NC0004987_Final Permit_20160909

NC-
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
S. JAY ZIMMERMAN
Water Resources
ENVIRONMENTAL QUALITY Director
September 9, 2016
Mr -Harry Sideris, Senior Vice President
Environmental, Health and Safety
Duke Energy Carolinas, LLC
Mail Code EC 13K
P.O. Box 1006
Charlotte, North Carolina 28201-1006
Subject: Issuance of NPDES Permit
Permit NC0004987
Marshall Steam Station
Catawba County
Facility Class I
Dear Mr. Sideris:
The Division of Water- Resources is forwarding herewith the Final NPDES permit for Riverbend
Steam Station. This permit renewal is issued pursuant to the requirements of North Carolina
General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the
U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended).
A public hearing was held on June 22, 2016 in Hickory seeking comments on the Draft
permit. This Final permit incorporates recommendations of the DWR Hearing Officer and EPA
as well as other changes:
• Clarifying language was added to the permit in Section A. (2.)/Note 2 to state that
continuous monitoring of Total Suspended Solids is only required when decanting via
pumps.
• Clarifying language was added to the permit in Section A. (2.) to specify that limits
and conditions in Section A. (3.) of the permit apply when water in the ash settling
basin is lowered below the three feet trigger mark.
• Clarifying language was added to the permit in Section A. (2.) to specify that the zero
discharge, limits on fly ash and bottom ash transport water only apply to fly ash and
bottom ash transport water generated after November 1, 2018 and January 31, 2021
accordingly.
• Section A. (7.) was corrected to include an addition of a Note 4 superscript to the total
mercury limit to clarify that limits are effective on January 31, 2021.
• Section A. (17.) was amended to include a separate IWC for dewatering phase toxicity
testing.
• The Groundwater Monitoring Plan attachment was amended to include the following
clarifying language: "3(h). The provisions of sections 3(f) and 3(g) -apply only to the
sampling events described in 3(b) above. The reporting requirements for any
sampling events other than those described in 3(b) above shall be in accordance with
the general provisions of 15A NCAC 02L."
• A Special Condition entitled "Domestic Wastewater Treatment Plan" was added to the
permit to address the EPA comment (Please see Special Condition A. (32.)).
• The Daily Maximum limit for TSS was reduced to 50.0 mg/L for Outfall 002 to meet the
requirements of 40 CFR 423.
State of North Carolina I Environmental Quality I Water Resources
1617 Mail service Center I Raleigh, North Carolina 27699-1611
919 707 9000

I
• The limits for TSS and Oil and Grease were added to Outfall 002A and 002B to meet
the requirements of 40 CFR 423.
• •A Special Condition A. (30.) was modified to address the EPA concern regarding the
permitting of the newly identified seeps and locations of the instream sampling for
compliance with the water quality standards.
• The limits for BOD and Fecal Coiiforms were added to Outfall 002 to address the EPA
comment.
• The footnote describing the effluent limitations for Turbidity was modified to better
address the state turbidity standard (Outfall 002).
• The monitoring frequency for Oil and Grease was increased to Monthly (Outfall 002) to
address the EPA comment.
• The Plan for Identscation of New Discharges was added to the permit to address the
EPA comment.
• The Seep Pollutant Analysis Special Condition (Please see A. (30.)) was modified based
on the discussion with the US Army Corps of Engineers.
• The additional decanting conditions for closing ash ponds were added to the permit to
address the EPA comment.
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the office of
Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless
such a demand is made, this permit shall be final and binding.
Please take notice that this permit is not transferable except after notice to the Division of Water
Resources. The Division may require modification or revocation and reissuance of the permit. This
permit does not affect the legal requirements to obtain other permits which may be required -by the
Division of Water Resources, the Division of Land Resources, the Coastal Area Management Act, or
any other federal or local governmental permit. f
If you have any questions on this permit, please contact Sergei Chernikov at 919-807-6386.
Sincerely,
S. J y Z merman, P.G.
Director, Division of Water Resources
Hardcopy: Central Files,
NPDES Files
Mooresville Regional Office, Water Quality
E -copy: US EPA, Region IV
Aquatic Toxicology Unit

PERMIT No. NC0004987
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other
lawful standards and regulations promulgated and adopted by the North Carolina.
Environmental Management Commission, and the Federal Water Pollution Control Act,
as amended,
Duke Energy Carolinas, LLC
is hereby authorized to discharge wastewater from a facility located at
Marshall Steam Station
At the intersection of NC Highway 150 and NCSR 1841
Terrell -
Catawba County
to receiving waters designated as the Catawba River (Lake Norman) in the Catawba River
Basin in accordance with effluent limitations, monitoring requirements, and other
applicable conditions set forth in Parts I, II, and III hereof.
This permit shall become effective October 1, 2016.
This permit and authorization to discharge shall expire at midnight on September 30,
2021.
Signed this day September 9, 2016.
S. Jay Zi��r>r�arG., Director
Division ate Resources
By Authority of the Environmental Management Commission
Page 1 of 27

PERMIT No. NC0004987
J
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge
are hereby revoked, and as of this issuance, any previously issued permit bearing this
number is no longer effective. Therefore, - the exclusive authority to operate and
discharge from this facility arises under the permit conditions, requirements, terms,
and provisions included herein.
Duke Energy Carolinas, LLC is hereby authorized to:
1. Continue to discharge:
• Outfall 001: once -through cooling water and intake screen backwash
• Outfall 002: treated wastewater (consisting of metal cleaning wastes, coal
pile runoff, ash transport water, domestic wastewater, storm water, low
volume wastes, and FGD wet scrubber wastewater) from the ash settling
basin
• Outfalls 002A and 00213: yard sump overflows
• Internal Outfall 003: non -contact cooling water from the induced draft fan
control house to intake for cooling water pumps
• Internal Outfall 004: treated FGD wet scrubber wastewater to the ash
settling basin
• Seep Outfalls 101 and 102: 2 potentially contaminated groundwater seeps
From a facility located at Duke Energy's Marshall Steam Station at the
intersection of NC Highway 150 and NCSR 1841 in Terrell, Catawba
County;
2. Discharge from said treatment works at the locations specified on the
attached map into the Catawba River (Lake Norman) which is classified
WS -IV and B CA waters in the Catawba River Basin.
Page 2 of 27

PERMIT No. NC0004987
PART I
A. (1.) Effluent Limitations and Monitoring Requirements (Outfall 001)
[ 15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until
expiration, the Permittee is authorized to discharge from Outfall 001 (once -through
cooling water). Such discharges shall be limited and monitored2 by the Permittee as
specified below:
-
DIscFIARGE LIMITATIONS, i
":'T& T012ING REQUIREMENTS'' '. C -:..`, .
:EFFLUENT_ _
Monthly`',,,,
. :.;_Daily
:'Measurement.
: Sample`
" Sa"niple _:
GiiAxa►cTExlsTfcs: = _ .:.
: ;`� Average._'`.
M_ aximum
= Fre uenc
e-
=Location:.. .
Pump logs or
Flow, MGD
Monitor & Report
Daily
similar
Effluent
readings
Temperature
33.3 OC
Daily
Grab
Effluent
November 1 - June 30
Temperature
34.4o
Daily
-Grab
Effluent
Jul 1 - October 31
Free Available
0.2 mg/L
0.5 mg/L
Daily
Grab
Effluent
Chlorines
NOTES•.
1 Once -through cooling water shall not be chlorinated. Should the facility wish to chlorinate
once -through cooling water, Division permission shall be obtained prior to
commencement of chlorination. The monitoring requirement and effluent limitations only
apply if chlorination is commenced.
2 Starting on December 21, 2016, begin submitting Discharge Monitoring Reports
electronically using NC DWR's eDMR application system. Please See Special Condition
A. (31.).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Based upon studies conducted by the permittee and submitted to the Division, it has been
determined pursuant to Section 316(a) of the Clean Water Act that the thermal component of
the discharge assures the protection and propagation of a balanced, indigenous population of
shellfish, fish and wildlife in the receiving water. s
Page 3 of 27

PERMIT No. NC0004987
1
A. (2.) Effluent Limitations and Monitoring Requirements (Outfall 002 - normal
operation/ decanting)
[ 15A NCAC 02B.0400 et seq., 02B.0500 et seq.]
During the period beginning on the effective date of this permit and lasting until
expiration, the Permittee is authorized to discharge from Outfall 002 (ash settling
basin discharge - decanting the free water above the settled ash layer that does
not involve mechanical disturbance of the ash). Such discharges shall be limited
and monitored4 by the Permittee as snecified below-
Ad- —L
ISCHARGE
elow-
EFFI UENT,,L'IiAR®CTERio ics:'
"
DISCHARGE I:IMITATIOBTS,; ' '
; >MONITORINCr REQUIREMENTS
'
''- MOIltihlj� .:::
Avera' e:
Daily
:.Maaciinual
Measur`ement,';
'Fre uenc"
:: Sairiple__:
e. -
Sample ;
iocationl . -
Flow, MGD
Monitor & Report
Weekly
Pump logs
or similar
readings
Effluent
Oil and Grease
9.0 mg/L
12.0 mg/L
Monthly
Grab
Effluent
Total Suspended Solids2
20.0 mg/L
50.0 mg/L
Monthly
Grab
Effluent
BOD, 5 -day, 20° C 2
30.0 mg/L
45.0 mg/L
Monthly
Grab
Effluent
Fecal Coliform (geo. mean)
200/100 mL
400/100 mL
Monthly
Grab
Effluent
Total Arsenic, µg/L
Weekly
Grab
Effluent
Total Copper
1.0 mg/L3
1.0 mg/L3
Weekly
Grab
Effluent
Total Iron
1.0 mg/L3
1.0 mg/L3
Weekly
Grab
Effluent
Total Mercury6
Weekly
Grab
Effluent
Total Selenium, µg/L
Weekly
Grab
Effluent
Turbiditys, NTU
Monthly
Grab
Effluent
Nitrate/nitrite as N, mg/L
Quarterly
Grab
Effluent
Bromide, mg/L
Monthly
Grab
Effluent
Total Hardness, mg/L
Monthly
Grab
Effluent
Total Nitrogen
NO2+NO3+TKN , m L
Monitor &Report
Quarterly
Grab
Effluent
Total Phosphorus, mg/L
Monitor & Report
Quarterly
Grab
Effluent
Chronic Toxicity
See Part I, Section A. (17.)
Monthly
Grab
Effluent
pH7
Between 6.0 and 9.0 Standard
Units
Monthly
Grab
Effluent
NOTES:
1 Effluent sampling shall be conducted at the discharge from the ash settling basin prior to
mixing with any other waste stream(s).
2 The facility shall continuously monitor TSS concentration when the decanting process
commences and the decanting pump shall be shutoff automatically when the one half of
the Daily Maximum limit (15 minutes average) is exceeded. Pumping will be allowed to
continue if interruption might result in a dam failure or damage. The continuous TSS
monitoring only required when the pumps are employed for decanting.
3 The limits for total copper and total iron only apply when chemical metal cleaning
wastewaters are being discharged.
4 Starting on December 21, 2016, begin submitting Discharge Monitoring Reports
electronically using NC DWR's eDMR application system. Please See Special Condition A.
(31.)..
5 The net turbidity shall not exceed 50 NTU using a grab sample and measured by the
difference between the effluent turbidity and the background turbidity. The sample for the
Page 4 of 27

L 10
PERMIT No. NC0004987
background turbidity shall be taken at point in the receiving waterbody upstream of the
discharge location, and the background turbidity and the effluent turbidity samples shall
be taken within the same 24 hour period.
NTU - Nephelometric Turbidity Unit.
6 The facility shall use EPA method 1631E.
7 The facility shall continuously monitor pH when the decanting process commences and, the
decanting pump shall be shutoff automatically when ' 15 minutes running average pH falls
below 6.1 standard units or rises above 8.9 standard units. Pumping will be allowed to
continue if interruption might result in a dam failure or damage.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The facility is allowed to drawdown the wastewater in the ash pond to no less than three
feet above the ash.
The level of water in the ash pond should not be lowered more than 1 ft/week, unless
approved by the DEQ Dam Safety Program.
The facility shall use a floating pump station with free water skimmed from the basin
surface using an adjustable weir.
By November 1, 2018 there shall be no discharge of pollutants in fly ash transport water.
This requirement only applies to fly ash transport water generated after November 1,
2018.
By January 31, 2021 there shall be no discharge of pollutants in bottom ash transport
water. This requirement only applies to bottom ash transport water generated after
January 31, 2021.
The limits and conditions in Section A. (3.) of the permit apply when water in the ash
settling basin is lowered below the three feet trigger mark.
The facility shall notify DWR Complex NPDES Permitting Unit and DWR Mooresville
Regional Office seven calendar days prior to the commencement of the decanting.
When the facility commences the ash pond/ponds decommissioning process, the facility
shall treat the wastewater discharged from the ash pond/ponds by the physical -chemical
treatment facilities. ,
Page 5 of 27

PERMIT No. NC0004987 •
A. (3.) Effluent Limitations and Monitoring Requirements (Outfall 002 -
dewatering phase)
[ 15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until
expiration, the Permittee is authorized to discharge from Outfall 002 Ash Settling
Basin Discharge (Dewatering - removing the interstitial water). Such discharges
shall be limited and monitored4 by the Permittee as specified below:
EFFLUENT=CIiAR_ACTERISTI_CS.
DISCHARGE
LIMITATIONS : • ' ' • ._ : _
''- :. ; , .,'.-MONITORING;REQUIR
ME_NTS, -,
Mgrit}lly, ;
,Avera�'e•
Dally
Maximum;:
-Me1SIIiemellt`
Fre ueno
Sa_ xiiple
=e,: :
"'Sample;;
L'o`cafionl
Flow
1.0 MGD
Weekly
Pump logs
or similar
readings
Effluent
Oil and Grease
9.0 mg/L
12.0 mg/L
Monthly
Grab
Effluent
Total Suspended Solids2
20.0 mg/L
50.0 mg/L '
Monthly
Grab
Effluent
Total Arsenic
397.1 µg/L
11,121 µg/L
Weekly
Grab
Effluent
Total Copper
1.0 mg/L3
1.0 mg/L3
Weekly
Grab
Effluent
Total Iron
1.0 mg/L3
1.0 mg/L3
Weekly
Grab
Effluent
BOD, 5 -day, 20° C 2
30.0 mg/L
45.0 mg/L
Monthly
Grab
Effluent
Fecal Coliform (geo. mean)
200/ 100 mL
400/100 mL
Monthly
Grab
Effluent
Total Mercury6
Weekly
Grab
Effluent
Total Selenium, µg/L
Weekly
Grab
Effluent
Turbidity5, NTU
Monthly
Grab
Effluent
Nitrate/nitrite as N, mg/L
Quarterly
Grab
Effluent
Bromide, mg/L
Monthly
Grab
Effluent
Total Hardness, mg/L
Monthly
Grab
Effluent
Total Nitrogen
NO2+NO3+TKN , m L
Monitor &Report
Quarterly
Grab
Effluent
Total Phosphorus, mg/L
Monitor & Report
Quarterly
Grab
Effluent
Chronic Toxicity
See Part I, Section A. (17.)
Monthly
Grab
Effluent
pH7
Between 6.0 and 9.0 Standard
Units
Monthly
Grab
Effluent
NoTEs•
1 • Effluent sampling shall be conducted at the discharge from the ash settling basin prior to
mixing with any other waste stream(s).
2 The facility shall continuously monitor TSS concentration when the dewatering process
commences and the dewatering pump shall be shutoff automatically when the one half
of the Daily Maximum limit (15 minutes average) is exceeded. Pumping will be allowed
to continue if interruption might result in a dam failure or damage.
3 The limits for total copper and total iron only apply when chemical metal cleaning
wastewaters are being discharged.
4 Starting on December 21, 2016, begin submitting Discharge Monitoring Reports
electronically using NC DWR's eDMR application system. Please See Special Condition
A. (31.).
5 The net turbidity shall not exceed 50 NTU using a grab sample and measured by the
difference between the effluent turbidity and the background turbidity. The sample for
the background turbidity shall be taken at point in the receiving waterbody upstream of
Page 6 of 27

PERMIT No. NC0004987
the discharge location, and the background turbidity and the effluent turbidity samples
shall be taken within the same 24 hour period.
NTU - Nephelometric Turbidity Unit.
6 The facility shall use EPA method 1631E.
7 The facility shall continuously monitor pH when the dewatering process commences
and the dewatering pump shall be shutoff automatically when 15 minutes running
average pH falls below 6.1 standard units or rises above 8.9 standard units. Pumping
will be allowed to continue if interruption might result in a dam failure or damage.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The level of water in the ash pond should not be lowered more than 1 ft/week, unless
approved by the DEQ Dam Safety Program.
By November 1, 2018 there shall be no discharge of pollutants in fly ash transport water.
This requirement only applies to fly ash transport water generated after November 1,
2018.
By January 31, 2021 there shall be no discharge of pollutants in bottom ash transport
water. This requirement only applies to bottom ash transport water generated after
January 31, 2021.
When the facility commences the ash pond/ponds decommissioning process, the facility
shall treat the wastewater discharged from the ash pond/ponds by the physical -chemical
treatment facilities.
Page 7 of 27

PERMIT No. NC0004987
A. (4.) Effluent Limitations and Monitoring Requirements (Outfall 002A)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until
expiration, the Permittee is authorized to discharge from Outfall 002A (yard sump # 1
overflows). Such discharges shall be limited and monitored2 by the Permittee as
specified below:
'
EFFLUENT•; ;:
— Disc13ARGE LIMITATIONS.':- `',•::
.•MO1vITORING, REQUIREMENTSs '
. =;c < `:.:'' — j.
: 'M011tlilj!`Measuiement
•
Sariiple
:'Sairiple''';
CHARACTERISTICSr:•{ •
Ave=a e .
'.`Maximum= °'
Fre "ueiic '
T ' `ei :'
;_Locations
Flow, MGD
Per discharge
Estimate
Effluent
event
pH
Between 6.0 and 9.0 Standard
Per discharge
Grab
Effluent
Units
event
Total Suspended Solids
30.0 mg/L
100.0 mg/L
Per discharge
Grab
Effluent
event
Oil and Grease
15.0 mg/L
20.0 mg/L
Per discharge
Grab
Effluent
event
Total Iron, mg/L
Per discharge
Grab
Effluent
event
NOTES'
1 Effluent samples shall be collected at a point upstream of the discharge to the Catawba River.
2 Starting on December 21, 2016, begin submitting Discharge Monitoring Reports
electronically using NC DWR's eDMR application system. Please See Special Condition A.
(31.).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
All flows shall be reported on monthly DMRs. Should no flow occur during a given
month, the words "No Flow" shall be clearly written on the front of the DMR. All samples
shall be of a representative discharge.
Page 8 of 27

PERMIT No. NC0004987
A. (5.) Effluent Limitations and Monitoring Requirements (Outfall 002B)
[ 15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until
expiration, the Permittee is authorized to discharge from Outfall 002B (yard sump #2
overflows). Such discharges shall be limited and monitored2 by the Permittee as
specified below:
r: -.• --.,;;, :._
..- DISCHAR('rE`L'IlYIITATIUNS '.. --�
MO NITORING •REQUIREMENTS;
!_'';, ° `� •. __ _ _ ._.­-• :.
=
.•r
Monthly ' ,."
Daily, _.
.
Measurement.
: ;-•.'Sairiple,
;, Sample: _-
CFIARACTERISTICS_ .• - ,,
, - ' Avera 6 , ;
:• ,
. ,; Maximum ..
•; _Fre uenc
e . _ ..
Locationl
Flow, MGD
Per discharge
Estimate
Effluent
event
Between 6.0 and 9.0 Standard
Per discharge
Grab
Effluent
p H
Units
event
Total Suspended Solids
30.0 mg/L
100.0 mg/L
Per discharge
event
Grab
Effluent
Oil and Grease
15.0 mg/L
20.0 mg/L
Per discharge
event
Grab
Effluent
Total Iron, mg/L
Per discharge
Grab
Effluent
11
event
NOTES'
1 Effluent samples shall be collected at a point upstream of the discharge to the Catawba River. .
2 Starting on December 21, 2016, begin submitting Discharge Monitoring Reports
electronically using NC DWR's eDMR application system. Please See Special Condition A.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
All flows shall be reported on monthly DMRs. Should no flow occur during a given
month, the words "No Flow" shall be clearly written on the front of the DMR. All samples
shall be of a representative discharge.
Page 9 of 27

PERMIT No. NC0004987
A. (6.) Effluent Limitations and Monitoring Requirements (Internal Outfall 003)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until
expiration, the Permittee is authorized to discharge from Internal Outfall 003 (non -
contact cooling water from the induced draft fan control house). Such discharges
shall be limited and monitored2 by the Permittee as specified below:
:; ;. '
DISCF7ARGEr`'LINlITATIQNS
-.
`.
'MONIT_ 012ING' REQUIREIYIEN_TS. = _
,: ' + :.,- .. - -.
EFFLUENT
w=
CiiAI2ACTEi2ISTICS "
_
= Nionfhly;.
Daily': ,_
�•Measureineiit
Sample_'=.'
:$ampler
Ayera' a
Maximum;'L®catiori.>
.-
Flow, MGD
Semi-annually
Estimate
Effluent
Temperature, OC
Semi-annually
Grab
Effluent
Total Residual
Semi-annually
Grab
Effluent
Chlorine',µ L
Free Available
'
0.2 m g�L
m L
0.5 g�
Semi-annually
Grab
Effluent
Chlorine'
pH
Between 6.0 and 9.0 Standard
Semi-annually
Grab
Effluent
Units
NoTEs:
1 Monitoring requirements apply only if chlorine is added to the cooling water. Neither free
available chlorine nor total residual chlorine may be discharged from any unit for more than
two hours in any one day and not more than one unit in any plant may discharge free
available chlorine or total residual chlorine at any one time.
2 Starting on December 21, 2016, begin submitting Discharge Monitoring Reports
electronically using NC DWR's eDMR application system. Please See Special Condition A.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Limitations shall be met at the discharge point.
Page 10 of 27

PERMIT No. NC0004987
A. (7.) Effluent Limitations and Monitoring Requirements (Internal Outfall 004)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until
expiration, the Permittee is authorized to discharge from Internal Outfall 004 (treated
FGD wet scrubber wastewater to ash settling basin). Such discharges shall be limited
and monitored2 by the Permittee as specified below:
EFFLUENT. ' `. ;. ` .; _
"CFIARACTERISTIC$;; r' -
DISCHARGE;_I.INIIT_ ATIONS'• "• .
MONITORING REQUIREMENTS' :`.
=Monthly;_' ". Baily " t •
Average Maximum. °
IVIeasureanent
F=e_ 'uency.. _
-
SamIple,; `
T. .e'
.
'_Sample
I:ocationi'
Flow, MGD
Monitor & Report
Monthly
Pump logs or
similar
readings
Effluent
Total Arsenic
8.0 µg/L4
11.0 µg/L4
Quarterly
Grab
Effluent
Total Mercury3, ng/L
356.0 ng/L4
788.0 ng/L4
Quarterly
Grab
Effluent
Total Selenium
12.0 pg/L4
23.0 pg/L4
Quarterly
Grab
Effluent
Nitrate/nitrite as N
4.4 mg/L4
17.0 mg/L4
Quarterly
Grab
Effluent
pH
Between 6.0 and 9.0 Standard
Units
Quarterly
Grab
Effluent
NOTES'
1 Sample Location: E - Effluent samples shall be collected from the constructed wetland
prior to discharge to the ash settling basin.
2 Starting on December 21, 2016, begin submitting Discharge Monitoring Reports
electronically using NC DWR's eDMR application system. Please See Special Condition
A. (31.).
3 The facility shall use EPA method 1631E.
4 The TBEL limits shall become effective on January 31, 2021. This time period is
provided in order for the facility to budget, design, and construct the treatment system.
The facility shall monitor these parameters even before the limits become effective.
All flows shall be reported on monthly DMRs. Should no flow occur during a given
month, the words "No Flow" shall be clearly written on the front of the DMR. All samples
shall be of a representative discharge.
Page 11 of 27

PERMIT No. NC0004987
A. (8.) Effluent Limitations and Monitoring Requirements (Outfall 101)
[15A NCAC 02B.0400 et seq., 02B.0500 et seq.]
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge from outfall 101 - Seep Discharge. Such discharges shall
be limited and monitored) by the Permittee asspecified below:
='EFFLUENT`CHif&A TERISTICS:..;;=.
-
DI$CHARGE,I:IMITATIONS`.;,;` ';•';,` :';; .0 :";;;:' '.RIjON;T012INGREQUIREMENTS;`,: „• _
MbAthly ' Daily . Measureinenf" : • Sample Sample'. _
=Avera e ' Maximum' "_ Fre 'iienc z ` T re". Location _
- _.
Flow, MGD
Monthly/ Quarterly
Estimate
Effluent
H3
Monthly Quarterly
Grab
Effluent
TSS
30.0 mg/L 100.0 mg/L
Monthly/ Quarterly
Grab
Effluent
Oil and Grease
15.0 m L 20.0 mg/L
Monthly Quarterly
Grab
Effluent
Fluoride, µ L
Monthly Quarterly
Grab
Effluent
Total Mercury4, n L
Monthly/ Quarterly
Grab
Effluent
Total Barium, m L
Monthly/ Quarterly
Grab
Effluent
Total Iron, µ L
Monthly Quarterly
Grab
Effluent
Total Manganese, µ L
Monthly Quarterly
Grab
Effluent
Total Zinc, µg/L
Monthly/ Quarterly
Grab
Effluent
Total Arsenic, µ L
Monthly Quarterly
Grab
Effluent
Total Cadmium, µ L
Monthly Quarterly
Grab
Effluent
Total Chromium, pg/L
Monthly/ Quarterly
Grab
Effluent
Total Copper, pg/L
Monthly/ Quarterly
Grab
Effluent
Total Lead, µ /L
Monthly Quarterly
Grab
Effluent
Total Nickel, µ L
Monthly/ Quarterly
Grab
Effluent
Total Selenium, µg/L
Monthly/ Quarterly
Grab
Effluent
Nitrate nitrite as N, m L
Monthly Quarterly
Grab
Effluent
Sulfates, mg/L
Monthly Quarterly
Grab
Effluent
Chlorides, m L
Monthly Quarterly
Grab
Effluent
TDS, m /L
Monthly/ Quarterly
Grab
Effluent
Total Hardness, mg/ L
Monthly/Quarterly
Grab
Effluent
Temperature, OC
Monthly/ Quarterly
Grab
Effluent
Conductivity, µmho/cm
Monthly/ Quarterly
Grab
Effluent
Notes:
1: Starting on December 21, 2016, begin submitting Discharge Monitoring Reports
electronically using NC DWR's eDMR application system. Please See Special Condition A.
(31.).
2. The facility shall conduct monthly sampling from the effective date of the permit. After one
year from the effective date of the permit the monitoring will be reduced to quarterly
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4. The facility shall use EPA method 1631E.
If the facility is unable to obtain a seep sample due to the dry or low flow conditions
preventing the facility from obtaining a representative sample, then "no flow" should be
reported on the DMR. This requirement is established in the Section D of the Standard
Conditions and 40 CFR 122.41 (j).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 12 of 27

PERMIT No. NC0004987
A. (9.) Effluent Limitations and Monitoring Requirements (Outfall 102)
[ 15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge from outfall 102 - Seep Discharge. Such discharges shall
be limited and momwrcu-
,EFFLUENT CHARACTERISTICS ", DISQHAi2GEIGIWTATIONS '" MOIJITORINGSREQUIREIVIENTSi
Nionfhly.. 1VIoIt'hly' Daily
"Avera e" Maxiinnm; - "•. iwera "e" Masnaurn .
"
Flow, MGD'
Monthly/ Quarterly
Estimate
Effluent
Monthly/ Quarterly
Grab
Effluent
H3
TSS
30.0 mg/L 100.0 mg/L
Monthly/Quarterly
Grab
Effluent
Oil and Grease
15.0 m /L -20.0 mg L
Monthly Quarterly
Grab
Effluent
Fluoride, mg/L
Monthly Quarterly
Grab
Effluent
Total Mercury4, ng/L
Monthly Quarterly
Grab
Effluent
Total Barium, m /L
Monthly/ Quarterly
Grab
Effluent
Total Iron, rag/L
Monthly/ Quarterly
Grab
Effluent
Total Manganese, µg/L
Monthly Quarterly
Grab
Effluent
Total Zinc, µg/L
Monthly/ Quarterly
Grab
Effluent
Total Arsenic, µ /L
Monthly Quarterly
Grab
Effluent
Total Cadmium, µg L
Monthly Quarterly
Grab
Effluent
Total Chromium, pg/L
Monthly Quarterly
Grab
Effluent
Total Copper, pg/L
Monthly Quarterly
Grab
Effluent
Total Lead, pg/L
Monthly Quarterly
Grab
Effluent
Total Nickel, pg/L
Monthly Quarterly
Grab
Effluent
Total Selenium,
Monthly Quarterly
Grab
Effluent
N, mg/L
Nitrate/nitrite as N,
Monthly Quarterly
Grab
Effluent
Euent
Sulfates, mg/L
Monthly/ Quarterly
Grab
Effluent
Chlorides, mg/L
Monthly Quarterly
Grab
Effluent
TDS, mg/L
Monthly Quarterly
Grab
Effluent
Total Hardness, m L
Monthly Quarterly
Grab
Effluent
Temperature, OC
Monthly Quarterly
Grab
Effluent
Conductivity, µmho/cm
Monthly/ Quarterly
Grab
I Effluent
Notes:
1. Starting on December 21, 2016, begin submitting Discharge Monitoring Reports
electronically using NC DWR's eDMR application system. Please See Special Condition A.
(31.).
2. The facility shall conduct monthly sampling from the effective date of the permit. After one
year from the effective date of the permit the monitoring will be reduced to quarterly
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 -standard units.
4. The facility shall use EPA method 1631E.
If the facility is unable to obtain a seep sample due to the dry or low flow conditions
preventing the facility from obtaining a representative sample, then "no flow" should be
reported on the DMR. This requirement is established in the Section D of the Standard
Conditions and 40 CFR 122.41 (j).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 13 of 27

PERMIT No. NC00049870
A. (10.) ADDITIONAL CONDITIONS AND DEFINITIONS
1. EPA methods 200.7 or 200.8 (or the most current versions) shall be used for
analyses of all metals except for total mercury (EPA Method 1631E).
2. All effluent samples for all external outfalls shall be taken at the most
accessible location after the final treatment but prior to discharge to waters of
the U.S. (40 CFR 122.410)).
3. The term low volume waste sources means wastewater from all sources except
those for which specific limitations are otherwise established in this part (40
CFR 423.11 (b)).
4. The term chemical metal cleaning waste means any wastewater resulting from
cleaning any metal process equipment"with chemical compounds, including,
but not limited to, boiler tube cleaning (40 CFR 423.11 (c)).
5. The term metal cleaning waste means any wastewater resulting from cleaning
[with or without chemical cleaning compounds] any metal process equipment
including, but not limited to, boiler tube cleaning, boiler fireside cleaning, and
air preheater cleaning (40 CFR 423.11 (d)).
6. For all outfalls where the flow measurement is to be "estimated" the estimate
can be done by using calibrated V -notch weir, stop -watch and graduated
cylinder, or other method approved by the Division.
7. The term "FGD wet scrubber wastewater" means wastewater resulting from the
use of the flue -gas desulfurization wet scrubber.
A. (11.) TOXICITY RE -OPENER CONDITION
This permit shall be modified, or revoked and reissued to incorporate toxicity limitations
and monitoring requirements in the event toxicity testing or other studies conducted on
the effluent or receiving stream indicate that detrimental effects may be expected in the
receiving stream as a result of this discharge.
A. (12.) APPLICABLE STATE LAW (STATE ENFORCEABLE ONLY)
The facility shall meet the requirements of Senate Bill 729 (Coal Ash Management Act). This
permit may be reopened to include new requirements imposed by Senate Bill 729.
A. (13.) POLYCHLORINATED BIPHENYL COMPOUNDS
There shall be no discharge of polychlorinated biphenyl compounds such as those
commonly used for transformer fluid.
A. (14.) BIOCIDE CONDITION
The permittee shall not use any biocides except those approved in conjunction with the
permit application. The permittee shall notify the Director in writing not later than
ninety (90) days prior to instituting use of any additional biocide used in cooling systems
which may be toxic to aquatic life other than those previously reported to the Division
of Water Resources. Such notification shall include completion of Biocide Worksheet
Form 101 and a map locating the discharge point and receiving stream. Completion of
Biocide Worksheet Form 101 is not necessary for those outfalls containing toxicity
testing. Division approval is not necessary for the introduction of new biocides into
outfalls currently tested for whole effluent toxicity.
Page 14 of 27

PERMIT No. NC0004987
A. (15.) INTAKE SCREEN BACKWASH
Continued intake screen backwash discharge and overflow from the settling basin are
permitted without limitations or monitoring requirements.
A. (16.) BEST MANAGEMENT PRACTICES
It has been determined from information submitted that the plans and procedures in
place at Marshall Steam Station are equivalent to that of a Best Management Practice
(BMP) .
A. (17.) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT — OUTFALL 002
[ 15A NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or
significant mortality to Ceriodaphnia dubia at an effluent concentration of 23.0% for
decanting and 2.6% for dewatering.
The permit holder shall perform at a minimum, monthl monitoring using test
procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay
Procedure," Revised December 2010, or subsequent versions or "North Carolina Phase
II Chronic Whole Effluent Toxicity Test Procedure" (Revised- December 20 10) or
subsequent versions. Effluent sampling for this testing must be obtained during
representative effluent discharge and shall be performed at the NPDES permitted fmal
effluent discharge below all treatment processes.
If the monthly test procedure results in a failure or ChV below the permit limit,
then multiple -concentration testing shall be performed at a minimum, in each of
the two following months as described in "North Carolina Phase II Chronic Whole
Effluent Toxicity Test Procedure" (Revised -December 2010) or subsequent
versions.
All toxicity testing results required as part of this permitcondition will be entered on
the Effluent Discharge Monitoring Form (MR -1) for the months in which tests were
performed, using the parameter code TGP3B for the pass/fail results and THP3B for
the Chronic Value. Additionally, DWR Form AT -3 (original) is to be sent to the
following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1623 Mail Service Center
Raleigh, North Carolina 27699-1623
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section
no later than 30 days after the end of the reporting period for which the report is
made.
Test data shall be complete, accurate, include all supporting chemical/ physical
measurements and all concentration/ response data, and be certified by laboratory
supervisor and ORC or approved designate signature. Total residual chlorine of the
effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Page 15 of 27

LZ J0 9I aged
•.zauueur siil4 ui pal-ea-ij uailm Ouiueajo lelaui jo moll am sours .zaTil
zad ure z iljtuz auo ueil} ssal aq sX-emje jjim pad ieqosrp iaddoo pug uo xt �o Ufa quenb aid
}L -u4 jgnop puoXaq ano id o} jjna-gjip si 11 `ouinjd aim jo sail uzasaxa ails J -e s.1ox-el aouj za4ui
f,repunoq jo aoualsixa om pue `suralgoid uorjnlip jo asn-eoag •spuod qsu ut 4uaugea-q
Xq 4uao zad +66 01 Z6 ,Io ague -I QIP ul sa}s-em Ouiuealo .zalloq ui sjelauz jo uo4L-.4ua3uo0
am aonpai of alglssod si 11 suoi}ipuoo umliao .zapun 4 -em pal -ea suouiop uaaq suit }I
S3;LSVtA JNIMVR'I7 'IVJMW Zd3IIMgH7 (-61) 'V
•papoau }ou si uol��oUra_iao orpouad `Tnu.zad
aul;o uual aq ioj Tstxa of pag-4jz)o uaaq s -eq auinjon as-enbop-ei-eip Juana gq4 uI :2,LOK
•sX-ep avid ulmlm joToaiiQ om of paaxodoi aq lleils uoraeoUwQo -Tons
2urjoajje suoiReTado 4ueld o4 sae
2uilo Xuy '-.mars 2uimojloj ails .zoj spuod Qq4 ui pallsodap
aq o} paaoadxa spjlos IT apnjoui o4 ioloej X4ajes aaenbage LjayA ajq-ejrene sI aulnjon
pa zmba z aixa 4-euoraBojjra iao u (S) pug `auinjon paa elnoleo aila jo uolaupr[eA mope 01
Ire}ap juapgns ur auInJOA J31Prn Q3JJ aila. JO SuoTsuauiip am Jo s}uauza.inSL'aui IeoisriiAd (3)
`puod i s -e o-qj jo auinlOA .IaILm aa.Ij Ien4o-e aria (l) :.&Ipomne 2uinssi aIuuod ails o4 I ioda.I
pu-e auiuuo4op IpT4s aai}iuuad am XTTnuuy •saurrj IT ju sauinjon uInUIIU-nu pas[nbai
aim ureaureul o� xapzo ui sarjjoudLz) a2-e.iols ajcTjjen-e am a�sejua as* zail}o Io spuod
am uIOJJ ILIO}-eUI pal}}as aAouia.z Ileus aailiuuad aila `;iuriad am jo u iaa am 2uun(I
•0•T
Jo IuatogJaoo JJOUr i -e OUIsn uailm `;uana He.Iurej moil--FZ `sears -0T -e uzo.IJ 2uglnsoi puod
am o} smolt jjouru 0 pu-e lMjurei aowip 0 snld sa2segosip lu-eld ino-q-VZ uinu-i=u-i
am jo urns aim oT auajenmba auznjon .za;um aa.zj ulnuiiuiuz le sauii� Ili J -e SUTe Urem
pup sapinord oo;jjuuad amssalun puod Ilse aid oT sa}s-em jueld jo a2xegosip ou
aq lleLls azaila `uopuzidxa lrjun 2ugsel pu-e1Iuuad si ilj jo 34L -p @A-goaj;a aid uo 2uruuiljag
KISV$ J11IPIizas HSV (-s1) -V
uu0}iuoui Ter
lui am jo muoul Qm OurmolloJ
muoui am jo rS-ep js-ej au} uum -iolul ou paaalduroo aq oT Ougsaj dn-moljoj 01-81pouzu l
azinbaj Ilim pu-e Asa; ptiL-aui uu a}n}ia suoo lleils `slo iluoo T4uauzuo.Irnua aj-er zdo.zdd�
pu-e `uoraonpojda i uisiue2�.io losjuoo runuiruT `reAlA ins uisiu-02jo losauoo uinuiruiul
se dons `juauinoop paTto ails ui paptoads se suor_jtpuoo Isa; anaujou of ainjre� :gyO1\l
•saiuzjl .io sluouiaunboi
.OuuoTruoui al-eu io le apnloul o4 pagipoui pu-e pauado-a i aq Seu-i Iluuod si
iT} `ureasas
�3UTAIaoa.i am of sTo-educt leraua;od aajoipui soo inosQ-d zaT-eAA, jo uoisinlQ-emlose0 uT.IoN
ail} Xq paurzolrad s4sal jo luamomnboi 2iuuo;tuoui still uioij �ej-ep 4saT Sue pino-qS
il}uoui Oupsal 4toixol aija uo pas -eq sI aou-eijdmoo 2410 xo}
jo juauissassV •Llauoui Ouimolloj aria. 5uiinp poiinba-i aq Iltm 2uuoTtuoul `pa.zinba.z
st 2ut.zoltuoui fgl0lxo4 goliTm ui muoTu -e 2ur znp io4luoui of TTe3 oa}}pmod aill pinor.IS
•anoq-e panto ssaipp-e am T -e uogoaS
soouaioS aa4uM aid} oT pal}tuzgns aq Ilegs I iodaj aiT,I, •Uuoj am jo -ease 4uouiuioo am
ut «nno13 0M„ jo uor4-elou am mtm T.ioda i ail} jo sears/muoui am pu-e `X unoo `.ioquinu
adid `.ioquinu 4tuuad `aureu f4ijto-q.l a�Ta 2uppm ui uuoj }sa4 (,LV) �toixo; of nb� ailT jo
don ai44 I -e paluool uorauUuojur aid o4alduioo Ilan aalltuuad cnI4 `pazinba i, si �3uuo4juoui
totX04 ilotilm uI illuoui -e Ouunp r4iltoL-j am uto-ij moll jo aOxeilosip ou aq a zaila pinoilS
L86t0000M 'ODI -LINHad

PERMIT No. NC0004987
The application of physical/ chemical methods of treating wastes has also been
demonstrated to be effective in the treatment of metal cleaning wastes. However, the
effectiveness of ash pond treatment should be considered in relation to the small
differences in effluent quality realized between the two methods.
It has been demonstrated that the presence of ions of copper, iron, nickel, and zinc in
the ash pond waters was not measurably increased during the ash pond equivalency
demonstration at the Duke Energy's Marshall Steam Station. Therefore, when the
following conditions are implemented during metal cleaning procedures, effective
treatment for metals can be obtained at this facility:
(1) Large ash basin providing potential reaction volumes.
(2) Well-defined shallow ash delta near the ash basin influent.
(3) Ash pond pH of no less than 6.5 prior to metal cleaning waste addition.
(4) Four days retention time in ash pond with effluent virtually stopped.
(5) Boiler volume less than 86,000 gallons.
(6) Chemicals for cleaning to include only one or more of the following:
(a) Copper removal step- sodium bromate, NaBr03; ammonium carbonate,
(NH4)2CO3; and ammonium hydroxide, NH40H.
(b) Iron removal step -hydrochloric acid, HCl; and ammonium bifluoride, (NH4)BF2
and proprietary inhibitors.
(7) Maximum dilution of wastes before entering ash pond 6 to 1.
(8) After treatment of metal cleaning wastes, if monitoring of basin effluents as required
by the permit reveals discharges outside the limits of the permit, the permittee will
re -close the basin discharge, conduct such in -basin sampling as necessary to
determine the cause of nonconformance, will take appropriate corrective actions,
and will file a report with EPA including all pertinent data.
A. (20.) FLOATING MATERIALS
The Permittee shall report all visible discharges of floating materials, such as an oil
sheen, to the Director when submitting DMRs.
A. (21.) CHEMICAL DISCHARGES
Discharge of any product registered under the Federal Insecticide, Fungicide, and
Rodenticide Act to any waste stream which may ultimately be released to lakes, rivers,
streams or other waters of the United States is prohibited unless specifically authorized
elsewhere in- this permit. Discharge of chlorine from the use of chlorine gas, sodium
hypochlorite, or other similar chlorination compounds for disinfection in plant potable
and service water systems and in sewage treatment is authorized. Use of restricted use
pesticides for lake management purposes by applicators licensed by the N.C. Pesticide
Board is allowed.
A. (22.) PRIORITY POLLUTANT ANALYSIS — OUTFALL 002
The Permittee shall conduct a priority pollutant analysis (in accordance with 40 CFR
Part 136) once per permit cycle at outfall 002 and submit the results with the application
for permit renewal.
Page 17 of 27

