NC0003425_Seep Management Amendment to CAP_20200902

DUKE
ENERGYY,
September 2, 2020
Via Overnight Mail
S. Daniel Smith
Director of Water Resources
North Carolina Department of Environmental Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Rick Bolich
Section Chief, Groundwater Resources Section
North Carolina Department of Environmental Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Report Under Special Order by Consent — EMC SOC WQ S 18-005
Duke Energy Progress, LLC — Roxboro Steam Electric Plant
NPDES Permit NC0003425
Seep Management Plan Amendment to Corrective Action Plan
Dear Messrs. Smith and Bolich:
Paul Draovitch
Senior Vice President
Environmental, Health & Safety,
CCP and Operations Support
526 S. Church Street
Mail Code: EC3XP
Charlotte, NC 28202
[phone]
On behalf of Duke Energy Progress, LLC (DEP), I am submitting to you the Seep Management
Plan Amendment to Corrective Action Plan as required by the Roxboro Steam Electric Plant
NPDES Permit NC0003425 Special Order by Consent (SOC), SOC No. S 18-005, Section 2.d.
This report follows the Seep Characterization Report submitted on July 6, 2020 and addresses
management of non-dispositioned seeps at the Roxboro site.
Please direct any questions about this submittal to Kim Witt at [phone] or Chris Hallman
at [phone].
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,

Messrs. Smith and Bolich
September 2, 2020
Page 2
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Sincere ,
Paul Draovi
Senior Vice President
Environment, Health & Safety. CCP and Operations Support
Duke Energy
Attachment:
Roxboro Steam Electric Plant Seep Management Plan Amendment to Corrective Action Plan
cc: Jim Wells, Duke Energy
Ed Sullivan, Duke Energy
Matt Hanchey, Duke Energy
Richard Baker, Duke Energy
Shannon Langley, Duke Energy
Lori Tollie, Duke Energy
Kim Witt, Duke Energy
Chris Hallman, Duke Energy
Robert Howard, Duke Energy
Bob Sledge, NCDENR

1610
synTerra
SEEP MANAGEMENT PLAN AMENDMENT TO
CORRECTIVE ACTION PLAN
ROXBORO STEAM ELECTRIC PLANT
1700 ❑UNNAWAY ROAD
SEMORA, NC 27343
SEPTEMBER 2,, 2020
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Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
EXECUTIVE SUMMARY
SynTerra prepared this Seep Management Plan Amendment to the Corrective Action
Plan (CAP) Update report (SynTerra, 2019) pertaining to the Roxboro Steam Electric
Plant (Roxboro or Site) to describe plans for management of identified seeps in a
manner that protects public health, welfare, the environment, and natural resources.
This amendment to the CAP Update was prepared on behalf of Duke Energy Progress,
LLC (Duke Energy).
Special Order by Consent (SOC) WQ S18-005, approved on August 15, 2018, addresses
management of seeps at the Site for the East Ash Basin (EAB) and the West Ash Basin
(WAB) during the process of basin closure under the Coal Ash Management Act of 2014
(CAMA), North Carolina General Statutes (G.S.) 130A-309.200 through 130A-309.231
and the federal Coal Combustion Residuals (CCR) rule, 40 CFR Parts 257 and 261. SOC
Section 2(d) Further Corrective Action states:
"Within 60 days of the submittal of the Seep Characterization Report, Duke
Energy shall submit a complete and adequate proposed amendment to the
groundwater Corrective Action Plan and/or Closure Plan as appropriate for the
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."
Findings in the July 2020 Seep Characterization Report (SynTerra, 2020b) indicate
identified seeps are either candidates to be dispositioned, recently covered under the
Site's National Pollutant Discharge Elimination System (NPDES) Permit, or do not
exhibit constituent concentrations that warrant additional corrective action. In order to
be considered for corrective action, 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 02B surface
water standards
Four non -constructed seeps (S-08, S-14, S-18, and S-20) have been identified based on
the above mentioned criteria.
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Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
Three of those seeps (S-08, S-14, and S-18) do not constitute, or flow to, WOS or
WOTUS. However, according to the SOC disposition criteria indicated in SOC Section
2(c)(3), these seeps are not available to be dispositioned.
Historically, visible flow at the signed location for seep S-20 that reached WOS or
WOTUS has been minimal and intermittent. Three consecutive quarterly observations
(Fourth Quarter 2019, First Quarter 2020 and Second Quarter 2020), as presented in the
Seep Characterization Report (SynTerra, 2020b), indicated that flow was not reaching
WOS or WOTUS at those times. An August 14, 2020 inspection of S-20 and the
wetland/stream complex below the signed seep location, indicated minimal,
intermittent seep flow may be reaching WOS or WOTUS. Therefore, S-20 remains as a
non-dispositioned seep.
Seep ID Description
East Ash Basin
S-14 This non -constructed seep does not constitute, and does not flow to,
WOS or WOTUS; however, per SOC disposition criteria, this seep is not
available to be dispositioned based on seep status or receiving water
body jurisdiction determination (JD). The seep is at the discharge point
of a 24-inch underground pipe that flows from the unnamed pond north
of the EAB to the gypsum storage area wastewater detention basins.
When flowing, seep discharge flows through a series of ditches to the
heated water discharge pond, a portion of the NPDES-regulated
wastewater treatment system and is acknowledged as a contributing
flow in the NPDES permit.
West Ash Basin
w:
This non -constructed seep does not constitute, and does not flow to,
WOS or WOTUS; however, per SOC disposition criteria, this seep is not
available to be dispositioned based on seep status or receiving water
body JD. When flowing, this seep flows to the heated water discharge
pond, a portion of the NPDES-regulated wastewater treatment system
and is acknowledged as a contributing flow in the NPDES permit.
S-18 This non -constructed seep does not constitute, and does not flow to,
WOS or WOTUS; however, per SOC disposition criteria, this seep is not
available to be dispositioned based on seep status or receiving water
body JD. Seep S-18 is positioned within the decommissioned sluice line
corridor area.
S-20 This non -constructed seep does not constitute WOS or WOTUS. To the
west and topographically downgradient from S-20, is a small stream
channel flowing west through a wetland to a portion of an NPDES-
regulated wastewater treatment system (heated water discharge pond).
Per SOC disposition criteria, this seep is not available to be dispositioned
based on the NPDES-permitted receiving water body. If sufficient flow
has been observed, monitoring has been conducted prior to flows
reaching the NPDES-permitted waste water treatment system.
Page ES-2

Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
Duke Energy continues to implement ash basin closure and corrective action activities
that affect groundwater seepage. Ongoing and anticipated ash basin closure and
corrective action activities are summarized in the table below.
Year
Closure or Corrective Action Activity
2019 - 2020
Passive decanting of free water from the WAB.
2021 - 2034
Dewatering and closure of the WAB. Excavation of the WAB is planned
to be complete by 2034.
2021 - 2034
Dewatering and closure of the EAB. Partial excavation of the EAB is
planned to be complete by 2034. Dredging of saturated ash from the
EAB extension impoundment.
2021- 2029
Groundwater extraction north of the EAB geographic limitation.
Evaluation of boron concentrations, as a leading indicator for affected groundwater, at
seeps S-08, S-14, S-18, and S-20 using the Mann -Kendall trend test demonstrates stable
to decreasing trends. In addition to boron, trend tests were performed on constituents
with North Carolina Administrative Code (NCAC), Title 15A, Subchapter 02B — Surface
Water and Wetland Standards (02B). Overall, the results of the Mann -Kendall trend
analysis indicate that the seep discharge has been geochemically stable with constituent
concentrations remaining stable or decreasing over time.
As described in the CAP Update report (SynTerra, 2019) and based on findings from
seep characterization (SynTerra, 2020b), the following corrective action strategy for the
non-dispositioned seeps is summarized.
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Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
Seep ID
Corrective Action Strategy
East Ash Basin
S-14
Groundwater remediation by extraction is proposed north-northeast of
the EAB, which it is predicted to reduce flows and COI migration
toward the north and S-14.
West Ash Basin
S-08
Cessation of sluicing to the WAB initiated in April 2019. Dewatering,
source removal, and closure at the WAB is anticipated to reduce flow to
this location prior to eliminating the seep. Contributing flow is
monitored at NPDES Outfall 003. No additional corrective action for this
location is anticipated.
S-18
Cessation of sluicing to the WAB initiated in April 2019 followed by
decommissioning of sluice lines, substantially reduced flow at this
location. No additional corrective action for this location is anticipated.
S-20
Cessation of sluicing to the WAB initiated in April 2019 followed by
decommissioning of sluice lines, substantially reduced flow at this
location. WAB active decanting (if necessary), dewatering and closure
is predicted to cause flow to cease in the future. No additional
corrective action for this location is anticipated.
Non-dispositioned seeps are scheduled to be monitored as required by the SOC until
termination of the SOC by DWR or no later than June 2022. In addition, the contribution
of flows from seeps S-08, S-14, S-18, and S-20 will also be monitored under the NPDES
permit.
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Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
TABLE OF CONTENTS
SECTION
PAGE
EXECUTIVE SUMMARY....................................................................................................
ES-1
1.0
INTRODUCTION.........................................................................................................1-1
1.1
Background................................................................................................................1-1
1.2
Purpose and Scope....................................................................................................1-1
1.3
Previous Reporting...................................................................................................1-2
2.0
OVERVIEW OF SEEPS................................................................................................2-1
2.1
Seeps Associated with the East Ash Basin............................................................
2-1
2.2
Seeps Associated with the West Ash Basin...........................................................
2-2
3.0
PROPOSED SEEP MONITORING PLAN...............................................................3-1
3.1
Seeps for Corrective Action.....................................................................................3-1
3.2
Nature and Extent of Source Related Constituents and Seeps ...........................3-2
3.3
Ash Basin Closure and Corrective Action.............................................................3-4
3.4
Mann -Kendall Trend Analysis................................................................................3-4
3.5
Seep Corrective Action Strategy.............................................................................
3-5
3.6
Potential Seep Monitoring.......................................................................................
3-6
4.0
REFERENCES................................................................................................................
4-1
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Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
LIST OF FIGURES
Figure 1-1
Site Location Map
Figure 2-1
Existing Seep Locations and Inspection Areas
Figure 3-1
Proposed Seep Locations and Inspections Areas
Figure 3-2
Seep Trend Analysis with Boron Groundwater Plume Depiction
LIST OF TABLES
Table 2-1 Seep Locations and Descriptions
Table 3-1 Seep Sampling Results
LIST OF APPENDICES
Appendix A SOC WQ S18-005
Appendix B Mann -Kendall Trend Test Analysis
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Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
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
µg/L
micrograms per liter
CAMA
Coal Ash Management Act
CAP
corrective action plan
CCRs
coal combustion residuals
COI
constituent of interest
DWR
Division of Water Resources
EAB
East Ash Basin
EMC
Environmental Management Commission
G.S.
North Carolina General Statutes
IMAC
interim maximum allowable concentration
JD
jurisdiction determination
mg/L
milligrams per liter
NCAC
North Carolina Administrative Code
NCDEQ
North Carolina Department of Environmental Quality
NC L.G.
North Carolina Licensed Geologist
NPDES
National Pollutant Discharge Elimination System
Site
Roxboro Steam Electric Plant
SOC
Special Order by Consent
USEPA
U. S. Environmental Protection Agency
UT
Unnamed Tributary
WAB
West Ash Basin
WOS
Waters of the State
WOTUS
Waters of the United States
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Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
1.0 INTRODUCTION
SynTerra prepared this Seep Management Plan Amendment to the Corrective Action
Plan (CAP) Update report (SynTerra, 2019) pertaining to the Roxboro Steam Electric
Plant (Roxboro or Site) to describe plans to manage identified seeps in a manner that
protects public health, welfare, the environment, and natural resources. This
amendment was prepared on behalf of Duke Energy Progress, LLC (Duke Energy).
1.1 Background
In preparation of ash basin closure, passive decanting (removal) of free water from the
West Ash Basin (WAB) was initiated in April 2019 with the redirection of some
wastewater inflows from the WAB to the lined retention basin treatment system and the
elimination of other flows by dry ash handling upgrades. Passive decanting of the WAB
was determined completed, with notification to the North Carolina Department of
Environmental Quality (NCDEQ) Division of Water Resources (DWR) in February 2020.
No decanting was required for the East Ash Basin (EAB). To support final closure of the
EAB, solids are to be dredged, as applicable, from the remaining open water area (EAB
extension impoundment). A site location map is provided as Figure 1-1.
Special Order by Consent (SOC) WQ S18-005, approved on August 15, 2018, addresses
management of 20 seeps at the Site during the process of basin closures under the Coal
Ash Management Act of 2014 (CAMA), North Carolina General Statutes (G.S.) 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.
1.2 Purpose and Scope
As stated in SOC Section 2(d), SynTerra is providing this Seep Management Plan as an
amendment to the CAP Update to describe plans to manage seeps identified in the Seep
Characterization Report (SynTerra, 2020b) in a manner that will protect public health,
safety, and welfare, the environment, and natural resources. The Seep Characterization
Report evaluated seeps based on the physical status, chemical composition, and
jurisdictional determination. To be considered in this management plan for corrective
action, a seep must:
1) Be non-dispositioned,
2) Constitute, or flow to Waters of the State (WOS) or Waters of the United States
(WOTUS), and
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Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
3) Exhibit constituent concentrations that are greater than applicable North
Carolina Administrative Code (NCAC), Title 15A, Subchapter 02B, Surface Water
and Wetland Standards (02B).
1.3 Previous Reporting
Detailed descriptions of previous Site SOC assessments and characterizations are
documented in the following:
• Corrective Action Plan Update, Roxboro Steam Electric Plant (SynTerra, 2019).
• 2020 Final Seep Report, Roxboro Steam Electric Plant (SynTerra, 2020a).
• Seep Characterization Report, Roxboro Steam Electric Plant (SynTerra, 2020b).
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Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
2.0 OVERVIEW OF SEEPS
According to the SOC, there are 20 identified seeps located at the Site. Of those 20 seeps,
four seeps (S-10, S-11, S-12 and S-13) associated with the EAB were dispositioned at
issuance of the SOC. The seeps identified in the SOC are described below. Additional
seep details including proposed status are included in Table 2-1.
2.1 Seeps Associated with the East Ash Basin
Existing seeps associated with the EAB are described below and depicted on Figure 2-1.
Seep ID Description
S-09 Discharge from extension of EAB. Regulated by NPDES permit.
S-10 Minimal AOW with no flow located on northern portion of EAB berm.
(dispositioned) Flow would drain to extension impoundment of EAB.
S-11 Minimal AOW with no flow located on central portion of EAB berm. Flow
(dispositioned) would drain to extension impoundment of EAB.
S-12
(dispositioned)
S-13
(dispositioned)
Minimal AOW with no flow located on southern portion of EAB berm.
Flow would drain to extension impoundment of EAB.
Not a seep. Outfall of culvert channeling flow from unnamed tributary
(UT) on east side of facility that receives flow from EAB extension
impoundment and S-21. Flows to facility water intake canal (Hyco
Reservoir).
S-14 Location is the end of the 24" pipe draining a boggy area south of the
gypsum storage area. Pipe extends under the pad towards the
northwest, under railroad tracks, with discharge to a ditch that drains to
the heated water discharge pond. This non -constructed seep flows to a
portion of an NPDES wastewater treatment system.
S-21 Seep emerging downgradient of storm water basin below EAB. Flow
joins EAB effluent channel prior to NPDES Outfall 001.
S-23 Located on sloped area along the southwest end of the EAB dam.
Saturated soil conditions with little to no flow. Diffuse flow is directed to
channel with discharge to heated water discharge pond and Outfall 003.
No sample data to date due to lack of flow. This non -constructed seep
flows to a portion of an NPDES wastewater treatment system.
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Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
2.2 Seeps Associated with the West Ash Basin
Existing seeps associated with the WAB are described below and depicted on
Figure 2-1.
Seep ID Description
S-01 Chimney drain discharge from WAB dam to heated water discharge
pond. Permitted by NPDES permit.
S-02 Chimney drain discharge from WAB dam to heated water discharge
pond. Permitted by NPDES permit.
S-03
Chimney drain discharge from WAB dam to heated water discharge
pond. Permitted by NPDES permit.
S-04
Chimney drain discharge from WAB dam to heated water discharge
pond. Permitted by NPDES permit.
S-05
Chimney drain discharge from WAB dam to heated water discharge
pond. Permitted by NPDES permit.
S-06
Chimney drain discharge from WAB dam to heated water discharge
pond. Permitted by NPDES permit.
S-07
Chimney drain discharge from WAB dam to heated water discharge
pond. Permitted by NPDES permit.
S-08
Seepage area approximately 30 feet west of chimney drain #7.
Drainage/flow is to the NPDES permitted heated water discharge pond.
S-18
Seepage from wet area north of WAB along sluice line corridor.
S-19
AOW with minimal flow located adjacent to the S-01 chimney drain at
the east end of the WAB dam. Any flow moves toward the heated water
discharge pond.
S-20
Small seep flow to small stream channel northeast of WAB dam. Drains
west through wetland area to heated water discharge pond.
S-22
Located just east of the Unit 3 cooling tower ponds. Wetness emerges
from several points on the hillside area. Minimal flow could eventually
reach Outfall 003. No sample data to date due to lack of flow. This non -
constructed seep flows to a portion of an NPDES wastewater treatment
system and is covered by the NPDES permit.
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Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
3.0 PROPOSED SEEP MONITORING PLAN
The nature and extent of identified seeps for corrective action, effects of ongoing ash
basin closure and corrective action activities, and details about potential proposed
monitoring are discussed in the following sections.
3.1 Seeps for Corrective Action
With concurrence from the NCDEQ DWR on physical status, chemical composition,
and jurisdictional determination (JD), four seeps have been identified that require
additional corrective action as described in the Seep Characterization Report (SynTerra,
2020b). Seeps proposed for disposition within the Seeps Characterization Report and
non-dispositioned seeps (S-08, S-14, S-18, and S-20) are depicted on Figure 3-1.
Seep ID Description
East Ash Basin
S-14 This non -constructed seep does not constitute, and does not flow to,
WOS or WOTUS; however, per SOC disposition criteria, this seep is not
available to be dispositioned based on seep status or receiving water
body JD. The seep is at the discharge point of a 24-inch underground
pipe that flows from north of the EAB to the gypsum storage area
wastewater detention basins. When flowing, seep discharge flows
through a series of ditches to the heated water discharge pond, a
portion of the NPDES-regulated wastewater treatment system and is
acknowledged as a contributing flow in the NPDES permit.
West Ash Basin
W:
This non -constructed seep does not constitute, and does not flow to,
WOS or WOTUS; however, per SOC disposition criteria, this seep is not
available to be dispositioned based on seep status or receiving water
body JD. When flowing, this seep flows to the heated water discharge
pond, a portion of the NPDES-regulated wastewater treatment system
and is acknowledged as a contributing flow in the NPDES permit.
S-18 This non -constructed seep does not constitute, and does not flow to,
WOS or WOTUS; however, per SOC disposition criteria, this seep is not
available to be dispositioned based on seep status or receiving water
body JD. Seep S-18 is positioned within the decommissioned sluice line
corridor area.
S-20
This non -constructed seep does not constitute WOS or WOTUS. To the
west and topographically downgradient from S-20, is a small stream
channel flowing west through a wetland to a portion of an NPDES-
regulated wastewater treatment system (heated water discharge pond).
Per SOC disposition criteria, this seep is not available to be dispositioned
based on the NPDES-permitted receiving water body. If sufficient flow
has been observed, monitoring has been conducted prior to flows
reaching the NPDES-permitted waste water treatment system.
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Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
3.2 Nature and Extent of Source Related Constituents and Seeps
Based on groundwater data collected through May 2020, constituents of interest (COIs)
associated with the ash basins in groundwater and surface water include:
• Arsenic • Fluoride
• Boron • Mercury
• Barium • Nickel
• Chloride • Nitrate/Nitrite
• Chromium • Selenium
• Sulfate
• Thallium
• Total Dissolved Solids (TDS)
• Total Hardness
Boron concentrations greater than North Carolina Administrative Code (NCAC), Title
15A, Subchapter 02L — Groundwater Classifications and Standards (02L) represent the
extent of affected groundwater associated with the ash basins. Because boron is non -
reactive and mobile in groundwater, it has been identified as a leading -edge indicator
and representative of the overall plume that contains other COIs greater than
comparison criteria [02L standard/ Interim Maximum Allowable Concentration (IMAC)
or background concentrations, whichever is greater]. Maximum boron concentrations
are downgradient of the EAB separator dike (CCR-110BR) and downgradient of the
WAB dikes adjacent to the western discharge canal (CCR-208BR), which flows to the
NPDES-regulated heated water discharge pond (Figure 3-2). Maximum boron
concentration data for each ash basin are summarized below.
Location of Maximum
15 NCAC 02L
Detection
Maximum
Date of
Constituent
standard
(pg/L)
Detection
Maximum
(lag/L)
(lag/L)
Detection
Well ID
Ash Basin
Boron
700
CCR-110BR
EAB
26,400
5/12/2016
Boron
700
CCR-208BR
WAB
52,900
7/24/2019
The primary flow path for groundwater is to the north within the basin's historical
stream valley. The NPDES permitted wastewater ponds are the primary groundwater
discharge zones downgradient of the basins. Seep locations relative to the area of
affected groundwater are shown on Figure 3-2.
As stated in Section 2.0, seeps at Roxboro do not constitute WOS or WOTUS including
S-20. If present, contributing flows at this seep are minimal. Any contributing flow from
S-20 drains to a small stream channel and wetland prior to reaching the NPDES-
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Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
permitted heated water discharge pond. Due to insufficient flow, no sampling has
occurred at the seep source prior to intersecting the small stream channel. Monitoring
related to S-20 is conducted prior to flows reaching the heated water discharge pond.
For informational purposes, historical maximum observed concentrations for boron and
constituents with concentrations greater than a 02B standard for seep S-20 are
summarized in the table below.
Total (T) or
Dissolved (D)
Constituent
15 NCAC 02B
standard
(mg/L)
Location of Maximum
Detection
Maximum
Detection
(mg/L)
Date of
Maximum
Detection
Seep
Location
Associated
Ash Basin
Boron (T)
NE
S-20
WAB
0.425
05/07/2019
Sulfate(T)
250
S-20
WAB
270
10/25/2018
TDS (T)
500
S-20
WAB
580
10/25/2018
Hardness
100
S-20
WAB
367
10/25/2018
Notes:
mg/L - milligrams per liter
NE - 02B standard not established
Historical analytical data for S-20 sampling prior to discharge to the heated water
discharge pond, with comparison to 02B standards, are provided in Table 3-1.
Seep S-20, and the downgradient stream and wetland area, had insufficient flow for
sample collection in May 2020. A comparison of the most recent analytical results
(March 2020) from S-20 with 02B surface water standards identified one constituent,
hardness, greater than 02B standards. This comparison and additional information
related to analytical results and seep status are summarized in the table below.
15NCAC 02B
Concentration
Seep ID
Constituent
Standard
Additional Information
(mg/L)
(mg/L)
S-20
Hardness
100
263
No established
groundwater standard
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Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
3.3 Ash Basin Closure and Corrective Action
Duke Energy continues to implement ash basin closure and corrective action that
provides adequate seep management and surface water protection at the Site. Ongoing
and anticipated ash basin closure and corrective action activities are summarized in the
table below.
Year
Closure or Corrective Action Activity
2019 - 2020
Passive decanting of free water from the WAB.
2021 - 2034
Dewatering and closure of the WAB. Excavation of the WAB is planned
to be complete by 2034.
2021 - 2034
Dewatering and closure of the EAB. Partial excavation of the EAB is
planned to be complete by 2034. Dredging of saturated ash from the
EAB extension impoundment.
2021 - 2029
Groundwater extraction north of the EAB geographic limitation.
3.4 Mann -Kendall Trend Analysis
The Mann -Kendall statistical test (Appendix B) was performed to analyze how
constituent concentrations at seep locations have changed over time. The Mann -Kendall
trend test evaluates data over time for each non-dispositioned seep to develop a
statistical conclusion that pertains to trends — increasing, decreasing, or no trend — of
a COI concentration.
Results of the Mann -Kendall test evaluation indicates the following:
• Trend analysis was performed on 37 constituent -location pairs.
• 73 percent of constituent locations (27 out of 37 constituent -location pairs)
demonstrated stable conditions with no trends
• 27 percent of the constituent locations (10 out of 37 constituent -location pairs)
demonstrated statistically significant decreasing trends
• Since implementation of passive decanting of the WAB in April 2019, stable to
statistically significant decreasing trends, including boron, are indicated for the
S-08 seep location
A depiction of the seep trend analysis is shown on Figure 3-2. Overall, the results of the
Mann -Kendall trend analysis indicate that the seep discharge has been geochemically
stable with COI concentrations remaining stable or decreasing over time. The Mann -
Kendall Analysis report is provided in Appendix B.
Page 3-4

Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
3.5 Seep Corrective Action Strategy
In order 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
Four non -constructed seeps (S-08, S-14, S-18, and S-20) have been identified based on
the above -mentioned criteria.
Three of those seeps (S-08, S-14, and S-18) do not constitute, or do not flow to, WOS or
WOTUS. However, according to the SOC disposition criteria indicated in SOC Section
2(c)(3), these seeps are not available to be dispositioned.
Historically, visible flow at the signed location for Seep 5-20 that reached WOS or
WOTUS has been minimal and intermittent. Three consecutive quarterly observations
(Fourth Quarter 2019, First Quarter 2020 and Second Quarter 2020), as presented in the
Seep Characterization Report (SynTerra, 2020b), indicated that flow was not reaching
WOS or WOTUS at those times. An August 14, 2020 inspection of S-20 and the
wetland/stream complex below the signed seep location, indicated minimal,
intermittent seep flow may be reaching WOS or WOTUS. Therefore, S-20 remains as a
non-dispositioned seep.
As described in the CAP Update report (SynTerra, 2019) and based on findings from
seep characterization (SynTerra, 2020b), the following corrective action strategy for the
non-dispositioned seeps is summarized.
Page 3-5

Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
Seep ID
Corrective Action Strategy
East Ash Basin
S-14
Groundwater remediation by extraction is proposed north-northeast of
the EAB, which it is predicted to reduce flows and COI migration
toward the north and S-14.
West Ash Basin
S-08
Cessation of sluicing to the WAB initiated in April 2019. Dewatering,
source removal, and closure at the WAB is anticipated to reduce flow to
this location prior to eliminating the seep. Contributing flow is
monitored at NPDES Outfall 003. No additional corrective action for this
location is anticipated.
S-18
Cessation of sluicing to the WAB initiated in April 2019 followed by
decommissioning of sluice lines, substantially reduced flow at this
location. No additional corrective action for this location is anticipated.
S-20
Cessation of sluicing to the WAB initiated in April 2019 followed by
decommissioning of sluice lines, substantially reduced flow at this
location. WAB active decanting, dewatering and closure is predicted to
cause flow to cease in the future. No additional corrective action for
this location is anticipated.
3.6 Potential 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 June 2022. In addition, any
contribution of flows from seeps S-08, S-14, S-18, and S-20, will also be monitored as
part of routine NPDES permit monitoring.
Page 3-6

Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
4.0 REFERENCES
North Carolina Department of Environmental Quality (2018). Special Order by Consent
EMC SOC WQ 518-005. August 2018.
SynTerra (2019). Corrective Action Plan Update — Roxboro Steam Electric Plant. December
2019.
SynTerra (2020a). 2020 Final Seep Report — Roxboro Steam Electric Plant. May 2020.
SynTerra (2020b). Seep Characterization Report, Roxboro Steam Electric Plant. July 2020.
Page 4-1

Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
FIGURES

0
0
STORAGE AREA
APPROXIMATE DFA �� r` (L ��ACD
HANDLING�ASH BASINPOWER PLANTrnd`WASTE BOUNDARY
"
EAB MAIN DAM EASTERN DISCHARGE CANAL
LCID LANDFILL , BOUNDARY EAST ASH BASIN
�-
1 � WAB MADAM
ASH BASIN
WASTE BOUNDARY SEPARATOR DIKE,'
((���
WEST ASH BASIN
INDUSTRIAL LANDFILL
WESTERN DISCHARGE CANAL BOUNDARY
lJ I►Y T L 0
N DISCHARGE CANAL y
- FILTER DIKE 1
r
DUKE ENERGY ` y
PROGRESS PROPERTY `
LINE
Q
a
O
Q A
1. ALL BOUNDARIES ARE APPROXIMATE.
2. PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY PROGRESS.
3. 2016 USGS TOPOGRAPHIC MAP, OLIVE HILL QUADRANGLE, OBTAINED
a o
FROM THE USGS STORE AT
https:#stom.usgs.gov/map-locator.
y i
'(O
PERSON COUNTY
FIGURE 1-1
486) DUKE
SITE LOCATION MAP
ENERGY
SEEP MANAGEMENT PLAN
PROGRESS
W/NSTON-SALEM
0RALEIGH
AMENDMENT TO CORRECTIVE ACTION PLAN
ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA
CHARLOTTE
DRAWN BY: J. KIRTZ DATE: 06/11/2019
REVISED BY: C. WYATT DATE: 08/27/202.
CHECKED BY: K. CAWING DATE: 08/27/2020
GRAPHIC SCALE
0 500 11000 21000 3,000
(IN FEET)
synTerra
APPROVED BY: K. CAWING DATE: 08/27/2020
PROJECT MANAGER: C. EADY
www.synterracorp.com

