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NC0004987_Protection & Restoration Annual Report_20220127
C' DUKE EHS Environmental Programs 411 Fayetteville Street ENERGY.: Mail Code:NC15 Raleigh,NC 27601 January 27, 2022 Mr. Stephen D. Smith D © IE LI Director North Carolina Division of Water Resources 1617 Mail Services Center FEB - 3 2022 J Raleigh, NC 27699-1617 Subject: Submittal of 2021 Surface Water Protection DIVISION OF WATER RESOURCES ._..... 'S and Restoration Annual Report t. DIPFCTOR OFFCE -------- Duke Energy Carolinas, LLC. Dear Mr. Smith, In accordance with North Carolina General Statute 130A-309.212(e), Duke Energy is required to "...submit an Annual Surface Water Protection Report to the department no later than January 31 of each year." Duke Energy is pleased to submit the attached 2021 Surface Water Protection and Restoration Annual Reports for Duke Energy Carolinas, LLC, The attached report provides information for the following facilities: Puke Eneray Carolinas. LLC Allen Steam Station, Belews Creek Steam Station, Buck Station, Rogers Steam Station (Cliffside), Dan River Station, Marshall Steam Station and Riverbend Steam Station If you have any questions regarding these materials, please contact me at (864) 356-8257 or randy.hawkinsduke-energy.com. Sincerely, Randy Hawkins Environmental Specialist Attachment Cc: Jeff Poupart—via email w/attachment Eric Smith —via email w/attachment Jim Wells—via email w/attachment Richard Baker—via email w/attachment Cyndi Winston —via email w/attachment EHS NC water SME's - via email w/attachment FileNet • Y DUKE ENERGY® CAROLINAS 2021 North Carolina Surface Water Protection and Restoration Annual Report Duke Energy Carolinas, LLC Submitted: January 2022 Duke Energy Carolinas,LLC 12021 Surface Water Protection and Restoration Annual Report Table of Contents Page Table of Contents i Section 1 - Introduction 2 Section 2 - Site Background 2 2.1 Allen Steam Station 2 2.2 Belews Creek Steam Station 3 2.3 Buck Combined Cycle Station 4 2.4 Rogers (Cliffside) Energy Complex 5 2.5 Dan River Combined Cycle Station 6 2.6 Marshall Steam Station 7 2.7 Riverbend Steam Station 7 Section 3—Surface Water Sampling Summary 9 Section 4— Surface Water Protection and Restoration Summary 12 Section 5 — Discharge Identification Status 13 Section 6— Discharge Assessment Status 13 Table 3-1. Duke Energy Coal-Fired Steam Stations 2021 Surface Water Quality Sampling 9 Page i Duke Energy Carolinas, LLC 2021 Surface Water Protection and Restoration Annual Report Section 1 - Introduction The purpose of this document is to address the requirements of North Carolina General Statutes (N.C.G.S.) § 130A-309.212(e), Reporting, as established by North Carolina Senate Bill 729, the Coal Ash Management Act of 2014 (CAMA), for multiple ash basin sites operated under National Pollutant Discharge Elimination System (NPDES) permits as referenced herein. The following requirements are contained in N.C.G.S. § 130A-309.212: (e) Reporting. —In addition to any other reporting required by the Department, the owner of a coal combustion residuals surface impoundment shall submit an annual Surface Water Protection and Restoration Report to the Department no later than January 31 of each year. The Report shall include a summary of all surface water sampling, protection, and restoration activities related to the impoundment for the preceding year, including the status of the identification, assessment, and correction of unpermitted discharges from coal combustion residuals surface impoundments to the surface waters of the State. CAMA establishes the submittal date of this report as no later than January 31, 2022. This report satisfies the requirements of N.C.G.S. § 130A-309.212(e) for activities occurring in 2021 at multiple facilities with ash basin treatment units. Section 2 - Site Descriptions 2.1 Allen Steam Station Allen Steam Station (Allen Station) is a five-unit, coal-fired electric generating plant with a capacity of 1,140 megawatts located on the west bank of the Catawba River on Lake Wylie in Belmont, Gaston County, North Carolina. The site is located east of South Point Road (NC 273), and the surrounding area generally consists of residential properties, undeveloped land, and Lake Wylie. Allen Station's ash basins consist of two former ash basins. The most recently active ash basin was commissioned in 1973 and is currently being dewatered. The inactive ash basin is located to the north of the active ash basin and is not in operation. A