NC0024406_24406 - Major Mod Application - 2020_20210311

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Duke Energy Carolinas LLC
Attn: Michael Lanning, GM
3195 Pine Hall Road
Belews Creek, NC 27009
Subject: Permit Application
Application No. NC0024406
Belews Creek Steam Station
Stokes County
Dear Applicant:
+nffi qu.µ •!o',
NORTH CAROL.INA
Environmental Quality
November 05, 2020
The Water Quality Permitting Section acknowledges the November 4, 2020 receipt of your permit modification
application and supporting documentation. Your application will be assigned to a permit writer within the Section's NPDES
WW permitting branch. Per G.S. 150E-3 your current permit does not expire until permit decision on the application is
made. Continuation of the current permit is contingent on timely and sufficient application for renewal of the current
permit. The permit writer will contact you if additional information is required to complete your permit renewal. Please
respond in a timely manner to requests for additional information necessary to allow a complete review of the application
and renewal of the permit.
Information regarding the status of your renewal application can be found online using the Department of Environmental
Quality's Environmental Application Tracker at:
https://deq.nc.gov/permits-regulations/permit-guidance/environmental-application-tracker
If you have any additional questions about the permit, please contact the primary reviewer of the application using the
links available within the Application Tracker.
cc: Central Files w/application
ec: WQPS Laserfiche File w/application
ODE
Sincerely,
Ki/n kC\
Wren Thedford
Administrative Assistant
Water Quality Permitting Section
I\ North Car: raDepartmzntofEnv ronmental Qua' rty I DusonofWaterResatras
W rstorSa em Regons' Off,De 145C 1'.est Hares h' Road,Sute 366 I Wi stonSaiem, North Carobna 27105
336-776-9800

�� DUKE
ENERGY
October 13, 2020
Sergei Chernikov, PhD, Acting Supervisor
Industrial Permitting Branch
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject:
Dear Dr. Chernikov,
Michael F. Lanning
General Manages
Belews Creek Steam Station
3195 Pine Hall Roaa
Belews Creek, NC 27009
[phone]
RECEIVED
NOV- 0 4 2020
NCDEQ/DWR/NPDES
NPDES permit modification request
Belews Creek Steam station
NC0024406
Stokes County
Duke Energy Carolinas, LLC (Duke Energy) hereby requests modification of the subject NPDES permit
to make the following changes:
1. Incorporate updated provisions and technology based effluent limits (TBEL) found in 40 CFR
part 423. Specifically, Duke Energy requests that the FGD TBELs be updated to the values in
the recently modified steam electric effluent limitations guidelines and that terms related to the
release of bottom ash transport water be clarified to align with updates to 40 CFR Part 423. The
revised rule was signed by the US Environmental Protection Agency (EPA) on August 31, 2020
and published in the Federal Register on October 13, 2020. The rule states that "Where permits
with the 2015 rule limitations have already been issued, EPA expects that the final rule
requirements will be incorporated through permit modifications in most cases." If necessary,
Duke Energy will work with the Department to develop a narrative permit requirement to assure
that treatment components in place continue to be properly operated and maintained to provide
optimum treatment.
2. With the update to the FGD TBEL's, Duke Energy requests that the attached combined waste
formula be used to calculate the limits to account for the use of the FGD wastewater treatment
infrastructure in providing additional treatment to FGD landfill leachate prior to release to the
lined retention basin and ultimately to the Dan River. The combined waste formula calculation
and supporting information can be found in Attachment 1 to this submittal.
3. Duke Energy requests clarification as to required instream sampling related to outfall 006. The
current permit condition A.(22.), refers to instream sampling associated with outfall 003. Ash
basin discharges through outfall 003 were eliminated as part of the work completed under
Consent Order EMC SOC S 18-009. Outfall 006 is located downstream of the previous outfall
003 location. Duke Energy requests the condition in outfall A.(22.) be updated to allow for
www.duke-energy.com

downstream sampling at the Pine Hall Road bridge. Property access limitations and safety
concerns exist downstream of outfall 006 as Duke Energy's property ends very near the outfall
006 location. There are no major tributaries between outfall 006 and the downstream bridge
making it a suitable and well mixed location to measure downstream effects from the discharge.
A map showing the requested sampling location is included as Attachment 2 to this submittal.
4. Duke Energy requests the domestic wastewater limits imposed on internal outfall 009 be
modified to align with technology limits. This system consists of a lagoon and appropriate limits
and sampling frequency for such a system found in 15A NCAC 2B .406 are 30 mg/1 BOD and 90
mg/1 TSS with sampling monthly for pH, TSS, BOD, fecal, ammonia nitrogen, and temperature.
The domestic discharge per day of the sewage lagoon is approximately 9,000 gallons with that
flow going to the lined retention basin before discharge to the Dan River. Copies of pump and
haul applications and issued permits are attached to the submittal as Attachment 3. Pumping
and hauling has been the method of disposal since the permit was issued.
5. Duke Energy requests the addition of landfill leachate flows, from the yet to be constructed CCR
landfill, to the lined retention basin. A new leachate holding basin will be constructed to collect
leachate and handle surges in contact water flow before being pumped to the LRB holding basin,
and ultimately discharged via internal outfall 006. A diagram of the proposed leachate holding
basin is attached as Attachment 4.
6. Duke Energy requests conditions A(3.) and A(4.) of the subject NPDES permit be updated to
remove the limit and footnote for iron at Outfall 006a related to the discharge of chemical/metal
cleaning waste to the ash basin. All flows to the ash basin ceased in March of 2019 so the
condition and footnote are no longer applicable to the ash basin.
A check in the amount of $1,030 is included with this submittal to cover the required permit
modification fee. Should you have any questions about this request please feel free to contact Mr.
Shannon Langley at [phone] or Ms. Lori Tollie at [phone].
Sincerely,
Michael Lanning
General Manager III - Regulated Stations
FHOCC Belews Creek Steam Station
Cc: Shannon Langley
Brenda Johnson
Matt Hanchey
Cynthia Winston

Attachment 3 — New CCR Landfill Leachate Storage Pond

Dewberry
TECHNICAL MEMORANDUM
Date: December 13, 2019
To: Rick Harrison, Duke Energy
From: Leigh -Ann Dudley, PE, Dewberry
Subject: Belews Creek FGD Treatment System Capacity Analysis
Message:
Duke Energy Belews Creek Steam Station (Belews Creek) utilizes an ABMet® biological system for the
treatment of Flue -Gas Desulfurization (FGD) blowdown wastewater. Leachate from the FGD Gypsum
Landfill and Craig's Road Landfill are currently discharged to a new lined retention pond; however, the
pond effluent exceeded the allowable effluent concentration for selenium. Duke executed a sampling plan
and identified the leachate wastestreams as the source. Duke is currently trucking the FGD Landfill
leachate to the FGD wastewater treatment system (FGD WWT). Duke wishes to redirect the leachate
wastestreams from the lined retention pond to the FGD treatment system to treat selenium. Duke wishes
to evaluate the capacity of the treatment system to accept the leachate wastestreams. Duke is interested
in considering the capacity of the treatment system for the following scenarios:
• Scenario 1: Full Baseline Load (Two Coal Units Operational) + FGD Landfill Leachate
o Daily average and maximum daily average FGD blowdown flow rates for specific unit
process evaluations
o Average and 25-year, 24-hour storm FGD Landfill leachate flow for specific unit process
evaluations
o Average and maximum constituent concentrations in FGD blowdown and FGD Landfill
leachate for contaminant loading evaluation
• Scenario 2: Full Baseline Load (Two Coal Units Operational) + FGD Landfill Leachate + Craig's
Road Landfill leachate
o Daily average Craig's Road Landfill leachate flow for specific unit process evaluations
o Average and maximum constituent concentrations in Craig's Road Landfill leachate for
contaminant loading evaluation
Duke anticipates an average leachate flow of 40 gallons per minute (gpm) of FGD Landfill leachate and
30 gpm of Craig's Road Landfill leachate.
Dewberry evaluated the capacity of the treatment system on a hydraulic and contaminant loading basis.
Average and maximum flow and concentration conditions were considered to evaluate typical conditions
and extreme conditions. This analysis is based on the Basis of Design submitted to Duke as Draft on July
11, 2017 and as Final on August 23, 2019 (Attachment A). Duke provided additional data related to the
FGD treatment system on September 18, 2019 and September 20, 2019. In addition, on October 8, 2019
Duke requested a capacity evaluation for the FGD Landfill leachate flow rate associated with a 25-year,
24-hour storm.
Hydraulic Analysis
Overall
Table 1 summarizes the overall hydraulic loading to the FGD treatment system.
Memorandum I 1 of 10

P Dewberry
TECHNICAL MEMORANDUM
Table 1. S stem Wide H draulic Summa 2017 — 2019 Data
Parameter
Average Maximum
(gpm) (gpm)
System Design Capacity 600
Daily FGD Blowdown 189
Average Daily FGD Blowdown 265
Instantaneous 5-min FGD Blowdown 475
Notes
469 All historical operating conditions
469 Two coal units operational
833 All historical operating conditions
The daily average FGD blowdown flow rate and maximum daily blowdown flow rates are below the 600
gpm design flow rate for the FGD wastewater treatment process. The average instantaneous FGD
blowdown is also below the design flow rate. The maximum instantaneous 5-min rate from 2017 — 2019
does exceed that design loading rate; however, this was sustained for less than 15 minutes in a single
occurrence during the two year period.
Additional analysis of individual system components is presented below.
Filtrate Sump
The filtrate sump has an operating capacity of approximately 37,340 gallons. Inputs to the sump include
ultrafilter backwash, filter press filtrate, the continuous backwashing filter, strainer backwash, and
chemical waste. Dewberry evaluated two scenarios for FGD Landfill leachate addition to the filtrate
sump: (i) an average continuous flow rate of 40 gpm and (ii) a maximum continuous flow rate of 280 gpm
for 29 hours to convey the total volume associated with the 25-year, 24-hour storm from the landfill (total
of 487,510 gallons; 63,360 gallons leachate, 120,150 gallons wheelwash and 304,000 gallons
stormwater). The proposed FGD Landfill leachate pump capacity of 280 gpm was used as the maximum
flow rate in this analysis.
The hydraulic analysis of the filtrate sump was based on a comparison of the combined influent flow rates
and the design effluent flow rate over a three day period. Table 2 summarizes the flow streams, flow
rates, total volumes discharged to the sump, and total volume pumped out of the sump for each FGD
Landfill leachate scenario.
There is capacity available in the filtrate sump to accept the additional influent flow from the FGD Landfill
leachate associated with both average and 25-year, 24-hour storm scenarios. The capacity of the filtrate
sump pumps to remove wastewater from the sump exceeds the total inputs for the three day modeling
period. The filtrate sump could accept the average FGD Landfill and Craig's Road Landfill leachate flows.
Memorandum 12 of 10

Dewberry'
TECHNICAL MEMORANDUM
Table 2. Filtrate Sum • H draulic Anal sis
Waste Stream
Maximum
Potential
Instantaneous
Flow (gpm)
Estimated Total
Volume Over Three
Days Including
Average FGD
Leachate Flow
(gallons)
Estimated Total
Volume Over Three
Days Including 25-
yr, 24-hr Storm
FGD Leachate Flow
(gallons)
Duration
Notes for
Flow Inputs
Inputs
Ultrafilter
Backwash
Filter Press
Filtrate
Cont. Backwash
Filter
Strainer
Backwash
726
500
60
80
Chemical Waste 396
FGD Landfill
Leachate
Total In • uts
Output
238,491
40,950
259,200
5 760
3.564
172,800
720,765
Filtrate Sump
Pumps
1,200
726,600
238,491
40,950
259,200
5,760
3, 564
590,640
1,138,605
1,144,800
Occurs every 20 minutes'
Average 325 gpm for 20
minutes twice per day2
Continuous; 3 filters x 20
gpm each3
Assumes entire daily
strainer backwash volume
discharges in single event
once per day
Occurs every 21 days4
Average flow is 40 gpm
continuous; 487,510
gallons from 25-yr, 24-hr
storm pumped at 280 gpm
(29 hours)
(2) x 600 gpm5
1 Per M7 Operating Conditions and Maximum and Minimum Treatment Rates
2 Per August 5, 2019 email from Derek Henderson. Dewberry assumed the average flow of 325 gpm based on
beginning at 500 gpm and declining to 150 gpm over 20 minutes.
3 Per August 5, 2019 email from Derek Henderson.
4 Chemical waste is from Clean in Place (CIP) process for the Ultra Filters. The CIP process occurs every 21 days.
5 For modeling purposes, the following simplified and conservative pump control logic was assumed: water level at 8
feet in sump initiates lead pump at 600 gpm, at 9 feet initiates lag pump at 600 gpm, and both pumps off at 4.5 feet.
Equalization (EQ) Tank
The EQ tank has an operating capacity of 177,000 gallons. The inputs to the EQ tank can be diverted to a
177,000 gallon Maintenance Tank, which we understand the operators currently use as a second EQ in
series. Inputs to the EQ and Maintenance Tanks include the FGD wastewater, backwash waste return,
filtrate sump effluent, and 2"d stage recycle. Flow data for the FGD blowdown is the only metered input.
The effluent from the EQ tank is pumped to the reaction tanks via the forwarding pumps.
As summarized in Table 3, the EQ/Maintenance Tanks can accept the additional average 40 gpm flow
from the FGD Landfill leachate, but cannot accept the higher flow rate of 280 gpm for 29 hours associated
with the 25-year, 24-hour storm from the landfill if the daily maximum FGD blowdown rate of 469 gpm
occurs at the same time. Additional storage volume of approximately 250,000 gallons would be required
for the EQ/Maintenance tanks to accept the volume associated with the 25-year, 24-hour storm from the
FGD Landfill (280 gpm for 29 hours) with the FGD blowdown at the maximum daily average flow rate. The
EQ/Maintenance tanks can accept a maximum continuous flow of approximately 51 gpm when the FGD
blowdown flow rate is 469 gpm, which is not enough capacity for the combined average flow rates of FGD
Landfill leachate and Craig's Road Landfill leachate. When the average FGD blowdown rate of 265 gpm
occurs concurrently with the 29 hours of 280 gpm from the FGD Landfill, the EQ/Maintenance tanks can
accept the flow. It will be critical for the landfill operator to communicate with the wastewater treatment
operator to understand the tank levels and FGD blowdown flow rates prior to initiating discharge of a 25-
year, 24-hour storm.
Memorandum 13 of 10

Dewberry
TECHNICAL MEMORANDUM
Table 3. EQ Tank Hydraulic Analysis
Waste Stream
Inputs
Maximum
Potential
Instantaneous
Flow (gpm)
Estimated
Total
Volume Over
Three Days
Including
Average
FGD
Leachate
Flow
(gallons)
Estimated Total
Volume Over Three
Days Including 25-yr,
24-hr Storm FGD
Leachate Flow
(gallons)
Duration Note
FGD Blowdown
Max Daily
Average
Backwash
Waste Return
Filtrate Sump
Pumps'
2nd Stage
Recycle Pumps
Total In. uts
Output
Forwarding
Pump Capacity
469
2,026,080
70 201,600
1,200 726,600
500
700
22,500
2,976,780 3,394,980
2,976,800
3,024,000
2,026,080
201,600
2017-2019 daily maximum with
two units operational
Per email from Derek
Henderson August 5, 2019;
runs 16 hours per day
1,144.800 (2) x 600 gpm2
Used as -needed per email
22,500 from Derek Henderson August
5, 2019; assumed 15 minutes
per day
700 gpm3
1The volumes from the filtrate sump include the FGD Landfill leachate.
2 For modeling purposes, the following simplified and conservative sump pump control logic was assumed: water
level at 8 feet in sump initiates lead pump, at 9 feet initiates lag pump, and both pumps off at 4.5 feet.
3 For modeling purposes, the following simplified and conservative forwarding pump control logic was assumed:
water level at 16 feet in EQ tank initiates pump at a maximum flow rate of 700 gpm and pump off at 10.5 feet.
Solids Contact Clarifier
The hydraulic capacity of the solids contact clarifiers is based on a comparison of projected loading
conditions on the design rise rate. Table 4 summarizes the baseline rise rate and the rise rate with the
addition of leachate flow. We understand Duke prefers to operate with a single clarifier. We have
calculated the projected rise rates below with one unit operational and both units operational for
comparison. Red text indicates the projected rise rate exceeds the design rise rate.
Memorandum 14 of 10

