi I 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 C. APPROVE) c60 00100 w*c.a2inI CAPE FEAR STEAM ELECTRIC PLANT „ Ten a, TM.NNIER.E.�R6oaER MONCURE,NORTH CAROLINA WWW.5 n[erracon.com ,c7: ''„.. I \ / j , e .1 A .. J `v- �••._ a •-_,. m l • HA'' I I •_` LEGEND 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) f A rfi •*' a 1 , 1 , ‘ k yr , N itiep w te, ii4 - fi ,,,-- '', •lir,.„. , ., , . -'.. "JO .• _,_ • ••""' _ 1 1 • oo, , \\,... 4/P• , ' ' •. . ' 2.,,,-4 ........0/. • ...,,,.\ * ' x 4kk, NI). , ... 4 I. \ L;C‘ elas'2. 4 * sc sg7 c7 Q" ltk CP2'6. N.' 41044 io al _ ,... (1) f...- „.„- 19R5 Ash Basin As , N" i i I, .„,- - • , Upstream — Deep River, Haw River & Shaddox Creek Downstream —Shaddox Creek Cape Fear Plant — Water Quality Monitoring (South) r 49411L iitr' • N 44,14140._ ♦, a 0) 1985 Ash Basin • -a CD T CD LU 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 4". synTerra Science & Engineering Consultants • S-7 S-8 S-15 i 120 120 120 J 9D J 9D J 90 v O O Q N p IT E. a`r 60 8 60• 80 U U 0 U u u u a w m 1,2 30 a 30 30 Date Date m Date S-16 120 rn 90 c O l m 60 Space not used. Space not used, 0 U u m a 30 0 Date LEGEND: NOTES: DUKE DRAWN BY:R.BADUM DATE:6/17/1012 FIGURE 1 —0—Non-detect • Data presented on concentration plots includes all sampling programs. 'I ENERGY REVISEDBY: DATE: TIME VERSUS TOTAL ARSENIC CONCENTRATION --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 • • ElevatedTS5concentrationsmayhaveinfluencedincreasedconstituentconcentrationsatS-15during CAPE FEAR STEAM ELECTRIC PLANT -Statistically Significant Increasing Trend the OR icro 23,2018 sampling event synTerra No Color-Cannot Analyze for Trends • pg/l-micrograms per liter wwwsynterracorp.com MONCURE,NORTH CAROLINA . w S-7 S-8 S-15 150 .— 150 150 J J J O 100 "100' .100• 0 o c 0 m m U N C c U U 0 U E 50• I 50- E 50, m m ro co Date ' o.Date Date J w S-16 150 J a, 1 "'100• 2. 2 c d L' Space not used. Space not used. 0 U E 50 ZE m ..--------.--•.-..„/j\N--• • Date LEGEND: NOTES: 'irI DUKE DRAWN BY:R.BADUM DATE:6/27/2022 FIGURE 2 —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 • Elevated TSS concentrations may have influenced increased constituent concentrations atS-15 during -Statistically SignificantIncreasing Trend the October 23,2018 sampling event S�/t1T21"Ccl CAPE FEAR STEAM ELECTRIC PLANT No Color-Cannot Analyze for Trends • Pa-micrograms per liter www.synterracorp.com MONCURE,NORTH CAROLINA S-7 S-8 S-15 7500 7500 7500 f J J J ab a 5000 3 5000 -=5000 4 .4 0 m m c 8 u U U U 0 2500 0 2500 0 2500 o 0 CO CD CO 0 0 0 0 Vl- N a Date m a; Et, v Date e s V m Date 2 w S-16 7500 -J P 5000 0 m Space not used. Space not used. ci g 2500 0` co 0 mDate 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 • CAPE FEAR STEAM ELECTRIC PLANT No Color-Cannot Analyze for Trends synTerra www.synterracorp.com MONCURE,NORTH CAROLINA I _ S-7 S-8 S-15 6000 6C00 6000 J 2- j O di 4000' &4000 40o0 0 0 0 5 Ei C. O' yy