large portion of the area on top of the inactive ash basin is permitted as an industrial landfill by the North Carolina Department of Environmental Quality (DEQ), Division of Waste Management (Permit No. 3612). The area contained within the ash basin waste boundary is approximately 322 acres. There are two earthen dikes impounding the active ash basin: the East Dike, located along the west bank of Lake Wylie, and the North Dike, separating the active and inactive ash basins. The surface area of the active ash basin is approximately 169 acres with an operating pond Page 2 Duke Energy Carolinas, LLC 12021 Surface Water Protection and Restoration Annual Report elevation of approximately 633.5 feet'. The full pond elevation of Lake Wylie is approximately 568.7 feet. The ash basin was historically operated as an integral part of the Allen Station's wastewater treatment system, receiving flows from the ash removal system, coal pile runoff, landfill leachate, flue-gas desulfurization (FGD) wastewater, the station yard drain sump, and stormwater flows. All wastewater inflows to the ash basin were ceased in 2019. Wastewater is now routed to a newly commissioned Lined Retention Basin. The facility began the permitted activity of decanting the ash basin in 2019. Ceasing inflows and decanting are the first steps towards closure of the basin. Decanting the ash basin was completed in 2020. Discharge from the ash basin system is permitted and regulated by the NCDEQ Division of Water Resources (DWR) under the NPDES Permit NC0004979. Historically, permitted effluent from the ash basin was discharged to Lake Wylie via a discharge tower and 42-inch diameter reinforced concrete pipe (RCP). Following modifications in 2016, effluent from the ash basin now discharges from a weir box structure located in the southeastern portion of the ash basin via a 42-inch diameter high-density polyethylene (HDPE) pipe to a concrete vault at the toe of the dam. The permitted effluent discharge then flows through a 42-inch reinforced concrete pipe (RCP) to Lake Wylie. The water surface elevation in the ash basin is controlled by the use of stop logs in the weir box structure. 2.2 Belews Creek Steam Station Belews Creek Steam Station (Belews Creek Station) is a co-fired electric generating facility with a capacity of 2,240 megawatts located on Belews Reservoir in Stokes County, North Carolina. Belews Creek Station is a two-unit station, which began commercial operation in 1974. Belews Creek, a tributary of the Dan River, was impounded by Duke Energy (Duke Power at the time of initial impoundment) to form Belews Lake. Belews Lake is approximately 3,800 acres in area and provides cooling water for the Belews Creek station. The ash basin system consists of a single cell impounded by an earthen dike located on the north end of the ash basin. The ash basin system was constructed from 1970-1972 and is located approximately 3,200 feet northwest of Belews Creek Station. The waste boundary for the ash basin encompasses approximately 342 acres. The full pond elevation for the Belews Creek Station ash basin is approximately 750 feet. The normal pond elevation of Belews Lake is approximately 725 feet. All wastewater inflows to the ash basin were ceased in 2019. Wastewater is now routed to a newly commissioned Lined Retention Basin. The facility began the permitted activity of decanting the ash basin in 2019. The facility reached a decanted state for the ash basin in 2020 and performs maintenance decanting as needed. Ceasing inflows and decanting are the first steps towards closure of the basin. The discharge from the ash basin was historically through a concrete discharge tower located in the northwest portion of the ash basin. The concrete discharge tower drains through a 24-inch-diameter SDR 17 high-density polyethylene pipe ' All elevations are reported in NAVD88. Page 3 Duke Energy Carolinas, LLC 12021 Surface Water Protection and Restoration Annual Report (HDPE) conduit for approximately 1,600 feet and then discharges into a concrete flume box. Modifications to the discharge flow path have been completed which allow for discharge from the basin to be directed to the main stem of the Dan river. 