PERMIT No. NC0004987
A. (23.) WAIVERS
Nothing contained in this permit shall be construed as a waiver by permittee or any
right to a hearing it may have pursuant to State or Federal laws or regulations.
A. (24.) GROUNDWATER MONITORING WELL CONSTRUCTION AND SAMPLING (STATE ENFORCEABLE
ONLY)
The permittee shall conduct groundwater monitoring to determine the compliance of
this.NPDES permitted facility with the current groundwater standards found under 15A
NCAC 2L .0200. The monitoring shall be conducted in accordance with the Sampling
Plan approved by the Division. See Attachment 1.
A. (25.) STRUCTURAL INTEGRITY INSPECTIONS OF ASH POND DAM
The facility shall meet the dam design and dam safety requirements per 15A NCAC
2K.
A. (26.) CLEAN WATER ACT SECTION 316(a) THERMAL VARIANCE
The thermal variance granted under Section 316(a) terminates on expiration of this
NPDES permit. Should the permittee wish a continuation of its 316(a) thermal
variance beyond the term of this permit, reapplication for such continuation shall be
submitted in accordance with 40 CFR Part 125, Subpart H and Section 122.21(1) (6)
not later than 180 days prior to permit expiration. Reapplication shall include a basis
for continuation such as a) plant operating conditions and load factors are unchanged
and are expected to remain so for the term of the reissued permit; b) there are no
changes to plant discharges or other discharges in the plant site area which could
interact with the thermal discharges; and c) there are no changes to the biotic
community of the receiving water body which would impact the previous variance
determination.
The next 316(a) studies shall be performed in accordance with the Division of Water
Resources approved plan. The temperature analysis and the balanced and indigenous
study plan shall conform to the specifications outlined in 40 CFR 125 Subpart H, the
EPA's Draft 316(a) Guidance Manual, dated 1977, and the Region 4 letter to NCDENR,
dated June 3, 2010. EPA shall be provided an opportunity to review the plan prior to
the commencement of the study.
Copies of all the study plans, study results, and any other applicable materials should
be submitted to:
1) Electronic Version Only (pdf and CD)
Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
2) Electronic Version (pdf and CD) and Hard Copy
Division of Water Resources
Water Sciences Section
1621 Mail Service Center
Raleigh, NC 27699-1621
Page 18 of 27

PERMIT No. NC0004987
A. (27.) CLEAN WATER ACT SECTION 316 (B)
The permittee shall comply with the Cooling
g Wate materials required FR
required by the Rule with take Structure Rule per 40 e
125.95. The permittee shall submit all
next renewal application.
A. (28.) FISH TISSUE MONITORING NE month POND annually and submit the results with
SCHARGE - OUTFALL 002
The facility shall conduct fish tissue g is to evaluate
the NPDES permit renewal apphby1�si The
this ueobjective
near of the monitoring the Ash Pond discharge. The
potential uptake of pollutants and mercury. The
parameters analyzed in fish tissue shall withe arsenic, lan approved by the
monitoring shall be conducted in accordance
Division.
A. (29.) INSTREAM MONITORING onitoring (approximately roximately one mile
The facility shall conduct semiannual instream mand discharge) for
upstream and approximately one mile downstream of the ash p er, zinc,
arsenic, selenium, mercury (method 1631E), chromium, l In )ea monitoring should
bromide, total hardness, and total dissolved solids (TDS).
ready
been establshed through the BIP
be conducted at the stations that havehall be submitt dlwith the NPDES permit
monitoring program. The monitoring results
renewal application.
A. (30.) DISCHARGE FROM SEEPAGE
Existing Discharges from Seepage ash
The facility identified 2 non -engineered discharges elow and from are depicted ge from e n the tm P
basin. The locations of the seeps are id
attached to the permit.
Table 1. Discharge Coordinates and Assigned Outfall Numbers
Latitude Longitude Outfall number
Discharge ID 101
S-1 35036 71 80057'62"102
S-2
35042'56" 80021'56"
l meeting the
The outfall for these discharges is .0228.ugh an effluent Within180 days of theeeffective date of this
requirements in 15A NCAC 2 linmeeting the
permit, the permittee shall demonstrate, through in -stream and ds in the receiving
requirements of condition A. (29.), that the water uality
stream are not contravened.
Discharges from See -page Identified After Permit Issuance
The facility shall comply with the "Plan for Identification of New Discharges" as
contained in Attachment 2. -For any discharge identified pursuant to this Plan, the
facility shall, within 90 days ofthe seep discovery, tandards established in AnNCAC 2B .0200 and
e if the discharge ep
meets the state water quality, s
submit the results of this determi atio duct monitorin to ng for the p theivision. if standardsspecified
ci d in A.
contravened, the facility shall con
(8 )
Page 19 of 27

PERMIT No. NC0004987
If any of the water quality standards are exceeded, the facility shall be considered in
violation until one of the options below is fully implemented:
1) Submit a complete application for 404 Permit (within 30 days after determining
that a water quality standards is exceeded) to pump the seep discharge to one
of the existing outfalls, install a pipe to discharge the seep to the Catawba
River, or install an in-situ treatment system. After the 404 Permit is obtained,
the facility shall complete the installation of the pump, pipe, or treatment
system within 180 days from the date of the 404 permit receipt and begin
pumping/ discharging or treatment.
2) Demonstrate through modeling that the decanting and dewatering of the ash
basin will result in the elimination of the seep. The modeling results shall be
submitted to the Division within 120 days from the date of the seep discovery.
Within 180 days from the completion of the dewatering the facility shall confirm
that the seep flow ceased. If the seep flow continues, the facility shall choose
one of the other options in this Special Condition.
3) Demonstrate that the seep is discharging through the designated "Effluent
Channel' and the water quality standards in the receiving stream are not
contravened. This demonstration should be submitted to the Division no later
than 180 days from the date of the seep discovery. The "Effluent Channel'
designation should be established by the DEQ Regional Office personnel prior
to the issuance of the permit. This permit shall be reopened for cause to include
the "Effluent Channel' in a revised permit.
All effluent limits, including water quality -based effluent limits, remain applicable
notwithstanding any action by the Permittee to address the violation through one of
the identified options, so that any discharge in exceedance of an applicable effluent
limit is a violation of the Permit as long as the seep remains flowing.
New Identified Seeps
If new seeps are identified, the facility shall follow the procedures outlined above. The
deadlines for new seeps shall be calculated from the date of the seep discovery. The
new identified seep are not permitted until the permit is modified and the new seep
included in the permit and the new outfall established for the seep.
A. (31.) ELECTRONIC REPORTING OF DISCHARGE' MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations tequire electronic submittal of all discharge monitoring reports
(DMRs) and program reports and specify that, if a state. does not establish a system to
receive such submittals, then permittees must submit monitoring data and reports
electronically to the Environmental Protection Agency (EPA). --The final NPDES
Electronic Reporting Rule was adopted and became effective on December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within
Part II of this permit (Standard Conditions for NPDES Permits):
• Section B. Signatory Requirements
(11.)
• Section D. (2.) Reporting
Page 20 of 27

PERMIT No. NC0004987
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements LSupersedes Section D. (2.) and Section E. (5.) (a)1
Effective December 21, 2016, the permittee shall report discharge monitoring data
electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR)
internet application.
Monitoring results obtained during the previous month(s) shall be summarized for
each month and submitted electronically using eDMR: The eDMR system allows
permitted facilities to enter monitoring data and submit DMRs electronically using
the internet. Until such time that the state's eDMR application is compliant with
EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be
required to submit all discharge monitoring data to the state electronically using
eDMR and will be required to complete the eDMR submission by printing, signing,
and submitting one signed original and a copy of the computer printed eDMR to
the following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
AT'T'ENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship
or due to the facility being physically located in an area where less than 10 percent
of the households have broadband access, then a temporary waiver from the
NPDES electronic reporting requirements may be granted and discharge
monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or
alternative forms approved by the Director. Duplicate signed copies shall be
submitted to the mailing address above. See "How to Request a Waiver from
Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the
month following the issuance of the permit or in the case of a new facility, on the
last day of the month following the commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the
following compliance monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek.an electronic reporting waiver from the Division (see "How
to Request a Waiver from Electronic Reporting" section below).
2. Electronic Submissions
Page 21 of 27

PERMIT No. NC0004987
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial
recipient at the time of each electronic submission. The permittee should use the
EPA's website resources to identify the initial recipient for the electronic
submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities
means the entity (EPA or the state authorized by EPA to implement the NPDES
program) that is the designated entity for receiving electronic NPDES data [see 40
CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic
reporting tool for each type of electronic submission and for each state.
Instructions on how to access and use the appropriate electronic reporting tool will
be available as well. Information on EPA's NPDES Electronic Reporting Rule is
found at: http://www2.epa.gov/compliance/final-national-pollutant-discharge-
elimination-system-npdes-electronic-reporting-rule.
Electronic submissions must start by the dates listed in the "Reporting
Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division.
To obtain an electronic reporting waiver, a permittee must first submit an
electronic reporting waiver request to the Division. Requests for temporary
electronic reporting waivers must be submitted in writing to the Division for written
approval at least sixty (60) days prior to the date the facility would be required
under this permit to begin submitting monitoring data and reports. The duration
of a temporary waiver shall not exceed 5 years and shall thereupon expire. At such
time, monitoring data and reports shall be submitted electronically to the Division
unless the permittee re -applies for and is granted a new temporary electronic
reporting waiver by the Division. Approved electronic reporting waivers are not
transferrable. Only permittees with an approved reporting waiver request may
submit monitoring data and reports on paper to the Division for the period that the
approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting
waiver are found on the following web page:
http://deg.nc.gov/about/divisions/water-resources/­edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes
Section B. (11.) (d)]
All eDMRs submitted to the permit issuing authority shall be signed by a person
described in Part II, Section B. (11.) (a) or by a duly authorized representative of
that person as described in Part II, Section B. (11.)(b). A person, and not a
position, must be delegated signatory authority for eDMR reporting purposes.
Page 22 of 27

PERMIT No. NC0004987
For eDMR submissions, the person signing and submitting the DMR must obtain
an eDMR user account and login credentials to access the eDMR system. For more
information on North Carolina's eDMR system, registering for eDMR and obtaining
an eDMR user account, please visit the following web page:
http: / / deg.nc.gov /about/ divisions /water -resources / edmr
Certification. Any person submitting an electronic DMR using the state's eDMR
system shall make the following certification [40 CFR 122.22]. NO OTHER
STATEMENTS OF CERTIFICATION WILL BE ACCEPTED:
"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 fines and imprisonment for knowing violations. "
5. Records Retention [Supplements Section D. (6.)l
The permittee shall retain records of all Discharge Monitoring Reports, including
eDMR submissions. These records or codes shall be maintained for a period of at
least 3 years from the date of the report. This period may be extended by request
of the Director at any time [40 CFR 122.41].
A. (32.) DOMESTIC WASTEWATER TREATMENT PLANT
The domestic wastewater treatment plant shall be properly operated and maintained to
ensure treatment of domestic wastewater to secondary levels.
Page 23 of 27

PERMIT No. NC0004987
Attachment 1
GROUNDWATER MONITORING PLAN
The permittee shall conduct groundwater monitoring as may be required to determine
the compliance of this NPDES permitted facility with the current groundwater Standards
found under 15A NCAC 2L.0200.
1. WELL CONSTRUCTION
a. Monitoring wells shall be constructed in accordance with 15A NCAC
02C .0108 (Standards of Construction for Wells Other than Water
Supply) and any other jurisdictional laws and regulations
pertaining to well construction.
b. Monitoring wells must be constructed by a North Carolina Certified
Well Contractor, the property owner, or the property lessee
according to General Statutes 87-98.4. If the construction is not
performed by a certified well contractor, the property owner or
lessee, provided they are a natural person, must physically perform
the actual well construction activities.
C. Within 30 days of completion of well construction, a completed Well
Construction Record (Form GW -1) must be submitted for each
compliance monitoring well to Division of Water Resources, Water
Quality Regional Operations Section (WQROS), 1636 Mail Service
Center, Raleigh, NC 27699-1636.
d. The Mooresville Regional Office, telephone number [phone],
shall approve the location of new compliance monitoring wells prior
to installation. The regional office shall be notified at least 48 hours
prior to the construction of any compliance monitoring well and
such notification to the WQROS regional supervisor shall be made
from 8:00 a.m. until 5:00 p.m. on Monday through Friday,
excluding State Holidays.
e. All monitoring wells shall be regularly maintained. Such
maintenance shall include ensuring that the well caps are rust -free
and locked at all times, the outer casing is upright and undamaged,
and the well does not serve as a conduit for contamination.
f. If the Permittee intends to abandon a compliance monitoring well
either temporarily or permanently, the Permittee shall justify the
abandonment and request approval from the WQROS Regional
Office within 30 business days prior to initiating abandonment
procedures.
g. Monitoring wells shall be abandoned in accordance with 15A NCAC
02C .0113 (Abandonment of Wells). Within 30 days of completion
of well abandonment, a completed Well Abandonment Record (Form
GW -30) must be submitted for each monitoring well to WQROS,
1636 Mail Service Center, Raleigh, NC 27699-1636.
2. MAPS
a. Updated maps shall be provided within 60 days when any of the
following occur:
i. Compliance monitoring wells are added or deleted from the
plan.
Page 24 of 27

PERMIT No. NC0004987
ii. The facility operation changes that would require a change
in the waste boundary, compliance boundary, or property
line.
b. If the map is updated, the Permittee shall submit two original copies
of a site map with an appropriate scale to easily identify all features
overlaid on the most recent aerial photograph. At a minimum, the
map shall include the following information:
i. The location and identity of each monitoring well.
ii. The location of major components of the waste disposal
system.
iii. The location of property boundaries within 500 feet of the
disposal areas.
iv. The elevation of the top of the well casing (i.e., measuring
point) relative to a common datum.
vi. The depth of water below the measuring point at the time the
measuring point is established.
vii. The location of compliance boundary.
viii. The date the map is prepared and/or revised.
ix. Topographic contours in no more than ten (10) foot intervals.
For areas of high relief, 20 foot intervals shall be acceptable.
C. The map and any supporting documentation shall be sent to the
WQROS, 1636 Mail Service Center, Raleigh, NC 27699-1636.
3. GROUNDWATER SAMPLING AND COMPLIANCE.
a. The compliance boundary for the disposal system shall be specified
in accordance with 15A NCAC 02L .0107(a) or (b) dependent upon
the date permitted. An exceedance of groundwater standards at or
beyond the compliance boundary is subject to remediation action
according to 15A NCAC 02L .0106(c) or (d) as well as enforcement
actions in accordance with North Carolina General Statute 143-
215.6A through 143-215.6C.
b. Monitoring wells shall be sampled after construction and thereafter
at the frequencies and for the parameters as specified in Part 4 of
this plan. All maps, well construction forms, well abandonment
forms and monitoring data shall refer to the permit number and the
well nomenclature.
C. Per 15A NCAC 02H .0800, a Division certified laboratory shall
conduct all laboratory analyses for the required effluent,
groundwater or surface water parameters.
d. The measurement of water levels shall be made prior to purging the
wells. The depth to water in each well shall be measured from the
surveyed point on the top of the casing.
e. The measuring points (top of well casing) of all monitoring wells
shall be surveyed to provide the relative elevation of the measuring
point for each monitoring well. The measuring points (top of casing)
of all monitoring wells shall be surveyed relative to a common
datum.
f. Two copies of the monitoring well sampling shall be submitted on a
Compliance Monitoring Form (GW-59CCR), and received no later
than 60 days from the sampling date. Copies of the laboratory
analyses shall be kept on site, and made available upon request.
Page 25 of 27

PERMIT No. NC0004987
The Compliance Monitoring Form (GW-59CCR) shall include this
permit number and the appropriate well identification number. The
Compliance Monitoring Forms (GW-59CCR) shall be submitted to
the Division of Water Resources Information Processing Unit, 1617
Mail Service Center, Raleigh, North Carolina 27699-1617
g. For groundwater samples that exceed the ground water quality
standards in 15A NCAC 02L .0202, the Regional Office shall be
contacted within - 30 days after submission of the groundwater
monitoring form; an evaluation *may be required to determine the
impact of the waste disposal activities. Failure to do so may subject
the permittee to a Notice of Violation, fines, and/or penalties.
h. The provisions of sections 3(fl and 3(g) apply only to the sampling
events described in 3(b) above. The reporting requirements for any
sampling events other than those described in 3(b) above shall be
in accordance with the general provisions of 15A NCAC 02L.
4. MONITORING WELLS, PARAMETERS, AND SAMPLING FREQUENCY.
a. Laboratory methods shall be EPA approved and sufficient to detect
constituent quantities at or below their individual 15A NCAC 02L
groundwater standards.
b. The following chart contains the compliance monitoring wells to be
sampled, the parameters to be sampled, and the frequency in which
the samples shall be collected.
MONITORING
WELLS
PARAMETERS
FREQUENCY
Laboratory Parameters
Aluminum
Antimony
Arsenic
Barium
Beryllium Boron Cadmium Calcium
Cobalt
Chromium
Copper
Iron
MW -4, MW -4D,
MW -10S, MW-
MW- 0S, Mw,
MW-
10D,MW-11D, MW-
MW -12D, MW-
13S
February,
June,
October
Lead Magnesium Manganese Molybdenum
MercuryNickel Potassium Selenium
Sodium Strontium Thallium Vanadium12S,
Zinc Chloride Sulfate Alkalinity
Total Total
Bicarbonate Carbonate Dissolved Suspended
MW -13D, MW-
Solids
Solids
Field Parameters
14S,
MW -14D
Turbidity
pH
Temperature
Specific
Conductance
Dissolved
Oxygen
Oxidation
Reduction
Potential
Water level
Page 26 of 27

PERMIT No. NC0004987
Attachment 2
Plan for Identification of New Discharges (State Enforceable Only)
http: / / deq.nc.gov/ about/ divisions/water-resources/water-resources-hot-topics/ dwr-
coal-ash-regulation/ duke-energy-npdes-permits-for-facilities-with-coal-ash-
ponds/ duke-energy-npdes-modifications-renewals
Page 27 of 27

JIM
Lake Nonnan North Quad
A
03-08-32
-m sm
_\lM.......... . . . . . . . . . .
002A and 002B
N M
Z
001
W',
yF
02
Ai I
6;
�QLl
003
ON;
gg
0 56
0 %.
qp
"An
1w,
!CN,
M
a
mkl
C,�
ilj�
IngWMA..
t/� Fakill
Receivin';Streaina.i: Lata b_aRi `e.
ceiv
ai
,X Y
01 v
--c'60 .......
pceTbw•6f C
Ke
e '0004987"
6-
�Yffidll, S&affi, St4ti
on
J:Oj�

All—
—
`ps7�'L:Y rb
d
o- r• r
1 <l s
f
q
I'�'%Z `Y { }S, +if',\�µ ��3 � f' /+. �F• 7-':z�'�'+.„yf�aC'3rtr .�-a+�yww.�' _C .� r� ,{ � 4 A � �. E C l \ 41t � ,, ♦ - 1
S'i ,-Xrs :[2-. E i- z�;'� ., ci ti�i•s ��"` ,i +^'"•'� nr �+ r tnw.xa� t"� T' c �1A' "�'ry� �"i''1 r i%-. � K ' * � L .. - -
:J.��-► u fr• ;y`"� :,v�..,1r- `=+r. _ > �" .`' + 5•.-u C1`a
r1 „in,Tc s• \ i,, yr..t , �~ �4 i AV,.,
.c�� 1'.+. •� +
\,,,� V i °pJry> Ie"
R
4pNV6 1iL J' x
� s w �a TF •v'}-. i� 'j 'it ��Y� �±j- -_. r -; , �: + L��, ��`+` '.t ./' t.,. h.\i �""i�``4.
t .,:: t'7"C *� ���;'r\'r, >,aQ r�✓�- �` "_.tr ^'. r � �-'i i'i �" i � t {,� , - ,
t•�,"�'cr .�dti�.•w _ '' 4f -MW 4- �• ' f:rr Si ( ''* ' - }• \' t
ifr• »-i'at rT �] _ t].- ;i - PpQE _
yk-
�Mt,. l� l blu"
i4
v,c'sJ�``\titi. Yy \Z4: `K3 )(;%• a(f�r�'NrlPEfl�1r804 r rd�t; 3 12-1,
..x" f -
r
fIy �xrt,R��+ii•{��J .y�'t { -'�•sX kxi,7%; � '' •ii, 1 1 �' �i r:,-... O,%� r - � ° +1., 1 , , ` `r ^1:`:
z: � �.+.. -:::yi L �. �� y ; (I _ .a 3 r{l l;way,!-: t t � q` i O L.•� .. S -� E i -'' -
+- � aj'� ry[;.�, �"3 (,y 1 it" i'-.`' �^i :. _ t � i-� -mac.. "�",v�.}�{ � (•% �f r'
•x ��` "ar ,+�+�'- r• ±t„�t<,c'i '+. r�'•ss�7dlG*J f .�\ ! (
��; � \ Y:�.\��'h! + 4 w. � - � • 7 rr � 'ek
h
< i h#{ Er 'is t ;,'k I .' r r of T r;•,�kCi i A "`
kr.
��t"- . iy _(,r"''f+,'1 y }k j•E' •r A,iiy� \+'u� ASH LANOFILLA4`rt, �� E• t t y . I ! r .r 1 ,� 3 r. X ` \..
;cam jd• ka § c 3�3 , > t :x r, z , y�:- 'i =n' c•„ i`_74.•��Ary*x � :.,t .�` � •��; MITNO 1804
{�/.." t• �"�* r �� _ �idt t•t s^e v s1"�I w i• , t - c}+ » - s
,LL, -,dy � r' ��. �`� d.+rul ,��..„* >•-/2 � a r v'-� t t1. `" ii `s<�i � {-_ r i r � ��
3''a ,y'r�, tr„isJ � �� � s fi; .•t' k£„o„y'r � \s t R_� fit. ' 'tt r :A�S; "� !r ! � r " r -
xl r. � � ,�,;rzf3 r �• , �.�jt`.. { y ,,, IL �r?t 1 �,+�; K,.trr � r t �.
�/• sf .r ,YF } J, �:rtv iiJ<�•-: :i.et;' njt"'tr�•x'i•A '.wf iM1 , -•t•. .�: rGw„fG µ C`i7'i'� f 1k"�..{ `�F ��i'. 7r •c-''� •+ l r t •' \kXt`eyO`tiz .••• ^\'i \ E r ,r �. M11 �,. _ _ .
,
e•
MW14D
�-g�
r
f >r
�c •\�''`1 j � �, y � "3^ —Y�� .� ���t � x.r�arsT> �� � .v -k r �,� !' -s'r4� �. �
7�
` �;�a • 4! t�.r„""'a _ �.,,��i �.� Y � j,:,;q�v ft,r��- �� s: - or'� f -rt ” r . �► f , _ _ •
�, TrY,..aSlyf S? _ r"r Y�'314� `, i ixr `� .t 3( y .s. ,•t .: •y t�h 1. ` S 1. _ i -
�„•. '`- _ 3
�`1r.ti, ,i d `, •r }Y i 37 t �w
r'Y� \ .
° .:c'r'1?� .- -' �`, f ,em � ° a �z .i+ c+"•i '? .tzk! � � •� t r / sr" s ) �l � x - "
-
,e•
t`
Y R ' w Ck�rait4 t m '"'.. - $.•. •c�! * t,}1
sr L°Y ,x ;'flr-
j41••ASH CAPIOILILL
a{ EE rJ �yx � t s pSH6ASIN tr} y*s, ter rT r„ ti ..
C,t v ..a�, ',i 7! tr' z. '� ' J t<.r.tl• z tYr - r '-;..• 7f ^ r-47 -PERMlT,hO 1804 'a
1�•
A-
A7.� � k
r �,'• . t + .-
(i,�i.4 ^'4 St f y } 'S�,{ iii, 1 isL. ..�. # -_ ri:• ,
.s\"z. 4 {iQE''a t' ; r `\r ti.�i`:t?t, I �� ` At.
r+'r t `+ �;, 'r LAKE NORMAN
y ,Nik.
Sf t t < ^$ACTNEASH BASINELEVATION 760 FT
f-" #i ' r._.1�� t%•- ���}� :+ 't ftELEVATION 790-T(APPROXIMATE)�`•: ti a t (APPROXIMATE)
r t
=• a yc { ° 3t \ . MW-iQ5
r1 �y�+- ��"+tJ' i • r F{ >' 7 1• \ i tiri i i�, vS Z-
_ + \ ' NPDES-10D
r\i1dZ1Ry,�'E x.7.,1„^ 'W ' t �X� cit'a �" � �•�' � _ _ rr� * 1 � ` j �'� r,�' �� -
«. -'
�MRy�NyryOs�ZS,rE.O, � ,' �- � a �,1 ��-I j. : -�j �a7�'+y # s ♦ •'fie'' e..�. /,-.. _ :` .. •
F'4Mx�_r �` er '• E `. �rh "+i1..rr \:i}y kKs t
�,���," �, ,- •-'r's' y ,t „e/ , . �' ' 'I. f { r mo'`'t 5 3 .L •, ir.!
..y,{
aFf)'n. frLtl M rs l _r t l t �5 +• � ! 1 s t i" — --- '- - � � i rt _, .
1 J•C! p Lra. .% '•1 ,._. t'r f`':1
4!`7'4 �w i l a `i-�.. a ` °j J >' s� t ''�� qf1• Ja"� �.:- �' � 4 r
Tt R � �y.;�,r i Y \^ t. ry C t , 9nri, / �14 . f�' 'Y� ' J • _ ,? � C y'{� � ,
-1�.�'` - `!�`��,- is?Y'� et'`-Hi—�cw`.tr....� -r�� �� ,�� r\� �5•`` .ti.��..'� .e, _ .. 1 .
Ft;..-a'.�_ .a. 5 /// ! %� ' a..-.. _ �`F : ""'ya--��:.E" _ , r+P" :...,-"'",' F�cw�a::� ..xr✓/���� r _ - - `' -aa... . , .. '

DUKE
ENERGY®
May 9, 2016
Jeffrey O. Poupart
Water Quality Permitting Section Chief
Division of Water Resources
Department of Environmental Quality
State of North Carolina
1617 Mail Service Center
Raleigh, NC 27699-1617
�
sero,r 0 V ,
Harry K. Sideris
Senior Vice President
Environmental, Health & Safety
526 S. Church Street
Mail Code: EC3XP
Charlotte, NC 28202
[phone]
RECEIVEDINCDEWW
MAY 13'2016
Water Quality
Permitting Section
Subject: Marshall Steam Station
Appropriate Applicability dates for Compliance with the new Effluent Guidelines Rule
Dear Mr. Poupart:
Duke Energy (Duke) submits the attached information as a justification for appropriate applicability dates
for compliance with the new Effluent Guidelines Rule (ELG Rule) (80 Fed. Reg. 67,838 (Nov. 3, 2015))
at Marshall Steam Station (MSS), located in Mooresville, North Carolina. The ELG Rule sets a range of
possible applicability dates for compliance with the new best available technology (BAT) limits for
bottom ash transport water (zero discharge) and FGD wastewater (numeric limits for selenium, arsenic,
mercury, and nitrate/nitrite), as well for fly ash transport water (zero discharge).
As the rule makes clear BAT limits may apply — depending on the individual circumstances of the
facilities subject to the rule — any time within the window of November 1, 2018 to December 31, 2023. In
selecting an appropriate applicability date for each waste stream subject to the new BAT limits, the
permitting authority is called upon to determine an "as soon as possible" date when supplied with
appropriate information by the permittee. The attached provides the appropriate information justifying the
following applicability dates:
Bottom Ash Transport Water: To convert the wet bottom ash transport system at MSS to a closed
loop system, Duke plans to install a remote mechanical drag chain system (RMDS). Duke would
like to request January 31, 2021 as the applicability date for the zero discharge of bottom ash
transport water, assuming a permit effective date of July 1, 2016.
— FGD wastewater: Duke anticipates that it will need to replace, in its entirety, the existing FGD
wastewater treatment system at MSS. Duke would like to request January 31, 2021 as the
applicability date for the BAT limits for FGD wastewater, assuming a permit effective date of
July 1, 2016.

Mr. Poupart
Appropriate Applicability dates for Compliance with the new Effluent Guidelines Rule
Page 2
Fly Ash Transport Water: Fly ash is handled dry during normal operation; therefore, Duke is not
requesting an applicability date for the zero discharge of fly ash transport water beyond
November 1, 2018.
If you have any questions or need to discuss further, contact Richard Baker at 704-382-7959.
Sincerely,
Harry Sideris
SVP - Environmental, Health & Safety
Enclosures

Marshall Steam Station: Effluent Guidelines Rule
Justification for Applicability Dates
A. Introduction
Duke Energy (Duke) is working diligently to develop and refine an optimized schedule for the
installation and upgrades to wastewater treatment systems to comply with the Steam Electric Power
Generating Effluent Limitation Guidelines (ELG) at seven coal-fired stations in North Carolina. Duke
submits the following information as a justification for appropriate applicability dates for compliance
with the new Effluent Guidelines Rule (ELG Rule) (80 Fed. Reg. 67,838 (Nov. 3, 2015)) at Marshall
Steam Station (MSS), located in Mooresville, North Carolina based on the preliminary fleet wide
optimization schedule.
MSS is a four -unit coal fired station with a total generating capacity of 2,110 megawatts (MW). Units
1 and 2 have a rated capacity of 385 MW each and Units 3 and 4 have a rated capacity of 670 MW
each. MSS currently discharges treated bottom ash transport water, and FGD wastewater. Under
normal plant operations, fly ash is collected dry and either disposed in a permitted on-site landfill or
transported offsite for beneficial reuse. If the dry fly ash collection system is not operating, the fly ash
is sluiced to the ash basin in which the transport water is treated in the ash basin and subsequently
discharged through outfall 002. Bottom ash from the boilers is sluiced with transport water to a
holding cell for recycling activities. The transport water is treated by the ash basin and is discharged
through outfall 002. The FGD wastewater is sent to a solids removal system followed by a vertical
flow wetland and then constructed wetlands prior to discharging to the ash basin via internal outfall
004.
The ELG Rule sets a range of possible applicability dates for compliance with the new BAT limits for
bottom ash transport water (zero discharge) and FGD wastewater (numeric limits for selenium,
arsenic, mercury, and nitrate/nitrite), as well for fly ash transport water (zero discharge). The
regulation provides that all permits issued after the effective date of the rule (January 4, 2016) should
contain applicability dates for compliance with the BAT limits, and that those dates should be "as
soon as possible" but not sooner than November 1, 2018 and not later than December 31, 2023.
For MSS, since the plant's final NPDES permit will be issued after January 4, 2016, but before
November 1, 2018, EPA specifically instructs permit writers to "apply limitations based on the
previously promulgated BPT limitations or the plant's other applicable permit limitations until at
least November 1, 2018." 80 Fed. Reg. at 67,883, col. 1 (emphasis added). As the rule makes clear,
however, BAT limits may apply — depending on the individual circumstances of the facilities subject
to the rule — any time within the window of November 1, 2018 to December 31, 2023. In selecting an
appropriate applicability date for each waste stream subject to the new BAT limits, the permitting
authority is called upon to determine an "as soon as possible" date.
The ELG Rule provides a very specific definition for "as soon as possible." The permit writer — when
supplied with appropriate information by the permittee — must consider a range of factors that affect
the timing of compliance. Those factors are as follows:
(1) Time to expeditiously plan (including to raise capital), design, procure, and install
equipment to comply with the requirements of this part.

(2) Changes being made or planned at the plant in response to:
(i) New source performance standards for greenhouse gases from new fossil fuel -
fired electric generating units, under sections 111, 301, 302, and 307(d)(1)(C) of the
Clean Air Act, as amended, 42 U.S.C. 7411, 7601, 7602, 7607(d)(1)(C);
(ii) Emission guidelines for greenhouse gases from existing fossil fuel -fired electric
generating units, under sections 111, 301, 302, and 307(d) of the Clean Air Act, as
amended, 42 U.S.C. 7411, 7601, 7602, 7607(d); or
(iii) Regulations that address the disposal of coal combustion residuals as solid waste,
under sections 1006(b), 1008(a), 2002(a), 3001, 4004, and 4005(a) of the Solid Waste
Disposal Act of 1970, as amended by the Resource Conservation and Recovery Act
of 1976, as amended by the Hazardous and Solid Waste Amendments of 1984, 42
U.S.C. 6906(b), 6907(a), 6912(a), 6944, and 6945(a).
(3) For FGD wastewater requirements only, an initial commissioning period for the
treatment system to optimize the installed equipment.
(4) Other factors as appropriate.
40 C.F.R. § 423.11(t).
The wastewater treatment systems at MSS will undergo significant modifications and in most cases
complete replacement to comply with the revisions to the ELG Rule. Duke would like sufficient time
to select, design and install the most cost effective technology at MSS to comply with the ELG limits
and reduce the burden to the ratepayers. We have prepared a preliminary timeline for planning,
designing, procuring, constructing and optimizing the technology once it is selected, for each
applicable waste stream. Based on our preliminary analysis, we request the following applicability
dates:
— Bottom Ash Transport Water: To convert the wet bottom ash transport system at MSS to a
closed loop system, Duke plans to install a remote mechanical drag chain system (RMDS).
Duke would like to request January 31, 2021 as the applicability date for the no discharge of
bottom ash transport water, assuming a permit effective date of July 1, 2016. Duke anticipates
that equipment will be installed by December 31, 2019 to comply with the North Carolina -
Coal Ash Management Act (NC -LAMA) and the Coal Combustion Residual _(CCR) rule.
These rules, however, only regulate the material, not the water. As discussed below, Duke
will need a 13 month window to optimize the system to operate as a zero discharge system. In
addition, the extent and complexity of the permits required are unknown at this time. Duke,
therefore, allocated 6 months to account for potential permitting delays.
FGD wastewater: Duke anticipates that it will need to replace, in its entirety, the existing
FGD wastewater treatment system at MSS. We plan to evaluate the development of a new
physical/chemical system augmented by a selenium reduction system. Duke would like to
request January 31, 2021 as the applicability date for the best available technology (BAT)
limits for FGD wastewater, assuming a permit effective date of July 1, 2016.
Fly Ash Transport Water: Fly ash is handled dry during normal operation; therefore, Duke is
not requesting an applicability date for the zero discharge of fly ash transport water beyond
November 1, 2018.
2

The following provides necessary information justifying the requested applicability dates provided
above.
B. Bottom Ash Transport Water
As stated above, significant portions of the bottom ash transport system at MSS will need to be
replaced to comply with the no discharge limit of bottom ash transport water (BATW). The rule
identified dry handling or closed-loop systems as the BAT technology basis for control of pollutants
in bottom ash transport water. Specifically, a mechanical drag system (MDS) was identified as the
technology basis for a dry handling system, where as a RMDS was identified as the technology basis
for a closed-loop system. Duke is planning on installing a RMDS at MSS to handle bottom ash dry.
The system will be designed to operate in a closed-loop mode to meet the zero discharge limits for
BATW. Duke anticipates 55 months from the effective date of the permit will be needed to design,
install and commission the RMDS as a zero discharge system based on the following preliminary
timeline.
Remote Mechanical Drag System (RMDS)
Activity Duration (Months)
Design
11
• Siting 4
• Engineering 7
Procurement
12
Potential Permitting Delays
6
Construction/Tie-in
13
Optimization & Operational Experience'
13
• Commissioning 2
o Start -Up 6
Total: I55
1) Even though is it estimated that commissioning and start-up can occur in 8 months, Duke
anticipates needing a 13 month window to obtain the necessary operating time at full load.
Assuming a permit effective date of July 1 2016, Duke estimates the system can be installed and
operated to comply with the zero discharge limit of BATW on or before January 31, 2021. To design,
procure, construct and optimize the RMDS at MSS to operate as a closed-loop system, the following
steps must be taken:
Design & En ing eering
Due to the simultaneous implementation of programs, such as the CCR Rule and NC -LAMA across
applicable sites in North Carolina, engineering and technology resources are limited. Duke, therefore,
estimates the design and engineering process will take 11 months. Some of the activities within the
water balance and siting task will occur concurrently; however the design cannot be completed until
the siting task is completed. The permitting process, if necessary, will be initiated in the design and
engineering phase, but it is assumed permit receipt / approval will be conducted concurrently with the
design and procurement phase and will be completed prior to the construction phase. The following
tasks will need to be completed.
3

Water Balance
The first step in the design process of the RMDS is to develop a detailed water balance of the current
BATW. To operate the system as a zero discharge system, there is a balance between the inputs of
water into the system and the outputs of water through evaporation and bottom ash removal. This is
necessary to determine if any additional treatment of the BATW is needed to avoid increase in fines
and concentration of other constituents that could affect equipment operability.
In addition, several non-BATW waste streams are currently commingled and treated along with
BATW. The flow of these waste streams will be rerouted from the BATW system to a new
wastewater treatment system. This will require the streams to be characterized for both volumetric
flow and constituent make-up in order to size and design an appropriate treatment system. It is
important to note that not all waste streams discharge continuously or simultaneously. Some waste
streams discharge intermittently based on activity occurrence, such air preheater and precipitator
washes, while others may only discharge under certain rainfall events. In addition, many waste
streams do not discharge if the unit is not running. With most coal-fired units operating in an
infrequent mode, the opportunities to collect samples are limited and the operation schedule could
affect the schedule of this task.
Upon completion of the water balance, detailed engineering of the RMDS system and piping reroutes
of non-BATW can commence.
Siting
The RMDS will need to be sited appropriately to avoid any historical or current coal combustion
product disposal (CCP) sites and avoid construction areas that will be used to complete closure of the
ash basins at MSS. In addition, Duke will attempt to site the system to avoid waters of the U.S.
(WOTUS). However, based on the final siting of the system, WOTUS may not be avoided, and
permits from the U.S. Army Corps of Engineers may be required.
Permitting
If WOTUS cannot be avoided, then permitting from the U.S. Army Corps of Engineers (USACE) will
be needed. At this time, it is unknown whether a USACE permit will be required or the type of permit
that may be required (nationwide permit (NPW) or individual permit). Duke, therefore, has included
12 months in the schedule to prepare and obtain any necessary USACE permits.
Once the RMDS is commissioned, the permitted discharge flows will change drastically. The amount
of water discharged could be reduced by as much as 85%. In addition, these flows typically were
treated along with the BATW in the ash basin. Duke, therefore, will need to design, and construct a
new treatment system for these low volume wastes. The size and technology of the treatment system
will be determined based on the water characterization study discussed above. With significant
changes to the characteristics of the permitted discharge, Duke anticipates a NPDES permit
modification will be required to revise the permit to account for the changes in flow and constituent
make-up.
In addition, based on the final siting of the low volume wastewater treatment system, a new outfall
may need to be constructed for the discharge of the effluent from this new wastewater treatment
4

system. The construction of a new outfall would require a permit/approval from the Federal Energy
Regulatory Commission (FERC) because Lake Norman is a FERC regulated reservoir. The FERC
approval process requires all other permits are received prior to submitting the approval application.
Even though the permitting task will be initiated during the design and engineering phase, it is expect
to continue through the procurement phase and up to the construction phase. In addition, the extent
and complexity of the permits required are unknown at this time. The required permits will be
evaluated during the engineering and design phase. Since time needed to prepare the permit
applications and the time needed to receive the permits is uncertain, Duke allocated 6 months to
account for potential permitting delays.
Procurement
After the design is complete, Duke will initiate the process to procure the necessary outside resources
to construct and install the new wastewater treatment systems. This process will involve the following
steps:
Evaluate potential vendors for proposal solicitation;
Develop and submit request for proposal (RFP) to selected vendors;
Conduct a review and vendor selection based on the received bids;
Develop required contract documents;
Acquire materials (potentially from overseas), which involves:
o Shipment, and
o Equipment Fabrication
Fabrication and inspection of equipment.
RMDS have a fabrication queue that is dependent on total industry -wide demand. Duke, therefore,
has allocated 12 months to acquire the necessary materials.
Construction
Once all the necessary materials are procured, Duke estimates construction of the RMDS will take
approximately 13 months. In addition, the tie-in of the RMDS to each individual generating unit will
need to occur during outages, which are anticipated to occur between March to May and October to
November depending on generation demand.
Optimization and Operational Experience
As stated above, Duke is planning to have the equipment installed by December 31, 2019 at the latest
to meet the obligations under CAMA, in addition, to any CCR requirements. Again, these rules
regulate the bottom ash material, not the transport water. Given the system will continue to utilize
water to transport bottom ash, time will be needed to gain operational experience and optimize the
system to meet the zero discharge limit. Duke estimates a 13 month window will be required to gain
the necessary operational experience and fine-tune the system. The 13 month window is estimated
based on the potential that the station may only be operating at full load during the winter and
summer months. Therefore, a 13 month window will be needed to acquire 2 to 3 month optimization
period and 6 to 9 months of operating experience with the system at full load.
5

