NC0005088_SOC (amendment)_20191122

DUKE Paul Draovitch, P.E.
Senior Vice President
Environmental, Health&Safety
ENERGY�� and Operations Support
526 S. Church Street
Mail Code:EC3XF
Charlotte, NC 28202
[phone]
November 22, 2019
Linda Culpepper, Director
NC Division of Water Resources rr��
1617 Mail Service Center -! fid
Raleigh, NC 27699-1617
Subject: SOC amendment application
Marshall and Rogers stations
EMC SOC WQ S 17-009
Dear Ms. Culpepper,
Enclosed please find an application for amendment of the subject Consent Order. A fee in the
amount of$400.00 is enclosed with this submittal.
If there are any questions about this matter, please contact Mr. Shannon Langley at (919) 546-
2439 or [e-mail].
incer y,
Pau Draovitch NOV 2 LA
Senior Vice P esident
Duke Energy
DIVISIOr: ,... wA1,
i._ D! FOC'
Enclosure
Cc: MRO DEQ WQ Supervisor w/enclosure
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Jeff Poupart—DWQ Section Chief w/enclosure
1617 Mail Service Center
Raleigh, NC 27699-1617
www.duke-energy.com

Ms. Linda Culpepper
SOC 17-009 amendment request
November 22, 2019
Robert Wylie/FileNet- via email
Shannon Langley—via email
Jim Wells - via email
Richard Baker—via email
Matt Hanchey—via email
Rick Roper- Station Manager
Art Barnhardt—Station Manager

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
APPLICATION FOR AN AMENDMENT TO A SPECIAL ORDER BY CONSENT
I. GENERAL INFORMATION:
1. Applicant (corporation, individual, or other): Duke Energy Carolinas, LLC.
2. Owner Phone: [phone] (or)
3. Owner Email: [e-mail]
4. Facility Name (must be the same as name on the original SOC):
Marshall Steam Electric Generating Station and Rogers Energy Complex
5. Original SOC No. /Issuance Date: EMC SOC WO S 17-009 approved 4/12/18
6. NPDES Permit No. (if applicable): NC0004987 and NC0005088
5. Application Date: November 15, 2019
II. SOC COMPLIANCE HISTORY:
Please attach a listing of all violations this facility has had under this Order. Include any
violation of interim dates, relaxed permit parameters, and existing permit limits. See attached.
III. ADDITIONAL FLOW OR REALLOCATION OF EXISTING FLOW:
Only facilities owned by a unit of government may request to add additional flow to the
treatment system as part of this SOC Amendment in accordance with NCGS 143-215.67(b).
Additional flow may be allowed under an SOC amendment only in specific circumstances.
These circumstances may include eliminating discharges that are not compliant with an NPDES
or Non-discharge permit as specified in the original SOC. These circumstances do not include
failure to perform proper maintenance on treatment systems, collection systems or disposal
systems. When requesting additional flow, the facility must include its justification and
supporting documentation. If the requested additional flow is non-domestic, the facility must be
able to demonstrate the ability to effectively treat the waste and dispose of residuals. The
applicant must provide a detailed analysis of all constituents in the proposed non-domestic
wastewater.