2.3 Buck Steam Station Buck Steam Station (Buck Station) is a former coal-fired electricity generating facility with a capacity of 256 megawatts located near the town of Salisbury in Rowan County, North Carolina. As of April 2013, all of the coal-fired units have been retired. The site is located northwest of Leonard Road, and the surrounding area generally consists of residential properties, undeveloped land, and the Yadkin River. The site now contains the Buck Combined Cycle Station (BCCS), a 620-megawatt natural gas-powered electric generating station. The entire site is approximately 640 acres in area. The ash basin system at the Buck Station was used to retain and settle ash generated from coal combustion at Buck Station. The ash basin system consists of three cells, the associated earthen dikes, discharge structures, and two canals. The cells are designated as Additional Primary Pond (Cell 1), Primary Pond (Cell 2), and Secondary Pond (Cell 3). The ash basin is located to the south (Cell 1) and southeast (Cells 2 and 3) of the retired Buck Steam Station Units 1 through 6 and the BCCS. The original ash pond at Buck Station began operation in 1957. The footprint of the original ash pond was the approximate current footprint of Cells 2 and 3. As the ash pond capacity diminished over time, the original pond was eventually divided into two ash ponds (Cells 2 and 3) by construction of a separator dike. In 1982, additional storage was created by construction of Cell 1, separate from the other cells, by building a new dike up gradient from Cell 2. Until Cell 1 was constructed, ash generated from the coal combustion process at Buck Station was sluiced via ash discharge lines to Cell 2. Following construction of Cell 1, sluiced ash was rerouted from Cell 2 to Cell 1. Flow from Cell 1 enters Cell 2 via the Primary Cell Discharge Tower. Flow from Cell 2 enters Cell 3 via the Old Primary Cell Discharge Structure. Flow from Cell 3 discharges to the Yadkin River through the Secondary Cell Discharge Tower. The approximate pond elevations for the three ash basin cells are: Cell 1 —elevation 705 feet; Cell 2 —elevation 682 feet; and Cell 3 —elevation 674 feet. The elevation of the Yadkin River near the site is approximately 624 feet. The area contained within the waste boundary for Cell 1 encompasses approximately 90 acres. For purposes of delineating the waste boundary, Cells 2 and 3 are considered a single unit, with the area contained within this portion of the waste boundary encompassing approximately 80.7 acres. Cell 3 was developed by increasing the elevation of the earthen dike along the Yadkin River and constructing an intermediate dike across the ash placed in Cell 2. The ash basin system was operated as an integral part of the site's wastewater treatment system. During operation of the coal-fired units, the ash basin received variable inflows from the ash removal system and other permitted discharges. The discharge from the ash basin is permitted and regulated by the NCDEQ DWR under Page 4 Duke Energy Carolinas,LLC 12021 Surface Water Protection and Restoration Annual Report NPDES Permit NC0004774. Effluent from the ash basin is discharged through an above- ground cast iron pipe spillway to the Yadkin River. During 2019, Duke Energy made significant progress towards decanting the ash basin as a step towards ultimate closure. Decanting was completed in 2020. House Bill 630 of 2016 required Duke Energy to designate two North Carolina sites for ash beneficial reuse by January 1, 2017 and a third North Carolina site for ash beneficial reuse by July 1, 2017. Duke Energy chose Buck Steam Station as one of the three sites designated for ash recycling in December 2016. A beneficiation system has been constructed to process the ash onsite before shipping it for reuse purposes. The beneficiation ash reprocessing unit at Buck started up in 2020. 2.4 James E. Rogers Energy Complex The James E. Rogers Energy Complex (formerly known as Cliffside Steam Station) is a coal- fired electric generating facility located along the south bank of the Broad River in Rutherford and Cleveland Counties at 573 Duke Power Road, Mooresboro, North Carolina. Rogers Energy Complex currently operates Units 5 and 6 only. The original Units 1-4 began commercial operation in 1940. Units 1-4 were retired in October 2011 and have been decommissioned. The surrounding area generally consists of residential properties, undeveloped land, and the Broad River. Rogers Energy Complex contained three ash basins. The newest ash basin and the Units 1-4 inactive ash basin are located in Cleveland County to the east and southeast of Cliffside Station. The Unit 5 inactive ash basin is located in Rutherford County west of Cliffside Station. The newest ash basin is located approximately 1,700 feet to the east-southeast of