NC0004979_Notice of Planned Participation_20210527

4INN DUKE 410 S Wilmington Street
ENERGY® Mail Code: 13th Floor
Raleigh, NC 27601
0:919-546-6227
c:919-801-9749
May 27, 2021
Dr. Sergei Chernikov RECEIVED
North Carolina Division of Water Resources
1617 Mail Service Center JUN 10 2021
Raleigh NC 27699-1617
RE: Duke Energy Carolinas, LLC—Allen Steam Station NCDEQ/DWR/NpDES
NPDES Permit NC0004979
Notice of Planned Participation
Dear Dr. Chernikov:
In accordance with the provisions of the Steam Electric Effluent Limitations Guidelines (ELG),
Duke Energy Carolinas, LLC is hereby providing a Notice of Planned Participation (NOPP) for
the Allen Steam Station, NPDES Permit NC0004979. Specifically, the NOPP is to permanently
cease the combustion of coal. However, if Units 4 nnotcombustion
and 5 do cease combust o of coal by
the December 31, 2028 regulatory date, Duke Energy reserves the option to implement
necessary technology for compliance with the Voluntary Incentives Program (VIP) by December
31, 2028 as described below. The necessary information to support the NOPP is specified at
40 CFR § 423.19(f)(2).
Please note that the provided retirement dates are subject to change based on several factors
including future regulatory actions. Any substantive retirement date changes will be provided in
the required 40 CFR § 423.19(f)(4) "Annual Progress Report".
Cease Combustion of Coal by December 31, 2028
The Allen Steam Station NOPP is for the five coal-fired units which are projected to retire as
follows:
• Unit 1 —on or before December 31, 2024
• Unit 2 —on or before December 31, 2024
• Unit 3 — retired March 31, 2021
• Unit 4—on or before December 31, 2028
• Unit 5 —on or before December 31, 2028
The retirement dates for Units 1 and 2 are established by a consent decree (The United States
District Court for the Middle District of North Carolina, Civil Action No.: 1.00 cv 1262). A copy of
this consent decree is located at https://www.epa.gov/sites/production/files/2015-
09/documents/duke-enerpv-consent-decree-civil-action-1cv1262 0.pdf.
The retirement date for Unit 3 is provided in the United States Securities and Exchange
Commission (SEC) Form 10-K dated February 25, 2021 which is located at https://www.duke-
enerpy.com/ /media/pdfs/our-company/investors/2020-duke-energy-form-10-k.pdf?la=en

The retirement dates for Units 4 and 5 are contained in the 2019 Integrated Resource Plan
(IRP) that was accepted by the North Carolina Utility Commission (NCUC) in Docket E-100 Sub
157 on April 6, 2020. The order is located at
https://starwl.ncuc.net/NCUCNiewFile.aspx?Id=86f 15be3-7617-4910-aeae-d8568c4d0983.
The entire 2019 IRP containing the retirement dates is located at
https://starwl.ncuc.net/NCUCNiewFile.aspx?Id=d5888a19-da40-42c6-b75c-f2ce7bdb1 ac4.
Excerpts from these four documents is contained in the enclosed attachments. Official
retirement of any Allen units beyond the already retired Unit 3 will require final management
approval. Furthermore, the final retirement dates for Unit 1 and Unit 5 are contingent on a
supporting switching station project and other operational considerations.
Please note that the filed 2020 IRP is currently under review by the NCUC. The 2020 IRP
states all five of the current Allen Steam Station coal-fired units could retire by December 31,
2023 based on an evaluation that determined the economic retirement date. In order to
facilitate retirement of all Allen coal-fired units, the "South Point Switching Station" project will
need to be constructed and operational.
Due to the relatively small period that the remaining generating units (1, 2, 4, and 5) are
projected to operate, a timeline to achieve the permanent cessation of coal combustion by
December 31, 2028 is as follows:
• Evaluate the validity of the anticipated retirement dates by June 30th of each calendar
year for those units that have not retired
• Monitor the 2020 IRP proceedings and review the NCUC order
• Monitor status of the "South Point Switching Station" project
• Obtain senior management authorization, including the Duke Energy Chief Executive
Officer, to cease combustion of coal at the remaining units
In accordance with the ELG Rule at 40 CFR § 423.19(f)(4), an "Annual Progress Report" will be
submitted beginning May 31, 2022. This report will provide updated retirement information for
the remaining Allen Steam Station generating units, including activities to facilitate retirement,
and providing copies of any relevant documents. Subsequent Annual Progress Reports will be
submitted by May 31 of each following year until all Allen Steam Station coal-fired units are
retired.
Unit 4 and 5 VIP Technology Operation by December 31, 2028
If Duke Energy decides to continue combustion of coal in Units 4 and 5 beyond December 31,
2028, FGD wastewater technologies will be installed to comply with the limitations at 40 CFR §
423.13(g)(3)(i). The treatment technology to be installed will incorporate membrane filtration
and/or a zero discharge of FGD wastewater to achieve compliance with the VIP limitations.
Due to the uncertainty of the Unit 4 and 5 retirement date, a general timeline to achieve
compliance with the VIP limitations is as follows:
• Evaluate by December 31, 2024 if Allen Steam Station Units 4 and 5 will continue to
combust coal for electrical generation beyond December 31, 2028.
• Monitor the development of any emerging wastewater treatment technologies through
December 31, 2024