C. New Wastewater Treatment System
As discussed above, with the removal of several non-BATW waste streams from the bottom ash
transport system, a new wastewater treatment system will need to be designed and constructed for co -
treatment of low volume waste and other regulated process streams per the CCR rule, ELGs, and
NDPES permitting requirements. The activities associated with the new wastewater treatment system
will be conducted concurrently with the other design activities at the site. These waste streams are not
subject to the applicability date in the ELG rule, therefore, Duke is not requesting a compliance date,
but this task will need to be completed prior to the effective date of the zero discharge of BATW.
Duke anticipates 30 months will be needed to design, install and commission the new wastewater
treatment system, based on the following preliminary timeline.
New Wastewater Treatment System
Activity
Duration (Months)
Siting
3
Engineering
6
Procurement
3
Construction/Tie-in
9
Commissioning
3
Start -Up
6
Total:
30
D. FGD Wastewater
Duke anticipates that it will need to replace in its entirety the existing FGD wastewater treatment
system at MSS. The existing constructed wetlands are located within a CCR disposal area, which may
need to be excavated or capped in place per NC -LAMA. Duke is anticipating installing a
physical/chemical treatment system and a selenium reduction technology. The selenium reduction
technology has not yet been selected and Duke will be evaluating suitable technologies based on cost
and feasibility. EPA recognizes that designing, procuring, installing, and optimizing an FGD
wastewater treatment system is a complicated and time-consuming undertaking, involving much
study and careful planning. For example, EPA states:
"For plants that are planning to include fuel flexing in their operations, in the years
prior to the installation and operation of the FGD wastewater treatment system, the
plant should consider sampling the untreated FGD wastewater to evaluate the
wastewater characteristics that are present based on the differing fuel blends. Based
on those characteristics, the plant will be better able to design a system that can
properly treat its FGD wastewater given variability that might occur at the plant, and it
will be better prepared to adjust chemical dosages in the chemical precipitation system
to mitigate the variability in the wastewater that enters the biological treatment
system."
Response to Comments, p. 5-387.
10

EPA also states:
"While EPA has based the effluent limitations and standards for selenium and
nitrate/nitrite (as N) for FGD wastewater based on the performance of the Allen and
Belews Creek biological treatment systems, EPA does not contend that every plant in
the industry can simply take the design parameters from those two plants, install the
biological treatment system, and meet the effluent limitations. Each plant will need to
work with engineering and design firms to assess the wastewater characteristics
present at their plant to determine the most appropriate technologies and design the
system accordingly meet the effluent limitations. Therefore, some plants may need to
design the bioreactors to provide additional bed contact time (as provided by the
hydraulic residence time and volume of biomass and carbon substrate), while other
plants may find they need less."
Response to Comments, p. 5-389
Duke anticipates 55 months from the effective date of the permit will be needed to design, install and
commission the FGD wastewater treatment system to meet the BAT limits based on the following
preliminary timeline.
FGD WWT Upgrade
Activity Duration (Months)
Design & Engineering
10
• Siting 4
• Engineering 6
Procurement
12
Potential Permitting Delays
6
Construction/Tie-in
12
Start-up & Optimization'
15
• Commissioning 6
• Start -Up 6
Total: 1
55
1) Duke is allocating a 15 month window to complete the commissioning and start-up under all
expected operating conditions from full load to partial load to periods of no load.
Assuming a permit effective date of July 1 2016, Duke estimates the system can be installed and
commissioned to meet the BAT limits on or before January 31, 2021. To design, procure, construct
and commission the FGD WWT system at MSS, the following steps must be taken:
Design & Engineering
As with the RMDS, engineering and technology resources are limited due to regulatory requirements
for concurrent implementation of programs, such as the CCR Rule and NC -LAMA across applicable
sites in North Carolina. Duke is, therefore, estimating 10 months to complete the design and
engineering phase of the project.
7

Siting
As with the RMDS, the FGD WWT system will need to be sited to avoid any former or current CCR
sites and avoid construction areas that will be used to complete closure of the ash basins at MSS.
Additionally, Duke will need to site the system to avoid nuisance odor outside the property boundary.
Duke will also attempt to site the system to avoid WOTUS. However, based on the final siting of the
system WOTUS may not be avoided, and permits from the U.S. Army Corps of Engineers may be
required.
Technology Selection
Duke has significant experience in the design, construction and operation of biological treatment
systems for selenium reduction. Based on Duke's experience, biological treatment alone may not be a
fool proof technology based on the characteristics of the coal. Duke, therefore, is obligated to review
and evaluate whether other suitable technologies are available to treat FGD wastewater for selenium
reduction at MSS. Duke will be working closely with utility organizations, such as the EPRI, to
identify suitable technologies for the removal of selenium from FGD wastewater and possibly
additional polishing steps that may be required to meet the limits.
Upon completion of the siting and technology selection, the engineering design of the system will be
completed.
Permitting
If WOTUS cannot be avoided, then permitting from the U.S. Army Corps of Engineers (USACE) will
be needed. At this time, it is unknown whether a USACE permit will be required or the type of permit
that may be required (nationwide permit (NPW) or individual permit). Duke, therefore, has included
12 months in the schedule to prepare and obtain any necessary USACE permits.
The installation of the FGD WWT may change the characteristics of the final discharge, therefore, a
NPDES permit modification may be required to revise the permit to account for the changes in flow
and constituent make-up.
Even through the permitting task will be initiated during the design and engineering phase, it is expect
to continue through the procurement phase and up to the construction phase. In addition, the extent
and complexity of the permits required are unknown at this time. The required permits will be
evaluated during the engineering and design phase. Since time needed to prepare the permit
applications and the time needed to receive the permits is uncertain, Duke allocated 6 months to
account for potential permitting delays.
Procurement
After the design is complete, Duke will initiate the process to procure the necessary outside resources
to construct and install the new wastewater treatment systems. This process will involve the following
steps:
— Evaluate potential vendors for proposal solicitation;
— Develop and submit a request for proposal (RFP) to selected vendors;

— Conduct a review and vendor selection based on the received bids;
— Develop required contract documents;
— Acquire materials (potentially from overseas), which involves:
o Shipment, and
o Equipment Fabrication
— Fabrication and inspection of equipment.
The selenium reduction technology will have a fabrication queue that is dependent on total industry-
wide demand. Duke, therefore, has allocated 12 months to acquire the necessary materials.
Additionally, raw materials needed may have an extended lead-time from time of order to delivery,
such as the granulated activated carbon used in the biological system, which has a lead time of 12
months.
Construction / Tie In
Once all the necessary materials are procured, Duke estimates construction of the FGD WWT will
take approximately 12 months to complete. In addition, the tie-in of the FGD WWT to each
individual FGD scrubber will need to occur during outages, which are anticipated to occur between
March to May and October to November depending on generation demand.
Commissioning & Start-up
1
Duke estimates that commissioning and start-up of the FGD WWT will take 12 months to complete,
6 months for each task. Duke, however, is allocating a 15 month window to complete the
commissioning and start-up under all expected operating conditions from full load to partial load to
periods of no load. This will allow the identification of necessary actions that need to be completed in
order to maintain the system under different operating scenarios.
E. EPA Provided A Range of Applicability Dates To Allow For Coordination Across Regulatory
Requirements and to Promote Orderly Decisions
The steam electric industry is in the midst of major transitions driven by new environmental
regulatory requirements in the air, waste, and water arenas. In the ELG Rule, EPA explicitly
acknowledged the complications of planning and executing ELG retrofits while developing and
executing compliance strategies under the other rules. EPA made it clear that the range of
applicability dates provided in the ELG Rule are supposed to be implemented in a manner that avoids
stranded costs and promotes orderly decisionmaking. For instance, EPA states:
"From an environmental protection/coordination standpoint, with the increased use of
flue gas desulfurization scrubbers and flue gas mercury controls in response to air
pollution -related requirements, this rule makes sense from a holistic environmental
protection perspective and from the perspective of coordinating across rules affecting the
same sector. This final ELG controls the discharges associated with these particular
waste streams."
Response to Comments, p. 8-388.
9

EPA also states that the permitting authority may "account for time the facility needs to coordinate all
the requirements of this rule, along with other regulatory requirements, to make the correct planning
and financing decisions, and to implement the new requirements in an orderly and feasible way."
Response to Comments, p. 8-129.
At Marshall, we need to coordinate our ELG implementation strategy with CCR and NC-CAMA
rules. For both the CCR and CAMA rules, we are evaluating one approximately 394 -acre ash pond to
determine whether it meets the locational restrictions of 40 C.F.R. § 257.60 - .64. The future of the
ash pond under both of these rules will determine whether it is available or not to receive legacy
wastewaters (i.e., those wastewaters generated before the applicability date for bottom ash transport
water retrofits) and continue to receive non-BATW. In addition, as discussed above, the final
determination of the extent of the ash pond, as well as the closure method could have significant
ramifications for the siting of both the RMDS and FGD WWT.
F. ELG Implementation Should be Coordinated with the Clean Power Plan (CPP) to Avoid
Stranded Costs
The ELG Rule clearly contemplates that the compliance timelines for its requirements should account
for any applicable obligations under the CPP. However, the affected units at Marshall will not know
their individual obligations under the CPP until well after November 1, 2018. As promulgated by
EPA, the CPP's emission guidelines do not apply directly to units. Instead, states are responsible for
developing state plans setting forth requirements applicable to individual units that implement those
emission guidelines. These state plans are subject to review and approval by EPA. If EPA determines
that the state has not submitted an approvable plan, then EPA will promulgate a federal plan in its
place. The timeline the CPP provides for developing and reviewing these state plans involves
numerous steps.
The initial deadline for state plan submittal was September 6, 2016. 40 C.F.R. § 60.5760(a). The
vast majority of states were expected to seek and obtain a two-year extension for final state plan
submittal until September 6, 2018. See id. § 60.5760(b). However, the Supreme Court issued a stay
of the CPP on February 8, 2016. Thus, the timing of the requirements of the CPP is uncertain at this
time, as we wait further decisions by the Supreme Court. Duke would like to request the option to
revise the applicability dates for the ELG requirements if the stay of the CPP is lifted and the
operation of MSS will be affected.
Statements in the Response to Comments regarding stranded costs apply to any rule, not just the CPP.
EPA explains in the Response to Comments that it provided flexibility in applicability dates so that
facilities could consider all new regulatory requirements and then have an adequate time to plan and
implement accordingly, and thus avoid stranded costs:
"EPA is sensitive to the need to provide sufficient time for steam electric power plants to
understand, plan for, and implement any changes to their operation to meet their
environmental responsibilities, and agrees with the commenter that transparency of
requirements is important for minimizing "stranded investments." ...Furthermore, as
described in the preamble, the final rule provides time for plant owners or operators to
implement changes to plant operations in order to meet the final limitations and
standards, as well as flexibility to permitting authorities in implementing the final rule.
10

The Agency specifically considered the timing of requirements of other environmental
regulations in establishing implementation requirements for the ELGs, in order to provide
steam electric power plants time to consider and implement their strategy for
compliance."
Response to Comments, p. 8-388.
Even though the implementation and effects of the CPP are uncertain, North Carolina Department of
Environmental Quality (NCDEQ) is justified providing flexibility in the applicability dates from other
regulatory requirements such as the CCR and NC-CAMA, as discussed above.
G. The Proposed Schedules Help To Maintain Marshall's Availability to the Grid, Which
Promotes Grid Reliability
Duke developed the proposed BATW retrofit schedule and its applicability date with grid reliability
in mind. The dispatch of units at MSS varies throughout the year. Typically one unit is operating
throughout the year and all four units are typically dispatched from December to March and June thru
September. Therefore, the final tie-in schedule will avoid these months and more than likely tie-ins
will need to occur across more than one outage.
EPA explicitly notes that the permitting authority should consider grid reliability in setting
applicability dates: "EPA's decision is also designed to allow, more broadly, for the coordination of
generating unit outages in order to maintain grid reliability and prevent any potential impacts on
electricity availability, something that public commenters urged EPA to consider." 80 Fed. Reg. at
67,854, col. 2. See also Response to Comments, p. 8-138.
Also, EPA clearly anticipated that much of the new technology required for retrofits to bottom ash
transport water and FGD wastewater systems would be constructed in a manner that would not
interrupt routine facility operations, and then tied in during regularly scheduled plant or unit outages.
According to the preamble, the timing of the final rule "enables facilities to take advantage of planned
shutdown or maintenance periods to install new pollution control technologies." 80 Fed. Reg. at
67,854, col. 2.
EPA also recognizes that tie-ins of new equipment may need to occur across more than one outage.
EPA states: "the need to span installation of equipment over separate unit outages [is] a consideration
that can be incorporated into the permit writer's determination of the `as soon as possible' date,
assuming the plant provides documentation demonstrating such a need." Response to Comments, p.
8-54.
11

DEQ/DWR
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0004987
SUMMARY
This revised draft permit incorporates changes made subsequent to a Public Hearing held on April 8,
2015 seeking comments to the original draft NPDES wastewater permit renewal for Marshall Steam
Station.
Duke Energy operates Marshall Steam Station in Catawba County. The Station operates six outfalls.
These outfalls are 001, 002, 002a, 002b, 003, and 004. The permitted outfalls are summarized below:
• Outfall 001 — Condenser Cooling Water (CCW) Units 1 — 4:
The CCW system is a once- through, non -contact cooling water system, which condenses steam
from the condensers and other selected heat exchangers. When the station is operating at full power,
it has a design capacity to pump 1463 MGD (1.016 MGPM) of cooling water through the network
of tubes that runs through the condenser and selected heat exchangers. The raw cooling water is
returned to the lake. No biocides or other chemicals are used in the condenser cooling water. Units
1 and 2 operate two CCW pumps each while units 3 and 4 operate three pumps.
• Outfall 002 — Ash Basin:
The station ash basin accommodates flows from two yard -drain sumps, an ash removal system, low
volume wastes and non -point source stormwater. Low volume waste sources include, but are not
limited to: wastewater from wet scrubber air pollution control systems, ion exchange water
treatment system, water treatment evaporator blowdown, laboratory and sampling streams, boiler
blowdown, floor drains, and recirculating house service water systems. A sanitary waste treatment
system consists of an aerated basin that provides treatment with a 30 — day retention time and has
a total volume of 587,000 gallons. Effluent from the aerated basin is polished further through
additional residence time in the ash basin. The new sanitary waste treatment system is designed for
6100 gpd (normal) and 13500 gpd (outage).
NPDES Permit NC 0004987
Page 1
Facility Information
Applicant/FacilityName:
Duke Ener — Marshall Steam Station
Applicant Address:
Water Management, Duke Energy, P.O.
28201
Box 1006, Charlotte, NC
Facility Address:
8320 E. NC Highway 150, Terrell, NC 28682
Permitted Flow
Not Limited
Type of Waste:
99.9% Industrial, 0.1% Domestic
Facility/Permit Status:
Renewal
County:
Catawba
Miscellaneous
Receiving Stream:
Lake Norman
Regional Office:
Mooresville
Stream Classification:
WS -IV & B CA
USGS To o Quad:
Lake Norman North
303(d) Listed?:
No
Permit Writer:
Sergei Chernikov, Ph.D.
Subbasin:
03-08-32
Date:
March 16, 2016
Drainage Area mg:.
NA
Summer 7Q10 cfs) ' Release 60 cfs)'
Winter 7Q10 cfs): NA
1Q10 cfs):
IWC (%): 18
SUMMARY
This revised draft permit incorporates changes made subsequent to a Public Hearing held on April 8,
2015 seeking comments to the original draft NPDES wastewater permit renewal for Marshall Steam
Station.
Duke Energy operates Marshall Steam Station in Catawba County. The Station operates six outfalls.
These outfalls are 001, 002, 002a, 002b, 003, and 004. The permitted outfalls are summarized below:
• Outfall 001 — Condenser Cooling Water (CCW) Units 1 — 4:
The CCW system is a once- through, non -contact cooling water system, which condenses steam
from the condensers and other selected heat exchangers. When the station is operating at full power,
it has a design capacity to pump 1463 MGD (1.016 MGPM) of cooling water through the network
of tubes that runs through the condenser and selected heat exchangers. The raw cooling water is
returned to the lake. No biocides or other chemicals are used in the condenser cooling water. Units
1 and 2 operate two CCW pumps each while units 3 and 4 operate three pumps.
• Outfall 002 — Ash Basin:
The station ash basin accommodates flows from two yard -drain sumps, an ash removal system, low
volume wastes and non -point source stormwater. Low volume waste sources include, but are not
limited to: wastewater from wet scrubber air pollution control systems, ion exchange water
treatment system, water treatment evaporator blowdown, laboratory and sampling streams, boiler
blowdown, floor drains, and recirculating house service water systems. A sanitary waste treatment
system consists of an aerated basin that provides treatment with a 30 — day retention time and has
a total volume of 587,000 gallons. Effluent from the aerated basin is polished further through
additional residence time in the ash basin. The new sanitary waste treatment system is designed for
6100 gpd (normal) and 13500 gpd (outage).
NPDES Permit NC 0004987
Page 1

• Outfall 002a — Sump #1 Overflow:
This outfall discharges very infrequent overflows of yard sump number 1.
• Outfall 002b — Sump #2 Overflow:
This outfall discharges very infrequent overflows of yard sump number 2.
• Outfall 003 (internal outfall) — Unit 4 ID Fan Control House Cooling Water discharge into the
intake for CCW:
Once -through, non -contact cooling water is supplied to the Unit 4 induced draft (ID) fan motor
control -house equipment to remove excess heat. No chemicals are added to the once -through raw
lake water
• Outfall 004 (internal outfall) — FGD system discharge into Ash Basin:
In association with Clean Smokestacks legislation, Duke Energy installed a flue -gas desulfurization
(FGD) wet scrubber. This scrubber generates a wastewater needing treatment prior to discharge. An
internal outfall (004) has been established for the effluent from the FGD treatment system. Internal
outfall 004 discharges to the ash settling basin which is currently permitted as outfall 002. FGD
treatment system includes physical/chemical treatment and wetlands.
• Proposed Outfalls 101 and 102 - Seeps.
The summer 7Q10 flow (60 cfs) is based on the minimum release from the dam that regulates the
receiving water body.
The federal rule 40 CFR 423 states that "there shall be no discharge of pollutants" in fly ash transport
water and in bottom ash transport water. It also states that "dischargers must meet the discharge
limitation in this paragraph by a date determined by the permitting authority that is as soon as possible
beginning November 1, 2018, but no later than December 31, 2023". Therefore, the facility must
comply with the following requirements:
1. By November 1, 2018 there shall be no discharge of pollutants in fly ash transport water.
2. By January 31, 2021 there shall be no discharge of pollutants in bottom ash transport water.
This time period beyond November 1, 2018 is provided in order for the facility to budget,
design, and construct the treatment system. Duke provided the justification for the proposed
deadline and the DWR concurred with the compliance date.
Duke Energy submitted application dated October 9, 2014. The current permit expired April 30, 2015.
SEEPS- OUTFALLS 101 AND 102
Existing Discharges from Seepage
The facility identified 2 non -engineered discharges from seepage from the ash settling basin. The
locations of the seeps are identified below and are -depicted on the map attached to the permit.
Table 1. Dischar e Coordinates and Assigned Outfall Numbers
Discharge ID Latitude Longitude Outfall number
S-1 35036'71" 80°57'62" 101
S-2 35042'56" 80°21'56" 102
NPDES Permit NC 0004987
Page 2

The outfall for these discharges is through an effluent channel meeting the requirements in 15A
NCAC 2B .0228. Within 180 days of the effective date of this permit, the permittee shall demonstrate,
through in -stream sampling meeting the requirements of condition A. (29.), that the water quality
standards in the receiving stream are not contravened.
Discharges from Seepage Identified After Permit Issuance
The facility shall comply with the "Plan for Identification of New Discharges" as contained in
Attachment 2. For any discharge identified pursuant to this Plan, the facility shall, within 90 days of
the seep discovery, determine if the discharge seep meets the state water quality standards established
in 15A NCAC 2B .0200 and submit the results of this determination to the Division. If the standards
are not contravened, the facility shall conduct monitoring for the parameters specified in A. (8.).
If any of the water quality standards are exceeded, the facility shall be considered in violation until one
of the options below is fully implemented:
1) Submit a complete application for 404 Permit (within 30 days after determining that a water
quality standards is exceeded) to pump the seep discharge to one of the existing outfalls, install
a pipe to discharge the seep to the Catawba River, or install an iii -sitar treatment system. After
the 404 Permit is obtained, the facility shall complete die installation of the pump, pipe, or
treatment system within 180 days from the date of the 404 permit receipt and begin
pumping/ discharging or treatment.
2) Demonstrate through modeling that the decanting and dewatering of the ash basin will result
in the elimination of the seep. The modeling results shall be submitted to the Division within
120 days from the date of the seep discovery. Within 180 days from the completion of the
dewatering the facility shall confirm that the seep flow ceased. If the seep flow continues, the
facility shall choose one of the other options in this Special Condition.
3) Demonstrate -that tine seep is discharging through the designated "Effluent Channel" and the
water quality standards in the receiving stream are not contravened. This demonstration
should be submitted to the Division no later than 180 days from the date of the seep
discovery. The "Effluent Channel" designation should be established by the DEQ Regional
Office personnel prior to the issuance of the permit. This permit shall be reopened for cause
to include the "Effluent Channel" in a revised permit.
All effluent limits, including water quality -based effluent limits, remain applicable notwithstanding any
action by the Permittee to address the violation through one of the identified options, so that any
discharge in exceedance of an applicable effluent limit is a violation of the Permit as long as the seep
remains flowing.
New Identified Seeps
If new seeps are identified, the facility shall follow the procedures outlined above. The deadlines for
new seeps shall be calculated from the date of the seep discovery. The new identified seep are not
permitted until the permit is modified and the new seep included in the permit and the new outfall
established for the seep.
ASH POND DAMS
Seepage through earthen dams is common and is an expected consequence of impounding water with
an earthen embankment. Even the tightest, best -compacted clays cannot prevent some water from
seeping through them. Seepage is not necessarily an indication that a dam has structural problems, but
should be kept in check through various engineering controls and regularly monitored for changes in
quantity or quality which, over time, may result in dam failure.
NPDES Pennit NC 0004987
Page 3

REASONABLE POTENTIAL ANALYSIS(RPA)-OUTFALL 002, OUTFALLS 101 AND 102
The Division conducted EPA -recommended analyses to determine the reasonable potential for
toxicants to be discharged at levels exceeding water quality standards/EPA criteria by this facility from
outfall 002 (Ash Pond). For the purposes of the RPA, the background concentrations for all
parameters were assumed to be below detection level. The RPA uses 95% probability level and 95%
confidence basis in accordance with the EPA Guidance entitled "Technical Support Document for
Water Quality -based Toxics Control." The RPA included evaluation of dissolved metals' standards,
utilizing a default hardness value of 25 mg/L CaCO3 for hardness -dependent metals.
Calculations included: As, Be, Cd, Chlorides, Cr, Cu, CN, Pb, Hg, Mo, Ni, Sc, Ag, Zn, Al, and B
(please see attached). The renewal application listed 8.3 MGD (the water flow diagram) as a current
flow. However, 11.44 MGD was used in the RPA as the highest reported flow during the last permit
cycle. The analysis indicates no reasonable potential to violate the surface water quality standards or
EPA criteria. The water -quality based limits for selenium were removed from the permit (Outfall 002)
based on the results of Reasonable Potential Analysis.
The Division also considered data for other parameters of concern in the EPA Form 2C that the
facility submitted for the renewal. The majority of the parameters were not detected in the discharge.
The Division reviewed the following parameters that were detected in the discharge and have an
applicable state standards or EPA criteria for Class WS -IV stream: phenols. This parameter was well
below the state standard.
An RPA was also conducted for the combined flow from the seeps (Outfalls 101 and 102). The
analysis was based on the dilution in the receiving stream since the effluent channels were delineated
for both seeps. Although one seep was not flowing at the time of the sampling, it was assumed that it
Might discharge during the wet season. Calculations included: As, Cd, Chlorides, Cr, Cu, F, Pb, Hg,
Mo, Ni, Se Zn, SO4, Al, Ba, B, Sb, and Tl (please see attached). The analysis indicates no reasonable
potential to violate the water quality standards or EPA criteria. The flow volume for the first seep was
measured at 0.0019 MGD. However, the flow of 0.5 MGD was used for the RPA to incorporate a
safety factor, account for potential new seeps that might emerge in the future or increase in flow
volume at the existing seeps.
In conclusion, the RPA analysis indicates that existing discharges from the facility outfalls and seeps
will not cause contravention of the state water quality standards/ EPA criteria.
The proposed pertmit requires that EPA methods 200.7 or 200.8 (or the most current versions) shall
be used for analyses of all metals except for total mercury.
DEWATERING — OUTFALL 002
To meet the requirements of the Coal Ash Management Act of 2014, the facility needs to dewater the
ash pond by removing the interstitial water from ash pond to meet the requirements of the NC Coal
Ash Management Act. The facility submitted data for the surface water in the ash ponds, interstitial
water in the ash, and interstitial ash water that was treated by 20 µm filter, 10 µm filter, and 0.45 µm
filter. To evaluate the impact of the dewatering on the receiving stream the RPA was conducted for
the wastewater that will be generated by the dewatering process. To introduce a margin of safety, the
highest measured concentration for a particular parameter was used. The RPA was conducted for As,
Cd, Chlorides, Cr, Cu, F, Pb, Mo, Hg, Ni, Se, Zn, SO4, Al, Ba, B, Sb, and Tl (please see attached).
Based on the results of the RPA, a WQBEL for Total Arsenic will be added to the dewatering effluent
sheet A. (3.).
NPDES Pennit NC 0004987
Page 4

FGD TECHNOLOGY BASED EFFLUENT LIMITS -INTERNAL OUTFALL 004
The new federal 40 CFR 423 Technology Based Effluent Limits (TBELs) have been added to the
Permit:
Total Arsenic — 8.0 µg/L (Monthly Average); 11.0 µg/L (Daily Maximum)
Total Selenium —12.0 µg/L (Monthly Average); 23.0 µg/L (Daily Maximum)
Total Mercury — 356.0 ng/L (Monthly Average); 788.0 ng/L (Daily Maximum)
Nitrate/nitrite as N — 4.4 mg/L (Monthly Average); 17.0 mg/L (Daily Maximum)
The federal rule 40 CFR 423 states that "dischargers must meet the effluent limitations for FGD
wastewater in this paragraph by a date determined by the permitting authority that is as soon as
possible beginning November 1, 2018, but no later than December 31, 2023". The DWR established
the date of compliance as January 31, 2021. This time period beyond November 1, 2018 is provided in
order for the facility to budget, design, and construct the treatment system. Duke provided the
justification for the proposed deadline and the DWR concurred with the compliance date.
MERCURY EVALUATION- OUTFALL 002
The State of North Carolina has a state-wide mercury impairment. A TMDL has been developed to
address this issue in 2012. The TMDL included the implementation strategy, both documents were
approved by EPA in 2012. The mercury evaluation was conducted in accordance with the Permitting
Guidelines for Statewide
Year
Mercur TMDL.
2010
2011
2.19
2012
1.55
2013
0.82
2014
0.89
Annual average
1.73
concentration n /L)
3.51
3.13
1.01
1.28
3.25
Maximum sampling
result n /L)
5
5
2
Number of samples
4
4
The allowable mercury concentration for this facility is 68.0 ng/L. All annual average mercury
concentrations are below the allowable level. All maximum sampling results are below the TBEL of 47.0
ng/L. Based on the Permitting Guidelines for Statewide Mercury TMDL, the limits are not required.
CWA SECTION 316(a) TEMPERATURE VARIANCE — OUTFALL 001
The facility has a temperature variance. In order to maintain the variance the facility has to conduct
annual biological and chemical monitoring of the receiving stream to demonstrate that it has a
balanced and indigenous macroinvertebrate and fish community. The latest BIP (balanced and
indigenous population) report was submitted to DWR in October of 2014. The DWR has reviewed
the report and concluded that Lake Norman near Marshall Steam Station has a balanced and
indigenous macroinvertebxate and fish community.
CWA SECTION 316(bl
The permittee shall comply with the Cooling Water Intake Stricture Rule per 40 CFR 125.95. The
Division approved the facility request for an alternative schedule in accordance with 40 CFR
125.95(a)(2). The permittee shall submit all the materials required by the Rule with the next renewal
application.
INSTREAM MONITORING -OUTFALL 002
The permit required semi-annual upstream and downstream monitoring near the ash pond discharge.
The upstream site (Station 15.9) is approximately 1 mile upstream of the discharge and downstream
location (Station 14) is approximately 1 mile downstream of the discharge. These monitoring stations
have been established through the BIP monitoring program, which was requited to maintain the
316(a) temperature variance. The monitored parameters are: As, Cd, Cr, Cu, Hg, Pb, Se, Zn, and Total
Dissolved Solids (TDS). The majority of the results are below detection level (Hg, As, Cd, Cr, Pb, Se),
NPDES Permit NC 0004987
Page

the rest of the results are below water quality standards (Cu, Zn, TDS). Most parameters did not
demonstrate any increase in the concentration at the monitoring stations below the discharge. The
exceptions are Zn, Cu, and TDS.
It is required that die monitoring of the instream stations will continue during the next permit cycle. It
is also required that the facility uses low level method 1631E for all Hg analysis.
FISH TISSUE MONITORING -NEAR OUTFALL 002
The permit required fish tissue monitoring for As, Se, and Hg near the ash pond discharge once every
5 years. This frequency is consistent with EPA guidance. Sunfish and bass tissues were analyzed for
these trace elements. The results were below action levels for Se and Hg (10.0 µg/g — Se, 0.40 µg/g —
Hg, NC) and screening value for As (1.20 — µg/g, EPA). These results are consistent with the previous
monitoring results.
TOZICITY TESTING -OUTFALL 002
Current Requirement: Outfall 002 — Chronic P/F @ 12% using Ceriodaphnia
Recommended Requirement: Outfall 002 — Chronic P/F @ 23% using Ceriodaphnia
This facility has passed all toxicity tests during the previous permit cycle, please see attached (23 out of
23).
The Division will increase the Instreain Waste Concentration from 12% to 23% due to the increased
wastewater flow, reported as 11.44 MGD. For the purposes of the permitting, the highest monthly
average flow reported during the last 3 years in conjunction with the 7Q10 summer flow was used to
calculate the percent effluent concentration to be used for WET.
COMPLIANCE SUMMARY
Notwithstanding the civil lawsuit filed for unauthorized discharges and groundwater
exceedances/violations, based on the monitoring required under the current version of the permit there
were no violations of effluent standards contained in the permit.
PERMIT LIMITS DEVELOPMENT
• The temperature limits (Outfall 001) are based on the North Carolina water quality standards
(15A NCAC 2B .0200) and 316(a) Thermal Variance. Summer and winter thermal limits have
been established in support of the 316(A) temperature variance issued by EPA in May of 1975
• Free Available Chlorine Limits (Outfall 001 and Outfall 003) were established in accordance
with 40 CFR 423.
• The limits for Oil and Grease and Total Suspended Solids (Outfall 002) are based on Best
Professional Judgment and are more stringent than prescribed in the 40 CFR 423.
• The pH limits (Outfall 002, 002A, 002B, and 003) in the permit are based on the North Carolina
water quality standards (15A NCAC 2B .0200).
• The pH limits (Outfall 004) in the permit are based on the BPJ.
• The limits for Total Copper and Total Iron (Outfall 002) were established in accordance with
40 CFR 423.
• The turbidity limit in the permit (Outfall 002) is based on the North Carolina water quality
standards (15A NCAC 2B .0200).
• The Technology Based Effluent Limits for Total Arsenic, Total Mercury, Total Selenium, and
Nitrate/nitrite as N (Outfall 004) are based on the requirements of 40 CFR 423.
• The Whole Effluent Toxicity limit (Outfall 002) is based on the requirements of 15A NCAC
2B .0500.
NPDES Permit NC 0004987
Page 6

. • The Total Arsenic limits (Outfall 002 dewatering) in the permit are based on the results of the
Reasonable Potential Analysis (RPA) of the interstitial water data. The calculations are
conducted in accordance with the EPA Guidance entitled "Technical Support Document for
Water Quality -based Toxics Control." The water quality chronic dissolved standard of 150.0
µg/L for Freshwater Aquatic Life and water quality acute dissolved standard of 340.0 were used
in the calculations of the limits. Please see attached RPA for details.
• The limits for seep Outfalls 101 and 102 (Oil and Grease and TSS) in the permit are based on
the requirements of 40 CFR 423.
PROPOSED CHANGES
• The Seep Outfalls 101 and 102 (Please see A. (8.) and A. (9.)) and Seep Pollutant Analysis
Special Condition (Please see A. (30.)) were added to the permit.
• A separate effluent page for the dewatering of the ash ponds (Outfall 002) was added to the
permit (Please see Special Condition A. (3.)).
• The Section 316(b) of CWA Special Condition was updated to reflect the new regulations.
• The turbidity limit was added to the permit (Outfall 002) to meet the state turbidity standard
per 15A NCAC 2B .0211(3) (k).
• The Technology Based Effluent Limits for Total Arsenic, Total Mercury, Total Selenium, and
Nittate/nitrite as N were added to the permit (Outfall 004).
• The water -quality based limits for Total Selenium were removed from the permit (Outfall 002)
based on the results of Reasonable Potential Analysis.
• Monitoring for Total Nickel was removed from the permit (Outfall 002) based on the results
of Reasonable Potential Analysis.
• Monitoring for Chlorides was removed from the permit (Outfall 002) based on the results of
Reasonable Potential Analysis.
• Monitoring for Total Zinc was removed from the permit (Outfall 002) based on the results of
Reasonable Potential Analysis.
• Monitoring for Total Zinc was removed from the permit (Outfall 004) based on the results of
Reasonable Potential Analysis.
• Monitoring for Total Arsenic was added to the permit (Outfall 004) due to the implementation
of the TBEL limit for Total Arsenic.
• Monitoring for Total Mercury was added to the permit (Outfall 004) due to the
implementation of the TBEL limit for Total Mercury.
• Starting December 21, 2016, federal regulations require electronic submittal of all discharge
monitoring reports (DMRs) and specify that, if a state does not establish a system to receive
such submittals, then permittees must submit DMRs electronically to the Environmental
Protection Agency (EPA). The final NPDES Electronic Reporting Rule was adopted and
became effective on December 21, 2015.
The requirement to begin reporting discharge monitoring data electronically using the NC
DWR's Electronic Discharge Monitoring Report (eDMR) Internet application has been added
to your final NPDES permit. (Please see A. (31.)) For information on eDMR, registering for
eDMR and obtaining an eDMR user account, please visit the following web page:
hn://deq nc gov/about/divisions/water-resources/edmr.
For more information on EPA's final NPDES Electronic Reporting Rule, please visit the
following web site:
NPDES Permit NC 0004987
Page 7

http: / /www2.el2a.kov/compliance/final-national-pollutant-discharge-elimination-system-
npdes-electronic-reporting-rule.
• The Applicable State Law Special Condition was added to the permit to meet the requirements
of Senate Bill 729 (Coal Ash Management Act, Please see Special Condition A. (12.)).
• The Additional Conditions and Definitions Special Condition was added to the permit. Please
see Special Condition A. (10.).
• Monitoring for Bromide was added to Outfall 002 and the Instreatn Monitoring Special
Condition A. (29.) to address the comment from the Public Water Supply Section/DWR.
• The monitoring frequency for the Whole Effluent Toxicity was increased to Monthly (Outfall
002) to address the EPA comment.
• The monitoring frequency for the -Total Arsenic, Total Selenium, and Total Mercury was
increased to Weekly (Outfall 002) to address the EPA comment.
• The IWC for the Whole Effluent Toxicity Test was changed based on the highest reported flow
data.
• Monitoring for Hardness was added to Outfall 002 and the Instream Monitoring Special
Condition A. (29.) to address the EPA comment.
• The attachment 1 entitled `Groundwater Monitoring Plan" was added to the permit.
PROPOSED SCHEDULE
Draft Permit to Public Notice: May 15, 2016
Permit Scheduled to Issue: August 26, 2016
STATE CONTACT
If you have any questions on any of the above information or on the attached permit, please contact
Sergei Chernikov at [phone] or [e-mail].
CHANGES IN THE FINAL PERMIT
The following modifications to the May Draft Permit were implemented based on public comirients
received during public hearing process, Division's staff recommendations included in the Hearing
Officer Report Quly 28, 2016), EPA comments, and Duke Energy comments:
• A Special Condition entitled "Domestic Wastewater Treatment Plan" was added to the permit
to address the EPA comment (Please see Special Condition A. (32.)).
• The Daily Maximum limit for TSS was reduced to 50.0 mg/L for Outfall 002 to meet the
requirements of 40 CFR 423.
• The limits for TSS and Oil and Grease were added to Outfall 002A and 002B to meet the
requirements of 40 CFR 423.
• A Special Condition A.30 was modified to address the EPA concern regarding the permitting
of the newly identified seeps.
• The limits for BOD and Fecal Coliforms were added to Outfall 002 to address the EPA
comment.
• The Plan for Identification of New Discharges was added to the permit to address the EPA
comment.
• The Seep Pollutant Analysis Special Condition (Please see A. (30.)) was modified based on the
discussion with the US Army Corps of Engineers.
• The additional decanting conditions for closing ash ponds were added to the permit to address the
EPA comment.
NPDES Permit NC 0004987
Page 8

Marshall Steam Station
NC0004987 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
Qw (MGD) = 1.00
1QIOS (cfs)= 49.15
7QI OS (cfs) = 60.00
7QIOW (cfs)= 60.00
30Q2 (cfs) = 60.00
Avg. Stream Flow, QA (cfs) = 60.00
Receiving Stream: Lake Norman HUC 03010103
WWTP/WTP Class: I
IWC% @ 1QIOS = 3.057199211
IWC% @ 7Q10S = 2.518277823
IWC% @ 7Q10W = 2.518277823
IWC% @ 30Q2 = 2.518277823
IW%C @ QA = 2.518277823
Stream Class: WS -IV
Outfall Seeps I
Qw = 1 MGD
COMBINED HARDNESS (mg/L)
Acute = 27.26 mg/L
Chromic = 26.86 mg/L
YOU HAVE DESIGNATED THM GR[ECEWOMO
STREAM AS WATER SUPPLY
Effluent Hard:1 val > 100 mg/L 0 va9 z 25 mg/L
default 99 mg/L (Effluent Hard Mad = 291 mg/L)
PARAMETER
STANDARDS & CRITERIA (2)
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
J
F
(1)
NC WQS / Applied '/z FAV /
W
z
n # Det Max Pred Cw Allowable Cw
Chronic Standard Acute
Acute (FW)- 11,121.3
Arsenic
C
150 FW(7Q10s) 340
ug/L
no limit
1 0
NO DETECTS
_
Chronic (FW) 5,956.5
Max MDV. = 1
Arsenic
C
10 HHIWS(Qavg)
ug/L
None-nj�9
-------------------------------------
_____________Arsenic
Chronic (HH): 397.1
Llerlted data sed
Max MDL =1
Acute: 2,126.13
Beryllium
NC
6.5 FW(7Q10s) 65
ug/L
0 0
N/A
--C _ _ ------------------------------------
Na .
--
hronic. 258 11
Acute: 114.294
no limit
Cadmium
NC
0.6228 FW(7Q10s) 34942
ug/L
1 0 NO DETECTS
i�dslem a�'�'
---------------------------------------
Chronic:
----
Umlacd data seg
Mass MDL =1
'Acute:
NO WQS
Chlorides (AL)
NC
230 FW(7Q10s)
mg/L
1 I 5.1
no limit
Notf-n�9 13ofpuftC'V.
___ _ _ _
Chronic: ---9,133.2 —
--- —
— — — — --- --- — —
Ur3a "lied &I''s set
No value > Allowable Cw
Acute. NO WQS
Chlorinated Phenolic Compounds
NC
1 A(30Q2)
ug/L
0 0
N/A
-C _ _ _ --
—hr _ -----
n/a
------------- --------------
39
onic: .7
Acute: NO WQS
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
0 0
N/A
-C _ _ _ _ _ —
—hronic: ---
Na
— - — - — - — - — - — - — - — - — - — — — -
11---
,912.9
- - —
Acute: 31,781.7
Chromium III
NC
124.8729 FW(7Q10s) 971.6302
gg/L
0 0
N/A
no limit
---------------------------------------------
Chronic: 4,958.7
Acute: 523.4
Chromium VI
NC
I 1 FW(7QIOs) 16
gg/L.
0 0
N/A
no limit
_ _ _ _ _
--Chronic: ----436.8 --
-----------------------.---
Chromium, Total
NC
µg/L
1 0 NO DETECTS
no limit
U¢swittd dmta sag
Max MDL =1.47
4987 -RPA dissolved seeps 1-2016, rpa
Page 1 of 3 4/21/2016

