NC0003417_Seep Management Amendment to Closure Plan_20220225

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DUKE Jessica L.Bednarcik
Senior Vice President
ENERGY® Environmental,Health&Safety,
Coal Combustion Products
526 S.Church Street
Mail Code:EC3XP
Charlotte, NC 28202
[phone]
February 23, 2022
Via Overnight Mail RECEIVED
EB 2 5 2022
Sushma Masemore, P.E.
Assistant Secretary NC�EQ/�WF�/NP�E$
North Carolina Department of Environmental Quality
217 West Jones Street
Raleigh, NC 27603
Subject: Report Under Special Order by Consent—EMC SOC WQ S 18-006
Duke Energy Progress, LLC—H. F. Lee Steam Electric Plant
NPDES Permit NC0003417
Wayne County
Seep Management Amendment to Closure Plan
Dear Assistant Secretary Masemore:
On behalf of Duke Energy Progress, LLC (DEP), I am submitting to you the Seep Management
Amendment to Closure Plan as required by Section 2.b.7 of the H.F. Lee Steam Electric Plant's
Special Order by Consent(SOC),SOC No. S 18-006. This report follows the Seep Characterization
Report submitted on December 28, 2021 and addresses management of non-dispositioned seeps
associated with the ash basins at H.F Lee.
Please direct any questions about this submittal to Shannon Langley at [phone].
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.

I f
Sincerely
F
essica L. Bednarcik
Senior Vice President
Environment, Health & Safety and Coal Combustion Products
Attachment:
HF Lee Steam Electric Plant Seep Management Plan Amendment to Closure Plan
cc: Jim Wells, Duke Energy
Ed Sullivan, Duke Energy
Matt Hanchey, Duke Energy
Richard Baker, Duke Energy
Shannon Langley, Duke Energy
Joyce Dishmon, Duke Energy
John Toepfer, Duke Energy
Mike Graham, Duke Energy
Danny Smith, NCDEQ
1617 Mail Service Center
Raleigh, NC 27699-1617
Ed Mussler, NCDEQ
1646 Mail Service Center
Raleigh, NC 27699-1646
Bob Sledge, NCDEQ
1617 Mail Service Center
Raleigh, NC 27699-1617
David May, DEQ
943 Washington Square Mall
Washington, NC 27889

t
synTerra Science & Engineering Consultants
synterracorp.com
SEEP MANAGEMENT PLAN
AMENDMENT TO THE CLOSURE PLAN
H.F. LEE ENERGY COMPLEX
SOC WQ S18-006
1199 BLACK JACK CHURCH ROAD
GOLDSBORO, NC 27530
FEBRUARY 2022
PREPARED FOR
f•� DUK
ENEREGY
PROGRESS
DUKE ENERGY PROGRESS, LLC
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Kathy Webb Tim Grant
t Senior Peer Review Senior Scientist
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Kelly Ferri
Project Manager