Dewberry
TECHNICAL MEMORANDUM
Table 4. Solids Contact Clarifier Loadin • Anal sis
Parameter
Unit Average Maximum
Surface Area (per clarifier)
square ft (sq ft)
Desi • n Rise Rate • • mis. ft
Baseline Condition (Two Coal Units)
Flow'
Rise Rate — One Clarifier
Rise Rate — Two Clarifiers
gpm
gpm/sq ft
352
0.214
0.107
1,649
0.205
578
0.350
0.175
Scenario 1
FGD Leachate Flow
Combined Flow
Rise Rate — One Clarifier
Rise Rate — Two Clarifiers
FGD + Craigs Road Leachate gpm
40
392
0 238
0.119
618
0375
0.187
Combined Flow gpm 422 648
Rise Rate — One Clarifier gpm/sq ft 0.393
Rise Rate — Two Clarifiers gpm/sq ft 0.128 0.196
1The baseline condition average and maximum flow rates are from forwarding pump data recorded between 2017
and 2019.
Even at the baseline flow with two coal units operational, the rise rate with one clarifier in operation
exceeds the design rise rate. We understand Duke has not experienced operational problems operating
one clarifier. For both Scenario 1 and Scenario 2, the rise rate at average and maximum flow is projected
to be above the design rise rate. At average flow conditions, the rise rates for both scenarios with one
clarifier is above the design rate but it is within the range 0.214 — 0.350 gpm/sq ft that Duke has
historically operated with one clarifier in operation during periods with two coal units in operation. The
projected rise rates with two clarifiers in operation is below the design rate for both scenarios. The
existing solids contact clarifiers have capacity to accept the FGD leachate and Craig's Road Landfill flow
rates. Under higher flow rates Duke may have to operate more than one clarifier to maintain effluent
quality.
Continuous Backwash Gravity Filter
The hydraulic capacity of the continuous backwash gravity filter is based on a comparison of projected
loading conditions on the design rise rate. The design rise rate was provided on the Process Flow
Diagram. Table 5 summarizes the baseline rise rate and the rise rate with the addition of leachate flow.
Table 5. Continuous Backwash Gravit Filter Loadin • Anal sis
Parameter Unit Average Maximum
Surface Area
gpm
gpm
gpm/sq ft
pm/sq ft
square ft (sq ft)
Desi • n Rise Rate • • m/s. ft
Baseline Condition Two Coal Units 1
Flow'
Rise Rate
cenario 1
gpm
m/s • ft
FGD Leachate Flow gpm
Combined Flow gpm
Rise Rate • •m/s
FGD + Craigs Road Leachate gpm
Combined Flow gpm 422 648
Rise Rate gpm/sq ft 1.60 2.45
'The baseline condition average and maximum flow rates are from forwarding pump data recorded between 2017
and 2019.
352
1.33
392
264
3.93
40
578
2.19
618
Memorandum 15 of 10

Dewberry
TECHNICAL MEMORANDUM
The projected rise rates for average and maximum flow conditions are within the design rise rate of the
continuous backwash gravity filters for Scenario 1 and Scenario 2.
Ultrafilter
Table 6 summarizes the hydraulic capacity analysis of the ultrafiltration system. The historical and
projected hydraulic loading to the ultrafiltration system is based on the flow data from the selenium
reduction pumps. Red text indicates the projected flow is above design capacity.
Table 6. Ultrafilter Loadin • Anal sis
Parameter
Value
Design Normal Operation'
Design Maximum Operation'
Baseline Condition (Two Coal Units)2
Average Flow
Maximum Flow
Scenario 1
FGD Leachate Flow
Projected Average Flow
Projected Maximum Flow
Scenario 2
0.58 MGD
403 gpm
0.92 MGD
638 • • m
365 gpm
708 ••m
40 gpm
405 gpm
748 ..m
FGD + Craig's Road Leachate 70 gpm
Projected Average Flow 435 gpm
Projected Maximum Flow 778 gpm
1 Per M7 Operating Conditions and Maximum and Minimum Treatment Rates
2The baseline condition average and maximum flow rates are from selenium reduction pump data recorded between
2017 and 2019.
The historical maximum flow for the baseline condition is above the maximum design condition as is the
maximum projected flow for Scenario 1 and Scenario 2. The average conditions for Scenario 1 and
Scenario 2 are between the normal operation and maximum operation design conditions.
Constituent Loading
In addition to hydraulic loading, Dewberry evaluated the constituent loading capacity of the treatment
system. Historical loading of the treatment system during periods when two coal units were operational
was compared to the influent design basis in Table 7 (attached). The baseline loading comparison was
performed for two conditions: average flow with average concentration and maximum flow with maximum
concentration.
While historical data from 2017-2019 showed periods when the influent concentrations exceeded the
influent design criteria, limited paired influent and effluent data was provided to allow for an analysis of
the system performance specifically during historical periods when the influent concentrations exceeded
the design. Duke provided additional flow and analytical data from the FGD treatment system from 2010
through 2019 to facilitate further analysis of selenium removal in the system, which is summarized in
Table 8 (attached). Dewberry also used the data from 2010 through 2019 to evaluate leachate addition
scenarios in Table 9 (attached) and to evaluate the biological portion of the treatment system based on
biological selenium reduction rates found in the literature in Table 10 (attached).
There were 238 dates where influent and effluent selenium concentrations and flow rates were recorded
between 2010 and 2019 (see Table 8, attached). On average, the influent selenium concentrations and
loading rates were within the influent design criteria. There have been historical loading rates that have
Memorandum 16 of 10

Dewberry'
TECHNICAL MEMORANDUM
exceeded the influent design criteria, but the data shows that the performance guarantees for selenium
removal have been met under these conditions (Table 8, attached).
Nitrate was a parameter of concern for this analysis as it interferes with the biological selenium removal
process. As shown in Table 7, nitrate historically remained below the design influent concentration of 200
milligrams per liter (mg/L) for the baseline condition and the addition of landfill leachate is not expected to
increase the nitrate concentration above the influent design criteria.
The average historical selenium loading to the FGD treatment system with additional landfill leachate
loading scenarios are presented in Table 9 (attached). Two scenarios of FGD Landfill leachate loading
were evaluated: (i) average selenium concentration and average flow rate and (ii) average selenium
concentration and flow rate from the 25-year, 24-hour storm. The FGD treatment system can handle both
selenium loading scenarios from the FGD Landfill leachate. The influent design capacity on a mass basis
for the system is 29 pounds of selenium per day (Ib/d). Under historical average loading, the influent
selenium mass is 14 Ib/d, leaving approximately 15 Ib/d remaining capacity. At the average leachate flow
of 40 gpm and selenium concentration of 1.74 mg/L, the FGD Landfill leachate will contribute 0.8 Ib
selenium per day. An FGD leachate flow of approximately 1 million gallons per day (average of 694 gpm)
at the selenium concentration of 1.74 mg/L would have to be discharged to use all of the remaining
capacity when the FGD blowdown is operating at average flow and average selenium concentration. At
the average Craig's Road leachate flow of 30 gpm and selenium concentration of 0.089 mg/L, the Craig's
Road Landfill leachate will contribute 0.03 Ib selenium per day. A flow of approximately 9 million gallons
per day (average of 6,550 gpm) from the Craig's Road Landfill could be accepted on top of the average
FGD blowdown and the 25-year, 24-hour storm from the FGD Landfill on a selenium capacity basis. It is
important to note that there have been historical FGD blowdown purges that have exceeded the influent
design criteria selenium concentration, so it is anticipated that periodic exceedances will continue to occur
with the addition of the landfill leachate.
Dewberry performed a literature review on biological selenium reduction to support the evaluation of the
Belews Creek FGD wastewater treatment system capacity. Fujita et al. performed laboratory -scale
testing in a continuous flow bioreactor and observed 99% removal of selenium for loading rates Tess than
or equal to 0.45 milligrams of selenium per liter per hour (mg/Uh). On average, the selenium loading rates
into the Belews Creek ABMet® system range from 0.03 mg/Uh when eight removal tanks are online to
0.12 mg/Uh when two removal tanks are online (see Table 10, attached). The selenium loading rates
remain below the literature value of 0.45 mg/L/h when the average selenium loading rates from the FGD
Landfill and Craig's Road Landfill are added to the average historical ABMet® system loading rates,
regardless of the number of removal tanks online. When the maximum selenium loading rates associated
with both landfill leachate streams are added to the FGD system operating at maximum historical loading,
the 0.45 mg/L/hr loading rate is exceeded; however, this scenario of maximum flow and maximum
concentration occurring at the same time is unlikely and has not occurred in the nine years of data
reviewed. In a publication by the Water Environment Federation describing ABMet® technology, a two -
to -sixteen hour empty bed contact time (EBCT) is recommended for the reduction and precipitation of
selenium. Assuming the empty bed volume is two-thirds of the removal tank volume, the EBCT in the
Belews Creek ABMet® system under historical average conditions with average selenium loading rates
from the FGD Landfill and Craig's Road Landfill leachates is within that range as long as at least four
tanks are online (see Table 10, attached).
Regulatory Review
Dewberry reviewed the Steam Electric Effluent Limitations Guidelines (40 CFR § 423) to evaluate the
regulatory impacts of the addition of one or both of the landfill leachate streams to the FGD wastewater
treatment system. In particular, Dewberry reviewed impacts to the numerical limitations in the Belews
Creek NPDES Permit NC0024406. The treated FGD blowdown is subject to numerical limits at internal
Outfall 002 before being discharged to the lined retention basin and then ultimately discharged to an
Unnamed Tributary to the Dan River.
Memorandum 17 of 10

Dewberry
TECHNICAL MEMORANDUM
Outfall 002, the treated FGD blowdown, is subject to the numerical effluent limits summarized in Table 11.
The permit indicates the limits for arsenic, mercury, selenium, and nitrate/nitrite are not in effect until
November 1, 2020.
Table 11. Permit NC0024406 Outfall 002 Numerical Effluent Limits and Regulatory References
Parameter
Monthly Average Daily Maximum
Permit Limit Permit Limit
Regulatory Reference
Total Arsenic
Total Mercury
Total Selenium
Nitrate/Nitrite as N
Oil and Grease
Total Suspended
Solids
8.0 µg/L
356.0 ng/L
12.0 µg/L
4.4 mg/L
15.0 mg/L
30.0 mg/L
11.0 µg/L
788.0 ng/L
23.0 µg/L
17.0 mg/L
20.0 mg/L
50.0 mg/L
40 CFR § 423.13(g)(1)(i)
40 CFR § 423.13(g)(1)(i)
40 CFR § 423.13(g)(1)(i)
40 CFR § 423.13(g)(1)(i)
40 CFR § 423.12(b)(11)
40 CFR § 423.12(b)(11)
It is anticipated that accepting landfill leachate at the FGD treatment system will impact the Outfall 002
numerical limits. According to 40 CFR § 423.12(b)(13) and § 423.13(n), "In the event that wastestreams
from various sources are combined for treatment or discharge, the quantity of each pollutant property
controlled in paragraphs...of this section attributable to each controlled waste source shall not exceed the
specific limitation for that waste source."
Combustion residual leachate is subject to the same TSS and oil and grease limits as FGD wastewater
per 40 CFR § 423.12(b)(11). As such, no changes in the TSS and oil and grease limits at Outfall 002 are
anticipated by combined landfill leachate and FGD wastewater for treatment.
Combustion residual leachate is not regulated for selenium, nitrate/nitrite-N, arsenic, or mercury in 40
CFR § 423. As such, it is anticipated that adding one or both leachate streams to the FGD wastewater
stream will decrease the concentration limits for these parameters from the existing FGD limits in NPDES
Permit NC0024406. The speculative limits are calculated based on a ratio of the flow contribution from
each wastestream and the numerical limits for each wastestream. The calculation approach for this is
outlined in Section 5.2.2.6 of the NPDES Permit Writers Manual (EPA-833-K-10-001, 2010). Table 12
presents speculative new limits if one or both leachate streams are combined with the FGD blowdown.
Table 13 presents speculative new limits for the combined wastestreams based on proposed Effluent
Limitations Guidelines for Steam Electric Power Generators published November 22, 2019.
Table 12. Existin I FGD Concentration Limits and Calculated Alternative Concentration Limits
Scenario
Current Duffel! 002 Limits
Speculative Scenario 1
Limits (FGD Landfill +
FGD Blowdown)
Speculative Scenario 2
Limits (FGD and Craig's
Road Landfill +
Blowdown)
Selenium
(ug/L)
Monthly Daily
Average Maximum
12 23
Nitrate/Nitrite-N Arsenic Mercury
(mg/L) (Ng/L) (ng/L)
Monthly Daily Monthly Daily Monthly Daily
Average Maximum. Average Maximum Average Maximum
4.4
17 8
11
356
788
10 20 3.8 15 7.0 10 309 685
9.5 18
3.5 13 6.3 9 282 623
Memorandum 18 of 10

Dewberry
TECHNICAL MEMORANDUM
Table 13. Anticipated FGD Concentration Limits and Calculated Alternative Concentration Limits
Based on ELGs • ro • osed November 22, 2019.
Scenario
Selenium Nitrate/Nitrite-N Arsenic Mercury
(µg/L) (mg/L) (µg/L) (ng/L)
Monthly Daily Monthly Daily Monthly Daily Monthly Daily
Avera•e Maximum Avera•e Maximum Avera•e Maximum Avera.e Maximum
Anticipated Outfall 002
Limits based on 2019 31 76 3.2
ELG revision
Speculative Scenario 1
4.6
9
18
31
85
Limits (FGD Landfill + 27 66 2.8 4.0 8 16 27 74
FGD Blowdown)
Speculative Scenario 2
Limits (FGD and Craig's 25 60 2.5 3.6 7 14 25 67
Road Landfill + FGD
Blowdown)
Conclusions
An evaluation of the FGD treatment system historical data indicates that the baseline condition when two
coal units are operational may periodically exceed the concentration and mass design basis for select
parameters (Table 7, attached). However, comparison of historical influent and effluent selenium
concentrations and mass flow rates indicates that the performance guarantees for selenium removal have
historically been met, even under high loading conditions (Table 8, attached). Under average FGD
blowdown conditions, there is selenium removal capacity available for the average flow rate and the flow
rate associated with the 25-year, 24-hour storm from the FGD Landfill leachate (Table 9, attached). It is
important to note that there have been historical FGD blowdown discharges that have exceeded the
influent design criteria selenium concentration, so it is anticipated that periodic exceedances will continue
to occur with the addition of the landfill leachate. The Belews Creek ABMet® system has historically
operated at selenium loading rates and empty bed contact times (EBCT) recommended for optimum
biological selenium removal published in the literature (Table 10, attached). Under average FGD
blowdown conditions, it is expected that the loading rates and EBCT will remain approximately within
literature -recommended ranges with the addition of the average selenium loading from the FGD Landfill
and Craig's Road Landfill leachate streams, when at least four bioreactor cells are in operation.
On a hydraulic basis, the filtrate sump and the EQ/Maintenance tanks can accept the average FGD
Landfill leachate flow of 40 gpm with the FGD blowdown at the maximum daily average flow of 469 gpm
(Tables 2 and 3). The filtrate sump and EQ/Maintenance tanks cannot accept the combined average FGD
Landfill leachate and Craig's Road Landfill leachate flows when the FGD blowdown is 469 gpm.
Additional storage volume of approximately 250,000 gallons would be required for the EQ/Maintenance
tanks to accept the volume associated with the 25-year, 24-hour storm from the FGD Landfill (280 gpm
for 29 hours) with the FGD blowdown at the maximum daily average flow rate. When the average FGD
blowdown rate of 265 gpm occurs concurrently with the 25-year, 24-hour storm flow (29 hours of 280
gpm) from the FGD Landfill, the EQ/Maintenance tanks can accept the flow. The EQ/Maintenance tanks
can accept the combined average FGD Landfill leachate and Craig's Road Landfill leachate when the
FGD blowdown is 265 gpm. It will be critical for the landfill operator to communicate with the wastewater
treatment operator to understand the tank levels and FGD blowdown flow rates prior to initiating
discharge of a 25-year, 24-hour storm.
The flow rate to the unit processes downstream of the EQ/Maintenance tanks is limited by the forwarding
pumps and discharge piping from the Equalization tank. Assuming the forwarding pumps operate at a
rate of 700 gpm or lower, the hydraulic analysis indicates the solids upflow clarifiers, the ultrafilters, and
the continuous backwash gravity filters have sufficient capacity to accept the additional flow.
Memorandum 19 of 10

Dewberry -
TECHNICAL MEMORANDUM
Evaluation of the Steam Electric Effluent Limitations Guidelines (40 CFR § 423) indicated that adding a
combustion residual leachate stream to the FGD wastewater stream will likely not change limits on TSS
or oil and grease and would potentially decrease numerical concentration limits for selenium,
nitrate/nitrite, arsenic, and mercury. The proposed Steam Electric Effluent Limitations Guidelines
published on November 22, 2019 include lower limits for mercury and nitrate/nitrite and higher limits for
arsenic and selenium as compared to the current limits. Dewberry anticipates addition of the leachate
stream to the FGD wastewater stream would also decrease numerical concentration limits for selenium,
nitrate/nitrite, arsenic, and mercury.
Attachments:
Table 7: FGD System Influent Design Criteria and Baseline Condition Loading
Table 8: FGD Wastewater Treatment System Influent and Effluent Conditions
Table 9: Comparison of FGD Wastewater Treatment System Average Loading Rates with Added
FGD Leachate Stream Scenarios to Alstom System Design Criteria
Table 10: Comparison of Biological System Selenium Loading Rates to Literature Reference Values
Attachment A: Dewberry Basis of Design for Landfill Leachate Treatment Evaluation Memorandum
References:
Fujita, M., Ike, M., Kashiwa, M., Hashimoto, R., & Soda, S. (2002). Laboratory -scale continuous reactor
for soluble selenium removal using selenate-reducing bacterium, Bacillus sp. SF-1. Biotechnology and
Bioengineering, 80(7), 755-761. doi: 10.1002/bit.10425
Sonstegard, J., Harwood, J., Pickett, T., & Kennedy, W. (2009). ABMet: setting the standard for selenium
removal. Proceedings from the Water Environment Federation, 2009(5), 234-246. doi:
10.2175/193864709793900654
United States Environmental Protection Agency. (2010). National pollutant discharge elimination system
(NPDES) permit writers' manual (EPA-833-K-10-001). Retrieved from
https://www.epa.gov/sites/production/files/2015-09/documents/pwm_2010. pdf
cc:
Derek Henderson, Duke Energy
Ed Byers, Duke Energy
Ryan Ames, PE, Dewberry
Katie Jones, PE, Dewberry
Amber Greune, PE, Dewberry
Memorandum 110 of 10