U U iO 0 U U U 0 2000 v 2000 0 2000 e e o m CO •..., COl am• • 0 0 0 Date — Date J Date S-16 h020 J Y 4000 m d ci Space not used. Space not used. \—0--0-0 a 2000 E e m 0 in Date 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 No Color-Cannot Analyze for Trends syriTerra www.synterracorp.com MONCURE,NORTH CAROLINA S-7 S-8 S-15 J J S O - O z O N N q C U W O O p U U U = 1 E 1- E = 1 0 0 0 a a E U o o U O O O O O O 0 0 0 Date Date - :- _. ,. / ., Date S-16 7 a z 4 2• 8 o Space not used. Space not used. 0 E E1 O m U u rn 1 g A/ ti Date 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 /nTor `'7 n e No Color-Cannot Analyze for Trends 1U ww s terracorp.com MONCURE,NORTH CAROLINA w.yn S-7 S-8 S-15 45 r.— 45 45 J J J E E ? 30 - 30 . 30 c, o O m m m c E• c 8 u c U U c U D 15 It TT 15 o 0 0 U U t U 0 0., p w Date Date Date S-16 45 J_ 0 30• 0 P c oSpace not used. Space not used. U a 15 1 c U 0." o, m Date w DUKE 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 4 4 4 J ei 3co 3 rn 3 `o_ .4 `o B m u 2 u 0 8 0 E E E E E E Q t o 00 0 0 0 0 0 0 0 0 0 .21• 0 00 0 0 0 0 0 0 0 0 0 o f 0 o V n o v ti Date Date Date S-16 13)3. .33 C. i2 Space not used. Space not used. E E ° l 0 0 0 0 0 0 0 0 0 0 L V o• . Date 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 10 to. to 8 8' 8 J J q . m 6 m 6 6 "O. 8 8 v 0 U4 041 U4 a o 0 a 2. 2• U 2 • 0 0 0 Date Date l Date U S-16 10 8• 0 6 m o Space not used. Space not used. U 4- m a a 0 U 2 0• Date 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. . No Color-Cannot Analyze for Trends • pg/L-micrograms per liter www.synterracorp.com MONCURE,NORTH CAROLINA • S-7 S-8 S-15 6 g .1 : J E E Ise- E E c a c a c 4. o B A m m 8 c c c o U o U 72 2 0 2 a, 2 0 0 C O LL LL LL O O 0 0 0 p Date Date Date S-16 6 I4- Space 23 not used. Space not used. U a 2' 0 LT_ 0• mh 'D 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 • S-7 S-8 S-15 1600 1600 1600 E 1200 q 1200 'o E E 1200 f c c 0 o ° g m @ u 600 u 600 600., O 0 Icsu 140: 140: NyCv 0i 3 2 2 4 3 3 • Date to Date 'pab S-16 1600•••11— 11200 c 8 600 o Space not used. Space not used. U N d C ly 400' ( H V E. W Date 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 -statisticallysignif ant Increasing Trend pg/L-micrograms per liter CAPE FEAR STEAM ELECTRIC PLANT No Color-Cannot Analyze for Trends synTer a ww : terracorp.com MONCURE,NORTH CAROLINA w.yn S-7 S-8 S-15 .1 4 4 J 3 J 3 j 3. ioa L 52. ` • 2 o C U U U m w N01 O • l 1• 0 0 0 O O p\\\\ 0./ 1• O O ��� O O O O O O 0 Or 0 0 . .. r. Date .: - Date - Date S-16 s 0 V 2 8 Space not used. Space not used. 0 U N0) V 0 0 0 0 0 D .