HYCO
RESERVOIR
HEATED WATER
DISCHARG NO rti
HYCO
RESERVOIR � E
'I 1 II
I VA
t,,
1'
i
1 •:
♦ `•♦
S-5
PS-20 -,8 S
_ S 6 `� Ak'
S-7 S_19
S-8 -
%c
FILTER DIKE
ir• .... .
♦v♦ • /
S-13 r
J
NPDES OUTFALL 001 I�
S-21 I
r -
S-10 • - • I
S-11 S-9 I
♦
♦
♦
1.
1
I
J♦
J
•� GRAPHIC SCALE
�•,� �-�N RGY UKE 700 D 700 1.400
'- -I (IN FEET)
PROGRESS DRAWN BY: J. KI RTZ DATE: 05/03/2019
REVISED BY: C. WYATT DATE: 08/27/2020
CHECKED BY: K. LAWING DATE: 08/27/2020
I APPROVED BY: K. LAWING DATE: 08/27/2020
svnTerra PROJECT MANAGER: C. EADY
- -
LEGEND
CONSTRUCTED SEEP
NON -CONSTRUCTED SEEP
DISPOSITIONED SEEP
1 NPDES OUTFALL LOCATION
ASH BASIN WASTE BOUNDARY
SOLID WASTE LANDFILL BOUNDARY
- DUKE ENERGY PROGRESS PROPERTY LINE
EFFLUENT DISCHARGE CANAL
WETLAND (AMEC NRTR)
STREAM (AMEC NRTR)
SPECIAL ORDER BY CONSENT (SOC) INSPECTION
AREA
NOTES:
1. SEEP LOCATIONS ARE DESCRIBED IN THE ENVIRONMENTAL MANAGEMENT
COMMISSION SPECIAL ORDER BY CONSENT (SOC) WQ S18-005.
2. PERMITTED SEEPS ARE DESCRIBED IN NATIONAL POLLUTANT DISCHARGE
ELIMINATION SYSTEM (NPDES) PERMIT NC00034245.
3. ALL BOUNDARIES ARE APPROXIMATE.
4. PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY PROGRESS, LLC.
5. SEEP LOCATIONS WERE DERIVED FROM VARIOUS SOURCES AND AREA MIX OF
SURVEYED AND APPROXIMATE LOCATIONS. THEREFORE, SEEP LOCATIONS ARE TO BE
DEEMED APPROXIMATE.
6. THE WATERS OF THE US DELINEATION HAS NOT BEEN APPROVED BY THE US ARMY
CORPS OF ENGINEERS AT THE TIME OF MAP CREATION. THIS MAP IS PRELIMINARY
JURISDICTIONAL DETERMINATION ONLY. THE PRELIMINARY WETLANDS AND STREAMS
BOUNDARIES WERE OBTAINED FROM AMEC FOSTER WHEELER ENVIRONMENTAL &
INFRASTRUCTURE, INC. NATURAL RESOURCES TECHNICAL REPORT (NRTR) FOR
ROXBORO STEAM ELECTRIC PLANT DATED JUNE 2015.
7. AERIAL PHOTOGRAPHY OBTAINED FROM GOOGLE EARTH PRO ON OCTOBER 11, 2017.
AERIAL WAS COLLECTED ON JUNE 13, 2016.
8. DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE PLANE
COORDINATE SYSTEM FIPS 3200 (NAD83).
FIGURE 2-1
EXISTING SEEP LOCATIONS AND INSPECTION AREAS
SEEP MANAGEMENT PLAN
AMENDMENT TO CORRECTIVE ACTION PLAN
ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA

••1�
_ ..
_ _
S-13
LL
S-14
y
NPDES OUTFACE 001
I�
• " • •
S-22
Il I
- • -
'
S-23
-'
NPDES OUTFALL 003 S 3
S-10 • " ' I
S-4
;
S-5
S-20
S-11 S-9
S-18
I
S-6
S-7
5- 9
S-12 �
_-'
LEGEND
-
0 AL
-
-
NON -CONSTRUCTED SEEP
•
I
'
`.
DISPOSITIONED SEEP
♦
d&M,, ♦••
• A
A NPDES OUTFALL LOCATION
�� // •
• ►� _ _
ASH BASIN WASTE BOUNDARY
-'
• -
SOLID WASTE LANDFILL BOUNDARY
�•
— - DUKE ENERGY PROGRESS PROPERTY LINE
' •
EFFLUENT DISCHARGE CANAL
WETLAND (AMEC NRTR)
rmmmrl
--)0- STREAM (AMEC NRTR)
1
SPECIAL ORDER BY CONSENT (SOC) INSPECTION
/
AREA
J
1 •
NOTES:
�.
1. SEEP LOCATIONSARE DESCRIBED IN THE ENVIRONMENTAL MANAGEMENT
♦
•
COMMISSION SPECIAL ORDER BY CONSENT (SOC) WQ S18-005.
' •
1,
�' _
G • •-� ''
`�
I
DISPOSITION IN THE SEEP CHARACTERIZATION REPORT SEEPS S-10ES-11, S-12, AND S-
13 WERE DISPOSITIONED AT THE ISSUANCE OF THE SOC.
� `
♦ �
�`
?�
�11
_ ♦
�
3. PERMITTED SEEPS ARE DESCRIBED IN NATIONAL POLLUTANT DISCHARGE
ELIMINATION SYSTEM (NPDES) PERMIT NC00034245.
_
`�
• e�
.�
-
,
•
4. ALL BOUNDARIES ARE APPROXIMATE.
• _ • -
� •
`♦
`•
•
�'
5. PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY PROGRESS, LLC.
•
r
-
/ •
• • •
6. SEEP LOCATIONS WERE DERIVED FROM VARIOUS SOURCES AND ARE A MIX OF
SURVEYED AND APPROXIMATE LOCATIONS. THEREFORE, SEEP LOCATIONS ARE TO BE
DEEMED APPROXIMATE.
'
`•
{ • ♦ `, . •
7. THE WATERS OF THE US DELINEATION HAS NOT BEEN APPROVED BY THE US ARMY
CORPS OF ENGINEERS AT THE TIME OF MAP CREATION. THIS MAP IS PRELIMINARY
`
• •
JURISDICTIONAL DETERMINATION ONLY. THE PRELIMINARY WETLANDS AND STREAMS
Ai i -`
• •
BOUNDARIES WERE OBTAINED FROM AMEC FOSTER WHEELER ENVIRONMENTAL &
•
' -
INFRASTRUCTURE, INC. NATURAL RESOURCES TECHNICAL REPORT (NRTR) FOR
ROXBORO STEAM ELECTRIC PLANT DATED JUNE 2015.
8. AERIAL PHOTOGRAPHY OBTAINED FROM GOGGLE EARTH PRO ON OCTOBER 11, 2017.
J
AERIAL WAS COLLECTED ON JUNE 13, 2016.
`
..,
� �.
�• . -1
, '
• ►
�'
•
�•
�
Off,
9. DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE PLANE
COORDINATE SYSTEM FIPS 3200 (NAD83).
1"�
/ • �
•'' GRAPHIC SCALE
. '
�
.. •v �' ,/
'4x
•� '
�.I•••I talk, DUKE 700 0 700 1,400
`' ENERGY
FIGURE 3-'I
PROPOSED SEEP LOCATIONS AND INSPECTION AREAS
•r
J ♦• ♦
^fir ' ♦ ��_-
(IN FEET)
r I PROGRESS
SEEP MANAGEMENT PLAN
•
`l I
DRAWN BY: C.WYATT
REVISED BY: C.WYATT
CHECKED BY: K. LAWING
DATE:08/21/2020
DATE: 08/27/2020
DATE: 08/27/2020
AMENDMENT TO CORRECTIVE ACTION PLAN
ROXBORO STEAM ELECTRIC PLANT
J
APPROVED BY: K. LAWING
n e� PROJECT MANAGER: C. EADY
DATE: 08/27/2020
SEMORA, NORTH CAROLINA
_ . ..
_ www.svnterracorD.COM

Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
TABLES

TABLE 2-1
SEEP LOCATIONS AND DESCRIPTIONS
SEEP MANAGEMENT PLAN AMENDMENT TO CORRECTIVE ACTION PLAN
ROXBORO STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS, LLC, SEMORA, NC
Seep ID
Location Coordinates
Constructed/
Receiving
Receiving
Interim Action
Number
Non -constructed
Waterbody
Waterbody
Description***
SOC Monitoring
Levels
Status
Notes
Latitude
Longitude
Classification
Heated Water
NA - Seep
S-01
36.477043
-79.076467
Constructed
Discharge Pond
NA - Not a Classified
Chimney drain discharge from West Ash Basin dam to Heated
contribution analyzed
NA - Not a Classified
Proposed for
Contributing flows monitored
flowing to NPDES
Surface Water
Water Discharge Pond. Permitted by NPDES permit.
in NPDES Permit
Surface Water
disposition
at NPDES Outfall 003
permit Outfall 003
monitoring
Heated Water
NA - Seep
S-02
36.477055
-79.076727
Constructed
Discharge Pond
NA - Not a Classified
Chimney drain discharge from West Ash Basin dam to Heated
contribution analyzed
NA - Not a Classified
Proposed for
Contributing flows monitored
flowing to NPDES
Surface Water
Water Discharge Pond. Permitted by NPDES permit.
in NPDES Permit
Surface Water
disposition
at NPDES Outfall 003
permit Outfall 003
monitoring
Heated Water
NA - Seep
S-03
36.476994
-79.076978
Constructed
Discharge Pond
NA - Not a Classified
Chimney drain discharge from West Ash Basin dam to Heated
contribution analyzed
NA - Not a Classified
Proposed for
Contributing flows monitored
flowing to NPDES
Surface Water
Water Discharge Pond. Permitted by NPDES permit.
in NPDES Permit
Surface Water
disposition
at NPDES Outfall 003
permit Outfall 003
monitoring
Heated Water
NA - Seep
S-04
36.476923
-79.077204
Constructed
Discharge Pond
NA - Not a Classified
Chimney drain discharge from West Ash Basin dam to Heated
contribution analyzed
NA - Not a Classified
Proposed for
Contributing flows monitored
flowing to NPDES
Surface Water
Water Discharge Pond. Permitted by NPDES permit.
in NPDES Permit
Surface Water
disposition
at NPDES Outfall 003
permit Outfall 003
monitoring
Heated Water
NA - Seep
Dry or non -flowing conditions,
S-05
36.476751
-79.077412
Constructed
Discharge Pond
NA - Not a Classified
Chimney drain discharge from West Ash Basin dam to Heated
contribution analyzed
NA - Not a Classified
Proposed for
any contributing flows monitored
flowing to NPDES
Surface Water
Water Discharge Pond. Permitted by NPDES permit.
in NPDES Permit
Surface Water
disposition
at NPDES Outfall 003
permit Outfall 003
monitoring
Heated Water
NA - Seep
S-06
36.47669
-79.077643
Constructed
Discharge Pond
NA - Not a Classified
Chimney drain discharge from West Ash Basin dam to Heated
contribution analyzed
NA - Not a Classified
Proposed for
Contributing flows monitored
flowing to NPDES
Surface Water
Water Discharge Pond. Permitted by NPDES permit.
in NPDES Permit
Surface Water
disposition
at NPDES Outfall 003
permit Outfall 003
monitoring
Heated Water
NA - Seep
S-07
36.476736
-79.077954
Constructed
Discharge Pond
NA - Not a Classified
Chimney drain discharge from West Ash Basin dam to Heated
contribution analyzed
NA - Not a Classified
Proposed for
Contributing flows monitored
flowing to NPDES
Surface Water
Water Discharge Pond. Permitted by NPDES permit.
in NPDES Permit
Surface Water
disposition
at NPDES Outfall 003
permit Outfall 003
monitoring
Heated Water
Seepage area approximately 30 feet west of chimney drain #
NA - Seep
S-08
36.476719
-79.078064
Non -Constructed
Discharge Pond
NA - Not a Classified
e
Drainage/flow is to the NPDES permitted Heated Water Discharge
contribution analyzed
NA - Not a Classified
Monitor per
Contributing flows monitored
flowing to NPDES
Surface Water
Pond.
in NPDES Permit
Surface Water
SOC
at NPDES Outfall 003
permit Outfall 003
monitoring
NA - Seep
See page 6 of
S-09
36.47823
-79.056076
Constructed
Effluent Channel to
NA - Not a Classified
Discharge from extension of East Ash Basin. Regulated by NPDES
contribution analyzed
attachment A of
Proposed for
Contributing flows monitored
NPDES Outfall 001
Surface Water
permit.
in NPDES Permit
Roxboro SOC S18-
disposition
at NPDES Outfall 001
monitoring
005 document.
5-10
36.479169
-79.056963
Non -Constructed**
Extension of East Ash
NA - Not a Classified
Minimal AOW with no flow located on northern portion of East Ash
NA - Seep
NA - Seep
Dispositioned
Dispositioned at issuance
Basin
Surface Water
Basin berm. Flow would drain to extension of East Ash Basin.
dispositioned
dispositioned
of SOC
S-11
36.478569
-79.056737
Non -Constructed**
Extension of East Ash
NA - Not a Classified
Minimal AOW with no flow located on central portion of East Ash
NA - Seep
NA - Seep
Dispositioned
Dispositioned at issuance
Basin
Surface Water
Basin berm. Flow would drain to extension of East Ash Basin.
dispositioned
dispositioned
of SOC
S-12
36.478103
-79.056735
Non -Constructed"
Extension of East Ash
NA - Not a Classified
Minimal AOW with no flow located on southern portion of East
NA - Seep
NA - Seep
Dispositioned
Dispositioned at issuance
Basin
Surface Water
Ash Basin berm. Flow would drain to extension of East Ash Basin.
dispositioned
dispositioned
of SOC
Page 1 of 2