Table 7
FGD System Influent Design Criteria and Baseline Condition Loading
Duke Energy Belews Creek
Influent Basis
of Design
Baseline Condition (Two
FGD Blowdown
(Average t..5Flow)
7• .
Coal Units Operational)
FGD Blowdown
(Maximum
Flow)
Flow
gpm
600
265
469
gpd
864 000
381,893
675.840
Total Suspended Solids
mg/I
16,000
115,292
20,000
144,115
9,333
29,725
78.360
Chloride
mg/I
12,000
86,469
12,000
86,469
9.576
30,498
15,770
Nitrate
mg/I
200
1,441
200
1,441
24
75
45
254
Selenium (Se)
mg/I
4.0
29
4.0
29
4.1
13.2
6.1
Ammonium
mg/I
14
101
14
101
-
-
-
-
Antimony (Sb)
ug/I
20.0
0.14
30.0
0.22
-
-
-
-
Arsenic (As)
ug/I
490
3.5
1,160
8.4
630
2.0
1 300
7 3
Barium (Ba)
ug/I
7,330
53
16,490
119
-
-
-
-
Beryllium (Be)
ug/I
13.0
0.09
52.0
0.37
-
-
-
-
Cadmium (Ca)
ug/I
100
0.7
180
1.3
9.9
0.03
16.7
0.1
Chromium (Cr)
ug/I
360
2.6
930
6.7
561
920
5.2
Cobalt (Co)
ug/I
420
3.0
530
3.8
-
-
-
-
Copper (Cu)
ug/I
540
3.9
760
5.5
385
1.2
3.2
Fluorine (F)
mg/I
39.5
285
53.7
387
-
-
-
-
Lead (Pb)
ug/I
350
2.5
780
5.6
-
-
-
-
Manganese (Mn)
ug/I
6,520
47
7,540
54
-
-
-
-
Mercury (Hg)
ug/I
300
2.2
300
2.2
0.9
426
Molybdenum (Mo)
ug/I
410
3.0
580
4.2
-
-
-
-
Nickel (Ni)
ug/I
760
5.5
930
6.7
506
1.6
1,070
Silver (Ag)
ug/I
60.0
0.4
70.0
0.5
-
-
-
-
Thallium (TI)
ug/I
200
1.4
210
1.5
-
-
-
-
Vanadium (V)
ug/I
560
4.0
1,410
10
-
-
-
-
Zinc (Zn)
ug/I
900
6.5
1,760
13
2.5
1.180
6 7
Red highlighting indicates the concentration or mass loading exceeds the influent basis of the design
Yellow highlighting indicates the concentration or mass lading is between 75' % - 1005,,, of the des.,.
Notes:
'-" indicates no historical data was provided for this parameter and wastestream.
Average historical FGD blowdown is compared to the average basis of design and the maximum condition is compared to maximum basis of design.
The analytical concentrations in the FGD Blowdown were collected from Duke's sample location ID: FGD Purge between January 2017 and March 2019.
Influent Basis of Design is based on the Alstom Wastewater Treatment System document Dated June 2, 2006.
Influent Basis of Design was provided only as influent concentrations. Dewberry calculated mass influent basis based on the flow of 600 gpm.
11/4/2019
1 of 1
• Dewberry

Table 8
FGD Wastewater Treatment System Influent and Effluent Conditions
Duke Energy Belews Creek
EQ Tank Effluent
Biological
System Effluent
©ateSystem
Forwarding Pump Rate
(9Pm)
303
Selenium Concentration
in EQ Tank Effluent
(m9�i
1.77
Selenium Mass Flow
(lb/day)
6
Selenium Reduction
Pump Rate
(9Pm)
272
Selenium Concentration
in Biological Seleni
Reduction Syst
Efflu
Selenium Mass Flow
(lb/day)
24-Mar-10
0.008
r03
08-Jun-11
540
3.74
24
553
0.003
0.02
22-Jun-11
561
3.83
26
592
0.003
0.02
13-Jul-11
542
4.94
32
570
0.006
0.04
27-Jul-11
327
8.98
35
345
0.006
0.02
10-Aug-11
524
9.53
60
544
0.005
0.03
24-Aug-11
540
4.65
30
576
0.005
0.03
14-Sep-11
593
5.25
37
590
0.005
0.04
28-Sep-11
563
1.07
7
587
0.005
0.04
12-Oct-11
449
4.11
22
460
0.012
0.07
26-Oct-11
608
4.20
31
596
0.003
0.02
09-Nov-11
643
3.69
28
617
0.003
0.02
13-Nov-11
614
4,42
33
585
0.003
0.02
14-Dec-11
631
4.16
31
608
0.003
0.02
28-Dec-11
434
3.74
19
427
0.003
0.01
11-Jan-12
426
3.70
19
428
0.005
0.03
25-Jan-12
601
2.46
18
604
0.003
0.02
08-Feb-12
544
3.81
25
544
0.005
0.03
14-Mar-12
499
3.71
22
497
0.003
0.01
28-Mar-12
274
3.08
10
278
0.003
0.01
25-Apr-12
257
2.69
8
267
0.005
0.02
09-May-12
483
4.98
29
523
0.005
0.03
21-May-12
458
5.25
29
468
0.005
0.03
22-May-12
514
3.85
24
527
0.007
0.04
23-May-12
480
2.69
15
479
0.007
0.04
28-May-12
488
4.20
25
476
0.013
0.08
29-May-12
494
3.86
23
493
0.014
0.08
30-May-12
519
5.13
32
527
0.016
0.10
13-Jun-12
515
3.97
25
510
0.003
0.02
27-Jun-12
491
4.54
27
488
0.009
0.05
08-Aug-12
479
5,01
29
454
0.008
0.05
29-Aug-12
445
0.53
3
445
0.008
0.04
12-Sep-12
497
2.74
16
494
0.006
0.04
26-Sep-12
342
3.22
13
337
0.003
0.01
10-Oct-12
388
3.80
18
383
0.003
0,01
29-Oct-12
370
4 13
18
369
0.006
0.03
31-Oct-12
254
4.66
14
246
0.005
0.02
02-Nov-12
390
3.97
19
388
0.003
0.01
05-Nov-12
393
2.53
12
388
0.008
0.04
09-Nov-12
546
3.77
25
554
0.005
0,04
12-Nov-12
564
4 44
30
579
0.003
0.02
14-Nov-12
513
3 71
23
522
0.003
0.02
16-Nov-12
431
4 84
25
437
0.003
0.01
19-Nov-12
418
3 35
17
421
0.008
0.04
21-Nov-12
462
3.59
20
469
0.005
0.03
11/4/2019
1 of 6
g Dewberry

Table 8
FGD Wastewater Treatment System Influent and Effluent Conditions
Duke Energy Belews Creek
EQ Tank Effluent
Biological
Selenium Reduction
Selenium Mass Flow
System Pump Rate
(Ibiday) (Om)
System Effluent
- - - rl
Selenium Concentration
Forwarding Pump Rate
in EQ Tank Effluent
(9pm) (mgfL)
Selenium Concentration
in Biological Selenium Selenium Mass Flow
System (lb/day)
Effluent
Effluent (mg/L)
0.009 0.06
MMLNIMEMIIIINNIMMINIIIIMEEM11111
a-
,
r
r
0.006
LEMM
IIMJMIIIIII
0.007
r ,
0.010
0.06
MIE ■ -
0.009
r r
MINIAa -
,•-
0.008
r r
„
0.008iliil
rr
,
„
MIIIIIIIIIIMiiiIIIIMINOMMIIIIMI
IZAZUMIMMIIIM@EllIIIMUIZIMIIMMIE0.003
ii:LaililiaMUMM3IMMEIIIIIIIMIM
■ -
0.008
0.006
r r•
r r
lZk
0.010
0.06
Iiiil•
r
0.006
MIIMELIMIIIMEI
Z-
;aIIMIMililMilla
MIEMMEQUIM=Iiii11.1111IMMIIM0.006
r
0.009
I
LU;11.IIII.11020.08
IMIELLIIMIM
0.006
r r
r
0.003
;;
0.003
2.11.
MIIIIELM:itillilliMMa0.003
MIIIMILL
rr
MIEUEZEMEMINIMI
r
0.003
•.
0.003
r r
,•
r
0.003
r r
ilalliMilIMIZINUIMIIIIIII0.006
r
0.003
LIIMMIIII
•
0.003
•rr
0.003
EMIll
MINIZilIZEUMMIME111BEMEMEll
,.MELIZZEMINIIIMIIIIME1111.11.1MIIMMIMM0.003
r
0.003
0.003
111111.111r
MilliiMIMIE
IIIMMENIMIIIIIIKEIJIMMIE0.003
IILI
r=MEESEZEIMINE11.1.M1.11011111.=0.005
0.003
.EILMIEM
0.003
, r
,,•
0.003
0.003
01.1113M11111.11
IMIUMIEM
1:11Z/M111111.11MISAIUMIIMEMIIIIMINIIMIRE.
-
IiIMENEMMIKIIMMIUMIMIEllial0.005
Milai,
MINE=EMEMZEMIMMINIIIMILMINEMIMMININIMM/30.003
,.
r
0.005
0.006
r r
0.003
0.006
0.003
jaMMIMI
Mill.2,
r r
MIKE•
r.
0.008
,r
09-Oct-13
0.008
,
11/4/2019
2 of6
Dewberry.

Table 8
FGD Wastewater Treatment System Influent and Effluent Conditions
Duke Energy Belews Creek
Forwarding Pump Rate
(gpm)
370
EQ Tank Effluent
Selenium Concentration
in EC) Tank Effluent
(m9/�)
2.49
Biological System Effluent
Selenium Reduction Selenium Concentration
in Biological Selenium
System Pump Rate
(9Pm1 Reduction System
Effluent (mg/L)
Selenium Mass Flow
(lb/day)
11
Selen 1 "• `
(lb/day)
16-Oct-13
352
0.006
0.03
23-Oct-13
263
1.65
5
255
0.006
0.02
30-Oct-13
391
3.21
15
361
0.006
0.03
04-Nov-13
337
3.20
13
320
0.003
0.01
06-Nov-13
321
3.30
13
322
0.003
0.01
08-Nov-13
235
2.65
7
231
0.003
0.01
11-Nov-13
334
3.39
14
327
0.005
0.02
13-Nov-13
299
3.29
12
292
0.007
0.02
15-Nov-13
344
0.00
0
338
0.000
0.00
18-Nov-13
300
2.15
8
281
0.003
0.01
20-Nov-13
301
2.14
8
284
0.007
0.02
22-Nov-13
180
0.26
1
169
0.007
0.01
26-Nov-13
334
0.54
2
328
-
28-Nov-13
331
2.69
11
323
0.005
0.02
26-Mar-14
427
5.68
29
429
0.005
0.03
09-Apr-14
301
0.65
2
300
0.005
0.02
23-Apr-14
436
3.04
16
413
0.005
0.02
13-May-14
440
2.39
13
451
0.002
0.01
28-May-14
430
2.97
15
439
0.002
0.01
11-Jun-14
377
2.73
12
389
0.003
0.01
23-Jul-14
318
2.28
9
332
0.003
0.01
13-Aug-14
240
1.97
6
250
0.002
0.01
28-Aug-14
323
2.47
10
338
0.005
0.02
10-Sep-14
385
3.53
16
376
0.005
0.02
24-Sep-14
332
4.30
17
339
0.004
0.02
09-Oct-14
293
2.12
7
286
0.011
0.04
12-Nov-14
252
3.89
12
234
0.003
0.01
26-Nov-14
92
2.68
3
95
0.004
0.00
09-Dec-14
78
2.40
2
73
0.007
0.01
23-Dec-14
97
2.61
3
95
0.005
0.01
14-Jan-15
303
4.79
17
280
0.010
0.03
29-Jan-15
333
3.79
15
404
0.032
0.16
11-Feb-15
341
2.43
10
341
0.013
0.05
25-Feb-15
331
4.36
17
310
0.038
0.14
11-Mar-15
506
3.78
23
477
0.012
0.07
24-Mar-15
274
1.76
6
255
0.003
0.01
13-Apr-15
323
3.63
14
291
0.011
0.04
22-Apr-15
165
2.81
6
152
0.007
0.01
12-May-15
300
4.95
18
292
0.016
0.06
27-May-15
411
4.88
24
392
0.013
0.06
09-Jun-15
432
3.09
16
425
0.011
0.06
23-Jun-15
373
6.00
27
367
0.008
0.04
07-Ju1-15
464
4.39
24
459
0.010
0.06
22-Jul-15
370
3.60
16
353
0.013
0.06
11-Aug-15
348
2.33
10
327
0.014
0.05
11/4/2019
3 of 6
It Dewberry

Table 8
FGD Wastewater Treatment System Influent and Effluent Conditions
Duke Energy Belews Creek
EQ Tank Effluent
Biological
Selenium Reduction
System Pump Rate
(gpm)
232
System Effluent
Selenium Concentration
in Biological Selenium
nt Reductionnt System
Efflue
0.008
Selenium Mass FI
,g`
(lb/day) .,..
0.02
rwarding Pump Rate
(gpm)
257
Selenium Concentration
in EQ Tank Effluent
(mglL)
3.11
Selenium Mass Flow
(Ib/day)
10
6-Aug-15
10-Sep-15
280
2.66
9
270
0.016
0.05
22-Sep-15
318
3.97
15
309
0.014
0.05
14-Oct-15
209
2 84
7
209
0.010
0.02
27-Oct-15
407
4 88
24
408
0.013
0.06
16-Nov-15
112
3.80
5
109
0.009
0.01
18-Nov-15
248
3.05
9
245
0.008
0.02
23-Nov-15
458
3,04
17
469
0.015
0.09
26-Nov-15
310
3.12
12
314
0.014
0.05
30-Nov-15
311
2.52
9
313
0.016
0.06
02-Dec-15
258
3.10
10
257
0.010
0.03
07-Dec-15
256
4.64
14
258
0.009
0.03
09-Dec-15
371
5.86
26
397
0.009
0.04
13-Dec-15
222
5.98
16
216
0.013
0.03
16-Dec-15
173
3.31
7
170
0.014
0.03
20-Dec-15
227
3.83
10
223
0.009
0.02
06-Jan-16
492
8.68
51
495
0.023
0.13
13-Jan-16
505
3.34
20
504
0.015
0.09
27-Jan-16
436
4.13
22
425
0.045
0.23
09-Feb-16
492
3.20
19
473
0.009
0.05
26-Feb-16
219
3.36
9
214
0.008
0.02
08-Mar-16
340
3.14
13
328
0.011
0.04
23-Mar-16
233
3.72
10
219
0.007
0.02
12-Apr-16
295
5.34
19
286
0.009
0.03
27-Apr-16
273
2.98
10
260
0.008
0.02
25-May-16
320
2.97
11
315
0.003
0.01
07-Jun-16
481
4 51
26
484
0.003
0.02
21-Jun-16
401
3.62
17
392
0.002
0.01
26-Jul-16
344
4 51
19
351
0.003
0.01
09-Aug-16
336
5.15
21
356
0.003
0.01
23-Aug-16
292
4.50
16
302
0.003
0.01
13-Sep-16
411
5.81
29
432
0.003
0.02
27-Sep-16
348
6.43
27
362
0.004
0.02
11-Oct-16
224
7.89
21
241
0.004
0.01
25-Oct-16
230
4.29
12
240
0.022
0.06
08-Nov-16
229
4.16
11
246
0.003
0.01
21-Nov-16
61
4.62
3
70
0.004
0.00
13-Dec-16
181
4.62
10
183
0.001
0.00
27-Dec-16
168
3.81
8
164
0.002
0.00
11-Jan-17
384
4.60
21
357
0.001
0.00
24-Jan-17
121
4.36
6
115
0.001
0.00
07-Feb-17
155
3.33
6
180
0.004
0.01
21-Feb-17
83
3.12
3
89
0.006
0.01
07-Mar-17
241
4.03
12
261
0.008
0.02
21-Mar-17
330
4.22
17
334
0.001
0.00
11/4/2019
4of6
Dewberry