Cliffside station adjacent to the Broad River. This ash basin is impounded by earthen dikes located between the west portion of the basin and Suck Creek and between the northeast portion of the basin and the Broad River. The waste boundary associated with this ash basin is approximately 117 acres in area. The approximate maximum full pool water elevation of this ash basin is 770 feet. The main section of the basin was historically operated below 765 feet to leave extra storage capacity during a heavy rain event. The Units 1-4 inactive ash basin is located approximately 400 feet to the southeast of the retired Units 1-4 and approximately 1,300 feet to the northeast of Unit 6, adjacent to the Broad River. The Units 1-4 inactive ash basin is impounded by an earthen dike located along the north and northeast side of the basin. The waste boundary associated with the Units 1-4 inactive ash basin is approximately 14.5 acres in area. The Unit 1-4 inactive ash basin is no longer used to retain storm water or plant process water. The impounded ash material within the inactive basin was capped with a soil cover approximately two-feet thick. Excavation is nearly complete for the Unit 1-4 basin. Two lined retention basins and a Wastewater Treatment Plant are being constructed within the footprint of the former ash basin. The Unit 5 inactive ash basin is located approximately 1,000 feet to the southwest of Unit 5 and approximately 1,000 feet west of Unit 6, south of the Broad River. The Unit 5 inactive ash basin is impounded by two earthen dikes located along the north and northeast sides of the basin. Page 5 • Duke Energy Carolinas,LLC 12021 Surface Water Protection and Restoration Annual Report The waste boundary associated with the Unit 5 inactive ash basin is approximately 58 acres in area. The ash basin system has been an integral part of the Rogers Station's wastewater treatment system, which has received historic inflows from the ash removal system, station yard drain sump, stormwater flows, and station wastewater. All wastewater inflows to the ash basin were ceased in 2019. Wastewater is now routed to a newly commissioned wastewater treatment system. The facility began the permitted activity of decanting the ash basin in 2019 and completed decanting in 2020. Ceasing inflows and decanting are the first steps towards closure of the basin. Effluent from the ash basin system is permitted and regulated by NPDES permit number NC0005088. Effluent from the treatment system is discharged from the active basin to the Broad River through a concrete inlet structure at the left abutment of the downstream dam. The inlet structure discharges through two 42" RCP Pipes that combine into a single 48" RCP pipe that runs along the access road at the left abutment and then into a concrete discharge structure that discharges to the Broad River. 2.5 Dan River Steam Station Dan River Steam Station (Dan River Station) was a coal-fired generating facility located near the town of Eden in Rockingham County, North Carolina. The three-unit station began commercial operation in 1949. All three coal-fired units, along with three oil-fired combustion turbine units, were retired in 2012 and have been decommissioned. The Dan River Combined Cycle Station (DRCCS), a 620-megawatt natural gas-fired facility, began commercial operations on site on December 10, 2012. The Dan River site is located on the north bank of the Dan River, and the surrounding area generally consists of undeveloped and agricultural land, the Dan River, and a small number of residential properties. The ash basin system was located adjacent to the Dan River and consisted of a Primary Cell, a Secondary Cell, and associated embankments and outlet works. The ash basin was impounded by earthen dikes, and an earthen/ash divider dike separates the Primary Cell from the Secondary Cell. The Primary Cell had a surface area of approximately 21.8 acres. The Secondary Cell had a surface area of approximately 12.2 acres. The original ash basin was constructed in 1956 with an approximate crest elevation of 525 feet. In 1968 and 1969, the ash storage basin was expanded to cover the area occupied today. At that time, the dikes were raised to an approximate elevation of 530 feet. In 1976 and 1977, the intermediate dike was constructed to stage sluicing by subdividing the basin into a Primary Cell and Secondary Cell. The intermediate dike and new Primary Cell dikes were vertically expanded through inward dike construction, where the outward dike slope