• Design, construct, and achieve operation of a VIP compliant system by December 31,
2028.
The opportunity to transfer to the VIP option is necessary as the IRP is a plan and does not
necessarily constitute a firm commitment to retire a coal-fired generation unit. Based on our
experience with installation of other FGD wastewater treatment systems, we believe that four
years will be necessary to design and construct wastewater treatment system for compliance
with the VIP option. Therefore, Duke Energy will likely determine that a transfer to the VIP
option is required several months prior to the regulatory December 31, 2025 date.
Please contact Elizabeth Glenn (980-737-0530 or [e-mail]) if you
have any questions regarding this NOPP.
Sincerely,
ulie Turner
Carolinas Coal Regional Vice President
Regulated & Renewable Energy
Attachments: 1. The United States District Court for the Middle District of North Carolina, Civil
Action No.: 1.00 cv 1262 (excerpt)
2. February 25, 2021 SEC Form 10-K (excerpt)
3. Duke Energy Carolinas, LLC North Carolina 2019 Integrated Resource Plan
(excerpts)
4. 2019 Integrated Resource Plan April 6, 2020 NCUC Order (excerpts)
cc: Shannon Langley
Elizabeth Glenn
Cynthia Winston
Michael Smallwood
Matthew Hanchey
Paul Draovitch
Rick Roper
Steve Immel
Dan Donochod
Ben Smith

Allen Steam Station — Notice of Planned Participation
Attachment 1
The United States District Court for the Middle District of North
Carolina, Civil Action No.: 1.00 cv 1262 (excerpt)

THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF NORTH CAROLINA
)
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
ENVIRONMENTAL DEFENSE, )
NORTH CAROLINA SIERRA CLUB, AND )
NORTH CAROLINA PUBLIC INTEREST )
RESEARCH GROUP )
)
Plaintiff-Intervenors, )
)
v. ) Civil Action No.: 1:00 cv 1262
)
DUKE ENERGY CORPORATION, )
)
Defendant. )
)
)
CONSENT DECREE