Table 8
FGD Wastewater Treatment System Influent and Effluent Conditions
Duke Energy Belews Creek
Date -
11-Apr-17
Forwarding Pump Rate
(9Prn)
358
EQ Tank Effluent
Selenium Concentration
in EC) Tank Effluent
(meal
,03
Selenium Mass Flow
(Ib/day)
22
Biological
Selenium Reduction
System Pump Rate
(9Pm)
381
System Effluent
Selenium Concentration
in Biological Selenium
Reduction System
Effluent (mg/1..)
Selen "••
(lb/day)
0.007
0.03
25-Apr-17
176
4.80
10
188
0.001
0.00
09-May-17
248
3.73
11
254
0.001
0.00
23-May-17
290
4.61
16
291
0.001
0.00
13-Jun-17
381
4,05
19
389
0.002
0.01
27-Jun-17
399
4.32
21
408
0.001
0.00
11-Ju1-17
442
4.94
26
453
0.003
0.01
25-Jut-17
304
410
15
309
0.002
0.01
09-Aug-17
323
3.49
14
339
0.003
0.01
22-Aug-17
387
5 59
26
414
0.002
0.01
17-Sep-17
173
3,90
8
190
0.001
0.00
29-Sep-17
131
5.52
9
143
0.002
0.00
11-Oct-17
185
4.66
10
201
0.002
0.01
22-Oct-17
72
3.51
3
71
0.001
0.00
20-Nov-17
214
4.81
12
219
0.002
0.01
12-Dec-17
158
4.96
9
177
0.001
0.00
29-Dec-17
189
4.04
9
212
0.001
0.00
09-Jan-18
447
3.57
19
487
0.002
0.01
23-Jan-18
317
2.15
8
346
0.001
0.00
16-Feb-18
85
4.28
4
91
0.001
0.00
28-Feb-18
59
4.00
3
63
0.001
0.00
14-Mar-18
219
2.69
7
235
0.001
0.00
28-Mar-18
243
2.17
6
262
0.001
0.00
16-Apr-18
64
1.98
2
66
0.001
0.00
25-Apr-18
53
2.07
1
57
0.001
0.00
08-May-18
203
3.91
10
211
0.001
0.00
22-May-18
375
3.66
16
386
0.001
0.00
12-Jun-18
387
2.23
10
408
0.003
0.01
10-Ju1-18
327
1.44
6
343
0.001
0.00
26-Jul-18
252
2.60
8
258
0,001
0.00
09-Aug-18
503
2.68
16
520
0.001
0.01
22-Aug-18
417
3.14
16
422
0,001
0.01
13-Sep-18
407
1.78
9
349
0.001
0.00
27-Sep-18
318
2.48
9
280
0.001
0.00
12-Oct-18
188
1.59
4
170
0.001
0.00
30-Oct-18
28
0.95
0
19
0.001
0.00
15-Nov-18
332
2.45
10
332
0.007
0.03
29-Nov-18
308
4.18
15
310
0.001
0.00
12-Dec-18
311
3.28
12
318
0.001
0.00
27-Dec-18
322
2.09
8
285
0.001
0.00
09-Jan-19
210
1.36
3
205
0.001
0.00
27-Jan-19
331
1.41
6
364
0.001
0.00
12-Feb-19
83
1.24
1
92
0.001
0.00
25-Feb-19
134
0.68
1
140
0.001
0.00
12-Mar-19
324
3.31
13
350
0.001
0.00
11/4/2019
5 of 6
Dewberry

Table 8
FGD Wastewater Treatment System Influent and Effluent Conditions
Duke Energy Belews Creek
Et) Tank Effluent Biological System Effluent
.;, grwarding Pump Rate
(9pm)
350
Selenium Concentration
in E0 Tank Effluent
(mg/L)
1.93
Selenium Mass Flow
(Ib/day)
8
Selenium Reduction
System Pump Rate
(gpm)
354
Selenium Concentration
in Biological Selenium
Reduction System
Effluent (mg/L)
0.001
Selenium Mass Flow
(lb/day)
0.00
26-Mar-15
09-Apr-19
204
1.79
4
202
0.001
0.00
23-Apr-19
37
1.29
1
25
0.001
0.00
02-May-19
222
0.84
2
219
0.001
0.00
06-May-19
339
2.61
11
317
0.001
0.00
09-May-19
276
1.54
5
281
0.010
0.03
16-May-19
177
1.01
2
183
0.001
0.00
21-May-19
178
1.89
4
187
0.001
0.00
23-May-19
379
1.88
9
387
0.004
0.02
12-Jun-19
184
2.17
5
184
0.001
0.00
27-J u n-19
510
1.78
11
517
0.001
0.01
12-JuI-19
572
3.02
21
574
0.003
0.02
23-Jul-19
532
2.89
18
555
0.001
0.01
350
3.37
14
349
0.006
0.02
643
9.53
60
617
0.045
0.23
Notes.
The influent flow rates in this table were recorded from the forwarding pumps and the effluent flow rates were recorded from the selenium reduction system pumps.
Flow rates less than 10 gallons per minute (gpm) were converted to 0 gpm.
The analytical concentrations in the FGD wastewater treatment system influent were collected from Duke's sample location ID: EQ TANK EFF.
The analytical concentrations in the Biological System Effluent section of this table were collected from Duke's sample location ID: Bio Sys Eff.
The selenium mass flow (pounds per day) was calculated by multiplying the pump flow rates and the selenium concentrations.
Alstom System influent design criteria and performance guarantees from specification no. BCS-6202.04-00-0001 rev. 05 02 June 2006.
Influent conditions exceeding the Alstom system design criteria are highlighted in red.
The influent design criteria for selenium mass flow (Ib/d) was calculated by multiplying the influent design criteria for the average flow and average selenium concentration.
No exceedances of the Alstom system performance guarantee for effluent selenium concentration were observed in this dataset.
-' indicates no historical data was provided for a particular parameter on a particular date.
gpm indicates gallons per minute.
mg/L indicates milligrams per liter.
Ib/d indicates pounds per day.
11/4/2019 6 of 6
IP Dewberry.

Table 9
Comparison of FGD Wastewater Treatment System Average Loading Rates with Added FGD Leachate Stream Scenarios to Alstom System Design Criteria
Duke Energy Belews Creek
Historical Data from
FGD WW Treatment
System Forwarding
Pumps
FGD Bbwdowntfota i seleni m�
_ation and FGD Landtitt Leachate flow
24-hour storm and average selenium
Flow (gpm)
Historical FGD
System + FGD
Landfill Leachate
Influent Selenium Concentration (mg/L) Influent Selenium Mass Flow (Mid)
Wastewater System Historical Data from
Influent Design EG Tank Effluent
Criteria Sampling Location
Historical FGD
System + FGD
Landfill Leachate
Notes
The FGD wastewater treatment system influent flow rates in this table were recorded from the forwarding pumps
The analytical concentrations in the FGD wastewater treatment system are from Duke's sample location ID E0 TANK EFF.
FGD landfill leachate data from 2016 to 2018 (s4 data parts total) provided by die. Average selenium concentration 1 74 mg/L and average flow rate 40 gpm
FGD landfill leachate flow rate of 338 gpm from 25-year, 24-hour storm event provided by Duke.
The selenium mass (pounds per day) was calculated by multiplying the pump flow rates and the selenium concentrations
Wastewater System influent design criteria from Alstom specification no. BCS-6202. 04-00-0001 rev. 05 02 June 2006
Influent condtions exceeding the Alstom system design criteria are Nghlightnd in red.
The influent design cntena for selenium mass flow (Ib/d) was calculated by multiplying the influent design criteria for the average flow and average selenium concentraton.
gpm indicates gallons per minute.
mg/L indicates milligrams per Iter
Ib/d indicates pounds per day.
11/42019
1 011
Wastewater System Historical Data from Historical FGD Wastewater System
Influent Design FGD W W Treatment System + FGD Influent Design
Criteria System Influent Landfill Leachate Criteria
10 Dewberry

Table 10
Companson of Biological System Selenium Loading Rates to Literature Reference Values
Duke Energy Belews Creek
Selenium Loading Rate (mg/L/hr)
Historical Data from Historical Biological Historical Biological"''
Biological System System + FGD Landfill System +FGD Landfill Literature°'
Influent Leachate Leachate • Craig's Road Reference V
Landfill Leachate
1 44
003
0.72
0 23
3.03
0.11
151
006
0 76
023
3 03
0.12
045
07
2.3
1.4
4.6
27
Empty Bed Contact Time (hour)
Historical Biological Historical Biolocial
System • FGD Landfill Literatures-4
System «FGD Land011 Leachate « Craig's Road Reference V
Leachate Landfill Leachate
10
06
2.1
1.3
42
2.6
Notes
Average selenium loading rates for the biological system calculated using average flow rate calculated from the selenium reduction pump data and average selenium Concentration from the biological system influent (2010-2019 data)
Maximum selenium loading rates for the biological system calculated using maximum flow rate calculated from the selenium reduction pump data and maximum selenium concentration from the biological system influent (2010-2019 data).
Average selenium loading rates from the FGD 364 Craig's Road Landfill Leachates calculated using the average flow rates and average selenium concentrations.
Maximum selenium loading rates from the FGD and Craig's Road Landfill Leachates calculated using the average flow rates and the maximum selenium concentrations.
FGD landfill leachate data from 201610 2018 (six data points total) provided by Duke
Craig's Road landfill leachate data from 2016-2019 (seven data points total) provided by Duke.
This analysis assumes no selenium removal from the eachate streams in the physical chemical treatment process of the FGD wastewater treatment system
Empty Bed Contact Time (EBCT) calculated assuming the empty bed volume Is two -Thirds of the lank volume.
Average EBCT calculated using average flow rates from the selenium reduction pumps and of the landfill leachate streams
Maximum EBCT calculated using maximum flow rates from the selenium reduction pumps and the average flow rates from the landfill leachate streams
Influent conditions outside the range of the recommendations found in the literature are highlighted in red
Selenium loading rate Iterature reference value from DOI. 10. 1002Ad.10425.
Empty Bed Contact Time (EBCT) literature reference value from DOI' 10 2175/193864709793900654.
mg/Lbtr indicates milligrams per liter per hour
11/42019
1 of1
10
0.6
1.9
1.2
39
2.4
2-16
Dewberry

Dewberry -
MEMORANDUM
Date: July 11, 2019
To: Rick Harrison, Duke Energy
From: Leigh -Ann Dudley, Dewberry
Subject: Basis of Design for Landfill Leachate Treatment Evaluation
Background
Duke Energy (Duke) Belews Creek Steam Station (Belews Creek) currently generates leachate from two
onsite landfills: the FGD Gypsum Landfill and the Craig's Road Fly Ash Landfill. These streams are
discharged to a new lined retention pond. Recently, the retention pond effluent exceeded its permitted
effluent concentration of 85 pg/L for selenium. Duke identified the leachate wastestreams as the source of
the selenium and has initiated periodic pump and haul of the leachate streams to the existing onsite Flue -
Gas Desulfurization (FGD) treatment system. At this time, Duke wishes to evaluate the potential to treat
the leachate streams onsite using the existing treatment system. The FGD treatment system consists of
equalization, a physical chemical treatment system with reaction tanks and solids contact clarifiers,
followed by continuous backwash gravity filters. Following the physical/chemical system are heat
exchangers and a two -stage biological selenium reduction system. Effluent from the biological system is
discharged to an ultrafiltration system before being discharged to the lined retention pond. Solids from the
physical/chemical system and solids wasted from the biological selenium system are wasted to a sludge
holding tank which feeds plate -and -frame filter presses for solids dewatering. The process flow diagrams
provided to Dewberry which include equipment sizing specifications are provided in Attachment A.
The FGD system was designed to accept FGD blowdown alone; the design criteria did not include
treatment of other onsite wastestreams. However, capacity exists within the FGD system, and Duke has
retained Dewberry to evaluate the capacity of the existing FGD system to treat the additional hydraulic
and constituent loads from the FGD Landfill leachate and the Craig's Road landfill leachate. We
understand Duke is interested in considering the capacity of the treatment system for the following
scenarios:
• FGD blowdown + FGD Landfill leachate
• FGD blowdown + FGD Landfill leachate + Craig's Road Landfill leachate
For FGD blowdown, it is assumed this condition will be modeled as full baseline load with two coal units
operational. This memorandum serves to document the basis of design for the capacity evaluation for the
FGD treatment system with FGD Landfill Leachate. Depending on the findings of the FGD Landfill
Leachate, Duke will consider extending the evaluation with Craig's Road Landfill Leachate.
Memorandum I 1 of 6

Dewberry
MEMORANDUM
Influent and Operational Basis of Design
Duke provided the FGD system Design Data/Performance Guarantees document dated June 2, 2006
(Attachment B). This document included the design influent flow and contaminant loading conditions
summarized in Table 1.
Table 1. Influent Desi
Parameter
Flow (Normal
Operation)
Flow (48 hr Surge)
n Criteria
Summarized from Attachment B
Units Design Operating Range
gpm 600
gpm
`615 (estimated)
0 — 600 gpm
Total Suspended
Solids
OA
1.6
0.5 — 2.0
Total Dissolved mg/L 25,000
Solids
Chloride mg/L 12,000
Temperature °F 124
Nitrate ma/L < 200
0 — 35,000
0 — 12,000
115 — 130
Selenium (Se) mg/L 2.44 4.0 4.0
Ammonium (NH4) mg/L <_ 14 s 14 14
Antimony (Sb) pg/L 20.0 20.0 30.0
Arsenic (As) pg/L 220 490 1,160
Barium (Ba) pg/L 7,330 7,330 1,6490
Beryllium (Be) pg/L 2.00 13.0 52.0
Cadmium (Cd) pg/L 70.0 100 180
Chromium (Cr) pg/L 70.0 360 930
Cobalt (Co) pg/L 420 420 530
Copper (Cu) pg/L 500 pan 7Rn
Fluorine (F)
mg/L
39.5 39.5 53.7
Lead (Pb) pg/L 130 350 780
Manganese (Mn) pg/L 6,520 6,520 7,540
Mercury (Hg) pg/L 30.0 300 300
Molybdenum (Mo) pg/L 410 410 580
Nickel (Ni) pg/L 740 760 930
Silver (Ag) pg/L 60.0 60.0 70.0
Thallium (TI) pg/L 200 200 210
Vanadium (V) pg/L 190 560 1,410
Zinc (Zn) pg/L 340 900 1,760
*Duke expects the second purge line to have the same flow rate as the existing and directed Dewberry to
change the flow from 720 to 615 gpm
Dewberry understands that when each power generation unit is running, it generates approximately 300
gpm each of FGD blowdown wastewater. The blowdown, or purge, is sent to the FGD wastewater plant
intermittently. Generally, there are 6 hours of purge and 4 hours off. This varies depending on how much
power is being generated and the quality of the coal being used as the blowdown is controlled by the
density of the scrubber water and chloride concentration.
Dewberry assumes both leachate streams will be discharged into the filtrate sump. The filtrate sump also
collects the backwash from the continuously backwashing gravity filters, ultrafilter backwash, strainer
backwash, and filter press filtrate. We understand the flow rates for individual backwash and filtrate
streams are not metered, but we assume they are captured in the flow data provided for the forwarding
Memorandum 1 2 of 6

tiP Dewberry -
MEMORANDUM
pumps. Dewberry will consider the hydraulic capacity of the filtrate sump and filtrate sump pumps in the
evaluation.
We understand the EQ tanks have a minimum operating level of 10 feet due to the configuration of the
tank mixer. Under normal operating conditions the EQ Tank and Maintenance Tank are both used as EQ
tanks and are operated in parallel. Operators try to maintain the level in these tanks below 26 feet. When
the tank levels exceed 26 feet, the operators minimize flow into the tanks by stopping processes that
generate recycle streams such as filter press filtrate. The tanks overflow to the filtrate sump at a water
level of 36 feet. When less wastewater is generated overnight or when operators anticipate a plant shut
down, wastewater is accumulated in the EQ tanks in order to maintain wastewater to feed the treatment
system. Dewberry will consider the hydraulic capacity of the EQ tanks in the evaluation.
Dewberry understands typically one solids contact clarifier is operated at a time and each clarifier is
intended to be 100% redundant. Dewberry understands the preference is to maintain 100% redundancy
in the solids contact clarifiers.
Dewberry understands from the June 21, 2019 site visit that the heat exchangers are currently a limiting
factor. There are two heat exchangers. Each heat exchanger is designed for 600 gpm, however, when
Duke operates close to 600 gpm the heat exchanger performance quickly declines with respect to flow
and heat capacity due to the suspended solids present in the FGD blowdown. Dewberry understands that
since Duke initiated pump and haul operations of the FGD landfill leachate, the leachate provides some
cooling and at times has been sufficient to reduce the combined water temperature below the ABMetTM
target operating temperature of 95°F, in which case Duke can bypass the heat exchangers. Dewberry will
consider the hydraulic capacity of the heat exchangers in the capacity evaluation. Dewberry expects the
leachate to have a positive impact on influent temperature, which has been observed during the leachate
pump and haul, and therefore will not model temperature for the combined discharges.
The first and second -stage selenium reduction systems each contain eight trains. Dewberry will evaluate
the hydraulic capacity of the selenium reduction system and will evaluate constituent loading capacity
with specific focus on selenium and nitrate.
Dewberry understands the ultrafilter system has four ultrafilter banks. The ultrafilters operate in a rotation
with three in service and one in backwash cycle. A filter runs for 15 minutes and then the backwash cycle
is five minutes. Backwash flow is 600 — 750 gpm for one minute of the five minute backwash cycle. The
operational flow rates to be used as the basis for the hydraulic capacity analysis for the ultrafilters are
included in Attachment D.
Dewberry understands the filter presses represent a solids and hydraulic limitation. Currently, Duke does
not condition solids and indicated solids settle and dewater well. Operators indicated when both power
generation units are running, they are near capacity with the four filter presses. Sources of solids include
the solids in the FGD wastewater and solids generated by the precipitation and biological process. Higher
than typical solids concentrations in the FGD wastewater cause capacity limitations in the filter presses.
Dewberry will evaluate the hydraulic capacity of the presses, but will focus on the additional solids loading
on the treatment system provided by the additional treatment of the FGD landfill leachate.
FGD Blowdown Basis of Design
Duke provided FGD blowdown data from 1/11/2017 — 5/6/2019. Dewberry analyzed the data for periods
when two coal units were operational. Table 2 summarizes the FGD blowdown data during periods when
two coal units were operational and that will be used for the baseline influent for the capacity evaluation.
Memorandum 13 of 6