Marshall Steam Station Outfall Seeps 1
NC0004987 Freshwater RPA - 95% Probability/95% Confidence Usinq Metal Translators ow = i mr.n
4987 -RPA dissolved seeps 1-2016, rpa
Page 2 of 3 4/21/2016
Acute: 371.67
Copper (AL)
NC
8.3800 FW(7QI0s) 11.3626
ug/L
I 1 1.00
no limit
--
Note. n S 9 DefaultC.V�
Chronic: —332 77
— - — -
Uufted, dats set
No value > Allowable Cw
Acute- 719.6,
Cyanide
NC
5 FW(7QI0s) 22
10
ug/L
0. 0
N/A
---7
We
---------------------------------------
Chronic: 198.5
'
Acute: NO WQS
Fluoride
NC
1800 FW(7QI0s)
ug/L
I 0 NO DETECTS
no limit
. 9
Noten 5
--7 - - - - 71,477.4 - - —
- —
EhrO---Chronic:
- — - — - — - — - — - — - — - — - — - — - — - — - — - -
Ulmitsd dati set
Max MDL = 500
Acute: 2,721992
Lead
NC
3.1895 FW(7Q]Os) 83.2167
ug/L
1 0
NO DETECTS
no limit
NoW. n5- 9
7 ----- T6--
-5�r————
—Chronic. 126.6T
------------------------- --
Limited data set
Max MDL = I
Acute: NO WQS
Mercury
NC
12 FW(7QI0s)
0.5
n g/L
1 0 1 NO DETECTS
no limit
Note- a � 9
Chronic: 476.5
Urnitr-d tinta -set
Max MDL = 50
Acute: NO WQS
Molybdenum
NC
2000 HH(7QI0s)
ug/L
10 NO
INO DETECTS
no limit
Note- vi 5 Y
---
----------------
Chronic: 79,4194
-------------------
Unift&d d0a set
Max MDL =1
(FW)- 11,798.3
Nickel
NC
39.5661 FW(7QI0s) 360.6984
µg2Acute
------------------
no limit
--------------------------
I 1
1.0
Chronic (FW): 1,571.2
NoU 9
Demalt C.V.
No value > Allowable Cw
Nickel
NC
25.0000 WS(7QIOs)
gg/L
Umited data set
Chronic (WS): TET ------
—
No value > Allowable Cw
Acute: 1,831.7
Selenium
NC
5 FW(7QI0s) 56
ug/L
1 0
NO DETECTS
no limit
Note. U.5 9
------ --------------------------------
011ie: 198.5
Unifted dati ser
Max MDL = 4.58
Acute: 11.253
Silver (AL)
NC
0.06 FW(7QIOs) 0.3440
ug/L
0 0
N/A
n1a
--rllie, —7 - - - - - - - - -
EhO--
2.383
- - - - - - - - - - - - - - - - - - - - - - - - - - - -
Acute: 4,424.9
Zinc (AL)
NC
134.6935 FW(7QlOs) 135.2792
ug/L
1 0
NO DETECTS
no limit
Now;; TI, 25
.............................................
Chronic- 5,348.6
Limi,ited data zefi
Max MDL = 5
Acute: NO WQS
Antimony
NC
5.6 WS(7QIOs)
gg/L
1 0 NO DETECTS
no limit
N4d4e-. n o'
------ -- -------------
--
Ulaff ite,d data set
Max MDL = I
Acute: NO WQS
Thallium
NC
0.24 WS(7QI0s)
gg/L
1 0 NO DETECTS
no limit
L
NrAv� IKA 5 9
- - - - - - -
- 7 - - - -
Chronic: . 9.53032
------------ - - - -- - -
Unifted data set
Max MDL = 0.2
Acute: NO WQS
4987 -RPA dissolved seeps 1-2016, rpa
Page 2 of 3 4/21/2016

•Marshall Steam Station
Outfall Seeps 1
NGUUU4yt5 / I-resnwater KFA - 95% Frobablllty/95%
Uontidence Using Metal Translators QW = 1 MGD
Sulfate NC 250 WS(7Q10s)
mg/L 1 1 I 290.00000
_ _ _ _ _ _ _..._-_
Note- a f 9 D-KI12uh C.V. Chronic: 2382.58065
Llmifi-d dab set No value > Allowable Cw
Acute: NO WQS
Aluminum
NC
87 FW(7Q10s)
µg/L
1 1 278.00000 FN,
no limit
_Note. ra5 ➢ �G est C.V.hronic:-3454.74194A
d ata set alue > Allowable Cw
4987 -RPA dissolved seeps 1-2016, rpa
Page 3 of 3 4/21/2016

Warshall Steam Station
Outfall Seeps 1
N00004987 Freshwater RPA - 95% Probability/95%
Confidence Using Metal Translators Qw = 1 MGD
Acute: 371.67
Copper (AL)
NC
8.3800 FW(7QIOs) 11.3626
ug/L
1 1 1.00
_ _ _
----3j-277--
no limit
l' ev u 9 D�ffi_ a ,j.
_
Chronic:
------------------_-------
Lhnited r .iu seta
No value > Allowable Cw
Acute: 719.6
n/a
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
0 0
N/A
—h-C _ _ _ _
r ---- -- --
--------------------------
Acute: NO WQS
Fluoride
NC
1800 FW(7Q10s)
ug/L
1 0 NO DETECTS
no limit
tat ia�9
_ _ _ _ _ _
Chronic: --- 71--- —
--------------------------
Umnitad dat<aa set
Max MDL = 500
•
Acute. 2,721.992
•
Lead
NC
3.1895 FW(7Q10s) 83.2167
ug/L
1 0 NO DETECTS
no limit
®taa
_ _ _ _ _ _
Chronic: — 126.656--
-------------------------
RAMRR' l d 3f a sat
Max MDL = 1
Acute: NO WQS
Mercury
NC
12 FW(7Q10s)
0.5
ng/L
1 0 NO DETECTS
no limit
Natas 59
_ _ -----------
Chronic- --476.5 —
— — -- ---- — — — —,--- — —
Limited data sat
Max MDL = 50
Acute: NO WQS
Molybdenum
NC
2000 HH(7Q10s)
ug/L
1 0 NO DETECTS
no limit
Note: n 3
Chronic: -- 79,419.4 —
— --- — — — — --- — — — --
United .rdaatR Set
Max MDL = H
Acute (FW): 11,798.3
Nickel
NC
39.5661 FW(7Q10s) 360.6984
µg2
no limit
1
1 1Fn""
_ _ _ ___ _ ___
---------------------------------------------
Chronic (FW) 1,571.2
_________________________
Not�o rs rC,-•
No value > Allowable Cw
Nickel
NC
25.0000 WS(7Q10s)
µg/L
Limited dV a set
Chronic (WS) 992.7
No value > Allowable Cw
Acute. 1,831.7
Selenium
NC
5 FW(7Q10s) 56
ug/L
1 0
NO DETECTS
no limit
Nraterat9
---------------------------------------------
Chronic: 198.5
Llammltael d0m sa
Max MDL = 4.58
Acute: 11.253
Silver (AL)
NC
0.06 FW(7Q10s) 0.3440
ug/L
0 0
N/A
n/a
_ _ ---------------------------------------
—Chronic: 2.383
Acute: 4,424.9
Zinc (AL)
NC
134.6935 FW(7Q10s) 135.2792
ug/L
1 0 NO DETECTS
no limit
Note- a9
_ _ _ _
—Chronic: -- 5,348.6--
--------------------------
L uni Red di-ta set
Max MDL = 5
Acute: NO WQS
Barium
NC
1 WS(7Q10s)
mg/L
1 1 0.09800
no limit
N�@e, mai 9taa�ltC.V.
_ _
Chronic: 39.70968--
Umniftd d albra set
No value > Allowable Cw
Acute: NO WQS
s
Boron
NC
7 WS(7Q10s)
mg/L
1 0 NO DETECTS
no limit
a�laEa,
_ _ _ ---- _ -— _ _
Chronic: ----
6774
-------------------------
L"mSter1(Astaa sett
Max MDL = 3.99
Acute:
4987 -RPA dissolved seeps 2-2016, rpa
Page 2 of 3 4/21/2016

REASONABLE POTENTIAL -ANALYSIS
4987 -RPA dissolved seeps 1-2016, data
1 - 4/21/2016
H
Paf01 8 Par02
Use "PASTE SPECIAL
Use "PASTE SPECIAL
Values" then "COPY"
Effluent Hardness (monthly average)
Valves" then "COPY"
Arsenic
. Maximum data,
points = 58
. Maximum data
points = 58
Date Data BDL=1/2DL Results
Date Data
BDL=1/2DL Results
1
2911 291 Std Dev. N/A
1
05 Std Dev. N/A
<
2
Mean 291.0000
2
Mean 0.5000
3
l C.V. 0.0000
3
C.V. 0.0000
4
I n 1
4
n 1
5
! 10% value 291.00 mg/L
5
6
Median Value: 99.00 mg/L
6
Mult Factor = 1.00
7
Max. Value 291.00 mg/L
7
Max. Value 0.5 ug/L
8
j
8
Max. Pred Cw O DETECTS ug/L
9
I
9
,
10
p
10
11
I
11
1212
f
13
13
14
14
15
15
16
16
'
17
17
18
- .
18a
19�
.,
19
20
20
21
I
21
22
i1
22
23
i
23
24
24
25
25
26
27�
}
26
27
28
28
29
{
291
30
30!
31
31
32
;
32
33
I
33
34
34
35
35
36
d
36
if
37
I
37
38
II
38
39
39
40
.
40
41
,
41
42
42
43
43
!
44
44�
45
451
'
46
"
46
47
47�
48
i
48'
49
9
49�
50
50
51
51
52
52
53
53
54
54
j
55
55
56
561
57
0
57
58
i
58
4987 -RPA dissolved seeps 1-2016, data
1 - 4/21/2016

REASONABLE POTENTIAL ANALYSIS
Par03
Use "PASTE SPECIAL
Par04
Uso"PASTE SPECIAL
Beryllium Values" then "COPY"
Cadmium Valuos" then "COPY"
. Maximum data
. Maximum data
points = 68
points = 68
Date Data BDL=1/2DL Results
Date Data
BDL=1/2DL Results
1
�`— i Std Dev. NO DATA
1
< 11
0.5 Std Dev. N/A
2
j Mean NO DATA
2
i Mean 0.5000
3
d, C.V. NO DATA
3
f C.V. 0.0000
4
n 0
4
1 n 1
5
"
5
6
Mult Factor = N/A
6
Mult Factor = 1.00
7
Max. Value N/A ug/L
7
} Max. Value 0.500 ug/L
Max. Fred Cw N/A ug/L
9
Max. Fred Cw O DETECTS ug/L
9
10
10
11
11
I
12
123
13
131
14
14
15
15i
16
1
163
3
17
171
18
18
194
E
19�
20
20
21
¢
21
22
22
23
23
2424
251
25
2626
271
27
}
281
28
1
29�
I
29
30
30
31
31
32
32
331
3
33t
34f
`}
34j
3511
;
35
36
36
37
i
37
4
38
38
I
39
39
40+
40
fj
41
j
41
42
431
- I
42
43
44
I
44
.
45
i
45
S
46
46
j
47
47
48
48
49
t"
I
49
50
50
51
52
i
51
52
53
53
54
54
55
55
56
56
57
57
58,,-58
4987 -RPA dissolved seeps 1-2016, data
- 2 - 4/21/2016

REASONABLE POTENTIAL ANALYSIS
Par05
Par06
Use "PASTE SPECIAL-
Use "PASTE S
Chlorinated
Values" then .
Phenolic Compounds
Chlorides
Values" then COPY" .
(AL) "
Maximumdatapoints=
58
Maximum
points =
Date Data
BDL=1/2DL Results
Date Data
BDL=1/2DL Results
1
5.1 Std Dev. N/A
1
Std Dev. NO DATA
5.1
2
Mean 51
2
Mean NO DATA
3
C.V. 0.0000
3
C.V. NO DATA
4
n 1
4
n 0
5
5
6
Mult Factor = 1.0
6
Mult Factor = N/A
7
Max. Value 5.1 mg/L
7
Max. Value N/A
8
Max. Pred Cw 5.1 mg/L
8
Max. Pred Cw N/A
9
9
10
10
11
•
11
12
12
�
13
13
I
14
14
�
15
15
.
16
16
J
17
17
18
18
19
19
20�
20
21�
21
.
22
22
23,
23
24�
24
25
25
26
26
27
27
28
28
29
29
30
30
31
31
32�
32
33
33
34
34
35
35
36
36
37
37
38
38
39
39
40
40
41
41
'
42
• "_
42
43
43
44
44
45
45
4646
r
.
471
47
48
48
i
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
58
4987 -RPA dissolved seeps 1-2016, data
- 3 - 4/21/2016

REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved seeps 1-2016, data
- 4 - 4/21/2016
Par07
Par08
ECIAL
Use "PASTE SPECIAL
'Uso "PASTE S
OPY"
Total Phenolic
Values" then "COPY"
Compounds
Values" then "
Chromium III
ata
Maximum data
Maximum
8
points = 58
points =
1
Date Data
BDL=1/2DL Results
Std Dev. NO DATA
1
Date Data BDL=1/2DL Results
—"� Std Dev. NO DATA
_
2
Mean NO DATA
2
Mean NO DATA
3
C.V. NO DATA
3
J C.V. NO DATA
4
n 0
4
ii n 0
5
51
6
Mult Factor = N/A
6
j Mult Factor = N/A
ug/L
7
Max. Value N/A ug/L
7
I Max. Value N/A
ug/L
8
Max Pred Cw N/A ug/L
8
i Max. Pred Cw N/A
9
9
10
10
11
11
12
12)
l
13
13
14
15
14�
15�
I
16
16
_
4
17
17�
18
18i
19
19!
4
20
20111
21
21
22
22
-
23
23
1
24
24
25
25
26
26'
27
27
I
28
28
29
29
30
30
!
31
31
32
32
33
33
34
34
35
35
P
1
36
36
37
37
'
38
38
39
39
y
40
40
41
41
{
42
42
j
43
43
44
44
45
45
i
46
46
1
47
47
i
48
48
49
49
50
50
51
51
52
52
l
53
53
i
54
54
55
56
55
56
57
57
58
58
y
4987 -RPA dissolved seeps 1-2016, data
- 4 - 4/21/2016

REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved seeps 1-2016, data
- 5 - 4/21/2016
Par09
Par10
ECIAL
Us'4 STE SPECIAL
OPY"
ChrOmlUm
. Valuos"then "COPY"ata
Vl
ChrOmlUm, Total
z
. Maximum data
points = 5U
S
1
Date Data
BDL=1/2DL Results
Std Dev. NO DATA
1
Date Data BDL=1/2DL Results
< 1 ATI 0.735 Std Dev. N/A
2
Mean NO DATA
2
Mean 0.7350
3
C.V. NO DATA
3
i C.V. 0.0000
4
n 0
4
; n 1
5
5�
6
Mult Factor = N/A
6
j Mult Factor = 1.00
pg/L
7
Max. Value N/A pg/L
7
Max. Value 0.7
pg/L
8
Max. Fred Cw N/A pg/L
8�
Max. Pred Cw O DETECTS
9
10
9
10�
11
11
1
12
12,
13
13
14
14
1
15
15�
16
,
16)
g
17
17+
!
18
18�
y
19
19
i
20
20
21
21�
22
2211111
23
231
24
24
25
25�
26
26
27
27
28
28
29
29
30
30
31
31
32
32
33
33I
34
3411
35
35
36
36
i
37
37
i
38
381
39
.
39
40
40
41
41
42
42
43
43
I
44
44
1
45
45
i
46
46
47
47
48
48
49
49
i
50
50
'
51
51
52
52
I
53
53
j
54
54
55
55
56
56
57
57
58
58
— - -
4987 -RPA dissolved seeps 1-2016, data
- 5 - 4/21/2016

J,
J
Q
Z
Q
J
Q
H
Z
W
a
W
J
m
Z
O
Q
w
w
rm CO
U O
N
O
ZZZ
FuzQQQ
❑❑❑
000
Z Z
U
oma
u°>a
� 0
c
1
y
� a)i
�
J
❑
a
c
ca
HI
U
m
o
d
R
❑
N
N M V (� CO 1� N m O r N M d' O t` W (A O N M V (n O N O W O N M V (n M f� CO m 0 NFM O h aD M 0 N M t0 r CO
cy
a
r r r r r' r r r r N N N N N N N N N N M M M M M M M M M M <} p 7 V V v V u7 li u') m m u') � Cn 4')
a
S J J
0)0)"
LU
> >
w�Eri
oor 000
F
L £ y 0 0 0 0 O
00
d
c o 0
y R n r 0
-
m �
�
m
Q
>>
Z
U
oma
j ca N
eN
LL
= aO c
c°i >. m
44) P acn
co
a
or
L �
C7
C. J
CL ❑
0 m
__
m
,
I
o
'
M to O r co m O r N M V (O f� W m O N M V CO CD r� CO M O N M M CO I- CO O O N CO V• tO O r CO CA O N CO C U) O t` N
r r r r r r r r r r N N N N N N N N N N M M M M M M M M M M d• d• v �{ V V 'V' '7 V V' l0 lq (CJ ll7 l0 In U7 CI) CI)
a
J
a
ro
1 1
W
a
rm CO
U O
N

REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved seeps 1-2016, data
- 7 - 4/21/2016
Par13
Par14
ECIAL
Use "PASTE SPECIAL
OPY"
Fluoride vahmes"men••60PY"
Lead
a
ata
. Maximum data
points = 58
8
1
Date Data
BDL=1/2DL Results
250 Std Dev. N/A
1
Date Data BDL=1/2DL Results
<y1, 05 Std Dev. N/A
< 500
2
Mean 250.0000
2
{ Mean 0.5000
3
C V. 0.0000
3
f C.V. 0.0000
4
n 1
41
f n 1
5
5,
S
6
Mult Factor = 1.00
6
Mult Factor = 1.00
ug/L
7
Max. Value 250.0 ug/L
7
JJf
Max Value 0.500
ug/L
8
Max Pred Cw O DETECTS ug/L
8
} Max. Pred Cw O DETECTS
9
9
10
10
11
11
s
12
12
q
13
13
14
14
f
15
15
j
16
161
17
17
18
18
19
19
1
20
201
21
211
I
22
221
23
23
i
24
24f
i
25
25
y
26
26
27
27
28
28
29
29
30
30
;
31
31
32
32
33
33
34
34
¢f
35
35
R
36
36
§
37
37,
38
38
;
39
39
, 4
40�
40
3
41
41
42
421
431
a
43�p
441
J
441
45
45�
g
46
46{
}
47
479
SSt
48
48�
49
49111111
j
50
50�
51
51+
52
521
53
54
53
54
55
55
1
56
56
i
57
57
58.
_
58
4987 -RPA dissolved seeps 1-2016, data
- 7 - 4/21/2016

J:
mu
W
d
0 r OLnU
yr O O O O F
yrEc
Ino W
a
y'X°
i 0 F-
LU
d
R
�
Q ❑
>>
Z U
u U
o
� -o
j U N
aN
L. >a
O
�c
�
>
ai . = m m
ami m � c
U
M U
J U�
C
❑o
ry
a
o
m
o�
a
c
❑
r N M V m f- m m 0 r N M V �0 (0 I� N O O N M V U7 m h m m 0 N M V U) m f� m m 0 N M V U) m I� m m 0 N CO) V tt� m h m
i4
CL
r r r r r �- r r r r N N N N N N N N N N M M M m P7 m M m M M V V V •� V V V V v 0 0 m m U -j m U� m
J=
Q
} J J
Q 07 cm
W
c c
4
V h
00— O O w
W
�=
d N Q 0 O. (—
E c o o rC4
N W
>
> Z U
It U
O
j p
N > (J l6 �
3�c uL>a
(UDIami >. =3m m
U c
N
� II
d Q
m
A
N
r N M V U) f0 I� m m N M V m 0 I- m m 0 N M V 0 m I� m m 0 N M V U7 m f.- m
r r r r r r r r r r N N N N N N N N N N M M M M M M M M M M V V V V V V V V V m U) m U] m m m U) U7
a
G
FWJ
�
p =°
d w
J J
o of
>
(0 m
cu
'a 0
N
m
N
CN d
a
a°'i
ami
0
w
Q
a
m
CD
,It

REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved seeps 1-2016, data
- 9 - 4/21/2016
Parl7 & Parl8
Par19
eCIAtI
0• Py,
Nickel
M
Selenium
ata
8
1
Date Data
BDL=1/2DL Results
0.95 Std Dev. N/A
IF
Date Data BDL=1/2DL Results
----Z-4.581 2.29 Std Dev.
< 1.9
2
Mean 09500
2
9 Mean
3
C.V. 0.0000
31
y C.V.
4
n 1
4
9 n
5
5
f
6
Mult Factor = 1.00
6
I Mult Factor =
ug/L
7
Max. Value 1.0 pg/L
7
Max Value
ug/L
8
Max. Fred Cw 1.0 pg/L
8
f Max. Fred Cw
9
9j
a
10
101
11
11�
2
12@
121
131,
131
14
141'
15
15
t
16•
16
I
17
17'
18
!
18
1
19
I
19
20
20
{
21
21
22
22
1
23
23,
1
24
241
25
215
26
26+
27
27
I
28
281
29
29+
y -
30
30
i
31
31
32
32
1
33
33
34
34
i
35
35
36
36�
37
37�
38
381
f
39
391
1
40
40�
41
41
42
42
43
43
pyp
44
44
Y
45
45
46
46
47
47
48
48
49
49
50
50
51
51
52
52
{
53
53
54
54�
55
55
56
56)
57
57
58
581
4987 -RPA dissolved seeps 1-2016, data
- 9 - 4/21/2016

REASONABLE POTENTIAL ANALYSIS
Use"PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 68
Par20
1
Date Data
Use"PASTE SPECIAL
Silver (AL) Values" then "COPY"
. Maximum data
points = 58
BDL=1/2DL Results
Std Dev. NO DATA
Par21
1
Date Data
Zinc AL
( )
BDL=1/2DL Results
2.5 Std Dev.
N/A
< 5�
2.2900
2
Mean NO DATA
2
Mean
0.0000
3
C.V. NO DATA
3
C.V.
1
4
n 0
4
n
5
5
1.00
6
Mult Factor = N/A
6
Mult Factor=
2.3 ug/L
7
Max. Value N/A ug/L
7
Max. Value
O DETECTS ug/L
8
Max. Pred Cw N/A ug/L
8
Max. Pred Cw
9
9
10
10
11
i
11
'
12
=�
12
13
14�
13
14
1
15�
15-
3
16
16
17
17
18
f
18
19
19
20
20
21
21
22
22
23
23
24
24
25
25
26
26
27
27
28
28
29
29
30
30
31
31
32
32
33
33
34
34
35
35
36
36
37
37
38
38
39
39
40
.
40
41
41
42
42
43
43
44
44
45
45
46
46
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
58
4987 -RPA dissolved seeps 1-2016, data
-10- 4/21 /2016

v
C0
}
J
Q
Z
a
J
La
r
Z
W
O
CL
W
J
m
a
Z
O
N
NW
w
M(D
16o
N
O
w
mP
.
❑I
r N Cl) -T 4) CO h W O) O r N M d' lO (O I� a0 O O N M �O (O h o7 0) O N M "r c0 h M 0) O N M V' li') lD f� O O) O N M V �O (O 1� m
a
r r r r r r r r r r N N N N N N N N N N M (7 M M M M M M M M V' V' V V V V V V 'V V �O UO �o 0 Lo W m Lo
a S
J J
La
a cm
:L =L
U 9 h
N c E n
Wh
O O r
o0
O O U
OOF.
r =
O O
IqO
O
rOU
o
00
O W
u
Q
O W
❑
>>
Z
U
11 U
w
a>
co
LLIL
y
Q C
!
_
N
7 (6 co
�+ J
Lo
C O
O
O N
II
w J
Q m
CIS
V
m
" "
clO
N
`
r N co •V' Lo CO I- c0 O) O N M "t h O h W O O N M VU� O 1` M M O N M 'V N O h M M O N M -T u') O I- M
N
CL
r r r r r r r r r r N N N N N N N N N N M M MOMOMMMMIT 'V' V' •V' v V' v V 'V V' 0 t(7 lO m UO UO M Lo lO
J
Q >
UaO�
J J
0) CF)
U v w
7 7
N G E
O O r
O m (n
W
yw E c
CD p p O
Unq
(V f
T" U
ay�a
0io
F
w('
n
>>
z
U
M(D
16o
N

REASONABLE POTENTIAL ANALYSIS
Use"PASTE SPECIAL
Values" then "COPY"
. Maximum data
Par24
Use "PASTE SPECIAL
Values" then "COPY"
Sulfate , Maximum data
points = 68
Par25
Aluminum
points = 68
Results
Date Data
BDL=1/2DL Results
Date Data
BDL=1/2DL
Std Dev. N/A
1
290 Std Dev. N/A
1
278
290
278
Mean 0.1000
2
Mean 290.0000
2
C.V. 0.0000
3
C.V. 0.0000
3
n 1
4
n 1
4
5
5
Mult Factor = 1.00
6
Mult Factor = 1.00
6
Max. Value 0.100000 pg/L
7
Max. Value 290.000000 mg/L
7
Max. Pred Cw O DETECTS pg/L
8
Max. Pred Cw 290.000000 mg/L
8,
10
10
`
12
12
I
13
"s
13
14,
14°
15
15
-
°
16
16
17
�
17
18
'
18.°."
19
19
-"
20
20
21
I
21
22
22-
23
23
24
24
25
25
26
26
27
27
28
28
29
29
30
30
31,
31
32
32
33
33
34
34
35
35
°
36
36
.
37
37
38
38
39
39
40'
_.
40
,
41
41.°.
42
42
43
43
44
44
45
45
46
'
46
.
47
47'
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
°
56
57
56
57
.
58_
58
4987 -RPA dissolved seeps 1-2016, data
-12- 4/21/2016

¢,
Results
Std Dev. N/A
Mean 278.0000
C.V. 0.0000
n 1
Mult Factor = 1 00
Max. Value 278.000000 pg/L
Max. Pred Cw 278.000000 pg/L
REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved seeps 1-2016, data
-13- 4/21/2016

REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved seeps 2-2016, data
-11 -
4/21/2016
Par22
Par23
Usc "PASTE SPECIAL
Use "PASTE SPECIAL
Values" then "COPY"
Values" then "COPY"
Barium
Boron
. Maximum data
, Maximum data
points = 58
points = 58
1
Date Data BDL=1/2DL Results
0.098 0.098 Std Dev. N/A
1
Date Data
BDL=1/2DL
1.995
N/A
<� 3.99
2.5000
2
Mean 0.0980
2
0.0000
3
I C.V. 0.0000
3
1
4
n 1
4
5
5
1.00
6
Mutt Factor = 1.00
6
2 5 ug/L
7
Max Value 0.098000 mg/L
7
O DETECTS ug/L
8
Max Pred Cw 0.098000 mg/L
8
9
t
9
10
10
11
11
12
12
13
13
14
14
z
15
15
16
16
17
17
18
18
19
19
20
20
21
21
22
I
22
23
23
24
24
25
25
26
26
27
27
2g
28
29
29
30
30
31
31
32
32
33
33
34
34
35
35
36
36
37
37
38
38
. n
39
39
40
- a
40
41
(
41
_
42
42
43
43
.o
44
44
;
45
1
45
46
46
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
58
4987 -RPA dissolved seeps 2-2016, data
-11 -
4/21/2016

7T
J
Q
a
J
Q
F—
Z
W
F-
0
a
W
J
Z
U)
W
m
J
❑
N
CD
II
J
m
`
r N co '7 UO CO 1� O m N co �• UO co I— co O O NM V' (O (D II. W m(D N M V m co r Om O N M V v) (D r, co
w
d
r r r r r r r r r N N N N N N N N N N co 07 co co co co M co co M V V V V V V v V d' V' (D ID (D tO u0 UO UO UO UO
J
as
e
Lu
o
N
v a o
O
G 3 N Z Z Z
> Z Z Z
>
u U
`o
-o
m� d
w
L a
y� m m
a16i>,
J
Cl
N
� I I
J
❑
m
cc
4
I
UO v1 O
r N co v UO ID I-- CO M O N CO V• Un (D h OD M O N M '7 UO (D I-. 00 O) O N M 'V N O h co m O N MUO Vl0
m
a
r r r r r r r r r r N N N N N N N N N N M M co co M co co M co co v '7 V V V a V C C' }• UO Un UO (D UO t0
UUO
U
_J J_
d ? m m
Lu
° E E
m
w
c E n oor oov)
c Lo c) 0oF
rn o o U
•_o rnW
>>
Z O
II U
7 LL % Il
0 c
co
m
u) .1 N! 7 x05

Mi arshall Steam Station
NC0004987 Freshwater RPA - 95% Probability/95% ConfidenceUsing Metal Translators
MAXIMUM DATA POINTS = 58
Qw (MGD) = 11.44 WWTP/WTP Class- I
IQ10S (cfs)= 49.15 PNC% @ 1QIOS = 26.51236506
7QI OS (cfs) = 60.00 IWC% @ 7Q10S = 22.81171204
7QIOW (cfs) = 60.00 IWC% @ 7Q10W = 22.81171204
30Q2 (cfs) = 60.00 IWC% @ 30Q2 = 22.81171204
Avg. Stream Flow, QA (cfs) = 60.00 IW%C @ QA = 22.81171204
Receiving Stream: Lake Norman HUC 03010103 Stream Class: WS -IV
Outfall, 002
Qw = 11.44 MGD
COMBINED HARDNESS (mg/L)
Acute = 25 mg/L
Chromic = 25 mg/L
YOU HAVE DESIGNATED THIS RECEIVING
STRFAM AS MATER SUPPLY
Effluent Hard:0 vall > 100 mg1L 0 val < 25 mg/L
Effluent Hard Med = 25 mg/L
PARAMETER
STANDARDS & CRITERIA (2)
rn
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
(1)
NC WQS / Applied %2 FAV /
2
z
n 4 Det Max Pred Cw Allowable Cw
Chronic Standard Acute
Acute (FW): 1,282.4
Arsenic
C
ISO FW(7QIOs) 340
ug/L
no limit
23 20
19.7
_
Chronic (FW) 657.6
Novalue>_Alllow_ableC6V-------------------------------
Arsenic
C
10 HH/WS(Qavg)
ug/L
Chronic (HH)_43.8
No value > Allowable Cw
Acute: 245.17
no limit
Beryllium
NC
65 FW(7QIOs) 65
ug/L
1 0
NO DETECTS—Chr
Note. n:59
_ _ ---------------------------------------
onic: 28.49
Limited data se>R
Max MDL = I
Acute: 12.219
no limit
Cadmium
NC
0.5899 FW(7QIOs) 3.2396
ug/L.
1 0 NO DETECTS
Nit °ri�9
_ ------------
Chronic: ------
--------------=----------
MWaRed &tu% s
Max MDL = I
Acute- NO WQS
Chlorides (AL)
NC
230 FW(7QIOs)
mg/L
22 22
488.4
no limit
--Chronic: ----1,008.3--
--------------------------
No value > Allowable Cw
Acute NO WQS
Chlorinated Phenolic Compounds
NC
1 A(30Q2)
ug/L.
0 0
N/A
--Chr_ _ _ -----44---
n/a
--------------------------
onic:
Acute: NO WQS
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
0 0
N/A
--------------------------------------------
n/a
Chronic: 1,315.1
Acute 3,413.8
Chromium III
NC
117.7325 FW(7QIOs) 905.0818
µg/L
0 0
N/A
no limit
--Ch_ _ ---- _ _
ronic: 516 1 -----------------------------
Acute: 603
Chromium VI
NC
11 FW(7QIOs) 16
µg/L
0 0
N/A
no limit
--C_ _ _ _
hronic: -----48.2 --
--------------------_----
Chromium, Total
NC
Rg/L
1 0
NO DETECTS
no limit
IIi d U m9ka dIme� �e�Q
Max MDL = I
4987 -RPA dissolved-2016.xlsx, rpa
Page 1 of 3 4/19/2016

Marshall Steam Station
Outfall 002
NC0004987 Freshwater RPA - 95% Probability/95%
Confidence
Using Metal Translators, Qw = 11.44 MGD
Acute: 39.50
Copper (AL)
NC
7.8806 FW(7QIOs) 10.4720
ug/L
2 0
NO DETECTS
no limit
I�lotem rc
_ _ _ _ _
Chronic: ---- -- --
-------_----------_-- - --
Limited daM set
Max MDL = 5
Acute: 83.0
Cyanide
NC
5 FW(7QIOs) 22
10
ug/L
1 0
NO DETECTS
no limit
E1€fea tell
_ _ ----------------------------------------- _ _
-------
Chronic: 21.9
-------------------------
LRwked de•4m s¢¢
Max MDIL = 10
Acute: NO WQS
Fluoride
NC
1800 FW(7QIOs)
ug/L
0 0
N/A
-Ch
-ron
n/a
_ _ _ _
--- --
ic: 7,8907
- - - - - - - - - - - - - - - - - - - -------
Acute: 284.724
Lead
NC
2.9416 FW(7QIOs) 754871
ug/L
1 0
NO DETECTS
_ _
no limit
i�leteo H 9
_ _ _
Chronic: ------ --
-------------------------
Urnited da,in set
Max MDL _ I
Acute: NO WQS
Mercury
NC
12 FW(7QIOs)
0.5
ng/L
22 20
4.7
no limit
--Chronic: -----52.6 --
--------------------------
No value > Allowable Cw
Acute: NO WQS
Molybdenum
NC
2000 HH(7QIOs)
ug/L
1 1
18.4
no limit
Nate ma
D %olt C. V.
---------------------------------------------Chronic: 8,767.4
Ulnitcd d"N set
No value > Allowable Cw
Acute (FW)' 1,264.3
"
Nickel
NC
37.2313 FW(7QIOs) 335.2087
µg2
no limit---------------------------------------------
23 23
28.8
Chronic (FW): 163.2
No value > Allowable Cw
Nickel
NC
25.0000 WS(7QIOs)
µg/L
Chronic (WS) 109.6
No value > Allowable Cw
•
Acute: 211.2
Selenium
NC
5 FW(7QIOs) 56
ug/L
58 58
6.0
---------------------------------------------
no limit
Chronic:21.9
No value > Allowable Cw
Acute: 1.118
Silver (AL)
NC
0.06 FW(7QIOs) 0.2964
ug/L
1 0 NO DETECTS
no limit
No s�toa ���;1
_ _ _ ---------------------------------------
Chronic:
Lint R d data set
Max MDL = I
Acute: 474.1
Zinc (AL)
NC
126.7335 FW(7QIOs) 1257052
ug/L
58 58
43.0
---------------------------------------------
no limit
Chronic 555.6
No value > Allowable Cw
Acute: NO WQS
Aluminum
NC
87 FW(7QIOs)
µg/L
1 1
227.00000
no limit
__--_°_--
NR.edu?1
leau1tC.°�"
_ _ _ _ _
Chronic -- 381.38304-
--------_-----_-
'Urnited data set
No value > Allowable Cw
Acute: NO WQS
Boron
NC
7 WS(7Q l Os)
mg/L
1 I 0.07600
no limit
Note. it 5 9 Dal°ae�k C. .
_ _ ------------
Chronic: -30.68599 -
- --- --- - ----- - - - -
U maned de62 Oet
No value > Allowable Cw
_
Acute:
4987 -RPA dissolved-2016.xlsx, rpa'
Page 2 of 3 4/19/2016

Date: 4/19/2016
Enter data onto 'Table 1" under the Input Sheet and enter
"Effluent Hardness" under the Data Sheet.
In accordance with 40 CFR 122.45 (c ), permits are, have and
must be written as total metals.
PERMIT: NC0004987
Dissolved to Total Metal Calculator
Bn es 6 once tttY&o rgdarII R fjul .ns, g itfY d PSca&E0n?� : fsa rafts n �a� `i' VEd,)a W 0 Cifn 121451(x)
HUC = 03010103
ReceivingRecevn 9
Stream Stream
Ree Stream NPOES Total Suspended
P
Solids
Combined
Hardness
Combined
Hardness
In.,. Insiream Effluent
HUC
Wastewater Wastewater Hardness
summer summer 7010
1010 Flow tdmd -Fined Value-
chronic
Acute
rden
Hardness Median
Cancentrc) Co ccafi b) Medan
7Q10 (CFS) (MGD)
MGD MGD (mg/L)
(mg/L)
(mg/L)
Chronle) (Acute) (m92) (mg/L)
60 0000 36.7097
31.7097 11.4400 10
25.000
25 000
22 8117 26 5124 25 25
This calculator has been inserted into the RPA to calculate Total
Metal allowable allocations once Table 1 has been completed
(Input Sheet) and Effluent hardness has been entered (Data
Sheet).
1) Following the spreadsheet from left to right. First
US EPA M81"istAlf.AkA Ela.0CWMITAW
COMMENT
the allowable allocations for the dissolved metals will
appear for all the metals listed once Table 1 is complete and
Dissolved Metals
PARAMETER
Chronle Acute
Translators -using (MaEt)asaTotalMeW
Default Partition •ossslo!MeW-Tra�aW
Coefficients Chronic Acute
effluent hardness entered. Use a default value of 25 mg/L if
no hardness data is available. Second, the
u il- u n
Cadmium (d) 0.15 0.82
streams . n tion
0.252 0.59 3.24
Cd -Trout streams 0.15 _ 051
0 252 0.59 2.01
Dissolved Metal allocations are divided by the Translators to
Chromium III d)(h) 24 183
0202 117.73 905.06
Chromium VI (d) 11 16
1.000 11.00 16.00
determine the Total Metals that can be allocated to the
Chromium, Total (t)
_
N/A N/A
Permittee. These Total Metals values are automatically
inserted into Table 2 and are the allowable Total Metal
- allocations determined for the Permittee prior to allowing
Copper (d)(h) 2.7 3.6
0.348 7.88 10.47
Lead (d)(h) 0.54 14
0.184 2.94 75.49
Nickel(d)(h) 16 145
0.432 37.23 335.21
for dilution. See Input sheet Table 2. The final acute and
Ni- WS stream`s (t "
_ 25 NIA
Silver (d)(h,acute) 0.06 030
1 000 0.06 0.30
chronic values shown under the RPA sheet are the Total
Zinc (d) h 36 36
0.288 126.73 125.71
- , Metal values listed in Table 2 divided by the acute and
" 'chronic IWC, respectively.
2) - The Translators used in the freshwater RPA are the Partition
Be Ilium 6.5 65 - 1.000 6.5 65
Arsenic (d '1501 340 1.000 150 340
Coefficients published by US EPA in 1984. They are TSS
' dependent equations and can be found listed with the WQS
(d)=dissolved metal standard. See 15A NCAC 026.0211 fbrmore information
hardness dependent equations under the sheet labeled
(h)=hardness-dependent dissolved metal standard. See 15A NCAC 028.0211 formers information.
Equations. A fixed TSS value of 10 mg/L is used to calculate
the Translator values.
(t) =based upon measurement of total recoveable metal See 15A NCAC 02B.0211 for more information.
The Human Health standard for Nickel in Water Supply Streams Is 25 mg/L which is Total Recoverable metal standard.
The Human Health standard for Arsenic is 10 pg/L which Is Total Recoverable metal standard.
3) Pretreatment Facilities- PERCS will need a copy of the
Dissolved to Total Metal Calculator spreadsheet and the
RPA sheet along with the Final Permit. Pretreatment
_
Facilities are required to renew their Headwords Analysis
after renewal of their permits. Since all their metal
allocations are likely to change PERCS needs to see any new
metal permit limits and the allowable allocations for the
dissolved metals to assess Maximum Allowable Headworks
Loading (MAHL) numbers for each metal based on the
Combined Hardness values used in the permit writers RPA
calculations.
4) For Cadmium, Lead, Nickel, Chromium and Beryllium, if all
the effluent sampling data for the last three to five years
shows the pollutant at concentrations less than the Practical
Quantitative Level (PQL), it is not likely a limit or monitonng
will be put in the permit. However, if the estimated NPDES
- permit limit is less than the Practical Quantitative Limit
(particularly, Cadmium and Lead) and the pollutant is
- believed to be present, to assess compliance with the new
standards and for future permit limit development,
monitoring for the pollutant will be required. If the facility is
monitoring for the pollutant in its Pretreatment LTMP, no
monitoring is needed in the permit.
5) For monitoring and compliance purposes if Total Chromium
(Identify parameters
HUC Hard Med (mg/L) = 21.5
EFF Hard Med (mg/L) = 25

REASONABLE POTENTIAL ANALYSIS
H
Effluent Hardness (monthly average)
Use "PASTE SPECIAL
values'• tnen "COPY"
. Maximum data
points = 68
Par01
& Par02
Arsenic
Use "PASTE SPECIAL
Values" u,en' copy
. Maximum data
points - 68
Date Data BDL=1/2DL Results
Date
Data
BDL=1/2DL
Results
1
251 25 Std Dev.
N/A
1
1.9
Std Dev.
3.6847
F 1.9!
2
Mean
25.0000
2
2.51
2.5
Mean
5.4435
3
C.V.
0.0000
3
< 2
1
C.V.
0.6769
41
(
n
1
4
< 2
1
n
23
5
i
t 10% value
25.00 mg/L
5
2.2i
2.2
6
Median Value:
2500 mg/L
6
3
3
Mult Factor =
1.34
7
Max Value
25.00 mg/L
7
< 2�
1
Max. Value
14.7 ug/L
8
a
8
3.26
326
Max. Ped Cw
19.7 uglL
9
1
9
3.25
3.25
10
I
10
4.75
4.75
11
11
.
6.811
6.81
12
12
10 5j
10.5
13
j
13
7.651
765
14
14
10.5
10.5
15
I
15
11.1;
11.1
16
16
5.871
5.87
17
171
4.79
4.79
18
18
7.28J
7.28
19
!
19
14.7It
14.7'
20
{
20
5.971
5.97
21
I
21
3.41.
3.41
22
22
4.651
4.65
23
j
23
8.11
8.11
24
f
24
25
+
25
2626
27�
27
28
28
29
29
30
30
31
31
32
i
32
If
I
33
I
33
34
34
35�
35
36
I
36
37
P
37
38
i
38
39
;
39
i
40
$
40
41
' ' ' €
41
42
=
42
I
43
43
44
j
44
45
1
45
46
46
47
I
47
48
48
49
49
50
I
50
51
51
52
i
52
1
53
`
53
54
54
55
i
55
56
56
57
57
58
I
58
4987 -RPA dissolved-2016.xlsx, data
1 4/19/2016

