NC0003425_Report_20200902

4ais D' 'KE Paul Draovitch
ENERGY® Senor Vice President
Environmental,Health&Safety,
CCP and Operations Support
526 S.Church Street
Mail Code:EC3XP
Charlotte,NC 28202
[phone]
September 2, 2020
Via Overnight Mail
S. Daniel Smith D © HOWIE "-‘")
Director of Water Resources
North Carolina Department of Environmental Quality ecn ® 7 'n'r
1617 Mail Service Center Pd.
Raleigh,NC 27699-1617
DIVISION OF WATER RESOURCES
Rick Bolich DIRECTORS OFFICE
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:
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(336) 215-4576 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 , -
jl.7-) "� r.,,f qq `:_ �1,,, ]-,2-1, Sam .1
a
Paul Daov;�tch. ,
Senior Vice President 1
Erivirotimemt,Health.&Safety,C,CP and Operations Support
Duke-Energy l ',1_. . . . .:. ,'.3
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

Terra
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SEEP MANAGEMENT PLAN AMENDMENT TO
CORRECTIVE ACTION PLAN
ROXBORO STEAM ELECTRIC PLANT
1700 DUNNAWAY ROAD
SEMORA, NC 27343
SEPTEMBER 2, 2020
PREPARED FOR
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DUKE ENERGY PROGRESS, LLC
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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
S-08 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
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
Page iii

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 Minimal AOW with no flow located on southern portion of EAB berm.
(dispositioned) Flow would drain to extension impoundment of EAB.
S-13 Not a seep. Outfall of culvert channeling flow from unnamed tributary
(dispositioned) (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
S-08 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 • Sulfate
• Boron • Mercury • Thallium
• Barium • Nickel • Total Dissolved Solids (TDS)
• Chloride • Nitrate/Nitrite • Total Hardness
• Chromium • Selenium
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 (Ng/L) Detection Maximum
(pg/L) (Ng/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.
Location of Maximum
Total (T) or 15 NCAC 02B Detection Maximum Date of
Dissolved (D) standard Detection Maximum
Constituent (mg/L) Seep Associated (mg/L) Detection
Location 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 (mg/L) Additional Information
(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 (5-08, 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 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.
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 S18-005. 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

1 \ t . j Ar:i�� \ m i._.,()
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NOTES
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1.ALL BOUNDARIES ARE APPROXIMATE L
DUKE ENERGY PROGRESS OBTAINEDz \ _ \�( J` �, ) r• 1 1�.,FROM THE USGS STORE AT ll-.---. -J '7" „'r ''?, / \ \\
ntt s//store us ov/ma-locator ,�,Y•ti'`,. �,�" .. � r• 4Y,.✓I(` �f7 - \'+`\
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(•5 DUKE PERSON COUNTY FIGURE 1-1
SITE LOCATION MAP
ENERGY a SEEP MANAGEMENT PLAN
WWSTON-SALEM AMENDMENT TO CORRECTIVE ACTION PLAN
PROGRESS `ihilipt RALEIGN
ROXBORO STEAM ELECTRIC PLANT
0SEMORA,NORTH CAROLINA
�CNARLOTTE�- ����
OROWN BY:J KIRTZ DATE,06/11/2019 GRAPHIC SCALE REVISED BY C WYATT DATE.08/27/2020 0 000 1,000 2,000 3,000
.-,,e •Terra CHECKED BY K LOWING DATE.08/27/2020 —
APPROVED BY K CAWING DATE 08/27/2020
www.synterracorp.com PROJECT MANAGER C.EADV IN FEET)

')1,.-4 1,'t L---\;--‘(.II'ThLF Ii __.
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7 Via- -..^ c*'14� `l • .4 RD-: :,-,
' •-'
•
i APPROXIMATE A ' _ :\
GYPSUM STORAGE AREA ,2
5 .--_ -- -_L. __ INTAKE CANAL A. `+
` . HANDLING AREA / i .\
APPROXIMATE DFA ___ ___ .,I a
ago- — \ , \ `#
/ POWER PLANT t w ASH BASIN \ v, - / `
1 TT ,� I I s WASTE BOUNDARY
- ------- --- EAB MAIN DAM EASTERN DISCHARGE CANAL
RESERVOIR ��< LCID LANDFILL ` •�� 54�—
BOUNDARY - � EASTASH BASIN • N
• \
W B MAIN DAM i _ \
ASH BASIN ' '� T--�
WASTE BOUNDARY A- SEPARATOR DIKE',
WESTASH BASIN `15� _��`
.11111C
'StXi FIY.
` - INDUSTRIAL LANDFILL 77....
WES TERN DISCHARGE CANAL ----- ' BOUNDARY �`
A51 L.
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lam•`` 5, .
......E 1\....
WESTERN DISCHARGE CANAL ) •
7.........„, - ' , / __ - , , ,
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4
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o / f ` —�' . . r,EfF -t/
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i
1.ALL BOUNDARIES ARE APPROXIMATE -
2.PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY PROGRESS. I
3. 2016 USGS TOPOGRAPHIC MAP, OLIVE HILL QUADRANGLE, OBTAINED 4. ( i /l\t - I
FROM THE USGS STORE AT Xn
Mtps J/store.usgs.goy/map-locator. """DDD \`
�� DUKE PERSON COUNTY FIGURE 1-1
SITE LOCATION MAP
SEEP MANAGEMENT PLAN
PROGRESS ERGY ,.� r . AMENDMENT TO CORRECTIVE ACTION PLAN
RALE/OH ROXBORO STEAM ELECTRIC PLANT
0 _CHARLO7TE O-A ��41 SEMORA,NORTH CAROLINA
� ��
DRAWN BY:1.KIRTZ DATE:06/11/2019 GRAPHIC SCALE
REVISED BY:C.WYATT DATE:08/27/2020 0 500 1,000 2.TOO 3.000
A �j� CHECKEDVE BY:K..LAWIG DATE:08/27/2020
�� a APPROVED 8Y:K.CAWING DATE.08/27/2020 UM
www.synterracorp.com PROJECT MANAGER:C.EADY (IN FEET)