1 T
Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
EXECUTIVE SUMMARY
SynTerra prepared this Seep Management Plan Amendment to the Closure Plan (Wood, 2019)
pertaining to the Active Ash Basin (AAB), the Inactive Ash Basins (IAB), and the Lay of the Land
Area (LOLA) at the H.F. Lee Energy Complex(H.F. Lee or Site)to describe plans for the
management of identified seeps in a manner that protects public health, safety and welfare,
the environment, and natural resources.This amendment to the closure plan was prepared on
behalf of Duke Energy Progress, LLC (Duke Energy). Corrective action beyond the planned
closure of the ash basins and LOLA may not be necessary for seeps at H.F. Lee.
Special Order by Consent (SOC) WQ S18-006, approved on January 11, 2019, addresses the
management of seeps during the process of basin closure under the Coal Ash Management Act
of 2014, North Carolina General Statutes 130A-309.200 through 130A-309.231, and the federal
Coal Combustion Residuals (CCR) Rule, 40 CFR Parts 257 and 261. Section 2.b.7 of the SOC
states:
Within 60 days of the submittal of the Seep Characterization Report, Duke Energy
shall submit a complete and adequate proposed amendment to the groundwater
Corrective Action Plan and/or Closure Plan as appropriate for the Facility
describing how any seeps identified in the Seep Characterization Report will be
managed in a manner that will be sufficient to protect public health, safety, and
welfare, the environment, and natural resources...
The Seep Characterization Report (SynTerra, 2021) identified nine non-dispositioned seeps
associated with the AAB, IABs, and LOLA (presented below by associated source area) that
require a
management plan:
g
Active Ash Basin
• S-08, located on the east side of the AAB, is a low flow seep that flows into the
perimeter ditch. S-08 was not sampled during the seep characterization sampling event
because of insufficient flow.
• S-23 and S-24 are located south of the AAB and flow to the Neuse River. Seep
characterization analytical results indicate that total arsenic, hardness, and total
dissolved solids (TDS) concentrations are greater than North Carolina Administrative
Code, Title 15A, Subchapter 02B, Surface Water and Wetland Standards (02B) standards.
However, the quarterly SOC monitoring data collected at instream monitoring locations
Downstream Neuse River and Downstream 2 Neuse River (located downstream of those
seep discharges) indicate that all Attachment B constituents are less than their
respective 02B standards.
February 2022
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
• S-22, S-25, and S-26 are low flow seeps located on the south side of the AAB between
the ash basin and the Neuse River. These seeps were not sampled during the seep
characterization sampling event because of insufficient flow.
Inactive Ash Basin
• Ponded water at S-18 on the east side of the IABs has been observed to be flowing to
the Neuse River in past events. S-18 was not sampled during the seep characterization
sampling event because of insufficient flow.
Lay of Land Area
• LOLA S-01A and LOLA S-01B, located north of the LOLA, are low flow seeps that flow
toward the Neuse River. Flow at these locations was insufficient to collect a sample
during the seep characterization sampling event.
Duke Energy continues to implement ash basin closure and corrective action activities that
affect groundwater seepage in a manner that is protective of public health, safety and welfare,
the environment, and natural resources. Completed, ongoing, and planned corrective action
and closure activities include:
Year Closure or Corrective Action Activity
2016-2018 Active Ash Basin decanting
2019-2020 Active Ash Basin dewatering
2022 Submit Groundwater Corrective Action Plan Update
Dewatering,excavation,and closure of the AAB
2020—2035
Excavation of the IABs and LOLA
Evaluation of constituent concentrations at seep locations using the Mann-Kendall trend test
demonstrates predominantly stable and decreasing trends. This evaluation indicates that the
system has been geochemically stable prior to, and since, implementation of ash basin closure
activities.
Based on findings from seep characterization (SynTerra, 2021), the following corrective action
strategies are planned to manage the remaining non-dispositioned seeps.
Seep Corrective Action Strategy
Active Ash Basin
S-08,S-22,S- AAB dewatering and excavation is anticipated to reduce or eliminate flow from these seeps.
23, S-24,S-25, Furthermore,basin closure will remove the source of potential CCR constituents in these seeps.
and S-26 Additional corrective action for these locations is not anticipated.
February 2022 Page ES-2
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
Seep Corrective Action Strategy
Inactive Ash Basin
IAB excavation might reduce flow at this location.Closure of the IAB will remove the source of
S-18 potential CCR constituents in the seep.Additional corrective action for this location is not
anticipated.
Lay of Land Area
LOLA S-01A
and LOLA S LOLA excavation will remove the source of potential CCR constituents at these locations.
and Additional corrective action for these locations is not anticipated.
Non-dispositioned seeps are scheduled to be monitored as required by the SOC until
termination of the SOC by the Division of Water Resources (DWR), or no later than February 28,
2023. Upon termination of the SOC, continued (effectiveness) monitoring of remaining non-
dispositioned seeplocations is recommended until closure of the ash basins is complete, or
until a seep is dry for two consecutive sampling events, or data indicate a seep does not contain
constituents associated with the ash basins at concentrations greater than 02B standards from
two consecutive sampling events. Seeps would be monitored on a semiannual basis consistent
with the nearby groundwater monitoring network to correlate changing water quality and
geochemical conditions. It is anticipated that seep monitoring would be discussed and new data
would be evaluated in Annual Groundwater and Surface Water Monitoring Reports.
February 2022 Page ES-3
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
TABLE OF CONTENTS
SECTION PAGE
EXECUTIVE SUMMARY ES-1
1.0 INTRODUCTION 1-1
1.1 Background 1-1
1.2 Purpose and Scope 1-1
1.3 Previous Reporting 1-2
2.0 OVERVIEW OF SEEPS PROPOSED FOR MANAGEMENT 2-1
2.1 Seeps Associated with the Active Ash Basin 2-1
2.2 Seeps Associated with the Inactive Ash Basins 2-2
2.3 Seeps Associated with the Lay of Land Area 2-2
3.0 PROPOSED SEEP MONITORING PLAN 3-1
3.1 Seeps Associated with the Ash Basins 3-1
3.2 Nature and Extent of Source Related Constituents and Seeps 3-1
3.3 Ash Basin Closure and Corrective Action 3-3
3.4 Mann-Kendall Trend Test Analysis 3-4
3.5 Seep Corrective Action Strategy 3-4
3.6 Seep Monitoring 3-5
4.0 REFERENCES 4-1
LIST OF FIGURES
Figure 1-1 Site Location Map
Figure 2-1 Existing Seep Locations and Inspection Areas
Figure 3-1 Proposed Seep Dispositional Status, Locations, and Inspection Areas
Figure 3-2 Conceptual Site Model - Boron
LIST OF TABLES
Table 2-1 Seep Status Summary
Table 3-1 Seep Characterization Sampling Results—October 2021
LIST OF APPENDICES
Appendix A SOC WQ S18-006
Appendix B Mann-Kendall Trend Test Analysis, February 2022
February 2022 Page i
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress,LLC
Goldsboro, North Carolina
LIST OF ACRONYMS
02B North Carolina Administrative Code, Title 15A, Subchapter 02B, Surface
Water and Wetland Standards
02L North Carolina Administrative Code, Title 15A, Subchapter 02L, Groundwater
Standards
µg/L micrograms per liter
AAB Active Ash Basin
CCR coal combustion residual
COI constituents of interest
DWR Division of Water Resources
Duke Energy Duke Energy Progress, LLC
IMAC interim maximum allowable concentration
IAB Inactive Ash Basin
LOLA Lay of the Land Area
mg/L milligrams per liter
NCDEQ North Carolina Department of Environmental Quality
NPDES National Pollutant Discharge Elimination System
Site/H.F. Lee H.F. Lee Energy Complex
SOC Special Order by Consent
TDS total dissolved solids
WOS Waters of the State
WOTUS Waters of the United States
February 2022 Page ii
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
1.0 INTRODUCTION
SynTerra prepared this Seep Management Plan Amendment to the Closure Plan (Wood, 2019)
pertaining to the Active Ash Basin (AAB), Inactive Ash Basins (IABs), and Lay of the Land Area
(LOLA) at the H.F. Lee Energy Complex(H.F. Lee or Site) to describe plans to manage identified
seeps in a manner that protects public health, safety and welfare, the environment, and natural
resources. This amendment to the Closure Plan was prepared on behalf of Duke Energy
Progress, LLC (Duke Energy). Corrective action beyond the planned closure of the ash basins
and LOLA may not be necessary for seeps at H.F. Lee.
1.1 Background
Special Order by Consent (SOC) WQ S18-006, approved on January 11, 2019, addresses
management of seeps at the Site during the process of basin closure under the Coal Ash
Management Act of 2014, North Carolina General Statutes 130A-309.200 through 130A-
309.231, and the federal Coal Combustion Residuals (CCR) Rule, 40 CFR Parts 257 and 261. The
SOC is provided in Appendix A.
Ash was sluiced to the AAB from approximately 1982 until 2012, when the coal-fired plant was
decommissioned. Despite the name, the AAB no longer receives coal ash, and the Site no longer
generates coal ash. In preparation for ash basin closure, wastewater inflows ceased in 2012 and
decanting of free water from the AAB began in April 2016 and was completed in November
2018. Dewatering of ash pore water began in July 2019 and is ongoing. Excavation of the AAB
began in September 2020.
The Inactive Ash Basins (IAB) consist of IAB 1, IAB 2, and IAB 3 and are located across the Neuse
River, west of Plant operations. Sluicing to IABs 1 and 2 began in the early 1950s and ended in
1969. IAB 3 was used from approximately 1962 until 1982.The three IABs are covered with
mature forest. Precipitation collects on the interior portion of the basins.There are currently no
outfall structures, although two are permitted by the modified National Pollutant Discharge
Elimination System (NPDES) permit dated February 28, 2020. No decanting is required for the
IABs, and construction activities to prepare for excavation are underway.
The LOLA is an area of approximately 7 acres located adjacent to the cooling pond and east of
the former coal-fired operations area and coal pile. The LOLA received coal ash during the early
years of Plant operation prior to the use of the IABs. The LOLA is separated from the AAB by the
Neuse River. No decanting is required in the LOLA.
A site location map is provided on Figure 1-1.
1.2 Purpose and Scope
As required in Section 2.b.7 of the SOC, SynTerra is providing this Seep Management Plan
Amendment to the Closure Plan to describe plans to manage seeps identified in the Seep
Characterization Report(SynTerra, 2021) in a manner that will protect public health, safety, and
February 2022 Page 1-1
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
welfare, the environment, and natural resources.The Seep Characterization Report evaluated
seeps based on the physical status, chemical composition, and jurisdictional determination. To
be considered for corrective action in this Seep Management Plan, a seep must:
1) Be non-dispositioned
2) Constitute, or flow to Waters of the State (WOS) or Waters of the United States
(WOTUS)
3) Exhibit constituent concentrations that are greater than applicable North Carolina
Administrative Code (NCAC), Title 15A, Subchapter 02B, Surface Water and Wetland
Standards (02B)
1.3 Previous Reporting
Detailed descriptions of previous Site SOC assessments and characterizations are documented
in the following:
• 2019 Annual Seep Report, H.F. Lee Energy Complex—SynTerra, April 2020
• 2020 Annual Seep Report, H.F. Lee Energy Complex—SynTerra, April 2021
• Comprehensive Site Assessment Update, H.F. Lee Energy Complex—SynTerra, December
2020
• Final Seep Report, H.F. Lee Energy Complex—SynTerra, October 2021
• Seep Characterization Report, H.F. Lee Energy Complex—SynTerra, December 2021
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
2.0 OVERVIEW OF SEEPS PROPOSED FOR MANAGEMENT
According to the SOC, there are 22 identified non-constructed seeps associated with the AAB,
the IABs, and the LOLA. Of those 22 non-constructed seeps, four seeps (5-05, 5-19, 5-20, and S-
21) were dispositioned at the issuance of the SOC. Nine seeps (S-01, S-02, 5-04, 5-06, 5-27, 5-28,
and 5-29) were proposed to be dispositioned in the Seep Characterization Report(SynTerra,
2021). Nine non-constructed seeps remain non-dispositioned. Seep descriptions and statuses
are provided in Table 2-1. The remaining non-dispositioned seeps identified in the SOC are
described below.
2.1 Seeps Associated with the Active Ash Basin
The following seeps are associated with the AAB and are depicted on Figure 2-1:
• 5-23 and S-24 are low flow seeps located on the south side of the AAB between the ash
basin and the Neuse River. Flow at those seeps has decreased because of ash basin
decanting and dewatering based on inspection observations. Seep characterization
analytical results indicate that total arsenic, hardness, and total dissolved solids
concentrations are greater than 02B standards. However, the quarterly SOC monitoring
data collected at instream monitoring locations Downstream Neuse River and
Downstream 2 Neuse River located downstream of those seep discharges indicate that
all Attachment B constituents are less than their respective 02B standards. Seep flow at
S-23 during the seep characterization sampling event was estimated to be 4 gallons per
minute. Seep flow at S-24 during the seep characterization sampling event was
estimated to be 2.1 gallons per minute.
• S-08, located on the east side of the AAB, is a low flow seep that flows into the
perimeter ditch. Flow at 5-08 has decreased because of ash basin decanting and
dewatering based on inspection observations. S-08 was not sampled during the seep
characterization sampling event because of insufficient flow.
• S-22, S-25, and S-26 are low flow seeps located on the south side of the AAB, between
the ash basin and the Neuse River. Flow at those seeps has decreased because of ash
basin decanting and dewatering based on inspection observations. 5-22, S-25, and S-26
were not sampled during the seep characterization sampling event because of
insufficient flow.
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
2.2 Seeps Associated with the Inactive Ash Basins
Non-dispositioned seeps associated with the IABs are depicted on Figure 2-1. Ponded water at
S-18 on the east side of IAB 2 has been observed to be flowing to the Neuse River in past
events. Flow at 5-18 was insufficient to collect a sample during the seep characterization
sampling event.
2.3 Seeps Associated with the Lay of Land Area
Non-dispositioned seeps associated with the LOLA are depicted on Figure 2-1. LOLA S-01A is
located to the east of the LOLA, and LOLA S-01B is located to the north of the LOLA. Both are
low flow seeps that flow toward the Neuse River. Flow at these locations was insufficient to
collect a sample during the seep characterization sampling event.
February 2022 Page 2-2
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress,LLC
Goldsboro, North Carolina
3.0 PROPOSED SEEP MONITORING PLAN
3.1 Seeps Associated with the Ash Basins
With concurrence from the North Carolina Department of Environmental Quality(NCDEQ) DWR
on seep jurisdictional and dispositional status and upon termination of the SOC, effectiveness
monitoring of the nine non-dispositioned seeps (5-08, S-18, 5-22, 5-23, S-24, S-25, 5-26, LOLA S-
01A, and LOLA S-01B) is recommended until closure of the associated ash basin/LOLA is
complete, or until a seep is dry for two consecutive sample events, or sample data from two
consecutive sampling events indicate seep discharges do not contain constituents associated
with ash basins and concentrations are less than 02B standards. Seeps proposed for disposition
within the Seep Characterization Report and non-dispositioned seeps are depicted on
Figure 3-1.
Duke Energy continues to implement ash basin closure activities to reduce groundwater
seepage. Source control is the primary remedy for managing seeps associated with the ash
basins and LOLA. Source control is conducted in a manner that is protective of public health,
safety, and welfare; the environment; and natural resources. Completed and ongoing ash basin
closure activities, implemented by Duke Energy, are detailed in Section 3.3. The nature and
extent of identified seeps, effects of ash basin closure, and details about proposed monitoring
are discussed in the following subsections.
3.2 Nature and Extent of Source Related Constituents and Seeps
Based on groundwater data collected through May 2020, constituents of interest (COls)
associated with the ash basins and the LOLA include (SynTerra, 2020):
• Arsenic • Iron • Strontium
• Barium • Lithium • Total dissolved solids (TDS)
• Boron • Manganese • Vanadium
• Cadmium • Molybdenum
• Cobalt • pH
Of those COIs, arsenic (total), barium, boron, pH, and total dissolved solids (TDS) are SOC
Attachment B surface water constituents with 02B standards or in-stream target values.
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
Boron analytical results greater than groundwater background concentrations represent the
extent of affected groundwater (Figure 3-2). Because boron is non-reactive and mobile in
groundwater, it has been identified as a leading-edge indicator and is representative of the
overall plume that contains other COIs greater than comparison criteria [02L standard/Interim
Maximum Allowable Concentration (IMAC) or background concentrations, whichever is
greater]. Boron concentrations found in groundwater at the AAB, the IABs, and the LOLA are
discussed below.
Active Ash Basin
The extent of affected groundwater associated with the AAB is limited to downgradient
areas south of the AAB, between the waste boundary and the Neuse River, and east of the
AAB (Figure 3-2). Groundwater in the AAB area generally flows south toward the Neuse
River.
Inactive Ash Basins
The extent of affected groundwater associated with the IABs is limited to an area beneath
IABs 1 and 2 and east toward the Neuse River and an area beneath IAB 3 (Figure 3-2).
Groundwater in the area of the IABs generally flows east toward the Neuse River, with
localized areas of groundwater flow toward Halfmile Branch.
Lay of Land Area
Boron concentrations in groundwater greater than background values do not form a
discernable plume around the LOLA. Groundwater around the LOLA generally flows north
toward the Neuse River.
The most recent seep sampling event (October 2021) was evaluated in the Seep
Characterization Report(SynTerra, 2021) and results are presented in Table 3-1. LOLA S-01A,
LOLA 5-01B, 5-08, S-18, S-22, 5-25, and S-26 exhibited insufficient flow to collect a sample. A
summary of non-dispositioned seep analytical results pertaining to seeps with SOC Attachment
B constituent concentrations greater than 02B standards during the October 2021 sampling
event is provided in the following table:
February 2022
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
Seep Constituent 02B Standard Concentration Additional Information
Locations
Hardness 100 430 No human health or aquatic life
(mg/L) concern with increased hardness.
Instream monitoring in the Neuse
Arsenic(µg/L) 10 121 River downstream of the Site seep
S-23 discharges(Downstream Neuse
River and Downstream 2 Neuse
River) indicates that SOC
TDS(mg/L) 500 539 Attachment B constituents are less
than their respective 02B
standards.
Hardness(mg/L) 100 397 No human health or aquatic life
concern with increased hardness.
Instream monitoring in the Neuse
Arsenic(µg/L) 10 259 River downstream of the Site seep
5-24 discharges(Downstream Neuse
River and Downstream 2 Neuse
TDS(mg/L) 500 507 River)indicates SOC Attachment B
constituents are less than their
respective 02B standards.
Notes:
ug/L—micrograms per liter
mg/I.—milligrams per liter
TDS—total dissolved solids
3.3 Ash Basin Closure and Corrective Action
Duke Energy continues to implement ash basin closure and corrective action activities that
provide adequate seep management and surface water protection at the Site. Completed,
ongoing, and planned corrective action and closure activities include:
Year Closure or Corrective Action Activity
2016-2018 Active Ash Basin decanting
2019-2020 Active Ash Basin dewatering
2022 Submit Groundwater Corrective Action Plan Update
Dewatering, excavation,and closure of the AAB
2020—2035 Excavation of the IABs and LOLA
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
3.4 Mann-Kendall Trend Test Analysis
The Mann-Kendall trend test (Appendix B) was performed to analyze how constituent
concentrations at seep locations have changed over time. The Mann-Kendall trend test
evaluates data over time to develop a statistical conclusion that pertains to trends —
increasing, decreasing, or stable — of a constituent concentration.
Mann-Kendall trend test results for AAB, IAB, and the LOLA were evaluated together to account
for insufficient data sets for seeps associated with the IABs and LOLA. Results of the Mann-
Kendall trend test indicate the following:
• A statistical conclusion was reached for 127 constituent-location pairs.
• 33 statistical conclusions are associated with field parameters.
• Of the 94 statistical conclusions pertaining to chemical constituents, 49 percent of
constituent concentrations are stable or have statistically significant decreasing trends.
• Of the 94 statistical conclusions pertaining to chemical constituents, 51 percent of
trends could not be analyzed due to greater than 50 percent non-detects.
• Out of 94 statistical conclusions pertaining to chemical constituents, no statistically
significant increasing trends were identified.
Overall, the results of the Mann-Kendall trend test indicate that the system has been
geochemically stable since the implementation of ash basin closure with constituent
concentrations remaining stable or decreasing over time. The Mann-Kendall Trend Test Analysis
report is provided in Appendix B.
3.5 Seep Corrective Action Strategy
To be considered for corrective action, a seep must:
1) Be non-dispositioned
2) Constitute, or flow to WOS or WOTUS
3) Exhibit constituent concentrations that are greater than applicable 02B surface water
standards
Nine non-constructed seeps have been identified based on the criteria above. Based on findings
from Seep Characterization Report(SynTerra, 2021), the following corrective action strategies
are planned to manage the remaining non-dispositioned seeps.
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
Seep Corrective Action Strategy
Active Ash Basin
S-08,5-22,5- AAB dewatering and excavation is anticipated to reduce or eliminate flow from these seeps.
23,5-24,S-25, Furthermore, basin closure will remove the source of potential CCR constituents in these seeps.
and 5-26 Additional corrective action for these locations is not anticipated.
Inactive Ash Basin
IAB excavation might reduce flow at this location. Closure of the IAB will remove the source of
S-18 potential CCR constituents in the seep.Additional corrective action for this location is not
anticipated.
Lay of Land Area
LOLA 5 01A LOLA excavation will remove the source of potential CCR constituents at these locations.
and LOLA S Additional corrective action for these locations is not anticipated.
01B
As described in Section 3.3, ash basin closure and corrective action activities are underway or
planned. Based on those activities and the findings presented in the Seep Characterization
Report(SynTerra, 2021) and in this Seep Management Plan, with DWR concurrence on seep
dispositional status, corrective action beyond the planned closure activities may not be
necessary.
Upon termination of the SOC and discontinuation of the interim action levels established
therein, some constituent concentrations in the AAB perimeter ditch may remain greater than
02B standards. It is recommended that the influence of affected groundwater from the AAB on
the perimeter ditch be evaluated in the forthcoming Groundwater Corrective Action Plan
Update.
3.6 Seep Monitoring
Non-dispositioned seeps are scheduled to be monitored as required by the SOC until
termination of the SOC by DWR, or no later than February 28, 2023. Upon termination of the
SOC, continued (effectiveness) monitoring of remaining, non-dispositioned seep locations is
recommended until closure of the ash basin is complete, or until a seep is dry for two
consecutive sampling events, or data indicate a seep does not contain constituents associated
with the ash basin at concentrations greater than 02B standards from two consecutive sampling
events. Seeps would be monitored on a semiannual basis consistent with the nearby
groundwater monitoring network to correlate changing water quality and geochemical
conditions. It is anticipated that seep monitoring would be discussed, and new data would be
evaluated in Annual Groundwater and Surface Water Monitoring Reports.
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
4.0 REFERENCES
SynTerra (2020). Comprehensive Site Assessment Update - H.F. Lee Energy Complex, December
2020.
SynTerra (2021). Seep Characterization Report- H.F. Lee Energy Complex, December 2021.
Wood. (2019). Closure by Excavation—1982 Ash Basin and Basins 1, 2, and 3 Closure Plan
Report; prepared by Wood Environment & Infrastructure Solutions, Inc. for the Duke
Energy H.F. Lee Energy Complex issued on December 11, 2019, and revised March 5,
2020.
February 2022
Page 4-1

1 i
Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
FIGURES
‘41
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Science & Engineering Consultants