REASONABLE POTENTIAL ANALYSIS
Par03
Use"PASTE SPECIAL
Par04
Beryllium
Values" then "COPY"
Cadmium
M
Maximum data
points = 58
Date Data BDL=1/2DL Results
Date Data
BDL=1/2DL Results
1
< 1 { 0.5 Std Dev. N/A
1
< 1'
0.5 Std Dev. N/A
2
' Mean 0.5000
2
I Mean 0.5000
3
C.V. 0.0000
3
C.V. 0.0000
4
; n 1
4
n 1
5
5
6
Mult Factor = 1.00
6
Mult Factor = 1.00
7
, ' i Max. Value 0.50 ug/L
7
Max Value 0.500 ug/L
8
Max. Fred Cw O DETECTS ug/L
8
i Max. Fred Cw O DETECTS ug/L
9
10'
I
9
10
!
11
9
11
12
12
t
13
t
14
15
R
14€
15i
9
16�
16
17
17
18
•
18
3
i
19
19
20
20
21
A
21
22
22
23
23
l
241
j
24
25
I
25`
26
261
27
27
28
28
29
I
29
301
j
30
31
31
32
32
33
`
33
34
34
35
35
36
36
}
37
37
38
38
i{
r
39
39
40
401
41j....
j
!
41i
42
_
42
43
_ -
431
1
44
441
45
45
461
461
47
i
47
48
48
49
•
49
50
I
50
51
51
52
52
53
. I
53
54
54
55
?
55
56
)
56
57
57
58
t
58
4987 -RPA dissolved-2016.xlsx, data
- 2 - 4/19/2016

REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved -2016 xlsx, data
- 3 - 4/19/2016
Par05
Par06
usa " PASTE SPECIAL-
use "PASTE S
Chlorides
(AL) Values"t's., P..
Chlorinated
Phenolic Compounds Values"then"
Maximum data points =
. Maximum
H
points
Date Data
BDL=1/2DL Results
Date Data
BDL=1/2DL Results
1
300 Std Dev. 61.6950
1
Std Dev. NO DATA
(� 306
2
300
300 Mean 285.9
2
Mean NO DATA
3
350
350 C.V. 0.2158
3
C.V. NO DATA
4
380
380 n 22
4
n 0
5
240
240
5
6
440
440 Mult Factor = 1.1
6
Mult Factor = N/A
7
240
240 Max. Value 440.0 mg/L
7
Max. Value N/A
8
270
270 Max. Fred Cw 488.4 mg/L
8
Max. Fred Cw N/A
9
310
310
9
10
350
350
10
11
290
290
11
12
190
190
12
13
270
270
13
-
14
300
300
14
15
290
290
15
16
280
280
16
17
220
220
17
18
170
170
18
19
300
300
19
20
210
210
20
21
290
290
21
22
300
300
22
23
23
24
24
25
25
26
26
27
27
28
28
29
29
30
30
31
31
32
32
33
33
34
34
35
35
36
36
37
37
38
'
38
39
39
401
40
41
41
42
42
43
43
44
44
45
45
46
46
47
47
48111111
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
58
4987 -RPA dissolved -2016 xlsx, data
- 3 - 4/19/2016

REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved-2016.xlsx, data
- 4 - 4/19/2016
Par07
Par08
ECIAL
use "PASTE SPECIAL
use"PASTE S
OPY"
Total Phenolic
Values" then "COPY"
Compounds
Chromium III
Values" then "
e
ata
Maximum data
Max, n
points =
E
points - 58
1
Date Data
BDL=1/2DL Results
Std Dev. NO DATA
1
Date Data BDL=1/2DL • Results
Std Dev. NO DATA
2
Mean NO DATA
2
Mean NO DATA
3
C.V. NO DATA
3
j C.V. NO DATA
4
n 0
4
n 0
5
5•
6
MultFactor= N/A
6'
MultFactor= N/A
ug/L
7
Max. Value N/A ug/L
7
Max. Value N/A
ug/L
8
Max. Pred Cw N/A ug/L
8
Max. Fred Cw N/A
9
91
10
10
11
11
12
12
13
13
., d
14
14
15
15
16
16
I
17
171j
18
18!
!
19
1911
20
20'
21
21
22
22
23
23
24
25
24�
25,
i
26
26+
5
27
27�
28
29
28
29,
I
30
30
31
31
32
32
I
33
33
t
34
34�
I
-35
35
36
36
37
37�
38
38
'
39
39.
1
40
40
I
41
41
42,
42
43
43
44
44�
j
45
451
I
46
46j
47
47i
48
48
49
49
50
501
51
51
52
52
53
53
54
54
55
55
56
56
57
57
i1
p
58
58
I
4987 -RPA dissolved-2016.xlsx, data
- 4 - 4/19/2016

J
Z
J
a_
F -
z
LU
a.
w
J
m
Q
Z
O
a
w
w
OpO Omz'-
O O O m (FUI❑-q
p
nO
0 0
LU-
Q
O
IIU
oma
>U N
r (L)w > a`
C)G _
ycts
! N
w
N :5N
O
❑ o
�_
II
E
❑
o
d
L
r
r N co V O h co (A O r N co CO I- CO O O N M V lO (0 r,, -W (A O N M V l0 (0 I� N C O N M V tO (0 I, W (P O N M V LL7 (O W
C. M 0 M rM
@
a
r r r r r r r r r N N N N N N N N N N M M M M M M M M M M V V V V V V V V V lO til M
J
a
L)
r J J
0.V
=L=L
N
= E u O ¢_
W
°N Z Z Z Q
Q Q
FF -F
>
> Z Z Z
I I U
Z5ma
N > U 6
w ay M> a
�❑
U)
=mm
id,>.
>
J
E o
E
m
U
—
m
m
❑
C
i
0
r N M V L0 0 r� W CA ON M V UO 0 1` W O O N M C0 0 h M M O N M V W CO h N M O N M V 0 0 f- W
r r rrrr r .- r r N N N N N N N N N N M �7 M M M M M M M M V V Vv V Vv V V V to LO � LO LO� LO LO
a
J
Q
U
Y
Q
J J
O7m
1 1

V:
co
J
Q
z
a
J
a_
H
z
W
r
O
CL
LU
MJ
W
Q
O
Q
W
w
(n
C E��
O 0—
O O (n
w
o
E
m O oo
c o
0� U
r
W
>>
z
p
II U
O
>
j -p
U(m d
N
-•
LL > a
v
m
as
J to
N
�
c0
J
Uin
in
Ir
'
M 'Ir u� m 1- m m O N M V' m m 1.- m m 0 N M -t U[ m Ih m m 0 N M 'V• to m 1- m
a
r r r r r r r r r r N N N N N N N N N N M M M M M M M M M M V V' 'V V' V V v R VLo m m m ul u7 Lo o
J
Q
:
Y
J J
>
G O O N
O LO F
W
r
((
N 0
y£ o 0 o
c O u� O
r N U
2
m x a O N O
LU
F,
W
_>
o
II U
O
u) j
� U
Uc9 N
a)c
li > a`
3
ai -o >.
3 m m
a1°i
65 c
J
J u� LO
Q
cV cV
L
�
_
a
o
v v
d
o,
�r
r
N co V uJ m lh m O 0 (N co -T u7 m 1- m m 0 N co 'V• Lo in 1` m O] O N M Vu') m 1- m W 0 N CO 'V' Lo m h m
R
rr rrrr rrrrNNNNN NNNNNM MMMMMMMMM V' Vad' V''V' V'V''V VLf) Lo un LoLf) ur LO u!
a
J_T>
J_RL
UO�
m m
m0
� N
N W
X
m
N
N
0
m
a
Q
a
n
C')
V

REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved-2016.xlsx, data
- 7 - 4/19/2016
Par13
Par14
ECIAL
Use "PASTE SPECIAL
Use "PASTE S
OPY"
Fluoride
Values" then "COPY"
Lead
Vaiues"then "
ata
. Maximum data
. Maximum
8
points = 58
points =
1
Date Data
BDL=1/2DL Results
Std Dev. NO DATA
1F
Date Data BDL=1/2DL Results
—y— < 11 0.5 Std Dev. N/A
2
Mean NO DATA
2I
1 Mean 0.5000
3
C.V. NO DATA
3!
C.V. 00000
4
n 0
4i
n 1
5
5
6
Mult Factor = N/A
6
Y Mult Factor = 1.00
ug/L
7
Max. Value N/A ug/L
7
1 Max. Value 0.500
ug/L
8
Max. Fred Cw N/A ug/L
8!
Max. Fred Cw O DETECTS
8
8
10
101
11
11
12
12
13
13
14
14
15
15
16
17
16+
17�
1
18
181
19
191
20
20I
21
21
22
22
23
23�
24
24
25
25
4
26
26
iii i
27
27
b
28
28
r
29
29
!
30
30
31
31
32
32
33
33
1
34
34
35
35
36
36
37
37
38
38
39
39
j
40
40
41
41
'
42
42
' 1
43
43
44
44
4
45
45
j
46
46
47
47
Y
48
48
49
49
i
50
50
51
51
52
52
53
53
j
54
54
I
55
55
56
56
57
57
f
58L
58+
4987 -RPA dissolved-2016.xlsx, data
- 7 - 4/19/2016

REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved-2016.xisx, data
- 8 - 4/19/2016
Par15
Par16
ECIAL
Use"PASTES
OPY"
Mercury
M
Molybdenum
Values" thenata
Maximum
points -
1
Date
Data
BDL=1/2DL
0.992
ResultsDate
Std Dev.
0.9299
1
Data BDL=1/2DL
18.471i 18.4
Results
Std Dev.
NIA
0.992
2
1.46
1.46
Mean
1.4203
2
4
Mean
18.4000
3
0.955
0.955
C.V.
0.6547
3
C.V.
0.0000
4
1.18
1.18
n
22
4
n
1
5
1.52
1.52
5
6
3.25
3.25
Mult Factor =
1.35
6
Mult Factor =
1.00
ug/L
7
3.51
3.51
Max. Value
3.5 ng/L
7
Max. Value
18.4
ug/L
8
1.17
1.17
Max. Pred Cw
4.7 ng/L
8
Max. Pred Cw
18.4
9
2.82
2.82
9
j
10
1.26
1.26
10
11
3.13
3.13
11
12
1.951
1.95
12
13
`°
0.864y
0.864
13
14
0.8951
0.895
14
,
15
0 929
0 929
15
16
0.953?
0.953
161
17
0.766
0.766
17
18
1.01,
1 01
18
19
0.852
0.852
19
i
20
< 0.5
0.25
20
21
1.28
1.28
21
22
< 0.5
0.25
22
23
23
24
24
25
25
26
26
p
27
27
{
28
28
j
29
29
30
30
I
31
31
32
32
j
33
33
34
34
35
35
36
36
37
37
38
38
i
39
39
1
40
i
40
41
41
42
42
43
43
44
44
45
45
46
46
47
47
48
48
49
49
i
50
50
51
51
PPf
52
52
53
53
54
54
55
55
1t
56
56
1
57
571
58
58I
4987 -RPA dissolved-2016.xisx, data
- 8 - 4/19/2016

REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved-2016.xlsx, data
- 9 - 4/19/2016
Par17 & Par18
Par19
ECIAL
Use "PASTE SPECIAL
oPY"
Nickel
Values" then "COPY"
Selenium
ata
, Maximum data
8
1
Date
Data
BDL=1/2DL
15.2
Results
Std Dev.
points = 58
5.0664
1-�
Date
Data
3.93
BDL=1/2DL
3.93
Results
Std Dev.
15-2
2
14.7
14.7
Mean
11.8452
2
3.17'
317
Mean
3
23.6
23.6
C.V.
0.4277
3
3.52,
352
C.V.
4
21.9
21.9
n
23
4
3.211
3.21
n
5
16.2
16.2
5
3.191
3.19
6
16.3
16.3
Mult Factor =
1.22
6
3.331
3.33
Mult Factor =
ug/L
7
12.7
12.7
Max. Value
23.6 Ng/L
71
3.31
3.3
Max. Value
ug/L
8
12.3
12.3
Max. Pred Cw
28.8 pg/L
8!
2.73
2.73
Max. Fred Cw
9
13.9
13.9
91
2.58.
2.58
10
13.4
13.4
10,
3.13;
3.13
11
15.9
15.9
111
3.321
3.32
12
8.5
8.45
121
2.6,41
264
13
12.9
12.9
13
t
3.07'
3.07
14
6.2
622
14
2 55
2.55
15
8.1
8.07
15
2.51:
2.51
16
8.3
8.28
16
2.04;
2.04
17
8.4
8.42
17
2.92+
2.92
18
9.91
9.88
18
2.79'
2.79
19
4.6I
4.61
19�
3.12,
3.12
20
4.7
4.67
20
2.71E
2.71
21
5.5
5.46
211
2.361
2.36
22
8.6
8.58
22
2.64
2.64
23
10.8
10.8
23
2.661
2.66
24
24
2.93;
2.93
25
25
2.741
2.74
26
26
2.46
2.46
27
27
2.621
2.62
28
28
2.211
221
29
29
1.871
1.87
30
30
1.871
1.87
31
31
1.94
1.94
32
32
2.381
2.38
33
33
2.26
2.26
34
34
3.21!
3.21
35
35
2.431
2.43
36
36
2.611
2.61
37
37
2.31
2.3
38
38
3.63
3.63
39
-
39
4.91,
4.91
40
401
4.511
4.51
41
41
4.731
4.73
42
42
4.36!
4.36
43
43
4.571
457
44
44
4.981
4.98
45
45
5.25
5.2
46
46
5.331
5.33
47
47
5.87,
5.87
48
48
5.56
5.56
49
49
6.041
6.04
50
50
4.23'
4.23
51
51
4.11
4.1
52
52
4.26;
4.26
53
53
3.35!
3.35
54
54
2.68
2.68
55
55
2.76
2.76
56
56
3.37
3.37 '
57
57
2.85
2.85
58
58
3.18;
3.18
4987 -RPA dissolved-2016.xlsx, data
- 9 - 4/19/2016

REASONABLE POTENTIAL ANALYSIS
Use"PASTE SPECIAL
Values" then "COPY" . Maximum data
points = 68
Par20
1
Date Data
$IIV2C (AL)
BDL=1/2DL ResultsDate
M
0.5 Std Dev. N/A
Par'21
1
Data
Zinc (AL)
BDL=1/2DL Results
37.6 Std Dev.
1.0437
< 1
37.6
3.3055
2
Mean 0.5000
2
'25.3
25.3 Mean
0.3157
3
C.V. 0.0000
3
26.8
26.8 C.V.
58
4
n 1
4
40.8
40.8 n
5
5
38
38
1.00
6
Mult Factor = 1.00
6
23.1
23.1 Mult Factor =
6.0 ug/L
7
Max. Value 0.500 ug/L
7
43
43 Max. Value
6.0 ug/L
8
Max. Pred Cw O DETECTS ug/L
8
29.5
29.5 Max. Pred Cw
9
9
17.1
17.1
10
10
15.8
168
11
11
16
16
12
12
8.3
8.3
13
13,x.`
28.8
28.8
14�
14
- 11
17.1
151
15
„ `9.2
9.2
16
16
14
14
17
17
15.8
15.8
18
18
12.4
12.4
19
19
21.2
21.2
20
20
11.9
11.9
21
21
.10 .9
10.9
22
22
9.05
9.05
23
23
11.4
11.4
24
24
10.7
10.7
25
25
14
14
26
26
17.8
17.8
27
27
13.1
13.1
28
28
10_.8
10.8
29
29
14
14
30
30
521
5.21
31
31
10.7
10.7
32
32
2.35
2.35
33
33
3,75
3.75
34
34
4.4
4.4
35
35
3.02
3.02
36
36
12.5
12.5
37
37
4.74
4.74
38
38,
4.41
4.41
39
39
9.18
9.18
40
40
A1.7
11.7
41
-,
41
162
16.2
42
42
.17.3
17.3
43
-
43`
-12 1
12.1
44
44
"6:28
6.28
45
.
45
1.58
1.58
46
46
2
2
47
47
3,42
3.42
48
48
'3.84
3.84
49
49
1 1.6
1.6
50
50
8:11
8.11
51
51
10.7
10.7
52
52
-11.5
11.5
53
53
.9.48
9.48
54
54
10.8
10.8
55
55
16.8
16.8
56
56
10.3
10.3
57
57
14
14
58
58
3.19
3.19
4987 -RPA dissolved-2016.xlsx, data
10- 4/19/2016

T
a
z
a
J
a
z
W
F-
0
CL
W
J
m
a
z
♦O♦/�
v♦
NW
w
�o
� N
X
N r
X
0
N
N
0
w
An
=o
n
co
v
J(D
C
0 ^ O
0
r O
O
!�
m
❑
[D
e
p�
m
p
M
r N M V (D (O I, M m O N M O O N M V (O (O N O O N M V UD (D h O Q) O N M V (O co W
a
(O (D (O (n (n (D (O
N N N N N N N N N N N N N N N M M M M M M M m M M co V �• V V V V V V V V (O Lr) LO
aS= JJ
lo) O7 o)
=Ls
a v 9 N
(q CE (( O O r O O O
LwLl o0 000
oo roo
a v m Q o 0
C-4
G Q N N N
7 J Z N N
u U
o
'o
W LL a`
❑ c
y -o � m m
ami>.
�c
E J N
N
E J
7 p
Q m
cc
N t
d
m
N
`
r N M V (1D (D h aD 0 O N M V (O (O I� O O) O N M V (O (O h CD O O N M V (() (D h O M O N M V (n (D r aO m O N M V M M I� OD
CL
r r r r r r r r r N N N N N N N N N N M M M M M M CO M M M V V V V V V V V V V (n (n (o (O (O (O LLD LL) LLD
U
0
M o)
a n
7
V h
Vi C E n
V N M Co o o o
LLf G y
(D O V (f) O M M
co cDF-
t E c
Io cD h 'T V
a y x a
W O
G
=
G
y >
�o
� N
X
N r
X
0
N
N
0
w
An
=o
n
co
v

REASONABLE POTENTIAL ANALYSIS
ResultsDate
m
Std Dev. N/A
Paf24
1
Data _
-�u
Use "PASTE SPECIAL
0 Values" then "COPY"
BDL=1/2DL Results
Std Dev. NO DATA
Par25
1
Date Data
U
BDL=1/2DL
Mean 0.0760
2
Mean NO DATA
2
C.V. 0.0000
3
C.V. NO DATA
3
n 1
4
n 0
4
5
5
Mult Factor = 1.00
6
" '
Mult Factor = N/A
6
Max. Value 0.076000 mg/L
7
Max. Value N/A
7
,
Max. Pred Cw 0.076000 mg/L
8
Max. Pred Cw N/A
8
9
9
10
10
11
11
12
12
13
_;
13`
_
14
"-_
14
15
15_
16
16
17
17
18
18
`
19
19
20
20
21
21
22
22
23
23
24
24
25
25
26
26
27
27
28
28
29
29'
30
30
31
31
32
32
33,
33
34
34
35
35
•
36
"
36
37
37
38
38
39
I
39
40
{p
40
,
41
fl
41
.
42
42
43
43
44
-
44
45
45
46
46
47
47
48
48
`
49
49
50
50
51
51
52
52
53
53,
"
54
54
55
55
56
56
57''"
57
58
'58
4987 -RPA dissolved-2016.xlsx, data
-12- 4/19/2016

Results �-
Std Dev. NO DATA
Mean NO DATA
C.V. NO DATA
n 0
Mult Factor = N/A
Max. Value N/A
Max. Pred Cw N/A
REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved-2016.xlsx, data
13- 4/19/2016

'Marshall Steam Station
NC0004987 Freshwater RPA - 95% Probability/95% Confidenc Using Metal Translators
MAXIMUM DATA POINTS = 5
Qw (MGD) = 1.00 WWTP/WTP Class: I
1Q10S (cfs)= 49.15 IWC% @ 1Q10S = 3.057199211
7Q10S (cfs) = 60.00 IWC% @ 7Q10S = 2.518277823
7Q10W (cfs) = 60.00 IWC% @ 7Q10W = 2.518277823
30Q2 (cfs) = 60.00 IWC% @ 30Q2 = 2.518277823
Avg. Stream Flow, QA (cfs) = 60.00 IW%C @ QA = 2.518277823
Receiving Stream: Lake Norman HUC 03010103 Stream Class: WS -IV
Outfall 002 dewatering
Qw = 1 MGD
COMBINED HARDNESS (mg/L)
Acute = 25 mg/L
Chromic = 25 mg/L
YOU HAVE DESIGNATED THIS RECOWNG
STREAM AS WATER SUPPLY
Effluent Hard:0 va9 > 100 mg/L 0 va9 < 25 mg/L
Effluent Hard Med = 25 mg/L
PARAMETER
STANDARDS & CRITERIA (2)
U)
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
(1)
�
oa.
f-
Z
NC WQS / Applied %z FAV /
D
n # Det Max Pred Cw Allowable Cw
Chronic Standard Acute
Acute (FW): 11,121.3
Arsenic
C
150 FW(7QIOs) 340
ug/L
add limit
1 1
3,560.0
------------------
Chronic (FW) 5,956.5
_ --------
DoWtC.V.
N_ov_alue>_Allow_able_Cw
Arsenic
C
10 HH/WS(Qavg)
ug/L
MAI-: oa S 9
------
Chronic (HH)_397.1
-------------------------
IL wvlited data, set
I values > Allowable Cw
Acute. 2,126.13
".
Beryllium
NC
6.5 FW(7QIOs) 65
ug/L
0 0
N/A
--Ch _ _ -----— _ --
Na
— — ----------------------
ronic: ] 1
Acute: 105.967
Cadmium
NC
0.5899 FW(7QIOs) 3.2396
ug/L
1 0 NO DETECTS
no limit
Nato- a S 9
___ _ ---_ _ ___
Chronic: 23.424
__........................
Umlkd datm mi
Max MDL = 1
Acute- NO WQS
no limit
Chlorides (AL)
NC
230 FW(7QIOs)
mg/L
1 1
288.0
— —
— — — --- — — — — — ----
Note: R5 9
I':&U➢tC.V.
Chronic: 9,133.2
—
Llmkcd data sed
No value > Allowable Cw
Acute: NO WQS
Chlorinated Phenolic Compounds
NC
1 A(30Q2)
ug/L
0 0
N/A
_ _ _ _ _
--Chronic -----39.7 --
Na
--, -------------- ---------
Acute: NO WQS
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
0 0
N/A
--------------------------------------------
Na
Chronic: 11
Acute: 29,604.9
Chromium III
NC
117.7325 FW(7QIOs) 905.0818
gg/L
0 0
N/A
no limit
---------------------------------------------
Chronic: 4,675.1
Acute: 523.4
Chromium VI
NC
1 I FW(7QIOs) 16
µg/L
0 0
N/A
no limit
_ _ _ _
--Chron----436.8 --
Chronic:
— ,------- ------=------- —
Chromium, Total
NC
gg/L
1 0
NO DETECTS
no limit
1 gfilQ
Max MDI. = I
4987 -RPA dissolved dewaterring 1-2016, rpa
Page 1 of 3 4/21/2016

Marshall Steam Station
Outfall 002 dewatering
N00004987 Freshwater RPA, 95% Probability/95%
Confidence
Using Metal Translators Qw =I MGD
Acute: 342.54
Copper (AL)
NC
7.8806 FW(7QIOs) 10.4720
ug/L
1 1
1.99
no limit
Note: m a
De �ufluC.
_ _ _ _ _
Chronic: ------- --
----_---------------------
Lamitecl data set
No value > Allowable Cw
'
Acute. 719.6
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L,
0 0
N/A
n/a
-Chr_ _ _
—onic: ---- 198.5 _ --
—; ------------------------
I
Acute: NO WQS
Fluoride
NC
1800 FW(7QIOs)
ug/L
1 1 2.8
m-
nidd�
Ne�Crea m:59 i eLaaaHtC.�1.
_ _ _ _ _ _ _
Chronic --- 71--- —
,477.4
------------------ . ------
➢Lirniked data set
No value > Allowable Cw
Acute' 2,469.159
Lead
NC
2.9416 FW(7QIOs) 75.4871
ug/L
1 0 NO DETECTS
no limit
i�te°da�9
_ _ _ _ _ _ _
Chronic: --- 116.811--
-----------------,---------
Lfmhtd daati set
Max MDL =1
'.
Acute. NO WQS
Mercury
NC
12 FW(7QIOs)
0.5
ng/L
1 1 2.0
no limit
Noteea 5 Tai u1dC.9.
_ _ _ _ _ _
Chronic. ---- -- --
--------------- ----------
IL„iaamkkl AxLsa sat
No value > Allowable Cw
Acute: NO WQS
Molybdenum
NC
2000 HH(7QIOs)
ug/L
11 854.0
no limit
Notv. u 97, I�o'iaa ft C.
_ _ _ _ _ _
Chronic: --- 79--- —
,419.4
------_-------------------
1,hrafta'd data set
No value > Allowable Cw
Acute (FW): 10,964.6
Nickel
NC
37.2313 FW(7QIOs) 335.2087
µ
--------------------
no limitg/L
1 1
14.8
Chronic (FW) 1,478.4
Note- n 5 9
1Default C.V.
No value > Allowable Cw
Nickel
NC
25.0000 WS(7QIOs)
itg/L
Lbmfted datm set
Chronic (WS) 9927
--------------
__Nickel
No value > Allowable Cw
Acute: 1,8317
Selenium
NC
5 FW(7QIOs) 56
ug/L
1 1
32
no limit
Note. aa53
Lc sit CIV.
_ _ _ _ _
Chronic: ----198.5 --
_-=-----------------------
_Laniteal data sel
No value > Aflowable Cw
Acute: 9.695
Silver (AL)
NC
0.06 FW(7QIOs) 0.2964
ug/L
0 0
N/A
n/a
_ _ _ _
--Chronic: ----2.383 --
— .------------------------
Acute: 4,111.8
Zinc (AL)
NC
126.7335 FW(7QIOs) 125.7052
ug/L
1 1 50.0
no limit
laata, �9 T etraaaaBC.n�.
_ _
Chronic: 5,— --- - --
-----------------c-------
um, Red dam set
No value > Allowable Cw
Acute: NO WQS
no limit
Aluminum
NC
87 FW(7Q10s)
µg/L
1 1 810.00000
Note. a59 DefauitC.V.
_ _ _ _ _ _ _
Chronic: — 3454.74194
— ----------------- --- _ — -----
Limited data set
No value > Allowable Cw
Acute: NO WQS
Boron
NC
7 WS(7Q10s)
mg/L
1 1 6.27000
no limit
�I'oge'tm� WzjiltC.V.
_ _ _ _
Chronic: — 2-7-7-69 .7_74
—------- ----- --- — — —
Lf wiled data set
No value> Allowable Cw
Acute: NO WQS_
" ��-
4987-RPA dissolved dewaterring 1-2016, rpa v
Page 2 of 3 4/21/2016

Marshall Steam Station
Outfall 002 dewatering
N000049B7 Freshwater RPA - 95% Probability/95%
Confidence Using Metal
Translators Qw =I MGD
Sulfate NC 250 WS(7Q10s)
mg/L 1 1 149.00000
r7
Note.. R � 9 Defao1ft C.V.
I
_ _ _ _ _ _ _ —_
Chronic: -- 2382.58065 ,�--
Ln�iaited �la4aset
Novalue > Allowable Cw
Acute: NO WQS
Barium
NC 1 WS(7Q10s)
mg/L
1 1 0.49800
no limit
N�Oyoeta 6 abMiflC.�°,
_ _ _ _ _ _
Chronic: 39.70968------- ---------------=— -------
Limited data set
No value > Allowable Cw
4987 -RPA dissolved dewaterring 1-2016, rpa
Page 3 of 3 4/21/2016

Marshall Steam Station Outfall 002 dewateTing
NC0004987 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Ow =I MGD
4987 -RPA dissolved dewaterring 2-2016, rpa
Page 2 of 3 4/21/2016
Acute: 342.54
Copper (AL)
NC
7.8806 FW(7QI0s) 10.4720
ug/L
1 1 1.99
----------------------------------------
no limit •
Notc. 'A �5 9 DuFault C,V,
Chronic: 312.94
UnAted datzi sat
No value > Allowable Cw
Acute: 719.6
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
0 0
N/A
n/a
- 198.5 -------------
—Chronic: --
------ ------------------- -
Acute: NO WQS
Fluoride
NC
1800 FW(7QI0s)
ug/L
1 1
2.8
n/a
Note: 11 :5 9
Dafault C.V.
---------------------------------------------
Chronic: 71,477.4
Uniftd data aeg
No value > Allowable Cw
Acute: 2,469.159
Lead
NC
2.9416 FW(7Q I Os) 75.4871
ug/L
1 0
1 NO DETECTS
no limit
No min 9
te- 5
Ei- 7 - - - - - 1 - -----
Chronic: 1
- ---_------- -_---- - -
LhuWA do'sa gat
Max MDL = I
Acute: NO WQS
Mercury
NC
12 FW(7QI0s)
0.5
ng/L
I 1
2.0
no limit
Note'. 115 9
Default C.V.
___ ------- ----------------------------------
Chronic: 476.5
Limited &'At'4 set
No value > Allowable Cw
Acute: NO WQS
Molybdenum
NC
2000 HH(7QI0s)
ug/L
1 854.0
�,
no limit
Note: rXI<— 9 N,jq'Uj� C.V.
--�W-7
Chronic: 79,419.4
LlffdkiA 612 su.
No value > Allowable Cw
Acute (FW): 10,964.6
Nickel
NC
37.2313 FW(7QI0s) 3352087
gg/L
no limit
1 1
14.8
---------------------------------------------
Chronic (FW): 1,478.4
Note. H 5 9
Ddznh C.V.
No value > Allowable Cw
Nickel
NC
25.0000 WS(7QI0s)
l.Lg/l,
Umfted dataset
-------------------------------
Chronic (WS): 992.7
No value > Allowable Cw
Acute: 1,831.7
Selenium
NC
5 FW(7QI0s) 56
ug/L
1 1
-,J.2
-------------------
no limit
----------
Note. H Z 9
Ddamlt C.V.
Chronic: 198.5
--------------
Limfted data ati
No value > Allowable Cw
Acute: 9.695
Silver (AL)
NC
0.06 FW(7QI0s) 0.2964
ug/L
0 0
N/A
n/a
---------------------------------------------
Chronic: 2.383
Acute: 4,111.8
Zinc (AL)
NC
126.7335 FW(7QI0s) 125.7052
ug/L
1 1 50.0
no limit
Hoqc'o �'C:5 ,V
C�.
---------------------------------
Chronic: -032.5
um ked dMtR Wt
No value > Allowable Cw
Acute: NO WQS
Antimony
NC
56 WS(7QI0s)
gg/L
1 0
1 NO DETECTS
-6�ronic:
no limit
Hoc, �R- ID!5 9
-7 7
i237419
UYmWddmft oot
IMax MDL = I
Acute: NO WQS
Thallium
NC
0.24 WS(7QI0s)
gg/L
I 1 1 0.82800
no limit
C.V.
— - -------------------------------
Chronic:
Eonic: — —53032
R;Jlmftt(20�@ na
No value > Allowable Cw
1
Acute:
4987 -RPA dissolved dewaterring 2-2016, rpa
Page 2 of 3 4/21/2016

Date: 4/21/2016
Enter data onto 'Table 1" under the Input Sheet and enter
"Effluent Hardness" under the Data Sheet.
In accordance with 40 CFR 122.45 (c), permits are, have and
must be written as total metals.
This calculator has been inserted into the RPA to calculate Total
Metal allowable allocations once Table 1 has been completed
(Input Sheet) and Effluent hardness has been entered (Data
Sheet).
1) Following the spreadsheet from left to right. First
the allowable allocations for the dissolved metals will
appear for all the metals listed once Table 1 is complete and
effluent hardness entered. Use a default value of 25 mg/L if
no hardness data is available. Second, the
Dissolved Metal allocations are divided by the Translators to
determine the Total Metals that can be allocated to the
Permittee. These Total Metals values are automatically
Inserted into Table 2 and are the allowable Total Metal
allocations determined for the Permittee prior to allowing
for dilution. See Input sheet Table 2. The final acute`and
chronic values shown under the RPA sheet are the Total
Metal values listed in Table 2 divided by the acute and
chronic IWC, respectively.
2) The Translators used in the freshwater RPA are the Partition
Coefficients published by US EPA in 1984. They are TSS
dependent equations and can be found listed with the WQS
.hardness dependent equations underthe sheet labeled
Equations. A fixed TSS value of 10 mg/L is used to calculate
the Translator values.
3) PretreatmentFacilities—PERCS will need a copy ofthe
Dissolved to Total Metal Calculator spreadsheet and the
RPA sheet along with the Final Permit. Pretreatment
Facilities are required to renew their Headwords Analysis
after renewal of their permits. Since all their metal
allocations are likely to change PERCS needs to see any new
metal permit limits and the allowable allocations for the
dissolved metals to assess Maximum Allowable Headworks
Loading (MAHL) numbers for each metal based on the
Combined Hardness values used in the permit writers RPA
calculations.
4) For Cadmium, Lead, Nickel, Chromium and Beryllium, if all
the effluent sampling data for the last three to five years
shows the pollutant at concentrations less than the Practical
Quantitative Level (PQL), it is not likely a limit or monitoring
will be put in the permit. However, if the estimated NPDES
permit limit is less than the Practical Quantitative Limit
(particularly, Cadmium and Lead) and the pollutant is
believed to be present, to assess compliance with the new
standards and forfuture permit limit development,
monitoring for the pollutant will be required. If the facility is
monitoring for the pollutant in its Pretreatment LTMP, no
monitoring is needed in the permit.
5) For monitoring and compliance purposes ifTotal Chromium
FACILITY: Marshall Steam Station
NPDES PERMIT: NC0004987
Dissolved to Total Metal Calculator
90 R�gw7i fm1 Fa 8 WMA b@ c', 4mon �Pg U@3l vwt3b PW Q CR 1=444)
Receiving ��Recl­,I
Stream
summer
7Q10 (CFS)
Sbeam
summer 7010
(MGD)
Rec. Stream
1010
rMGDj
NPDES Total Suspended
Solitls
Flaw Lm"
-Fixed Value-
FMGDI
Combined
Hardness
chronic -
Combined
Hardness
Acute
60 0000
38 7097
317097
1.0000 10
25 000
25 000
US EPA
u..AtvsBI. EllhrengCooankatxn
COMMENTS (identify pan
Dlae)lved Metals
Tronsiators-using
4c) m a Tatel Petit
PARAMETER
Default Partition
-O�aalved Meral.Tradl xcr
_ChremC..
Acute
Coefficients
Chronic Acute
(d) = dissolved metal standard. See 15A NCAC 02B.0211 for more information.
(h) = hardness -dependent dissolved metal standard. See 15A NCAC 02B.0211 for more information.
(t) = based upon measurement of total recoveable metal. See 15A NCAC 02B.0211 for more Information.
The Human Health standard for Nickel in Water Supply Streams is 25 mg/L which is Tota) Recoverable metal standard.
The Human Health standard for Arsenic Is 10 pg/L which Is Total Recoverable metal standard.
Instream Instream Effluent
8 digit HUC
Concentration
Wastexatio Hardness
Hardness Medan
C(Chronic) Concentration (mom) Medmn
(chronic) (A.A.) (mgrL)
1Ut: Hard Med (mg/L) = 21.1
EFF Hard Med (md/L) = 25

REASONABLE POTENTIAL ANALYSIS
H
Use "PASTE SPECIAL
Effluent Hardness (monthly "at ues"then". Maximum data COPY"
points = 58
Par01
& Par02
Use "PASTE SPECIAL
values"then"COPY"
Arsenic Maximum data
.
points = 68
Date Data BDL=1/2DL Results
Date Data
BDL=1/2DL Results
11
25y� 25 Sid Dev. N/A
m 3560
3560 Sid Dev. N/A
25.0000
2
560.0000
3
9 C.V. 0.0000
3
�! C.V. 0.0000
4
n 1
4
I n 1
5
; 10% value 25.00 mg/L
5
6
Median Value; 25.00 mg/L
6
Mult Factor = 1.00
7
Max. Value 25.00 mg/L
7
. a ".
Max. Value 3560.0 ug/L
8'
8
Max. Fred Cw 3560.0 ug/L
9
i
9
10
!
10
11
11
12
12
13
13,
. .
14
a
14
15
;
15
16i
16
II
171
17
I
181
��
18
191
19
20
20
21
21
j
22
22
•
j
23
23
24
24
25
25
26
26
27
a
27
`
28
28
29
29
'
f
301
.
30
31�
I
31
32
32
33
;
33
_° • ,
34
34
35
35
,
36
36`
37
37
,.
38
38
39
39
40
40
41
",
41
42
w
42
43
i
43
i
44
44
i
45
451
46
.
46
i
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
57
g
56i
57
58
58
L� '
4987 -RPA dissolved dewaterring 1-2016, data
1 - 4/21/2016

REASONABLE POTENTIAL ANALYSIS
Par03
Use"PASTE SPECIAL
Values" then "COPY"
Beryllium Maximum data
points - 58
Par04
Use"PASTE SPECIAL
Values" then "COPY"
Cadmium Maximum data
points = 58
Date Data BDL=1/2DL Results
Date Data
BDL=1/2DL Results
1
• - Std Dev. NO DATA
1
0.5 Std Dev N/A
< f
2
Mean NO DATA
2
-
Mean 0.5000
3
1 C.V. NO DATA
3
C.V. 0.0000
4
n 0
4
n 1
5
5
6
Mult Factor = NIA
6
Mult Factor = 1.00
7
Max. Value NIA ug/L
7
°: -
I Max. Value 0.500 ug/L
8
Max. Pred Cw N/A ug/L
8
I Max. Pred Cw O DETECTS ug/L
9
9
10
10
11
11
12
12
13
13
14
14
15
15
'
16
f
16
17
i
171
}
18
18;
1
19
{
19"
20
20
21
21
22
!!!
22
. • ,
23
23
.
24{j
24
25j
i
25
1
26i
26
27
27
28
28
29
29
30
311
31
}
32
32
33
33
34.
34
35
_ ` ' j'
35
Jy
36
i
36
37
i
37
I
38
38
39
39
_
40
40
41
41
"
42
42
43
43
44
44
45
45
i
'
46
46
47
I
47
48
48
49
49
I
50
50
51
51
52
52
.? ;
53
53
54
54
55
55
56
56
'
57
.
57
..
58
58
4987 -RPA dissolved dewaterring 1-2016, data
- 2 - 4/21/2016

REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved dewaterring 1-2016, data
- 3 - 4/21/2016
Paf05
Par08
Use "PASTE SPECIAL-
Use "PASTE S
Chlorides
Values" then "COPY" .
(AL)
Chlorinated
Values" then "
Phenolic Compounds
Maximum data points =
58
Maximum
points =
Date Data
BDL=1/2DL Results
Date Data
BDL=1/2DL Results
1
288
288 Std Dev. N/A
1
Std Dev. NO DATA
�-
2
Mean 288.0
2
'
Mean NO DATA
3
C.V. 0.0000
3
C.V. NO DATA
4
n 1
4
n 0
5
5
6
Mult Factor = 1.0
6
Mult Factor = N/A
7
Max Value 288.0 mg/L
7
Max. Value N/A
8
Max. Pred Cw 288.0 mg/L
8
Max. Fred Cw N/A
9
-
9
10
10
11
11
12
12
13
13
a
14
14
151
15
161
16
17111
17
18
18
19
19
20
20
21
21
22
22
23
23
ff
24
24
I
25
25
26
..
26
27
27
28
28
29
29
;
30
30
31
31
32
32
33
33
34�
34
35
35
36
36
37�
37
`
38
38
e
39
39
40
40
41
41
.
42
42
43
43
44
44
45
45
46
46
-
47
47
48
48
49
49
50
50
51
51
52
52t
53
531
54
54
55
55
5656
57
57
58
I
58
a _
4987 -RPA dissolved dewaterring 1-2016, data
- 3 - 4/21/2016

T
}
J
Q
Q
J
Q
F..
Z
LW
r
a
W
J
m
Q
Z
O
U)
Q
W
w
O
g¢a
Q Q Qzzz
toEz
o o
m
000
z z
I I U
o 2
w ami
� j n`
(D.
� m m
E
o
7
E
O
s
m
0
0O
G
r N CO V' In
O t` CO m O r N CO V' 4) (O I-. M W O I- W O O N M V• M O t` N m O N M V' 0 0 I- M m 0 N M V• (17
a
r r r r r r r r r r N N N N N N N N N N M M M M M m m M M M V' V' V' d• V' V' V' V' V V' (Cl l!i (n ([) (n (n (n0 (4
J
e
m `cm
d
U v
7 :3
O
-Q Q Q
y
$ E
c
z z z
coo
>
>
z z z
11 U
`)
j D
m
(A
w aa)
N
LL
C
�mm
OQ
O
a
U
o
n
O
im
C
d
m
a.
.a.
m
I—
C
r N M V- U)
(O I� co O O r N M d• � O t` co 0 O N M 'V' (p O� W O O N M V' M t0 f, M O O N M r LL� O t` O W O N M 'V' LD O r- co
(p
a
N N N N N N N N M M M M M M M M M M V' V- V' V d• V' v V• V• V' (4 (n 0 (n to Up (n (n 0
J
W
O io
m
01 m
7 7
co
N O
N