•
. V 4
. ,�S 1 3
•
..40_...
/Y.)
• GYPSUM
M
� z STORAGE G E�' . ♦ AREA• f% _
1 •
a POWER PLANT • • UNIT 3 COOLING •— ♦ I •+
TOWER POND .�� � I• S-Z�
•
•
,� LEGEND
,�.r'UNNAMED ��►+.i •.. ; j'♦
I POND • e" ♦�
• ....I •` • SEEP WITH STABLE BORON CONCENTRATION TREND
♦ SEEP WITH DECREASING BORON CONCENTRATION
�� ® TREND
® ' • SEEP NOT ANALYZED FOR TREND
S-Z 3 ►!.' r' ; ASH BASIN WASTE BOUNDARY
® __ idi
SOLID WASTE LANDFILL BOUNDARY
♦� �I♦`��+I•' ".•+• ,'�, S-10 ! , APPROXIMATE EXTENT OF BORON IN GROUNDWATER
® )iiiisiii\ _ _ +- �. GREATER THAN 02L
- "' EAST ASH 41 •♦�'• j' • -DUKE ENERGY PROGRESS PROPERTY LINE
S-4 BASIN •�• . •% EFFLUENT DISCHARGE CANAL
' • j"•.�� 1 .S-9 WETLAND(AMEC NRTR)
i'^'' �� :S.:::
► STREAM(AMEC NRTR)
S-G •. • `^ ``..•I--•♦♦ 12 �• APPROXIMATE GROUNDWATER FLOW DIRECTION
• S-98a +♦ . • r . NOTES:
® S19 .� I ,
♦ ♦ ♦ • I 1.EXTENT OF AFFECTED GROUNDWATER IS DEFINED AS BORON CONCENTRATIONS
j • GREATER THAN APPLICABLE REGULATORY STANDARD WITHIN ALL FLOW ZONES.FLOW
�• f / •�. ,♦ `• • AND TRANSPORT MODEL PREDICTED PLUME DEPICTION(SYNTERRA,2019)IS USED
,- "r� �` •,♦` •I %•, : SEPARATOR DIK • WHERE EMPIRICAL DATA IS NOTAVAILIABLE.
j r. •
" g • * ♦• •. • ♦ 2 BORON CONCENTRATION TRENDS WERE CALCULATED AND DESCRIBED IN THE
a \ +0 y. • _ •• ♦ j MANN-KENDALL TREND ANALYSIS REPORT(APPENDIX B)
•
••♦ I-—•••.♦ •—••INDUSTRIAL LANDFILL $ I 3 SEEP LOCATIONS ARE DESCRIBED IN THE ENVIRONMENTAL MANAGEMENT
I j •-- ♦ r' � ♦ •• COMMISSION SPECIAL ORDER BY CONSENT(SOC)WO S18-005.
♦ • j
• ' •♦
I
• 4 NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM(NPDES)LOCATIONS ARE
•— DESCRIBED IN PERMIT NC00034245.
I •• WEST ASH ! I,• •+ , 5.ALL BOUNDARIES ARE APPROXIMATE.
BASIN •'• +'+
♦�. 6.PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY PROGRESS,LLC.
FGD :}: • I• 7.SEEP LOCATIONS WERE DERIVED FROM VARIOUS SOURCES AND AREA MIX OF
• PONDS ;T •+- _ SURVEYED AND APPROXIMATE LOCATIONS.THEREFORE.SEEP LOCATIONS ARE TO BE
♦ I I
DEEMED APPROXIMATE.
♦ •
♦ 8.THE WATERS OF THE US DELINEATION HAS NOT BEEN APPROVED BY THE US ARMY
I I CORPS OF ENGINEERS AT THE TIME OF MAP CREATION.THIS MAP IS A PRELIMINARY
JURISDICTIONAL DETERMINATION ONLY.THE PRELIMINARY WETLANDS AND STREAMS
•• _ ♦' /� % BOUNDARIES WERE OBTAINED FROM AMEC FOSTER WHEELER ENVIRONMENTAL 8
INFRASTRUCTURE,INC.NATURAL RESOURCES TECHNICAL REPORT(NRTR)FOR
ROXBORO STEAM ELECTRIC PLANT DATED JUKE 2015.
!♦ .,
9 AERIAL PHOTOGRAPHY OBTAINED FROM GOOGLE EARTH PRO ON OCTOBER 11.2017
• (......
a• AERIAL WAS COLLECTED ON JUNE 13.2016.
• 10.DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE PLANE
COORDINATE SYSTEM FIPS 3200(NAD83).
♦ •
,• • �� DUKE GRAPHIC SCALE FIGURE 3-2
•:• lM..' •j•�•�.'•• 350 0 350 ;np 1
•
S I ENERGY SEEP TREND ANALYSIS WITH BORON
1 ° FEE GROUNDWATER PLUME DEPICTION
1 '� S SS DRAWN BY:1.KIRTZ DATE:05/03/2019
I SEEP MANAGEMENT PLAN
• REVISED BY:C.WYATT DATE:08/27/2020
♦ h ,I'+•+•♦1 ; A ,
�,� CHECKED BY:K.LAWING DA7E:08/27/2020 AMENDMENT TO CORRECTIVE ACTION PLAN
APPROVED BY:K.LAWING DATE:08/27/2020 ROXBORO STEAM ELECTRIC PLANT
♦ s/ PROJECT MANAGER:C.EADY
♦ } ?---/ nTe1�1a SEMORA, NORTH CAROLINA
♦_ 1, —J www.s nterracor..corn