I l
NOTES:
I ALL BOUNDARIES ARE APPROXIMATE.
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2 USGS TOPOGRAPHIC MAP PROVIDED BY ESRI BASEMAP
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ENERGYSEEP MANAGEMENT PLAN AMMENDMENT
f q,-., ��. TO THE CLOSURE PLAN
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LEGEND
' CONSTRUCTED SEEP
iS POSITIONED SEEP
STREAM SURFACE WATER LOCATION PER SOC
/ ACTIVE ASH BASIN BASTE BOUNDARY
INACTIVE ASH BASIN WASTE BOUNDARY
i 3 SOC INSPECTION AREA
LAY OF LA...BOUNDARY
.......
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FIGURE 2-B
\ al a NERGY MI=MilTEE _ EXISTING SEEP LOCATIONS AND INSPECTION AREAS
• SEEP MANAGEMENT PLAN
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— AMENDMENT TO THE CLOSURE PLAN
�,F H.F.LEE ENERGY COMPLEX
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J SPOSiTiONED SEEP
• (STREAM SURFACE WATER LOCATION PER SOC
! 9 THE ASH BASIN WASTE BOUNDARY
NACTNE ASH BASIN WASTE BOUNDARY
•
AREA
fI lnY OF LgND AREA BOUNWRY
w URE EUERGV PROGRESS PROPERTY LINE
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V'ENERGY PROPOSED SEEP DISPOSITIONAL STATUS,
LOCATIONS,AND INSPECTION AREAS
SEEP MANAGEMENT PLAN
`,' AMENDMENT TO THE CLOSURE PLAN
^�•• 0T1-°""r:m, H.F.LEE ENERGY COMPLEX
synTerra www,smmracorP.com GOLDSBORO,NORTH CAROLINA
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j LEGEND
• SEEPS WITH STABLE BORON CONCENTRATION
TREND
/ SEEPS WITH DECREASING BORON
-••• CONCENTRATION TREND
/
• SEEP NOT ANALYZED FOR TRENDS
, INSUFFICIENT SEEP ANALYTICAL DATA TO
I PERFORM TREND ANALYSIS
IN-STREAM SURFACE WATER LOCATION PER
SOC
/ ACTIVE ASH BASIN WASTE BOUNDARY
_ •'-1 INACTIVE ASH BASIN WASTE BOUNDARY
I 1- SOC INSPECTION AREA
.\ LAY OF LAND AREA BOUNDARY
I , ', --DUKE ENERGY PROGRESS PROPERTY LINE
I. STREAM(AMEC NRTR)
,^.. C a:S.S SURFACE WATER FLOW DIRECTION
ow. .oro.." ":• •.r•'"iiiZ cem"wo.."" ``-\ 1 •Ste.•J� I--- •�I GROUNDWATER FLOW DIRECTION
.APPROXIMATE EXTENT OF AFFECTED
- •_•GROUNDWATER
• a r r , o"w n "mr ora.wn mwm"uc."."o..oca.r '• •
-.
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• AMENDMENT TO THE CLOSURE PLAN
M.F.LEE ENERGY COMPLEX
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Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
TABLES
dlibA41114?
synTerra
Science & Engineering Consultants

TABLE 2-1
SEEP STATUS SUMMARY
SEEP MANAGEMENT PLAN AMENDMENT TO
THE CLOSURE PLAN
H.F. LEE ENERGY COMPLEX
DUKE ENERGY PROGRESS, LLC,GOLDSBORO, NC
Seep Associated Source Area Receiving Seep Status
Waterbody
LOLA S-01 LOLA Neuse River Proposed to be dispositioned
LOLA S-01A LOLA Neuse River Non-dispositioned
LOLA S-01B LOLA Neuse River Non-dispositioned
S-01 Active Ash Basin Neuse River Proposed to be dispositioned
S-02 Active Ash Basin Neuse River Proposed to be dispositioned
S-03* Active Ash Basin Neuse River Not a seep per SOC
5-03A* Active Ash Basin Neuse River Not a seep per SOC
5-04 Active Ash Basin Neuse River Proposed to be dispositioned
S-05 Active Ash Basin Neuse River Dispositioned per SOC
5-06 Active Ash Basin Neuse River Proposed to be dispositioned
S-07 Active Ash Basin Neuse River Proposed to be dispositioned
S-08 Active Ash Basin Neuse River Non-dispositioned
S-09* Active Ash Basin Neuse River Not a seep per SOC
S-18 Inactive Ash Basin Neuse River Non-dispositioned
5-19 Inactive Ash Basin Neuse River Dispositioned per SOC
5-20 Inactive Ash Basin Neuse River Dispositioned per SOC
5-21 Active Ash Basin Neuse River Dispositioned per SOC
S-22 Active Ash Basin Neuse River Non-dispositioned
S-23 Active Ash Basin Neuse River Non-dispositioned
S-24 Active Ash Basin Neuse River Non-dispositioned
5-25 Active Ash Basin Neuse River Non-dispositioned
S-26 Active Ash Basin Neuse River Non-dispositioned
S-27 Active Ash Basin Neuse River Proposed to be dispositioned
5-28 Active Ash Basin Neuse River Proposed to be dispositioned
5-29 Active Ash Basin Halfmile Branch Proposed to be dispositioned
Prepared by:KHF Checked by: TCP
Noes;
LOLA-Lay of Land Area
SOC-Special Order by Consent
*Locations S-03,5-03A,and 5-09 are monitoring locations in the Active Ash Basin perimeter ditch,and are not considered seeps by the SOC.
Seeps proposed to be dispositioned were presented in the Seep Characterization Report(SynTerra,2021).
Page 1 of 1

TABLE 3-1
SEEP CHARACTERIZATION SAMPLING RESULTS-OCTOBER 2021
SEEP MANAGEMENT PLAN
AMENDMENT TO THE CLOSURE PLAN
H.F.LEE ENERGY COMPLEX
DUKE ENERGY PROGRESS,LLC,GOLDSBORO,NC
Field parameter. Total concentration _-
Specific Dissolved CY'Y'.ion
Analytical Parameter ph Temperature Conductance grygen RPotentialeduction Ex Turbidity' Flow Arsenic Barium Boron Bromide Cadmium Calcium Chloride Chromium Copper Fluoride Hardness
Parting Units S.U. Dog C pmhos/cm m0/L 'RV mV BTUs GYM pe/L MIA pg/L pg/L pg/L mg/L mg/L pg/L pg/1 mg/L mg/L
IRA NCACDSB(Class C,W5-IV) 8.0-9.0 32 NE 1 NE NE 50 NE 10 1000 7300^ NE NE NE 250 NE NE 1.0 100
Sample Semple
lucatldn le Media LatItede Long.* Collection Analytical Results
Date
Nxrrm xrve Water 35.1e069 -71.06500 10/18/'2021 /.5 II 160 0.05 166 371 12 Xn <1 ]a <50 <100 <0.1 5.12 19 <1 <2 0.12 323
p.nn•Nnn Water 35.36719 -78.00290 10/1e21021 7.6 1g lei 313 135 3e0 21 HM <1 lz <50 <100 <0.1 eJe 39 <t <2 0.12 32 2
Water 35.30117 -70.02213 1021022021 /.4 20 eel 3,0 41 131 100 1 121 405 2010 <100 <0.1 135 12 1.68 <3 0.70 430
S 21 Wafer 35.30106 2007643 10/0022020 /.3 20 24l 4.25 -42 162 36 2., 259 402 2I10 210 <0.1 128 4.5 <1 <2 0.10 397 I
'Oei+lver and turbld0y are not re0ulred parameters per SOL Alter lxronrl B.
'Berney standerdof 0.012 p9/L represents a chronic value.
.e•r r bndard of 10 mg/L represents a nitrate as niwurrr vabm.
�nmin. mNN of 5 VOA represents a chronic value.
'Di.solved msrmrc standard of 150 non represents a chronic value.
'On.mlred chromium standard of tl pg/L represents a chronic value-are<rh+0,dIssolvo chromium(VII.Dissolved
ved chromium standards are hardness depxnd.'nr O m/.salved chromium concentrations from the October 2021 sampling event represent total dissolved chromiu concentrations.
Bald highlighted cells indicate concentrations greater than apple alrin tensely...15 NCAC 02B 03essC,W5.31 stand...
• n s monitoring location per 50C.
.i r..nn target value established per language In 15A NCAC 0211.11202 end.0208.
-oncen ra inn not see greater than adjusted g lieut.
ISA rAC o'2B[Class C.WSCWI[15ANCAC Subchapter 02B Secti n 0200 Standard far Class C,WS-IV Surface Waters
C degrees Celsius
1.1 reduction potential
oxidation
pm minute
N O r n.s. pendent dissolved metal standard
s
P121.0 piYi^/and spate duo failure.
loins:rni morons as0er ssntimeter
ntiHigrions per liter
out riulbvu ins nitrogen per liter
nr
rm.w rl.aile or riot analyzed
Rol.Administrative Code
xN xn ire�r�i,rxa
• Nmilielionetrle Turbidity units
Order CO Consent

•
TABLE 3-1
SEEP CHARACTERIZATION SAMPLING RESULTS-OCTOBER 2021
SEEP MANAGEMENT PLAN
AMENDMENT TO THE CLOSURE PLAN
H.F.LEE ENERGY COMPLEX
DUKE ENERGY PROGRESS,LLC,GOLDSBORO,NC
Tatar Concen melon(Continued) Dissolved concentration
Analytical Parameter Lead rlaseeslirm Mercury' bete a D Sulfate Thallium Total
ole '' Cadmium premium Capper Lead Nickel Zinc
Nickel end SOlaniurn' Dissolved Suspended Zinc Arsenic
Selenium.rvue iSolids Salida (0.65p) (0.e5p) (0.45p) (OASP) ("Sp) (0..0 (0.e5p)
R..Ortins vnita pg/L m0/L Vs/L ps/L m g-N/l m0/L pS/L m0/L pg/l mg/t mO/L p0/L NSA p0/L pig/L VOL p0/L ps/L NSA
UN NCAC OSP(Glass C,WS-IV) NE NI 0.012 25 10 NE 5 250 2^ 500 MS NI 1S0 MO It/MD MD MD ND MO
Legation 10 Medu Latitude Longitude C00.non Analytical Results
HeuzeDownz0.lver' Water 26.70069 -70.06600 10/16/2021 0.28 2.65 0.0011 1.21 0.66 NA <1 16 <0.2 116 NA 5.16 <1 <0,1 <1 <2 <0.2 el <5
Downstreamit
Water 25.36729 -11.00296 10/111/2021 0.104 2.15 0.00294 1.25 0.69 NA <1 16 <0.2 117 NA eS <! <0,1 01 <2 0.691 <t <5
Neuseaver
597 Water 15.261V -76.07712 10/10/2021 LW 22.7 0.00144 1.56 0.06 <5 <1 9.5 <0.2 320 66 946 AO <01 <1 <2 <0.2 <t e5
529 Waver 1516 I06 -70.01641 /16/2021 0.267 19 0.000907 eI 002M <S <I Uea 2 SO7 as <5 eaa e0I el <2 e0.2 <I <5
- Created by/oVNHT Checked by bbs
Notes:
'Clasolved oxygen ant turbidity are notrequired parameters per SOD Attachment B.
standard 0f 0.012 VO/L rapresen a chrons valu3
a nitrite standard of 10 mg/L represents a nitrate as nitrogen value.
'Selenium standard of 5 NWL represents a chronic value.
Ns0lved arsena standard of 1.Ng,represents a chronic value.
'Dissolved chromium standard of 11 Vg/L represents a chronic value specific to dissolved chromium(VII Dissolved chromium(III)standards are hardness-de0endent.Dissolved chromum rnncentratiens Iron the October 202)sampinq event represent total dissolved chromium concentrations.
Sold highlighted cells m&cote concentrations greater than ao0ircabie conservative IS NCAC 025(Class C,WS-IV)Randards.
nr ,beaten per
SOC.
•In-stream target value wtablhhdper Ong..in 16A NUC 025 0202 and NUN
< C.centration
not detected at or greater Man Me dlusted reporting Ilmt.
15A NUCO20(Class C,W5-NI'15A NUC Subchapter 021 Settles 0200 Standard for Class C,WS•IV Surface Waters
Deg C degrees Celsius
Ea'oxidation reduction potential
GPM•gallons per minute
D•hardness dependent dissolved metal standard
• Mena spike/matrix spike duo failure•
mhos/cm emicfemhes per<weeniler
pg/L•micrograms per liter
mg/I.- per liter
mgN/lm milligrams nitrogen per Inter
mNraD
• availabie or not analyzed
NUC•1North Carolina Administrative Code
NE•not established
NM-not measured
NNW•Nephelometrlc Turbidity Units
SOC.Special Order by Comfit
5.U.•standard units
Page z of2

Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
APPENDIX A
SOC WQ S18-006
4.11,
•
411114At°tIt 0
Terra syn
Science & Engineering Consultants

A.... 4%
ROY COOPER ,, (
Governor l-
- 1 jj
d'1
MICHAEL S.REGAN `.� ,
Secretary -b= •`
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
January 11,2019
Mr. Paul Draovitch, Senior Vice President EHS
Duke Energy
526 S. Church Street
Mail Code EC3XP
Charlotte,NC 28202
Subject: SPECIAL ORDER BY CONSENT
SOC No, S18-006
Duke Energy Progress, LLC
H.F. Lee Plant
NPDES Permit NC0003417
Wayne County
Dear Mr. Draovitch:
Attached for your records is a copy of the Special Order by Consent(SOC) approved by the
Environmental Management Commission and signed by the Chairman of the Commission on
January 10, 2019.
The terms and conditions of the SOC are in full effect,including those requiring submittal of
written notice of compliance or non-compliance with any schedule date. The following items are
brought to your attention as they pertain to the terms and conditions of the SOC:
• Payment of the upfront penalty is due no later than February 15,2019.
• Monitoring performed per the terms of the SOC shall commence during the current calendar
quarter(January- March),with results submitted to DWR no later than April 30,2019.
Subsequent monitoring and reporting shall occur as specified in the SOC.
Pursuant to North Carolina General Statute 143-215.3D, water quality fees have been revised to
include an annual fee for activities covered under a Special Order by Consent. Duke Energy will
be subject to a fee of$500.00 on a yearly basis while under the Order. The initial fee payment
will be invoiced at a later date, with future fee invoicing done on an annual basis.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mall Service Center I Raleigh,North Carolina 27699-1617
.cam„V,�.�i�;=
4:.:.b�+ w1ar 919.707.9000