was maintained and extended upward to the dike crest. Through inward dike construction, portions of the main dike were constructed over ash. The intermediate dike was also constructed over ash. In 1980, newer dikes, referenced as the dredge dikes, were constructed north of the Primary and Secondary Cells, creating a dredge pond and two dry storage areas. Ash was dredged to the southernmost portion of the northern ash fill, and free liquids were allowed to gravity drain to the topographically lower dredge pond located between the dry storage areas. Once dewatered, Page 6 Duke Energy Carolinas, LLC 12021 Surface Water Protection and Restoration Annual Report ash was transported and placed dry in the two dry storage areas known as Ash Fill 1 and Ash Fill 2. The placement of ash in the ash storage areas occurred during multiple projects. The ash basin was operated as an integral part of the site's wastewater treatment system. During operation of the coal-fired units, the ash basin received variable inflows from the ash removal system, station yard drain sump, stormwater flows, and other permitted discharges. The coal ash was sluiced to the southwest corner of the Primary Cell on a variable basis (i.e , dependent on Dan River Station operations) via sluice pipes. Removal of CCR material from Ash Stack 1 was completed on July 27, 2017, The CCR material was hauled off site for disposal or reuse until the onsite landfill became operational The Ash Basin has been excavated and is no longer in service and all CCR surface impoundments have now reached a Clean Closure status as of March 2, 2021. 2.6 Marshall Steam Station Marshall Steam Station (Marshall Station) is a four-unit, co-fired electric generating plant with a capacity of 2,090 megawatts located in Catawba County, North Carolina, near the community of Terrell. The site is located north of NC Hwy 150, east of Sherrills Ford Road and south of Island Point Road, and the surrounding area generally consists of residential properties, undeveloped land, and Lake Norman. The ash basin system consists of a single cell impounded by an earthen dike located on the southeast end of the ash basin. The ash basin system was constructed in 1965 and is located approximately 2,000 feet northeast of Marshall Station. The full pond elevation for the Marshall Steam Station ash basin is approximately 790 feet. The normal pond elevation of Lake Norman is approximately 760 feet. The ash basin was operated as an integral part of Marshall Steam Station's wastewater treatment system and receives inflows from the ash removal system, coal pile runoff, landfill leachate, FGD wastewater, the station yard drain sump, stormwater flows, and station wastewater. All wastewater inflows to the ash basin were ceased in 2019. Wastewater is now routed to a newly commissioned Lined retention basin. The facility began the permitted activity of decanting the ash basin in 2019 and completed decanting in 2020. Ceasing inflows and decanting are the first steps towards closure of the basin. The discharge from the ash basin is permitted and regulated by NPDES permit number NC0004987. Treated effluent is released through a 36-inch HDPE pipe into Lake Norman. 2.7 Riverbend Steam Station Riverbend Steam Station (Riverbend Station) is a former coal-fired electric generating facility which had a capacity of 454 megawatts located near the town of Mt. Holly in Gaston County, North Carolina. As of April 2013, all of the coal-fired units have been retired. The seven-unit station began commercial operation in 1929 with two units and then expanded to seven by 1954. During its final years of operation, Riverbend Station was considered a cycling station and was brought online to supplement energy supply when electricity demand was at its highest. Page 7 Duke Energy Carolinas, LLC 12021 Surface Water Protection and Restoration Annual Report The ash basin area is located approximately 2,400 feet to the northeast of the power plant, adjacent to Mountain Island Lake The ash basin system consisted of a Primary Cell and a Secondary Cell, separated by an intermediate dike. The ash basin at Riverbend Station originally consisted of a single-cell basin commissioned in 1957 and was expanded in 1979. The single basin was divided by constructing a divider dike to form two separate cells in 1986.The Primary Cell is impounded by an earthen embankment dike, referred to as Dam #1 (Primary), located on the west side of the Primary Cell. The Secondary Cell is impounded by an earthen