N
}
J
Q
_Q
z
W
a
LU
MJ
W
Z
O
a
LU
w
m�
En
Dor oLOCO
d
in O O ♦-
00
Lno r U
yy�c
aQ
H
°a o o F ,
m
wm
Z O
II U
�
O
N >U (0
a) Ll > IL
750 C _
y N > > m m
w
O
❑ O
C
N
�
II
E
o
0°
v
Co v
O . _
O
i
r (N CO V' M 0 f'- W m O r N M V LO O M m 0 N M V w CO 1- O m a N M V U) 0 f- M O O N M V M M h W m O N CM -,tLO O I` M
a
J:
Q
U
}
°
r r r r r r r r r r N N N N N N N N N N M M M M M M M M M M V V V V V V V V V UO LO LO LOW LO LO LO LO
J J
m m
R
U
7. S
OQQQ
LU
h
d
'^ Z Z Z
h h H
n
>>
°z°
II U
� 7 a
.�CO
) a >a
�
v -o m > > ccoo m
>
E
J
o
G
J
O
L
m
U
co
O
r N M 7 LO CO I` co m O r N CO V' W (O t` (b m O N M } LO m I- O m O N M V 0 CO h CO M O N M `0' Lo o n CO m O N M V m CO I- CO
w
r r r r r r r r r r N N N N N N N N N N M M M M M M M M M M ot V V V V V V V V V LO M LO M m LO LO 0 Cl')
a
J
Qm
JJ
W
1 1

REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved dewaterring 1-2016, data
- 6 - 4/21/2016
Pall
Par12
ECIAL
Use "PASTE SPECIAL
Use "PASTE S
OPY"
Values"then"COPY"
Copper (AL)
Values"then'
Cyanide
ata
Maximum data
. Maximum
8
points = 58
points =
1
Date Data
'1.99
BDL=1/2DL Results
1.99 Std Dev. N/A
1
Date Data
BDL=1/2DL Results
Std Dev. NO DATA
�-�
2
Mean 1.9900
2
Mean NO DATA
3
C.V. 0.0000
3
C.V. NO DATA
4
n 1
4
n 0
5
5
6
Mult Factor = 1.00
6
•
Mult Factor = N/A
Ng/L
7
•
Max. Value 1.99 ug/L
7�
Max. Value N/A
ug/L
8
Max. Pred Cw 1.99 ug/L
8
Max. Pred Cw N/A
9
9
1
-
1
111
"
111
12
12
13
13
14
14
15
15
16
16
17
17
18
18
19
19
20
20
21
21
22
22
23
23
24
24
25'
25
26
26
27
27�
28
28
„
+
29
._
29
2
30—
30
31
31
32
32
33
33
34
..
34
j
35
" `
35
.
36
36
37
37
38
38)
39
39
40
40
41
41]
42
42
43
43
44
44
45
.
45
46
'
461
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
56
55
561
57'x`
'
57(
58
' '
58L
4987 -RPA dissolved dewaterring 1-2016, data
- 6 - 4/21/2016

J
Z
J
Q
F'
Z
W'
O
CL
W
MJM
A.IJ
Q
Z
O
Q
NW
w
ooO O O O(Ino
iimoor
oWo Wo oWz
p
II U
O j p
u) j U N N
LL >d
N.� (o
J �
� O
c
`
cc
d
J
11
�
00
`
r N M •cr N M'T w m h w m 0 N M V m O I- N m o N M V (n w I'- w m o N ml' o m I` O
y
r r r r r r r r r r N N N N N N N N N N M M M M M M M M M M V 7 V V V V V V V V n n o o (0 o (n o O
CL
J
4
} J
V
Lu
mJ
D m m
w�
FL
E oor 00000
p (V
�Y 0000
�N
I� O
a
y A 6 N O
3
y
N Q
>>
Z
I U
W LL 4
w ❑ co _
y co
N! 7 N N
O I`
•L N N
C II
7
M
LL m
m
IIN
v •
O
_
M
N CO C' (0 (0 1� m m O r N M V' LL) (0 t` OD m yM N M •V' (n (0 rl D7 m 0 N M V (CJ (0 Ih ao m 0 N M S ({0 (O h oD m o N M V' (n O I- w
r r r r r r r r r r N N N N N N N N N N M M M M M M M M M M R V C V V R V V V (n u7 m o w (n w (n o
a
Q Y
b U
J J
O7 m
W O m N
7 7

Y
U)
}
J
Z
J
LQ
Z
W
O
CL
W
m
Z
O
U)
Q
W
w
o ' ° o o r
m 7 An 0 0
N
00 0
O V' V'
r
r£ C O O
aaHR°a
Avo
m Q m
> > Z
II U
`o
v
w ami
LL> a`
� ❑ c
d�
m m
a@>,
E
M
S J
mco
r___-�_-
0
��
m
cc
D
.
o
.
r r N co 'T
co r- co m O r N co AD (D h lD m 0 N M V' tD (O h c0 m 0 N M V' tD (D f� w O O N M V' (D I� tb m 0 N M V' AD rfl r N
l4
CL
J
U
m
r r r r r r r r r r N N N N N N N N N N M M M M M M M M M M V s} V' V' V' V' V• V• sf «) An an An tD o AD AD AD
Lu Om
m
c c
y o h
w E u o o r
Fw- L E An n OO
o 0 0
cV (V
N r C m O
O
m
> > Z
I I U
`o
a
a�
mm
IL > a
m❑ m
do
Smm
ami>.
Q'tA�U c
MM2
rn
� N r
� I I
d Q
m
�m
7.
O
m�
N M
tD o I*- m m O r N M V' Aft O W m O N co V' lq O Ab m O N M V' AI) w n w m O N M v AD (D h N m O N M AD (D 1� M
r r r r r r r r r r N N N N N N N N N N M M M M M M M M M M V' V' V' V V' It V' -T V' V' w (17 U) o m AD AD AD AD
a
J-
m
w �
m

REASONABLE POTENTIAL ANALYSIS
ECIAL
Par17 & Par18
Use "PASTE SPECIAL
Par19
opy"
Nickel Values" then "COPT'
Selenium
ata
. Maximum data
8
points = 58
1
Date Data
BDL=1/2DL Results
14.8 Std Dev. N/A
1
Date Data BDL=1/2DL Results
9:151 3.15 Std Dev.
14.8
2'
Mean 14.8000
2
j Mean
3
C.V. 0.0000
3
I C.V.
4
n 1
41
5•
n
5
6
Mult Factor = 1.00
6IMult
Factor =
ug/L
7
_
Max. Value 148 Ng/L
7
f Max Value
ug/L
8
Max. Pred Cw 14.8 pg/L
8
Max. Pred Cw
9
9
10
"
10
I
11
11
j
12
12
l
13
13
a I
14
14
I
15
15
16
16
t
17
17
18''
_
18
19
19
20
20
I
21
21
22
22
23
23
24,
24
25
25
I
26
26
27
27
28
28
S
29
.•
2s
9
30
30
31
31�
32
32
{
33
33
I
34
34
35
35
.
36
36i
j
37
37j
38'
381
39
391
40
- `
401
41
411
I
42
42
43
43�
44
44
45
45
1
46
461
47
47
1
48
48
y
49
49
50
50
51
51
52
52
53
53
54
54
1
55
551
56
56
57
,';„ '
571
58
4987 -RPA dissolved dewaterring 1-2016, data
- 9 - 4/21/2016

REASONABLE POTENTIALANALYSIS
4987 -RPA dissolved dewaterring 1-2016, data
_10- 4/21/2016
Paf20
Par21
Use "PASTE SPECIAL
M
Zinc (AL)
Values" then "COPY"
Silver (AL)
. Maximum data
points = 68
1
Date Data
BDL=1/2DL ResultsDate
Std Dev. NO DATA
1
Data
BDL=1/2DL Results
50 Std Dev.
N/A
- 501
3.1500
2
Mean NO DATA
2
Mean
0.0000
3
C.V. NO DATA
3
C.V.
1
4
n 0
4
n
5
5
1.00
6
Mult Factor = N/A
6
Mult Factor =
3 2 ug/L
7
Max. Value N/A ug/L
7
Max. Value
3.2 ug/L
8
Max. Fred Cw N/A ug/L
8
Max. Pred Cw
9
9
10
10
11
11
12
12�
13
°
13
14
14�
15
15
16
16
17
u
17
18�
18
19+
19
201
20
21�
21
22
.
22
23
23
24
• `
24
25
25
26
26
27
27
28
28
29
29
"
30
30
,
31
31
32
32
33
33
34
` ' ? -
34
"
35
.
35
.`
36
36
37
37
38
38
39
.
39
'
40
`_
40
=
41
41
42
42
43
43
44
44
45
45
46,•-
46
`
47
s
47
48
48
'
49
49
50
50
51
51
52
''
52
'
53
53
54
54
55
55
.
56
. , .
56
57
58
58
4987 -RPA dissolved dewaterring 1-2016, data
_10- 4/21/2016

REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved dewaterring 1-2016, data
11 - 4/21/2016
Par22
Par23
,use "PASTE SPECIAL
Use "PASTE SPECIAL
Values"then"COPY"
Aluminum Values"then"COPY"
Boron
. Maximum data
. Maximum data
points = 58
points = 58
1
Date Data BDL=1/2DL Results
8101 810 Std Dev. N/A
Date Data
BDL=1/2DL
6.27
N/A
50.0000
201
-" " Mean 8100000
2
.,•p,
0.0000
3
C V. 00000
3
1
4
n 1
4
5
..
5
1.00
6
a Mult Factor = 1 00
6
-
50.0 ug/L
7
=' r Max. Value 810.000000 Ng/L
7
50.0 ug/L
8
Max. Pred Cw 810.000000 Ng/L
8
9
9
10
10
12
.
12
,
13
13
14
Q
14
15
'' . 1
15.
16.
16
,
17
"
17
18,
18
19
-
19
20
. '° a �•
20
21
. ` . ,
21
,
22
22
`
23
..
23
,
24
24
25
°'
25
'
26
.
26
27
:: i
27
._
28
28
29
29
30
= v jjjttt
30
31
=,
31
"
32
`7
32
33.
..
33
..
34
.'
34
n'
35
�•u`
35
36
36
,
37,'.
37
e
38
38
.
39
39
40,';
40'
41
'
41
42,-.,
42
43
43
44
44
45
"{
45
"a ,
46
46
4747
48
`s ,',' .A,
48
49
49'
.•
5050
�.
51
51
..
52
52
53
.
;
53
„
54
`.
54n,.
`.
55
55
....
56
. '.
56
57
57
58
L _ ..-a -.� �_A
58
4987 -RPA dissolved dewaterring 1-2016, data
11 - 4/21/2016

REASONABLE POTENTIAL ANALYSIS
Use "PASTE SPECIAL Par24 I Use "PASTE SPECIAL Par25
Results
Std Dev. N/A
Mean 6.2700
C.V 0.0000
n 1
Mult Factor = 1 00
Max. Value 6.270000 mg/L
Max. Pred Cw 6.270000 mg/L
Date Data
1 't, 14S
2
3•x:
4
5
6' ^`
7 ...
g°x4•. .
9
10 :..
12
13
14
15
16
17-
18
19• �•
20 =
21
22-, ..
23 -
24 -
25...
26
27
28 ' •.
29:"
30 ,
31
32 • ;.:
34
35
36
37
38-
39
40
41
42
43•
44
45 `
46
47
48
49
50
51." ,
52`, .
53'
54
55
561.
57�.,
Sulfate
BDL=1/2DL Results
149 Std Dev.
N/A
Mean
149.0000
C.V.
0.0000
n
1
Mult Factor =
1.00
Max. Value 149.000000 mg/L
Max. Pred Cw 149 OQ0000 mg/L
Date Data
1 0.498,
2
3
4_
5
6
7
8
10
12 ,
13
14
15, ;
16 '
17 :f '
18
19.
20 „
21 , b
22
23
24 °
25 -
26
27 '
28°..''
29 .
30 >?'
31
32'; ,4 '
33'
34 ,.
35 -• °�
36
37r'.`., „
38'
39
40
41
42
43
44 .-: • , .
45
46
47
48-
49. "
50.,-
51
52
53
54 °
55
56
57�_
58
Barium
BDL=1/2DL
0.498
4987 -RPA dissolved dewaterring 1-2016, data
-12- 4/21/2016
4

Results
Std Dev. N/A
Mean 0.4980
C.V. 0.0000
n 1
Mult Factor = 1.00
Max Value 0.498000 mg/L
Max Pred Cw 0.498000 mg/L
REASONABLE POTENTIAL ANALYSIS
4987 -RPA dissolved dewaterring 1-2016, data
-13- 4/21/2016

J
a
Z
a
J
a
Z
W
O
IL
LU
MJ
W
a
Z
O
U)
LU
w
O r
r
O N
N
N
C
(6
ani
CL)
0
N
Q
a
0)
T
G
❑ N
3
N �
O
t
O
�
m
CV
OR
`
r N M 'It UO (O t` W 0) O r N CO V Un 0 f- CO O) O N CO V UO CO 1, 00 0) O N M V M (o r,- co O O N M V UO 0 1- w m O N M V UO (O t` co
y
a
r r r r r r r r r r N N N N N N N N N N M M M M A m m m co m V V V 'r V V V V V V 0 n UO UO M UO 0 UO m
Q
S
J J
U
«
m m
1 S
W
v Uf C) CDO O r
0 O
O O F
o
UOo
N«
c
`-'OU
aim°y
oo
m
v
m
Q
O p
a>
Z
0
u U
«c>a
a-0 �>
> x x
A
J UO
�
❑ O
N
c�
J
M
a
m
CN
N M V UO 0 tt M 0) O r N M V UO O "(� N O) O N Cl) V u) O f, M 0) O N CO V m O 1- W 0) Co N M V M 0 O M O N M V UO m f+ M
a
r r r r r r r r �- r N N N N N N N N N N M m M M M M M M M M V V V V V V V V V V UO UO (O M 0 0 (O UO UO
Q
tea«
T
J J
mm
a
9
= 7
y
F
E n
y
00C) 0 r
0 0 0
O
y
t=
C
O O
O O
Lo UOn
a�qa
mg
UO0O
�
Q
Z
O r
r
O N
N
N
C
(6
ani
CL)
0
N
Q
a
0)
T

M
13
T
CO
J
Q
z
Q
J
a_
I --
z
`w
f -
O
a
w
z
w
w
(na
A
OI
J
N
J
O
CD
4
N cM V cn (D r� W W O r N M V W f� W d1 0 r N M V W W I� W m O r N M V' W 1� W m O r N M [t tD W I� N O_.�0 r N M V to W I� W
N N N N N N N N N N M M M M M M M "t d' o UJ lD tD to to (D ((� 47
o
QQQ
Q¢Q
ZZZ
000
> ❑.
o
ll
>mm
z z z
n U
°D
N >
o
U N
� O
LL
=
y-0
m m
t�>.
J
❑
N
❑
m
r N M u"J W h W m O r N M V In W I� N O ON M V LO W n W W O N M V N (D r W O O N M R W (D (l W O O N M V (D W (� W
r r r r r r r r r r N N N N N N N N N N M M M M M M M M M M V V T T V V v '7 v `7 (n W LO M m Up to cD tci
J J
m m
S 1
O O r O O O
W O 00 O
N O O O
W O r W W
00 W OR
00
W c0
O
N
W �
r N
o v
N
N
m
N
3
a�
a
S
0
a
n
co
rn
v
N
u U
o
U)'
� p
> ❑.
p c
y$a�i>
ll
>mm
W c0
O
N
W �
r N
o v
N
N
m
N
3
a�
a
S
0
a
n
co
rn
v
N

U
May 17, 2016
MEMORANDUM
To: Clinton O. Cook, PE, Assistant Regional Engineer
NC DEQ / DWR / Public Water Supply Section
Mooresville Regional Office
From: Sergei Chernikov, Environmental Engineer II, Complex NPDES Unit,
Division of Water Resources ([e-mail])
Subject: Review of the discharge locations for the following Draft NPDES permits:
NC00004987 Marshall Steam Station
Catawba County
Please indicate below by June 17, 2016 your agency's position or viewpoint on the facility
listed above. We cannot issue the permit without your concurrence. Please return this form
at your earliest convenience.
RESPONSE:
This agency has reviewed the draft permit and determined that the proposed
discharge will not be sufficiently close to any existing or known proposed
public water supply intake so as to create an adverse effect on water quality.
We concur with the issuance of this permit provided the. facility is operated
and maintained properly, the stated effluent limits are met prior to discharge,
and the discharge does not contravene the designated water quality standards.
X Concurs with issuance of the above permit, provided the following conditions
are met:
1. Sa=les collected and measurements taken, as required by the permit, shall be
=resentative of the permitted discharge Samples collected at a frequency
less than daily shall be taken on a day and time that is representative of the
discharge for the period of time that the same a represents If effluent water
characteristics fluctuate such that a single sample cannot represent the period
of time that the sample is intended to represent. additional samples shall be
collected.
Opposes the issuance of the above permit, based on reasons stated below, or
attached:
cc: file
0
Date: i& 2A/

'p-yJIL
)2+NO3 (Color
TKN Colorim
Bromide
Chloride
Aluminum
Calcium
Arsenic (As)
Cadmium (Cd)
Chromium (Cr)
Copper(Cu)
Lead (Pb)
olybdenum (Mo)
Nickel (Ni)
Selenium (Se)
lium (TI) Low Level
Vanadium (V)
lercury (CVAFS)
TDS
TSS
Marshall
Dewatering Data Submittal
May 2015
1.2
Marshall
Marshall
18.23
Ash Basin -
Ash Basin -
Ash Basin
Marshall Ash
Q.88
0.57
Ash Basin -
0.83
120.6
142
Bason 0.3m
Ash Basin 2
Ash Basin 4
Interstitial
Interstitial with
Interstitial with
interstitial with
4.28
meters
meters
92.7
20 u filter
10 u filteru
0.45 u filter
Result
es
Result
Result
esu
Result
esul
< 5
0.394
8.07
0.397
0.006
<
0.005
0.363
0.31
0.42
0.056
0.018
0.021
0.028
1.2
0.97
1.1
18.23
20
28.6
184.7
195
Q.88
0.57
0.63
0.83
120.6
142
149
0.474
IAO.M
0.16
0.07
0.07
0.08
4.28
4.64
6.27
92.7
102
133
0.671
1.12
0.36
43.2
46.7
63.9
0.713
0.98
K1.2-
• .250.037
0.037
0.04
0.03
O 18
.05
0.02
< 1
< 1
< 1
7-23
7.591
4.03
<
< 1
< 1
<
<
0.498
2.4
4.99
2.48
126
0.475
128
0.7
5
19
10.8
14
13.5
2.45
3.01
C 3.1
1.52
620
8
0.38 0.38
1.72 < 1
1.9 0.56
670 920
4.2
4.3
3.8
8.727
8.738
115.3
8.753
114.3
2.773
2.77
76.07
2.77
75.55
0.254
0.236
0.492
75.59
0.498
5.06
<
5.13
126
0.475
128
B.S.
.55
52.1
5.02
52.9
1.12
1.14
0.394
8.07
0.397
0.006
<
0.005
< 1
<
1
3560
3480
< 1
<
1
< 1
<
1
1.54
0.005
1.1
< 1
<
1
C -83P
3550
806
2.18
<
1.23
1.22
1
1.01
< 0.2
<
0.82
1.33
i
1.07
< 2
<
2
660
1
1
660
26
26
r
4.3
4.8
8.701
8.753
115.8
115.1
2.77
Q1.70
74.92
75.59
0.16
<
0.005
0.475
0.407
4.92
5.02
125
125
8.07
0.479
51.9
51.8
1.09
1.08
0.375
0.097-
<
0.005
<
0.005
<
1
<
1
3550
1930
<
1
<
1
<
1
<
1
<
i
<
1
<
1
<
1
841
823
<
1
<
1
1.07
1.03
0.365
<
0.2
1.05
<
1
<
0.5
<
0.5
680
680
19
<
10
r

d`
FF
Apr. 19, 2016
Sergei Chernikov, Ph.D.
Environmental Engineer Il
Complex NPDES Permitting Unit
NC Department of Environmental Quality
1617 Mail Service Center, Raleigh, NC 27699-1617
Express Mail: 512 N. Salisbury St., Raleigh, NC 27604
RE: APPROVAL REQUEST TO CONTINUE PILOT STUDY
FGD Wastewater Treatment — Vertical Flow Cells
Marshall Steam Station
Catawba County
NPDES Permit NC0004987
Dear Mr. Chernikov:
Duke Energy
Marsha!! Steam Station
8329 East NC Hwy 150
Terrell, NC 28682
828-478-7700
Duke Energy (Duke) is submitting this request to the NC Department of Environmental Quality
(NCDEQ) for approval to extend the pilot test period at Marshall Steam Station (Marshall) for
the FGD wastewater treatment Vertical Flow Cell area (VFC). Duke contacted (NCDEQ) on _
June 4, 2015, to request approval to conduct a two-month pilot test at the Marshall's VFC which
included use of pressurized wastewater to more efficiently manage dispersion of mulch in each
of the cells. The pilot study was subsequently approved by NCDEQ on June 4`h.
The pilot test was initiated on July 9, 2015. Specifically, the pilot test consisted of using a
diesel -powered pump and spray nozzle system to disperse floating compost mats in the VFCs. A
diesel pump was placed inside a lined containment adjacent to the equalization basin (EQ)
discharge splitter box and a 6 -inch diameter intake hose was placed in the EQ basin two feet
below the water surface. Pressurized wastewater was conveyed from the EQ to the VFC area via
a 4 -inch diameter hose placed inside an external PVC pipe that served as a containment barrier
for the hose. This hose was connected to a pipe header located inside the lined VFC area where
a 1.5 -inch diameter spray hose was attached at multiple locations between cells A -F. The spray
hoses were then used to direct the high pressure water to break apart floating mats of the
compost in each of the VFCs weekly, or as needed.
The VFC management team at Marshall found that the use of the diesel -pump and spray system
provided a safe and effective means of dispersing floating compost mats within the VFCs as
opposed to using a conventional hose. The pump and hose assembly provided a higher flow rate
and pressure for breaking up composts mats located near the center of the cells eliminating the
need for conventional/mechanical dispersion by boat and thereby improving both effectiveness
and safety of the cell maintenance.
Page 1 of 2 www.duke-energy.com

Duke Energy
Marshall Steam Station
8329 East NC Flwy 150
Terrell, NC 28682
828-478-7700
Upon initial testing, Duke requested an extension of the pilot test on September 9, 2015, from
NCDEQ that extended the test period through the end of 2015. The request was subsequently
approved by NCDEQ on September 9`h. The pilot test resumed operation through late November
2015, or until seasonal floating subsided during cooler months.
The method used during late 2015 at Marshall has been shown to provide a more safe and
effective means to maintaining mulch dispersion in the VFCs. Duke is requesting that this pilot
test be approved for continuation through 2016. Additional, Duke seeks to have this method
included as an approved process within the revised NPDES permit NC0004987.
Please feel free to contact Environmental Specialist, Brad Loveland, at [phone] if you
have any questions regarding this request.
Sincerely,
Rick R. Roper
General Manager III
Marshall Steam Station
Power Generation Carolinas West
be w/attachment: Brad Loveland
Scott La Sala
Scott Parks
www.duke-energy.com
Page 2 of 2

+ Chernikov, Sergei
From: Langley, Shannon <[e-mail]>
Sent: Monday, March 14, 2016 11:52 AM
To: Chernikov, Sergei
Cc: Pruett, Jeremy J.; Loveland, Brad P; Hartfield, Ross Evan
Subject: FW: FW: request
Sergei,
I spoke with my coworkers and they indicate the AOW noted in the correspondence you reference below was
determined to be the same as 5-02 at Marshall.
Shannon
From: Chernikov, Sergei[mailto:[e-mail]]
Sent: Monday, March 14, 2016 7:48 AM
To: Langley, Shannon
Subject: request
x** Exercise caution. This, [s an EXTERNAL email. DCS NOT Open attachments or click Hnk , from,
unknown senders or, unexpected ernafl
Shannon,
On August 14, 2015 Brad Loveland notified DWR of the new area of wetness at the Marshall Steam station. Could you
please e-mail me the updated Seep map with this AOW included. Please identify it as S-3.
Thankyou!
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex NPDES Permitting Unit
Tel. [phone]
Fax: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617
Express Mail: 512 N. Salisbury St., Raleigh, NC 27604

DUKE
ENERGY®
CAROLINAS
August 14, 2015
Mr. Sergei Chernikov
North Carolina Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Duke Energy Carolinas, Inc.
Marshall Steam Station
Submittal of Notification of Potential New Seep
Catawba County
Dear Mr. Chernikov,
EHS CCP Environmental Programs
Duke Energy
526 South Church Street
Charlotte, NC 28202
Mailing Address:
EC13K / P.O. Box 1006
Charlotte, NC 28201-1006
AUG 19 2015
Water Qua ft
Permitting W
Duke Energy personnel observed an area of wetness at Marshall Steam Station on 29 June 2015, collected
a water quality sample on 10 July 2015, and notified the North Carolina Division of Water Resources of
such activities via letter dated 27 July 2015. Enclosed with this letter are the results of the water quality
sampling.
The water appears to be seepage from the ash basin. However, the water only pools and eventually
either evaporates or percolates into the ground. The seep has no point source discharge into Lake
Norman.
In accordance with Duke Procedures, this seep will be monitored weekly for changes as part of our
weekly inspections.
If you have any questions, please contact Mr. Brad Loveland at [phone].
SincereOand
ra P Permitting and Compliance
Duke Energy, Inc.
Enclosure
cc: Richard Baker, Director, EHS CCP Environmental Programs
Brad Loveland, Environmental Specialist, CCP Permitting and Compliance
Miphael Parker, Mooresville Regional Office NCDENR

Sample Description
Station
Collected Date
Component
Method
CAS Number
< or >
Result
Units
MDL
RDL
Suspect Seep
MARSHALL
07/10/15
Oil and Grease
EPA 1664B
Oil/Grease
<
5
mg/L
1.056
5
Suspect Seep
MARSHALL
07/10/15
Aluminum (AI)
EPA 200.7
7429-90-5
0.413
mg/L
0.002
0.005
Suspect Seep
MARSHALL
07/10/15
Barium (Ba)
EPA 200.7
7440-39-3
0.107
mg/L
0.0001
0.005
Suspect Seep
MARSHALL
07/10/15
Boron (B)
EPA 200.7
7440-42-8
6.11
mg/L
0.0033
0.05
Suspect Seep
MARSHALL
07/10/15
Calcium (Ca)
EPA 200.7
7440-70-2
107
mg/L
0.035
0.1
Suspect Seep
MARSHALL
07/10/15
Iron (Fe)
EPA 200.7
7439-89-6
0.249
mg/L
0.0013
0.01
Suspect Seep
MARSHALL
07/10/15
Magnesium (Mg)
EPA 200.7
7439-95-4
45.7
mg/L
0.044
0.05
Suspect Seep
MARSHALL
07/10/15
Manganese (Mn)
EPA 200.7
7439-96-5
8.75
mg/L
0.0002
0.005
Suspect Seep
MARSHALL
07/10/15
Phosphorus (P)
EPA 200.7
7723-14-0
0.109
mg/L
0.0033
0.02
Suspect Seep
MARSHALL
07/10/15
Total Hardness (Ca and Mg)
EPA 200.7
0
455
/L (CaC(
0.1273
0.19
Suspect Seep
MARSHALL
07/10/15
Zinc (Zn)
EPA 200.7
7440-66-6
0.016
mg/L
0.0026
0.005
Suspect Seep
MARSHALL
07/10/15
Antimony (Sb)
EPA 200.8
7440-36-0
<
1
ug/L
0.106
1
Suspect Seep
MARSHALL
07/10/15
Arsenic (As)
EPA 200.8
7440-38-2
1.74
ug/L
0.078
1
Suspect Seep
MARSHALL
07/10/15
Cadmium (Cd)
EPA 200.8
7440-43-9
<
1
ug/L
0.101
1
Suspect Seep
MARSHALL
07/10/15
Chromium (Cr)
EPA 200.8
7440-47-3
<
1
ug/L
0.061
1
Suspect Seep
MARSHALL
07/10/15
Copper (Cu)
EPA 200.8
7440-50-8
<
1
ug/L
0.11
1
Suspect Seep
MARSHALL
07/10/15
Lead (Pb)
EPA 200.8
7439-92-1
<
1
ug/L
0.065
1
Suspect Seep
MARSHALL
07/10/15
Molybdenum (Mo)
EPA 200.8
7439-98-7
<
1
ug/L
0.066
1
Suspect Seep
MARSHALL
07/10/15
Nickel (Ni)
EPA 200.8
7440-02-0
1.43
ug/L
0.194
1
Suspect Seep
MARSHALL
07/10/15
Selenium (Se)
EPA 200.8
7782-49-2
<
1
ug/L
0.092
1
Suspect Seep
MARSHALL
07/10/15
Thallium (TI) Low Level
EPA 200.8
7440-28-0
0.59
ug/L
0.134
0.2
Suspect Seep
MARSHALL
07/10/15
Vanadium (V)
EPA 200.8
7440-62-2
<
1
ug/L
0.053
1
Suspect Seep
MARSHALL
07/10/15
Bromide
EPA 300.0
7726-95-6
22
mg/L
0.12
1
Suspect Seep
MARSHALL
07/10/15
Chloride
EPA 300.0
16887-00-6
230
mg/L
1.1
5
Suspect Seep
MARSHALL
07/10/15
Fluoride
EPA 300.0
16984-48-8
0.19
mg/L
0.017
0.1
Suspect Seep
MARSHALL
07/10/15
Sulfate
EPA 300.0
14808-79-8
140
mg/L
0.9
5
Suspect Seep
MARSHALL
07/10/15
1 Kjeldahl Nitrogen (Colorim(
EPA 351.2
0
0.43
mg-N/L
0.03
0.15
Suspect Seep
MARSHALL
07/10/15
litrite + Nitrate (Colorimetric
EPA 353.2
14797-65-0
0.096
mg-N/L
0.004
0.01
Suspect Seep
MARSHALL
07/10/15
pH
Field Work
pH
5.57
SI Units
0
0
Suspect Seep
MARSHALL
07/10/15
Specific Conductance
Field Work
0
895
uS/cm
0
0
Suspect Seep
MARSHALL
07/10/15
Temperature
Field Work
0
20.5
°C
0
0
Suspect Seep
MARSHALL
07/10/15
COD
HACH 8000
SW317
<
20
mg/L
3.78
20
Suspect Seep
MARSHALL
07/10/15
TDS
SM2540C
SW311
890
mg/L
16.75
25
Suspect Seep
MARSHALL
07/10/15
TSS
SM2540D
TSS
31
mg/L
3.35
5
Suspect Seep
MARSHALL
7/10/2015
Mercury (CVAFS)
1631E
7439-97-6
36
ng/L
1
1
FIELD BLANK
MARSHALL
7/10/2015
Mercury (CVAFS)
1631E
7439-97-6
<
0.5
ng/L
0.5
0.5
Trip blank
MARSHALL
1/0/1900
Mercury (CVAFS)
1631E
7439-97-6
<
0.5
ng/L
0.5
0.5

DUKE
ENERGY®
CAROLINAS
27 July 2015
Mr. Sergei Chernikov
North Carolina Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Duke Energy Carolinas, Inc.
Marshall Steam Station
Submittal of Notification of Potential New Seep
Catawba County
0-00.a&""
Dear Mr. Chernikov,
EHS CCP Environmental Programs
Duke Energy
526 South Church Street
Charlotte, NC 28202
Mailing Address:
EC13K / P.O. Box 1006
Charlotte, NC 28201-1006
RECENEDIDENRIDWR
JUL 2 8 2015
Water Quality
Permitting Section
On 29 June 2015, Duke Energy personnel observed an area of wetness at 35°42.560'N, 80021.566'W at
Marshall Steam Station. The water was observed to be clear and emerging between rip rap armoring a
newly constructed headwall for a storm water pipe. No discharge to Lake Norman was observed.
Duke Energy personnel re -inspected this area on 3 July 2015, and no change in condition was
observed. A sample of this area of wetness was collected on 10 July 2015 for analysis. The
analytical results will be included in a future letter.
If you have any questions, please contact Mr. Brad Loveland at [phone]
gradLSincerely,gandCCP'Permitting
and Compliance
Duke Energy, Inc.
Enclosure
cc: Richard Baker, Director, EHS CCP Environmental Programs
Brad Loveland, Environmental Specialist, CCP Permitting and Compliance
Michael Parker, Mooresville Regional Office NCDENR
Ross Hartfield, Environmental Specialist 2, CCP Permitting and Compliance

So stf,
UNITED STATES ENVIRONMENTAL PAOTECTION'AGENCY
REGION 4
s '
ATLANTA FEDERAL CENTER
�<44
61 FORSYTH STREET
pAo
ATLANTA, GEORGIA 30303-8960
AUG 19 2016
Mr. S. Jay Zimmerman
Director, Division of Water Resources
North Carolina Department of Environmental Quality
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27.699-1617
Re: Review of Proposed Final Permit
Duke Energy Carolinas, LLC, Marshall Steam Station
National Pollutant Discharge Elimination System Permit NC0004987
Dear Mr. Zimmerman:
On May 17, 2016, a draft National Pollutant Discharge Elimination System (NPDES) permit and
supporting documents for the above referenced facility were received by the U.S. Environmental
Protection Agency from the North Carolina Department of Environment Quality (NC DEQ), Division
of Water Resources (DWR). NC DWR provided a public comment period for the draft permit and
supporting documents from May 17 through June 22, 2016. The EPA completed its review of the draft
permit and provided its comments and recommendations with respect to the draft permit in a letter
dated June 16, 2016.
The EPA received a proposed final permit from NC DWR via email on August 4,2016. On August 16,
2016, staff from our respective agencies participated in a teleconference to discuss EPA's review of
the proposed permit. Following the teleconference, the EPA summarized our continents in an August
16, 2016, email and on August 18, 2016, a revised proposed permit was transmitted to the EPA from
NC DWR via email. The majority of the EPA's comments were addressed. However, in accordance
with Section IV.13.6 of the NPDES Memorandum of Agreement between EPA and NC DEQ, the EPA
reiterates these comments and recommendations, which have not been addressed:
A "Plan for Identification of New Discharges" should be included in the final permit.
Conditions for decanting wastewater from coal ash ponds,should be consistent for all facilities.
The final permit should require daily monitoring,for flow as well as the requirement specified in
NC DWR's July 20, ?016, letter to Duke Energy:
"The decanting can only occur if one of the provisions below is met:
1) The wastewater is treated by physical -chemical treatment facilities.
Intemet Address (URL) • http:/iwww.epa.gov,
RecyclodlRecyclable • Printed with vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer)

2) The wastewater in the ash pond [should be analyzed] prior to the discharge and the
results of the analysis should be returned to the facility by the lab within 24 hours. If the
facility determines that the results of the analysis are.below-water quality,standards, the
facility is allowed to discharge wastewater for 1 week only. After discharge period of 1
week is com_ pleted,'the facility shall begin the cycle again by sampling the wastewater in the
ash pond."
In addition, the EPA notes that fly gash at the Marshall facility is currently handled dry during normal
operation; therefore it is within DWR's discretion as the permitting authority, to require upon the
effective date of the permit, there shall be no discharge of pollutants in fly ash transport water rather
than allowing a compliance period until November 1, 2018, which does not appear,to"be needed by'the
facility.
The EPA does not currently have enough information to determine where the seeps emerge or reach
jurisdictional waters of the United States: We recommend that the United States Army Corps of
Engineers verify any jurisdictional determination before the permit is finalized.
Finally, as we have discussed, the proposed final permit authorizes discharges from un -engineered
seeps that are not discharged through an engineered outfall or collected -and rerouted to an engineered
outfall. This creates challenges in permit development and compliance monitoring as it is unclear how
such discharges can be accurately monitored for flow and discharge characterization. We note that an
enforcement mechanism providing for elimination or rerouting of these seeps is an alternative and
potentially preferable approach for addressing seeps of this nature. It has been North Carolina's
election to develop_ permits for these discharges rather than addressing them through an enforcement
mechanism, notwithstanding the difficulty of developing appropriate permit conditions and monitoring
compliance.
The EPA has no further comments. If you have any questions, please do not hesitate to contact me at
[phone] or Ms. Deinisse Diaz [phone].
Sincerely,
James D. Giattina
Director
Water Protection Division
cc: Mr. Harry Sideris, Senior Vice President
Duke Energy Carolinas, LLC

' Chernikov, Sergei
From: Zimmer, Andrea <[e-mail]>
Sent: Tuesday, August 16, 2016 5:21 PM
To: Chernikov, Sergei; Poupart, Jeff
Cc: Shell, Karrie-Jo; Staples, Bridget; Davis, Molly; Diaz, Denisse
Subject: Duke Energy - R4/NCDEQ conference call to discuss final proposed NPDES permit for
Marshall NC0004987
Attachments: NC_Marshall_IOJ_06032010.pdf
Jeff and Sergei,
Thank you for the opportunity to discuss our comments on the proposed final NPDES permit for the Duke Energy
Marshall facility. Following is a summary of our conversation:
1. A "Plan for Identification of New Discharges" should be included in the final permit in order to clearly define
enforceable minimum requirements for identifying unpermitted discharges, such as areas to be inspected,
inspection procedures, frequency of inspections, constituents to be sampled, etc.
2. In December 2015, EPA and NCDEQ agreed to appropriate conditions for decanting wastewater from coal ash
ponds. Subsequently, on July 20, 2016, NCDEQ issued a letter reiterating the original conditions and adding a
new requirement. All of these requirements should be included in the final NPDES and become effective when
decanting commences. We particularly discussed the new provision, real time pH monitoring, and the
requirement to notify DEQ prior to beginning the decanting process. We did not discuss, but note, that the
proposed final permit does not require daily flow monitoring during decanting.
3. Conditions requiring no discharge of pollutants in fly ash transport water and bottom ash transport water are
included in the proposed final permit on pages 5 and 7. The clarifying language on applicability should be edited
such that the applicability of each condition refers to either fly ash transport water or bottom ash transport
water, not both.
4. For outfalls 002A and 00213: measurement frequency, sample type, and sample location were omitted for Oil -
and Grease.
5. For Outfall 003, which is an internal outfall, Note 1 is not applicable.
6. For Outfall 004, the permit should clearly indicate that monitoring only is required for total arsenic, total
mercury, total selenium, and nitrate/nitrite until the limits become effective.
7. For A. (26.), the temperature analysis and the balanced and indigenous study plan should conform to the
specifications outlined in 40 CFR 125 Subpart H and the Region 4 letter to NC DNR dated June 3, 2010. A copy of
the letter is attached for convenience.
8. The final proposed permit clarifies that the instream sampling for demonstration of compliance with WQS for
- seep discharges will be conducted in accordance with the condition A. (29.). However, A. (29.) does not specify
the location of the upstream and downstream monitoring stations.
9. DEQ agreed to, and has since provided, the information submitted by Duke Energy which NC reviewed to
determine the applicability dates for the new Effluent Guideline Limitations.
As we discussed, DEQ will provide a revised final permit before EPA's 15 -day comment period ends on Friday, August 19.
If you have any questions, please let us know.
Thanks!