Mr. Paul Draovitch
S 18-006 Transmittal
p. 2
If you have any questions concerning this matter, please contact Bob Sledge at(919) 807-6398.
Sincerely,
r Linda Culpepper
Attachment
cc: Central Files
NPDES Unit—SOC File
ec: Washington Regional Office—DWR/Water Quality Regional Operations
Shannon Langley—Duke Energy
Sara Janovitz—EPA Region 4
Jeff Poupart—DWR/WQPS

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF WAYNE
IN THE MATTER OF )
NORTH CAROLINA ) SPECIAL ORDER BY CONSENT
NPDES PERMIT NC0003417 )
) EMC SOC WQ S18-006
HELD BY )
DUKE ENERGY PROGRESS, LLC )
Pursuant to the provisions of North Carolina General Statutes(G.S.) 143-215.2,this Special
Order by Consent is entered into by Duke Energy Progress, LLC,hereinafter referred to as Duke
Energy, and the North Carolina Environmental Management Commission, an agency of the State
of North Carolina created by G.S. 143B-282, and hereinafter referred to as the Commission.
Duke Energy and the Commission are referred to hereafter collectively as the"Parties."
1. Stipulations: Duke Energy and the Commission hereby stipulate the following:
a. This Special Order by Consent("Special Order") addresses issues related to the
elimination of seeps (as defined in subparagraphs f and g below) from Duke
Energy's coal ash basins during the separate and independent process of basin
closure under the Coal Ash Management Act, G.S. 130A-309.200 through 130A-
309.231 ("CAMA") and the Federal Coal Combustion Residuals Rule,40 CFR
Parts 257 and 261. The Environmental Protection Agency first directed
permitting authorities to consider potential impacts on surface water of seeps from
earthen impoundments in 2010. At that time, Duke Energy began discussions
with the North Carolina Department of Environmental Quality("the
Department")regarding seeps at multiple Duke Energy facilities,including
identifying certain seeps in permit applications and providing data to the
Dept talent regarding seeps. In 2014, Duke Energy provided a comprehensive
evaluation of all areas of wetness and formally applied for NPDES permit
coverage of all seeps. Since 2014, Duke Energy has performed periodic
inspections and promptly notified the Department of new seeps and sought
NPDES permit coverage where appropriate. On March 4, 2016,the Department
issued Notices of Violation("NOVs") to Duke Energy related to seeps.

•
EMC SOC WQ S 18-006
Duke Energy Progress,LLC
p. 2
Both decanting and dewatering of the H. F. Lee Facility's coal ash basins will be
required before the ash basins can be closed. Decanting(i.e.,removal of the free
water on the surface of the coal ash basin), has already been observed to affect
existing seeps at Duke Energy's H. F. Lee Facility. Removal of remaining coal
ash wastewater through continued decanting and dewatering(i.e. removal of
sufficient interstitial water) is expected to substantially reduce or eliminate the
seeps. In order to accomplish this goal of substantially reducing or eliminating
seeps,this Special Order affords certain relief to Duke Energy related to the non-
constructed seeps (as defined in subparagraph g below),while Duke Energy
completes activities associated with closure of the ash basins at the H. F. Lee
Facility. After completion of those activities, for any remaining seeps,Duke
Energy must take appropriate corrective action as specified more fully below.
b. Duke Energy has been issued a North Carolina NPDES permit for operation of an
existing wastewater treatment works at the following electric generation facility
(the "H. F. Lee Facility"):
Permit Issuance Receiving Water
Facility Number County . Date for Primary
Outfall
H. F. Lee NC0003417 Wayne i 07/23/2010 Neuse River
c. The H. F. Lee Facility listed above has ceased coal fired generation and now
consists of a 3 x 1 combined cycle unit capable of being fired on natural gas or
oil, and five simple cycle combustion turbines. The facility's coal ash basins still
exist, and are subject to the provisions of this Special Order.
d. The H.F. Lee Facility also has a permitted wastewater cooling pond that was used
during coal-fired operations,and continues to be used for the combined cycle
plant. Several areas of minor seep flow from the cooling pond to the Neuse River
have been observed. Chemical testing of the cooling pond seeps has revealed
some contain minor concentrations of coal combustion residuals (CCR). The
cooling pond seeps listed in Attachment A are also addressed by this Special
Order.
e. Wastewater treated at coal-fired electric stations includes water mixed with ash
produced through the combustion of coal for the steam generation process. Ash is
controlled and collected through the use of water, creating a slurry that is
conveyed to impoundments or basins with earthen dike walls. In the ash basin,
the solids separate from the liquid portion,with the resulting supernatant
discharged under the terms of the NPDES permit.

EMC SOC WQ S 18-006
Duke Energy Progress,LLC
p. 3
f. The coal ash basins and the cooling pond at the H. F. Lee Facility are unlined,
having no impermeable barrier installed along their floors or sides. Earthen
basins and dike walls are prone to the movement of liquid through porous features
within those structures through a process known as seepage. The H. F. Lee
Facility exhibits locations adjacent to,but beyond the confines of,the coal ash
basins and the cooling pond where seepage of wastewater from those basins may
intermix with groundwater,reach the land surface(or"daylight"), and may flow
from that area. Once such seepage reaches the land surface, it is referred to as a
"seep." Each of the seeps identified at the H. F. Lee Facility and addressed in this
Special Order exhibit some indication of the presence of coal ash wastewater.
Both(a)confirmed seeps and(b)areas identified as potential seeps that were later
dispositioned,are identified in Attachment A.
g. Seeps that are not on or within the dam structure or that do not convey wastewater
via a pipe or constructed channel directly to a receiving stream are referred to as
"non-constructed seeps." Non-constructed seeps at the H. F. Lee Facility often
exhibit low flow volume and may be both transient and seasonal in nature, and
may,for example,manifest as an area of wetness that does not flow to surface
waters,a point of origin of a stream feature,or flow to an existing stream feature.
These circumstances of the non-constructed seeps make them difficult to discern,
characterize,quantify and/or monitor as discrete point source discharges. This
creates challenges in permit development and compliance monitoring because it is
difficult to accurately monitor for flow and discharge characterization. Non-
constructed seeps at the H. F.Lee Facility present significant challenges to their
inclusion in NPDES permits as point source discharges,but they do cause or
contribute to pollution of classified waters of the State. Therefore,these non-
constructed seeps are addressed in this Special Order rather than in an NPDES
permit.
h. Investigations and observations conducted by the Department and U. S.Army
Corps of Engineers staff have concluded that some seeps emanating from Duke
Energy's coal ash ponds create and/or flow into features delineated as classified
waters of the State or Waters of the United States.
Collectively,the volume of non-constructed seeps is generally low compared to
the volume of permitted wastewater discharges at the Duke Energy Facilities.

EMC SOC WQ S18-006
Duke Energy Progress,LLC
p. 4
j. In 2014, Duke Energy conducted a survey of each coal-fired electric generation
station to identify potential seeps from the coal ash surface impoundments. Duke
Energy included all areas of wetness identified around the impoundments as
seeps, and submitted applications to include those seeps in NPDES permits.
Beginning in 2015,Duke Energy has implemented semi-annual surveys to
identify new seeps in the vicinities of the coal ash basins. Additional seeps have
been observed and documented during these surveys and reported to the
Department pursuant to a Discharge Identification Plan mandated by CAMA.
Additional investigation has determined that not all of areas identified in 2014 are
seeps,but each Duke Energy facility does have multiple seeps.
k. The Department issued NOVs to Duke Energy on March 4,2016 for the seeps
that emanate from the unlined coal ash surface impoundments at the Duke Energy
Facilities.
Non-constructed seeps create conditions such that certain surface water quality
standards may not consistently be met at all Duke Energy monitoring sites.
m. The presence of coal ash influenced water in the non-constructed seeps causes or
contributes to pollution of the waters of this State, and Duke Energy is within the
jurisdiction of the Commission as set forth in G.S. Chapter 143, Article 21.
n. A list of seeps identified in the vicinities of the coal ash surface impoundments at
the fl.F. Lee Facility, as well as their locations, and the bodies of water those
seeps may flow into(if applicable), can be found in Attachment A to this Special
Order.
o. Duke Energy must close the coal ash surface impoundments at all North Carolina
coal-fired electric generating stations in accordance with applicable requirements
set out in CAMA and the Federal Coal Combustion Residuals Rule, requirements
of which are independent of the resolution of seeps addressed in this Special
Order.
p. Decanting of wastewater performed at Duke Energy's coal ash basins is expected
to eliminate or substantially reduce the seeps from the ash basins at the Duke
Energy Facilities.
q. Since this Special Order is by consent, the Parties acknowledge that review of the
same is not available to the Parties in the N.C. Office of Administrative Hearings.
Furthermore, neither party shall file a petition for judicial review concerning the
terms of this Special Order.

EMC SOC WQ S18-006
Duke Energy Progress,LLC
P. 5
2. Duke Energy,desiring to resolve the matters causing or contributing to pollution of the
waters of the State described above,hereby agrees to do the following:
a. Penalties
1) Upfront Penalty. As settlement of all alleged violations due to seepage at
these Duke Energy Facilities,pay the Department,by check payable to the
North Carolina Department of Environmental Quality, a penalty in the
amount of$72,000, calculated based upon$6,000 each for twelve non-
constructed seeps identified prior to January 1,2015.
A certified check in the amount of$72,000.00 must be made payable to
the Department of Environmental Quality and sent to the Director of the
Division of Water Resources(DWR)at 1617 Mail Service Center,
Raleigh,North Carolina 27699-1617 by no later than thirty(30)days
following the date on which this Special Order is approved and executed
by the Commission,and received by Duke Energy.
No penalty shall be assessed for seeps identified after December 31, 2014,
given Duke Energy's inclusion of seeps in permit applications and
compliance with the Discharge Identification Plan required under CAMA.
By entering into this Special Order, Duke Energy makes no admission of
liability,violation or wrongdoing. Except as otherwise provided herein,'
payment of the upfront penalty does not absolve Duke Energy of its
responsibility for the occurrence or impacts of any unauthorized
discharges in the area of the Duke Energy Facilities that may be
discovered in the future,nor does the payment preclude DWR from taking
enforcement action for additional violations of the State's environmental
laws.
See especially paragraph 2(a)(2) excepting newly identified seeps from future penalties under
certain conditions.

EMC SOC WQ S 18-006
Duke Energy Progress,LLC
p. 6
2) Stipulated Penalties. Duke Energy agrees that unless excused under
paragraph 5,Duke Energy will pay the Department, by check payable to
the North Carolina Department of Environmental Quality, stipulated
penalties according to the following schedule for failure to perform
activities described in paragraphs 2(b and c), or for failure to comply with
interim action levels listed in Attachment A.
Failure to meet a deadline in the Compliance I $1,000.00/day for the first seven
Schedule in 2(b)of this Special Order days; $2,000.00/day thereafter
Failure to meet any other deadline in this $1,000.00/day for the first seven
Special Order days; $2,000.00/day thereafter
Exceedance of an interim action level listed in $4,500.00 per monitored exceedance
Attachment A
Monitoring frequency violations $1,000.00 per violation
Failure to submit,by the deadline set forth
herein,adequate amendments to groundwater
Corrective Action Plans or Closure Plans to 5 000.00per da to a maxim
um mum of
Y�
address all remaining seeps, through $1,000,000.00.
corrective action as applicable under
paragraph 2(b)(7 i of this Special Order.2
As long as Duke Energy remains in compliance with the terms of this Special Order, as
well as CAMA and conditions of any approvals issued thereunder,the Department shall
not assess civil penalties for newly identified seeps.
b. Compliance Schedule. Duke Energy shall undertake the following activities in
accordance with the indicated time schedule. No later than fourteen(14)calendar
days after any date identified for accomplishment of any activity, Duke Energy
shall submit to the Director of DWR written notice of compliance or
noncompliance therewith. In the case of compliance, the notice shall include the
date compliance was achieved along with supporting documentation if applicable.
In the case of noncompliance,the notice shall include a statement of the reason(s)
for noncompliance, remedial action(s)taken, and a statement identifying the
extent to which subsequent dates or times for accomplishment of listed activities
may be affected.
2 Failure to adequately implement any amended Corrective Action Plan or Closure Plan will be
handled in the normal course.

EMC SOC WQ S 18-006
Duke Energy Progress,LLC
P- 7
Duke Energy is required to comply with the requirements of G.S. § 130A-
309.216. Duke Energy has announced plans to construct an ash beneficiation
plant at the H. F. Lee Facility capable of processing 300,000 tons of CCR material
per year.
1) The Coal Ash Management Act(G.S. § 130A-309.210)required the
cessation of CCR wastewater placement into the basins at the H. F.Lee
Facility by October 1,2014. Duke Energy commenced decanting in April
2016. Decanting will be completed by March 31,2019.
2) Dewatering will be required in order to excavate the ash for the purpose of
beneficiation. Duke Energy will begin the process of removal of
interstitial water from the H.F. Lee Facility no later than July 31, 2019
and will continue as needed to support the beneficiation plant described
above.
3) Once the dewatering process is initiated,within(30) days after the end of
each quarter,Duke Energy shall provide reports on the status of
dewatering work and other activities undertaken with respect to
excavation of each coal ash surface impoundment to DWR. The quarterly
reports are due by April 30, July 30,October 30, and January 30. The
reports are to be submitted as follows: one copy must be mailed to DWR's
Washington Regional Office Supervisor,943 Washington Square Mall,
Washington,NC 27889, and one copy must be mailed to the Water
Quality Permitting Program, Division of Water Resources, 1617 Mail
Service Center,Raleigh NC 27699-1617. The quarterly reporting
requirement shall remain in force until completion of two years of
beneficiation operations.