TABLE 2-1
SEEP LOCATIONS AND DESCRIPTIONS
SEEP MANAGEMENT PLAN AMENDMENT TO CORRECTIVE ACTION PLAN
ROXBORO STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS, LLC, SEMORA, NC
Seep ID
Location Coordinates
Constructed/
Receiving
Receiving
Interim Action
Number
Non -constructed
Waterbody
Waterbody
Description***
SOC Monitoring
Levels
Status
Notes
Latitude
Longitude
Classification
Not a seep. Outfall of culvert channeling flow from UT on east
See page 6 of
See page 6 of
S-13
36.486175
-79.059612
Non -Constructed **
Hyco Reservoir Intake
WS-V• B
side of facility that receives flow from East Ash Basin extension
attachment A of
attachment A of
Dispositioned
Dispositioned at issuance
Canal
(Hyco Reservoir)
and S-21. Flows to facility water intake canal (Hyco Reservoir).
Roxboro SOC 518-
Roxboro SOC 518-
of SOC
005 document.
005 document.
Unit 3 cooling tower
Location is the end of the 24" pipe draining a boggy area south of
pond to the Heated
the gypsum storage area. Pipe extends under the pad towards
NA - Seep
S-14
36.483738
-79.063751
Non -Constructed
Water Discharge
NA - Not a Classified
the northwest, under railroad tracks, with discharge to a ditch
contribution analyzed
NA - Not a Classified
Monitor per
Contributing flows monitored
Canal flowing to
Surface Water
that drains to the Heated Water Discharge Pond. This non-
in NPDES Permit
Surface Water
SOC
at NPDES Outfall 003
NPDES permit Outfall
constructed seep flows to a portion of an NPDES wastewater
monitoring
003
treatment system.
Quarterly monitoring
Small stream flowing
NA - Not a Classified
Seepage from wet area north of West Ash Basin along sluice line
at point prior to
Hardness 1200 mg/L
Monitor per
Contributing flows monitored
S-18
36.477947
-79.073728
Non -Constructed
to Heated Water
Surface Water
corridor.
flowing into Heated
TDS 1600 mg/L
SOC
at NPDES Outfall 003
Discharge Pond
Water Discharge
Sulfates 1000 mg/L
Pond.
Heated Water
AOW with minimal flow located adjacent to the S-01 chimney
NA - Seep
Dry or non -flowing conditions,
S-19
36.477176
-79.0763902
Non -Constructed
Discharge Pond
NA - Not a Classified
drain at the east end of the West Ash Basin dam. Any flow moves
contribution analyzed
NA - Not a Classified
Proposed for
any contributing flows monitored
flowing to NPDES
Surface Water
toward the Heated Water Discharge Pond.
in NPDES Permit
Surface Water
disposition
at NPDES Outfall 003
permit Outfall 003
monitoring
Quarterly monitoring
Small stream flowing
NA - Not a Classified
Small seep flow to small stream channel northeast of West Ash
at point prior to
Hardness 1200 mg/L
Monitor per
Contributing flows monitored
S-20
36.47799
-79.0749
Non -Constructed
to Heated Water
Surface Water
Basin dam. Drains west through wetland to Heated Water
flowing into Heated
TDS 1600 mg/L
SOC
at NPDES Outfall 003
Discharge Pond
Discharge Pond. No sample data due to lack of flow.
Water Discharge
Sulfates 1000 mg/L
Pond.
Seep emerging downgradient of storm water basin below East
NA - Seep
S-21
36.48246
-79.0559
Non -Constructed
Effluent Channel to
NA - Not a Classified
Ash Basin. Flow joins East Ash Basin effluent channel prior to
contribution analyzed
NA - Not a Classified
Proposed for
Contributing flows monitored
NPDES Outfall 001
Surface Water
NPDES Outfall 001.
in NPDES Permit
Surface Water
disposition
at NPDES Outfall 001
monitoring.
Located just east of the cooling tower ponds. Wetness emerges
Heated Water
from several points on the hill side area. Minimal flow could
NA - Seep
Dry or non -flowing conditions,
S-22
36.48184
-79.0657
Non -Constructed
Discharge Pond
NA - Not a Classified
eventually reach Outfall 003. No sample data to date due to lack
contribution analyzed
NA - Not a Classified
Proposed for
any contributing flows monitored
flowing to NPDES
Surface Water
of flow. This non -constructed seep flows to a portion of an NPDES
in NPDES Permit
Surface Water
disposition
at NPDES Outfall 003
permit Outfall 003
wastewater treatment system and is covered by the NPDES
monitoring
permit.
Located on sloped area along the southwest end of the East Ash
Heated Water
Basin dam. Saturated soil conditions with little to no flow. Diffuse
NA - Seep
Dry or non -flowing conditions,
S-23
36.48035
-79.0685
Non -Constructed
Discharge Pond
NA - Not a Classified
flow is directed to channel with discharge to Heated Water
contribution analyzed
NA - Not a Classified
Proposed for
any contributing flows monitored
flowing to NPDES
Surface Water
Discharge Pond and Outfall 003. No sample data to date due to
in NPDES Permit
Surface Water
disposition
at NPDES Outfall 0033
permit Outfall 003
lack of flow. This non -constructed seep flows to a portion of an
monitoring
NPDES wastewater treatment system.
Notes:
** Seep dispositioned via repair and/or non -flowing condition to potentially reach Waters of the U. S., or other, as noted. Seep dispositioned at issuance of SOC.
*** - Some descriptions have been updated from the original text found in the SOC Attachment A table for accuracy and currency.
pg/L - micrograms per liter
mg/L - milligrams per liter
NA - Not Applicable
NPDES - National Pollutant Discharge Elimination System
PVC - polyvinyl chloride
SOC - Special Order by Consent
UT - Unnamed Tributary
TDS - Total Dissolved Solids
Prepared by: KTL Checked by: CDE
Page 2 of 2

TABLE 3-1
SEEP SAMPLING RESULTS
SEEP MANAGEMENT PLAN AMENDMENT TO CORRECTIVE ACTION PLAN
ROXBORO STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS, LLC, SEMORA, NC
FIELD PARAMETERS
ANALYTICAL RESULTS (TOTAL CONCENTRATION)
S.U.
Deg C
pmhos/cm
mg/L
mV
mV
NTUs
GPM
pg/L
pg/L
pg/L
pg/L
pg/L
mg/L
mg/L
pg/L
pg/L
mg/L
Reporting Units
15A NCAC 02B (Class B, WS-V)
6.0-9.0
29
NE
4
NE
NE
25
NE
10
1000
NE
NE
NE
NE
250
NE
NE
1.8
Location With
Sample
Oxidation
Location ID
Location Description
Associated Unit
Respect to
Sample
Latitude
Longitude
Collection
pH
Temperature
Specific
Dissolved
Reduction
Eh
Turbidity
Flow
Arsenic
Barium
Boron
Bromide
Cadmium
Calcium
Chloride
Chromium
Copper
Fluoride
Groundwater
Media
Date
Conductance
Oxygen
Potential
Flow Direction
Channel flowing into the
S-20
heated discharge pond
West Ash Basin
Downgradient
Water
36.47786693
-79.07489695
10/25/2018
7.4
13
837
8.04
-107
98
2.4
0.214
<1
75
334
<1000
<0.1
74.3
19
<1
<1
<1
S-20
Channel flowing into the
West Ash Basin
Downgradient
Water
36.47786693
-79.07489695
02/28/2019
6.8
9
524
7.62
161
366
6.1
7.37
<1
66
341
<500
<0.1
47.8
13
<1
<1
<0.5
heated discharge pond
Channel flowing into the
S-20
heated discharge pond
West Ash Basin
Downgradient
Water
36.47786693
-79.07489695
05/07/2019
7.2
20
766
6.36
100
305
11.0
NM
<1
88
425
580
<0.1
72.3
18
<1
<1
<0.5
S-20
Channel flowing into the
West Ash Basin
Downgradient
Water
36.47786693
-79.07489695
03/18/2020
7.6
12
620
6.24
219
424
1.3
NM
<1
59
376
<500
<0.1
52.2
16
<1
<1
<0.5
heated discharge pond
Notes:
15A NCAC 02B (Class B) - 15A NCAC 02L .0202 Standard for Class B Surface Waters
Blue highlighted cells indicate concentrations greater than applicable conservative 15 NCAC 02B (Class B) standards.
The comparative standard for dissolved oxygen represents the minimum criteria. Dissolved oxygen values presented are instantaneous values. Per 15 NCAC 02B .0202 (6)(a) daily average for dissolved oxygen shall be at least four samples therefore a daily average was not calculated.
*Calculated hardness dependent metal standards represent most conservative value. Standards are calculated using 25 mg/L hardness, regardless if actual instream hardness values are greater than 25 mg/L. Derived using calculations from Table A in 15A NCAC 02B.0211 (11).
Deg C - degrees Celsius
Eh - Redox Potential
GPM - gallons per minute
mg/L - milligrams per liter
mg-N/L - milligrams nitrogen per liter
my - millivolts
NA - not analyzed
NCAC - North Carolina Administrative Code
NE - not established
NM - not measured
NTU - Nephelometric Turbidity Units
S.U. - pH standard units
pg/L - micrograms per liter
µmhos/cm - micromhos per centimeter
UT - unnamed tributary
Prepared by: KTL Checked by: KHG
Page 1 of 2

TABLE 3-1
SEEP SAMPLING RESULTS
SEEP MANAGEMENT PLAN AMENDMENT TO CORRECTIVE ACTION PLAN
ROXBORO STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS, LLC, SEMORA, NC
ANALYTICAL RESULTS (TOTAL CONCENTRATION)
ANALYTICAL RESULTS (DISSOLVED CONCENTRATION)
mg/L
pg/L
mg/L
pg/L
pg/L
mg-N/L
mg/L
pg/L
mg/L
pg/L
mg/L
mg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
Reporting Units
SSA NCAC 02B (Class B, WS-V)
100
NE
NE
0.012
25*
10
NE
5
250
NE
500
NE
NE
150
0.15
24
2.7
0.54
16
36
Location With
Sample
Total
Total
Location ID
Location Description
Associated Unit
Respect to
Sample
Latitude
Longitude
Collection
Hardness
Lead
Magnesium
Mercury
Nickel
Nitrate +
Oil and
Selenium
Sulfate
Thallium
Dissolved
Suspended
Zinc
Arsenic
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
Groundwater
Media
Date
Nitrite
grease
Solids
Solids
Flow Direction
Channel flowing into the
S-20
heated discharge pond
West Ash Basin
Downgradient
Water
36.47786693
-79.07489695
10/25/2018
367
<0.2
44
0.000793
<1
0.02
NA
<1
270
<0.2
580
NA
<5
<1
<0.1
<1
<1
<0.2
<1
<5
S-20
Channel flowing into the
West Ash Basin
Downgradient
Water
36.47786693
-79.07489695
02/28/2019
240
<0.2
29.3
0.0016
<1
0.02
<5
<1
170
<0.2
360
<5
<5
<1
<0.1
<1
<1
<0.2
<1
<5
heated discharge pond
Channel flowing into the
S-20
heated discharge pond
West Ash Basin
Downgradient
Water
36.47786693
-79.07489695
05/07/2019
343
<0.2
39.4
0.00107
<1
0.02
NA
<1
230
<0.2
380
NA
<5
<1
<0.1
<1
<1
<0.2
<1
<5
S-20
Channel flowing into the
West Ash Basin
Downgradient
Water
36.47786693
-79.07489695
03/18/2020
263
<0.2
32.2
0.000525
<1
<0.01
NA
<1
210
<0.2
415
<2.5
<5
<1
<0.1
<1
<1
<0.2
<1
<5
heated discharge pond
Notes:
15A NCAC 02B (Class B) - 15A NCAC 02L .0202 Standard for Class B Surface Waters
Blue highlighted cells indicate concentrations greater than applicable conservative 15 NCAC 02B (Class B) standards.
The comparative standard for dissolved oxygen represents the minimum criteria. Dissolved oxygen values presented are instantaneous values. Per 15 NCAC 02B .0202 (6)(a) daily average for dissolved oxygen shall be at least four samples therefore a daily average was not calculated.
*Calculated hardness dependent metal standards represent most conservative value. Standards are calculated using 25 mg/L hardness, regardless if actual instream hardness values are greater than 25 mg/L. Derived using calculations from Table A in 15A NCAC 02B.0211 (11).
Deg C - degrees Celsius
Eh - Redox Potential
GPM - gallons per minute
mg/L - milligrams per liter
mg-N/L - milligrams nitrogen per liter
my - millivolts
NA - not analyzed
NCAC - North Carolina Administrative Code
NE - not established
NM - not measured
NTU - Nephelometric Turbidity Units
S.U. - pH standard units
pg/L - micrograms per liter
µmhos/cm - micromhos per centimeter
UT - unnamed tributary
Prepared by: KTL Checked by: KHG
Page 2 of 2

Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
APPENDIX A
SOC WQ S 18-005

NORTH CAROLINA
ROY COOPER Environmental Quality
Gotmor
MICHAEL S. RECAN
srnrwr
L.INDA CULPEPP€R
Imeam (3 irwror
August 16, 2018
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. S18-005
Duke Energy Progress, LLC
Mayo Plant and Roxboro Plant
NPDES Permits NCO038377 & NC0003425
Person 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 Chairman of the Commission on
August 15, 2018.
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:
o Payment of the upfront penalty is due no later than September 20, 2018.
+ Monitoring performed per the terms of the SOC shall commence during the current calendar
quarter (July - September), with results submitted to DWR no later than October 30, 2018.
Subsequent monitoring and reporting shall occur as specified in the SOC.
�J QE Q
Nsrth Carolina Denartment of Environmental (duality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707,9000

Mr. Paul Draovitch
S 18-005 Transmittal
p. 2
Pursuant to North Carolina General Statute 143-215.31), 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
will be invoiced at a later date, with future fee invoicing done on an annual basis.
If you have any questions concerning this matter, please contact Bob Sledge at [phone].
Sincerely,
Linda Culpepper
Attachment
cc: Central Files
NPDES Unit — SOC File
ec: Raleigh Regional Office — DWR/Water Quality Regional Operations
Shannon Langley — Duke Energy
Sara Janovitz — EPA Region 4
Jeff Poupart — DWR/WQPS