} aa Ci o chi g N g h to m m Dale o -LL N w 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 - -- — 2e-00 2e+00 • zB-of 2e at -- 2-01 7 • 0 o O N A u 2e-02 u 2e-02 S 2e-02 U U 0 U r U U 2e-03 2 2e-03 ge_03 • 2e-04 2e-04 -�- 2:-04 Date Date m Date S-16 �, 2-0,- 0 :i: i Space not used. Space not used. 2e-04 --—--- • u a o N W Date 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 J J T a p, 200' =200 a 200 O O (q Nyy qyy U U U U S. C U 1 100 m 100 s 10c u Z Z Z 0- • ��• •• •• •• •• •• •• •• •• 0'. --• + • •• _ _ _ ... _ ♦ 0 Date Date Date J S-16 300 Li 200 `o ♦ m 1 Space not used. Space not used. 0 U m 100. sz 0 u w a Date o N W LEGEND: NOTES: DUKE DRAWN BY:R.BADUM DATE:6rznizozc FIGURE 13 Non-detect • Data presented on concentration plots includes all sampling programs. ENERGY REVISED BY: DATE: TIME VERSUS TOTAL NICKEL CONCENTRATION i-Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRFS': CHECKED BY:K.FERRI DATE:1112/3011 SEEP MANAGEMENT PLAN 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 Stable,no trend'if analyzedican[Decreasing TrendII y2P PROJECT MANAGER,E.YURKOVICH MANN-KENDALL TREND TEST ANALYSIS -Statistically Significant Increasing Trend • Hg/L-mlcrogramz per liter 5)/t 1TeRa CAPE FEAR STEAM ELECTRIC PLANT No Color-Cannot Analyze for Trends WWw.synterracor MONCURE,NORTH CAROLINA p.com S-7 S-8 S-15 10 10 ID J J J E e' 9 E 8 o G c m m o c 6 0 o 0 O O O O 0 0 0 0 0 0 0 0 o 0 0 0 0 0 0 0 0 0 U 0 U v 4 w w q. 4 W T 2..' c 2 2 0 Z O O p 0 0_ p Date m Date y Date S-16 to J O 8 E c 0 • c 6' U 0 0 0 O 0 0 0 O Space not used. Space not used. N 4 m En V C 2. 0 • Date LEGEND: NOTES: DUKE DRAWN BY:R.BADUM DATE:6/27/2022 FIGURE 14 - Nan-detect • Data presented on concentration plots indudes all sampling programs. /ENERGY REVISED BY: DATE: TIME VERSUS OIL AND GREASE CONCENTRATION - Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERRI DATE:7/12/2021 SEEP MANAGEMENT PLAN 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 -Stable,no trends there Is no color the data could not be analyzed for trends `� MANN-KENDALL TREND TEST ANALYSIS -Statistically Significant Decreasing Trend yze PROJECT MANAGER:E.YURKOVICN • -Statistically Significant Increasing Trend /nTorr7 ''7 n e 1U pg/L-micrograms per liter � CAPE FEAR STEAM ELECTRIC PLANT No Color-Cannot Analyze for Trends wwwsyntemarorp.com MONCURE,NORTH CAROLINA S-7 S-8 S-15 12 s 12 12 • • • 10. 10 10 c I D 8 D 8 D 8 p -2 a to 9 22 9 FF../ WIN in 8 % 8 05 8 a a =o. 4 4 4 2 2 3 2 2 DM* it.Date Date S-16 12 10 D a 2 43 Space not used. Space not used. vt 8 a 4 2 0 -Date LEGEND: NOTES: t�DUKE �IDRAWN BY:R.BADCM DATE:Bl2T/2022 FIGURE 15 -0-Nan-detect • Data presented on concentration plots includes all sampling programs. ' ENERGY REviSEDBY. DATE. TIME VERSUS pH -0-Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERW DATE:7n2/2022 SEEP MANAGEMENT PLAN responding reporting limit. • Time vs total pH plat for all locations with available data.Trends are denoted by the box Color,if there APPROVED BY:E.YURKOVICH DATE 0/19/2022 APPENDIX B 111-Stable,no trends color the data could not be analyzed for trends `� MANN-KENDALL TREND TEST ANALYSIS -SStatlstically$Ignificant Decreasing Trend y2e PROJECT MANAGER:E.YDRKOVICH -StatisncallySgnificantincreasingTrend CAPE FEAR STEAM ELECTRIC PLANT No Color-Cannot Analyze for Trends synTerra www.synterracorp.com MONCURE,NORTH CAROLINA S-7 S-8 S-15 .. 