EMC SOC WQ S 18-006
Duke Energy Progress,LLC
p. 8
4) Duke Energy shall conduct annual comprehensive surveys of areas down
gradient of the ash basins,the Lay of Land Area(LOLA) and the cooling
pond, identifying new seeps, and documenting the physical characteristics
of previously documented seeps. All examinations of seeps must include
identification of seeps by approximate latitude and longitude and date-
stamped digital photographs of their appearance. A report summarizing
the findings of the surveys, including a section analyzing the effect
decanting of the basin(s)has on seep flows, accompanied by copies of the
photographs noted above ("Annual Seep Report"), shall be submitted to
DWR in conjunction with submittal of the April 30 quarterly report noted
in 2(b)(3) above. This Annual Seep Report must list any seep that has
been dispositioned(as described below)during the previous year,
including an analysis of the manner of disposition. For purposes of this
Special Order, "dispositioned" includes the following: (1)the seep is dry
for at least three consecutive quarters; (2)the seep does not constitute, and
does not flow to,waters of the State or Waters of the United States for
three consecutive quarters; (3)the seep is no longer impacted by flow
from any coal ash basin as determined by the Director of DWR in accord
with applicable law and best professional judgment; or(4)the seep has
been otherwise eliminated(e.g.,through an engineering solution). if a
seep that has been dispositioned through drying up reappears in any
subsequent survey,such a seep will no longer be deemed dispositioned
and can be subsequently re-dispositioned as specified above.
5) No later than October 31, 2021 Duke Energy shall conduct a
comprehensive survey of areas down gradient of ash basins at the 1-l. F.
Lee Facility, identifying new seeps, and documenting the physical
characteristics of previously documented seeps. All examinations of seeps
must include identification of seeps by approximate latitude and longitude
and date-stamped digital photographs of their appearance. A report
summarizing the findings of this survey, including a section analyzing the
effect decanting of the basin(s)has had on seep flows, accompanied by
copies of the photographs noted above, shall be submitted to the Director
of DWR("Final Seep Report"). This Final Seep Report must list any seep
that has been dispositioned(as described in subparagraph(4)above)
during decanting process, including an analysis of the manner of
disposition. The determination of whether a seep is dispositioned rests
with the Director of DWR. At, or at any time prior to, submission of the
Final Seep Report,Duke Energy shall seek formal certification from the
Director of DWR, certifying the disposition of any seep that Duke Energy
has characterized as dispositioned. Any seeps not certified as
dispositioned by the Director of DWR shall not be deemed as
dispositioned.

EMC SOC WQ Si8-006
Duke Energy Progress,LLC
P. 9
6) If any seeps have not been certified by the Director of DWR as
dispositioned(as described in subparagraph 4) above),Duke Energy shall
conduct a characterization of those seeps.3 Duke Energy shall submit a
report on the findings of these characterizations ("Seep Characterization
Report")to the Director of DWR no later than December 31,2021 (i.e.,
within 60 days of the submittal of the Final Seep Report). The Seep
Characterization Report must include all sampling data for each remaining
seep as well as Duke Energy's evaluation of the jurisdictional status of all
seeps at the H. F. Lee Facility. The determination regarding whether a
surface water feature is a classified water of the State rests with DWR.
7) Within 60 days of the submittal of the Seep Characterization Report, Duke
Energy shall submit a complete and adequate proposed amendment to the
groundwater Corrective Action Plan and/or Closure Plan as appropriate
for the Facility describing how any seeps identified in the Seep
Characterization Report will be managed in a manner that will be
sufficient to protect public health, safety, and welfare,the environment,
and natural resources. This proposed amendment will go to public
comment. Duke Energy shall submit documentation that the proposed
modification has been submitted to the appropriate division within the
Department that has authority for approving modification of the
groundwater Corrective Action Plan and/or Closure Plan. The content of,
and DEQ's review of, an amendment to a groundwater Corrective Action
Plan shall be consistent with Title 15A,Chapter 2L of the N.C.
Administrative Code(specifically including 2L.0 1 06(h)-(o)). The
amendment to the Corrective Action Plan and/or Closure Plans shall be
implemented by Duke Energy in accordance with the deadlines contained
therein, as approved or conditioned by the Department. Failure by Duke
Energy to implement the amendment will be handled in the normal course
by the Department in accordance with its enforcement procedures(i.e.,
outside this Special Order). Notwithstanding the foregoing provisions of
this paragraph, any cooling pond seeps contained in the Seep
Characterization Report shall be addressed in a separate report(rather than
a proposed amendment to the groundwater Corrective Action Plan and/or
Closure Plan),specific to the matters of those seeps, and describe how
remaining cooling pond seeps will be managed in a manner that will be
sufficient to protect public health, safety, and welfare,the environment,
and natural resources. The report shall be submitted to DWR's Complex
3 If any seep is dispositioned between the time that the Final Seep Report is submitted and the
time the Seep Characterization Report is submitted,an analysis of the manner of disposition
must be included in the Seep Characterization Report,and Duke Energy must seek certification
of such a disposition from the Director of DWR. Only if such certification is received prior to
the due date of the proposed amendment described in paragraph 2(b)(7)may such a seep,
certified as dispositioned,be omitted from the proposed amendment.

EMC SOC WQ S18-006
Duke Energy Progress,LLC
p. 10
Permitting Unit within 60 days of the submittal of the Seep
Characterization Report("Cooling Pond Seep Report").
For clarity,listed below is a summary of the timetable for the documents due after
completion of steps above:
Document Due Date
Final Seep Report October 31, 2021
Seep Characterization Report December 31,2021
Proposed amendment to groundwater
Corrective Action Plan and/or Closure February 28, 2022
Plan, and/or Cooling Pond Seep
Rport
8) Termination of Special Order
This Special Order shall terminate on the later of the following dates:
• January 31, 2022; or
+ 30 days following the approval of an amended groundwater
Corrective Action Plan and/or Closure Plan, as appropriate (if an
amendment is submitted in compliance with subparagraph 2(b)(7)
above).
c. interim Action Levels.
1) Upon the complete execution of this Special Order,with regard to non-
constructed seeps, interim action levels for the receiving waters (which are
minor tributaries) are hereby established as noted in Attachment A. The
interim action levels are site-specific. Duke Energy shall monitor at
approved sampling sites to ensure interim action levels are met. Interim
action levels shall remain effective in the designated surface waters until
the applicable termination date in paragraph 2(b)(8)is reached.
2) Duke Energy shall perform monitoring of waters receiving flow from non-
constructed seeps in accordance with the schedules listed in Attachments
A and B, except as noted in paragraph 2(c)(3)below

EMC SOC WQ S 18-006
Duke Energy Progress,LLC
p. II
3) If the monitoring of any classified water of the State receiving flow from
seeps regulated by this Special Order indicates exceedance of any interim
action level established by the Special Order,Duke Energy shall increase
monitoring at that location from quarterly to monthly until concentrations
of monitored characteristics return to those observed at the initiation of the
Special Order. If any interim action level established by the Special Order
is exceeded by more than 20% in a single sampling event,or exceeded for
two(2)consecutive monitoring events,in addition to paying the
associated stipulated penalty,Duke Energy shall conduct a re-assessment
of the contributing seep(s),including,but not limited to,evaluation of
proposed remedial actions for treatment and/or control of the seep such
that impacts to the receiving waters are quickly mitigated. A report
compiling the findings of the re-assessment,including proposed remedial
actions,shall be provided to the Director of DWR within 60 days of any
applicable exceedance. Following its review,DWR shall notify Duke
Energy of its concurrence or disapproval of Duke Energy's proposed
remedial actions.
4) Monitoring associated with seeps covered by this Special Order is exempt
from the electronic reporting requirements associated with NPDES
permits. Results of monitoring required exclusively per the terms of this
Special Order shall be reported to the Director of DWR in a
spreadsheet/worksheet format agreed to by Duke Energy and DWR.
Monitoring data shall be submitted to the Director of DWR in a digital
format no later than 30 days following the end of each calendar quarter for
as long as the Special Order is in effect. Monitoring data shall be sent to
the following email address: desocdata®ncdenr.gov. Data from those
sites with monitoring required exclusively per the terms of the Special
Order will be posted on DWR's wcbsite to provide the public with the
opportunity for viewing.
3. Duke Energy will continue to operate the H. F. Lee Facility's coal ash surface
impoundments in such a manner that their performance is optimized,and potential for
surface waters to be affected by seeps is minimized.
4. Duke Energy shall make available on its external website the NPDES permits,this
Special Order and all reports required under this Special Order for the H. F. Lee Facility
no later than thirty(30)days following their effective or submittal dates.

EMC SOC WQ S 18-006
Duke Energy Progress,LLC
p. 12
5. Duke Energy and the Commission agree that the stipulated penalties specified in
paragraph 2(a)(2)are not due if Duke Energy satisfies DWR that noncompliance was
caused solely by:
a. An act of God;
b. An act of war;
c. An intentional act or omission of a third party,but this defense shall not be
available if the act or omission is that of an employee or agent of Duke Energy or
if the act or omission occurs in connection with a contractual relationship with
Duke Energy;
d. An extraordinary event beyond the Duke Energy's control, specifically including
any court order staying the effectiveness of any necessary permit or approval.
Contractor delays or failure to obtain funding will not be considered as events
beyond Duke Energy's control; or
e. Any combination of the above causes.
6. Failure within thirty(30) days of receipt of written demand by DWR to pay the stipulated
penalties, or challenge them by a contested case petition pursuant to G.S. 150B-23,will
be grounds for a collection action,which the Attorney General is hereby authorized to
initiate. The only issue in such an action will be whether the thirty(30) days has elapsed.
7. Any non-constructed seeps causing or contributing to pollution of waters of the State
associated with the coal ash impoundments and the cooling pond at Duke Energy's H. F.
Lee Facility, and listed in Attachment A to this Special Order,are hereby deemed
covered by this Special Order. Any newly-identified non-constructed seeps discovered
while this Special Order is in effect, and timely reported to the Department per the terms
of CAMA and this Special Order, shall be deemed covered by the terms of the Special
Order, retroactive to the time of their discovery. Newly-identified non-constructed seeps
must be sampled for the presence of those characteristics listed in Attachment B to this
Order. Newly-identified non-constructed seeps found to be causing or contributing to
pollution of the waters of the State,with the effect of causing a violation of water quality
standards in surface waters not already referenced in the Special Order,may require
modification of the Special Order to address those circumstances.
8. Noncompliance with the terms of this Special Order is subject to enforcement action in
addition to the above stipulated penalties,including,but not limited to injunctive relief
pursuant to G.S. 143-215.6C or termination of this Special Order by the Director of DWR
upon ten(10)days'notice to Duke Energy. Noncompliance with the terms of this
Special Order will not be subject to civil penalties in addition to the above stipulated
penalties.

EMC SOC WQ S 18-006
Duke Energy Progress,LLC
p. 13
9. This Special Order and any terms or conditions contained herein,hereby supersede any
and all previous Special Orders,Enforcement Compliance Schedule Letters,terms,
conditions,and limits contained therein issued in connection with NPDES permit
NC0003417.
10. This Special Order may be modified at the Commission's discretion,provided the
Commission is satisfied that Duke Energy has made good faith efforts to secure funding,
complete all construction, and achieve compliance within the dates specified. In
accordance with applicable law,modification of this Special Order will go to public
notice prior to becoming effective.
11. Failure to pay the up-front penalty within thirty(30)days of execution of this Special
Order will terminate this Special Order.
12. In addition to any other applicable requirement, each report required to be submitted by
Duke Energy under this Special Order shall be signed by a plant manager or a corporate
official responsible for environmental management and compliance, and shall include the
following certification:
I certify under penalty of law that this document and all attachments
were prepared under my direction or supervision in accordance with
a system designed to assure that qualified personnel properly gather
and evaluate the information submitted. Based on my inquiry of the
person or persons who manage the system,or those persons directly
responsible for gathering the information, the information submitted
is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fine and
imprisonment for knowing violations.
13. This Special Order shall become effective in accordance with state law, and once
effective,Duke Energy shall comply with all schedule dates,terms, and conditions
herein.