ancillary equipment, including pollution control equipment and systems necessary for production
of electricity. An electric steam generating station may be comprised of one or more Units.
46. "Unit Operating Day"means any Day on which a Unit fires Fossil Fuel.
47. "Working Day"means a day other than a Saturday, Sunday, or Federal Holiday.
In computing any period of time under this Consent Decree,where the last day would fall on a
Saturday, Sunday, or Federal Holiday,the period shall run until the close of business on the next
Working Day.
IV. RETIREMENT OF PLANT MODERNIZATION PROGRAM UNITS
48. Defendant has already ceased operations at and permanently shut down Buck Unit
3, Buck Unit 4, Buck Unit 5, Cliffside Unit 1, Cliffside Unit 2, Cliffside Unit 3, Cliffside Unit 4,
Dan River Unit 3, Riverbend Unit 4, Riverbend Unit 6, and Riverbend Unit 7. Upon entry of this
Consent Decree,the permanent Retirement of these units shall also become an enforceable
obligation under this Consent Decree.
49. By no later than December 31, 2024, Defendant shall permanently Retire Allen
Unit 1 and Allen Unit 2.
V. INTERIM NO.EMISSION REDUCTIONS AND CONTROLS
A. Operation and Performance NO.Requirements at Allen Units 1 and 2
50. Commencing no later than 120 Days after the Date of Entry, and continuing until
the Unit is Retired, Defendant shall Continuously Operate the existing SNCR at Allen Unit 1.
Commencing no later than 485 Days after the Date of Entry, and continuing until the Unit is
Retired,Defendant shall achieve and maintain a 365-Day Rolling Average NOX Emission Rate of
no greater than 0.250 lb/mmBTU.
12

e. Defendant must be and remain in full compliance with the provisions of this
Consent Decree establishing performance, operational, and control technology
requirements established by this Consent Decree including, but not limited to, (a)
the Interim NOX Emission Reductions and Controls specified in Section V of this
Consent Decree, (b)the Interim SO2 Emission Reductions and Controls specified
in Section VI of this Consent Decree, (c) requirements pertaining to the Surrender
of SO2 and NOX Allowances, and(d)the Retirement of Allen Units 1,2, and 3 as
required under this Consent Decree.
68. Nothing in this Consent Decree is intended to preclude the emission reductions
generated under this Consent Decree from being considered by the applicable state regulatory
agency or EPA for the purpose of attainment demonstrations submitted pursuant to § 110 of the
Act,42 U.S.C. § 7410, or in determining impacts on National Ambient Air Quality Standards,
PSD increment, or air quality related values, including visibility, in a Class I area.
IX. ADDITIONAL INJUNCTIVE RELIEF
69. By no later than December 31, 2024 Defendant shall permanently Retire Allen
Unit 3.
70. Defendant shall implement the additional Environmental Mitigation Projects
("Projects") described in Appendix A to this Consent Decree in compliance with the approved
plans and schedules for such Projects and other terms of this Consent Decree. In implementing
the Projects,Defendant shall spend no less than $4,400,000 in Project Dollars. Defendant shall
19

Allen Steam Station — Notice of Planned Participation
Attachment 2
February 25, 2021 SEC Form 10-K (excerpt)

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
WASHINGTON,D.C.20549
FORM 10-K
(Mark One)
® ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d)OF THE SECURITIES EXCHANGE ACT OF 1934
For the fiscal period ended December 31,2020 or
TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d)OF THE SECURITIES EXCHANGE ACT OF 1934
For the transition period from to
Commission Registrant,State of Incorporation or Organization,Address of Principal IRS Employer
file number Executive Offices and Telephone Number Identification No.
DUKE
ENERGY®
1-32853 DUKE ENERGY CORPORATION 20-2777218
(a Delaware corporation)
550 South Tryon Street
Charlotte,North Carolina 28202-1803
704-382-3853
1-4928 DUKE ENERGY CAROLINAS, LLC 56-0205520
(a North Carolina limited liability company)
526 South Church Street
Charlotte, North Carolina 28202-1803
704-382-3853
1-15929 PROGRESS ENERGY, INC. 56-2155481
(a North Carolina corporation)
410 South Wilmington Street
Raleigh, North Carolina 27601-1748
704-382-3853
1-3382 DUKE ENERGY PROGRESS, LLC 56-0165465
(a North Carolina limited liability company)
410 South Wilmington Street
Raleigh,North Carolina 27601-1748
704-382-3853
1-3274 DUKE ENERGY FLORIDA, LLC 59-0247770
(a Florida limited liability company)
299 First Avenue North
St.Petersburg,Florida 33701
704-382-3853
1-1232 DUKE ENERGY OHIO,INC. 31-0240030
(an Ohio corporation)
139 East Fourth Street
Cincinnati,Ohio 45202
704-382-3853
1-3543 DUKE ENERGY INDIANA, LLC 35-0594457
(an Indiana limited liability company)
1000 East Main Street
Plainfield,Indiana 46168
704-382-3853
1-6196 PIEDMONT NATURAL GAS COMPANY, INC. 56-0556998
(a North Carolina corporation)
4720 Piedmont Row Drive
Charlotte,North Carolina 28210
704-364-3120