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 O1 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
7
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 NA - Seep
Discharge Pond NA - Not a Classified Seepage area approximately 30 feet west of chimney drain #7. contribution analyzed NA - Not a Classified Monitor per Contributing flows monitored
S-08 36.476719 -79.078064 Non-Constructed flowing to NPDES Surface Water Drainage/flow is to the NPDES permitted Heated Water Discharge in NPDES Permit Surface Water SOC at NPDES Outfall 003
permit Outfall 003 Pond. 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.
•
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 at issuance
S 10 36.479169 -79.056963 Non Constructed** Basin Surface Water Basin berm. Flow would drain to extension of East Ash Basin. dispositioned dispositioned Dispositioned of SOC
** 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 at issuance
S 11 36.478569 -79.056737 Non Constructed Basin Surface Water Basin berm. Flow would drain to extension of East Ash Basin. dispositioned 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
Location Coordinates Receiving
Seep ID Constructed/ Receiving Waterbody Description*** SOC Monitoring Interim Action Status Notes
Number Latitude Longitude Non-constructed Waterbody Classification Levels
Not a seep. Outfall of culvert channeling flow from UT on east See page 6 of See page 6 of
5-13 36.486175 -79.059612 Non-Constructed** Hyco Reservoir Intake WS-V; B attachment A of attachment A of Dispositioned at issuance
Canal (Hyco Reservoir) side of facility that receives flow from East Ash Basin extension Roxboro SOC S18- Roxboro SOC S18- Dispositioned of SOC
and S-21. Flows to facility water intake canal (Hyco Reservoir). 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 in NPDES Permit Surface Water disposition
permit Outfall 003 toward the Heated Water Discharge Pond. monitoring at NPDES Outfall 003
Quarterly monitoring
Small stream flowing Small seep flow to small stream channel northeast of West Ash at point prior to Hardness 1200 mg/L
S-20 36.47799 -79.0749 Non-Constructed to Heated Water NA Not a Classified Basin dam. Drains west through wetland to Heated Water flowing into Heated TDS 1600 mg/L Monitor per Contributing flows monitored
Surface Water 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 contribution analyzed NA - Not a Classified Proposed for Contributing flows monitored
Ash Basin. Flow joins East Ash Basin effluent channel prior to
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
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 Dry or non flowing conditions,
S-22 36.48184 -79.0657 Non Constructed 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
permit Outfall 003 wastewater treatment system and is covered by the NPDES monitoring at NPDES Outfall 003
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.
Prepared by: KTL Checked by: CDE
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.
ug/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
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)
Reporting Units 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
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 CollectionpH Temperature Specific Dissolved Reduction Eh TurbidityFlow Arsenic Barium Boron Bromide Cadmium Calcium Chloride Chromium Copper
P Groundwater Media 9 P Conductance Oxygen Fluoride
Flow Direction Date Potential
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 -10 L 98 2.4 0.214 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
5-2G Channel flowing into the West Ash Basin Downgradient Water 36.47786693 -79.07489695 05/07/2019 7.2 20 766 6.36 100 305 11.0 1151 <1 88 425 580 <0.1 72.3 18 <1 .1 <0.5
heated discharge pond
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 0P1 <1 59 376 <500 <0.1 52.2 16 <1 <0.5
heated discharge pond
Prepared by: KTL Checked by: KH6Z
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 mV-millivolts NTU-Nephelometric Turbidity Units
Eh-Redox Potential NA-not analyzed S.U.-pH standard units
GPM-gallons per minute NCAC-North Carolina Administrative Code pg/L-micrograms per liter
mg/L-milligrams per liter NE-not established µmhos/cm-micromhos per centimeter
mg-N/L-milligrams nitrogen per liter NM-not measured UT-unnamed tributary
1
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)
Reporting Units 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
15A 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
Respect to Sample Nitrate+ Oil and
Location ID Location Description Associated Unit Latitude Longitude Collection Hardness Lead Magnesium Mercury Nickel Selenium Sulfate Thallium Dissolved Suspended Zinc Arsenic Cadmium Chromium Copper Lead Nickel Zinc
Groundwater Media Date Nitrite grease Solids Solids
Flow Direction
5-20 Channel flowing into the West Ash Basin Downgradient Water 36.47786693 -79.07489695 10/25/2018 367 0 2 44 0.000153 <1 0.02 NA 270 0.2 580 NA <0.1 <1 <0.2 <1 5
heated discharge pond
5-20 Channel flowing into the West Ash Basin Downgradient Water 36.47786693 -79.07489695 02/28/2019 240 0.2 29 3 0.0016 0.02 5 170 0.2 60 <5 30.1 <1 <1 <0.2
heated discharge pond
S-20 Channel flowing into the 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
heated discharge pond
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
L
Prepared by: KTL Checked by: KHG
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 028.0202(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 028.0211(11).
Deg C-degrees Celsius mV-millivolts NTU-Nephelometric Turbidity Units
Eh-Redox Potential NA-not analyzed S.U.-pH standard units
GPM-gallons per minute NCAC-North Carolina Administrative Code pg/L-micrograms per liter
mg/L-milligrams per liter NE-not established umhos/cm-micromhos per centimeter
mg-N/L-milligrams nitrogen per liter NM-not measured UT-unnamed tributary
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
Governor
MICHAEL S.REGAN
Secretary
UNDA CULPEPPER
Interim Director
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 Peiuiits NC0038377 &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:
• 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.
D_EQ
North Carolina Department of Environmental Quality(Division of Water Resources
512 North Salisbury Street(1617 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 143-215.3D, water quality fees have been revised to
include an annual fee for activities covered under a Special Order by Consent. Duke Energy will
be subject to a fee of$500.00 on a yearly basis while under the Order. The initial fee payment
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(919) 807-6398.
Sincerely,
Linda Culpepper
fai
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 ) SPECIAL ORDER BY CONSENT
NPDES PERMITS NC0038377& )
NC0003425 ) EMC SOC WQ S 18-005
)
HELD BY )
DUKE ENERGY PROGRESS, LLC )
Pursuant to the provisions of North Carolina General Statutes(G.S.) 143-215.2,this Special
Order by Consent is entered into by Duke Energy Progress, LLC,hereinafter referred to as Duke
Energy, and the North Carolina Environmental Management Commission, an agency of the State
of North Carolina created by G.S. 143B-282,and hereinafter referred to as the Commission.
Duke Energy and the Commission are referred to hereafter collectively as the "Parties."
1. Stipulations: Duke Energy and the Commission hereby stipulate the following:
a. This Special Order by Consent ("Special Order") addresses issues related to the
elimination of seeps(as defined in subparagraphs e, f, and g below) from Duke
Energy's coal ash basins during the separate and independent process of basin
closure under the Coal Ash Management Act, G.S. 130A-309.200 through 130A-
309.231 ("CAMA")and the Federal Coal Combustion Residuals Rule, 40 CFR
Parts 257 and 261. The Environmental Protection Agency first directed
permitting authorities to consider potential impacts on surface water of seeps from
earthen impoundments in 2010. At that time, Duke 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 S18-005
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 1
r--7 Facility Number CountyDate 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 S 18-005
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."
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.
m. Non-constructed seeps create conditions such that certain surface water quality
standards may not consistently be met at all Duke Energy monitoring sites.
n. The presence of coal ash influenced water in the non-constructed seeps causes or
contributes to pollution of the waters of this State, and Duke Energy is within the
jurisdiction of the Commission as set forth in G.S. Chapter 143, Article 21.
l