The total domestic additional flow requested: _N/A gallons per day.
The total non-domestic additional flow requested: _N/A gallons per day.
The total additional flow (sum of the above): _N/A gallons per day.
If a reallocation of existing additional flow is needed the facility must provide justification as to
why this reallocation is needed.
Any additional flow that may be allowed will be determined by an analysis of projected adverse
impacts on the wastewater treatment facility and/or surface waters.
IV. WHY AN SOC AMENDMENT IS NEEDED:
Please provide a detailed explanation as to why the SOC amendment is being requested. Include
actions already taken to avoid noncompliance with the existing SOC. Also provide details on
activities that were delayed. See attached.
THE DIVISION OF WATER RESOURCES WILL NOT ACCEPT THIS APPLICATION
PACKAGE UNLESS ALL OF THE APPLICABLE ITEMS ARE INCLUDED WITH THE
SUBMITTAL.
Required Items:
a. One original and two copies of the completed and appropriately executed application
form, along with all required attachments.
• If the SOC Amendment is for a City/Town, the person signing the SOC must be
a ranking elected official or other duly authorized employee.
• If the SOC Amendment is for a Corporation / Company / Industry / Other, the
person signing the SOC must be a principal executive officer of at least the level
of vice-president, or his duly authorized representative.
• If the SOC Amendment is for a School District, the person signing the SOC must
be the Superintendent of Schools or other duly authorized employee.
Note: Reference to signatory requirements in SOCs may be found in the North
Carolina Administrative Code [T15A NCAC 2H .1206(a)(3)].
b. The non-refundable Special Order by Consent (SOC) processing fee of $400.00. A
check must be made payable to The Department of Environment and Natural
Resources.
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APPLICANT'S CERTIFICATION:
(NO MODIFICATION TO THIS CERTIFICATION IS ACCEPTABLE)
I, _Paul Draovitch , attest this application for a Special Order by Consent
(SOC) amendment has been reviewed by me and is accurate and complete to the best of my
knowledge. I understand if all required parts of this application are not completed and if all
required supporting information and attachments are not included, this application package may
be returned as incomplete. (Please be advised that the return of this application does not prevent
DWR from collecting all outstanding penalties upon request). Furthermore, I attest by my
signature that I fully understand that an upfront penalty, which may satisfy as a full
settlement for past violations, may be imposed. {Note: Reference to upfront penalties in
Sp ial ders by ent may be found in the North Carolina Administrative Code [T15A
NCAC 2H 1206(c)(3)].
` — Date /.901-
Signature of Sign. g Official �� V
Paul Draovitch, SVP, Duke Energy
Printed Name of Signing Official
THE COMPLETED AMENDMENT APPLICATION PACKAGE, INCLUDING ALL
SUPPORTING INFORMATION, SHOULD BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER RESOURCES
POINT SOURCE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1617
IF THIS APPLICATION IS FOR A NON-DISCHARGING SYSTEM, THEN SEND TO:
NORTH CAROLINA DIVISION OF WATER RESOURCES
AQUIFER PROTECTION SECTION
1636 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1636
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II. SOC COMPLIANCE HISTORY: and
IV. WHY AN SOC AMENDMENT IS NEEDED:
Marshall Station
The Marshall facility has complied with all dates as required by the Special Order by Consent.
These include conversion to 100% dry fly ash, conversion to 100% dry bottom ash and cessation
of all inflows and initiation of ash basin decanting. The next compliance date for the facility is
the completion of decanting which is March 31, 2021.
Sampling required by the SOC was undertaken and complied with all requirements for the first
year. The station has recently experienced an increase in the total hardness values at sampling
location S-1 above the Interim Action level set by the SOC. Duke Energy has initiated a
response to this result which has included interim measures used to remove hardness from the
flow. These measures have shown success however, appear to be of short duration and require
extensive maintenance. Duke is interested in moving to more long-term sustainable actions and
is evaluating those options. Those more extensive options will be detailed in the report being
prepared in response to the exceedence along with the groundwater corrective action plan (CAP)
to be submitted for the facility. That SOC exceedence assessment response will be submitted in
late November.
Based on Duke's analysis so far, it appears that the hardness levels associated with sampling
location S-1 may be the result of changed site conditions, with the result that S-1 may continue to
exceed the hardness levels established in the SOC for a period until more permanent measures
can be developed. The exceedances are not the result of poor operation or maintenance of the
ash basin. As stated, above, the ash basin has been removed from service and is currently being
decanted. Duke is requesting relief while the company and the Department evaluate what, if any,
new permanent measures are required.
Duke has completed the sampling for October and was able to demonstrate compliance using
filter socks with ion exchange resin.
Hardness in water is a secondary standard, in place mainly for aesthetic reasons related to scale
in piping and difficulty in lathering of soaps. There is no health or environmental concern
associated with water hardness. In fact, it is well established that water hardness can inhibit
uptake of other metals by aquatic life.
Duke Energy is undertaking measures to address the water hardness in the samples. Duke
Energy requests re-evaluation of the IAL for hardness in the small tributary.
Rogers Energy Complex
The Rogers Energy complex has complied with all milestone dates and interim limits in the SOC
to date. As reported to the Department at the time, lowering of water levels in the Active Ash
Basin during basin decanting resulted in unexpected internal ash movement. Out of caution, the
station halted decanting until the effects of the ash movement were understood. This, coupled
with the requirement to lower the basin no more than 1 foot per day imposed by Dam Safety,
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leave little margin for additional setbacks outside the company's control, creating the risk that
the company will not be able to complete decanting by March 31, 2020. Duke Energy continues
to undertake actions to comply with the date but also requests relief of this interim milestone
date. Duke requests the completion of decanting date be extended to August 31, 2020. Duke
does not request an extension of the final expiration date.
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