FINANCIAL STATEMENTS REGULATORY MATTERS
The table below contains the net carrying value of generating facilities planned for retirement or included in recent IRPs as evaluated for potential
retirement.Dollar amounts in the table below are included in Net property,plant and equipment on the Consolidated Balance Sheets as of
December 31,2020,and exclude capitalized asset retirement costs.
Remaining Net
Capacity Book Value
(in MW) (in millions)
Duke Energy Carolinas
Allen Steam Station Units 1-3(a) 604 $ 113
Allen Steam Station Units 4-5(e) 526 338
Cliffside Unit 5(b) 546 350
Duke Energy Progress
Mayo Unit 1(b) 746 676
Roxboro Units 3-4(b) 1,409 484
Duke Energy Florida
Crystal River Units 4-5(e) 1,430 1,696
Duke Energy Indiana
Gallagher Units 2 and 4(d) 280 102
Gibson Units 1-5(e) 2,845 1,866
Cayuga Units 1-2(e) 1,005 777
Total Duke Energy 9,391 $ 6,402
(a) As part of the 2015 resolution of a lawsuit involving alleged New Source Review violations,Duke Energy Carolinas must retire Allen
Steam Station Units 1 through 3 by December 31,2024.The long-term energy options considered in the IRP could result in retirement
of these units earlier than their current estimated useful lives.Unit 3 with a capacity of 270 MW and a net book value of$26 million at
December 31,2020,is expected to be retired in March 2021.
(b) These units are included in the IRP filed by Duke Energy Carolinas and Duke Energy Progress in North Carolina and South Carolina
on September 1,2020.The long-term energy options considered in the IRP could result in retirement of these units earlier than their
current estimated useful lives.In 2019,Duke Energy Carolinas and Duke Energy Progress filed North Carolina rate cases that included
depreciation studies that accelerate end-of-life dates for these plants.A decision by NCUC is expected by the end of the first quarter
2021.
(c) On January 14,2021,Duke Energy Florida filed a settlement agreement with the FPSC,which proposed depreciation rates reflecting
retirement dates for Duke Energy Florida's last two coal-fired generating facilities,Crystal River Units 4-5,eight years ahead of
schedule in 2034 rather than in 2042,in support of Duke Energy's carbon reduction goals.A request for the FPSC to hold a hearing
has been made and a decision by the FPSC is expected in the second quarter 2021.
(d) Duke Energy Indiana committed to either retire or stop burning coal at Gallagher Units 2 and 4 by December 31,2022,as part of the
2016 settlement of Edwardsport IGCC matters. In February 2021,upon approval by MISO of a new retirement date,Duke Energy
Indiana determined it would modify the retirement date to June 1,2021.
(e) On July 1,2019,Duke Energy Indiana filed its 2018 IRP with the IURC.The 2018 IRP included scenarios evaluating the potential
retirement of coal-fired generating units at Gibson and Cayuga.The rate case filed July 2,2019,included proposed depreciation rates
reflecting retirement dates from 2026 to 2038.The depreciation rates reflecting these updated retirement dates were approved by the
IURC as part of the rate case order issued on June 29,2020.
4. COMMITMENTS AND CONTINGENCIES
INSURANCE
General Insurance
The Duke Energy Registrants have insurance and reinsurance coverage either directly or through indemnification from Duke Energy's captive
insurance company,Bison,and its affiliates,consistent with companies engaged in similar commercial operations with similar type properties.
The Duke Energy Registrants'coverage includes(i)commercial general liability coverage for liabilities arising to third parties for bodily injury and
property damage;(ii)workers'compensation;(iii)automobile liability coverage;and(iv)property coverage for all real and personal property
damage.Real and personal property damage coverage excludes electric transmission and distribution lines,but includes damages arising from
boiler and machinery breakdowns,earthquakes,flood damage and extra expense,but not outage or replacement power coverage.All coverage
is subject to certain deductibles or retentions,sublimits,exclusions,terms and conditions common for companies with similar types of operations.
The Duke Energy Registrants self-insure their electric transmission and distribution lines against loss due to storm damage and other natural
disasters.As discussed further in Note 3,Duke Energy Florida maintains a storm damage reserve and has a regulatory mechanism to recover
the cost of named storms on an expedited basis.
The cost of the Duke Energy Registrants'coverage can fluctuate from year to year reflecting claims history and conditions of the insurance and
reinsurance markets.
163