EMC SOC WQ S 18-005
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.
r. Since this Special Order is by consent, the Parties acknowledge that review of the
same is not available to the Parties in the N.C. Office of Administrative Hearings.
Furthermore, neither party shall file a petition for judicial review concerning the
terms of this Special Order.
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 $5,000.00 per day,to a maximum of
Corrective Action Plans or Closure Plans to
$1,000,000.00 per electric generating
address all remaining seeps,
whether
constructed or non-constructed, through facility.
corrective action as applicable under
paragraph 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 S 18-005
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(I) 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 drr ash handling projects in accordance with the following
schedule
Facilitx Fly Ash Bottom Ash
Mayo Complete Complete
Roxboro Complete 5/31/2019
2) Initiation of Decanting
Mayo 6/30/2019
Roxboro 6/30/2019
3) Completion of Decanting
Mayo 12/31/2020
Roxboro 6/30/2020
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 SI8-005
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 WO 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.
I) 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 he 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.
3. Duke Energy will continue to operate its coal ash surface impoundments in such a
manner that their performance is optimized, and potential for surface waters to be
affected by seeps is minimized.

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 WQ S t 8-005
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
NC0038377 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 Energ Progress, LLC:
,.01111, —......./ gri'. i ( (841
Paul Draovit Date
Senior Vice President,Environmental, Health & Safety
For the Nort r ina En onmental Management Commission:
6//5- (1.7-1-)1
J. D _ om n, P.E.
C it of the Commission Date

Attachment A
S18-005
Duke Energy Progress, LLC—Mayo Steam Station, p.1
Constructed Seeps
1 Approximate Location _
I Seep ID Receivingg
Number _Coordinates Description Receiving Waterbody Waterbody SOC Monitoring I Interim Action._
Latitude ' Longitude
--.- r___ �_.__ Classification I Levels
_g_
N/A—Flow is collected and 1- " -`
i I
pumped back to NPDES I
5-01 36.538849 -78.893512 Seep flow from west permitted wastewater
toe drain system in accordance with N/A N/A N/A
the pumping system's
- _ ___ design capacity.
N/A—Flow is collected and
pumped back to NPDES-
S 02 36.537964 -78.891364 Seep flow from east permitted wastewater
toe drain system in accordance with N/A N/A 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

Attachment A
S18-005
Duke Energy Progress, LLC—Mayo Steam Station, p.2
Non-Constructed Seeps
Seep ID ' Approximate Location Receiving ,�
Coordinates Description Receiving g Interim Action
Number - ------ p WaterbodySOC Monitoring
! Latitude Longitude Waterbody Levels
�� .____ g Classification
C Monitoring in
Minor seep forming within filter bed at the Crutchfield
toe of the west dam and flowinginto UT to
an
S-01A 36,538903 -78.89351Crutchfield B
Branch N/A—2B Standards
unnamed tributary(UT)to Crutchfield Branch downstream of Apply
Branch all seep flow
. contributions i
Monitoring in
Minor seep forming within filter bed 20 feet Crutchfield
S-02A 36.538005 t -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
. j Minor seep forming just downgrade of 5-02 Crutchfield
S-02B 36.537989 -78.891339 1 collection box,flowing into Crutchfield Crutchfield B Branch N/A—2B Standards
Branch. Branch downstream of Apply
all seep flow
contributions
S-03** i 36.538654 -78.890714 Sampling Location;not a seep Crutchfield B NJA—Seep NJA—seep
Branch Dispositioned _I Dispositioned
S-04** 36.538896 -78.89341 Sampling Location;not a seep Crutchfield B N/A—Seep N/A—Seep
Branch Dispositioned Dispositioned
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 _
5-06* 36.521971 -78.88526 southeast of power plant. Flows to Mayo Mayo Lake WS-V N/A—Seep N/A—Seep
Lake. Dispositioned 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.

Attachment A
S18-005
Duke Energy Progress, LLC—Mayo Steam Station, p.3
Approximate Location ——— --
Seep ID ReceivingReceiving
Coordinates Description Interim Action
Number - -- p Waterbody Waterbody SOC Monitoring
Latitude Longitude Classification Levels
Intermittently observed area of wetness
I downslope from former production well
location. No flow observed during recent
5-07* 36.521798 -78.892152 evaluations.Any flow would drain Mayo Lake WS-V N/A—Seep N/A—Seep
southeast,merging with flow at S-06 before Dispositioned Dispositioned
reaching Mayo lake. From sampling—No
CCR impacts.
_ Monitoring in
Crutchfield Seep forms one ridge over(east)from east
5-08 36.537502 -78.890398 toe drain,flowing northwest in small Crutchfield B Branch N/A—2B Standards
Branch downstream of
channel to Crutchfield Branch. Apply
I all seep flow
contributions
Natural stream flow to Mayo Lake i
S 09* 36.522902 78.886868 originating southeast of plant. Location is Mayo Lake WS-V N/A—Seep N/A—Seep
upstream of,and flowing toward 5-06. From Dispositioned Dispositioned •
sampling—No CCR impacts. i
Monitoring in
Crutchfield
S 10 35.538422 7g.g9039S Minor seep to small channel,flowing Crutchfield Branch N/A—2B Standards
northwest into Crutchfield Branch. Branch B downstream of Apply
all seep flow
_ __1__.__ i 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.