Dewberry
Table 2. Historical FGD Blowdown with Two Coal Units Operational
Parameter Units
FGD Blowdown
Avera•e Maxi u
Flow
Arsenic
Mercury
Nitrate/Nitrite
Total Suspended Solids
Selenium (dissolved)
Selenium (total)
Methylseleninic acid
Selenite (IV)
Selenium (unknown speciation)
Selenate (VI)
Selenocyanate
Selenomethionine
Chloride
Sulfate
Boron
Cadmium
Chromium
Copper
Nickel
Zinc
Bromine
Total Dissolved Solids
gpd
mg/I
pg/I
mg/I
mg/I
pg/I
pg/I
pg/I
pg/I
pg/I
pg/I
pg/I
pg/1
mg/I
mg/I
mg/I
mg/I
mg/I
mg/1
mg/I
mg/I
mg/I
mg/I
417,792
0.63
269
24
No Data
322
4,139
6.7
362
8.8
85
4.7
3.4
9,576
1.359
279
0.01
0.56
0.39
0.51
0.77
128
24,290
561,805
1.30
426
45
No Data
784
6,070
17
2,000
67
157
36
3.5
15,770
1,610
416
0.02
0.92
0.57
1.1
1.2
196
39,000
MEMORANDUM
Leachate Basis of Design
Duke provided constituent data for the FGD Gypsum Landfill leachate and Craig's Road Landfill leachate.
For The FGD Gypsum Landfill, Duke provided semiannual data from 2016-2018, six data points in total.
For the Craig's Road Landfill leachate, Duke provided semiannual data from 2016 — 2019, totaling seven
data points. Table 3 summarizes the average and maximum flow and constituent data for each landfill
leachate. The average flow data were provided by Duke during proposal development. For the capacity
evaluation, Dewberry will evaluate the capacity based on average flow with maximum concentration.
From communications with Duke, Dewberry understands the FGD Landfill Leachate can have a maximum
instantaneous flow of 120 gpm.
Memorandum 14 of 6

Dewberry
MEMORANDUM
Table 3. Landfill Leachate Data
Parameter Units
FGD Landfill Leachate Craig's Road Landfill Leachate
Average Maximum Average Maximum
Flow
pH
Total Dissolved Solids
Nitrate
Chloride
Sulfate
Fluoride
Arsenic
Barium
Cadmium
Chromium
Copper
Iron
Lead
Nickel
Selenium
Mercury
gpm
s.u.
mg/I
mg/I
mg/I
mg/I
mg/I
pg/I
pg/I
pg/I
pg/I
pg/l
mg/I
pg/I
pg/I
mg/1
pg/I
40
6.58
2,104
0.813
71.1
1,588
1.55
<1.25
18
<1.25
<2.50
<2.50
No Data
<1.25
<2.50
1.74
<0.03
Not Provided
6.85
2,660
1.12
104
1,730
2.57
<5.0
23
<5.00
<2.50
<2.50
30
5.11
2,960
25.1
344
1,815
<2.00
25
29
3.49
<2.50
3.12
0.441
<5.00 5.2
<2.50 90
2.25 0.089
<0.03 <0.03
Not Provided
7.55
3,940
39.2
562
2,410
<2.50
46
39
5.74
<2 50
6.85
1.820
7.8
156
0.118
0.06
Effluent Basis of Design
Dewberry understands the FGD treatment system effluent measured at the ultrafilter effluent is subject to
NPDES limits as Outfall 002 in NC0024406 (Attachment C). Table 4 summarizes the effluent limits and
the effluent performance guarantees provided by the vendor for the FGD treatment system.
Table 4. Effluent Limit and Effluent Performance Guarantees by Alstom
Parameter Units
NC0024406
Outfall 002
Sampling
Frequency
NC0024406 Outfall 002
Limit
Monthly Daily
Average Maximum
FGD Treatment System
Effluent Performance
Guarantee
Normal Surge
Operating Operating
Conditions Conditions
Flow
Total Arsenic
Total Mercury
Total Selenium
Nitrate/nitrite as N
Oil and Grease
Total Suspended
Solids
Chloride'
pH
gpm Daily
pg/L Quarterly
Monitor and Report
8.0 11
ng/L Quarterly 356 788
pg/L Quarterly 12 23
mg/L Quarterly 4.4 17
mg/L Quarterly 15 20
mg/L Quarterly 30 50 50
mg/L Not included in permit 12,000 14,000
s.u. Not included in permit 5.3 - 9.0
600 720
Not included
1,000
100
Not included
Not included
100
Memorandum 15 of 6

Y Dewberry
MEMORANDUM
1 Dewberry understands the chloride effluent performance guarantee was based on meeting a maximum
chloride concentration for discharge to the wetlands. Since the wetlands are no longer in service and
there is not an Outfall 002 chloride limit, chloride will not be considered further in our capacity evaluation.
As part of the study, Dewberry will evaluate if the effluent from the FGD treatment system will be subject
to the same Outfall 002 limits if leachate is treated through the FGD treatment system. Dewberry
anticipates using the ELG's Combined Waste Stream formula for determining discharge limits.
Attachments:
Attachment A: Process Flow Diagrams
Attachment B: Design Data/Performance Guarantees dated June 2, 2006
Attachment C: Outfall 002 Limits extracted from NC0024406 dated March 25, 2019
Attachment D: M7 Operating Conditions at Maximum and Minimum Treatment Rates
CC:
Name
Organization
Derek Henderson
Travis Thornton
Ed Byers
Ryan Ames
Katie Jones
Duke Energy
Duke Energy
Duke Energy
Dewberry
Dewberry
Memorandum 16 of 6

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, 7

Attachment B
WASTEWATER TREATMENT
SPECIFICATION NO.:
AL
ST
O
■ ' M ■
SYSTEM
REV 0502.04-00-0001
DATE: 02 JUNE 2006
PAGE 28 OF 60
ATTACHMENT A: DESIGN DATA / PERFORMANCE GUARANTEES
Application Data:
Service
FGD System Purge Stream
Quantity of Systems Required
One (1)
System Operating Frequency
Continuous or Intermittent
System Location
Indoors/Outdoors (Building by Supplier)
FGD System Purge Stream:
Stream Characteristic
Units
Design Amount
Operation
Range
Notes
Influent (Maximum under
NORMAL operation)
gpm
600
0 — 600
Influent (Maximum under
SURGE condition)
gpm
720
(estimated)
Event duration is
48 hours. For
design purposes,
assume this event
only occurs once
every three years.
Influent (NORMAL
operation)
lb./hr.
307,459
0 — 307,459
Water
wt %
98.4
98.0 — 99.5
Total Suspended Solids
wt %
1.6
0.5 — 2.0
Total Dissolved Solids
mg/I
25,000
0 — 35,000
Stream Specific Gravity
-
1.028
1.020 — 1.050
Solids Specific Gravity
-
2.4
2.2 — 2.5
pH
-
5.6
5-7
Temperature
°F
124
115 — 130
Oil and Grease
mg/I
< 1.0
< 1.0
Nitrate
mg/I
200 max.
Expected
FGD Purge Stream Suspended Solids Composition:
\\Nt000101\Fgdshared\TS&C Central Engineering\Programs\Wastewater Treatment\Belews Creek\Drawings And Manuals\BCSS VWVf
Technical Specification.Docx

WASTEWATER TREATMENT
SPECIFICATION NO.:
A
L STO
11
SYSTEM
BCS-6202.04-00-0001
REV. 05
DATE: 02 JUNE 2006
PAGE 29 OF 60
ATTACHMENT A: DESIGN DATA / PERFORMANCE GUARANTEES
Constituent
Units
Design Amount
(Normal Operation)
Operation
Range
Notes
CaSO4 • 2H20
wt %
49.70
30 - 55
CaSO3 • %H20
wt %
0.19
0 — 1
CaCO3
wt%
4.04
0-10
CaF2
wt%
0.42
0-2
Flyash
wt %
6.82
0 — 15
Inerts
wt %
38.7
0 — 55
FGD Purge Stream Dissolved Solids Composition:
Constituent
Units
Design Amount
(Normal Operation)
Operation
Range
Notes
Chloride (aq), Maximum
mg/I
12,000
0 — 12,000
Chloride (aq), Maximum
under SURGE Conditions
mg/I
14,000
estimated
Event duration is 48
hours. For design
purposes, assume this
event only occurs once
every three years.
Dibasic Acid (DBA)
Mixture (aq)
mg/I
0
0 — 1,000
Range conditions could
occur several times per
year for several days
Predicted Particle Size Distribution of FGD Purge Stream Solids:
w
wt%
Size (microns)
Notes
100%
less than 10
94%
less than 5
27%
less than 1
Typical Organic Acid Mixture to the FGD System:
Constituent
Units
Amount
Operation
Range
Notes
Succinic Acid
wt%
18 — 28
Glutaric Acid
wt%
51 — 61
Adipic Acid
wt%
15 — 25
Typical Design and Maximum of Dissolved Constituents in FGD Wastewater Before Solids Removal:
\\Nt000101\Fgdshared\TS&C Central Engineering\Programs\Wastewater Treatment\Belews Creek\Drawings And Manuals\BCSS VWVr
Technical Specification.Docx

Attachment 8
WASTEWATER TREATMENT
SPECIFICATION NO.:
AL
STO
" M ■
SYSTEM
REV 0502.04-00-0001
DATE: 02 JUNE 2006
PAGE 30 OF 60
ATTACHMENT A: DESIGN DATA / PERFORMANCE GUARANTEES
Elements in
Wastewater
Minimum Estimated
Concentration in
Wastewater
(ppm)
Average Estimated
Concentration in
Wastewater
(ppm)
Maximum Estimated
Concentration in
Wastewater
(ppm)
Ammonium (NH4)
<_ 14
5 14
14
Antimony (Sb)
0.02
0.02
0.03
Arsenic (As)
0.22
0.49
1.16
Barium (Ba)
7.33
7.33
16.49
Beryllium (Be)
0.002
0.013
0.052
Cadmium (Cd)
0.07
0.10
0.18
Chromium (Cr)
0.07
0.36
0.93
Cobalt (Co)
0.42
0.42
0.53
Copper (Cu)
0.50
0.54
0.76
Fluorine (F)
39.5
39.5
53.7
Lead (Pb)
0.13
0.35
0.78
Manganese (Mn)
6.52
6.52
7.54
Mercury (Hg)
0.03
0.30
0.30
Molybdenum (Mo)
0.41
0.41
0.58
Nickel (Ni)
0.74
0.76
0.93
Selenium (Se)
2.44
4.00
4.00
Silver (Ag)
0.06
0.06
0.07
Thallium (TI)
0.20
0.20
0.21
Vanadium (V)
0.19
0.56
1.41
Zinc (Zn)
0.34
0.90
1.76
\\Nt000101\Fgdshared\TS&C Central Engineering\Programs\Wastewater Treatment\Belews Creek\Drawings And Manuals\BCSS WVVT
Technical Specification.Docx

Attachmen
WASTEWATER TREATMENT
SPECIFICATION NO.:
A
L ST
�,
"M
SYSTEM
BCS-6202.04-00-0001
REV. 05
DATE: 02 JUNE 2006
PAGE 31 OF 60
Performance Guarantees for Wastewater Treatment System:
Description
Quantity
Units
Test Method
Notes
pH (Effluent)
5.3 — 9.0
EPA 150.1
Inlet to Wetlands
Supply Tank
(Prior to Dilution)
TSS (Effluent)
50 max
mg/I
EPA 160.3
NORMAL
Operation
Inlet to Wetlands
Supply Tank
(Prior to Dilution)
TSS (Effluent)
100 max
mg/I
EPA 160.3
For SURGE
Condition Only
Inlet to Wetlands
Supply Tank
(Prior to Dilution)
Inlet to Wetlands
Supply Tank
(Prior to Dilution)
Chloride (Effluent)
12,000 max
Normal
14,000 max
Surge
mg/I
EPA 300.0
Selenium (Se)
0.10
mg/I
EPA 200.8 —
ICP/MS;
Detection Limit
1.2 ppb
EPA 200.7 —
ICP;
Detection Limit
36 ppb
Inlet to Wetlands
Supply Tank
(Prior to Dilution)
Mercury (Hg)
0.001
mg/I
EPA 245.1 —
Graphite
Furnace/AA;
Detection Limit
0.07 ppb
Inlet to Wetlands
Supply Tank
(Prior to Dilution)
Maximum sound pressure
level (ref. 0.0002 microbar)
at three (3) feet from all
equipment provided based
on a free field condition
85
dB(A)
Availability
100
%
NOTE: Final diluted stream to the wetlands shall be at maximum temperature of 108°F or less. Dilution
water (max 1,200 gpm available) at a temperature range of 35 - 92°F may be used to dilute chloride
concentration of the 600 gpm of wastewater treatment system effluent from a concentration range of 0 -
12,000 ppm to a final value for delivery to the wetlands of 4,000 ppm. Any additional cooling beyond that
flow which is required for dilution of chlorides shall be accomplished without increasing total wastewater flow
to the wetlands. A minimum dilution flow of 300 gpm may be assumed based on 600 gpm purge flow, for a
total flow to the wetlands of 900 gpm.
\\Nt000101\Fgdshared\TS&C Central Engineering\Programs\Wastewater Treatment\Belews Creek\Drawings And Manuals\BCSS VVVVT
Technical Specification.Docx

Attachment C
Extracted from NC0024406 Dated March 15, 2019
Permit NC0024406
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Internal
Outfall 002)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge from Internal Outfall 002 (treated FGD wet scrubber
wastewater to ash settling basin). Such discharges shall be limited and monitored' by the Permittee
as specified below:
PARAMETER
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample Location
Flow, MGD
Weekly
Pump Logs or similar
readings
Effluent
Total Arsenic
8.0 pg1L2
11.0 pg/L2
Quarterly
Grab
Effluent
Total Mercury3
356.0 ng/L2
788.0 ng/L2
Quarterly
Grab
Effluent
Total Selenium
12.0 pgIL2
23.0 pg/L2
Quarterly
Grab
Effluent
Nitrate/nitrite as N
4.4 mg/L2
17.0 mg/L2
Quarterly
Grab
Effluent
Oil and Grease
15.0 mg/L
20.0 mglL
Quarterly
Grab
Effluent
Total Suspended Solids
30.0 mg/L
50.0 mg/L
Quarterly
Grab
Effluent
Notes:
1. Please See Special Condition A. (23.).
2. In accord with the Steam Electric Effluent Limitations Guidelines for FGD wastewater (40 C.F.R.
423), these limits shall become effective on November 1, 2020. This permit may be reopened and
modified if changes are made to 40 C.F.R. 423.
3. The facility shall use EPA method 1631E.
All flows shall be reported on monthly DMRs, should no flow occur during a given month, the words
"No Flow" shall be clearly written on the front of the DMR. All samples shall be of a representative
discharge.
Page 5 of 23

Attachment D
M7 Operating Conditions at Maximum and Minimum Treatment Rates
Project Name: Belews Creek Steam Station
Evoqua Project No.: 2034-000768
BMcD Project 888873
Contract Name: FGD Wastewater Treatment UBrafiltration System
Contract No: 5.3210
821/17
Belews Creek Steam Station Customer Parameter Sheet Revision 3
Plant Capacity
Operation
Maximum Operation
Normal Operation
Occasional Operation e
System Type
4 X CPII MR1,30 (L4ON)
4 X CPII MR1,30 (L4ON)
3 X CPII MR1,30 (L4ON)
Design Capacity (MGD)
0.92 MGD
0.58 MGD
0.58 MGD
Unit Operation
N+2 w/CR
N+2
N+2 w/CR
Filtrate Flow
Maximum Inst Design Flow Design Capacity Setpoint per Unit (gpm)
331 gpm
242 gpm
413 gpm
Minimum Inst Design Flow Setpoint per Unit (gpm)
232 gpm
170 gpm
289 gpm
Feed Water Requirements
Operating pH Range
6 to 9
Operating Temperature Range
15.6 - 35 deg C / 60 - 95 deg F
Backwash
Backwash Interval (min)
20 min
Backwash Duration (min)
2.08 min
TMP increase during filtration cycle to backwash
1 psi
Resistance increase during filtration cycle to backwash
0.5
Aeration Air Flow (SCFM/module)
5.9 SCFM/module
Total Aeration Air Flow (SCFM)
177 SCFM
Aeration, ADBW and Sweeping Flow (gpm)
396 gpm
Sweeping with Aeration Flow (gpm)
396 gpm
Sweeping Flow (gpm)
726 gpm
Lumen Fill Flow (gpm)
396 gpm
Waste Volume per Backwash (gal)
853 gallons
Air Hold Test (ANT)
AHT Interval (hrs)
24 hours
AHT Duration (min)
15 min
AHT Regulator Setpoint (psi)
15 psi
Integrity System Volume (gal)
114 gallons
General Clean In Place (CIP)
CIP Interval
21 operational days per unit, not to exceed 42 calendar days
CIP Regime Order
Acid followed by Chlorine
Chemical Cleaning Volume (gal)
741 gallons
CIP Recirculation Flow (gpm/module)
13.2 gpm/module
CIP Recirculation Flow (gpm)
396 gpm
Each CIP or MW Waste Volume (gal)
3587 gallons
Acid Clean In Place (A-CIP)
Acid CIP - Tank Solution Temperature
30 °C
Acid CIP Duration (min)
180 min
Acid CIP Solution Cleaning Concentration
50% Citric Acid bulk dosed to 1% cleaning solution + 31.45% Hydrochloric Acid bulk dosed to 0.06%
cleaning solution (pH of 2.0)
Estimated Acid Chemical Volume Required (gal)
12.04 gallons - 50% Citric Acid + 1.22 gallons - 31.45% Hydrochloric Acid, dosed to pH of 2.0
Chlorine Clean In Place (C-CIP)
Chlorine CIP - Tank Solution Temperature
20 °C
Chlorine CIP Duration (min)
180 min
Chlorine CIP Solution Cleaning Concentration
12.5% Sodium Hypochlorite bulk dosed to 500 ppm, 350 ppm free chlorine
Estimated Chlorine Chemical Volume Required (gal)
2.48 gallons - 12.5% Sodium Hypochlorite
Acid Maintenance Wash (A-MW)
Interval and Temperature
48 operational hours, not to exceed 96 calendar hours, ambient temperature
Acid MW Duration (min)
45 min
Acid MW Solution Cleaning Concentration
31.45% Hydrochloric Acid bulk dosed to 0.06% cleaning solution (pH of 2.2)
Estimated Acid Chemical Volume Required (gal)
1.22 gallons - 31.45% Hydrochloric Acid
Chlorine Maintenance Wash (C-MW)
Interval and Temperature
48 operational hours, not to exceed 96 calendar hours, ambient temperature
Chlorine MW Duration (min)
45 min
Chlorine MW Solution Cleaning Concentration
12.5% Sodium Hypochlorite bulk dosed to 100 ppm, 70 ppm free chlorine
Estimated Chlorine Chemical Volume Required (gal)
0.5 gallons - 12.5% Sodium Hypochlorite
Notes
Operational time includes all time except time spent in standby, shutdown, waiting or CIP Halt.
* Occasional operation should only be used when CIPs, MWs or maintenance events are performed.