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF PERSON
IN THE MATTER OF
NORTH CAROLINA
NPDES PERMITS NCO038377 &
NC0003425
HELD BY )
DUKE ENERGY PROGRESS, LLC )
SPECIAL ORDER BY CONSENT
EMC SOC WQ S18-005
Pursuant to the provisions of North Carolina General Statutes (G.S.) 143-215.2, this Special
Order by Consent 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."
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 Energy began discussions
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 18-005
Duke Energy Progress, LLC
p. 2
Decanting (i.e., removal of the free water on the surface of the coal ash basins),
which is required before ash basins can be closed, 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 requiring Duke Energy to accelerate the schedule for decanting as
specified more fully below. Constructed seeps (as defined in subparagraphs e and
f below) will be addressed in the NPDES permits. After completion of decanting,
for any remaining seeps, whether constructed or non -constructed, Duke Energy
must take appropriate corrective action as specified more fully below.
b. Duke Energy has been issued North Carolina NPDES permits for operation of an
existing wastewater treatment works at each of the following coal fired, electric
generation facilities ("Duke Energy Facilities," or in the singular, "Facility"):
Permit
Issuance
Receiving Water
Facility
Number
County
Date
for Primary
Outfall
Mayo
NC0038377
Person
07/13/2018
Mayo Reservoir
Roxboro
NC0003425
Person
04/09/2007
Hyco Reservoir
C. The Duke Energy Facilities listed above will continue to operate and generate
coal ash, and each is 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 S18-005
Duke Energy Progress, LLC
p. 3
e. The coal ash basins at the Duke Energy Facilities 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. Each of the Duke Energy
Facilities covered by this Special Order 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 Duke
Energy Facilities 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. Some of Duke Energy's coal ash impoundments contain constructed features on
or within the dam structures (such as toe drains or filter blankets) to collect
seepage. This wastewater is conveyed via a pipe or a constructed channel directly
to a receiving water. These discrete, identifiable, point source discharges are or
will be covered and regulated by the respective NPDES permits and designated as
outfalls therein. The characteristics of these wastewater flows are similar to those
discharging from other permitted outfalls for ash basin effluent. In this Special
Order, seeps that are (1) on or within the dam structures and (2) convey
wastewater via a pipe or constructed channel directly to a receiving water are
referred to as "constructed seeps." 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."
g. Non -constructed seeps at the Duke Energy Facilities 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 Duke Energy Facilities 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.

EMC SOC WQ S 18-005
Duke Energy Progress, LLC
p. 4
h. A subset of these non -constructed seeps at the Duke Energy Facilities 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
NPDES permits 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."
i. 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 ponds create and/or flow into features delineated as classified
waters of the State or Waters of the United States.
j. Collectively, the volume of non -constructed seeps is generally low compared to
the volume of permitted wastewater discharges at the Duke Energy Facilities.
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 NOVs to Duke Energy on March 4, 2016 for the seeps
that emanate from the unlined coal ash surface impoundments at the Duke Energy
Facilities.
in. 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.

EMC SOC WQ S18-005
Duke Energy Progress, LLC
p. 5
o. A list of seeps identified in the vicinities of the coal ash surface impoundments at
the Mayo and Roxboro plants, 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 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 Duke
Energy Facilities.
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.
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
these Duke Energy Facilities, pay the Department, by check payable to the
North Carolina Department of Environmental Quality, a penalty in the
amount of $150,000, calculated based upon $12,000 each for ten
constructed seeps identified prior to January 1, 2015 and $6,000 each for
five non -constructed seeps identified prior to January 1, 2015.
A certified check in the amount of $150,000.00 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.

EMC SOC WQ S 18-005
Duke Energy Progress, LLC
p. 6
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 Duke Energy Facilities 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.
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, c, and d), 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, within 210 days of the
completion of decanting at each Facility,
adequate amendments to groundwater
Corrective Action Plans or Closure Plans to
$5,000.00 per day, to a maximum of
address all remaining seeps, whether
$1,000,000.00 per electric generating
constructed or non -constructed, through
facility.
corrective action as applicable under
ara ra h 2 d of this Special Order.2
1 See especially paragraph 2(a)(2) excepting newly identified seeps from future penalties under
certain conditions.
2 Failure to adequately implement any amended Corrective Action Plan or Closure Plan will be
handled in the normal course.

EMC SOC WQ S18-005
Duke Energy Progress, LLC
p. 7
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.
Duke Energy shall accelerate compliance with the requirements of G.S. 130A-
309.210(d) and (f) such that all projects necessary to eliminate discharges of
stormwater into the surface impoundments at the Duke Energy Facilities and to
convert to dry bottom ash handling shall be complete prior to the deadline for
initiating decanting set out below.
1) Complete dry ash handling ro"ects in accordance with the followin
schedule
Facility
Fly As Bottom Ash
Mayo
Complete Complete
Roxboro
Complete 5/31 /2019
2) Initiation of Decantinz
Mayo
6/3 0/2019
Roxboro
6/30/2019
3) Completion of Decanting
Mayo
12/31 /2020
Roxboro
6/3 0/2020
This schedule is premised upon timely issuance of necessary permits or approvals,
and no requirement imposed by DWR to implement physical/chemical treatment
during decanting except as required by an NPDES permit. Should any of these
assumptions prove to be incorrect, the Parties shall renegotiate these deadlines,
provided that the final expiration date of this Special Order will not be affected by
such renegotiation.

EMC SOC WQ S18-005
Duke Energy Progress, LLC
P. 8
4) Termination of Special Order
This Special Order shall terminate on a facility -by -facility basis on the
later of the following dates:
• 180 days following completion of decanting; or
• 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 d.
below).
C. Additional Compliance Measures. Duke Energy shall undertake the following
additional compliance measures:
1) 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.
2) Once the decanting process is initiated, within thirty (30) days after the
end of each quarter, Duke Energy shall provide reports on the status of
decanting work and other activities undertaken with respect to closure of
each coal ash surface impoundment to DWR. The quarterly reports are
due by April 30, July 30, October 30 and January 30 while this Special
Order is in effect. The reports are to be submitted as follows: one copy
must be mailed to the appropriate Regional Office Supervisor for each
facility and one copy must be mailed to the Water Quality Permitting
Program, Division of Water Resources, 1617 Mail Service Center,
Raleigh, NC 27699-1617.

EMC SOC WQ S 18-005
Duke Energy Progress, LLC
P. 9
3) Duke Energy shall conduct annual comprehensive surveys of areas down
gradient of 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 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 report noted in 2(c)(2) 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.
Non -constructed seeps described in paragraph 1(h) of this SOC cannot be
dispositioned through option (2) above.
4) No later than 90 days following the completion of decanting at each
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 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 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 (3) above) during
decanting process, 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.

EMC SOC WQ S 18-005
Duke Energy Progress, LLC
P. 10
d. Further Corrective Action. Following completion of decanting, if any seeps
(including both constructed and non -constructed seeps) have not been certified by
the Director of DWR as dispositioned (as described in subparagraph c. 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 within 150 days of completion of decanting at
each Facility (i.e., within 60 days of the submittal of the Final Seep Report). 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 relevant Facility. The determination regarding whether a surface water feature
is a classified water of the State rests with DWR.
Within 60 days of the submittal of the Seep Characterization Report, Duke
Energy shall submit a complete and adequate proposed amendment to the
groundwater Corrective Action Plan and/or Closure Plan as appropriate for the
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 Plans 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(d) may such a seep, certified
as dispositioned, be omitted from the proposed amendment.

EMC SOC WQ S18-005
Duke Energy Progress, LLC
P. 11
For clarity, listed below is a summary of the timetable for the documents due after
completion of decanting (as described in 2(c)(4) and 2(d) above):
Document
Due Date
Final Seep Report
90 days after completion of decanting
150 days after completion of
Seep Characterization Report
decanting (i.e., 60 days after
submission of Final Seep Report)
Proposed amendment to groundwater
210 days after completion of
Corrective Action Plan and/or Closure
decanting (i.e., 60 days after
Plan
submission of Seep Characterization
Report)
e. 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)(1) above.
2) 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)(4) is reached.
3) 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: [e-mail]. 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.
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.

EMC SOC WQ S 18-005
Duke Energy Progress, LLC
p. 12
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 each of the Duke
Energy Facilities 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;
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 Mayo and Roxboro electric
generation stations, and listed in Attachment A to this Special Order, are hereby deemed
covered by this Special Order. Any newly -identified non -constructed seeps discovered
during the annual investigations for seeps referenced in paragraph 2(c)(3) above, or at
any other time 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.

EMC SOC NVQ S18-005
Duke Energy Progress, LLC
p. 13
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 permits
NCO038377 and NC0003425.
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.
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 18-005
Duke Energy Progress, LLC
p. 14
This Special Order by Consent shall expire no later than June 30, 2022.
Fo uke Energy Progress, LLC:
Paul Draovit6 Date
Senior Vice President, Environmental, Health & Safety
For the Nortyarlina Enyronmental Management Commission:
6
� 1,5- zz-DI�5
I DyI ',41omKn, P.E.
Cl - it of the Commission Date

Attachment A
S18-005
Duke Energy Progress, LLC — Mayo Steam Station, p.1
Constructed Seeps
m
Seep ID Approximate Location Receiving
Number Coordinates Description Receiving Waterbody Waterbody SOC Monitoring
Latitude Longitude Classification
— _ N/A— Flow is collected and
pumped back to NPDES-
S-01 36.538849 j-78.893512 ° Seep flow from west permitted wastewater
toe drain system in accordance with N/A
the pumping system's
design capacity. _
N/A — Flow is collected and
II pumped back to NPDES-
S-02 136.537964-78.891364 Seep flow from east permitted wastewater
° toe drain system in accordance with N/A
the pumping system's
— design capacity.
*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.
Interim Action
Levels
N/A N/A
N/A

Attachment A
S18-005
Duke Energy Progress, LLC — Mayo Steam Station, p.2
Non -Constructed
Seeps
Seep ID
s Approximate Location
f
Receiving
-
Number
Coordinates _
--
Latitude Longitude
Description
p
Receiving
Waterbody
Waterbody SOC Monitoring
Interim Action
Levels
..._..._
_ _
Classification
Monitoring in
—Crutchfield
Minor seep forming within filter bed at the
S-01A
36.538903-78.89351
toe of the west dam and flowing into an
UT to
Crutchfield
Branch
g
N /A - 2B Standards
unnamed tributary (UT) to Crutchfield
Branch
downstream of
Apply
Branch
all seep flow
- ---
_
contributions
_
Monitoring in
Minor seep forming within filter bed 20 feet
Crutchfield
5-02A
36.538005 i-78.891611
upslope of east dam toe drain (S-02)
Crutchfield
B Branch
N/A - 2B Standards
collection box, flowing into Crutchfield
Branch
downstream of
Apply
Branch.
all seep flow
contributions
Monitoring in
Minor seep forming just downgrade of S-02
Crutchfield
S-02B
36.537989-78.891339
collection box, flowing into Crutchfield
Crutchfield
B
, Branch
N/A - 2B Standards
Branch.
Branch
downstream of
Apply
all seep flow
Crutchfield
contributions
S-03**
36.538654 !-78.890714
Sampling Location; not a seep
B
N/A -Seep
N/A -Seep
Branch
Dispositioned
Dispositioned
._ B
-
S-04**
36.538896-78.89341
Sampling Location; not a seep
Crutchfield
Branch
j N/A -Seep
Dispositioned
N/A- Seep
Dispositioned
7]
z
S-05**
36.535039-78.891693
Ash Basin Sampling Location; not a seep
Mayo Lake
WS-V
N/A -Seep
N/A -Seep
—
— -
Dispositioned
Dispositioned
Seep flow to small channel that originates
_
S-06* 36.521971-78.88526
E_
southeast of power plant. Flows to Mayo
Lake.
Mayo Lake
WS-V
N/A - Seep
Dispositioned
N/A - Seep
Dispositioned
�-
*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.

Seep ID
Number
S-07*
Attachment A
S 18-005
Duke Energy Progress, LLC — Mayo Steam Station, p.3
Approximate Location
Coordinates
Wd '_ y
Latitude Longitude
Intermittent) observed area of wetness
downslope from former production well
location. No flow observed during recent
36.521798-78.892152 evaluations. Any flow would drain
southeast, merging with flow at S-06 before
reaching Mayo Lake. From sampling— No
_ - CCR impacts.
i— —
S-08 1 36.537502
S-09* 36.522902
I
S-10 1 36.538422
Description
Seep forms one ridge over (east) from east
-78-890398 toe drain, flowing northwest in small
channel to Crutchfield Branch.
Natural stream flow to Mayo Lake
-78.886868 originating southeast of plant. Location is
upstream of, and flowing toward S-06. From
sampling — No CCR impacts.
-78.890395 Minor seep to small channel, flowing
northwest into Crutchfield Branch.
ReceivingReceiving I
Interim Action
Waterbody Waterbody SOC Monitoring Levels
Classification
Mayo Lake WS-V N/A — Seep N/A — Seep
Dispositioned Dispositioned
I
Monitoring in
Crutchfield
Crutchfield Branch N/A — 2B Standards
Branch B
downstream of � Apply
all seep flow
contributions
Mayo Lake WS-V N/A — Seep
N/A — Seep
Dispositioned
Dispositioned
Monitoring in
Crutchfield
Crutchfield Branch
B
N/A —2BStandards
Branch downstream of
Apply
all seep flow
contributions
*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.