Water Resources
ENVIRONMENTAL QUALITY
July 25, 2016
MEMORANDUM
To: Jay Zimmerman
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secrelary
S. JAY ZIMMERMAN
From: Jim Gregson, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Subject:Hearing Officer's Report and Recommendations
Duke Energy Carolinas, LLC - Draft NPDES Wastewater Permit No. NC0004987
Marshall Steam Station, Catawba County
Director
I served as the Hearing Officer for two public hearings held on April 8, 2015 at the James Warner Citizen
Center, 115 West Main Street, in Lincolnton, NC and on June 22, 2016, at the Catawba Valley
Community College East Wing Auditorium at 2550 Highway 70 Southeast, in Hickory, NC. The purpose
of the public hearings was to allow the public to comment on the draft NPDES wastewater permit for
Duke Energy Carolinas, LLC's Marshall Steam Station. The April 8, 2015, public hearing was a combined
public hearing for both the draft NPDES wastewater permit and the draft NPDES stormwater permit.
Brad Cole from the Division of Energy, Mineral and Land Resources served as the hearing officer for the
draft NPDES stormwater permit.
The Hearing Officer's Report for the Marshall Steam Station NPDES permit includes two public hearings
and two public comment periods. Due to substantial changes in the draft permit,"a second public
hearing was required by the Coal Ash Management Act of 2014.
In addition to listening to oral comments at the public hearings, I have reviewed all written comments
received during the first public comment period which ended on May 5, 2015, and the second public
comment period which ended on June 22, 2016. In preparation of this report I have considered all of
the public comments, the public record, and the site visits for the three facilities.
The report has been prepared using the following outline:
I. Site History/ Background
II. Site Visit
III. April 8, 2015, Public Hearing and Comments Summary
IV. June 22, 2016 Public Hearing and Comments Summary
V. Recommendations
VI. Attachments
State of North Carolina I Department of Environmental Quality I Division of Water Resources
127 Cardinal Drive Ext., Wilmington, NC 28405
919 796 7215

Hearing Officer Report
April 8, 2015, and June 22, 2016, PUBLIC HEARINGS —DRAFT NPDES PERMIT No.
NC0004987 FOR DUKE ENERGY CAROLINAS, LLC TO DISCHARGE WASTEWATER
FROM THE MARSHALL STEAM STATION, 8320 EAST N.C. HIGHWAY 150, TERRELL,
NC., CATAWBA COUNTY
I. History/ Background
Duke Energy's Marshall Steam Station is a four -unit coal fired steam electric generating facility
located along Lake Norman in Catawba County. The facility has been in operation since 1965
and has a capacity of 2,090 megawatts. Marshall Steam Station is permitted to discharge
wastewater under NPDES Permit No. NC0004987 to Lake Norman. The Marshall Steam Station
ash basin consists of a single cell of approximately 382 acres that was constructed in 1965. The
ash basin receives wastewater flow from the ash removal system, yard drain sumps, low
volume wastes, effluent from a 6,100 GPD domestic wastewater treatment system, the FGD
treatment system, as well as stormwater. The FGD system discharges to the ash basin via
internal outfall 004. The ash basin discharges via NPDES Outfall 002 to Lake Norman.
§ 130A-309.210 of the Coal Ash Management Act of 2014 requires owners of coal combustion
residuals surface impoundments to identify and assess all discharges from the impoundments
and to implement corrective action to prevent unpermitted discharges from the impoundments
to the surface waters of the State. Identification of discharges includes engineered channels
designed or improved for the purpose of collecting water from the toe of the impoundment
(toe drains), as well as non -engineered seeps and weeps. One method of proposed corrective
action allowed under the Act is to make application for a National Pollutant Discharge
Elimination System (NPDES) permit amendment to bring the unpermitted discharge under
permit regulations. A Discharge Assessment Plan for the unpermitted discharges at the
Marshall Steam Station was submitted by Duke Energy to the department on December 30,
2014.
Duke Energy identified two unpermitted seeps at the Marshall Steam Station from the ash
settling basin. The two seeps are not located on the wall of the ash basin dike. Flow volume for
the seeps was determined to be 0.0019 MGD. The two seeps would be incorporated into the
NPDES Permit under Outfalls 101 and 102. A summary of the proposed changes to the NPDES
permit can be found on the Fact Sheet for NPDES Permit Development in Attachment B.
II. Site Visits

A site visit was conducted on April 8, 2015, at the Marshall Steam Station. The site visits were
conducted with Duke Energy staff, DWR staff, as well as the hearing officer for DEMLR. The site
visit focused on the unpermitted seeps and other wastewater and stormwater outfalls that are
the subject of the draft NPDES Permit.
Ill. April 8, 2015 Public Hearing and Comments Summary
A public hearing was held on April 8, 2015, at 6:00 pm, at the James Warner Citizen Center, 115
West Main Street, in Lincolnton, NC. The purpose of the public hearing was to allow the public
to comment on the draft NPDES wastewater permits and the draft NPDES stormwater permits
for Duke Energy Carolinas, LLC's Allen Steam Station, Marshall Steam Station and Riverbend
Steam Station. Because this was a combined public hearing, Brad Cole from the Division of
Energy, Mineral and Land Resources served as the hearing officer for the draft NPDES
stormwater permits.
Notice of the hearing (Attachment E.) was published in the Hickory Daily Record, the Charlotte
Observer, and the Gaston Gazette on March 6, 2015. Additionally, a news release of the Notice
was issued on March 6, 2015, and publication of this notice was posted on the DEQ DWR and
DEMLR websites. The public comment period closed on May 5, 2015.
Approximately 86 people attended the public hearing including 24 staff members of the
Division of Water Resources and the Division of Energy, Mineral and Land Resources and the
two hearing officers. A total of 60 individuals signed the attendance sign in sheets at the
hearing (Attachment F. and G.). The hearing officer provided opening comments and Sergei
Chernikov, Ph.D., with the Division of Water Resources gave a brief overview of the draft NPDES
wastewater permits. Bradley Bennett with the Division of Energy, Mineral and Land Resources
then gave a brief overview of the draft NPDES stormwater permits. Twenty-four individuals
registered in advance of the hearing to provide oral comments. Speakers were allowed five
minutes to comment. Additional time was provided after everyone that registered to speak
was finished. Two individuals that spoke at the hearing also provided written comments. The
list of speakers is included as Attachment F. The two written comments provided at the public
hearing are included with other written comments in Attachment C.
All speakers were generally opposed to the NPDES permit drafts. The following is a summary
by major -topic area of oral comments received at the public hearing:
Permits would allow coal ash to leak legally or would make legal polluting that is subject
to criminal charges by the United States Department of Justice. (Speakers 1, 2, 7, 8, 11,
12, and 16)
Response: § 130A-309.210 of the Coal Ash Management Act (CAMA) of 2014 requires
owners of coal combustion residuals surface impoundments to identify and assess all
3

discharges from the impoundments and to implement corrective action to prevent
unpermitted discharges from the impoundments to the surface waters of the state.
Identification of discharges includes engineered channels designed or improved for
the purpose of collecting water from the toe of the impoundment (toe drains), as well
as non -engineered seeps and weeps. One method of proposed corrective action
allowed under the Act is to make application for a National Pollutant Discharge
Elimination System (NPDES) permit amendment to bring the unpermitted discharge
under permit regulations. A Discharge Assessment Plan for the unpermitted
discharges at the Marshall Steam Station was submitted by Duke Energy to the
Department on December 30, 2014. The facility identified two unpermitted seeps (all
non -engineered) from the ash settling basin. Under the draft NPDES Permit, both
seeps are considered to be discharging through delineated Effluent Channels. The
Effluent Channels were delineated by DWR staff on May 4, 2016, in accordance with
15A NCAC 02B .0228. The draft permit requires the permittee to demonstrate that
water quality standards in the receiving stream are not contravened. This
demonstration must be submitted to the Division no later than 180 days from the
effective date of the permit.
• Coal ash should be moved out of the storage ponds and placed in safe lined storage
areas or general comments concerning site clean- up. (Speakers 1, 2, 4, 7, 8, 12, 14, 16,
17, 18, 19 and 23)
Response: §130A-309.213 of the Act required the department to develop a proposed
classification system for all coal combustion residuals surface impoundments,
including active and retired sites. §130A-309.214 requires owners of coal combustion
residual surface impoundments to submit a proposed closure plan for the
Departments approval. High-risk impoundments shall be closed no later than
December 31, 2019, intermediate -risk impoundments shall be closed no later than
December 31, 2024, and low-risk impoundments shall be closed no later than
December 31, 2029.
• Permits would violate laws that are designed to protect the ground waters of North
Carolina or general groundwater concerns. (Speakers 2, 11, 15, 17, 19, and 23)
Response: While non -engineered seeps do have the potential to contaminate both
surface water and groundwater; the draft NPDES permit requires groundwater
monitoring be conducted to determine compliance with current groundwater
standards found under 15A NCAC 02L.0200. In accordance with 15A NCAC 02L.0104,
the permit requires that said monitoring wells be in place at the compliance boundary,
such that the groundwater within the designated area is sufficiently monitored.
Groundwater standard violations would be investigated and regulated according to
15A NCAC 02L and the Coal Ash Management Act of 2014.
Permits should require best available treatment technology (BAT) and/or use require
technology based effluent limits (TBEL). (Speakers 2, 16, and 17)
4

Response: The draft NPDES permit requires both TBEL limits and BAT limits in
accordance with 40 CFR 423 Steam Electric Power Generating Point Source Category.
Permits should require sampling for additional constituents. (Speakers 6, 12, 13, 14, 16,
17 and 21)
Response: The sampling requirements in the draft NPDES permit is based on the state
and federal rules, regulations, and policies. The state conducts a Reasonable Potential
Analysis (RPA) to' determine the need for a monitoring or limit for a particular
constituent. RPA is the statistical analysis of the effluent data that was approved by
EPA. The RPA is conducted on the 126 parameters in the renewal/major modification
application. The RPA is conducted on the parameters that are above detection level
and have appropriate state water quality sr criteria.
The majority of the
parameters in the renewal application are
below dete
Seeps should be monitored separately or concerns about unspecified seeps. (Speakers
2, 16 and 17)
Response: The draft NPDES permit requires regular inspection for new seeps and
monitoring requirement for all identified seeps. The two identified seeps would be
monitored separately as Outfalls 101 and 102.
• Specific concerns about PCBs. (Speaker 14)
Reser: The draft NPDES permit requires priority pollutant analysis be conducted
once per permit cycle at Outfall 002 (ash pond discharge) and specifically prohibits the
discharge of polychlorinated biphenyl compounds (Condition A.13).
Specific concerns about selenium and fish contamination. (Speaker 21)
Response: The draft NPDES permit requires fish tissue monitoring annually and
'requires submission of the results with the renewal application. The parameters
analyzed include arsenic, selenium, and mercury.
The public hearing including oral comments is included as Attachment D.
In addition to the public hearing, DWR received 503 written comments via email and 99
comments via the US Mail during the public comment period. Those comments are
included as Attachment C.
42 of the email comments were received using the following form letter email:
1. Using NPDES permits to approve illegal seeps goeslagainst the Clean Water Act and
our own NC General Statutes.
5

2. The Clean Water Act requires that the permits include limits based on the "Best
Available Technology" and must eliminate discharges of pollution when possible. Here, it
is possible. Excavating the coal ash from leaking lagoons and storing it in dry, lined
landfills away from public waters, or recycling it for concrete. DENR's new permits should
include a requirement to eliminate the discharges from these sites by excavating them to
lined storage or recycling.
3. Many of the toxic metals listed in the permit have no limits on the amount that can be
discharged for coal ash pollutants like cobalt, boron, strontium, and zinc that are leaking
out of the lagoons, and the limits it has set for arsenic, mercury, and selenium are too
weak. This is not acceptable, DENR must SET STRONG LIMITS on ALL coal ash pollutants.
4. Monitoring of many discharges is proposed for only twice a year, which is totally
inadequate. Monitoring should be increased to gain an accurate understanding of the
changes in discharges throughout the year.
Response: The inclusion of the seeps into the NPDES permit is based on the provisions
of the Coal Ash Management Act of 2014 (CAMA). The DWR has been consulting with
EPA in'regard to the incorporation of the seeps into the NPDES wastewater permits.
The inclusion of the seeps is considered an interim measure until the facilities
decommission the ash ponds. Some of the seeps are part of the natural groundwater
flow and might remain at the sites even after the ash ponds are decommissioned.
The draft NPDES permit requires both TBEL limits and BAT limits in accordance with 40
CFR 423 Steam Electric Power Generating Point Source Category.
The permit also includes the requirement to meet the CAMA provisions. The CAMA
requires removal of the ash from the high-risk and intermediate risk impoundments
and disposing of it in the landfills.
The Total Arsenic limits (Outfall 002 dewatering) in the permit are based on the results
of the Reasonable Potential Analysis (RPA) of the interstitial water data. The
calculations are conducted in accordance with the EPA Guidance entitled "Technical
Support Document for Water Quality -based Toxics Control." The water quality chronic
dissolved standard of 150.0 µg/L for Freshwater Aquatic Life and water quality acute
dissolved standard of 340.0 were used in the calculations of the limits.
The State of North Carolina has a state-wide mercury impairment. A TMDL has been
developed to address this issue in 2012. The TMDL included the implementation
strategy, both documents were approved by EPA in 2012. The mercury evaluation was
conducted in accordance with the Permitting Guidelines for Statewide Mercury TMDL.
The allowable mercury concentration for this facility is 68.0 ng/L. All annual average
mercury concentrations are below the allowable level. All maximum sampling results
are below the TBEL of 47.0 ng/L. Based on the Permitting Guidelines for Statewide
Mercury TMDL, the limits are not required.

Water Quality Based Effluent Limits are established in accordance with the EPA
Guidance entitled "Technical Support Document for Water Quality -based Toxics
Control. The limits are established only when the particular parameter demonstrates
a reasonable potential to exceed the state water quality standard or EPA criterion.
The state conducts a Reasonable Potential Analysis (RPA) to determine the need for a
limit for a particular constituent. RPA is the statistical analysis of the effluent data
that was approved by EPA and is based on the conservative assumption of the low
flow and the highest detected value in the monitoring data set during the last 5 years
of the facility operation. The RPA is conducted on the 126 parameters (if the
parameter is detected) in the renewal/major, modification application submitted by
Duke Energy.
The monitoring requirements in the permit are based on the state and federal rules,
regulations, and policies. The established frequency is sufficient to conduct a valid
statistical analysis of the effluent data.
127 comments were received using the following form letter email:
I am concerned about the coal ash pollution, which includes arsenic, mercury, cobalt,
seeping into the Catawba River from Duke Energy's leaking and unlined lagoons. The
draft permits are unacceptably' weak and will not adequately protect our communities
from contaminates in coal ash.
For instance, DENR is proposing to start allowing random, untreated streams of polluted
coal ash wastewater to spew out of Duke Energy's lagoons.
These leaks should be stopped and Duke must be required to clean up their source—the
coal ash—and move it away from our waterways.
Response - The inclusion of the seeps into the NPDES permit is based on the provisions
of the Coal Ash Management Act of 2014 (CAMA). The DWR has been consulting with
-EPA in regard to the incorporation of the seeps into the NPDES wastewater permits.
The inclusion of the seeps is considered an interim measure until the facilities
decommission the ash ponds. The combined seeps flow for operating coal-fired power
plants represents a miniscule portion of the wastewater flow from coal ash
impoundment. For example, combined seep flow from Marshall Steam Station
represents only 0.02% of the ash pond discharge. The chemical composition of the
seep discharge is almost identical to the ash pond wastewater but the pollutant
concentrations are generally lower. The statistical analysis conducted on the effluent
from ash pondiand seeps indicates no reasonable potential to contravene state water
quality standards or EPA criteria in the receiving stream.
7

146 comments were received using the following form letter email:
Please reject the current NPDES permits for Duke Energy's three coal ash power plants
along the Catawba River. I'm concerned because the draft permits would allow Duke
Energy to discharge unlimited amounts of arsenic, mercury, and selenium into the
Catawba River and Mountain Island Lake (a drinking water supply reservoir). This is
unacceptable.
The NPDES permitting program goal is to eliminate pollutant discharges and these
permits do not do that. Please protect our communities from coal ash pollution. -
Response: In order to eliminate pollutant discharges from the Duke Energy sites, the
facilities need NPDES wastewater permits that establish conditions for ash pond
dewatering. The dewatering is the first step in the ash pond decommissioning, which
would significantly decrease pollutant loading to the Catawba River.
153 comments were received using the following form letter email:
Please do not"allow Duke Energy to pollute our waterways with toxic coal ash. The
NPDES permits for the three power plants along the Catawba River are woefully
inadequate and 1 hope that you will reject them. As written, the permits would not even
monitor or report on elements and chemicals that are known to be associated with coal
ash ponds. Also, industrial chemicals have been permitted to be dumped into the coal
ash ponds and Duke should be required to test for them at outfalls.
These permits cannot simply be a way to allow Duke Energy to keep its coal ash in
leaking, unlined lagoons next to bodies of water. I urge you to reject these NPDES
permits as they do not properly protect our communities.
Response: The monitoring requirements in the permit are based on the state and
federal rules, regulations, and policies. The state conducts a Reasonable Potential
Analysis (RPA) to determine the need for a monitoring for a particular constituent.
RPA is the statistical analysis of the effluent data that was approved by EPA. The RPA
is conducted on the 126 parameters (if the parameter is detected) in the
renewal/major modification application. The RPA is conducted on the parameters
that are above detection level and have appropriate state water quality standard/EPA
criteria. The majority of the parameters in the renewal applications are below
detection level. The permit also contains a plan for/dentification of new discharges.
In order to eliminate ash ponds, the facilities need NPDES wastewater permits that
establish conditions for ash pond dewatering. The dewatering is the first step in the
ash pond decommissioning.

99 comments were received via the US Mail using the following form letter:
• Using NPDES permits to approve illegal seeps goes against the Clean Water Act and our
own NC General Statutes.
• Permits do not include a timeline for eliminating this illegal discharge. The leaks should
be stopped, not permitted under a fictional collective seep outfall. DENR should consider
utilizing its own SOC process for getting Duke in compliance with the law, and not allow
these illegal discharges to be permitted under an NPDES permit.
Many of the toxic metals listed in the permit have NO LIMITS on the amount that can be
discharged. DENR should never allow unsafe amounts of arsenic, mercury, and selenium
to be discharged into drinking. water supplies. There needs to be specified limits for all
elements and chemicals associated with coal ash.
Response: § 130A-309.210 of the Coal Ash Management Act of 2014 requires owners
of coal combustion residuals surface impoundments to identify and assess all
discharges from the impoundments and to implement corrective action to prevent
unpermitted discharges from the impoundments to the surface waters of the state.
Identification of discharges includes engineered channels designed or improved for
the purpose of collecting water.from the toe of the impoundment (toe drains), as well
as non -engineered seeps and weeps. One method of proposed corrective action
allowed under the Act is to make application for a National Pollutant Discharge
Elimination System (NPDES) permit amendment to bring the unpermitted discharge
under permit regulations. A Discharge Assessment Plan for the unpermitted
discharges at the Marshall Steam Station was submitted by Duke Energy to the
Department on December 30, 2014. The two non -engineered seeps identified at the
Marshall facility would be incorporated into the NPDES wastewater permit as Outfalls
101 and 102. Under the permit, the seeps would be monitored and subject to
applicable effluent limits which would ensure that seep discharges would not result in
unacceptable impacts to surface waters. Incorporation of the seeps in to the NPDES
permit is considered an interim measure until the coal ash impoundments are closed.
The draft permit requires that the facility continue to implement a plan for the
identification of new seeps. A seep identification survey shall be conducted semi-
annually and new seeps are to be reported to the Division within five days of
detection.
Special Orders by Consent (SOC) can be an appropriate action when a facility is unable
to consistently meet terms, conditions or limits in an NPDES permit. In this case, there
is no evidence that Duke Energy will be unable to meet the proposed effluent limits.
The Division conducted EPA -recommended analyses to determine the reasonable
potential for toxicants to be discharged at levels exceeding water quality
standards/EPA criteria by this facility from outfall 002 (Ash Pond). For the purposes of
the RPA, the background concentrations for all parameters were assumed to be below
w]

detection level. The RPA uses 95% probability level and 95% confidence basis in
accordance with the EPA Guidance entitled "Technical Support Document for Water
Quality -based Toxics Control."
Calculations included: As, Be, Cd, Chlorides, Cr, Cu, CN, PI% Hg, Mo, Ni, Se, Ag, Zn, Al,
and B (please see attached). The renewal application listed 8.3 MGD as a current flow.
However, 11.44 MGD was used in the RPA as the highest reported flow during the last
permit cycle. The analysis indicates no reasonable potential to violate the surface
water quality standards or EPA criteria. The water -quality based limits for selenium
were removed from the permit (Outfall 002) based on the results of Reasonable
Potential Analysis.
The Division also considered data for other parameters of concern in the EPA Form 2C
that the facility submitted for the renewal. The majority of the parameters were not
detected in the discharge. The Division reviewed the following parameters that were
detected in the discharge and have an applicable state standards or EPA criteria for
Class WS -IV stream: phenols. This parameter was well below the state standard.
An RPA was also conducted for the combined flow from the seeps (Outfalls 101 and
102). The analysis was based on the dilution in the receiving stream since the effluent
channels were delineated for both seeps. Although one seep was not flowing at the
time of the sampling, it was assumed that it might discharge during the wet season.
Calculations included: As, Cd, Chlorides, Cr, Cu, F, Pb, Hg, Mo, Ni, Se Zn, SO4, Al, Ba, B,
Sb, and TI (please see attached). The analysis indicates no reasonable potential to
violate the water quality standards or EPA criteria. The flow volume for the first seep
was measured at 0.0019 MGD. However, the flow of 0.5 MGD was used for the RPA to
incorporate a safety factor, account for potential new seeps that might emerge in the
future or increase in flow volume at the existing seeps.
In conclusion, the RPA analysis indicates that existing discharges from the facility
outfalls and seeps will not cause contravention of the state water quality standards/
EPA criteria.
Other comments received expressed issues that have already been addressed above or are
comments from specific organizations as listed below.
The following is a summary of comments received from Duke Energy (Response to Duke's
updated comments on the second public notice are included in Section IV):
• Technology Based Effluent Limits (TBELs) - There was no indication that the Division
considered any of the factors established in 40 CFR 125.3(d) insetting the TBELs. The
Fact Sheet indicates that existing federal regulations require the,development of TBELs
for parameters of concern. In Duke Energy's opinion, the permit writer has discretion
10

to choose to impose BPJ limits which is supported by recent court ruling in Tennessee.
Since EPA considered setting numeric limits for metals, the Division is not obligated to
establish TBELs for these parameters.
• MercurV Limits at Outfall 002 and Outfall 010 — Duke Energy requests a 5 -year
compliance schedule to comply with the mercury limit.
Outfall 002 — Duke Energy requests the removal of TBELs from Outfall 002, given the
reasonable potential analysis concluded that the discharge is not expected to violate
applicable water quality criterion and the TBELs were not developed in accordance with
40 CFR 125.3(d). If the TBELs are applied, Duke Energy requests the specific model
technology used to derive the TBELs that were applied to Outfall 002. If imposed limits
are not achieved, Duke Energy would like.to have the option of requesting a less
stringent limit as allowed under the Clean Water Act §402(o)(2)(E). Duke Energy would
like clarifying language in the permit authorizing the removal free water above the
settled ash layer including, but not limited to decanting, controlled pumping and/or
normal operation. Duke Energy requests the title for the ash basin discharge outfall to
be revised to "Outfall 002 (discharges from the ash basin associated with normal
operations, decanting and/or stormwater)". Duke Energy would like to request the
language in the Fact Sheet be updated to reflect current discharges to the ash basin.
Outfall 002 Dewatering- Duke Energy requests specific clarifying language in the permit•
that "dewatering limits" are applicable to removal of interstitial water only and that
limits would only apply to the removal of interstitial water generated by dewatering
activities occurring in the secondary ash basin. Duke Energy requests that the title for
the dewatering outfall be revised to "Outfall 002 (discharge of interstitial water due to
dewatering)". Duke Energy requests the removal of the TBELs from Outfall 002
(Dewatering). if the Division is bound to develop TBELs for the dewatering process,
Duke Energy request interim limits for a period of 4.5 years to further evaluate the
characteristics of the dewatering waste stream and evaluate, budget and design a
treatment technology. If the TBELs are applied, Duke Energy requests the specific
model technology used to derive the TBELs that were applied to Outfall 002
(Dewatering). If imposed limits are not achieved, Duke Energy would like to have the
option of requesting a less stringent limit as allowed under the Clean Water Act
§402(o)(2)(E).
Outfall 010 —The nitrate/nitrite limits established for Outfall 010 is extremely low and
unnecessary. The permit, needs to state the methodology to calculate the concentration
for the combined seeps to be reported in the discharge monitoring reports (DMR).
Duke Energy requests the seeps listed and updated in the Discharge Identification, Plan
(DIP) referenced in Appendix B be used as the official seep identification with regards to
official location and type (non -engineered seeps and engineered seeps) Duke Energy
believes it is appropriate that the seeps be grouped into two outfalls: one for
11

engineered seeps and one for non -engineered seeps. The same permit limits and
conditions applied to Outfall 001 should be applied to engineered seeps. Duke Energy
requests the removal of the TBELs from Outfall 010. In lieu of TBELs, Duke Energy
requests the Division to adopt a similar process as with new seep identification to
evaluate the constituent concentration and flow. If the concentration of any parameter
exceeds the concentrations in Table 1 of the permit or the total flow of all seeps is
determined to be in excess of 0.5 MGD, the Division should calculate reasonable
potential to determine if water quality based effluent limits (WQBELs) are necessary. If
so, a formal modification of the permit can be conducted to incorporate the WQBELs in
the permit. This approach would be consistent with the Hanlon memo. If the Division is
bound to develop TBELs for the seeps, Duke Energy requests a 5 -year compliance
schedule. The permit states the limits can be met by installing a treatment system, re-
routing the discharge to the existing treatment system, or discontinuing the discharge.
The Fact Sheet, however, states it will be time-consuming and ineffective to re-route the
seeps back to the ash basin. Given these conflicting statements, a compliance schedule
is necessary to evaluate, budget, design and construct the treatment system or
eliminate the discharge. Duke Energy requests the inclusion of the methodology for
determining the concentration to be reported in the DMR for Outfall 010.
• Seep Pollutant Analysis — Duke Energy requests the inclusion of clarifying language.in
the permit defining a seep that warrants further evaluation. Duke Energy requests the
following clarifying language be included in the permit:
"Seepage is considered to be the movement of wastewater from the ash basin through
the ash basin embankment, the embankment foundation, the embankment abutments,
through residual material in areas adjacent to the ash basin, or through the bottom of
the ash basin. Therefore, a seep is defined in this permit as an expression of seepage at
the ground surface above the ordinary high water mark of any waters of the state. Only
seeps that have the presence of a discernible, confined and discrete conveyance to the
surface water will be considered a new seep warranting further evaluation of flow and
pollutant characterization." Duke Energy requests the screening value of nitrate/nitrite
removed from Table 1. Duke Energy requests the screening values for arsenic and
selenium be revised to be 10 times the baseline concentration as with the other
parameters. Duke Energy requests the inclusion of clarifying language on the
notification requirements for newly identified seeps. The following language is
recommended:
"New seeps identified through the seep survey or otherwise discovered or reported to
the permittee shall have their flow calculated, and be sampled for
parameters indicated in Table 1. The location(s) of the seep shall be reported to Division
of Water Resources within 5 business days. Samples of the seep shall be collected within
10 business days of identification and the sampling results shall be submitted within 30
days of sampling for administrative inclusion in Appendix A."
• Outfall 011 -Duke Energy requests the removal of the monitor and report requirements
for arsenic, selenium, mercury, nitrate/nitrite as N, total phosphorus and total nitrogen
on Outfall 011. Duke Energy requests the removal of the turbidity requirements for
12

Outfall 011. Duke Energy requests the revision of the oil and grease (O&G) limits for
Outfall 011 to equal the (O&G) limits in the current ELG, which are a monthly average of
15 mg/L and a daily maximum of 30 mg/L. There was no justification stated for the
lower limits in the permit or Fact Sheet. Duke Energy requests the revision of the total
suspended solids (TSS) limits for Outfall 011 to equal the TSS limits in the current ELG,
which are a monthly average of 30 mg/L and a daily maximum of 100 mg/L. There was
no justification for the lower limits in the permit or Fact Sheet. Duke Energy requests
the removal of footnote 2 from Outfall 011. There are no copper and iron limits imposed
on this outfall and there are no chemical metal cleaning wastewater discharged to this
outfall.
• Outfall 002A (Yard Sump Overflow) - Duke Energy requests the removal of the copper
and iron limits on Outfall 002A.,There was no justification within the permit or Fact
Sheet for these limits.
• Nonchemical Metal Cleaning Wastewater -Duke Energy requests the inclusion of
language defining nonchemical metal cleaning wastewater as low volume wastewater
and only subject to the low volume wastewater limits of O&G and TSS:
Chronic Toxicity - The permit contains conflicting effluent concentrations at which the
chronic toxicity test should be conducted. On page 8 of 15, the effluent chronic toxicity
is listed at 2.7%; however, for footnote 4 under Outfall 002 (ash basin discharge) page 4
of 15 and (dewatering), page 5 of 15, the effluent concentration is listed as 10%.
The -following is a summary of comments received from the Sierra Club:
• The Department proposes to permit the discharge of pollutants from illegal seeps in
violation of the Clean Water Act.
Response: The inclusion of the seeps into the NPDES permit is based on the provisions
of the Coal Ash Management Act of 2014 (CAMA). § 130A-309.210 of the Coal Ash
Management Act of 2014 requires owners of coal combustion residuals surface
impoundments to identify and assess all discharges from the impoundments and to
implement corrective action to prevent unpermitted discharges from the
impoundments to the surface waters of the state. Identification of discharges
includes engineered channels designed or improved for the purpose of collecting
water from the toe of the impoundment (toe drains), as well as non -engineered seeps
and weeps. One method of proposed corrective action allowed under the Act is to
make application for a National Pollutant Discharge Elimination System (NPDES)
permit amendment to bring the unpermitted discharge under permit regulations. A
Discharge Assessment Plan for the unpermitted discharges at the Marshall Steam
Station was submitted by Duke Energy to the Department on December 30, 2014.
Under the permit, the seeps would be monitored and subject to applicable effluent
13

limits which will ensure that seep discharges will not result in unacceptable impacts to
surface waters. Incorporation of the seeps into the NPDES permit is considered an
interim measure until the coal ash impoundments are closed. The draft permit
requires that the facility continue to implement a plan for the identification of new
seeps. A seep identification survey shall be conducted semi-annually and new seeps
are to be reported to the Division within five days of detection. The DWR has been
consulting with EPA in regard to the incorporation of the seeps into the NPDES
wastewater permits.
• Seeps, leaks or other structural issues should be addressed directly with sound
engineering solutions, i.e., removal of all coal ash�for reuse or stored in adequately lined
landfill.
Response: §130A-309.213 of the Act required the department to develop a proposed
classification system for all coal combustion residuals surface impoundments,
including active and retired sites. §130A-309.214 requires owners of coal combustion
residual surface impoundments to submit a proposed closure plan for the
Departments approval. High-risk impoundments shall be closed no later than
December 31, 2019, intermediate -risk impoundments shall be closed no later than
December 31, 2024, and low-risk impoundments shall be closed no later than
December 31, 2029.
• Limits that the Department has proposed are inadequate. Permits do not set any limits
on the discharge of cobalt, boron, strontium, zinc and a variety of harmful pollutants.
Proposed monitoring frequencies are inadequate.
Response: The sampling requirements in the draft NPDES permit are based on the
state and federal rules, regulations, and policies. The state conducts a Reasonable
Potential Analysis (RPA) to determine the need for monitoring or a limit for a
particular constituent. RPA is the statistical analysis of the effluent data that was
approved by EPA. The RPA is conducted on the 126 parameters in the renewal/major
modification application. The RPA is conducted on the parameters that are above
detection level and have appropriate state water quality standard/EPA criteria. The
majority of the parameters in the renewal applications are below detection level.
• Draft permits should be revised to include numeric effluent limits that are based on best
available technology for all pollutants discharged into receiving waterways.
Response: The sampling requirements in the draft NPDES permit is based on the state
and federal rules, regulations, and policies. The state conducts a Reasonable Potential
Analysis (RPA) to determine the need for a monitoring or limit for a particular
constituent. RPA is the statistical analysis of the effluent data that was approved by
EPA. The RPA is conducted on the 126 parameters in the renewal/major modification
application. The RPA is conducted on the parameters that are above detection level
14

and have appropriate state water quality standard/EPA criteria. The majority of the
parameters in the renewal application are below detection level. Effluent limits and
monitoring for all pollutants of concern is not necessary to ensure that the pollutants
are adequately controlled because many of the pollutants originate from similar
sources, have similar treatabilities, and are removed by similar mechanisms. Because
of this, it may be sufficient to establish effluent limits for one pollutant as a surrogate
or indicator pollutant that ensures the removal of other pollutants of concern." The
permit also implements Best Practicable Technology Currently Available (BPT) as well
as BAT requirements of 40 CFR 423 Steam Electric Power Generating Point Source
Category.
The following is a summary of comments received from the Catawba Riverkeeper:
• In permitting seeps, the permit fails to identify specific wastewater streams, instead
collectively labeling random, untreated, uncontrolled wastewater streams as a single
outfall.
Response: The draft NPDES permit requires regular inspection for new seeps and
monitoring requirement for all identified seeps. The two identified seeps would be
monitored separately as Outfalls 101 and 102.
• .The permit fails to set limits on multiple parameters known to be of significant concern.
Response: The sampling requirements in the draft NPDES permit is based on the state
and federal rules, regulations, and policies. The state conducts a Reasonable Potential
Analysis (RPA) to determine the need for monitoring or a limit for a particular
constituent. RPA is the statistical analysis of the effluent data that was approved by
EPA. The RPA is conducted on the 126 parameters in the renewal/major modification
application. The RPA is conducted on the parameters that are above detection level
and have appropriate state water quality standard/EPA criteria. The majority of the
parameters in the renewal applications are below detection level.
• The permit fails to monitor at all for elements and chemicals we know to be associated
with coal ash ponds.
Response: The effluent limitations in the permit are established in accordance with
the existing federal and state rules and regulations. EPA has recently updated 40 CFR
423 and after reviewing parameters of concern established TBELs for several of these
parameters. The EPA decided that TBELs for all parameters of concern are not
necessary because "Effluent limits and monitoring for all pollutants of concern is not
necessary to ensure that the pollutants are adequately controlled because many of
the pollutants originate from similar sources, have similar treatabilities, and are
15

removed by similar mechanisms. Because of this, it may be sufficient to establish
effluent limits for one pollutant as a surrogate or indicator pollutant that ensures the
removal of other pollutants of concern."
• The permit fails to temporally and spatially monitor the site in an adequate manner.
Response: The monitoring requirements in the permit are based on the state and
federal rules, regulations, and policies. The established frequency is sufficient to
conduct a valid statistical analysis of the effluent data.
Duke should be required to reduce the impacts of thermal pollution from the facility,
and the facility should not be allowed a 316(a) temperature variance.
Response: In order to maintain the temperature variance the facility has to conduct
annual biological and chemical monitoring of the receiving stream to demonstrate
that it has a balanced and indigenous macroinvertebrate and fish community. The
latest BIP (balanced and indigenous population) report was submitted to DWR in
October of 2014. The DWR has reviewed the report and concluded that Lake Norman
near Marshall Steam Station has a balanced and indigenous macroinvertebrate and
fish community.
The following is a summary of comments received from the Southern Environmental Law
Center on behalf of the Catawba Riverkeeper Foundation, Inc., the Waterkeeper Alliance and
the Sierra Club.:
• The proposed permit violates North Carolina Groundwater Rules.
Response: While non -engineered seeps do have the potential to contaminate surface
water and groundwater, the draft NPDES permit requires groundwater monitoring be
conducted to determine compliance with current groundwater standards found under
15A NCAC 02L.0200. In accordance with 15A NCAC 02L.0104, the permit requires
that said monitoring wells be in place at the compliance boundary, such that the
groundwater within the designated area is sufficiently monitored.
Groundwater standard violations would be investigated and'regulated according to
15A NCAC 02L and the Coal Ash Management Act of 2014.
• The draft permit sets deficient technology-based effluent limits.
Response: The draft NPDES permit requires both TBEL limits and BAT limits in
accordance with 40 CFR 423 Steam Electric Power Generating Point Source Category.
The draft permit authorizes uncontrolled and unidentifiable leaks from lagoons in
violation of the Clean Water Act, and violates the public notice and comment and other
requirements of the clean water act.
16

Response: The inclusion of the seeps into the NPDES permit is based on the provisions
of the Coal Ash Management Act of 2014 (CAMA). § 130A-309.210 of the Coal Ash
Management Act of 2014 requires owners of coal combustion residuals surface
impoundments to identify and assess all discharges from the impoundments and to
implement corrective action to prevent unpermitted discharges from the
impoundments to the surface waters of the state. Identification of discharges
includes engineered channels designed or improved for the purpose of collecting
water from the toe of the impoundment (toe drains), as well as non -engineered seeps
and weeps. One method of proposed corrective action allowed under the Act is to
make application for a National Pollutant Discharge Elimination'System (NPDES)
permit amendment to bring the unpermitted discharge under permit regulations. A
Discharge Assessment Plan for the unpermitted discharges at the Marshall Steam
Station was submitted by Duke Energy to the Department on December 30, 2014.
Under the permit, the seeps would be monitored and subject to applicable effluent
limits which will ensure that seep discharges will not result in unacceptable impacts to
surface waters. Incorporation of the seeps into the NPDES permit is considered an
interim measure until the coal ash impoundments are closed. The draft permit
requires that the facility continue to implement a plan for the identification of new
seeps. A seep identification survey shall be conducted semi-annually and new seeps
are to be reported to the Division within five days of detection. The DWR has been
consulting with EPA in regard to the incorporation of the seeps into the NPDES
wastewater permits:
• The draft permit fails to set protective water quality based effluent limits.
Response: The Division conducted EPA -recommended analyses to determine the
reasonable potential for toxicants to be discharged at levels exceeding water quality
standards/EPA criteria by this facility from outfall 002 (Ash Pond). For the purposes of
the RPA, the background concentrations for all parameters were assumed to be below
detection level. The RPA uses 95% probability level and 95% confidence basis in
accordance with the EPA Guidance entitled "Technical Support Document for Water
Quality -based Toxics Control."
Calculations included: As, Be, Cd, Chlorides, Cr, Cu, CN, Pb, Hg, Mo, Ni, Se, Ag, Zn, Al,
and B (please see attached). The renewal application listed 8.3 MGD as a current flow.
However, 11.44 MGD was used in the RPA as the highest reported flow during the last
permit cycle. The analysis indicates no reasonable potential to violate the surface
water quality standards or EPA criteria. The water -quality based limits for selenium
were removed from the permit (Outfall 002) based on the results of Reasonable
Potential Analysis.
The Division also considered data for other parameters of concern in the EPA Form 2C
that the facility submitted for the renewal. The majority of the parameters were not
detected in the discharge. The -Division reviewed the following parameters that were
17

detected in the discharge and have an applicable state standards or EPA criteria for
Class WS -IV stream: phenols. This parameter was well below -the state standard.
An RPA was also conducted for the combined flow from the seeps (Outfalls 101 and
102). The analysis was based on the dilution in the receiving stream since the effluent
channels were delineated for both seeps. Although one seep was not flowing at the
time of the sampling, it was assumed that it might discharge during the wet season.
Calculations included: As, Cd, Chlorides, Cr, Cu, F, Pb, Hg, Mo, Ni, Se Zn, SOa, Al, Ba, B,
Sb, and TI (please see attached). The analysis indicates no reasonable potential to
violate the water quality standards or EPA criteria. The flow volume for the first seep
was measured at 0.0019 MGD. However, the flow of 0.5 MGD was used for the RPA to
incorporate a safety factor, account for potential new seeps that might emerge in the
future or increase in flow volume at the existing seeps.
In conclusion, the RPA analysis indicates that existing discharges from the facility
outfalls and seeps will not cause contravention of the state water quality standards/
o, EPA criteria.
• The proposed permit violates the Clean Water Act's anti -backsliding provisions.
Response: Anti -backsliding provisions are applicable to the TBEL limits, none of the
TBEL limits in the proposed permit are less stringent than in the previous limits.
• The proposed permit violates the Clean Water Act's anti -backsliding provisions.
Response: Anti -backsliding provisions are applicable to the TBEL limits, none of the
TBEL limits in the proposed permit are less stringent than in the previous limits.
• The draft permit sets inadequate monitoring requirements for seeps.
Response: The monitoring requirements in the permit are based on the state and
federal rules, regulations, and policies. The established frequency is sufficient to
conduct a valid statistical analysis of the effluent data.
The following is a summary of comments received from the Neuse Riverkeeper Foundation:
• The pollution limits in the permits are too weak.
Response: The effluent limitations in the permit are established in accordance with the
existing federal and state rules and regulations. EPA has recently updated 40 CFR 423
and after reviewing parameters of concern established TBELs for several of these
parameters. The EPA decided that TBELs for all parameters of concern are not
necessary because "Effluent limits and monitoring for all pollutants of concern is not
necessary to ensure that the pollutants are adequately controlled because many of
18

the pollutants originate from similar sources, have similar treatabilities, and are
removed by similar mechanisms. Because of this, it may be sufficient to establish
effluent limits for one pollutant as a surrogate or indicator pollutant that ensures the
removal of other pollutants of concern."
• Permitting the leaks violates the Clean Water Act.
Response: The inclusion of the seeps into the NPDES permit is based on the provisions
of the Coal Ash Management Act of 2014 (CAMA). § 130A-309.210 of the Coal Ash
Management Act of 2014 requires owners of coal combustion residuals surface
impoundments to identify and assess all discharges from the impoundments and to
implement corrective action to prevent unpermitted discharges from the
impoundments to the surface waters of the state. Identification of discharges
includes engineered channels designed or improved for the purpose of collecting
water from the toe of the impoundment (toe drains), as well as non -engineered seeps
and weeps. One method of proposed corrective action allowed under the Act is to
make application for a National Pollutant Discharge Elimination System (NPDES)
Permit amendment to bring the unpermitted discharge under permit regulations. A
Discharge Assessment Plan for the unpermitted discharges at the Marshall Steam
Station was submitted by Duke Energy to the Department on December 30, 2014.
Under the permit, the seeps would be monitored and subject to applicable effluent
limits which will ensure that seep discharges will not result in unacceptable impacts to
surface waters. Incorporation of the seeps into the NPDES permit is considered an
interim measure until the coal ash impoundments are closed. The draft permit
requires that the facility continue to implement a plan for the identification of new
seeps. A seep identification survey shall be conducted semi-annually and new seeps
are to be reported to the Division within five days of detection. The DWR has been
consulting with EPA in regard to the incorporation of the seeps into the NPDES
wastewater permits.
IV. June 22, 2016, Public Hearing and Comments Summary
A second public hearing was held on June 22, 2016, at 6:00 pm, at the Catawba Valley
Community College East Wing Auditorium, at 2550 Highway 70 Southeast, in Hickory, NC. The
purpose of the public hearings was to allow the public to comment on the draft NPDES
wastewater permit for Duke Energy Carolinas, LLC's Marshall Steam Station.
Notice of the hearing (Attachment E.) was published in the Hickory Daily Record on May 22,
2016, and in the Charlotte Observer on May 19, 2016. Additionally, a news release of the
Notice was issued on May 17, 2016, and publication of this notice was posted on the DEQ
website. The public comment period closed on June 22, 2016.
19