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
June 18, 2020
Mr. Michael Lanning, General Manager III - Regulated Stations
Belews Creek Steam Station
Duke Energy Carolinas, LLC
3195 Pine Hall Road
Belews Creek, North Carolina 27009
SUBJECT: Wastewater Pump & Haul Permit Application
Belews Creek Steam Station
Stokes County
Permit No. WQ0041747
Dear Mr. Lanning:
In accordance with your permit application received June 15, 2020, we are forwarding herewith
Permit No. WQ0041747, dated June 18, 2020, to Duke Energy Carolinas LLC for the time -limited
operation of a domestic wastewater pump and haul operation. This permit shall become effective
August 18, 2020 and will expire on February 14, 2021; shall void previously issued Permit
No. WQ0041493 which will expire on August 17, 2020; and shall be subject to the conditions
and limitations as specified therein. This cover letter shall be considered a part of this permit
and is therefore incorporated therein by reference.
Please pay particular attention to Permit Condition 13, which requires accurate record keeping and
reporting. Also note Permit Condition 18, which requires that the facilities associated with the
pump and haul activities be inspected and pumped as often as necessary to prevent any
malfunctions, overflows, or nuisances.
Permission is hereby granted to Duke Energy Carolinas, LLC for the operation of:
• A domestic wastewater pump and haul operation for the sanitary lagoon located at the
Belews Creek Steam to allow for design and construction of upgrades to the system. The
upgrade will be mechanical filtration. The sanitary lagoon will be permitted as a new
internal outfall in the NPDES permit.
• The anticipated flow for this pump and haul operation is greater than 10,000 gallons per
day gallons per day of domestic wastewater generated in the station administration building.
GQE
ai€m«w... ai awn f"
North Carolina Department of Environmental Quality I Division of Water Resources
Winston Salem Regional Office 450 West Hanes Mill Road, Suite 300 I Winston-Salem. North Carolina 27105
336.776.9800

• Please notify this office when the modification of the septic system is complete and the
pump and haul operation is no longer necessary.
The wastewater collected by this system shall be pumped by Shamrock Environmental
Corporation for treatment or discharge into the City of Eden, Mebane Bridge Wastewater
Treatment Plant (WWTP) for final treatment.
This permit shall become voidable unless the agreements between Shamrock Environmental
Corporation, Duke Energy Carolinas, LLC, and the City of Eden, Mebane Bridge WWTP for the
pumping, hauling and/or final treatment of wastewater are in full force and effect.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request must be in the form of a written petition, conforming to Chapter 150B of
North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail
Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be
final and binding.
If you have any questions regarding this permit or require any additional information, please
contact Jim Gonsiewski or me by phone at [phone].
Sincerely,
r—DocuSIgnod by:
'r S jer
`-145649E225C94EA...
for S. Daniel Smith, Director
Division of Water Resources
by Lon T. Snider
Regional Supervisor, Water Quality Regional Operations
Division of Water Resources
cc: Joyce Dishmon — Duke Energy (Electronic Copy)
Stokes County Health Department (Electronic Copy)
WSRO Electronic Files
Laserfiche Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
DOMESTIC WASTEWATER PUMP & HAUL PERMIT
PERMIT No. WQ0041747
This permit shall be effective August 18, 2020, will expire on February 14, 2021, and
shall be subject to the following specified conditions and limitations:
1. This permit shall become voidable unless the subject pump and haul activities are
carried out in a manner that has been approved by this Division.
2. This permit is effective only with respect to the nature and volume of wastes described
in the application dated June 10, 2020 and other supporting data.
3. The facilities shall be properly maintained and operated at all times.
4. This permit is NOT transferable. In the event that there is a desire for the facilities
to change ownership, or there is a name change of the Permittee, a formal request
must be submitted to the Division.
5. No type, kind or quantity of wastewater other than the pumped and hauled wastewater
from Duke Energy Carolinas, LLC shall be included in these pump and haul activities.
6. This permit shall become voidable unless the agreements between Shamrock
Environmental Corporation, Duke Energy Carolinas, LLC, and the City of Eden,
Mebane Bridge WWTP for the pumping, hauling and/or final treatment of wastewater
are in full force and effect.
7. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, Duke Energy Carolinas, LLC shall cease operation of all pump
and haul activities and take such immediate corrective actions as may be required by
this Division.
8. The wastewater collected by this system shall be properly treated in the Shamrock
Environmental Corporation treatment facility, Permit Number NCS-00790 or in the
City of Eden, Mebane Bridge WWTP (NC0025071) for final treatment and disposal.
9. Duke Energy Carolinas, LLC is liable for any damages caused by a spill or failure of
the pump and haul operations.

10. Adequate inspection, maintenance, and cleaning shall be provided by Duke Energy
Carolinas, LLC to ensure proper operation of the subject facilities.
11. Duke Energy Carolinas, LLC or its designee, shall inspect the pump and haul
collection facilities to prevent malfunctions and deterioration, operator errors, and
discharges that may cause or lead to the release of wastes to the environment, a threat
to human health, or a nuisance.
12. Any duly authorized officer, employee, or representative of the Division of Water
Resources may, upon presentation of credentials, enter and inspect any property,
premises, or place on or related to the pump and haul collection facilities at any
reasonable time for the purpose of determining compliance with the Division's
approval; may inspect or copy any records that must be maintained under the terms
and conditions of this permit; and may obtain samples.
13. An accurate record of the pump and haul activities must be maintained by Duke
Energy Carolinas, LLC indicating:
• Date and times wastewater is removed from the facility
• Name of contract hauler
• Name of facility receiving wastewater
• Volume of wastewater removed
• An inspection log including the date and time of inspections, observations made,
and any maintenance, repairs, or corrective actions taken by the Permittee.
These records shall be submitted quarterly by the following Wednesday to the Water Quality
Regional Operations Supervisor, at address 450 West Hanes Mill Road, Suite 300, Winston-
Salem, NC 27105
14. Failure to abide by the conditions and limitations contained in this permit may subject
Duke Energy Carolinas, LLC to appropriate enforcement actions available to the
Division.
15. The granting of this permit does not preclude Duke Energy Carolinas, LLC from
complying with any and all statutes, rules, regulations, or ordinances, which may be
imposed by other government agencies (local, state, and federal), which have
jurisdiction.
16. Noncompliance Notification: Duke Energy Carolinas, LLC shall report by
telephone to the Winston-Salem Regional Office, telephone no. [phone], as
soon as possible, but in no case more than twenty-four (24) hours or on the next
working day following the occurrence or first knowledge of the occurrence of any of
the following:
a. Any process unit failure, due to known or unknown reasons, that render the
facility incapable of adequate wastewater storage and/or treatment such as
failures of tanks, piping, pumps, etc.

b. Any failure of a pumping station, sewer line, etc., resulting in a spill or by-pass
directly to receiving waters without treatment of all or any portion of the
influent to such station or facility.
17. Persons reporting such occurrences by telephone shall also file a written report in
letter form within five (5) business days following first knowledge of the occurrence.
This report must outline the actions taken or proposed to be taken to ensure that the
problem does not recur.
18. The facilities associated with the pump and haul activities shall be inspected and
pumped as often as necessary to prevent malfunctions, overflows, or nuisances.
19. Should ownership or financial circumstances change during this permit, immediate
notification should be made to the regional office.
20. When these pump and haul activities are no longer necessary, please send written
notification to:
Water Quality Regional Supervisor
Winston-Salem Regional Office
NCDEQ-DWR
450 W. Hanes Mill Rd, Suite 300
Winston-Salem, NC 27105
21. Sixty (60) days prior to the expiration of this permit (i.e. December 16, 2020), a
status report of the permanent wastewater treatment system shall be submitted to the
Winston-Salem Regional Office. This report shall include:
i.Anticipated flows; and
ii.Proposed start-up date; or
iii.Other alternatives being considered for permanent or temporary treatment of
wastewater.
Permit issued this the 18th day of June 2020, with a Permit Effective date of August 18, 2020.
CDocuSiprnd by:
L-#A. t SMits
145B49E225C94EA...
for S. Daniel Smith, Director
Division of Water Resources
by Lon T. Snider
Regional Supervisor, Water Quality Regional Operations
Division of Water Resources

(I DUKE
ENERGY,
August 20, 2019
Mr. Lon Snider
NC DWR
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27415
Subject: Duke Energy Belews Creek Steam Station
Pump and Haul Permit Application
Stokes County
Dear Mr. Snider:
Belews Creek Steam Station
Duke Energy Carolinas
3195 Pine Hall Road
Belews Creek, NC 27009
Pursuant to 15A NCAC 02T 0.0204 Duke Energy Carolinas LLC (Duke Energy) is requesting a
permit to pump and haul domestic wastewater from Belews Creek Steam Station to Shamrock
Environmental to allow Duke Energy additional time to complete design and installation of
upgrade to our sanitary lagoon. The request is for one year.
The submittal package includes the following:
I. Pump and Haul Application P&H 1-16
2. Letter and permit from Shamrock Environmental
3. Check for permitting fee - $1310.00
Belews Creek began evaluating the sanitary lagoon treatment system in preparation for the
issuance of the new NPDES permit. The new permit included an internal outfall 009 for this
system. The evaluation revealed concerns with meeting BOD and TSS permit limits. NC DEQ
provided Pump and Haul Permit #WQ0040669.
Hazen and Sawyer, Hazen, was contracted to evaluate treatment options for the sanitary lagoon
treatment system to reduce BOD and TSS. It was determined that algae growth in the lagoon and
chlorination of the algae is affecting both the BOD and TSS. Hazen evaluated the use of bag and
cartridge filters using various micron filters to remove the algae. It has been determined that
cartridge filters would remove the algae but at a reduced flow rate and cost.
Hazen presented their findings to Belews Creek on June 17, 2019. Their recommendation included
evaluation of sand filters as a treatment option. Belews Creek requested that Hazen also evaluate
additional alternative treatment options to include installation of a septic and spray irrigation
system. Hazen advised that the evaluations requested would take until September 2019 to

complete. Upon completion of evaluation of treatment options Duke Energy will require the
additional time for potential permitting, design, and installation. Thus, Duke Energy has requested
a permit duration of one year for this permit.
Should you have any questions regarding this submittal or require additional information, please
contact Joyce Dishmon at 336-623-0238 or [e-mail].
Reginald D. Anderson
General Manager III, Regulated Stations
Belews Creek Steam Station
Power Generation Carolinas East
cc: Brenda Johnson, Environmental Field Support
Joyce Dishmon/Filenet

DWR
Division of Water Resources
State of North Carolina
Department of Environmental Quality
Division of Water Resources
15A NCAC 02T .0200 — WASTEWATER PUMP AND HAUL SYSTEMS
INSTRUCTIONS FOR FORM P&H 01-16 & SUPPORTING DOCUMENTATION
Documents shall be prepared in accordance with 15A NCAC 02T .0100 15A NCAC 02T .0200, and Division policies. Failure to submit
all required items will necessitate additional processing and review time. For more information, visit the Wastewater Branch's
website or contact the Regional Office serving your county.
General — This permit application applies to all pump and haul activities of wastewater under the authority of the Division on Water
Resources. Permit coverage is required for the system producing the wastewater. This permit does not apply to the transport of
animal waste from an animal waste management systems, not the transport of wastewater residuals or biosolids.
NOTE: Pump and haul permits are not acceptable long term domestic wastewater treatment alternatives and shall only be issued
in cases of environmental emergencies, nuisance conditions, health problems, or for unavoidable delays in construction of system
previously permitted by the Division.
The Applicant shall submit one original and one copy of the application and supporting documentation.
A. Pre -submittal Contact & Cover Letter
® Contact the appropriate Regional Office prior to submittal
® Submit a cover letter explaining the circumstances associated with this pump and haul permit request
B. Application Fee (Domestic Wastewater Only)
® Submit a check made payable to: North Carolina Department of Environmental Quality (NCDEQ)
The appropriate application fee is: $810.00 for flows < 10,000 GPD and $1,310.00 for flows > 10,000 GPD
C. Wastewater Pump and Haul (FORM: P&H 01-16) Application:
® Submit the completed and appropriately executed Wastewater Pump and Haul (FORM: P&H 01-16) application. Any
unauthorized content changes to this form shall result in the application package being returned. If necessary for clarity or
due to space restrictions, attachments to the application may be made, as long as the attachments are numbered to
correspond to the section and item to which they refer
D. Receiving Facility Letter:
® Submit a letter from the owner/authority of the receiving wastewater treatment facility, as required by 15A NCAC 02T .0204
(b), stating that the pumped and hauled wastewater will be accepted and specifying the volume and type of wastewater that
wilt be accepted. The letter should be signed by an authorized signing official in accordance with 1SA NCAC 02T .0106(bl
E. Contract Hauler Letter:
® Submit a fetter from the hauler stating their capability and willingness to perform the pump and haul activity
® Letter shall include: Owner/Company Name, Contact Information, & Hauling Volume of Vehicle(s)
F. Certifications:
® The Applicant's Certification on Page 4 of the application shall be signed in accordance with 15A NCAC 02T .0106(b). Per 15A
NCAC 02T .0106(c), an alternate person may be designated as the signing official if a delegation letter is provided from a
person who meets the criteria in 15A NCAC 02T .0106(b)
❑ The Professional Engineer's Certification on Page 5 of the application shall be signed, sealed and dated by a North Carolina
licensed Professional Engineer (if required)
G. Plans and Specifications (Required for activities that result in the Practice of Engineering per G.S. 89C-3):
❑ Submit two sets of plans and specifications (signed, sealed and dated by a N.C. Licensed Professional Engineer)
❑ Plans must include:
A general location map
Diagram of the components associated with the pump and haul activity (drains, piping, tanks, pumps, etc)
Tank Details that indicate high water alarm
Other items as required
INSTRUCTIONS FOR APPLICATION P&H 01-16
Page 1 of 5

Industrial Pump and Haul Activities
Per 15A NCAC 02T .0203(A)(2), Industrial pump and haul activities are deemed permitted provided the following criteria is met:
i The facility notifies the appropriate Division regional office in writing advising of the type of operation, type and quantity of
wastewater generated, location, and the receiving wastewater treatment facility. A letter from the facility accepting the
wastewater (type and quantity) specifically agreeing to accept wastewater from the applicant shall be included.
The wastewater does not contain any human waste.
%- The waste is collected and discharged into a sewer or treatment system designed and permitted to accept the type of
wastewater being pumped and hauled.
The pump and haul activity is not to alleviate a failing wastewater system.
The Division regional office concurs in writing that the activity meets the criteria in this Rule.
CONTACT THE REGIONAL OFFICE PRIOR TO INITIATING ANY INDUSTRIAL PUMP AND HAUL ACTIVITES. SUBMITTAL OF THIS
APPLICATION/DOCUMENTS AND WRITTEN APPROVAL IS STILL REQUIRED FOR INDUSTRIAL PUMP AND HAUL ACTIVITIES
THE COMPLETED APPLICATION PACKAGE INCLDING ALL SUPPORTING INFORMATION AND MATERIALS, SHOULD BE SENT TO THE
APPROPRIATE REGIONAL OFFICE:
REGIONAL OFFICE
Asheville Regional Office
Water Quality Operations
Fayetteville Regional Office
Water Quality Operations
Mooresville Regional Office
Water Quality Operations
Raleigh Regional Office
Water Quality Operations
Washington Regional Office
Water Quality Operations
Wilmington Regional Office
Water Quality Operations
Winston-Salem Regional Office
ADDRESS
2090 US Highway 70
Swannanoa, North Carolina 28778
[phone]
[phone] Fax
225 Green Street Suite 714
Fayetteville, North Carolina 28301
[phone]
[phone] Fax
610 E. Center Avenue
Mooresville, North Carolina 28115
[phone]
[phone] Fax
1628 Mail Service Center
Raleigh, North Carolina 27699-1628
[phone]
[phone] Fax
943 Washington Square Mall
Washington, North Carolina 27889
[phone]
[phone] Fax
127 Cardinal Drive Extension
Wilmington, North Carolina 28405
[phone]
[phone] Fax
COUNTIES SERVED
Avery, Buncombe, Burke, Caldwell, Cherokee,
Clay, Graham, Haywood, Henderson, Jackson,
Macon, Madison, McDowell, Mitchell, Polk,
Rutherford, Swain, Transylvania, Yancey
Anson, Bladen, Cumberland, Harnett, Hoke,
Montgomery, Moore, Robeson, Richmond,
Sampson, Scotland
Alexander, Cabarrus, Catawba, Cleveland,
Gaston, Iredell, Lincoln, Mecklenburg, Rowan,
Stanly, Union
Chatham, Durham, Edgecombe, Franklin,
Granville, Halifax, Johnston, Lee, Nash,
Northampton, Orange, Person, Vance, Wake,
Warren, Wilson
Beaufort, Bertie, Camden, Chowan, Craven,
Currituck, Dare, Gates, Greene, Hertford, Hyde,
Jones, Lenoir, Martin, Pamlico, Pasquotank,
Perquimans, Pitt, Tyrrell, Washington, Wayne
Brunswick, Carteret, Columbus, Duplin, New
Hanover, Onslow, Pender
450 W. Hanes Mill Road
Suite 300
Winston-Salem, North Carolina 27105
(336)-776-9800
Alamance, Alleghany, Ashe, Caswell, Davidson,
Davie, Forsyth, Guilford, Rockingham, Randolph,
Stokes, Surry, Watauga, Wilkes, Yadkin
INSTRUCTIONS FOR APPLICATION P&H 01-16
Page 2of5