Allen Steam Station — Notice of Planned Participation
Attachment 3
Duke Energy Carolinas, LLC North Carolina 2019 Integrated Resource
Plan (excerpts)

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DEC-Assumptions of Load,Capacity,and Reserves Table 0
The following notes are numbered to match the line numbers on the Winter Projections of Load,Capacity,
and Reserves tables. All values are MW(winter ratings)except where shown as a percent.
cr)
1. Planning is done for the peak demand for the Duke Energy Carolinas System including Nantahala.
A firm wholesale backstand agreement for 47 MW between Duke Energy Carolinas and Piedmont cs'
Municipal Power Agency(PMPA)starts on 1/1/2014 and continues through the end of 2020.This U
backstand is included in Line 1. 0
2. Firm sale of Catawba backstand for NCEMC. (481 MW * 17%RM)=82 MW
3. Cumulative new energy efficiency and conservation programs(does not include demand response
programs).
4. Peak load adjusted for firm sales and cumulative energy efficiency.
5. Existing generating capacity reflecting designated additions,planned uprates,retirements and
derates as of July 1,2019.
Includes 103 MW Nantahala hydro capacity. Only DEC portion of Catawba Nuclear Station
capacity is included. Lee CC capacity of 683 MW (net of NCEMC ownership of 100 MW) is
included.
6. Designated Capacity Additions include:
Planned runner upgrades on each of the four Bad Creek pumped storage units. Each upgrade is
expected to be 65 MW and are projected in the 2020—2023 timeframe.
One unit will be upgraded per year.
Nuclear upgrades of 15 MW for each Oconee unit between 2022 through 2024.
402 MW Lincoln CT 17 included in 2025.
7. A planning assumption for coal retirements has been included in the 2018 IRP. Dates correspond
to the depreciation study approved as part of the DEC rate case.
Allen Steam Station Units 1-3 (604 MW)are assumed to retire in December 2024.
Allen Steam Station Units 4-5 (526 MW)are assumed to retire in December 2028.
Page 54

Allen Steam Station — Notice of Planned Participation
Attachment 4
2019 Integrated Resource Plan April 6, 2020 NCUC Order (excerpts)