S-01A
S-02A
S-0
4A0 S-10
r \kmoof
S-08
Ash
Basin
Ow
SAO"
Mayo Lake

Attachment A
S18-005
Duke Energy Progress, LLC — Roxboro Steam Station, p.1
Constructed Seeps
Approximate Location
Seep ID Receiving Number --- Coordinates _ Description ReceivingWaterbodySOC Monitoring
Latitude Lon etude Waterbody
a g —. _ _ Classification
iHeated
Water N/A — Not a N/A — Seep
Chimney drain discharge from active ash Discharge Classified contribution
5-01 36.47704-79.0765 basin dam to Heated Water Discharge Pond flowing analyzed in
Pond. to NPDES Surface NPDES Permit
permit outfall Water monitoring
003
Heated
Water T N/A — Seep
5-02 1 36.47706
MIN
36.47699
-79.0767
-79.077
5-04 36.47692-79.0772
Chimney drain discharge from active ash Discharge N/A — Not a
g Classified contribution
basin dam to Heated Water Discharge Pond flowing analyzed in
Pond. to NPDES Surface NP
Water DES Permit
permit outfall monitoring
003
Heated
Water N/A — Seep
Chimney drain discharge from active ash Discharge N/A — Not a contribution
basin dam to Heated Water Discharge Pond flowing Classified
g g analyzed in
Pond. to NPDES Surface
Water NPDES Permit
permit outfall monitoring
µ 003---
Heated
Water N/A — Seep
Interim Action '
Levels
N/A — Not a
Classified Surface
Water
N/A — Not a
Classified Surface
Water
N/A — Not a
Classified Surface
Water
Chimney drain discharge from active ash Discharge
N/A —Not a
contribution N/A— Not a
basin dam to Heated Water Discharge Pond flowing
g g
Classified
analyzed in Classified Surface
Pond. to NPDES
Surface
Water
NPDES Permit Water
permit outfall
monitoring
003
* 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
S 18-005
Duke Energy Progress, LLC — Roxboro Steam Station, p.2
Approximate Location
p SeeID �
I Coordinates I Description
er Numb ------
L Latitude _ I Longitude -
Chimney drain discharge from active ash
S-05 36.47675-79.0774 I basin dam to Heated Water Discharge
Pond.
S-06 36.47669 1-79.0776
S-07
S-09
36.47674
Chimney drain discharge from active ash
basin dam to Heated Water Discharge
Pond.
Chimney drain discharge from active ash
-79.078 basin dam to Heated Water Discharge
Pond.
36.47823 I-79.05607 1 Discharge from extension of East Ash Basin
ReceivingReceiving
Interim Action
Waterbody
Waterbody
SOC Monitoring
Classification
Levels
--�`
Heated
Water
- Not a
N/A - Seep
Discharge
Cl
contribution
N/A - Not a �
Pond flowingClassified
Surface
analyzed in
Classified Surface
to NPDES
Water
NPDES Permit
Water
permit outfall
monitoring
003
Heated
_
- -
Water
N/A -Not a
N/A - Seep
a Dischar
g
Classified
contribution
N/A - Not a
Pond flowing
Surface
analyzed in
Classified Surface
to NPDES
Water
NPDES Permit
Water
permit outfall
monitoring
003
Heated
Water
N/A -Not a
N/A - Seep
Discharge
Classified
contribution
N/A- Not a
Pond flowing
Surface
analyzed in
Classified Surface
to NPDES
Water
NPDES Permit
Water
permit outfall
P
monitoring
003
N/A -
Unnamed
Monitoring
tributary (UT)
WS-V; B
Established per
See page 6 of this
to Hyco Lake
Terms of NPDES
Attachment A
Permit
* 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.

Non -Constructed Seeps
4 Seep ID Approximate Location
Number Coordinates __1
Latitude - Longitude 6
Attachment A
S18-005
Duke Energy Progress, LLC — Roxboro Steam Station, p.3
Description
Seepage area approximately 30 feet west of
chimney drain V. Drainage/flow is to the
S-08 36.47672-79.0781 Heated Water Discharge Pond. This non -
constructed seep flows to a portion of an
NPDES wastewater treatment system.
36.47917
5-11** 1 36,47857
5-12** 36,4781
5-13** 36.48618
Minimal AOW with no flow located on
-79.057 northern portion of East Ash Basin berm.
Any flow would drain to extension of east
ash basin. _
Minimal AOW with no flow located on
-79.0567 central portion of East Ash Basin berm. Any
flow would drain to extension of east ash
basin.
Minimal AOW with no flow located on
-79.0567 southern portion of East Ash Basin berm.
Any flow would drain to extension of east
ash basin.
Not a seep. Outfall of culvert channeling
flow from UT on east side of facility that
-79.0596 receives flow from East Ash Basin extension
and 5-21. Flows to facility water intake
i channel (Hyco Lake).
Receiving
Waterbody
Heated
Water
Discharge
Pond
flowing to
NPDES
permit
outfall 003
Extension of
East Ash
Basin
Extension of
East Ash
Basin
Extension of
East Ash
Basin
Receiving
Waterbody
Classification
N/A — Not a
Classified
Surface
Water
SOC Monitoring
N/A — Seep
contribution
analyzed in
NPDES Permit
monitoring
N/A — Not a
Classified
N/A — Seep
Surface
Dispositioned
Water
N/A — Not a
Classified
N/A — Seep
Surface
Dispositioned
Water_
N/A — Not a
Classified N/A — Seep
Surface Dispositioned
Water
See page 6 of
Hyco Lake WS-V; B this Attachment
A
* 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.
Interim Action Levels
I
N/A — Not a Classified
Surface Water
N/A — Seep
Dispositioned
t
N/A — Seep
Dispositioned
N/A — Seep
Dispositioned
See page 6 of this
Attachment A
-_..I

Attachment A
S18-005
Duke Energy Progress, LLC — Roxboro Steam Station, p.4
Seep ID Approximate Location
Number ---- Coordinates Description
Latitude Longitude
Location is the end of a 24" pipe draining a
boggy area south of the gypsum pad. Pipe
extends under the pad toward the
S-14 36.48374-79.0638 northwest, under railroad tracks, with
discharge to a ditch that drains to the
l Heated Water Discharge Pond. This non-
k constructed seep flows to a portion of an
T treatment system.
NPDES wastewater
Seepage to wet area north of active ash
basin. Flows north into a waterbody flowing
S-18 36.47795-79.0737 i to Heated Water Discharge Pond.
Waterbody is potentially WOTUS. This non -
I constructed seep flows to a portion of an
NPDES wastewater treatment system.
AOW with minimal flow located adjacent to
the 5-01 chimney drain at the east end of
5-19 36.47718-79,0764 the 1973 ash basin dam. Any flow moves
toward the Heated Water Discharge Pond.
This non -constructed seep flows to a portion
of an NPDES wastewater treatment system.
S-20 1 36.47799 4
Seep flow to small stream channel northeast
of West Ash Basin dam. Drains west through
79 0749 wetland to Heated Water Discharge Pond.
No sample data due to lack of flow. This
non -constructed seep flows to a portion of
Receiving
Waterbody
Heated
Water
Discharge
Pond
flowing to
NPDES
permit
o_utfall 003
Small
stream
flowing to
Heated
Water
Discharge
1 Pond
Heated
Water
Discharge
Pond
flowing to
NPDES
permit
outfall 003
Small
stream
flowing to
Heated
Water
Receiving
Waterbody
Classification
SOC Monitoring Interim Action Levels
N/A — Not a
N/A — Seep
Classified
contribution
Surface
analyzed in
Water
NPDES Permit
monitoring
N/A — Not a Classified
Surface Water I
Quarterly
monitoring at
WS-V; B point prior to Hardness 1200 mg/L
(Hyco Lake) flowing into TDS 1600 mgjL
Sulfates 1000 mgjL
Heated Water
Discharge Pond.
N/A — Not a N/A —Seep
contribution
Classified
I
f N/A — Not a Classified
analyzed in
Surface
Surface Water
NPDES Permit
Water
monitoring
WS-V; B
(Hyco Lake)
an NPDES wastewater treatment system. Discharge
Pond_ -
* 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.
Quarterly
monitoring at Hardness 1200 mg/L
point prior to TDS 1600 mg/L
flowing into Sulfates 1000 mgjL
Heated Water
Discharge Pond.

Seep ID
Number
S-21
5-22
S-23
Attachment A
SIB-005
Duke Energy Progress, LLC — Roxboro Steam Station, p.5
Approximate Location w
Coordinates_ Description
Latitude Longitude —
Seep emerging downgradient of stormwater
basin.below East Ash Basin. Flow drains
36.48246 -79,0119 adjacent to East Ash Basin effluent channel
from point of emergence to UT to Hyco
Lake.
36,48184 ;-79.0657
Located just east of the cooling tower
ponds. Wetness emerges from several
points on the hill side of the area. Minimal
flow could eventually reach Outfall 003. No
sample data to date due to lack of flow. This
non -constructed seep flows to a portion of
an NPDES wastewater treatment system.
Located on sloped area along the southwest
end of the East Ash Basin dam. Large AOW
but with little to no flow. Diffuse flow is
directed to channel with discharge to
36.48035-79.0685 Heated Water Discharge Pond and Outfall
003. No sample data to date due to lack of
flow. This non -constructed seep flows to a
portion of an NPDES wastewater treatment
j systems
Receiving
Waterbody
UT to Hyco
Lake
Receiving
Waterbody SOC Monitoring Interim Action Levels
Classification
WS-V; B
(Hyco Lake)
Heated
Water
Discharge
N/A — Not a
Pond
Classified
flowing to
Surface
NPDES
Water
permit
outfal 1003
Heated
Water
Discharge
Pond
flowing to
NPDES
permit
outfall 003
N/A — Not a
Classified
Surface
Water
* 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
Monitoring of
I
UT to Hyco Lake
Sulfates 1000 mg/L
at established
Hardness 1000 mg/L
Duke Energy
TDS 1000 mg/L
S-13 monitoring
Copper 5 µg/L
location
N/A — Seep
contribution
analyzed in
NPDES Permit
monitoring
N/A — Seep
contribution
analyzed in
NPDES Permit
monitoring
N/A — Not a Classified
Surface Water
N/A — Not a Classified
Surface Water

Instream Monitoring
Description
Instream Monitoring to
evaluate potential impacts
from S-9 and 5-21
Attachment A
S18-005
Duke Energy Progress, LLC — Roxboro Steam Station, p.6
Receiving Waterbody Receiving Waterbody
Classification
Unnamed Tributary f
(UT) to Hyco Lake I WS-V, B
SOC Monitoring Interim Action Levels
Monitoring of UT to Hyco Lake at Sulfates 1000 mg/L
established Duke Energy S-13 monitoring Hardness 1000 mg/L
location TDS 1000 mg/L
Copper 5 µg/L
* 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

Hyco
La ke
Heated "
Water
Discharge
Pond
Ash dFill _
r
-- 1
11 East Ash Basin
West Ash Basin �._ f • -�

SOC S 18-005
Duke Energy Progress, LLC — Mayo & Roxboro Plants
Attachment B
Monitoring Requirements
The following represents the parameters to be analyzed and reported at all monitoring locations
designated within this Special Order.
Parameter
TSS
Oil and Grease
pH
Fluoride
Total Mercury
Total Barium
Total Zinc
Total Arsenic
Total Boron
Total Cadmium
Total Chromium
Total Copper
Reporting Units
mg1L
mg/L
Standard Units (s. u.)
Ng/L
ng/L
pg/L
Ng/L
erg/L
pg/L
pg/L
lug/L
pg/L
Total Thallium
pg/L
Total Lead
pg/L
Total Nickel
Ng/L
Total Selenium
pg/L
Nitrate/Nitrite as N
mg/L
Bromides
Sulfates
Chlorides
TDS
Total Hardness
Temperature
Conductivity, Nmho/cm
mg/L
mg/L
mg/L
mg/L
mg/L
°C
pmho/cm
Monitoring
Annually
Annually
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly

Seep Management Plan Amendment to Corrective Action Plan September 2, 2020
Duke Energy Progress, LLC, Roxboro Steam Electric Plant, Semora, NC SynTerra
APPENDIX B
MANN-KENDALL ANALYSIS, AUGUST 2020

,(VIP
synTerra
MANN-KENDALL TREND TEST ANALYSIS
AUGUST 2020
PREPARED FOR
DUKE
ENERGY
G
PROGRESS
DUKE ENERGY PROGRESS, LLC

Mann -Kendall Trend Test Analysis August 2020
Roxboro Steam Electric Plant, Duke Energy Progress, LLC SynTerra
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
Figure 2
Time Versus Dissolved Arsenic
Figure 3
Time Versus s Total Boron
Figure 4
Time Versus Total Barium
Figure 5
Time Versus Dissolved Cadmium
Figure 6
Time Versus Total Chloride
Figure 7
Time Versus Dissolved Chromium
Figure 8
Time Versus Total Chromium
Figure 9
Time Versus Dissolved Copper
Figure 10
Time Versus Total Fluoride
Figure 11
Time Versus Total Hardness
Figure 12
Time Versus Total Mercury
Figure 13
Time Versus Total Nitrate + Nitrite
Figure 14
Time Versus Dissolved Nickel
Figure 15
Time Versus Total Nickel
Figure 16
Time Versus Dissolved Lead
Figure 17
Time Versus pH
Figure 18
Time Versus Total Selenium
Figure 19
Time Versus Total Sulfate
Figure 20
Time Versus Total Dissolved Solids
Figure 21
Time Versus Total Thallium
Figure 22
Time Versus Dissolved Zinc
LIST OF TABLES
Table 1 Sampling Locations and Constituents Included in Plots of Concentration
Over Time
Table 2 Results of Mann -Kendall Trend Test
Page i

Mann -Kendall Trend Test Analysis August 2020
Roxboro Steam Electric Plant, Duke Energy Progress, LLC SynTerra
1.0 THE MANN-KENDALL TREND TEST
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 at Roxboro, the data must first be processed as
follows:
• Samples taken in the same month must be removed. If more than one sample is
present in a calendar month, the most complete sample will be kept. If samples
are identically complete, the oldest sample is kept. All other samples in that
month will be considered duplicates and removed.
• If multiple detection limits are present, only the lowest non -detect values are
included for each constituent.
• Non -detects are treated as the detection limit.
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: 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.
Page 1-1

Mann -Kendall Trend Test Analysis August 2020
Roxboro Steam Electric Plant, Duke Energy Progress, LLC SynTerra
2.0 TIME VERSUS CONCENTRATION PLOTS
Plots of concentration over time provide a visual representation of possible trends in the
data. All plots can be viewed in Figure 1 to Figure 22. 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. All locations and constituents included in these plots
can be found 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, whereas non -detect
measurements are shown as an open circle.
Page 2-1

Mann -Kendall Trend Test Analysis August 2020
Roxboro Steam Electric Plant, Duke Energy Progress, LLC SynTerra
3.0 MANN-KENDALL TREND TEST RESULTS
Results of the Mann -Kendall trend tests are displayed in Table 2. Trend analysis could
be performed for only 37 location -constituent pairs due to a lack of detect
measurements. 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 48 percent. The
large number of non -detect measurements present in the dataset indicates that many
constituent -location pairs have concentrations less than the regulatory limit and are not
predicted to be of concern at Site.
Locations not displayed in Table 2 are excluded due to having less than minimum
number of samples required to run the "Kendall" package in RStudio. Locations must
have at least three samples to be included, but individual location -constituent pairs
with less than three measurements can be analyzed as long as the location itself has
three samples. However, it is important to note that location -constituent pairs with less
than four detects cannot be analyzed for trends based on the criteria described in
Section 1.0.
Out of the 37 constituent -location pairs that have trend conclusions, 73 percent are
stable with no trends (27 out of 37 constituent -location pairs), and 27 percent have
statistically significant decreasing trends (10 out of 37 constituent -location pairs).
Overall, the results of the Mann -Kendall trend tests indicate a system that has been
geochemically stable over the sampling period, with concentrations of constituents
remaining stable or in some cases decreasing over time.