I. PRESUBMITTAL INFORMATION:
1. Contacted representative from regional office (Pre -submittal)?. ® Yes No
2. Contact name (For Regional Office): Lon Snider. James Gonsiewski ❑
II. APPLICANT INFORMATION:
1. Applicant's name (Municipality, Individual, Corporation, etc): Duke Ener Carolinas LLC Belews Creek Steam
Station
2. Applicant type: ❑ Municipal ❑ State ❑ Privately -Owned Public Utility
❑ County ® Other: Corporation
3. Origin of Wastewater:
❑ Residential Subdivision
❑ Apartments/Condominiums
❑ Mobile Home Park
❑ School
❑ Restaurant
❑ Office
❑ Retail (Stores, Shopping Centers)
❑ Institution
❑ Hospital
❑ Church
❑ Nursing Home
® Other (specify)
4. Signature authority's name: Reeinald Anderson per 15A NCAC 02T 0106(bl
Title: GM III - Reeuiated Stations
5. Applicant's mailing address: 3195Pine Hall Road
City: Belews Creek State: NC
6. Applicant's contact information:
Phone number: [phone]
W. CONTACT/CONSULTANT INFORMATION:
1. Contact name: Aaron Babson
Title/Affiliation: Senior Associate Hazen and Sawyer
2. Contact's information:
Phone number: [phone]
Zip: 27009-
Domestic: 100 %
Commercial: %
Industrial:
Other: %
Email: Re inald.Anderson@duke-ener .corn
Email: ababson hazenandsaw er.com
IV. RECEIVING FACILITY INFORMATION:
If more than 1 facility has agreed to accept the wastewater, please list all the owners, facility names, and permit
numbers as a separate attachment)
1. Owner: Shamrock Environmental
2. Facility name:
3. Facility permit number: NCS-00790
4. WWTF permit number:
5. WWTF contact name: Jim Hollin sworth
Title/Affiliation: HSE Director
6. WWTF contact information:
Phone number: [phone]
Email:[e-mail]
APPLICATION P&H 01-16
Page 3 of 5

v. PROJECT INFORMATION:
1. Location of Project (physical address): 3195 Pine Hall Road, Belews Creek , NC
Approximate Coordinates (Decimal Degrees): Latitude: 36.2883330 Longitude:-80.05So
2. Duration of Pump and Haul Request (Six Months Typical): 12 months
3. Has a prior permit been issued? New ® Prior Pump & Haul Permit
Permit No.: WQ0040669
4. Permanent Method of Wastewater Disposal: Evaluating treatment/discharge under current NPDES versus
design and installation of alternate system - spray irrigation/septic ystem
5. Date Permanent Disposal will be available:
6. Have permits / approvals for permanent disposal been obtained?
Yes ® No Permit Number:
7. Is there a Pretreatment Program in effect? 0 Yes ® No
8. Describe any pretreatment prior to pumping and hauling:
9. Volume of Wastewater Generated: >10,000 Gallons per Day
10. Explain how the wastewater flow was determined: Q 15A NCAC 02T .0114 or ® Representative Data
If representative data, describe: Operation of the facility requires the volumes remain within the range of
discharge.
11. Describe Tank / Container wastewater will be pumped from (attach description if necessary):
Concrete Vault
12. is Tank / Container in place or will it be installed (attach description if necessary):
In place
13. What type of high water alarm does the container have (and/or):
Audible and Visual (] Telemetry (Auto Dialer / SCADA)
V. CERTIFICATION:
1. Applicant's Certification: (Signature of Signing Official and Project Name)
I, Reginald Anderson , attest that this application for Pump and Haul Permit has been reviewed
by me and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are
not completed and that if all required supporting documentation and attachments are not included, this application package
is subject to being returned as incomplete. I understand that issuance of a permit will require pump and haul facilities or
activities to be inspected at least daily by me or a designated representative. Note: In accordance with North Carolina General
Statutes 143-215.6A and 143-215.66, any person who knowingly makes any false statement, representation, or certification
in any application shall be guilty of a Class 2 misdemeanor, which may include a fine not to exceed $10,000 as well as civil
penalties up ,000 per violation.
Signature
Date
APPLICATION P&H 01 16
Page 4 of 5

ENGINEERING DOCUMENTS MUST BE COMPLETED PRIOR TO SUBMITTAL.
ACTIVITIES SHALL BE INSPECTED AT LEAST DAILY BY THE PERMITTEE OR IT'S REPRESENTATIVE PER 15A NCAC 02T.0205 d .
THE ENGINEER'S CERTFICATION IS REQUIRED FOR ACTIVITIES THAT RESULT IN THE PRACTICE OF ENGINEERING PER G.S. 99C-3.
ENGINEERING DOCUMENTS MUST BE COMPLETED PRIOR TO SUBMITTAL. IF CERTIFICATION BY AND ENGINEER IS REQUIRED,
THIS PAGE IS NOT NECESSARY.
2. Professional Engineer's Certification: (Signature of Design Engineer and Project Name}
I' ,attest that this application for
accurate, complete and consistent with the information in the engineering plans, tios bean reviewed by me and is
other suportin
documentation to the best of my knowledge. I further attest that to he best ofmy knowledgeonsthe pr posted design as been
prepared in accordance with all the applicable regulations. Although other professionals may have developed certain portions
of this submittal package, inclusion of these materials under my signature and seal signifies that 1 have reviewed this material
and have judged it to be consistent with the proposed design. Note: In accordance with NC General Statutes 143-215 6A and
14 215.6E any person who knowingly makes any false statement, representation, or certification in any application shall be
guilty of a Class 2 misdemeanor which may include a fine not to exceed $10,000 as well as civil penalties up to $25,000 per
violation.
2a
Professional Engineer Name
2b.
Engineering Firm
2c
2d.
2g.
Mailing Address
City
Telephone
2h.
Facsimile
2e.
2i.
2f.
State Zip
E mail
NC PE Seal, Signature & Date
APPLICATION P&H 01 16
Page 5 of 5

6106 Corporate Park Drive Browns Summit, NC 27214
336-375-1989. 800-881-1098 - Fax [phone]
www,shamrockenviro.com • [e-mail]
ENVIttOr!lMENrU carounoN
February 19, 2019
Joyce Dishmon
Duke Energy
ENS CCP Permitting and Compliance
Office: 336-623-0238
Cell: 336-394-5524
Email: iovice.dishmon a.duke-eneray.com
Re: Pump & Haul Permit
Dear Ms. Dishmon:
As duly authorized representative of the owner/authority, please be advised that Shamrock
Environmental Corporation a North Carolina Corporation and owner operator of the permits,
vehicles and site described herein is permitted to haul septage in NC under Septage Management
Permit NCS-00790. We have several vacuum loader equipped vehicles permitted to haul septage
ranging between 3500 gallons to 6000 gallons in capacity which gives us more than adequate
capacity to handle 5000 to 8000 per day from Belews Creek, NC.
Furthermore, we are permitted under NC Septage Detention & Management Permit Number
SDTF-41-03 to receive and treat regulated septage at our facility located at 6106 Corporate Park
Drive in Browns Summit, NC with capacity to accept and treat an average daily maximum of
150,000 gallons per day of this type of wastewater. (Facility is permitted for 275,000 gallons
average daily maximum).
In summary, Shamrock Environmental is fully permitted, capable and willing to accept the
proposed daily volume in your proposed permit application of 5,000 to 8,000 gallons per day
subject to conformance with our profiling and acceptance procedures.
For any questions related to this matter, please contact me direct at 336.478.1202, toll -free at
800.881.1098 or by email at jhollingsworth a;shamrockenviro.com.
Sincerely,
Jim lingsworth CIH, C, CHMM, REM
Dir for of Health, Safety & Environmental
File: Duke Belo%s Septage Page 1 of I

DA2157
DUKE ENERGY BUSINESS SERVICES !LC
400 5 TRYON STREET
ACCOUNTS PAYABLE - ST2SB
CHARLOTTE, NC 28202
000017 R3K1SDA
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENTAL QUALITY
WINSTON-SALEM REGIONAL OFFICE
450 HANES MILL ROAD SUITE 300
WINSTON-SALEM NC 27105
(� DUKE
' ENERGY
Remittance Advice
Page 1 of 1
Date: 08/08/2019
Check #: 1000177899
Payment Amount: 1,310.00
Vendor #: 0000071949
33
Invoice Date
08/01/2019
BCPUMPAPP
Invoice #
Voucher ID #
11280218
Invoice Gross Amt
Discount Amount
1,310.00 0.00
Invoice Net Amt
1,310.00
PLEASE DETACH BEFORE DEPOSITING CHECK
SHADED AREA MUST GRADUALLY CHANGE FROM BLUE AT TOP TO GREEN AT BOTTOM
DUKE ENERGY BUSINESS SERVICES LLC
400 5 TRYON STREET
ACCOUNTS PAYABLE • ST2SB
CHARLOTTE, NC 26202
Pay Exactly "One Thousand Three Hundred Ten and 00/100 -US Dollars "
TO THE
ORDER
OF
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENTAL QUALITY
JP MORGAN CHASE BANK, N A
SYRACUSE, NY 13206
50-017/213
Date: 08/08/2019
Check#: 1000177899
Amount
$****1,31Q.00
VOID AFTER 180 DAYS
j--47
A thorized Signer
u' L000 1 7 78990 1:0 2 1 309 3 791:
60 L8t,656 LIP

ROY COOPER
Governor
MICHAEL S. REGAN
Secretory
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
February 26, 2019
Mr. Reginald Anderson, General Manager III - Regulated Stations
Belews Creek Steam Station
Duke Energy Carolinas, LLC
3195 Pine Hall Road
Belews Creek, North Carolina 27009
SUBJECT: Wastewater Pump & Haul Permit Application
Belews Creek Steam Station
Stokes County
Permit No. WQ0040669
Dear Mr. Anderson:
In accordance with your permit application received February 22, 2019, we are forwarding
herewith Permit No. WQ0040669, dated February 26, 2019, to Duke Energy Carolinas LLC for
the time -limited operation of a domestic wastewater pump and haul operation. This permit shall
become effective February 26, 2019 and will expire on August 24, 2019; and shall be subject
to the conditions and limitations as specified therein. This cover letter shall be considered a
part of this permit and is therefore incorporated therein by reference.
Please pay particular attention to Permit Condition 13, which requires accurate record keeping and
reporting. Also note Permit Condition 18, which requires that the facilities associated with the
pump and haul activities be inspected and pumped as often as necessary to prevent any
malfunctions, overflows, or nuisances.
Permission is hereby granted to Duke Energy Carolinas, LLC for the operation of:
• A domestic wastewater pump and haul operation for the sanitary lagoon located at the
Belews Creek Steam to allow for design and construction of upgrades to the system. The
upgrade will be mechanical filtration. The sanitary lagoon will be permitted as a new
internal outfall in the NPDES permit.
• The anticipated flow for this pump and haul operation is a maximum of 8,000 gallons per
day gallons per day or less of domestic wastewater generated in the station administration
N4, D_E �/ CAROLINA
onroro .nt av i Yvnnunui fUMr
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 Hanes MITI Road, Suite 300 I Winston-Salem. North Carolina 27103
336.776.9800

building. It is the Permittee's responsibility to notify the Division within 24 hours if the
flow volume estimated above is exceeded by any amount on any day.
• Please notify this office when the modification of the septic system is complete and the
pump and haul operation is no longer necessary.
The wastewater collected by this system shall be pumped by Shamrock Environmental
Corporation for treatment and discharged into the City of Greensboro TZ Osborne Water
Reclamation Facility for final treatment.
This permit shall become voidable unless the agreements between Shamrock Environmental
Corporation, Duke Energy Carolinas, LLC, and the City of TZ Osborne Water Reclamation
Facility for the pumping, hauling and/or final treatment of wastewater are in full force and effect.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request must be in the form of a written petition, conforming to Chapter 150B of
North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail
Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be
final and binding.
If you have any questions regarding this permit or require any additional information, please
contact Jim Gonsiewski or me by phone at [phone].
Sincerely,
oocuslgn.d by:
CLoA, -r SMitcr
_ 142349E225C94EA
for S. Jay Zimmerman, Director
Division of Water Resources
by Lon T. Snider
Assistant Regional Supervisor, Water Quality Regional Operations
Division of Water Resources
cc: Joyce Dishmon — Duke Energy
Stokes County Health Department
DWR Central Office — Permit File WQ0040669
WSRO Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
DOMESTIC WASTEWATER PUMP & HAUL PERMIT
PERMIT No. WQ0040669
This permit shall be effective February 26, 2019, will expire on August 24, 2019, and
shall be subject to the following specified conditions and limitations:
1. This permit shall become voidable unless the subject pump and haul activities are
carried out in a manner that has been approved by this Division.
2. This permit is effective only with respect to the nature and volume of wastes described
in the application dated February 22, 2019 and other supporting data.
3. The facilities shall be properly maintained and operated at all times.
4. This permit is NOT transferable. In the event that there is a desire for the facilities
to change ownership, or there is a name change of the Permittee, a formal request
must be submitted to the Division.
5. No type, kind or quantity of wastewater other than the pumped and hauled wastewater
from Duke Energy Carolinas, LLC shall be included in these pump and haul activities.
6. This permit shall become voidable unless the agreements between Shamrock
Environmental Corporation, Duke Energy Carolinas, LLC, and the City of
Greensboro TZ Osborne Water Reclamation Facility for the pumping, hauling and/or
final treatment of wastewater are in full force and effect.
7. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, Duke Energy Carolinas, LLC shall cease operation of all pump
and haul activities and take such immediate corrective actions as may be required by
this Division.
8. The wastewater collected by this system shall be properly treated in the Shamrock
Environmental Corporation treatment facility, Permit Number SDTF-41-03, prior to
discharge into the City of Greensboro TZ Osborne Water Reclamation Facility
(NC0047384) for final treatment and disposal.
9. Duke Energy Carolinas, LLC is liable for any damages caused by a spill or failure of
the pump and haul operations.
10. Adequate inspection, maintenance, and cleaning shall be provided by Duke Energy
Carolinas, LLC to ensure proper operation of the subject facilities.