STATE OF NORTH CAROLINA
UTILITIES COMMISSION
RALEIGH
DOCKET NO. E-100, SUB 157
BEFORE THE NORTH CAROLINA UTILITIES COMMISSION
In the Matter of
2019 Integrated Resource Plan Update ) ORDER ACCEPTING FILING OF
Reports and Related 2019 REPS ) 2019 UPDATE REPORTS AND
Compliance Plans ) ACCEPTING 2019 REPS
COMPLIANCE PLANS
HEARD: Monday, March 9, 2020, at 7:00 p.m. in Commission Hearing Room 2115,
Dobbs Building, 430 North Salisbury Street, Raleigh, North Carolina
BEFORE: Commissioner Daniel G. Clodfelter, Presiding, Chair Charlotte A. Mitchell,
Commissioners ToNola D. Brown-Bland, Lyons Gray, Kimberly W. Duffley,
Jeffrey A. Hughes, and Floyd B McKissick, Jr.
APPEARANCES:
For Virginia Electric and Power Company, d/b/a Dominion Energy North Carolina:
Nicholas A. Dantonio, McGuireWoods LLP, 434 S. Fayetteville Street, Suite 2600,
Raleigh, North Carolina 27603
For Duke Energy Progress, LLC, and Duke Energy Carolinas, LLC:
Lawrence B. Somers, Deputy General Counsel, Duke Energy Corporation, 410
South Wilmington Street, NCRH 20, Raleigh, North Carolina 27602
For the Using and Consuming Public:
Lucy E. Edmondson, Staff Attorney; Layla Cummings, Staff Attorney; and Nadia
Luhr, Staff Attorney; Public Staff-North Carolina Utilities Commission, 4326 Mail
Service Center, Raleigh, North Carolina 27699-4300
BY THE COMMISSION: Integrated Resource Planning (IRP) is intended to identify
those electric resource options that can be obtained at least cost to the utility and its
ratepayers consistent with the provision of adequate, reliable electric service. IRP
considers demand-side alternatives, including conservation, efficiency, and load
management, as well as supply-side alternatives in the selection of resource options.
Commission Rule R8-60 defines an overall framework within which the IRP process takes
place in North Carolina. Analysis of the long-range need for future electric generating

Commission views the ISOP program and stakeholder involvement in that program as an
important opportunity to strengthen effective communication and interaction both in
planning and in operations between the Companies and the non-regulated distribution
system operators that serve a significant portion of the State.
The Commission determines that the 2020 IRPs should continue to report on the
progress of the ISOP effort. As a minimum, the IRPs should communicate with some
specificity the project plan and dates for the ISOP effort. In addition, the Commission will
direct the utilities to discuss the expected outputs of the ISOP process and how they will
be utilized in the IRP process.
Utility Statement of Need
As discussed in the Commission's 2018 IRP Order dated August 27, 2019, the
Public Staff noted the fundamental link between each IOU's IRP and avoided costs,
formalized with the passage of HB 589, which provided that a "future capacity need shall
only be avoided in a year where the utility's most recent biennial [IRP] filed with the
Commission . . . has identified a projected capacity need to serve system load . . ." See
amended N.C.G.S. § 62-156(b)(3). The Public Staff pointed out that a number of
assumptions used by the IOUs in the avoided cost proceeding have not been clearly
specified by each utility. To remedy this issue and mitigate the potential for paying for
more capacity than what is needed, the Public Staff recommended that the utilities, in
their IRP Update to be filed in 2019 and all future IRPs and updates, include a new Utility
Statement of Need section. Duke agreed with the Public Staff's recommendations and
stated that it will include a Statement of Need section to more clearly identify the
undesignated capacity needs for each utility in DEC's and DEP's 2019 IRP Updates and
in future biennial IRP filings. See 2018 IRP Order, at p. 65.
The Commission determines that the "First Resource Need" section of DEC's and
DEP's 2019 IRPs is an appropriate output of the integrated resource planning processes
and adequate to support future avoided cost calculations.
Conclusion
Based upon the record in this proceeding, the comments of the Public Staff
regarding the IRP Update Reports and REPS compliance plans submitted by DEC, DEP
and DENC, the Companies' written submissions in this docket dated November 4, 2019,
and the materials and testimony presented at the January 8, 2020 hearing, the
Commission hereby accepts the 2019 IRP Update Reports filed by the utilities as
complete and fulfilling the requirements set out in Commission Rule R8-60. The
Commission further accepts the REPS compliance plans submitted by DEC, DEP and
DENC, as recommended by the Public Staff. In preparing their 2020 biennial IRPs the
14

utilities shall follow the applicable guidance and directives set forth in this order and in the
mmi Co ssion s August 27, 2019 Order addressing the 2018 biennial IRPs.
IT IS, THEREFORE, SO ORDERED.
ISSUED BY ORDER OF THE COMMISSION.
This the 6th day of April, 2020.
NORTH CAROLINA UTILITIES COMMISSION
Janice H. Fulmore, Deputy Clerk
Commissioner Lyons Gray did not participate in this decision.
15