Mayo Steam Electric Power Plant — Water Quality Monitoring Locations
�a
_ S01A �����cd
S-02A ( Qj
+p
•`�
.m-.�-
•
y, \ - .�.�. -...
S-08
Ash
4 , Basin
it
#.4"
ti
r•
' Mayo Lake
f-
i : -., -,.. .e: •i-t
, Ar"vg4S4
Ap
* Stream Monitoring

Attachment A
S18-005
Duke Energy Progress, LLC—Roxboro Steam Station, p.1
Constructed Seeps
Approximate Location ?
ISeep ID ReceivingReceiving I
I Number Coordinates Description i Waterbody ' SOC Monitoring Interim Action
Latitude -1 Lon itude Waterbody E Levels 1
__._,._.__--. _c g _;__----_- _ Classification
Heated I
Water ' N/A-Not a N/A-Seep
Chimney drain discharge from active ash Discharge contribution N/A-Not a
S-01 36.47704 -79.0765 basin dam to Heated Water Discharge Pond flowingClassified
g Surface analyzed in Classified Surface
Pond. to NPDES NPDES Permit Water
permit outfall Water
monitoring
i
003
Heated I
Water N/A-Seep
Chimney drain discharge from active ash Dischar a N/A-Not a
g contribution N/A-Not a
S-02 36.47706 -79.0767 basin dam to Heated Water Discharge Pond flowingClassified
g Surface analyzed In Classified Surface
Pond. to NPDES
Water NPDES Permit Water
permit outfall monitoring
...._.... 003
Heated j
Water N/A-Seep
Chimney drain discharge from active ash Dischar a N/A-Not a
g contribution N/A-Not a
S-03 I 36.47699 -79.077 basin dam to Heated Water Discharge Pond flowingClassified
Surface analyzed in Classified Surface
Pond. to NPDES NPDES Permit Water
permit outfall Water
monitoring 1
-- 003 I
Heated
i
Water N/A-Seep
Chimney drain discharge from active ash Discharge N/A-Not a
g Classified contribution N/A-Not a
5-04 36.47692 -79.0772 basin dam to Heated Water Discharge Pond flowing analyzed in Classified Surface
Pond. to NPDES Surface
I
Water NPDES Permit Water
permit outfall monitoring
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.

Attachment A
S 18-005
Duke Energy Progress, LLC—Roxboro Steam Station, p.2
Approximate Location
Se ReceivingReceiving
[ :PlD Coordinates Description ? Interim Action
Number ---- - i p Waterbody SOC Monitoring
Latitude Longitude _ _ Waterbody I Levels
-_ -�. Classification i
Heated
Water N/A-Seep
Chimney drain discharge from active ash Discharge N/A-Not a contribution N/A-Not a
S-OS 36.47675 -79.0774 1 basin dam to Heated Water Discharge Pond flowing Classified analyzed in Classified Surface
Pond. to NPDES Surface
Water NPDES Permit Water
permit outfall monitoring
003
. _.__ —Heated
Water N/A-Seep
Chimney drain discharge from active ash Dischar a N/A-Not a
g contribution N/A-Not a
S-06 36.47669 -79.0776 basin dam to Heated Water Dischar a Pond flowingClassified
g analyzed in Classified Surface
Surface
Pond.
l to NPDES Water NPDES Permit Water
permit outfall monitoring
E—------ ---_ . _ _ — — 003
Heated
Water N/A-Seep
Chimney drain discharge from active ash Dischar a N/A-Not a
g contribution N/A-Not a
Classified
5-07 36.47674 i -79.078 basin dam to Heated Water Discharge Pond flowing analyzed in Classified Surface
Pond. to NPDES Surface NPDES Permit Water
permit outfall Water
monitoring
003
N/A- —
Unnamed Monitoring
S-09 36.47823 -79.05607 Discharge from extension of East Ash Basin tributary(UT) WS-V;B Established per See page 6 of this
to Hyco Lake Terms of NPDES f,f Attachment A
Permit i
* 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
S18-005
Duke Energy Progress, LLC—Roxboro Steam Station, p.3
Non-Constructed Seeps
Approximate Location
Seep ID I Receiving Receiving
Coordinates Description
Number — -- -----I p WaterbodyWaterbody SOC Monitoring Interim Action Levels
Latitude Longitude i Classification .
Heated
Water
Seepage area approximately 30 feet west of N/A—Seep
chimney drain#7.Drainage/flow is to the Discharge N/A—Not a
Pond Classified contribution
N/A—Not a Classified
S-08 36.47672 -79.0781 Heated Water Discharge Pond.This non- analyzed in
constructed seep flows to a portion of an flowing to Surface Surface Water I
NPDES Water NPDES Permit
NPDES wastewater treatment system. monitoring
permit i
outfall 003
Minimal AOW with no flow located on —
Extension of N/A—Not a
S 10** 36.47917 79.057 northern portion of East Ash Basin berm. Classified N/A—Seep N/A—Seep
Any flow would drain to extension of east East Ash
Basin Surface Dispositioned Dispositioned
ash basin. Water ,
Minimal AOW with no flow located on
Extension of N/A—Not a
S 11** 36.47857 79.0567 central portion of East Ash Basin berm. Any East Ash Classified N/A—Seep N/A—Seep
flow would drain to extension of east ash Surface Dispositioned Dispositioned
basin. Basin
_. ._..._ Water
Minimal AOW with no flow located on N/A—Not a
,* southern portion of East Ash Basin berm. Extension of Classified N/A—Seep N/A—Seep
S-12 36.4781 -79.0567 East Ash
Any flow would drain to extension of east Surface Dispositioned Dispositioned
i Basn
ash basin.
Water
Not a seep.Outfall of culvert channeling — —
flow from UT on east side of facility that See page 6 of
S-13** 36.48618 -79.0596 receives flow from East Ash Basin extension Hyco Lake WS-V;B this Attachment See page 6 of this I
and S-21.Flows to facility water intake A Attachment A
channel(Hyco Lake).
* 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
Attachment A
S18-005
Duke Energy Progress, LLC—Roxboro Steam Station, p.4
See ID ' Approximate Location j Receiving
} Coordinates Description
Number --— --Coordinates Waterbody SOC Monitoring Interim Action Levels
---- T 1 Waterbody
ud Latite Longitude ____...__.___ Classification
Location is the end of a 24"pipe draining a Heated
boggy area south of the gypsum pad.Pipe Water N/A—Seep
extends under the pad toward the Discharge N/A—Not a
contribution
S 14 36.48374 79 063$ northwest,under railroad tracks,with Pond Classified N/A—Not a Classified
l discharge to a ditch that drains to the flowingto Surface analyzed in
g Surface Water
NPDES Permit
Heated Water Discharge Pond.This non- NPDES Water i
constructed seep flows to a portion of an permit monitoring
NPDES wastewater treatment system. outfall 003
Seepage to wet area north of active ash Small Quarterly
Y
basin.Flows north into a waterbody flowing monitoring at
i flowing to Hardness 1200 mg/L
S 18 36.47795 79.0737 to Heated Water Discharge Pond. WS-V;B point prior to TDS 1600 mg/L
Waterbodyis potentiallyWOTUS.This non Heated
(Nyco Lake) flowing into Water Sulfates 1000 mg/L
constructed seep flows to a portion of an Heated Water
NPDES wastewater treatment system. Discharge Discharge Pond.
Pond
Heated
AOW with minimal flow located adjacent to Water
the S-01 chimney drain at the east end of Discharge N/A—Not a N/A—Seep
contribution
S 19 36.47718 7g 0764 the 1973 ash basin dam.Any flow moves Pond Classified analyzed in N/A—Not a Classified
i toward the Heated Water Discharge Pond. flowing to Surface NPDES Permit Surface Water
This non-constructed seep flows to a portion NPDES Water
of an NPDES wastewater treatment system. permit monitoring
—r outfall 003
Seep flow to small stream channel northeast Small
stream Quarterly
of West Ash Basin dam.Drains west through monitoring at
flowing to Hardness 1200 mg/L
( wetland to Heated Water Discharge Pond. WS-V;B point prior to TDS 1600 mg/L
S-20 F 36.47799 -79.0749 Heated
{ No sample data due to lack of flow.This Water (Nyco Lake) flowing into Sulfates 1000 mg/L
non-constructed seep flows to a portion of Heated Water
an NPDES wastewater treatment system. Discharge
Y Pond 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 B of this Order.