embankment dike, referred to as Dam #2 (Secondary), located along the northeast side of the Secondary Cell. The toe areas for both dikes are in close proximity to Mountain Island Lake. The surface area of the Primary Cell was approximately 41 acres and had an approximate maximum pond elevation of 724 feet during normal, historic operations. The surface area of the Secondary Cell was approximately 28 acres and had an approximate pond maximum elevation of 714 feet during normal, historic operations. The full pond elevation of Mountain Island Lake is approximately 647 feet. The ash basin system was an integral part of Riverbend Station's wastewater treatment system, which predominantly received inflows from the ash removal system, station yard drain sump, and stormwater flows. Before the Riverbend Station was retired, inflows to the ash basin were variable due to the cyclical nature of station operations. The inflows from the ash removal system and the station yard drain sump are discharged through sluice lines into the Primary Cell. Discharge from the Primary Cell to the Secondary Cell was through a concrete discharge tower located near the divider dike. The Riverbend Station is retired, and the ash basin system has been excavated and no longer discharges to Mountain Island Lake through the concrete discharge tower. A wastewater treatment facility was constructed and began operations in 2016 to assist in decanting and dewatering efforts as part of ash basin closure activities. Ash excavation at Riverbend Station began in 2015 with excavation from the Ash Storage Area, and excavation of ash from the Primary Cell began in late 2016. Bulk dewatering was completed in February 2017 and the intermediate dam was decommissioned in March 2017. The primary dam was lowered 10 feet in December 2017 in order to access and excavate ash underlying the dam material. Excavation of the ash basin was completed in 2019 and final decommissioning activities have been completed. Page 8 Duke Energy Carolinas,LLC 12021 Surface Water Protection and Restoration Annual Report Section 3 — Surface Water Sampling Summary The NPDES program regulates wastewater discharges from ash basins to surface waters to ensure that surface water quality standards are maintained. Surface water discharges are identified and evaluated to locatepotential outfalls for inclusion in the permit. The NPDES permitting program requires that permits be renewed at least every five years. Routine surface water monitoring was performed in 2021 in accordance with each site's NPDES permit conditions and CAMA. Table 3-1 below summarizes the 2021 routine surface water quality sampling conducted at the seven Duke Energy Carolinas, LLC coal-fired steam stations described in Section 2. Sample results are submitted to the Department of Environmental Quality in accordance with timelines and procedures identified in each site's respective NPDES permit. Some additional site-specific sampling events were undertaken associated with the requirements of various consent orders and groundwater to surface water interaction demonstrations. Those results were also submitted to the Department in accordance with the requirement timeframes and protocols. Table 3-1. Duke Energy Coal-Fired Steam Stations 2021 Surface Water Quality Sampling Station Water Quality' Water Chemistry2 Trace Elements' Allen Station X X Fish muscle tissues Belews Creek Station X X Fish muscle tissues Buck Station X X Fish muscle tissues Rogers Steam Station X X Fish muscle tissues Dan River Station X X Fish muscle tissues Marshall Station X X Fish muscle tissues Riverbend Station X X Fish muscle tissues 'Temperature, dissolved oxygen, conductivity, pH, secchi disk transparency depth (at lake stations only). Page 9 Duke Energy Carolinas,LLC 12021 Surface Water Protection and Restoration Annual Report 2 Water Chemistry constituents analyzed U) 0 o :2 E U) c ma I- a) c j -c3 L N a) O E E (Du) i >, a) N o o = co z 1 m o E m c o � UU) coo E ai L Z .E is o b -o o m -0 3 c o Q E — c o E m -o_ co cn c n- Z a) o .c �o o E '� E . .