Mann -Kendall Trend Test Analysis August 2020
Roxboro Steam Electric Plant, Duke Energy Progress, LLC SynTerra
FIGURES

25
20
15
10
J 5
am
70
m
Q 25
0
20
15
10
5
0
S-18
LO co ti oo m o
r r r r r (\J
O CD O O O O
N N N N N N
LEGEND NOTES
- Stable, no trends Trends are denoted by the box color, if there is no color the data
-0-Non-detect could not be analyzed for trends.
+ Detect - Statistically Significant Decreasing Trend
-0 - Statistically Significant Increasing Trend
No Color - Cannot Analyze for Trends
S-20
Ln cm ti co rn o
o r r r r r N
N OC\1 N N N N
Date
P jfi DUKE
ENERGY
PROGRESS
,0'
synTerra
DRAWN BY: K. MARSAC DATE: 07/23//2020
REVISED BY: K. MARSAC
CHECKED BY: K.LAWING
APPROVED BY: C. EADY
PROJECT MANAGER: C. EADY
www.synterracorp.com
FIGURE 1
TIME VERSUS TOTAL ARSENIC
MANN KENDALL TREND TEST ANALYSIS
ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA

4
3
2
J 1
am
'F 0
m
Q
m
4
0
G 3
2
1
S-18
S-14
S-20
CO I` 00 O O C4 ti 00 O O
O O O O O O O O O O
N N N N N N N N N N
Date
LEGEND NOTES ,f> DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data ENERGY REVISED BY: K. MARSAC
� Non -detect + could not be analyzed for trends. Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. LAWING
-0 - Statistically Significant Increasing Trend
No Color -Cannot Analyze for Trends 410 APPROVED BY: C. EADY
PROJECT MANAGER: C. EADY
synTerra
www.synterracorp.com
FIGURE 2
TIME VERSUS DISSOLVED ARSENIC
MANN KENDALL TREND TEST ANALYSIS
ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA

J
Cn
100000
10000
1000
MR
_
O
O
m 100000
10000
1000
100
S-08
S-20
LO (0 I` oo m o LO co ti ao m O
N T_ T_ T_ T_ Ir- N
O O O O O O O O O O O O
N N N N N N N N N N N N
Date
LEGEND NOTES ,�> DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data ENERGY REVISED BY: K. MARSAC
� Non -detect + could not be analyzed for trends. Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. LAWING
-0 - Statistically Significant Increasing Trend
No Color -Cannot Analyze for Trends /p APPROVED BY: C. EADY
�r PROJECT MANAGER: C. EADY
synTerra
www.synterracorp.com
FIGURE 3
TIME VERSUS TOTAL BORON
MANN KENDALL TREND TEST ANALYSIS
ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA

250
200
150
100
J
am 50
.­o
E
'i
m 250
c�
H 200
150
100
50
Ln co ti oo m o U-) co
N N N N N N O O
Date
S-14
S-20
ti co O O
T_ T_ N
O O O O
N N N N
LEGEND NOTES DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data P ENERGY REVISED BY: K. MARSAC FIGURE 4
� Non -detect could not be analyzed for trends. TIME VERSUS TOTAL BARIUM
+ Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. CAWING
—0
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color - Cannot Analyze for Trends fp APPROVED BY: C. : C. ROXBORO STEAM ELECTRIC PLANT
�r PROJECT MANAGER: EADY synTerra
www.synterracorp.com SENORA, NORTH CAROLINA

0.20
0.15
0.10
J
CD 0.05
.­o
E
0.00
c�
U
m
0.20
0
0.15
0.10
0.05
m m
0
S-18
S-14
S-20
rn O rn O
N N
O O O O
N N N N
Date
0
LEGEND NOTES DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data ENERGY REVISED BY: K. MARSAC FIGURE 5
-0- Non -detect could not be analyzed for trends. TIME VERSUS DISSOLVED CADMIUM
-0- Detect -Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. CAWING
—0
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color - Cannot Analyze for Trends /p APPROVED BY: C. : C. ROXBORO STEAM ELECTRIC PLANT
�r PROJECT MANAGER: EADY SENORA, NORTH CAROLINA
�T� www.synterracorp.com

1000
100
10
1000
C
10
S-08
LO (0 ti oo rn O Ln (.0
N T_
O O O O O O O a
N N N N N N N CN
Date
S-14
S-20
ti ao rn O
T_ T_ N
O O O O
N N N N
LEGEND NOTES DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data P ENERGY REVISED BY: K. MARSAC FIGURE 6
� Non -detect could not be analyzed for trends. TIME VERSUS TOTAL CHLORIDE
+ Detect -Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. CAWING
—0
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color - Cannot Analyze for Trends fp APPROVED BY: C. : C. ROXBORO STEAM ELECTRIC PLANT
�r PROJECT MANAGER: EADY synTerra
www.synterracorp.com SENORA, NORTH CAROLINA

2.0
1.5
1.0
J_
an 0.5
E
0.0
0
2.0
m
0
N 1.5
W11
0.5
m
33
3m
S-14
S-20
C4 ti 00 07 O C4 ti 00 rn O
T_ T_ N T_ T_ 7- N
N N N N N N �N N N N
Date
LEGEND NOTES ,f> DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data ENERGY REVISED BY: K. MARSAC
-0- Non -detect -0-could not be analyzed for trends. Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. LAWING
-0 - Statistically Significant Increasing Trend
No Color -Cannot Analyze for Trends 410 APPROVED BY: C. EADY
PROJECT MANAGER: C. EADY
synTerra
www.synterracorp.com
FIGURE 7
TIME VERSUS DISSOLVED CHROMIUM
MANN KENDALL TREND TEST ANALYSIS
ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA

3
2
i
J
Cn
E 0
O
3
U
O
H
1
0
S-18
S-14
S-20
LO co ti oo m O LO (0 r` oo m O
T_ T_ T_ T_ T_ N T_ T_ T_ T_ T_ N
O O O O O O O O O O O O
N N N N N N N N N N N N
Date
LEGEND NOTES ,�> DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data ENERGY REVISED BY: K. MARSAC
-0- Non -detect -0-could not be analyzed for trends. Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. LAWING
-0 - Statistically Significant Increasing Trend
No Color -Cannot Analyze for Trends /p APPROVED BY: C. EADY
�r PROJECT MANAGER: C. EADY
SnTErra www.synterracorp.com
FIGURE 8
TIME VERSUS TOTAL CHROMIUM
MANN KENDALL TREND TEST ANALYSIS
ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA

2.0
1.5
1.0
J 0.5
am
Q 0.0
CL
0
U
2.0
0
G 1.5
W11
0.5
m
33
3m
S-14
S-20
C4 ti 00 07 O C4 ti 00 rn O
T_ T_ N T_ T_ 7- N
N N N N N N �N N N N
Date
LEGEND NOTES ,f> DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data ENERGY REVISED BY: K. MARSAC
-0- Non -detect -0-could not be analyzed for trends. Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. LAWING
-0 - Statistically Significant Increasing Trend
No Color -Cannot Analyze for Trends 410 APPROVED BY: C. EADY
PROJECT MANAGER: C. EADY
synTerra
www.synterracorp.com
FIGURE 9
TIME VERSUS DISSOLVED COPPER
MANN KENDALL TREND TEST ANALYSIS
ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA

1.25
1.00
0.75
0.50
0.25
CD
E
0.00
'i
1.25
0 1.00
H
0.75
0.50
0.25
0.00
S-08
S-20
S-14
ti oo m o
(\1
0 0 0 0 0 0
LO ( ti oo m o
N
NN N �N N N N
Date
LEGEND NOTES DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data ENERGY REVISED BY: K. MARSAC FIGURE 10
� Non -detect could not be analyzed for trends. TIME VERSUS TOTAL FLUORIDE
+ Detect -Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. CAWING
—0
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color - Cannot Analyze for Trends /p APPROVED BY: C. : C. ROXBORO STEAM ELECTRIC PLANT
�r PROJECT MANAGER: EADY SENORA, NORTH CAROLINA
�T� www.synterracorp.com

1 II
3000
2000
cm 1000
E
m
c�
= 4000
c�
0
H
3000
2000
1000
S-18
O O O O O O O O
N N N N N N N N
Date
S-14
S-20
ti oo rn O
N
O O O O
N N N N
LEGEND NOTES DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data P ENERGY REVISED BY: K. MARSAC FIGURE 11
� Non -detect could not be analyzed for trends. TIME VERSUS TOTAL HARDNESS
+ Detect -Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. CAWING
—0
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color - Cannot Analyze for Trends fp APPROVED BY: C. : C. ROXBORO STEAM ELECTRIC PLANT
�r PROJECT MANAGER: EADY synTerra
www.synterracorp.com SENORA, NORTH CAROLINA

J
Cm
m
0
H
0.1000
0.0100
0.0010
0.0001
0.1000
0.0100
0.0010
0.0001
(0 ti U) o c4 r` ao rn O
N T_ T N
O O CD O O O O O O O
N N N N N N N N N N
Date
LEGEND NOTES DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data P ENERGY REVISED BY: K. MARSAC FIGURE 12
-0- Non -detect could not be analyzed for trends. TIME VERSUS TOTAL MERCURY
-0- Detect -Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. CAWING
—0
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color - Cannot Analyze for Trends fp APPROVED BY: C. : C. ROXBORO STEAM ELECTRIC PLANT
�r PROJECT MANAGER: EADY synTerra
www.synterracorp.com SENORA, NORTH CAROLINA

J
Z
6)
E
Z
m
c�
Z
0
H
1.00
0.10
0.01
1.00
0.10
0.01
S-18
CO ti oo m O
N
No O N O O
LEGEND NOTES
- Stable, no trends Trends are denoted by the box color, if there is no color the data
—0—Non-detect could not be analyzed for trends.
+ Detect - Statistically Significant Decreasing Trend
—0 - Statistically Significant Increasing Trend
No Color - Cannot Analyze for Trends
S-20
c0 ti oo m 0
N
O N O O O
04
Date
�>DUKE
ENERGY
PROGRESS
,0p
WnTena
DRAWN BY: K. MARSAC DATE: 07/23//2020
REVISED BY: K. MARSAC
CHECKED BY: K.LAWING
APPROVED BY: C. EADY
PROJECT MANAGER: C. EADY
www.synterracorp.com
FIGURE 13
TIME VERSUS TOTAL NITRATE + NITRITE
MANN KENDALL TREND TEST ANALYSIS
ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA

3
2
i
J
cm
m 0
C�
3
0
0
2
1
S-14
S-20
co ti oo rn o c0 ti oo rn o
oo N N N N O O O O O
Date
LEGEND NOTES DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data ENERGY REVISED BY: K. MARSAC FIGURE 14
� Non -detect could not be analyzed for trends. TIME VERSUS DISSOLVED NICKEL
+ Detect -Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. CAWING
—0
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color - Cannot Analyze for Trends /p APPROVED BY: C. : C. ROXBORO STEAM ELECTRIC PLANT
�r PROJECT MANAGER: EADY SENORA, NORTH CAROLINA
�T� www.synterracorp.com

A
0
2
J
cm
.� 0
v
z 6
0
H
4
2
3m
S-20
LO (0 1` 00 rn O L0 c4 ti 00 rn O
T T_ N T N
O O O O O O O O O O O O
N N N N N N N N N N N N
Date
LEGEND NOTES ,f> DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data ENERGY REVISED BY: K. MARSAC
-0- Non -detect -0-could not be analyzed for trends. Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. LAWING
-0 - Statistically Significant Increasing Trend
No Color -Cannot Analyze for Trends 410 APPROVED BY: C. EADY
PROJECT MANAGER: C. EADY
synTerra
www.synterracorp.com
FIGURE 15
TIME VERSUS TOTAL NICKEL
MANN KENDALL TREND TEST ANALYSIS
ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA

mil
0.3
0.2
0.0
m
J
> 0.4
0
0.2
0.1
m
S-18
S-14
S-20
rn O rn O
N N
O O O O
N N N N
Date
0
LEGEND NOTES DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data P ENERGY REVISED BY: K. MARSAC FIGURE 16
� Non -detect could not be analyzed for trends. TIME VERSUS DISSOLVED LEAD
+ Detect -Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. CAWING
—0
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
`
No Color - Cannot Analyze for Trends `10 APPROVED BY: C. : C. ROXBORO STEAM ELECTRIC PLANT
PROJECT MANAGER: EADY synTerra
www.synterracorp.com SENORA, NORTH CAROLINA

361
�Jl
7.5
7.0
6.5
M
= 8.5
7.5
7.0
6.5
LO (.0 ti 00 rn o LO
T_ T_ N T
OC\1 N N N N N N OC\1
Date
S-14
ti 00 O O
T_ T_ N
O O O O
N N N N
LEGEND NOTES DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
� Non -detect
- Stable, no trends Trends are denoted by the box color, if there is no color the data P ENERGY REVISED BY: K. MARSAC FIGURE 17 + could not be analyzed for trends. Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. CAWING TIME VERSUS PH
—0 - Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color - Cannot Analyze for Trends fp APPROVED BY: C. : C. ROXBORO STEAM ELECTRIC PLANT
�r PROJECT MANAGER: EADY synTerra
www.synterracorp.com SENORA, NORTH CAROLINA

100
10
J
Cn
E 1
m
100
c�
0
H
10
33
3m
S-14
S-20
LO (0 ti oo m o LO co ti oo m O
T_ T_ T_ T_ T_ N T_ T_ T_ T_ T_ N
O O O O O O O O O O O O
N N N N N N N N N N N N
Date
LEGEND NOTES ,�> DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data ENERGY REVISED BY: K. MARSAC
-0- Non -detect -0-could not be analyzed for trends. Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. LAWING
-0 - Statistically Significant Increasing Trend
No Color -Cannot Analyze for Trends /p APPROVED BY: C. EADY
�r PROJECT MANAGER: C. EADY
SnTErra www.synterracorp.com
FIGURE 18
TIME VERSUS TOTAL SELENIUM
MANN KENDALL TREND TEST ANALYSIS
ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA

1250
1000
750
500
� 250
am
E 0
m
c�
1250
Cn
4-0
0 1000
750
500
250
S-08
S-18
LO (0 ti oo m O LO c4
N
O O O O O O O O
N N N N N N N N
Date
ti oo rn O
N
O O O O
N N N N
LEGEND NOTES DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data P ENERGY REVISED BY: K. MARSAC FIGURE 19
-0- Non -detect could not be analyzed for trends. TIME VERSUS TOTAL SULFATE
-0- Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. CAWING
—0
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color - Cannot Analyze for Trends fp APPROVED BY: C. : C. ROXBORO STEAM ELECTRIC PLANT
�r PROJECT MANAGER: EADY synTerra
www.synterracorp.com SENORA, NORTH CAROLINA

J
cm
E 2000
N
5t�
T
m
0
G 6000
4-0
H
1 II
2000
S-08
S-18
LO (0 ti 0o m O
N
O O O O O O
N N N N N N
LEGEND NOTES
- Stable, no trends Trends are denoted by the box color, if there is no color the data
—0—Non-detect could not be analyzed for trends.
+ Detect - Statistically Significant Decreasing Trend
—0 - Statistically Significant Increasing Trend
No Color - Cannot Analyze for Trends
S-14
Ln O ti 00 O O
ON
Date
P jfi DUKE
ENERGY
PROGRESS
,0'
synTerra
DRAWN BY: K. MARSAC DATE: 07/23H2020
REVISED BY: K. MARSAC
CHECKED BY: K.LAWING
APPROVED BY: C. EADY
PROJECT MANAGER: C. EADY
www.synterracorp.com
FIGURE 20
TIME VERSUS TOTAL DISSOLVED
SOLIDS
MANN KENDALL TREND TEST ANALYSIS
ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA

mil
0.3
0.2
J 0.1
am
E 0.0
c�
0.4
c�
0
~ 0.3
0.2
0.1
m
33
S-14
S-20
LO co I` oo m O LO co ti oo m O
T_ T_ T_ T_ T_ (V T_ T_ T_ T_ T_ (\1
O O O O O O O O O O O O
N N N N N N N N N N N N
Date
LEGEND NOTES ,�> DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data ENERGY REVISED BY: K. MARSAC
� Non -detect + could not be analyzed for trends. Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. LAWING
-0 - Statistically Significant Increasing Trend
No Color -Cannot Analyze for Trends /p APPROVED BY: C. EADY
�r PROJECT MANAGER: C. EADY
SnTErra www.synterracorp.com
FIGURE 21
TIME VERSUS TOTAL THALLIUM
MANN KENDALL TREND TEST ANALYSIS
ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA

4
oil
J
0
0
R
> 6
0
4
2
0
33
0
S-18
S-14
S-20
CO I` 00 O O C4 ti 00 O O
O O O O O O O O O O
N N N N N N N N N N
Date
LEGEND NOTES ,f> DUKE DRAWN BY: K. MARSAC DATE:07/23//2020
- Stable, no trends Trends are denoted by the box color, if there is no color the data ENERGY REVISED BY: K. MARSAC
-0- Non -detect -0-could not be analyzed for trends. Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K. LAWING
-0 - Statistically Significant Increasing Trend
No Color -Cannot Analyze for Trends 410 APPROVED BY: C. EADY
PROJECT MANAGER: C. EADY
synTerra
www.synterracorp.com
FIGURE 22
TIME VERSUS DISSOLVED ZINC
MANN KENDALL TREND TEST ANALYSIS
ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA

Mann -Kendall Trend Test Analysis August 2020
Roxboro Steam Electric Plant, Duke Energy Progress, LLC SynTerra
TABLES

Mann -Kendall Trend Test Analysis August 2020
Roxboro Steam Electric Plant, Duke Energy Progress, LLC SynTerra
TABLE 1
SAMPLING LOCATIONS AND CONSTITUENTS INCLUDED IN PLOTS
OF CONCENTRATIONS OVER TIME
Sampling Locations
Constituents
S-08
Total Arsenic
S-14
Dissolved Arsenic
S-18
Total Boron
S-20
Total Barium
Dissolved Cadmium
Total Chloride
Dissolved Chromium
Total Chromium
Dissolved Copper
Total Fluoride
Total Hardness
Total Mercury
Total Nitrate + Nitrite
Dissolved Nickel
Total Nickel
Dissolved Lead
pH
Total Selenium
Total Sulfate
Total Dissolved Solids
Total Thallium
Dissolved Zinc
Prepared by: KTL Checked by: KEM
Note:
If a location -constituent pair does not have a plot, data was not available for that pair.

Mann -Kendall Trend Test Analysis
Roxboro Steam Electric Plant, Duke Energy Progress, LLC
TABLE 2
RESULTS OF MANN-KENDALL TREND TEST
gust 2020
SynTerra
Well ID
Analyte
Number of
Samples
Non-
Detects
Detects
PercentageIs
of Non-
Detects
Trend Analysis
Applicable?
Two -Sided
P Value
S Value
Trend Conclusion
S-08
Total Boron
8
0
8
0
Yes
0.00443
-24
Statistically significant decreasing trend
S-14
Total Boron
10
0
10
0
Yes
1
-
Stable, no significant trend
S-18
Total Boron
11
0
11
0
Yes
0.06171
-25
Statistically significant decreasing trend
S-20
Total Boron
4
0
4
0
Yes
0.30818
-
Stable, no significant trend
S-08
Total Chloride
8
0
8
0
Yes
0.00168
-26
Statistically significant decreasing trend
5-14
Total Chloride
10
0
10
0
Yes
0.92844
-
Stable, no significant trend
S-18
Total Chloride
11
0
11
0
Yes
0.24148
-
Stable, no significant trend
5-20
Total Chloride
4
0
4
0
Yes
0.7341
-
Stable, no significant trend
S-08
Total Sulfate
8
0
8
0
Yes
0.15787
-
Stable, no significant trend
5-14
Total Sulfate
10
0
10
0
Yes
0.78762
-
Stable, no significant trend
S-18
Total Sulfate
11
0
11
0
Yes
0.03389
-28
Statistically significant decreasing trend
S-20
Total Sulfate
4
0
4
0
Yes
0.7341
-
Stable, no significant trend
S-08
Total Dissolved Solids
8
0
8
0
Yes
0.01874
-20
Statistically significant decreasing trend
S-14
Total Dissolved Solids
10
0
10
0
Yes
0.78592
-
Stable, no significant trend
S-18
Total Dissolved Solids
11
0
11
0
Yes
0.07249
-24
Statistically significant decreasing trend
S-20
Total Dissolved Solids
4
0
4
0
Yes
1
-
Stable, no significant trend
S-08
Total Arsenic
8
0
8
0
Yes
0.53619
-
Stable, no significant trend
S-14
Total Arsenic
10
0
10
0
Yes
0.15241
-
Stable, no significant trend
S-18
Total Arsenic
11
11
0
100
No
-
-
Cannot Analyze for Trends
S-20
Total Arsenic
4
4
0
100
No
-
-
Cannot Analyze for Trends
S-08
Total Barium
8
0
8
0
Yes
0.001982
-26
Statistically significant decreasing trend
S-14
Total Barium
10
0
10
0
Yes
0.049098
-23
Statistically significant decreasing trend
S-18
Total Barium
11
0
it
0
Yes
0.347262
-
Stable, no significant trend
S-20
Total Barium
4
0
4
0
Yes
0.734095
-
Stable, no significant trend
S-08
Total Chromium
8
8
0
100
No
-
-
Cannot Analyze for Trends
S-14
Total Chromium
10
7
3
70
No
-
-
Cannot Analyze for Trends
S-18
Total Chromium
11
11
0
100
No
-
-
Cannot Analyze for Trends
S-20
Total Chromium
4
4
0
100
No
-
-
Cannot Analyze for Trends
S-08
Total Mercury
5
5
0
100
No
-
-
Cannot Analyze for Trends
S-14
Total Mercury
9
0
9
0
Yes
0.1753
-
Stable, no significant trend
S-18
Total Mercury
11
5
6
45
Yes
0.7071
-
Stable, no significant trend
S-20
Total Mercury
4
0
4
0
Yes
0.7341
-
Stable, no significant trend
S-08
Total Nickel
8
0
8
0
Yes
0.1078
-
Stable, no significant trend
S-14
Total Nickel
10
1
9
10
Yes
0.3481
-
Stable, no significant trend
S-18
Total Nickel
11
8
3
73
No
-
-
Cannot Analyze for Trends

Mann -Kendall Trend Test Analysis
Roxboro Steam Electric Plant, Duke Energy Progress, LLC
TABLE 2
RESULTS OF MANN-KENDALL TREND TEST (CONTINUED)
gust 2020
SynTerra
Well ID
Analyte
Number of
Samples
Non-
Detects
Detects
PercentageIs
of Non-
Detects
Trend Analysis
Applicable?
Two -Sided
P Value
S Value
Trend Conclusion
S-20
Total Nickel
4
4
0
100
No
-
-
Cannot Analyze for Trends
S-08
Total Nitrate + Nitrite
6
3
3
50
No
-
-
Cannot Analyze for Trends
S-14
Total Nitrate + Nitrite
8
2
6
25
Yes
0.5661
-
Stable, no significant trend
S-18
Total Nitrate + Nitrite
11
7
4
64
No
-
-
Cannot Analyze for Trends
S-20
Total Nitrate + Nitrite
4
1
3
25
No
-
-
Cannot Analyze for Trends
5-08
Total Thallium
8
8
0
100
No
-
-
Cannot Analyze for Trends
S-14
Total Thallium
10
10
0
100
No
-
-
Cannot Analyze for Trends
5-18
Total Thallium
11
11
0
100
No
-
-
Cannot Analyze for Trends
S-20
Total Thallium
4
4
0
100
No
-
-
Cannot Analyze for Trends
5-08
Total Selenium
8
8
0
100
No
-
-
Cannot Analyze for Trends
S-14
Total Selenium
9
0
9
0
Yes
0.2945
-
Stable, no significant trend
S-18
Total Selenium
11
11
0
100
No
-
-
Cannot Analyze for Trends
S-20
Total Selenium
4
4
0
100
No
-
-
Cannot Analyze for Trends
S-08
Dissolved Arsenic
1
0
1
0
No
-
-
Cannot Analyze for Trends
S-14
Dissolved Arsenic
3
0
3
0
No
-
-
Cannot Analyze for Trends
S-18
Dissolved Arsenic
6
6
0
100
No
-
-
Cannot Analyze for Trends
S-20
Dissolved Arsenic
4
4
0
100
No
-
-
Cannot Analyze for Trends
S-08
Dissolved Cadmium
1
1
0
100
No
-
-
Cannot Analyze for Trends
S-14
Dissolved Cadmium
1
1
0
100
No
-
-
Cannot Analyze for Trends
S-18
Dissolved Cadmium
6
6
0
100
No
-
-
Cannot Analyze for Trends
S-20
Dissolved Cadmium
4
4
0
100
No
-
-
Cannot Analyze for Trends
S-08
Dissolved Chromium
1
1
0
100
No
-
-
Cannot Analyze for Trends
S-14
Dissolved Chromium
3
3
0
100
No
-
-
Cannot Analyze for Trends
S-18
Dissolved Chromium
6
6
0
100
No
-
-
Cannot Analyze for Trends
S-20
Dissolved Chromium
4
4
0
100
No
-
-
Cannot Analyze for Trends
S-08
Dissolved Copper
1
0
1
0
No
-
-
Cannot Analyze for Trends
S-14
Dissolved Copper
3
3
0
100
No
-
-
Cannot Analyze for Trends
S-18
Dissolved Copper
6
6
0
100
No
-
-
Cannot Analyze for Trends
S-20
Dissolved Copper
4
4
0
100
No
-
-
Cannot Analyze for Trends
S-08
Dissolved Lead
1
1
0
100
No
-
-
Cannot Analyze for Trends
S-14
Dissolved Lead
1
1
0
100
No
-
-
Cannot Analyze for Trends
S-18
Dissolved Lead
6
6
0
100
No
-
-
Cannot Analyze for Trends
S-20
Dissolved Lead
4
4
0
100
No
-
-
Cannot Analyze for Trends
S-08
Dissolved Nickel
1
0
1
0
No
-
-
Cannot Analyze for Trends
S-14
Dissolved Nickel
3
1
2
33
No
-
-
Cannot Analyze for Trends

Mann -Kendall Trend Test Analysis
Roxboro Steam Electric Plant, Duke Energy Progress, LLC
TABLE 2
RESULTS OF MANN-KENDALL TREND TEST (CONTINUED)
gust 2020
SynTerra
Well ID
Analyte
Number of
Samples
Non-
Detects
Detects
PercentageIs
of Non-
Detects
Trend Analysis
Applicable?
Two -Sided
P Value
S Value
Trend Conclusion
S-18
Dissolved Nickel
6
5
1
83
No
-
-
Cannot Analyze for Trends
S-20
Dissolved Nickel
4
4
0
100
No
-
-
Cannot Analyze for Trends
S-08
Dissolved Zinc
1
1
0
100
No
-
-
Cannot Analyze for Trends
S-14
Dissolved Zinc
3
2
1
67
No
-
-
Cannot Analyze for Trends
S-18
Dissolved Zinc
6
6
0
100
No
-
-
Cannot Analyze for Trends
S-20
Dissolved Zinc
4
4
0
100
No
-
-
Cannot Analyze for Trends
S-08
Total Fluoride
1
0
1
0
No
-
-
Cannot Analyze for Trends
5-14
Total Fluoride
3
0
3
0
No
-
-
Cannot Analyze for Trends
S-18
Total Fluoride
0
0
0
NA
No
-
-
Cannot Analyze for Trends
5-20
Total Fluoride
3
3
0
100
No
-
-
Cannot Analyze for Trends
S-08
Total Hardness
7
0
7
0
Yes
0.1331
-
Stable, no significant trend
S-14
Total Hardness
7
0
7
0
Yes
1
-
Stable, no significant trend
S-18
Total Hardness
9
0
9
0
Yes
0.0476
-20
Statistically significant decreasing trend
S-20
Total Hardness
4
0
4
0
Yes
0.7341
-
Stable, no significant trend
S-08
pH
8
0
8
0
Yes
0.04271
-17
Statistically significant decreasing trend
S-14
pH
10
0
10
0
Yes
0.5844
-
Stable, no significant trend
S-18
pH
11
0
11
0
Yes
0.15858
-
Stable, no significant trend
S-20
pH
4
0
4
0
Yes
0.7341
-
Stable, no significant trend
Prepared by: KEM Checked by: MG