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-IA 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 August 2020
Roxboro Steam Electric Plant,Duke Energy Progress,LLC SynTerra
TABLE 2
RESULTS OF MANN-KENDALL TREND TEST
Percentage
Number of Non- Is Trend Analysis Two-Sided
Well ID Analyte Samples Detects Detects of Non- Applicable? P Value S Value Trend Conclusion
Detects
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
S-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
S-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
S-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 11 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 August 2020
Roxboro Steam Electric Plant,Duke Energy Progress,LLC SynTerra
TABLE 2
RESULTS OF MANN-KENDALL TREND TEST (CONTINUED)
Number of Non- Percentage Is Trend Analysis Two-Sided
Well ID Analyte Samples Detects Detects of Non- Applicable? P Value S Value Trend Conclusion
Detects
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
S-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
S-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
S-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 August 2020
Roxboro Steam Electric Plant,Duke Energy Progress,LLC SynTerra
TABLE 2
RESULTS OF MANN-KENDALL TREND TEST (CONTINUED)
Percentage
Number of Non- Is Trend Analysis Two-Sided
Well ID Analyte Samples Detects Detects of Non- Applicable? P Value S Value Trend Conclusion
Detects
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
S-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
S-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
5-18 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

S-08 S-14
6-
0
4-
2-
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0
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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 la., ENERGY REVISED BY:K.MARSAC FIGURE 22
--0— Non-detect could not be analyzed for trends. TIME VERSUS DISSOLVED ZINC
AO— Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends 0APPROVED BY: C.EADY ROXBORO STEAM ELECTRIC PLANT
PROJECT MANAGER: C.EADY SEMORA, NORTH CAROLINA
synTerra
www.synterracorp.com J
L

S-08 S-14
0.4-
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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 21
- Non-detect could not be analyzed for trends. TIME VERSUS TOTAL THALLIUM
f- Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.CAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends 0 APPROVED BY: C.EADY ROXBORO STEAM ELECTRIC PLANT
synTerra PROJECT MANAGER C EADY SEMORA, NORTH CAROLINA
www.synterracorp.com

S-08
S-14
6000
4000
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0
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N N N N N N N N N N N N
Date
LEGEND NOTES fs DUKE DRAWN BY: K.MARSAC DATE:07/23//2020 FIGURE 20
- Stable, no trends Trends are denoted by the box color, if there is no color the data ENERGY REVISED BY.K.MARSAC TIME VERSUS TOTAL DISSOLVED
Non-detect could not be analyzed for trends.
+ Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING SOLIDS
- Statistically Significant Increasing Trend . MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends 0APPROVED BY: C EADY
PROJECT MANAGER: C.EADY ROXBORO STEAM ELECTRIC PLANT
synTerra SEMORA, NORTH CAROLINA
www.synterracorp.com

S-08 1 5-14
1250-
1000-
750-
•
500-
250-
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V/
0
0
W S-18 S-20
cn 1250 I
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1000
750
500
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0 0 0 0 0 0 0 0 0 0 0 0
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 le ENERGY REVISED BY:K.MARSAC FIGURE 19
—0— Non-detect could not be analyzed for trends. TIME VERSUS TOTAL SULFATE
Detect _ - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.CAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends 0 APPROVED BY: C.EADY ROXBORO STEAM ELECTRIC PLANT
-(��J/■�'�� PROJECT MANAGER C EADY SEMORA, NORTH CAROLINA
��� www.synterracorp.com