2 J -J J 0- m 01 C O o m c°�' 1• O 00 O O O O O O O O o 8 1- 0 00 O O O O O O O O 0 u 1- o O O O O 0 0 O O o U U o U E E E m m `m m • cn rn <n 0 G . Date .. Date - Date S-16 0 0 0 0 0 0 0 0 0 0 Space not used. Space not used. U E 0 0 On o 9 Date LEGEND: NOTES: !`DUKE DRAWN BY:R.BADUM DATE:6/27/2022 FIGURE 16 • Data presented on concentration plots includes all sampling programs. V'ENERGY REAISEDBY: DATE: TIME VERSUS TOTAL SELENIUM CONCENTRATION -0-Non-detect f 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. • T me vs total selenium plot far all locations with available data.Trends art denoted by the box color,if APPROVED BY:E.YURKOVICH DATE:11/1812022 APPENDIX B Stame,nptregni • there is no color the data could not be anal d for trends 0MANN-KENDALLTRENDTESTANALYSIS 111 - Statistically Significant Decreasing Trend y2P PROJECT MANAGER:E.YURKOVICH -Statistically Significant Increasing Trend • HKiL-micrograms per liter synTerra CAPE FEAR STEAM ELECTRIC PLANT No Color-Cannot Analyze for Trends www.synterracorp.com MONCURE,NORTH CAROLINA Y II S-7 S-8 S-15 3000 3000 3000. u __or) u O , E 2000 E 2000• E 2000 8 u g c t m u o0 c 50 0 El 1 0 0 1000 1000• 0 1000 • • 40 u u fin In 0 o 0+ U Date a Data Date S-16 3000 • 0 L E 2000 i c m t Space not used. Space not used. 0 U 1000 u n v1 0 C. PS Lel Date LEGEND: NOTES: elliNDUKE DRAWN By:R.BADIIM DATE'.sratia022 FIGURE 17 ,-0-rvon-detect • Data presented on concentration plots includes all sampling programs. ENERGY REWSEDBv'. DATE. TIME VERSUS SPECIFIC CONDUCTANCE +Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERRI DATE m2/2022 SEEP MANAGEMENT PLAN corresponding reporting limit. • Time vs specific Conductance plot for all locations with available data.Trends are denoted by the box r APPROVED BY:E.VURKOVICH DATE:8/1912022 APPENDIX B -Stable,no trendsIll color,if there is no color the data could not be analyzed for trends `� PROTECT MANAGER:E.vuRKwlcn MANN-KENDALL TREND TEST ANALYSIS -Statistically Significant Decreasing Trend • pmhos/cm-micromhos per centimeter -Statistically Significant Increasing Trend TefCC� CAPE FEAR STEAM ELECTRIC PLANT No Color-Cannot Analyze for Trends I www.synterracorp.com c MONCURE,NORTH CAROLINA w.yn erracorp.com 4 S-7 S-8 S-15 3000 3000 3000 J J J m E 2000 E 2000 2000 c c g o a m m m 8 8 c m c U U D U le 1000 m 1000 m 1000 n 3 (n f n 0-4.0.--0-0---A—•—•---.4 • •---• • — • • •• • • 0 • 0 0 Date Date Jo Date S-16 3000 J co - 2000 c 0 m 8 Space not used. Space not used. 0 U v 1000 m 3 (n pl c. a;Date LEGEND: NOTES: (�• DUKE DRAWN BY,R.BADUM DATE'612712022 FIGURE 18 `/ Non-detect • Data presented on concentration plots includes all sampling programs. ENERGY REv6EOBY: DATE, TIME VERSUS TOTAL SULFATE 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 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 -Statistically Significant Decreasing Trend • y PROJECT MANAGER:E.YURKOVICH -StatisticallySignif<antIncreasingTrend mg/L-millogramsperliter CAPE FEAR STEAM ELECTRIC PLANT No Color-Cannot Analyze for Trends synTerra WWw.synterracorp.com MONCURE,NORTH CAROLINA r r S-7 S-8 S-15 30 30 30 U20 U20 U20 § m 0w al E E a E H 10 113 10 10 0 o I I I us w Date m N a Date Date S-16 30 U 20 m m Space not used. Space not used. B E w I— 10 0 Date — LEGEND: NOTES. 'ilk,DUKE DRAWN BY:R.BADUM DATE 6/20/2022 FIGURE 19 Non-detect Data presented on concentration platsindudes all samplingprograms. 'ENERGY REVISED BY: DATE: TIME VERSUS TEMPERATURE —0—♦-Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERRI DATE:ln2/2022 SEEP MANAGEMENT PLAN corresponding reporting limit. I Stable,no trends • Time vs te no color the data t for all locationsanalyzed for trends le data.Trends are denoted by the boo color,if APPROVED BY:E.YURKOVICH DATE:8/19/2022 APPENDIX B -Statistically Significant Decreasing Trend there is no color the could not be analyzed for trends �� PROTECT MANAGER:E.YURNOVICH MANN-KEN DALL TREND TEST ANALYSIS -StatisticallysignifcantlncreasingTrend CAPE FEAR STEAM ELECTRIC PLANT No Color-Cannot Analyze for Trends synTerra www .synterracorp.com MONCURE,NORTH CAROLINA 0 S-7 S-8 S-15 J _J J _1 O, o, O C 2. O C 2 p < T. T C C S g o 0 0 0 U E t . t. E t 76 t m H //�L�\ I— F //�\ ^v--0--0--0-0--OvO• O 0 0 0 0 0 0 0 0 0 0 0 0 C O o 0 0 0 0 o O Or 0 p Date Date a v a Date e J H ,. S-16 31 J d O O c 2, C s Space not used. Space not used. U m L r 0 4 9 Date 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 —0—- Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERRI DATE:)IeL2D22 SEEP MANAGEMENT PLAN responding reporting limit. • Tiome vs total thallium plot for all locations with available data.Trends are denoted by the boo color,if APPROVED BY:E.YURNOWCH DATE:en9l2oz2 APPENDIX B -stable,no trends there is no color the data could not he analyzed for trends 0 PROJECT MANAGER:E.VURNOVICH MAN N-KEN DALL TREND TEST ANALYSIS -Statistically Significant Decreasing Trend • -Statistically Significant Increasing Trend pg/L-micrograms per liter CAPE FEAR STEAM ELECTRIC PLANT No Color-Cannot Analyze for Trends synTerra www .synterracorp.com MONCURE,NORTH CAROLINA ra r S-7 S-8 S-15 3000 3000 3000 E E c c Q 2 2000 E8 2000 & 2000 U U O U .- o v (.1)6 (°n o n N 1000 ? 1000 , 1000 1 u2.O N N_ O 0 O • , N ♦ N H T �� 0 0 0 0 1.4 e Date Date m Date S-16 3000 C, E c 0 c 2000 `o U 9 Space not used. Space not used. 0 co m 1000 O O m 0 I- 0 H a 4 a Date LEGEND: NOTES: ebbs DUKE DRAWN BY:R.DAMN DATE:6121/2022 FIGURE 21 -0-Non-detect • Data presented on concentration plots includes all sampling programs. ` ENERGY REVISED BY: DATE: TIME VERSUS TOTAL DISSOLVED SOLIDS CONCENTRATION AI-Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERRI DATE:7112/2022 SEEP MANAGEMENT PLAN corresponding reporting limit. !ITim¢vs total dissolved solids plot