EMC SOC WQ S 18-006
Duke Energy Progress,LLC
p. 14
This Special Order by Consent shall expire no later than February 28, 2023.
F e Ene Progress, LLC:
t ( 3 /1.a
Paul Draovitch Date
Senior Vice President,Environmental,Health& Safety
For the No olina Environmental Management Commission:
--___ / /I b C
J. �. Sol P.E.
C�tair of the Commission Date

•
Attachment A
S18-006
Duke Energy Progress,LLC-H.F.Lee Energy Complex,p,1
Approximate Receiving
Seep ID Receiving ! Interim Action
Location Coordinates Description Waterbody SOC Monitoring
Number ----__----_._--_--- Levels
Waterbody
Latitude 1 Longitude Classification
—- — Seep from the land area north of the cooling Instream
pond,between the cooling pond and the N/A-28 Standards
LOLA 5-01 35.379568 j -78.075043 Neuse River WS-IV;NSW I monitoring of the ,
Neuse River.Not a seep emanating from the Neuse River Apply
active ash basin. I} _
Seep p..__ g -- -I Instrem •
from the land area north of the cooling
pond,between the coolingand and the N/A-2B Standards
LOLA 5-01A 35.379648 -78.074632 Neuse River.Not a seep emanating from the Neuse River WS-IV;NSW monitoringof the Apply
active ash basin. Neuse River
Seep from the land area north of the cooling Instream
pond,between the cooling pond and the N/A-28 Standards
LOLA S-018 35.380846 -78.077697 Neuse River.Not a seep emanating from the j Neuse River WS-IV;NSW monitoring of the Apply
active ash basin. Neuse River
Low volume seep to small channel north of Ditch system
draining areas
active ash basin at the toe of the dike.Flows Monitoring at
S-01 35.386858 -78.073453 ; west,then south,toward confluence with north and WS-IV;NSW location S-03A See S-03A
Neuse River at sampling site 5-03A. west of active
ash basin
----.._..__.--- — Ditch system i
Low volume seep to small channel north of draining areas
S-02 35.384001 -78.081383 active ash basin at the toe of the dike.Flows Monitoring at
north and WS-IV;NSW See S-03A
west,then south,toward confluence with west of active location S-03A
Neuse River at sampling site S-03A. ash basin
•
"Location previously investigated as a seep. Monitoring has not indicated the presence of coal combustion residuals.
•'Seep dispositioned via repair and/or non-flowing condition to potentially reach WOTUS,or other,as noted.
Monitoring shall be conducted at the approximate locations indicated on the attached site map.
All monitoring shall be conducted per the requirements found in Attachment B of this Order.

Attachment A
518-006
Duke Energy Progress, LLC—H.F.Lee Energy Complex,p,2
Approximate
I'' Receivin i Receiving
Location Coordinates Descriptiong
N. oe- Waterbod ' 4Jacerbady SOC Monitoring Interim Action Levels
Latitude Longitude y Classification
Ditch system
Channe'on west side of active_ash basin.Directs draining areas 1
S.G3'` 35.382666 -78,084374 flow from ditch on,north side of active ash basin north and I WS-IV;NSW Monitoring at See S-03A
south toward Meuse River. Not a seep. west of active
location 5-03A
i
,. ash basin i
Duct system I — •
Site Jut beforeconfluence 0e 513 channel draining areas Monitoring at ' Arsenic 400 µglL I
I location 5 03>03 " 35.331806 -78.084052 conveyinii flo f )m upstream sites and the north and 4VS-IV;NSW Hardness 500 mg/i.Nei,e 4 ar Nota seep west of active prior to enter,^g TOS 800 mg/i.
rill basin ; Neusa Riser
ace • I
nta u: water inland r orr r Dist eani
5 04. - 35.381993 78.078734 P.A-2B Standards '
Neuse River ..VS-IV;N544' ! mcato ing r
heir v ou v ,we of active ash b mr Apply
the N.u.e Pmr_r
Static AOW ,ear riprap area on the south iidt o=
S 0 " 35.379045 ; -78.070293 the southeast corner of active ash basin. NIA-Sao N/A-Seep
Location has been repaired.No flow obit-•,e:,in Meuse Roar 4'S-iV;NSW
Dispnsi:icn;d Dispositioned
recent observations.
Low volume seep to small channel on east side of Ditch system T
active ash basin at the toe of the dike.Flows draining areas
5-06 35.386968 -78.071942 • north and east WS-IV;NSW See at
south,toward confluence with Neuse River atlocation S-09 See 5-09
of active ash
. sampling site 5-09.
basin
i Low volume seep to small channel on east side of Ditch system
draining areas
5-07 i 35.382767 78.069655 active ash basin at the toe of the dike.Flows I Monitoring at
I north and east WS-I ,NSW i See S-09
I south,toward confluence with Meuse River at
I of active ash location S-09 1
i I sampling site 5-09. 1
basin i
'Location previously investigated as a seep. Monitoring has not indicated the presence of coal combustion residuals.
"Seep dispositioned via repair and/or non-flowing condition to potentially reach WOTUS,or other,as noted.
Monitoring shali be conducted at the approximate locations indicated on the attached site map.
All monitoring shall be conducted per the requirements found in Attachment B of this Order

i . •
Attachment A
S18-006
Duke Energy Progress,LLC—H.F.Lee Energy Complex,p.3
Approximate
Seep ID Location Coordinates I Receiving Receiving
i Description Waterbody SOC Monitoring Interim Action Levels
Number i Waterbody
Latitude I Longitude l Classification l
.
1
i I Static AOW near riprap area on the east side of
Ditch system
draining areas
S-08 35.38051 78.068532 the southeast corner of active ash basin.Any north and east ! WS-IV;NSW Monitoring at See S-09
flow collects in channel and flows south toward of active ash location S-09
I. S-09.No flow observed in recent observations. basin
Monitoring location Just before confluence of Ditch system
Monitoring at
draining areas Arsenic 400 µg/L
channel on east side of active ash basin location 5-09
5-09"" 35.379492 -78.067718 conveying flow from upstream sites and the north and east WS-IV;NSW prior to entering Hardness 500 mg/L
' Neuse River. Not a seep. of active ash Neuse River T05 800 mg/L
:—_..---- basin
i Stagnant,ponded water inland from river terrace Instream
N/A—28 Standards
S-18 35.379222 -78.101206 Neuse Rivers WS-IV;NSW monitoring of the
. below east side of inactive ash basin. e River ,
Stag
from river terrace
5-19* j 35.38179 -78.097649 below northeant, stsidaterinactve ash basin. From Neuse River i WS-IV;NSW ply
N/As-Seep N/A—Seep
Seep
j sampling—No CCR impacts.
—— Dispositioned Dispositioned
"� I Seep near well CMW-10,along the south side of N/A—Seep N/A—Seep
S-20 35.382406 -78.082051 active ash basin.Location has been repaired to Neuse River WS-IV;NSW i Dispositioned Dispositioned
eliminate see .
I Stagnant seep along south side of active ash
S-21"" 35.382151 -78.080376 basin.Any flow reinfiltrates prior to reaching Neuse River WS-IV;NSW ! N/A—Seep N/A—Seep
— surface water. Dispositioned Dispositioned
Seepalongsouth side of active ash basin. Flows Im N/A—28pStandards I
5-22 35.381466 -78.077819 Neuse River WS-IV;NSW . monitoringof the /
toward Neuse River. ! Apply I
i_ _ , _ _ Neuse River
r { _ ! Seep alongtowa Neuse Rive side of active ash basin. Flows ^— — I N/A—28A Standards
5-23 35.381175 -78.077136 p Neuse River WS-IV;NSW monitoringof the /
r.
Neuse River Apply I
*Location previously investigated as a seep. Monitoring has not indicated the presence of coal combustion residuals.
""Seep dispositioned via repair and/or non-flowing condition to potentially reach WOTUS,or other,as noted.
Monitoring shall be conducted at the approximate locations indicated on the attached site map.
All monitoring shall be conducted per the requirements found in Attachment B of this Order.

Attachment A
518-006
Duke Energy Progress,LLC-H.F.Lee Energy Complex,p.4
Approximate
Seep ID T— Receiving
Description Receiving
Location Coordinates I D
Number I p Waterbody Waterbody SOC Monitoring Interim Action Levels
Latitude Longitude L Classification
Seep along south side of active ash basin. Flows Instream
5-24 35.381063 eusever monitoring of the
Ri WS-IV;NSW N/A-ZBStandards
j ; toward Neuse River. Apply
i Neuse River
Seep along south side of active ash basin. Flows Instream
5-25 35.380922 78.076001 Neuse River WS-IV;NSW monitoring of the N/A-28 Standards
toward Neuse River. Apply
Neuse River
.._._...--_-----_{
Seep within a small drainage channel for ponded Instream
S-26 35.38164 -78.078322 water within the river bank below south side of Neuse River WS-IV;NSW : monitoring of the N/A-2B Standards
active ash basin. Flows toward Neuse River. Neuse River Apply
Low volume seep to small channel north of Ditch system
• active ash basin at the toe of the dike.Flows draining •area, Monitoring at
5-27 35.385848 78A75999 , west,then south,toward confluence with Neuse north and WS-IV;NSW location S-03A See S-03A
River at sampling site S-03A. west of active j
ash basin
Low volume seep to small channel north of Ditch system
5-28 35.385133 -78.078197 ' active ash basin at the toe of the dike.Flows
draining areas Monitoring at
north and WS-IV;NSW See 5-03A
west,then south,toward confluence with Neuse west of active location S-03A
River at sampling site 5-03A.
_---- _._-.---_-- ash basin
Seep to Halfmile Branch on southwest side of Halfmile Instream See Halfmile Branch '
5-29 35.37862 -78.10593 retired ash basin#2. Branch W5-IV;NSW monitoring of Instream Monitoring
Halfmile Branch (p.8)
*Location previously investigated as a seep. Monitoring has not indicated the presence of coal combustion residuals.
**Seep dispositioned via repair and/or non-flowing condition to potentially reach WOTUS,or other,as noted.
Monitoring shall be conducted at the approximate locations indicated on the attached site map.
All monitoring shall be conducted per the requirements found in Attachment B of this Order.

I
Attachment A
S18-006
Duke Energy Progress,LLC-H.F.Lee Energy Complex,p.5
Approximate i Receiving
Seep ID Receiving
Location Coordinates Description Waterbody SOC Monitoring Interim Action Levels
Number { Waterbody
l Latitude I Longitude i Classification
Seep from the berm surrounding the cooling Instream
CPS-01 35.37924 -78.07377 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW monitoring of the N/A-28 Standards
basin. Neuse River Apply
i Seep from the berm surrounding the cooling Instream
•
CPS-02 35.37901 -78.07298 pond.Not a seep emanating from the active ash Neuse River j WS-IV;NSW monitoring of the N/A-26 Standards
j I basin. Neuse River
Apply
Seep from the berm surrounding the cooling Instream N%A-28 Standards
CPS-03 35.37895 ' -78.06270 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW monitoring of the
basin. ' Neuse River Apply
_ .._. --- _._._..__._... . ..------. ----__ —_...._ .___.._ i.___
Seep from the berm surrounding the cooling Instream
N/A-28 Standards
CPS-04 35.37902 i -78.06707 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW monitoring of the
basin. Neuse River Apply
Seep from the berm surrounding the cooling Instream N/A-2B Standards
CPS-05 35.37998 -78.06574 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW ' monitoring of the
basin. Neuse River Apply
Seep from the berm surrounding the cooling I Instream
CPS-06 35.37179 -78.06642 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW I monitoring of the N/A-28 Standards
basin. Neuse River Apply
Seep from the berm surrounding the cooling I Instream
CPS-07 35.37177 -78.06661 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW monitoring of the N/A 20 Standards
basin. Neuse River I Apply
'Location previously investigated as a seep. Monitoring has not indicated the presence of coal combustion residuals.
**Seep dispositioned via repair and/or non-flowing condition to potentially reach WOTUS,or other,as noted.
Monitoring shall be conducted at the approximate locations indicated on the attached site map.
All monitoring shall be conducted per the requirements found in Attachment B of this Order

Attachment A
518-006
Duke Energy Progress,LLC—H.F.Lee Energy Complex,p.6
NumberSeep
D
oxima
i • Loca onrCoordinates Description ReWecervody Waterbody I SOC Monitoring Interim Action Levels i
Latitude Longitude Classification •
Seep from the berm surrounding the cooling Instream
CPS-08 35.37711 -78.06780 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW monitoring of the N/A—28 Standards
basin. Neuse River Apply
Seep from the berm surrounding the cooling Instream
CPS-09 35.36922 -78.07880 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW monitoring of the N/A—28 Standards
basin. Neuse River Apply
Seep from the berm surrounding the cooling Instream
CPS-10 35.36840 -78.08125 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW monitoring of the N/A—26 Standards
basin. • Neuse River Apply
Seep from the berm surrounding the cooling Instream
CPS 11 35.36829 -78.08141 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW monitoring of the N/A—28 Standards
basin. Neuse Rive- Apply
Seep from the berm surrounding the cooling Instream
CPS-12 ' 35.36816 -78.08156 pond.Not a seep emanating from the active ash Neuse River ' WS-IV;NSW I monitoring of the N/A—28 Standards
basin. Apply
—.._—__.. _ Neuse River
Seep from the berm surrounding the cooling i Instream
CPS-13 35.37972 -78.07540 pond.Not a seep emanating from the active ash Neuse River i WS-IV;NSW monitoring of the N/A—28 Standards
basin. Neuse River APpIY i
— — — ------ —.--_______,._.. t ---
Seep from the berm surrounding the cooling Instream • —i
I CPS-14 I 35.37963 -78.07527 pond.Not a seep emanating from the active ash Neuse River • WS-IV;NSW i monitoring of the N/A—28 Standards
j basin. Apply ,
:._._._.__—._...�_______—_ , Neuse River
"Location previously investigated as a seep. Monitoring has not indicated the presence of coal combustion residuals.
"Seep dispositioned via repair and/or non-flowing condition to potentially reach WOTUS,or other,as noted.
Monitoring shall be conducted at the approximate locations Indicated on the attached site map.
All monitoring shall be conducted per the requirements found in Attachment 8 of this Order.