S-08 S-14
100-
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N N N N N cV N N N N N N
Date
LEGEND NOTES eiraNDUKE 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 18
- Non-detect could not be analyzed for trends. TIME VERSUS TOTAL SELENIUM
f Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING '
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends 0 APPROVED BY: C.EADY PROJECT MANAGER: C.EADY ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA 1
Terra www.synterracorp.com

S-08 S-14
8.5 .
8.0.
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7.0. •
7
6.5- ✓
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I 8.5
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6.5-
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0 0 0 0 0 0 0 0 0 0 0 0
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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 17
—0— Non-detect -- could not be analyzed for trends. TIME VERSUS PH
+ Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends 0 APPROVED BY: C.EADY ROXBORO STEAM ELECTRIC PLANT
PROJECT MANAGER: C.EADY SEMORA, NORTH CAROLINA
synTerra
www.synterracorp.com

S-08 S-14
0.4-
0.3-
0.2-
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0.0-
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a�
S-18 S-20
> 0.4-
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0.1 -
0.0-
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Date
LEGEND NOTES JOS 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 16
-o- Non-detect could not be analyzed for trends. TIME VERSUS DISSOLVED LEAD
Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends / APPROVED BY: C.EADY PROJECT MANAGER: C EADY ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA
synTerra
www.synterracorp.com

S-08 S-14
6
4 .
2
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z 6-
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I-
4-
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N N N N N N N N N N N N
Date
LEGEND NOTES 4.1.) DUKE DRAWN BY: K.MARSAC DATE:07/23//2020
5
Stable, no trends Trends are denoted by the box color, if there is no color the data ENERGY REVISED BY:K.MARSAC FIGURE A
Non-detect — could not be analyzed for trends. TIME VERSUS TOTAL NICKEL
f- Detect — - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.CAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends 0 APPROVED BY: C.EADY ROXBORO STEAM ELECTRIC PLANT
PROJECT MANAGER: C.EADY SEMORA, NORTH CAROLINA
s ,1)erT"a www.synterracorp.com

S-08 S-14
3-
2-
a)
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a)
V
Z S-18 S-20
0 3
0
cn
cn
01
co N. co rn O CO N CO rn O
c- e- 1- = N c— r— c- c- N
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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 FIGURE 14
Non-detect could not be analyzed for trends. TIME VERSUS DISSOLVED NICKEL
—0— Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends �r/� APPROVED BY: C. EADY ROXBORO STEAM ELECTRIC PLANT
PROJECT MANAGER: C.EADY SEMORA, NORTH CAROLINA
synTerra
www.synterracorp.com

S-08 S-14
1.00-
0.10-
E
a)
1 0.01 -
+ S-18 S-20
°? 1 .00-
c�
z
03
0
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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 13
-� Non-detect could not be analyzed for trends. I TIME VERSUS TOTAL NITRATE + NITRITE
-� Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends 0 APPROVED BY: C.EADY ROXBORO STEAM ELECTRIC PLANT
PROJECT MANAGER C. EADY SEMORA, NORTH CAROLINA
synTerra
www.synterracorp.com

S-08 S-14
0.1000-
0.0100-
0.0010-
.-- O O O O O
, 0.0001 -
m
0 S-18 S-20
a)
2 0.1000-
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0
I-
0.0100-
0.0010-
0.0001 -
cfl r- co rn o co N. co am o
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Date
LEGEND NOTES, 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 'r DUKE ENERGY REVISED BY:K.MARSAC FIGURE 12
- Non-detect could not be analyzed for trends. TIME VERSUS TOTAL MERCURY
♦— Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING
'''' - Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends 0 APPROVED BY: C.EADY PROJECT MANAGER C EADY ROXBORO STEAM ELECTRIC PLANT
. SEMORA, NORTH CAROLINA
synTerra
www.synterracorp.com

S-08 S-14 -71
4000
3000
2000
11000
= 4000
Ts
0
I-
3000
2000
1000
co r� co 0 0 Lo co ti co rn o
e- r— 7— c-- N r- r— N— 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 tiros' 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 11
-� Non-detect s,, could not be analyzed for trends. TIME VERSUS TOTAL HARDNESS
—III— Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends 0 APPROVED BY: C. EADY ROXBORO STEAM ELECTRIC PLANT
PROJECT MANAGER' C.EADY SEMORA, NORTH CAROLINA
synTerra
www.synterracorp.com

S-08 S-14
1.25
1 .00-
0.75- •
0.50-
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E
a -
0.00
S-20
0 1 .25- N N N CV o N N
U-
0 1.00-
I-
0.75-
0.50-
0.25-
0.00-
Ln ( r-- 03 rn o
N
0 0 0 0 N0 0
Date
LEGEND NOTES t DUKE DRAWN BY: K.MARSAC DATE 07i23N2020
Stable, no trends Trends are denoted by the box color, if there is no color the data Ir ENERGY REVISED BY:K.MARSAC FIGURE 10
-0- Non-detect could not be analyzed for trends. TIME VERSUS TOTAL FLUORIDE
-f- Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends 0 APPROVED BY: C.EADY PROJECT MANAGER: C.EADY ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA
synTerra
www.synterracorp.com

S-08 1 S-14
2.0-
1.5-
•
1 .0- 0 0
I 0.5-
o)
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E. 0.0
Q.
0 S-18 S-20
C) 2.0-
>
0
U
U 1.5-
0
1 .0- 00 0 O 0-0 0 0 0 0
0.5-
0.0-
I
co N- Co 0) 0 co ► - CO 0) o
r r r r (N r r r r N
0 0 0 0 0 0 0 0 0 0
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 9
—0— Non-detect could not be analyzed for trends.
Detect + TIME VERSUS DISSOLVED COPPER
111. - Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends 0 APPROVED BY: C.EADY ROXBORO STEAM ELECTRIC PLANT
PROJECT MANAGER: C.EADY SEMORA, NORTH CAROLINA
synTerra
www.synterracorp.com