� 2 -0 O O fl' ` c C . m > 'X -a To L 32 .J +.. � - C ca cL. Q O C fU �p Y N U N (0 N E H H H U o) m` U Q < F co o- m m Ooo. U 0 0 0 li 2 Fo- Z I° U) H H N I I° H Z < Y Allen XXXXXXX XXXXXX XX XXXXXXXXXXXXXXXX Belews XXXXXX XXXXXXX XX XXX X XXXXXXXXXXX Creek Buck XXXXX XXXX X XXX X XXX XX XXXXXXXX Dan River XXXXX XXXXXXX XX XXXXX XXXXXXXXXX X Rogers XXXXXX X XX X XX XXXXXXXX XXXXXXX (Cliffside) Marshall X X X X X X XX XXX XX XXX X XXXXXXXXXX Riverbend XXXXX XXXXXXX XXXXXXX XXX XXXXXX Page 10 Duke Energy Carolinas,LLC 12021 Surface Water Protection and Restoration Annual Report Section 4 — Surface Water Protection and Restoration Summary In 2021, Duke Energy identified and submitted several documents and undertook a number of actions to comply with the CAMA requirements. Documents submitted and additional activities of note undertaken are listed below: • Conducted weekly and annual dam inspections. • Retirement of Allen Units 2, 3, and 4. • Completed removal of ash from all CCR impoundments at Riverbend and Dan River Stations. • Received Conditional Approval of Groundwater Corrective Action Plans for: Allen, Belews Creek, Roders (Cliffside), Dan River, Marshall, and Riverbend • Excavation of Rodgers (Cliffside) Station Unit 5 Inactive Ash Basin began on June 10, 2021. • A total of 454,713 tons of ash been removed from the inactive ash basin at Rogers (Cliffside) Station as of December 2, 2021. • New landfills approved at Allen and Belews Creek Stations. • Approval received to allow up to 10% bottom ash transport water to be purged as allowed under the ELG regulations. • Received and began implementation of NPDES permit modifications for Marshall and Rogers (Cliffside) Stations. • Continued implementation of NPDES permit coverage for industrial stormwater discharges at all sites. • Completed a number of conservation and recreation projects identified as part of the Dan River Natural Resource Damage Assessment and Restoration (NRDAR) process the company initiated following the February 2014 Dan River coal ash release. • Completed decanting of ash basins at Allen, Buck, Belews Creek, Marshall and Rogers. • Completed construction of ash beneficiation facility at Buck, H.F. Lee, and Cape Fear stations. • Completed work to allow for co-firing of natural gas at Belews Creek and Marshall stations. • The beneficiation units at Buck, HF Lee, and Cape Fear are all commercial. • Dan River and Riverbend have met all CAMA closure requirements • A total of 550,000 cubic yards of ash have been excavated from Marshall ash basin as of December 31, 2021, • Finally, the Special Order of Consent for Belews Creek (EMC-SOC-WQ S18-004) and Allen, Marshall, and Rogers (EMC-SOC-WQ S17-009) were all terminated during the reporting period. Upcoming commitments and activities related to the CAMA include: Page 12 Duke Energy Carolinas, LLC 12021 Surface Water Protection and Restoration Annual Report • Close basins as required by CAMA and in accordance with performance standards set out in the federal coal combustion residuals rule to the extent of its applicability to a particular station. Section 5 — Discharge Identification Status The Discharge Identification Plans submitted in September 2014 for all seven (7) DEC sites addressed the requirements of N.C.G.S. § 130A-309.212(d), Identification and assessment of discharges; correction of unpermitted discharges. Inspection procedures developed to satisfy the requirements of N.C.G.S. § 130A-309.212(d) were presented in these plans and used as the basis for developing the topographic map required by N.C.G.S § 130A-309.212(a)(2). These documents were submitted to DEQ on September 30, 2014 for all seven (7) DEC stations described in Section 2. In 2019, Duke Energy implemented the procedures outlined in the previously submitted Discharge Identification plans. Special orders by Consent issued by the North Carolina Environmental management Commission for DEC stations govern required activities for future identification of discharges Section 6 — Discharge Assessment Status Duke Energy submitted the required Topographic Map and Discharge Assessment Plans to DEQ on December 30, 2014. The plan addressed the requirements of N.C.G.S. § 130A- 309.212(a)(2), topographic map, and (b), Assessment of Discharges from Coal Combustion Residuals Surface Impoundments to the Surface Waters of the State. The elements required in N.C.G.S. § 130A-309.212(a) were incorporated into the plan. These documents were submitted to DEQ on December 30, 2014 for all seven (7) stations described in Section 2. During 2019, Duke Energy provided sampling data to DEQ of potential discharges from coal combustion residuals surface impoundments. Duke Energy participated in numerous meetings and site visits with DEQ staff in evaluating such potential discharges. Special Orders by Consent issued by the North Carolina Environmental Management Commission for DEC stations govern required activities for future handling of discharges. Page 13