Attachment A
S18-006
Duke Energy Progress,LLC-H. F.Lee Energy Complex,p.7
Approximate
Location Coordinates Receiving
Seep ID -__-_.. _- Description Receiving Waterbody SOC Monitoring Interim Action Levels
Number Waterbody
Latitude Longitude Classification
I
Seep from the berm surrounding the cooling Instream N/A-28 Standards
CPS-15 35.37962 -78.07460 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW monitoring of the
basin. Neuse River I Apply
i
Seep from the berm surrounding the cooling Instream
CPS-16 35.37942 -78.07423 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW monitoring of the N/A-2B Standards
basin. Neuse River Apply
Seep from the berm surrounding the cooling Instream
CPS-17 35.37465 -78.06165 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW ; monitoring of the N/A-28 Standards
basin. Neuse River Apply
.
Seep from the berm surrounding the cooling Instream NJA 28 Standards
CPS-18 35.37195 -78.06605 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW monitoring of the
basin. Neuse River 1 Apply
I
' Seep from the berm surrounding the cooling Instream
N/A-2B Standards
CPS-19 135.37192 -78.06625 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW monitoring of the
` basin Neuse River Apply
Seep from the berm surrounding the cooling Instream
CPS-20 35.37202 -78.06630 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW monitoring of the I
1 1 N/A-28 Standards
basin. Neuse River I Apply
i � — I _ ...-. —
I
Seep from the berm surrounding the cooling Instream
CPS-21 i 35.36983 i -78.07580 pond.Not a seep emanating from the active ash Neuse River WS-IV;NSW monitoring of the N/A-28 Standards
basin. Neuse River ! Apply
*Location previously investigated as a seep. Monitoring has not indicated the presence of coal combustion residuals.
"Seep dispositioned via repair and/or non-flowing condition to potentially reach WOTUS,or other,as noted.
Monitoring shall be conducted at the approximate locations indicated on the attached site map.
All monitoring shall be conducted per the requirements found in Attachment 8 of this Order.

Attachment A
518-006
Duke Energy Progress,LLC—H.F.Lee Energy Complex,p.8
Instream Monitoring
Description ReceivingWaterbodyReceiving Waterbody
p Classification SOC Monitoring Interim Action Levels
In,tream Monitoring to
evaluate potential impacts Neuse River WS-IV;NSW Upstream&Downstream Monitoring of the N/A—28 Standards
from seeps Neuse River Apply
In stream Monitoring to Upstream&Downstream Monitoring of Mercury 0.02 pg/L
evaluate potential impacts Halfmile Branch WS-IV;NSW Halfmile Branch Selenium 30 µg/L
from seeps
'Location previously investigated as a seep. Monitoring has not indicated the presence of coal combustion residuals.
**Seep dispositioned via repair and/or non-flowing condition to potentially reach WOTUS,or other,as noted.
Monitoring shall be conducted at the approximate locations indicated on the attached site map.
All monitoring shall be conducted per the requirements found in Attachment B of this Order.

H. F. Lee Energy Complex —Water Quality Monitoring
N
i
i " , Ash
\ + '3 S-03A Basin \ /
" '
ease
N
'Sd Rif'er 5 09
,6 /F/h i� /
it
• .. Cooling
o
+1' :-, Pond
* ,
`. f`
Upstream: Halfmile Branch &Neuse River
* Stream Monitoring
* Downstream: Halfmile Branch& Neuse River

SOC S18-006
Duke Energy Progress, LLC—H. F. Lee Plant
Attachment B
Monitoring Requirements
The following represents the parameters to be analyzed and reported at all monitoring locations
designated within this Special Order.
Parameter Reporting Units Monitoring
Frequency__
TSS mg/L Annually
Oil and Grease mg/L Annually
pH Standard Units(s. u.) Quarterly
Fluoride pg/L Quarterly
Total Mercury i ng/L Quarterly
Total Barium pg/L Quarterly
Total Zinc pg/L Quarterly
Total Arsenic pg/L j Quarterly
Total Boron pg/L I Quarterly
Total Cadmium pg/L Quarterly
Total Chromium pg/L Quarterly
Total Copper pg/L Quarterly
Total Thallium pg/L Quarterly
Total Lead pg/L Quarterly
Total Nickel pg/L Quarterly
Total Selenium pg/L Quarterly
Nitrate/Nitrite as N mg/L Quarterly
Bromides mg/L Quarterly
Sulfates mg/L Quarterly
Chlorides j mg/L Quarterly
TDS mg/L Quarterly
Total Hardness mg/L Quarterly
Temperature °C Quarterly
Conductivity, pmho/em pmho/cm Quarterly
Analyses of all monitoring conducted per the terms of this SOC shall conform to the requirements of 15A
NCAC 2B .0505(e)(4)and(5); i.e.,standard methods and certified laboratories shall be used.

Seep Management Plan Amendment to the Closure Plan
H.F. Lee Energy Complex—Duke Energy Progress, LLC
Goldsboro, North Carolina
APPENDIX B
MANN KENDALL TREND TEST ANALYSIS,
FEBRUARY 2022
•
synTerra
Science & Engineering Consultants

•
syrTerra Science & Engineering Consultants
synterracorp.com
APPENDIX B
MANN-KENDALL TREND TEST ANALYSIS
H.F. LEE ENERGY COMPLEX
FEBRUARY 2022
PREPARED FOR
• DUKE
ENERGY
PROGRESS
DUKE ENERGY PROGRESS,LLC

Appendix B-Mann-Kendall Trend Test Analysis
H.F. Lee Energy Complex, Duke Energy Progress, LLC
Goldsboro, North Carolina
TABLE OF CONTENTS
SECTION PAGE
1.0 THE MANN-KENDALL TREND TEST 1-1
2.0 TIME VERSUS CONCENTRATION PLOTS 2-1
3.0 MANN-KENDALL TREND TEST RESULTS 3-1
LIST OF FIGURES
Figure 1 Time versus Total Arsenic
Figure 2 Time versus Total Barium
Figure 3 Time versus Total Boron
Figure 4 Time versus Bromide
Figure 5 Time verses Total Cadmium
Figure 6 Time versus Chloride
Figure 7 Time versus Total Chromium
Figure 8 Time versus Total Copper
Figure 9 Time versus Flow Rate
Figure 10 Time versus Fluoride
Figure 11 Time versus Hardness
Figure 12 Time versus Total Lead
Figure 13 Time versus Total Mercury
Figure 14 Time versus Total Nickel
Figure 15 Time versus Nitrate + Nitrite
Figure 16 Time versus Oil and Grease
Figure 17 Time versus pH
Figure 18 Time versus Total Selenium
Figure 19 Time versus Specific Conductance
Figure 20 Time versus Temperature
Figure 21 Time versus Total Thallium
Figure 22 Time versus Total Dissolved Solids
Figure 23 Time versus Total Sulfate
Figure 24 Time versus Total Suspended Solids
Figure 25 Time versus Total Zinc
LIST OF TABLES
Table 1 Sampling Locations and Constituents Included in Concentration over Time Plots
Table 2 Mann-Kendall Trend Analysis Results
February 2022 Page i

Appendix B-Mann-Kendall Trend Test Analysis
H.F. Lee Energy Complex, Duke Energy Progress, LLC
Goldsboro, North Carolina
THE MANN-KENDALL TREND TEST
Mann-Kendall trend tests were performed on available seep data associated with the ash
basins and lay of the land area at the H.F. Lee Energy Complex. The Mann-Kendall trend test
evaluates data over time for monotonic trends, where monotonic indicates a trend that is solely
increasing or decreasing. Mann-Kendall is a useful trend test in that it is non-parametric and
does not require normal distribution of data.
To perform the Mann-Kendall trend test, data were processed as follows:
• Non-detects greater than regulatory values were removed. If a constituent does not
have a regulatory limit and there are multiple reporting limits, only the lowest reporting
limit was retained.
• Detects that were less than the reporting limit were treated at non-detects.
• Samples with pH greater than 10 standard units were removed.
Next, the data must meet the following requirements for a Mann-Kendall trend test to be
applicable:
• There must be at least four detect measurements.
• Non-detects must make up less than or equal to 50 percent of measurements.
In a Mann-Kendall trend test, each value is compared to the proceeding values to calculate
whether the value has increased, decreased, or stayed the same over time. These comparisons
are recorded as simply 1 (increasing), -1 (decreasing), or 0 (stayed the same). These
comparisons give an S value, where S indicates the type of trend. A negative S value indicates a
decreasing trend, and a positive S value indicates an increasing trend. Whether or not these
trends are statistically significant is dependent on the two-sided p value. A p value ranges from
0 to 1 and indicates whether the results are due to chance or the results are statistically
significant. Greater p values indicate a trend is not statistically significant, and a p value less
than 0.1 indicates a statistically significant trend.
All Mann-Kendall trend tests are performed in the program RStudio using the "Kendall"
package.
February 2022 Page 1-1

Appendix B-Mann-Kendall Trend Test Analysis
H.F. Lee Energy Complex, Duke Energy Progress, LLC
Goldsboro, North Carolina
2.0 TIME VERSUS CONCENTRATION PLOTS
Plots of concentration over time provide a visual representation of possible trends in the data.
Time versus concentration plots are presented as Figures 1 through 25. Plots are grouped by
constituent, and within the figure, a plot of concentration over time is displayed for each
location that has data for that constituent. Locations and constituents included in these plots
are presented in Table 1.
Trends from the Mann-Kendall tests are displayed on plots with colored borders representing
trend conclusions. Blue indicates no trend was present, green indicates a decreasing trend, gold
indicates an increasing trend, and no color indicates the constituent-location pair cannot be
analyzed for trends due to a lack of detect measurements. Detect measurements are shown as
a black point, and non-detect measurements are shown as an open circle.
February 2022 Page 2-1

Appendix B-Mann-Kendall Trend Test Analysis
H.F. Lee Energy Complex, Duke Energy Progress, LLC
Goldsboro, North Carolina
TABLE 1
SAMPLING LOCATIONS AND CONSTITUENTS INCLUDED IN PLOTS OF CONCENTRATIONS OVER
TIME
Sampling Locations Constituents
LOLA S-01A Total Arsenic
LOLA S-01B Total Boron
S-08 Bromide
5-18 Total Cadmium
S-22 Chloride
S-23 Total Chromium
5-24 Total Copper
S-25 Flow Rate
S-26 Fluoride
Hardness
Total Lead
Total Mercury
Total Nickel
Nitrate+Nitrite
Oil and Grease
pH
Total Selenium
Specific Conductance
Temperature
Total Thallium
Total Dissolved Solids
Total Sulfate
Total Suspended Solids
Total Zinc
Note:
If a location-constituent pair does not have an identified trend or plot,data was not available for that pair.
February 2022 Page 2-2

P
Appendix B-Mann-Kendall Trend Test Analysis
H.F. Lee Energy Complex, Duke Energy Progress, LLC
Goldsboro, North Carolina
3.0 MANN-KENDALL TREND TEST RESULTS
Results of the Mann-Kendall trend tests are presented in Table 2. Mann-Kendall trend tests
were conducted for data pertaining to the 9 non-dispositioned seeps associated with the ash
basins and lay of the land area. Out of the 9 seeps evaluated, six had four or more samples and
thus were evaluated for trends.Trend analyses were completed for 127 location-constituent
pairs using available seep data that was collected between 2015 and 2021. For the other
occurrences where trend analysis could not be performed, either there are less than four
detects, or the number of non-detects is greater than the number of detects. The average
percentage of non-detects for all constituent-location pairs included in the Mann-Kendall trend
test is 33 percent.
Locations not displayed in Table 2 are excluded due to having less than the minimum number
of samples required to run the "Kendall" package in RStudio. Location-constituent pairs with
less than four detects are included in Table 2 but cannot be analyzed for trends based on the
criteria in Section 1.0.
Out of the 127 constituent-location pairs that have trend conclusions, 33 are associated with
the following field parameters: flow rate, pH, specific conductance, temperature, total
dissolved solids, and total suspended solids. Trends for these field parameters were evaluated
for information but are not included in percentages below. Of the 94 chemical constituent-
location pairs that have trend conclusions, 49 percent of constituent concentrations are stable
or have statistically significant decreasing trends (46 out of 94 constituent location pairs), 51
percent (48 out of 94) of trends could not be analyzed due to greater than 50 percent non
detects. Of the 94 chemical constituent-location pairs, no increasing trends were identified.
Overall, the results of the Mann-Kendall trend tests indicate a system that is geochemically
stable, with the majority of constituent concentrations remaining stable over time.
February 2022 Page 3-1
Project:00 0061.20