S-08 S-14
3-
2-
1 - 0 0 0 0 0 0 0 0
ap
z
E 0-
E S-18 S-20
0
-C 3-
U
76
0
I-
2-
1 - ono— 0 0 o a o o-0 0 0 0 0
0-
1 1 1 I
to c0 r` co rn 0 LC) (0 r` Co O) 0
c- e- l- r- N N— r c- V- '1- N
0 0 0 0 0 0 0 0 0 0 0 0
N N N N N N N N N N N N
Date
LEGEND NOTES 4.4•N
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 8
—0— Non-detect could not be analyzed for trends. TIME VERSUS TOTAL CHROMIUM
f Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.CAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends `/� APPROVED BY: C.EADY ROXBORO STEAM ELECTRIC PLANT
PROJECT MANAGER C EADY SEMORA, NORTH CAROLINA
Terra www.synterracorp.com

S-08 S-14
2.0-
1.5-
1.0- 0 0 0 O
°' 0.5-
E
•- 0.0-
0
S-18 S-20
v 2.0-
CD
>
0
N 1 .5-
0
1 .0- 0 0 0 0 0 0 0 0 0 0
0.5-
0.0-
CD N. CO a) O CD r` CO O) 0
t— T— e— N 7- e- .- N- N
0 0 O 0 0 0 0 0 0 0
N N N N N N N N N N
Date
LEGEND NOTES l 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 7
-0— Non-detect could not be analyzed for trends. TIME VERSUS DISSOLVED CHROMIUM
AI— Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends 0 APPROVED BY: C.EADY ROXBORO STEAM ELECTRIC PLANT
PROJECT MANAGER C.EADY SEMORA, NORTH CAROLINA
'7" wwwsynterracorp.com

S-08 S-14
1000
100
a)
E 10
a)
.0 S-18 S-20
0
U
1000-
0
I-
100-
10-
Ln co r— co am o 1.11 CO ti CO rn o
1— r- N— r— r- N N— N— 1— .— e— 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 FIGURE 6
Non-detect could not be analyzed for trends. TIME VERSUS TOTAL CHLORIDE
Detect Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING MANN KENDALL TREND TEST ANALYSIS
- Statistically Significant Increasing Trend
No Color- Cannot Analyze for Trends �r/� APPROVED BY: C.EADY ROXBORO STEAM ELECTRIC PLANT
PROJECT MANAGER C EADY SEMORA, NORTH CAROLINA
wnTerra
www.synterracorp.com

S-08 S-14
0.20-
0.15-
0.10- °
a) 0.05-
E
= 0.00-
lt▪i S-18 S-20
U
-0 0.20-
aD
0
cn 0.15
0.10- o 0 0 o 0 ° 0 0 0 —�
0.05-
0.00-
rn rn o
0 0 0 N
Date
LEGEND NOTES eireN 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
AI- Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.CAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends APPROVED BY: C.EADY ROXBORO STEAM ELECTRIC PLANT
synPROJECT MANAGER: C.EADY SEMORA, NORTH CAROLINA
��� www.synterracorp.com

S-08 S-14
250-. ---
200
150
100
a, 50 ~~ ..N. •
I
S-18 S-20
250 200
150
. .l .
100
50
CO f` CO 0) C) LC) C. ti CO d) O
'(- R! •(- e- N- l- N
O 0 O 0 0 0 0 0 0 0 0 0
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 FIGURE 4
Non-detect could not be analyzed for trends. TIME VERSUS TOTAL BARIUM
-�- Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING
Statistically Significant Increasing Trend — MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends 0 APPROVED BY C.EADY PROJECT MANAGER: C EADY ROXBORO STEAM ELECTRIC PLANT
SEMORA, NORTH CAROLINA
iferra www.synterracorp.com

S-08 S-14
100000-
• .�,. . . •
10000-
1000-
01
? 100-
o S-18 S 20
m 100000-
cu
0
F-
10000-
1000-
100-
cfl ti co 0-) 0 in CO I"- CO rn 0
CV N- N- N
0 0 0 0 0 0 0 0 0 0 0 0
N N N N N CV 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 FIGURE 3
—0— Non-detect could not be analyzed for trends. TIME VERSUS TOTAL BORON
f Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color 0 APPROVED BY: C.EADY
Cannot Analyze for Trends ROXBORO STEAM ELECTRIC PLANT
PROJECT MANAGER C. EADY Terra SEMORA, NORTH CAROLINA
'1" www.synterracorp.com

S-08 ! S-14
4= '
3-
2- •
J _
a)
_U
c 0-
a)
S-18 S-20
a)
4-
>
0
cn 0 3-
2-
1 - 0 0 0 O 0 0 0 0 0 0
0-
co r-- co rn o co r` co rn o
c— N— e— e— N T— N
O O O 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 dataSIP ENERGY REVISED BY:K.MARSAC FIGURE 2
Non-detect could not be analyzed for trends. TIME VERSUS DISSOLVED ARSENIC
Detect Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends APPROVED BY: C.EADY ROXBORO STEAM ELECTRIC PLANT
PROJECT MANAGER: C.EADY
SEMORA, NORTH CAROLINA
synTerra
www.synterracorp.com

S-08 S-14
25-
20-
15-
10-
c 5
=. __.
c0 0-
c
0 S-18 S-20
L
< 25-
ra
0
F' 20-
15-
10-
5-
O O O 0 O O-0 0 0 _0_0 O 0 0 O
0- 1 I 1
in 0 ti CO O 0 in (0 r` CO 0) 0
r— r— = N = = r— N
0 0 0 0 0 0 0 O 0 0 0 0
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 FIGURE 1
—0-- Non-detect could not be analyzed for trends. TIME VERSUS TOTAL ARSENIC
� Detect - Statistically Significant Decreasing Trend PROGRESS CHECKED BY: K.LAWING
- Statistically Significant Increasing Trend MANN KENDALL TREND TEST ANALYSIS
No Color- Cannot Analyze for Trends �r/� APPROVED BY: C.EADY ROXBORO STEAM ELECTRIC PLANT
PROJECT MANAGER C.EADY SEMORA, NORTH CAROLINA
S)/C1TErta www.synterracorp.com