for all locations with available data.Trends are denoted by the hoc APPROVED BY:E.YURKOVICH DATE:8e012022 APPENDIX B -Stable,no trends color,if there is no color the data could not be anal d for trends 0MANN-KENDALL TREND TEST ANALYSIS -Statistically Significant Decreasing Trend y26 PROJECT MANAGER:E.YURKOVICH -Statistically Significant increasing Trend mg/L-milligrams per liter • CAPE FEAR STEAM ELECTRIC PLANT No Color-Cannot Analyze for Trends synTerra www.: t MONCURE,NORTH CAROLINA yn erracorp.com A Ill S-7 S-8 S-15 400 400 400 J J J 5 ? E c e 300 300• m 300• c c c c U U a U ✓ 200 Y 200• ,a 200. (1) (P) O n a o a c c c n 100 N 100• n in. (n CO CO m m .____7-. .-4 7\__. o F - -DateR Date Date m S-16 LI- C O T 300• C of UU C O O 200- (S— Space not used. Space not used. 4, ar v N 100• S' rn T.o 0 • o+ 0 m Date 1EMita NOTES` (��DUKE DRAWN BY:R.BADUM DATE:Y11I2022 FIGURE 22 -O-Non-detect • Data presented on concentration plots indudes all sampling programs. ` ENERGY REVISED BY: DATE: TIME VERSUS TOTAL SUSPENDED SOLIDS CONCENTRATION -1111--Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERRI DATE:11122022 SEEP MANAGEMENT PLAN corresponding reporting limit. I • Time vs total suspended solids plot for all locations with available data.Trends are denoted by the boo APPROVED BY:E.YURKOVICH DATE:vroico22 APPENDIX B -Stahle,no trends color,if there is no color the data could not be analyzed for trends -Statistically Significant Decreasing Trend • PROJECT MANAGER:E.TURKOVICH MA N N-K EN DALL TREND TEST ANALYSIS -Statistically Significant Increasing Trend mg/Lmilllgrams per liter r� �^ CAPE FEAR STEAM ELECTRIC PLANT No Color-Cannot Analyze for Trends �1 ITeIr1a www.synterracorp.com MONCURE,NORTH CAROLINA A 1S S-7 S-8 S-15 600 eoo rl... J' J _ 'L..'.400 d 400 m 400 c _ a 4 0 m m m c U N U U U 0 U aoo 0 200 200 N CIr:_ _ _A.7._..___.7___ _7. .... N P. Date Date ' Date S-16 600 sen 400 0 u Space not used. Space not used. `o U u 200 I 07 8 Date 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 -•-Detect • Data presented may include lab-qualified results.Non-detect analytical results are plotted at the PROGRESS CHECKED BY:K.FERRI DATE:11t2/2021 SEEP MANAGEMENT PLAN corresponding reporting limit. Time vs total zinc for all locations with available data.Trends are denoted by the box color,if there is APPROVED BY:E.YURKOVICH DATE:8/19/2022 APPENDIX B U Stable,no trends no color the data could not be analyzed for trends -StatisticallytSignificantDecreasingTrend y �, PRo2ECTtAANACER:E.YDRKovicH MANN-KENDALLTRENDTESTANALYSIS • • Elevated TS5 concentrations may have influenced increased Constituent concentrations at S-15 during -SlatisBcally Significant Increasing Trend the October 23,2018 sampling event CAPE FEAR STEAM ELECTRIC PLANT No Color-Cannot Analyze for Trends • pg/L-micrograms per liter synTerra www.synterracorp.com MONCURE,NORTH CAROLINA 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.