11. Duke Energy Carolinas, LLC or its designee, shall inspect the pump and haul
collection facilities to prevent malfunctions and deterioration, operator errors, and
discharges that may cause or lead to the release of wastes to the environment, a threat
to human health, or a nuisance.
12. Any duly authorized officer, employee, or representative of the Division of Water
Resources may, upon presentation of credentials, enter and inspect any property,
premises, or place on or related to the pump and haul collection facilities at any
reasonable time for the purpose of determining compliance with the Division's
approval; may inspect or copy any records that must be maintained under the terms
and conditions of this permit; and may obtain samples.
13. An accurate record of the pump and haul activities must be maintained by Duke
Energy Carolinas, LLC indicating:
• Date and times wastewater is removed from the facility
• Name of contract hauler
• Name of facility receiving wastewater
• Volume of wastewater removed
• An inspection log including the date and time of inspections, observations made,
and any maintenance, repairs, or corrective actions taken by the Permittee.
These records shall be submitted quarterly by the following Wednesday to the Water Quality
Regional Operations Supervisor, at address 450 West Hanes Mill Road, Suite 300, Winston-
Salem, NC 27105
14. Failure to abide by the conditions and limitations contained in this permit may subject
Duke Energy Carolinas, LLC to appropriate enforcement actions available to the
Division.
15. The granting of this permit does not preclude Duke Energy Carolinas, LLC from
complying with any and all statutes, rules, regulations, or ordinances, which may be
imposed by other government agencies (local, state, and federal), which have
jurisdiction.
16. Noncompliance Notification: Duke Energy Carolinas, LLC shall report by
telephone to the Winston-Salem Regional Office, telephone no. [phone], as
soon as possible, but in no case more than twenty-four (24) hours or on the next
working day following the occurrence or first knowledge of the occurrence of any of
the following:
a. Any process unit failure, due to known or unknown reasons, that render the
facility incapable of adequate wastewater storage and/or treatment such as
failures of tanks, piping, pumps, etc.

b. Any failure of a pumping station, sewer line, etc., resulting in a spill or by-pass
directly to receiving waters without treatment of all or any portion of the
influent to such station or facility.
17. Persons reporting such occurrences by telephone shall also file a written report in
letter form within five (5) business days following first knowledge of the occurrence.
This report must outline the actions taken or proposed to be taken to ensure that the
problem does not recur.
18. The facilities associated with the pump and haul activities shall be inspected and
pumped as often as necessary to prevent malfunctions, overflows, or nuisances.
19. Should ownership or financial circumstances change during this permit, immediate
notification should be made to the regional office.
20. When these pump and haul activities are no longer necessary, please send written
notification to:
Water Quality Regional Supervisor
Winston-Salem Regional Office
NCDEQ-DWR
450 W. Hanes Mill Rd, Suite 300
Winston-Salem, NC 27105
21. Sixty (60) days prior to the expiration of this permit (i.e. June 26, 2019), a status
report of the permanent wastewater treatment system shall be submitted to the
Winston-Salem Regional Office. This report shall include:
i.Anticipated flows; and
ii.Proposed start-up date; or
iii.Other alternatives being considered for permanent or temporary treatment of
wastewater.
Permit issued this the 26th day of February, 2019, with a Permit Effective date of February 26,
2019.
CDec( IW)ea by:
L.a„ T SAARCr
145046E225CG4EA...
for S. Jay Zimmerman, Director
Division of Water Resources
by Lon T. Snider
Assistant Regional Supervisor, Water Quality Regional Operations
Division of Water Resources

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
February 20, 2020
Mr. Reginald Anderson, General Manager III - Regulated Stations
Belews Creek Steam Station
Duke Energy Carolinas, LLC
3195 Pine Hall Road
Belews Creek, North Carolina 27009
SUBJECT: Wastewater Pump & Haul Permit Application
Belews Creek Steam Station
Stokes County
Permit No. WQ0041493
Dear Mr. Anderson:
In accordance with your permit application received February 10, 2020, we are forwarding
herewith Permit No. WQ0041493, dated February 20, 2020, to Duke Energy Carolinas LLC for
the time -limited operation of a domestic wastewater pump and haul operation. This permit shall
become effective February 20, 2020 and will expire on August 17, 2020; and shall be subject
to the conditions and limitations as specified therein. This cover letter shall be considered a
part of this permit and is therefore incorporated therein by reference.
Please pay particular attention to Permit Condition 13, which requires accurate record keeping and
reporting. Also note Permit Condition 18, which requires that the facilities associated with the
pump and haul activities be inspected and pumped as often as necessary to prevent any
malfunctions, overflows, or nuisances.
Permission is hereby granted to Duke Energy Carolinas, LLC for the operation of:
• A domestic wastewater pump and haul operation for the sanitary lagoon located at the
Belews Creek Steam to allow for design and construction of upgrades to the system. The
upgrade will be mechanical filtration. The sanitary lagoon will be permitted as a new
internal outfall in the NPDES permit.
• The anticipated flow for this pump and haul operation is greater than 10,000 gallons per
day gallons per day of domestic wastewater generated in the station administration building.
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

• Please notify this office when the modification of the septic system is complete and the
pump and haul operation is no longer necessary.
The wastewater collected by this system shall be pumped by. Shamrock Environmental
Corporation for treatment or discharge into the City of Eden, Mebane Bridge Wastewater
Treatment Plant (WWTP) for final treatment.
This permit shall become voidable unless the agreements between Shamrock Environmental
Corporation, Duke Energy Carolinas, LLC, and the City of Eden, Mebane Bridge WWTP for the
pumping, hauling and/or final treatment of wastewater are in full force and effect.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request must be in the form of a written petition, conforming to Chapter 150B of
North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail
Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be
final and binding.
If you have any questions regarding this permit or require any additional information, please
contact Jim Gonsiewski or me by phone at [phone].
Sincerely,
COoauftned by:
L o� "t 5,,u*cr
145B49E225CB4EA...
for S. Daniel Smith, Director
Division of Water Resources
by Lon T. Snider
Regional Supervisor, Water Quality Regional Operations
Division of Water Resources
cc: Joyce Dishmon — Duke Energy (Electronic Copy)
Stokes County Health Department (Electronic Copy)

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
DOMESTIC WASTEWATER PUMP & HAUL PERMIT
PERMIT No. WQ0041493
This permit shall be effective February 20, 2020, will expire on August 17, 2020, and
shall be subject to the following specified conditions and limitations:
1. This permit shall become voidable unless the subject pump and haul activities are
carried out in a manner that has been approved by this Division.
2. This permit is effective only with respect to the nature and volume of wastes described
in the application dated February 14, 2020 and other supporting data.
3. The facilities shall be properly maintained and operated at all times.
4. This permit is NOT transferable. In the event that there is a desire for the facilities
to change ownership, or there is a name change of the Permittee, a formal request
must be submitted to the Division.
5. No type, kind or quantity of wastewater other than the pumped and hauled wastewater
from Duke Energy Carolinas, LLC shall be included in these pump and haul activities.
6. This permit shall become voidable unless the agreements between Shamrock
Environmental Corporation, Duke Energy Carolinas, LLC, and the City of Eden,
Mebane Bridge WWTP for the pumping, hauling and/or final treatment of wastewater
are in full force and effect.
7. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, Duke Energy Carolinas, LLC shall cease operation of all pump
and haul activities and take such immediate corrective actions as may be required by
this Division.
8. The wastewater collected by this system shall be properly treated in the Shamrock
Environmental Corporation treatment facility, Permit Number NCS-00790 or in the
City of Eden, Mebane Bridge WWTP (NC0025071) for final treatment and disposal.
9. Duke Energy Carolinas, LLC is liable for any damages caused by a spill or failure of
the pump and haul operations.
10. Adequate inspection, maintenance, and cleaning shall be provided by Duke Energy
Carolinas, LLC to ensure proper operation of the subject facilities.

11. Duke Energy Carolinas, LLC or its designee, shall inspect the pump and haul
collection facilities to prevent malfunctions and deterioration, operator errors, and
discharges that may cause or lead to the release of wastes to the environment, a threat
to human health, or a nuisance.
12. Any duly authorized officer, employee, or representative of the Division of Water
Resources may, upon presentation of credentials, enter and inspect any property,
premises, or place on or related to the pump and haul collection facilities at any
reasonable time for the purpose of determining compliance with the Division's
approval; may inspect or copy any records that must be maintained under the terms
and conditions of this permit; and may obtain samples.
13. An accurate record of the pump and haul activities must be maintained by Duke
Energy Carolinas, LLC indicating:
• Date and times wastewater is removed from the facility
• Name of contract hauler
• Name of facility receiving wastewater
• Volume of wastewater removed
• An inspection log including the date and time of inspections, observations made,
and any maintenance, repairs, or corrective actions taken by the Permittee.
These records shall be submitted quarterly by the following Wednesday to the Water Quality
Regional Operations Supervisor, at address 450 West Hanes Mill Road, Suite 300, Winston-
Salem, NC 27105
14. Failure to abide by the conditions and limitations contained in this permit may subject
Duke Energy Carolinas, LLC to appropriate enforcement actions available to the
Division.
15. The granting of this permit does not preclude Duke Energy Carolinas, LLC from
complying with any and all statutes, rules, regulations, or ordinances, which may be
imposed by other government agencies (local, state, and federal), which have
jurisdiction.
16. Noncompliance Notification: Duke Energy Carolinas, LLC shall report by
telephone to the Winston-Salem Regional Office, telephone no. [phone], as
soon as possible, but in no case more than twenty-four (24) hours or on the next
working day following the occurrence or first knowledge of the occurrence of any of
the following:
a. Any process unit failure, due to known or unknown reasons, that render the
facility incapable of adequate wastewater storage and/or treatment such as
failures of tanks, piping, pumps, etc.
b. Any failure of a pumping station, sewer line, etc., resulting in a spill or by-pass
directly to receiving waters without treatment of all or any portion of the
influent to such station or facility.

17. Persons reporting such occurrences by telephone shall also file a written report in
letter form within five (5) business days following first knowledge of the occurrence.
This report must outline the actions taken or proposed to be taken to ensure that the
problem does not recur.
18. The facilities associated with the pump and haul activities shall be inspected and
pumped as often as necessary to prevent malfunctions, overflows, or nuisances.
19. Should ownership or financial circumstances change during this permit, immediate
notification should be made to the regional office.
20. When these pump and haul activities are no longer necessary, please send written
notification to:
Water Quality Regional Supervisor
Winston-Salem Regional Office
NCDEQ-DWR
450 W. Hanes Mill Rd, Suite 300
Winston-Salem, NC 27105
21. Sixty (60) days prior to the expiration of this permit (i.e. June 19, 2020), a status
report of the permanent wastewater treatment system shall be submitted to the
Winston-Salem Regional Office. This report shall include:
i.Anticipated flows; and
ii.Proposed start-up date; or
iii.Other alternatives being considered for permanent or temporary treatment of
wastewater.
Permit issued this the 20th day of February 2020, with a Permit Effective date of February 20,
2020.
DocusgTbedbby: y
146a49EYn5C04EA.
for S. Daniel Smith, Director
Division of Water Resources
by Lon T. Snider
Regional Supervisor, Water Quality Regional Operations
Division of Water Resources

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
August 21, 2019
Mr. Reginald Anderson, General Manager III - Regulated Stations
Belews Creek Steam Station
Duke Energy Carolinas, LLC
3195 Pine Hall Road
Belews Creek, North Carolina 27009
SUBJECT: Wastewater Pump & Haul Permit Application
Belews Creek Steam Station
Stokes County
Permit No. WQ0041120
Dear Mr. Anderson:
In accordance with your permit application received August 20, 2019, we are forwarding herewith
Permit No. WQ0041120, dated August 21, 2019, to Duke Energy Carolinas LLC for the time -
limited operation of a domestic wastewater pump and haul operation. This permit shall become
effective August 21, 2019 and will expire on February 21, 2020; and shall be subject to the
conditions and limitations as specified therein. This cover letter shall be considered a part of
this permit and is therefore incorporated therein by reference.
Please pay particular attention to Permit Condition 13, which requires accurate record keeping and
reporting. Also note Permit Condition 18, which requires that the facilities associated with the
pump and haul activities be inspected and pumped as often as necessary to prevent any
malfunctions, overflows, or nuisances.
Permission is hereby granted to Duke Energy Carolinas, LLC for the operation of:
• A domestic wastewater pump and haul operation for the sanitary lagoon located at the
Belews Creek Steam to allow for design and construction of upgrades to the system. The
upgrade will be mechanical filtration. The sanitary lagoon will be permitted as a new
internal outfall in the NPDES permit.
• The anticipated flow for this pump and haul operation is greater than 10,000 gallons per
day gallons per day of domestic wastewater generated in the station administration building.
NoRD_E Q,
wv.nMnmIn•Nom nawrN.,"
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road. Suite 300 I Winston-Salem. North Carolina 27105
336.776.9800

• Please notify this office when the modification of the septic system is complete and the
pump and haul operation is no longer necessary.
The wastewater collected by this system shall be pumped by Shamrock Environmental
Corporation for treatment and discharged into the City of Greensboro TZ Osborne Water
Reclamation Facility for final treatment.
This permit shall become voidable unless the agreements between Shamrock Environmental
Corporation, Duke Energy Carolinas, LLC, and the City of TZ Osborne Water Reclamation
Facility for the pumping, hauling and/or final treatment of wastewater are in full force and effect.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request must be in the form of a written petition, conforming to Chapter 150B of
North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail
Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be
final and binding.
If you have any questions regarding this permit or require any additional information, please
contact Jim Gonsiewski or me by phone at [phone].
Sincerely,
DOCUWtned by:
E.—ox : y
er
146849E225C94EA..
for Linda Culpepper, Director
Division of Water Resources
by Lon T. Snider
Regional Supervisor, Water Quality Regional Operations
Division of Water Resources
cc: Joyce Dishmon — Duke Energy
Stokes County Health Department
DWR Central Office — Permit File WQ0041120
WSRO Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
DOMESTIC WASTEWATER PUMP & HAUL PERMIT
PERMIT No. WQ0041120
This permit shall be effective August 21, 2019, will expire on February 21, 2020, and
shall be subject to the following specified conditions and limitations:
1. This permit shall become voidable unless the subject pump and haul activities are
carried out in a manner that has been approved by this Division.
2. This permit is effective only with respect to the nature and volume of wastes described
in the application dated August 20, 2019 and other supporting data.
3. The facilities shall be properly maintained and operated at all times.
4. This permit is NOT transferable. In the event that there is a desire for the facilities
to change ownership, or there is a name change of the Permittee, a formal request
must be submitted to the Division.
5. No type, kind or quantity of wastewater other than the pumped and hauled wastewater
from Duke Energy Carolinas, LLC shall be included in these pump and haul activities.
6. This permit shall become voidable unless the agreements between Shamrock
Environmental Corporation, Duke Energy Carolinas, LLC, and the City of
Greensboro TZ Osborne Water Reclamation Facility for the pumping, hauling and/or
final treatment of wastewater are in full force and effect.
7. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, Duke Energy Carolinas, LLC shall cease operation of all pump
and haul activities and take such immediate corrective actions as may be required by
this Division.
8. The wastewater collected by this system shall be properly treated in the Shamrock
Environmental Corporation treatment facility, Permit Number NCS-00790, prior to
discharge into the City of Greensboro TZ Osborne Water Reclamation Facility
(NC0047384) for final treatment and disposal.
9. Duke Energy Carolinas, LLC is liable for any damages caused by a spill or failure of
the pump and haul operations.
10. Adequate inspection, maintenance, and cleaning shall be provided by Duke Energy
Carolinas, LLC to ensure proper operation of the subject facilities.

11. Duke Energy Carolinas, LLC or its designee, shall inspect the pump and haul
collection facilities to prevent malfunctions and deterioration, operator errors, and
discharges that may cause or lead to the release of wastes to the environment, a threat
to human health, or a nuisance.
12. Any duly authorized officer, employee, or representative of the Division of Water
Resources may, upon presentation of credentials, enter and inspect any property,
premises, or place on or related to the pump and haul collection facilities at any
reasonable time for the purpose of determining compliance with the Division's
approval; may inspect or copy any records that must be maintained under the terms
and conditions of this permit; and may obtain samples.
13. An accurate record of the pump and haul activities must be maintained by Duke
Energy Carolinas, LLC indicating:
• Date and times wastewater is removed from the facility
• Name of contract hauler
• Name of facility receiving wastewater
• Volume of wastewater removed
• An inspection log including the date and time of inspections, observations made,
and any maintenance, repairs, or corrective actions taken by the Permittee.
These records shall be submitted quarterly by the following Wednesday to the W•
ater Quality
Regional Operations Supervisor, at address 450 West Hanes Mill Road, Suite 300, Winston-
Salem, NC 27105
14. Failure to abide by the conditions and limitations contained in this permit may subject
Duke Energy Carolinas, LLC to appropriate enforcement actions available to the
Division.
15. The granting of this permit does not preclude Duke Energy Carolinas, LLC from
complying with any and all statutes, rules, regulations, or ordinances, which may be
imposed by other government agencies (local, state, and federal), which have
jurisdiction.
16. NoncompIiance Notification: Duke Energy Carolinas, LLC shall report by
telephone to the Winston-Salem Regional Office, telephone no. [phone], as
soon as possible, but in no case more than twenty-four (24) hours or on the next
working day following the occurrence or first knowledge of the occurrence of any of
the following:
a. Any process unit failure, due to known or unknown reasons, that render the
facility incapable of adequate wastewater storage and/or treatment such as
failures of tanks, piping, pumps, etc.

b. Any failure of a pumping station, sewer line, etc., resulting in a spill or by-pass
directly to receiving waters without treatment of all or any portion of the
influent to such station or facility.
17. Persons reporting such occurrences by telephone shall also file a written report in
letter form within five (5) business days following first knowledge of the occurrence.
This report must outline the actions taken or proposed to be taken to ensure that the
problem does not recur.
18. The facilities associated with the pump and haul activities shall be inspected and
pumped as often as necessary to prevent malfunctions, overflows, or nuisances.
19. Should ownership or financial circumstances change during this permit, immediate
notification should be made to the regional office.
20. When these pump and haul activities are no longer necessary, please send written
notification to:
Water Quality Regional Supervisor
Winston-Salem Regional Office
NCDEQ-DWR
450 W. Hanes Mill Rd, Suite 300
Winston-Salem, NC 27105
21. Sixty (60) days prior to the expiration of this permit (i.e. December 24, 2019), a
status report of the permanent wastewater treatment system shall be submitted to the
Winston-Salem Regional Office. This report shall include:
i.Anticipated flows; and
ii.Proposed start-up date; or
iii.Other alternatives being considered for permanent or temporary treatment of
wastewater.
Permit issued this the 21 st day of August 2019, with a Permit Effective date of August 21, 2019.
CnoousgTnwcby: y
A, 1 JMI{tt
145B4QE225014EA...
for Linda Culpepper, Director
Division of Water Resources
by Lon T. Snider
Regional Supervisor, Water Quality Regional Operations
Division of Water Resources

River View G
Cou
Duke Energy
Property Line
Outfall
006
Proposed Instream
Sampling Location