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•
•
TABLE 2
MANN-KENDALL TREND ANALYSIS RESULTS
SEEP MANAGEMENT PLAN-APPENDIX B
H.F.LEE ENERGY COMPLEX
DUKE ENERGY PROGRESS,LLC,GOLDSBORO,NC
Well ID Analyfe Number of Samples Non-Detests Detects Percent Non- Is Trend Analysis Two-Sided
Detects Applicable? p Value 5 Value Trend Conclusion
LOLAS OIA pH a 0 4 0 Yes 1.00E+00 - Stable,no significant trend
5•08 pH 6 0 6 0 Yes 2.60E-01 - Stable,no significant trend
gni
S-22 pH 6 0 6 0 Yes 1.81E-01 - Stable,no significant trend
5-23 pH 7 0 7 0 Yes 1.58E-01 - Stable,no significant trend
5-24 pH 7 0 7 0 Yes 3.41E-01 - Stable,no significant trend
5-26 pH 5 0 5 0 Yes 6.13E-01 - Stable,no significant trend
LOLASOIA Temperature 4 0 4 0 Yes 7.34E-01 Stable,no significant trend
S.08 Temperature 6 0 6 0 Yes 4.52E-01 - Stable,no significant trend
5•21 Temperature 6 0 6 0 Yes 1.00E+00 - Stable,no significant trend
5-23 Temperature 7 0 7 0 Yes 6.09E-01 - Stable,no significant trend
S-N Temperature 7 0 7
0 Yes 1.00E+00 - Stable,no significant trend
5.26 Temperature 5 0 5 0 Yes 4.62E-01 Stable,no significant trend
LOLA 5-01A Specific Conductance 4 0 4 0 Yes 3.08E-01 •
Stable,no significant trend
5•06 Specific Conductance 6 0 6 0 Yes 4.52E-01 - Stable,no significant trend
5.22 Specific Conductance 6 0 6 0 Yes 1.00E+00 - Stable,no significant trend
5•23 Specific Conductance 7 0 7 0 Yes 1.33E-01 - Stable,no significant trend
-
5.24 Specific Conductance 7 0 7 0 Yes 5.08E-01 Stable,no significant trend
5•26 Specific Conductance 5 0 5 •
0 Yes 1.00E+00 - Stable,no significant trend
5.08 Flow 4 0 4 0 Yes 3.08E-01 Stable,no significant trend
S Z3 Flow 5 0 5 0 Yes 8.06E-01 - Stable,no significant trend
5.24 Flow 6 0 6 0 Yes 7.07E.01 - Stable,no significant trend
LOLA 5.01A Total Suspended Solids 4 0 4 0 Yes 1.00E+00 - Stable,no significant trend
S-08 Total Suspended Solids 6 0 6 0 Yes 1.29E-02 14 Statistically significant increasing trend
5.22 Total Suspended Solids 6 0 6 0 Yes 2.60E-01 - Stable,no significant trend
5-23 Total Suspended Solids 7 0 •7 0 Yes 5.48E-01 - Stable,no significant trend
5.24 Total Suspended Solids 7 0 7 0 Yes 1.00E+00 - Stable,no significant trend
S.26 Total Suspended Solids 5 0 5 0 Yes 8.64E-02 -8 Statistically significant decreasing trend
LOLA5-01A Total Boron 4 3 1 75 No - - Cannot Maly.for Trends
508 Total Boron 6 0 6 0 Yes 7.07E-01 - Stable,no significant trend
5,12 Total Boron 6 0 6 0 Yes 6.03E-02 -11 Statistically significant decreasing trend
5-21 Total Boron 7 0 7 0 Yes 7.64E-01 - Stable,no significant trend
s24 Total Boron 7 0 7 0 Yes 6.49E-31 - Stable,no significant trend
5.26 Total Boron 5 0 5 0 Yes 8.06E-01 ' Stable,no significant trend
--I OIA S-0lA Chloride 4 0 4 0 Yes 3.08E-01 - Stable,no significant trend
5,08 Chloride 6 0 6
0 Yes 2.62E-02 -13 Statisticaly significant decreasing trend
5-22 Chloride 6 0 6 0 Yes 1.81E-01 - Stable,no significant trend
5.21 Chloride 7 0 7 0 Yes 4.83E-02 -14 Statistically significant decreasing trend
5.24 Chloride 7 0 7 0 Yes 6.86E-03 -19 Statistically significant decreasing trend
5-26 Chloride 5 0 5 0 Yes 3 12E-01 - Stable,no significant trend

TABLE 2
MANN-KENDALL TREND ANALYSIS RESULTS
SEEP MANAGEMENT PLAN-APPENDIX B
H.F.LEE ENERGY COMPLEX
DUKE ENERGY PROGRESS,LLC,GOLDSBORO,NC
Percent Non- Is Trend Analysis Two-Sided
Well ID Analyze Number of Samples Non-Detects Detects S Value Trend Conclusion
Detects Applicable? PVats.
YesO e - Stable, niti t trend
5 OIA Sulfate 4 0 4 0 l O E 00 no significant tre d
5-08 Sulfate 6 0 6 0 Yes 6.03E-02 -11 Statistically significant decreasing trend
5-22 Sulfate 6 0 6 0 Yes 2.60E-01 - Stable,no significant trend
5-23 Sulfate 7 0 7 0 Yes 1.00E+00 - Stable,no significant trend
S-24 Sulfate 7 0 7 0 Yes 7.64E-01 - Stable,no significant trend
• 5-26 Sulfate 5 0 5 0 Yes 6.13E-01 - Stable,no significant Vend
LOLA S-01A Total Dissolved Solids 4 0 4 0 Yes 8.94E-02 -6 Statistically significant decreasing trend
•
S-08 Total Dissolved Solids 6 0 6 0 Yes 3.39E-01 - Stable,no significant trend
5-22 Total Dissolved Solids 6 0 6 0 Yes 1.00E+00 - Stable,no significant trend
5•23 Total Dissolved Solids 7 0 7 0 Yes 2.30E-01 - Stable,no significant trend
5-20 Total Dissolved Solids 7 0 7 0 Yes 2.88E-01 - Stable,no significant trend
• S•26 Total Dissolved Solids 5 1 4 20 Yes 8.06E-01 - Stable,no significant trend
LOLA S-01A Total Arsenic 0 0 4 0 Yes 100E+00 - Stable,no significant trend
5-08 Total Arsenic 6 0 6 0 Yes 1.33E-01 - Stable,no significant trend
5-22 Total Arsenic 6 0 6 0 Yes 7.07E-01 - Stable,no significant trend
5-23 Total Arsenic 7 0 7 0 Yes 2.30E-01 - Stable,no significant trend
5-24 Total Arsenic 7 0 7 0 Yes 1.00E+00 - Stable,no significant trend
5-26 Total Arsenic 5 0 5 0 Yes 2.21E-01 - Stable,no significant trend
LOLA 5-01A Total Barium 4 0 0 0 Yes 3.08E-01 • Stable,no significant trend
5-08 Total Barium 6 0 6 0 Yes 7.07E-01 - Stable,no significant trend
5-22 Total Barium 6 0 6 0 Yes 1.00E+00 - Stable,no significant trend
5-23 Total Barium 7 0 7 0 Yes 6.49E-01 - Stable,no significant trend
5-24 Total Barium 7 0 7 0 Yes 3.68E-01 - Stable,no significant trend
5-26 Total Barium 5 0 5 0 Yes 8.06E-01 . Stable,no significant trend
5-08 Total Cadmium 6 6 0 100 No - - Cannot Analyze for Trends
5.22 Total Cadmium 5 5 0 100 No - - Cannot Analyze for Trends
5-23 Total Cadmium 6 6 0 100 No - - Cannot Analyze for Trends
5-24 Total Cadmium 7 7 0 100 No - Cannot Analyze for Trends
5-26 Total Cadmium 0 4 0 100 No • - Cannot Analyze for Trends
•
5.08 Total Chromium 6 6 0 100 No . • Cannot Analyze for Trends
5-22 Total Chromium 6 4 2 67 No - - Cannot Analyze for Trends
5-23 Total Chromium 6 4 2 67 No - - Cannot Analyze for Trends
5-24 Total Chromium 7 7 0 100 No • - Cannot Analyze for Trends
• 5-26 Total Chromium 5 3 2 60 No . . Cannot Analyze for Trends
5-0B Total Copper 6 6 0 100 No • - Cannot Analyze for Trends
5-22 Total Copper 6 4 2 67 No • - Cannot Analyze for Trends
5-23 Total Copper 6 4 2 67 No - - Cannot Analyze for Trends
5-24 Total Copper 7 7 0 100 No - . Cannot Analyze for Trends
5-26 Total Copper 4 2 2 50 No - - Cannot Analyze for Trends
Pate 2.4

•
•
•
TABLE 2
MANN-KENDALL TREND ANALYSIS RESULTS
SEEP MANAGEMENT PLAN-APPENDIX B
H.F.LEE ENERGY COMPLEX
DUKE ENERGY PROGRESS,LLC,GOLDSBORO,NC
Well 10 Analyze Number of Samples Non-Detects Detect, Perzeet Non- Is Trend Analysis Two Sided S V.slue Trend Conclusion
Detects Applicable? P Value
3-08 Total Lead 6 6 0 100 No Cannot Analyze for Trends
5-22 Total Lead 6 4 2 67 No - - Cannot Analyze for Trends
S-23 Total Lead 6 4 2 67 No - - Cannot Analyze for Trends
5-24 Total Lead 7 7 0 100 Na - - Cannot Analyze for Trends
5-22 • Total Mercury 4 0 4 0 Yes 3.08E-01 - Stable,no significant trend
5-23 Total Mercury 6 2 4 33 Yes 1.29E-02 -14 Statistically significant decreasing trend
5-24 Total Mercury 6 4 2 67 No - - Cannot Analyze for Trends
S-08 Total Nickel 6 0 6 0 Yes 1.81E-01 - Stable,no significant trend
5•22 Total Nickel 6 3 3 50 No - - Cannot Analyze for Trends
5-23 Total Nickel 6 4 2 67 No - - Cannot Analyze for Trends
5-24 Total Nickel 7 7 0 100 No - - Cannot Analyze for Trends
5-26 Total Nickel 4 3 1 75 No - . Cannot Analyze for Trends
LOLA 5-01A Nitrate 6 Nitrite 4 2 2 50 No - Cannot Analyze for Trends
5•08 Nitrate+Nitrite 6 3 3 50 No - - Cannot Analyze for Trends
5•22 Nitrate+Nitnte 5 4 1 80 l No - - Cannot Analyze for Trends
5.23 Nitrate+Nitrite 6 3 3 50 Na . - Cannot Analyze for Trends
-
5-24 Nitrate+Nitrite 6 - 4 33 Yes 314E-01 •
Stable,no significant trend
5•26 Nitrate+Nitrite 4 3 1 75 No - - Cannot Analyze for Trends
508 Total Selenium 6 6 0 100 No - - Cannot Analyze for Trends
5-22 Total Selenium 5 5 0 100 No - - Cannot Analyze for Trends
5-23 Total Selenium 6 6 0 100 No - - Cannot Analyze for Trends
5-24 Total Selenium 7 7 0 100 No - - Cannot AnaNze for Trends
5-26 Total Selenium 4 4 0 100 No - Cannot Analyze for Trends
-
5-08 Total Thallium 6 5 1 83 No - - Cannot Analyze for Trends
5-22 Total Thallium 5 5 0 100 No - Cannot Analyzefor Trends
5-23 Total Thallium 6 6 0 100 No - Cannot Analyze for Trends
—
5-24 Total Thallium 7 7 0 100 No - Cannot Analyze for Trends
5-26 Total Thallium 4 4 0 100 No - Cannot Analyze for Trends
` 5-08 Total Zinc 6 5 1 83 No - - Cannot Analyze for Trends
5-22 Total Zinc 6 2 4 33 Yes 5.66E-01 - Stable,no significant trend
5-23 Total Zinc 7 3 4 43 Yes 4.33E-01 - Stable,no significant trend
5-24 Total Zinc 7 6 1 86 No - - Cannot Analyze for Trends
5-26 Total Zinc 5 3 2 60 No - - Cannot Analyze for Trends
IOLA S-01A Fluoride 4 0 4 0 Yes 4.70E-01 - Stable,no significant trend
5-08 Fluoride 6 0 6 0 Yes 1.00E+00 Stable,no significant trend
5-22 fluoride 5 0 5 0 Yes 1.30E•01 - Stable,no significant trend
S-23 Fluoride 7 0 7 0 Yes 1.33E-01 - Stable,no significant trend
5-24 Fluoride 6 0 6 •
0 Yes 5.66E.01 - Stable,no significant trend
5-26 Fluoride 5 0 5 0 Yes 4 62E•01 - Stable,no significant trend
Page 3 of

•
TABLE 2
MANN—KENDALL TREND ANALYSIS RESULTS
SEEP MANAGEMENT PLAN—APPENDIX B
H.F.LEE ENERGY COMPLEX
DUKE ENERGY PROGRESS,LLC,GOLDSBORO,NC
Percent Non- Is Trend Analysis Two-Sided
Well ID Analyze Number of Samples Non-Detects Detects SValue Trend Conclusion
Defects Applicable? PValue
S-08 Hardness 4 0 4 0 Yes 1.00E+00 - Stable,no significant trend
-S-22 Hardness 4 0 4 0 Yes 308(.01 - Stable,no significant trend
5-23 Hardness 5 0 5 0 Yes 4.62E•01 - Stable,no significant trend
5-24 Hardness 5 0 5 0 Yes 8.06E•01 - Stable,no significant trend
5-26 Hardness 4 0 4 0 Yes 7.34E-01 - Stable,no significant trend •
5-08 Oil and grease 4 4 0 100 No - - Cannot Analyze for Trends
5.22 Oil and grease 4 4 0 100 No - Cannot Analyze for Trends
5-23 Oil and grease 4 4 0 100 No - - Cannot Analyze for Trends
5-24 Oil and grease 5 5 0 100 No - - Cannot Analyze for Trends
Ion and grease e — a o 100 Na Cannot Analyze for Trends
g Prepared by-fa checked bv:_
Beechen limits were adjusted in accordance with USFPA guidelines.
To be analYaed for trend.there must be et least A detects and Ins than or equal to SO%non-detects.
A P value lee than 0.1 indicates a statistically significant trend.
negative S value indicates a decreasing trend.
•psitsve s...indicates an increasing trend
.

Appendix B-Mann-Kendall Trend Test Analysis
H.F. Lee Energy Complex, Duke Energy Progress, LLC
Goldsboro, North Carolina
FIGURES
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