,Approximately 16 people attended the public hearing including 10 staff members of the
Division of Water Resources and the hearing officer. A total of 6 individuals signed the
attendance sign in sheets at the hearing (Attachment F). The hearing officer provided opening
comments and Sergei Chernikov, Ph.D., with the Division of Water Resources gave a brief
overview of the draft NPDES wastewater permit. One individual registered in advance of the
hearing to provide oral comments and indicated that she was representing the Sierra Club.
The speaker list is also included as Attachment F.
The following is a summary of the comments received at the public hearing.
• Draft permit would allow polluted pond water to continue to leak into Lake Norman and
into North Carolina's groundwater.
• Removing coal ash and contaminated water is the only way to protect our waterways.
• Proposed permit violates the Clean Water Act and North Carolina's groundwater rules.
• Permit gives Duke more than two years to of extra time before is must meet new limits
for scrubber wastewater.
Response: § 130A-309.210 of the Coal Ash Management Act (CAMA) of 2014 requires
owners of coal combustion residuals surface impoundments to identify and assess all
discharges from the impoundments and to implement corrective action to prevent
unpermitted discharges from the impoundments to the surface waters of the state.
Identification of discharges includes engineered channels designed or improved for
the purpose of collecting water from the toe of the impoundment (toe drains), as well
as non -engineered seeps and weeps. One method of proposed corrective action
allowed under the Act is to make application for a National Pollutant Discharge
Elimination System (NPDES) permit amendment to bring the unpermitted discharge
under permit regulations. A Discharge Assessment Plan for the unpermitted
discharges at the Marshall Steam Station was -submitted by Duke Energy to the
Department on December 30, 2014. The facility identified two unpermitted seeps (all
non -engineered) from the ash settling basin. Under the draft NPDES Permit, both
seeps are considered to be discharging through delineated Effluent Channels. The
Effluent Channels were delineated by DWR staff on May 4, 2016, in accordance with
15A NCAC 0213.0228. The draft permit requires the permittee to demonstrate that
water quality standards in the receiving stream are not contravened. This
demonstration must be submitted to the Division no later than 180 days from the
effective date of the permit.
§130A-309.213 of the Act required the department to develop a proposed
classification system for all coal combustion residuals surface impoundments,
20

including active and retired sites. §130A-309.214 requires owners of coal combustion
residual surface impoundments to submit a proposed closure plan for the
Departments approval. High-risk impoundments shall be closed no later than
December 31, 2019, intermediate -risk impoundments shall be closed no later than
December 31, 2024, and low-risk impoundments shall be closed no later than
December 31, 2029.
The NPDES Permit for Marshall Steam station has been developed in accordance with
the existing federal and state rules and regulations. The Permit conditions are
established to provide compliance with the water quality standards in the receiving
stream.
The extended deadlines for Compliance with the New Effluent Limitations have been
established in accordance with the 40 CFR 423. Duke provided justification for the
compliance schedule, which is well within authorized by the federal rule. .
�`Q.
' l/" L J t
The public hearing#ipt including oral comments is included as Attachment D.
In addition to the public hearing, DWR received 127 written comments via email during the
public comment period. Those comments are included as Attachment C.
125 of the email comments were received using the following form letter email:
Duke Energy's Marshall coal plant has polluted our lakes and rivers for decades. The
proposed permit, which would authorize Duke to continue operating the leaky ash pond
at the plant and to continue discharging contaminated pond water through seeps into
Lake Norman, violates the Clean Water Act and North Carolina's groundwater rules. The
release of coal ash pollution into our waterways puts public health and the environment
at risk.
In addition, the proposed permit would give Duke more than two years of extra time
before it must meet new limits on the discharge of scrubber wastewater. Duke Energy -
has had more than enough time to plan for how to deal with its toxic waste streams. It is
time for the company to stop fouling the waters of our state.
Therefore, I request that DEQ revise the permit so that it protects the waters of our state
from Duke Energy's toxic coal plant pollution.
Response: § 130A-309.210 of the Coal Ash Management Act (CAMA) of 2014 requires
owners of coal combustion residuals surface impoundments to identify and assess all
discharges from the impoundments and to implement corrective action to prevent
unpermitted discharges from the impoundments to the surface waters of the state.
Identification of discharges includes engineered channels designed or improved for
the purpose of collecting water from the toe of the impoundment (toe drains), as well
as non -engineered seeps and weeps. One method of proposed corrective action
21

1.
allowed under the Act is to make application for a National Pollutant Discharge
Elimination System (NPDES) permit amendment to bring the unpermitted discharge
under permit regulations. A Discharge Assessment Plan for the unpermitted
discharges at the Marshall Steam Station was submitted by Duke Energy to the
Department on December 30, 2014. The facility identified two unpermitted seeps (all
non -engineered) from the ash settling basin. Under the draft NPDES Permit, both
seeps are considered to be discharging through delineated Effluent Channels. The
Effluent Channels were delineated by DWR staff on May 4, 2016, in accordance with
15A NCAC 02B .0228. The draft permit requires the permittee to demonstrate that
water quality standards in the receiving stream are not contravened. This
demonstration must be submitted to the Division no later than 180 days from the
effective date of the permit.
The extended deadlines for Compliance with the New Effluent Limitations have been
established in accordance with the 40 CFR 423. Duke provided justification for the
compliance schedule, which is well within authorized by the federal rule.
The following is a summary of comments received from the Southern Environmental Law
Center on behalf of the Catawba Riverkeeper Foundation, Inc., the Sierra Club and the
Waterkeeper Alliance:
1. Permitting Waters of the United States as "effluent channels" violates the Clean
Water Act and North Carolina Law.
Response: The Effluent Channels at the Marshall Steam Station have been
delineated in accordance with the requirements of 15A NCAC 02B .0228. The EPA
and USACOE did not object to this action.
2. The draft permit fails to account for discharges of wastewater through hydrologically
connected groundwater.
Response: The NPDES program regulates point source discharges to the Waters of
the US, the infiltration of the wastewater to the groundwater does not fit the
definition of the point source discharge. The groundwater contamination is being
regulated under a separate program within DWR.
3. The Department cannot issue a permit to a facility that is violating surface water
standards.
Response: The NPDES Permit for Marshall Steam station has been developed in
accordance with the existing federal and state rules and regulations. The Permit
conditions are established to provide compliance with the water quality standards
in the receiving stream.
22

4. The Reasonable Potential Analysis is inadequate.
Response: he Reasonable Potential Analysis (RPA) has been conducted in
compliance with the CWA. The RPA uses 95% probability level and 95% confidence
basis in accordance with the EPA Guidance entitled "Technical Support Document
for Water Quality -based Toxics Control." The RPA procedure has been approved by
EPA. The downstream analysis of the water in the receiving stream does not
indicate violations of the water quality standards.
5. The draft permit violates its own permit term —the Removed Substances Provision.
Response: The disposal of the coal ash in wet lagoons has been authorized by the
EPA in accordance with the CWA. New federal regulations will gradually phase out
the use of coal ash lagoons.
6. The draft permit violates requirements applicable to critical areas.
Response: The MCL levels for Sb, As, Ba, Be, Cd, Cr, Cu, CN, F, Pb, Hg, NO3i NO2, Se,
and TI have been established by EPA and are applicable to the Critical Area of the
receiving stream. Most of these parameters (Hg, As, Cd, Cr, Cu, Se, Pb, NO3) have
been sampled downstream of the discharge location. The instream-sampling
indicate that most parameters are below detection level, the rest are below water
quality standard. The only parameter that exceeds the MCL is NO3. However, the
effluent monitoring data shows that concentration of nitrate in the ash pond
discharge is well below MCL. Therefore, exceedance of MCL can be attributed to
other point and non -point sources of pollution.
7. The Department cannot justify extended deadlines for compliance with new effluent
limitations.
Response: The extended deadlines for Compliance with the New Effluent
Limitations have been established in accordance with the 40 CFR 423. Duke
provided justification for the compliance schedule, which is well within that
authorized by the federal rule.
8. The effluent limitations in the proposed permit are too weak.
Response: The effluent limitations in the permit are established in accordance with
the existing federal and state rules and regulations. EPA has recently updated 40
CFR 423 and after reviewing parameters of concern established TBELs for several
of these parameters. The EPA decided that TBELs for all parameters of concern are
not necessary because "Effluent limits and monitoring for all pollutants of concern
is not necessary to ensure that the pollutants are adequately controlled because
many of the pollutants originate from similar sources, have similar treatabilities,
and are removed by similar mechanisms. Because of this, it may be sufficient to
23

establish effluent limits for one pollutant as a surrogate or indicator pollutant that
ensures the removal of other pollutants of concern."
The SELC mistakenly concluded that the dewatering stage for outfall 002 includes
TBEL for As. However, this is a water -quality based limit, it has been established in
accordance with the results of RPA.
The SELC also suggests that more monitoring for seeps is needed. The combined
seep discharge represents less than 0.02% of the discharge from the ash pond.
This is a miniscule contribution to the overall discharge from the facility and the
monitoring frequency is adequate to evaluate its impact. In addition, the EPA has
approved the monitoring frequency for seeps.
The following is a summary of comments received from Duke Energy.
1. Comments on Draft Permit Section A. (2.) Effluent Limitations and Monitoring
Requirements (Outfall 002 -normal operations)
• In the DRAFT Permit, the monitoring frequency for arsenic and mercury is
"weekly," in contrast to the "quarterly" monitoring frequency in the current
permit. Historical monitoring data do not indicate that the discharge from
Outfall 2 has caused problems with arsenic and mercury in the receiving
stream, and the reasonable potential analysis ("RPA") demonstrates the
discharge will not cause contravention of the water quality criteria for either
of these constituents. Given that more frequent monitoring is not necessary
to address an immediate concern, Duke Energy requests the sampling
frequency be returned to "quarterly". If NCDEQ feels that more frequent
monitoring is needed, Duke Energy would not object to "monthly" sampling.
Response: The monitoring frequency for As, Hg, were increased to address
EPA comments. The Division is unable to grant request from Duke for a
monitoring frequency reduction.
• The DRAFT Permit requires chronic toxicity testing "monthly" during normal
operations, contrasted with "quarterly" in the current permit. Historical data do not
indicate that chronic toxicity is a concern during normal operations, and Duke
Energy requests that the monitoring frequency be changed to a "quarterly"
requirement during normal operations.
Response: The monitoring frequency for toxicity testing was included as monthly
to address EPA comments. The Division is unable to grant request from Duke for a
monitoring frequency reduction.
24
w

1
• Duke Energy requests that the language in Note 2 be clarified to state that
continuous monitoring of Total Suspended Solids ("TSS") is only required when
decanting via pumps. As written, the permit could be interpreted to require
continuous TSS monitoring during normal operations not involving pumping from
the ash basin.
Response: The Division will add clarifying language for TSS continual monitoring in
the Final Permit.
• Duke Energy requests re-insertion of Note 2 from the existing permit related to TSS.
The existing footnote reads: "A total suspended solids average of 40 mg/L is
permitted provided the permittee can demonstrate that the difference between the
monthly average of 20 mg/L and 40 mg/L is the result of the concentration of total
suspended solids in the intake water."
Response: The Division is unable to re-insert the Note 2 from the previous Permit.
This change was made to address the EPA comment.
• Duke Energy requests that language on page 5 be amended as follows: "The facility
is allowed to drawdown the wastewater in the ash d settling basin to no less
than three feet above the ash at the pump intake location under this section.
Lowering the level below the three feet mark triggers the limits and conditions in
Section A. (3) of this permit. Without this clarification, the permit could be
misinterpreted to prevent Duke from ever undertaking the work authorized in
Section A. (3).
Response: The Division will add clarification to the drawdown language in the Final
Permit.
• Duke Energy requests that the language on page 5 be clarified to state that the zero
discharge limits on fly ash and bottom ash transport water only applies to fly ash
and bottom ash transport water generated after November 1, 2018 and January 31,
2021. Fly ash and/or bottom ash transport water generated prior to these dates and
stored in the ash basins is classified as "legacy wastewater" under the Steam Electric
Effluent Limitations Guidelines (ELG) Rule. As stated in the rule, legacy wastewater is
not subject to the same limits. We believe the intent of the permit is to allow
continued discharges from the ash basin afterthe effective dates but to require zero
discharge of new fly ash transport water after 2018 and of bottom ash transport
water after 2021. To address this concern, Duke Energy suggests either adding
additional definitions to Section A.(10.) or making the following clarifications on
page 5:
25

o The zero discharge limit of fly ash transport water only applies to fly ash
transport water generated after November 1, 2018.
o The zero discharge limit of bottom ash transport water only applies to
bottom ash transport water generated after January 31, 2021.
Response: The Division will add clarification regarding fly ash and bottom ash
transport water in the Final Permit.
Comments on Draft Permit Section A. (3) Effluent Limitations and Monitoring
Requirements (Outfall 002 -dewatering phase)
• The DRAFT Permit sets a flow limit at 1.0 million gallons per day (MGD). Duke Energy
requests the flow limit be removed and only require monitor and report. Flows during
dewatering will be lower than flows during decanting, for which Section A.(2) does
not set a daily limit. Dewatering is already subject to a limit on drawdown of 1 ft/week
for dam safety purposes.
Response: The flow limit for the dewatering phase was added to address the EPA
comment. The Division is unable to remove it.
Comments on Draft Permit Section A. (7.) Effluent Limitations and Monitoring
Requirements (Internal Outfall 004)
• As written, the Discharge Limitation on Total Mercury in this section is not subject
to Note 4, probably due to a typographical error. Duke Energy requests the
addition of a Note 4 superscript to the total mercury limits in the permit limit
table to clarify that limits on total mercury are also effective on January 31, 2021.
Response: The Division will correct this error in the Final Permit.
4. Comments on Draft Permit Sections A. (8.) and A. (9.) Effluent Limitations and
Monitoring Requirements (Outfall 101 and 102)
• Duke Energy requests that Note 3 be amended to state that a measurement of pH
lower than 6.0 or higher than 9.0 is not a violation of the permit limits. As a result
of the hydro geochemistry involved in the migration of ash basin seepage through
groundwater, the pH of water measured at Outfalls 101 and 102 will not always
be representative of the seep flow discharge from the ash basin. Water in the ash
basin consistently discharges between 6.0 and 9.0, but natural conditions,
including contributions from stormwater, in the vicinity of the ash basin can result
in lower pHs measured at the Outfalls. As long as discharges from the ash basin at
Outfall 002 remain between 6.0 and 9.0, lower pHs at Outfalls 101 and 102 could
be considered unrepresentative samples.
Response: The Division is unable to change pH requirements in the Permit; this is a
statutory requirement.
26

• Similarly, Duke Energy requests that a note be added to state that TSS levels due to
conditions of the sampling area (sediment entrainment) should be considered an
unrepresentative sample since a seep flow from the Ash Basin would not carry TSS
levels in excess of 30 mg/I.
Response: The Division believes that existing language regarding low flow
condition already addresses the issue of the excessive sample turbidity.
• Duke Energy requests the removal of the monitoring and reporting requirements
for Total Iron, Total Manganese and Conductivity. There are no surface water
quality standards associated with these parameters; therefore, it is unnecessary
to conduct monitoring and report for these parameters.
Response: The Division believes that monitoring for Fe, Mn, and conductivity is
necessary to evaluate the hydrogeological conditions at the site, .detect changes
caused by the decanting and dewatering, and determine the source of the seep.
5. Comments on Draft Permit Section A. (10.) ADDITIONAL CONDITIONS AND
DEFINITIONS
• Duke Energy requests the inclusion of the following statement based on the
historical permitting of non -chemical metal waste without limits for copper and
iron: "Non -chemical metal cleaning wastewater will be treated as 'low volume
waste' subject only to TSS and oil and grease limits based on the historical
permitting of non -chemical metal cleaning wastewater."
Response: The Division is unable to grant this request, all the definitions in the
Permit are based on the 40 CFR 423 and have been approved by EPA.
6. Comments on Draft Permit Section A. (17.) Chronic Toxicity Pass/Fail Permit Limit
• The DRAFT Permit establishes the chronic toxicity effluent concentration of 23%
for Outfall 002, changed from 12% in the current permit. Duke Energy requests
this to be changed to 18% based on the instream wastewater concentration (IWC)
reported in the Fact Sheet and the minimum flow release of Cowens Ford dam of
80 cubic feet per second (cfs). See additional comments on the minimum flow
release below.
Response: The Division is unable to grant the request regarding the IWC. The IWC
is based on the flow data reported on the DMR and the historic stream flow data.
• The DRAFT Permit establishes the chronic toxicity requirement for dewatering
and references Part I, Section A. (17.), which sets a chronic toxicity effluent
27

f,
concentration of 23.0%. The RPA for dewatering was conducted at a flow of
1.0 MGD and the DRAFT Permit sets a flow limit of 1.0 MGD. Therefore, the
chronic toxicity effluent concentration for dewatering should be set at an
appropriate level based on RPA calculations (Ex. 2.0% based on a flow of 1.0
MGD and a 7Q10s of 80 cfs or 3.7% based on a flow of 2.0 MGD and a 7Q10s
of 80 cfs).
Response: The Division will add a separate IWC for dewatering phase in the Final
Permit.
7. Comments on Draft Permit Section A. (30.) Seep Pollutant Analysis
• Duke Energy appreciates that the approach of this section is based on the model
developed for the Riverbend NPDES permit. However, the circumstances at
Marshall are different because, as stated in the Draft Permit, Marshall's two
existing seeps, S-1 and S-2, have been designated as Effluent Channels, and both
are included as outfalls in the draft permit. Because water quality standards do
not apply in Effluent Channels, as stated in 15A NCAC 213 .0200, there is no need to
determine compliance with water quality standards in the channels themselves.
Because both discharge to the Catawba River, the RPA performed for the permit
should be sufficient to demonstrate that water quality standards in the receiving
stream are not contravened, as required in subparagraph 3. As a result, there is no
further work to be done with respect to the existing seeps required by Section
A.(30). Duke Energy proposes to revise this section so that it applies only to New
Identified Seeps.
Response: The Division is unable to grant this request, the text of this condition
has been approved by EPA.
8. Comments on Attachment 1: Groundwater Monitoring Plan
• Please add the following clarifying language to the permit:
"3(h). The provisions of sections 3(f) and 3(g) apply only to the sampling events
described in 3(b) above. The reporting requirements for any sampling events
other than those described in 3(b) above shall be in accordance with the general
provisions of 15A NCAC 02L."
Response: Agree. We will add to the language in the Groundwater Monitoring
Plan.
• Additionally, Duke requests that the GW59CCR form submittal date be 60 days
after sampling in lieu of 45 days.
28

la
Response: Disagree. We believe that 45 days is ample time to submit sampling
data, and is consistent with other coal ash facilities that have been recently
renewed.
9. Comments on Fact Sheet
• The Fact Sheet states that the summer 7Q10 flow of 60 cubic feet per second
(cfs) is based on the minimum release from the dam that regulates the receiving
water body (Cowens Ford). However, based on the issued Catawba-Wateree
operating license, the minimum release from Cowens Ford is 80 cfs and the
minimum average daily release requirement is 311 cfs. In the recently issued
permit for McGuire Nuclear Station, the 7Q10 was set at 80 cfs. In addition, the
IWC reported in the Fact Sheet is 18%, which corresponds to a flow of 11.44
MGD and 7Q10 of 80 cfs. Duke request the 7Q10 reflect the minimum release
from Cowan's Ford Dam stated in the current Catawba-Wateree operating
license.
Response: The Division calculated the IWC based on the historic stream flow
data. The IWC in the fact sheet is a typo, the correction will be made in the
Final Permit.
V. Recommendations
Based on the review of the public record, written and oral public comments, the North
Carolina General Statutes and Administrative Code, the'Coal Ash Management Act of
2014, the site visit -and discussions with other DWR staff, I recommend to the Division
Director that the draft NPDES permit for the Marshall Steam Station be modified and
issued with the following minor changes:
1. Clarifying language should be added to the permit in Section A. (2). Note 2 should
be clarified to state that continuous monitoring of Total Suspended Solids ("TSS") is
only required when decanting via pumps. As written, the permit could be
interpreted to require continuous TSS monitoring during normal operations not
involving pumping from the ash basin.
2. Clarifying language should be added to the permit in Section A. (2), Page 5 to
specify that limits and conditions in Section A. (3) of the permit apply when water
in the ash settling basin is lowered below the three feet trigger mark.
3. Clarifying language should be added to the permit in Section A. (2), Page 5 to
specify that the zero discharge limits on fly ash and bottom ash transport water
only applies to fly ash and bottom ash transport water generated after November
1, 2018 and January 31, 2021.
99

4. Section A. (7) should include addition of a Note 4 superscript to the total mercury
limit to clarify that limits are effective on January 31, 2021.
5. Section A. (17) should include a separate IWC for dewatering phase toxicity testing.
The Groundwater Monitoring Plan attachment should include the following
clarifying language: "3(h). The provisions of sections 3(f) and 3(g) apply only to
the sampling events described in 3(b) above. The reporting requirements for any
sampling events other than those described in 3(b) above shall be in accordance
with the general provisions of 15A NCAC 02L."
Vle Attachments
A. NPDES Application
B. Draft Permit and Fact Sheet
C. Written Comments Received During Public Comment Period
D. Public Hearing Transcript, Including Oral Comments
E. Notice of Public Hearing
F. Speaker Sign -in Sheets
G. Non -speaker Sign -in Sheets
30

(> DUKE
ENERGY
June 22, 2016
North Caroljrfa Department of
Environ/ental Quality
Divisi ri of Water Resources
Att : Wastewater Permitting
17 Mail Service Center
Raleigh, NC 27699-1617
Subject: Comments on the DRAFT NPDES Permit
Marshall Steam Station
Permit No.: NC0004987
Catawba County
Wastewater Permitting Staff:
Harry Sideris
Senior Vice President
Environmental, Health and Safety
Duke Energy
526 South Church Street
Charlotte, NC 28202
Mailing Address:
Mail Code EC131</ P.O. Box 1006
RECEIVEDINCDEWWR
JUN 2 4 2016
Water Quality
Permitting Section
Duke Energy Carolinas, LLC submits the following comments on the draft National Pollutant Discharge
Elimination System Permit for Marshall Steam Station, issued for public comment by the North Carolina
Department of Environmental Quality ("NCDE(X") on May 17, 2016. Duke Energy appreciates NCDEQ's
efforts to develop the Draft Permit, which addresses novel issues associated with surface impoundment
decommissioning. Duke Energy continues to work toward closing Marshall's surface impoundments,
and finalizing this wastewater permit is a critical step to advance that process by authorizing decanting
and dewatering. The company further agrees with the conclusion stated in the draft permit that
discharges from the facility's outfalls will not cause contravention of the state water quality standards in
the receiving waters. In addition to these general comments, Duke Energy offers the following
comments on specific provisions of the Draft Permit:
1. Comments on Draft Permit Section A. (2.) Effluent Limitations and Monitoring Requirements
(Outfall 002 -normal operations)
In the DRAFT Permit, the monitoring frequency for arsenic and mercury is "weekly," in contrast
to the "quarterly" monitoring frequency in the current permit. Historical monitoring data do
not indicate that the discharge from Outfall 2 has caused problems with arsenic and mercury in
the receiving stream, and the reasonable potential analysis ("RPA") demonstrates the discharge
will not cause contravention of the water quality criteria for either of these constituents. Given
that more frequent monitoring is not necessary to address an immediate concern, Duke Energy
requests the sampling frequency be returned to "quarterly". If NCDEQ feels that more frequent
monitoring is needed, Duke Energy would not object to "monthly" sampling.

Page 12
• The DRAFT Permit requires chronic toxicity testing "monthly" during normal operations,
contrasted with "quarterly" in the current permit. Historical data do not indicate that chronic
toxicity is a concern during normal operations, and Duke Energy requests that the monitoring
frequency be changed to a "quarterly" requirement during normal operations.
• Duke Energy requests that the language in Note 2 be clarified to state that continuous
monitoring of Total Suspended Solids ("TSS") is only required when decanting via pumps. As
written, the permit could be interpreted to require continuous TSS monitoring during normal
operations not involving pumping from the ash basin.
• Duke Energy requests re-insertion of Note 2 from the existing permit related to TSS. The existing
footnote reads: "A total suspended solids average of 40 mg/L is permitted provided the
Permitee can demonstrate that the difference between the monthly average of 20 mg/L and 40
mg/L is the result of the concentration of total suspended solids in the intake water."
• Duke Energy requests that language on page 5 be amended as follows: "The facility is allowed
to drawdown the wastewater in the ash pend settling basin to no less than three feet above the
ash at the pump intake location under this section. Lowering the level below the three feet
mark triggers the limits and conditions in Section A.(3) of this permit." Without this
clarification, the permit could be misinterpreted to prevent Duke from ever undertaking the
work authorized in Section A.(3).
• Duke Energy requests that the language on page 5 be clarified to state that the zero discharge
limits on fly ash and bottom ash transport water only applies to fly ash and bottom ash
transport water generated after November 1, 2018 and January 31, 2021. Fly ash and/or
bottom ash transport water generated prior to these dates and stored in the ash basins is
classified as "legacy wastewater" under the Steam Electric Effluent Limitations Guidelines (ELG)
Rule. As stated in the rule, legacy wastewater is not subject to the same limits. We believe the
intent of the permit is to allow continued discharges from the ash basin after the effective dates
but to require zero discharge of new fly ash transport water after 2018 and of bottom ash
transport water after 2021. To address this concern, Duke Energy suggests either adding
additional definitions to Section A.(10.) or making the following clarifications on page 5:
o The zero discharge limit of fly ash transport water only applies to fly ash transport water
generated after November 1, 2018.
o The zero discharge limit of bottom ash transport water only applies to bottom ash
transport water generated after January 31, 2021.
2. Comments on Draft Permit Section A. (3) Effluent Limitations and Monitoring Requirements
(Outfall 002 -dewatering phase)
• The DRAFT Permit sets a flow limit at 1.0 million gallons per day (MGD). Duke Energy requests
the flow limit be removed and only require monitor and report. Flows during dewatering will be
lower than flows during decanting, for which Section A.(2) does not set a daily limit. Dewatering
is already subject to a limit on drawdown of 1 ft/week for dam safety purposes.

Page 13
3. Comments on Draft Permit Section A. (7.) Effluent Limitations and Monitoring Requirements
(Internal Outfall 004)
• As written, the Discharge Limitation on Total Mercury in this section is not subject to Note 4,
probably due to a typographical error. Duke Energy requests the addition of a Note 4
superscript to the total mercury limits in the permit limit table to clarify that limits on total
mercury are also effective on January 31, 2021.
4. Comments on Draft Permit Sections A. (8.) and A.(9.) Effluent Limitations and Monitoring
Requirements (Outfall 101 and 102)
• Duke Energy requests that Note 3 be amended to state that a measurement of pH lower than
6.0 or higher than 9.0 is not a violation of the permit limits. As a result of the
hydrogeochemistry involved in the migration of ash basin seepage through groundwater, the pH
of water measured at Outfalls 101 and 102 will not always be representative of the seep flow
discharge from the ash basin. Water in the ash basin consistently discharges between 6.0 and
9.0, but natural conditions, including contributions from stormwater, in the vicinity of the ash
basin can result in lower pHs measured at the Outfalls. As long as discharges from the ash basin
at Outfall 002 remain between 6.0 and 9.0, lower pHs at Outfalls 101 and 102 could be
considered unrepresentative samples.
• Similarly, Duke Energy requests that a note be added to state that TSS levels due to conditions
of the sampling area (sediment entrainment) should be considered an unrepresentative sample
since a seep flow from the Ash Basin would not carry TSS levels in excess of 30 mg/I.
• Duke Energy requests the removal of the monitoring and reporting requirements for Total Iron,
Total Manganese and Conductivity. There are no surface water quality standards associated
with these parameters; therefore, it is unnecessary to conduct monitoring and report for these
parameters.
5. Comments on Draft Permit Section A. (10.) ADDITIONAL CONDITIONS AND DEFINITIONS
• Duke Energy requests the inclusion of the following statement based on the historical
permitting of non -chemical metal waste without limits for copper and iron: "Non -chemical
metal cleaning wastewater will be treated as 'low volume waste' subject only to TSS and oil and
grease limits based on the historical permitting of non -chemical metal cleaning wastewater."
6. Comments on Draft Permit Section A. (17.) Chronic Toxicity Pass/Fail Permit Limit
• The DRAFT Permit establishes the chronic toxicity effluent concentration of 23% for Outfall 002,
changed from 12% in the current permit. Duke Energy requests this to be changed to 18%
based on the instream wastewater concentration (IWC) reported in the Fact Sheet and the
minimum flow release of Cowens Ford dam of 80 cubic feet per second (cfs). See additional
comments on the minimum flow release below.
• The DRAFT Permit establishes the chronic toxicity requirement for dewatering and references
Part I, Section A. (17.), which sets a chronic toxicity effluent concentration of 23.0%. The RPA
for dewatering was conducted at a flow of 1.0 MGD and the DRAFT Permit sets a flow limit of
1.0 MGD. Therefore, the chronic toxicity effluent concentration for dewatering should be set at

Page 14
an appropriate level based on RPA calculations (Ex. 2.0% based on a flow of 1.0 MGD and a
7Q10s of 80 cfs or 3.7% based on a flow of 2.0 MGD and a 7Q10s of 80 cfs).
7. Comments on Draft Permit Section A. (30.) Seep Pollutant Analysis
• Duke Energy appreciates that the approach of this section is based on the model developed for
the Riverbend NPDES permit. However, the circumstances at Marshall are different because, as
stated in the Draft Permit, Marshall's two existing seeps, S-1 and S-2, have been designated as
Effluent Channels, and both are included as outfalls in the draft permit. Because water quality
standards do not apply in Effluent Channels, as stated in 15A NCAC 2B .0200, there is no need to
determine compliance with water quality standards in the channels themselves. Because both
discharge to the Catawba River, the RPA performed for the permit should be sufficient to
demonstrate that water quality standards in the receiving stream are not contravened, as
required in subparagraph 3. As a result, there is no further work to be done with respect to the
existing seeps required by Section A.(30). Duke Energy proposes to revise this section so that it
applies only to New Identified Seeps, as follows:
The facility has identified two previously unpermitted seeps (all non -engineered) from the ash settling
basin, S-1 and S-2, the locations of which are identified on the attached map. On May 4, 2016, DWR
representatives delineated Effluent Channels at the Marshall Steam Station for both seeps, in accordance
with the requirements of 15A NCAC 02B .0228. Both Effluent Channels discharge to the Catawba River.
An RPA performed for this permit demonstrates that water quality standards in the Catawba River will
not be contravened by these existing seepage flows.
Table 1. Seep Coordinates and Assigned Outfall Numbers
Seep ID Latitude Longitude Outfall Number
S-1 3503671" 80057'62" 101
S-2 3504256" 80021'56" 102
New Identified Seeps
If new seeps are identified that meet the definition of a point source and discharge to waters of the
state, the facility shall follow the following procedures. The facility shall determine within 90 days from
the date of discovery if a seep meets the state water quality standards established in 15A NCAC 2B.0200
and submit the results of this determination to the Division. If the standards are not contravened, the
facility shall conduct monitoring for the parameters specified in A. (8.) and A. (9.). In accordance with
15A NCAC 02B.0205, water quality standards will not be considered violated when values outside the
normal range are caused by natural conditions.
If any of the water quality standards are exceeded, and values outside the normal range are not caused
by natural conditions, the facility shall implement one of the following options within the prescribed time
frame. The facility shall.
1) If the seep itself is within a jurisdictional water as set forth in a final Jurisdictional
Determination issued by the United States Corps of Engineers, submit a complete application
as applicable for a 404 Permit (within 30 days after determining that a water quality
standard is exceeded) to pump the seep discharge to one of the existing outfalls, install a
pipe to discharge the seep to the Catawba River, or install an in-situ treatment system. The
facility shall complete the installation of the pump, pipe, or treatment system within 180

Page IS
days from the date of the 404 permit receipt (or determining no 404 permit is required) and
begin pumping/discharging or treatment.
2) Demonstrate through modeling that the decanting and dewatering of the ash basin will
result in the elimination of the seep and submit the modeling results to the Division. Within
180 days from the completion of the dewatering the facility shall confirm that the seep flow
ceased. If the seep flow continues, the facility shall choose one of the other options in this
Special Condition.
3) Demonstrate within 30 days of determining that a water quality standard is exceeded that
the seep is discharging through the designated "Effluent Channel" and the water quality
standards in the receiving stream are not contravened.
S. Comments on Attachment 1: Groundwater Monitoring Plan
• Please add the following clarifying language to the permit:
"3(h). The provisions of sections 3(f) and 3(g) apply only to the sampling events described in 3(b)
above. The reporting requirements for any sampling events other than those described in 3(b)
above shall be in accordance with the general provisions of 15A NCAC 02L."
• Additionally, Duke requests that the GW59CCR form submittal date be 60 days after sampling in
lieu of 45 days.
9. Comments on Fact Sheet
• The Fact Sheet states that the summer 7Q10 flow of 60 cubic feet per second (cfs) is based on
the minimum release from the dam that regulates the receiving water body (Cowens Ford).
However, based on the issued Catawba-Wateree operating license, the minimum release from
Cowens Ford is 80 cfs and the minimum average daily release requirement is 311 cfs. In the
recently issued permit for McGuire Nuclear Station, the 7Q10 was set at 80 cfs. In addition, the
IWC reported in the Fact Sheet is 18%, which corresponds to a flow of 11.44 MGD and 7Q10 of
80 cfs. Duke request the 7Q10 reflect the minimum release from Cowan's Ford Dam stated in
the current Catawba-Wateree operating license.
Duke Energy welcomes any further discussion on our comments or the Draft Permit. If you have any
questions, please contact Shannon Langley at [phone] or at [e-mail].
Sinc rely,
Harry Sideris
Duke Energy
Senior Vice President Environment, Health & Safety

I
Page 6
cc: Rick Roper, Duke Energy, Station Manager
Jim Wells, Duke Energy, VP EHS CCP
Richard Baker, Duke Energy, EHS CCP
Scott LaSala, Duke Energy, Marshall Plant Environmental Coordinator

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
2YZ REGION 4
ATLANTA FEDERAL CENTER
I's = 61 FORSYTH STREET
"+'It PRO" leo ATLANTA, GEORGIA 30303-8960
S. Jay Zimmerman A 3 6 416
Director, Division of Water Resources
North Carolina Department of Environmental Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: Review of draft National Pollutant Discharge Elimination System permit for Duke Energy
Carolinas, LLC, Marshall Steam Station, NPDES Permit Number NC0004987
Dear Mr. Zimmerman:
On May 17, 2016, the above -referenced draft National Pollutant Discharge Elimination System
(NPDES) permit and fact sheet were received by the United States Environmental Protection Agency
from the North Carolina Division of Water Resources (NC DWR) via email. On June 2, 2016, staff from
our respective agencies participated in a teleconference to discuss the EPA's preliminary comments.
Following the teleconference, the EPA summarized our comments in a June 6, 2016, email and on June
13, 2016 a revised draft NPDES permit and fact sheet were transmitted to the EPA from NC DWR via
email.
The EPA has reviewed the revised draft NPDES permit, focusing on the revisions in response to our
comments. The following comments have been addressed in the revised draft NPDES permit:
1. Effluent limitations and monitoring requirements for Outfall 002 [Parts I.A. (2.) and A. (3.)]
have been revised to include BODS and fecal coliform to address the flow of treated sanitary
wastewater into the ash pond. In addition, Part I.A. (32.) has been added to the revised permit to
require proper operation and maintenance of the domestic wastewater plant.
2. The daily maximum effluent limitation for Total Suspended Solids at Outfall 002 [Parts I.A. (2)
and A. (3)] has been changed from 65.0 mg/l to 50 mg/l to address Effluent Limitations
Guidelines for coal pile runoff into the ash pond.
3. The footnote describing the effluent limitation for Turbidity at Outfall 002 [Parts I.A. (2) and A.
(3)] has been changed to reflect NC's net turbidity water quality criterion.
4. Effluent limitations and'monitoring requirements for Total Suspended Solids and Oil and Grease
have been added to Outfalls 002A and 002B [Parts I.A. (4.) and A. (5.)] to address Effluent
Limitations Guidelines for low volume wastes.
5. The EPA and NC DWR agree that the draft permit authorizes discharges from two seeps,
identified as S-1.(Outfall 10 1) and S-2 (Outfall 102). Part I.A. (30.) has been revised to clarify
that discharges from newly identified seeps will not be authorized under the pen -nit until the
permit has been modified to include the additional seeps and designated outfalls.
NC DWR agreed to the EPA's recommendation that the monitoring frequency for Oil and Grease at
Outfall 002 [Parts I.A. (2) and A. (3)] should be changed from quarterly to monthly. However, this
change was not reflected in the revised draft permit and may have been inadvertently omitted.
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable oil eased Inks on Recycled Paper (Minimum 301/o Postconsumer)

The EPA and NC DWR also discussed that the use of 7Q 10 and 1 Q10 flows for dilution may be
inappropriate for reasonable potential analyses for discharge of toxicants to a large reservoir. The
spreadsheets provided indicate that such flows were used to provide dilution when estimating the total
allowable effluent concentrations of a range of pollutants, however there was no demonstration that
"complete and rapid mixing" occurs as it might with a discharge to a small stream. For example, many
of the acute water quality criteria presume exposures not in excess of criteria for greater than 4 hours. If
it is NC DWR's-intention to provide some dilution, it would seem more appropriate for the state to
allocate an impact zone in the reservoir that complies with NC's water quality standards provisions for
mixing zone allocation. A mixing zone model such as CORMIX could be used to then evaluate critical
conditions for mixing and to confirm the end -of -pipe concentrations that result in compliance with water
quality standards at the regulatory mixing zone boundary. In addition, existing ambient background data
should be considered in the assimilative capacity analysis rather than assuming that background
concentrations are zero. The EPA and NC DWR agreed to continue collaborating to determine
appropriate procedures for reasonable potential analyses for future permits.
The EPA reiterates additional comments and recommendations for improving the permit which were
discussed during file teleconference, as well as in past discussions with NC DWR:
The draft permit and fact sheet for the Marshall facility indicate that Effluent Channels have
been delineated and a reasonable potential analysis conducted that concludes that water quality
based effluent limits are not required, as reflected. in Parts I A. (8) and A. (9) which lists
monitoring only for the identified effluent characteristics. Part I. A. (30) requires that the
permittee demonstrate that water quality standards in the receiving stream are not contravened.
The permit should be clarified to indicate the locations for effluent monitoring required for
Outfalls 101 and 102, as well as the sampling location in the receiving stream for demonstrating
compliance with water quality standards. In addition, the permit should specify which
constituents of concern must be sampled to demonstrate compliance with water quality
standards.
2. Part I. A. (30.) includes a section for "New Identified Seeps" but the permit does not include the
"Plan for Identification of New Discharges". This Plan should be included in order to clearly
define enforceable minimum requirements for identifying unpermitted discharges, such as areas
to be inspected, inspection procedures, frequency of inspections, constituents to be sampled, etc.
As we have discussed, the draft permit authorizes discharges from unengineered seeps that are not
discharged through an engineered outfall or collected and rerouted to an engineered outfall. This creates
challenges in permit development and compliance monitoring as it is unclear how such discharges can
be accurately monitored for flow and discharge characterization. Although DWR includes a Seep
Pollutant Analysis with options for addressing water quality exceedances in the NPDES permit, we note
that an enforcement mechanism providing for elimination or rerouting these seeps is an alternative and
potentially preferable approach for addressing seeps of this nature. It has been NC's election to develop
permits for these discharges rather than addressing them through an enforcement mechanism,
notwithstanding the difficulty of developing appropriate permit conditions and monitoring compliance.
In accordance with the NPDES Memorandum of Agreement (MOA) between the EPA Region 4 and
North Carolina and 40 CFR § 123.44, the EPA submits the above comments and recommendations on
the Marshall revised draft permit. The EPA requests that DWR revise the permit and fact sheet to
address these remaining unaddressed comments and recommendations. We understand that you may
receive significant public comments objecting to the draft permit, and that the draft permit may undergo
significant further changes based on public comments. In either case, pursuant to Section N.13.6. of the

MOA, you would be required to afford the EPA an opportunity to review the proposed final permit. If
you have any questions, please call me at [phone] or have your staff contact Karrie Jo Shell in
the NPDES Permitting Section at [phone].
Sincerely,
L
James D. Giattina
Director
Water Protection Division
cc: Mr. Harry Sideris, Senior Vice President
Duke Energy Carolinas, LLC

Hickory Daily Record
Advertising Affidavit
NCDEQ/DWR
ATTN: WREN THEDFORD
1617 MAIL RFR\IICF_ CFnITER
Public Notice
North Carolina Environmental Man-
agement Commission/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a NPDES
Wastewater Permit
The North Carolina Environmental
Management Commission proposes
to issue a NPDES wastewater dis-
charge permit to the person(s) listed
below. Written comments regarding
the proposed permit will be accept-
ed until 30 days after the publish
date of this notice. The Director of
the NC Division of Water Resources
(DWR) may hold a public hearing
should there be a significant degree
of public interest. Please mail com-
ments and/or information requests
to DWR at the above address. Inter-
ested persons may visit the DWR at
512 N. Salisbury Street, Raleigh, NC
to review information on file. Addi-
tional information on NPDES permits
and this notice may be found on our
website: http://deq.nc.gov/about/di
visions/water-resources/water-
resources-permits/wastewater-
branch/npdes-wastewater/public-
notices,or by calling [phone].
PUBLIC NOTICE
N.C. DEPARTMENT OF ENVIRON-
MENTAL QUALITY INTENT TO ISSUE
NPDES WASTEWATER DISCHARGE
PERMIT #NC0004987
Public comment or objection to the
draft permit modification is invited.
All comments received by June 22,
2016 will be considered in the final
determination regarding permit issu-
ance and permit provisions.
PERMIT APPLICATION
Duke Energy Carolinas, LLC has ap-
plied for a renewal of its NPDES
wastewater permit (NC0004987) for
Marshall Steam Station, 8320 East
N.C. Highway 150, Terrell, N.C., Cat-
awba County. The facility discharges
treated industrial wastewater to
Lake Norman in the Catawba River
basin. This discharge may affect fu-
ture allocations in this portion of the
Catawba River basin.
The thermal component of the dis-
charge is subject to effluent limita-
tions under the federal Clean Water
Act sections 301/306 and N.C. Ad-
ministrative Code Section: 15A
NCAC 26.0211 (3) (j), which prohib-
its an exceedance of 2.8 degrees C
(5.04 degrees F) above the natural
water temperature, and in no case to
exceed 32 degrees C (89.6 degrees
F). The permit holder has requested
a continuance of a Clean Water Act
316(a) variance, which would im-
nncp sn alternative. less stringent
PO Box 968
Hickory, NC 28603
Account Number
3611028
Date
May 22, 2016
,gory Description Ad Number Ad Size
al Notices Public Notice North Carolina Environmental Management Comi 0000221789 1 x 127 L
Publisher of
Hickory Daily Record
Catawba County
Before the undersigned, a Notary Public of Catawba County, North Carolina, duly
commissioned, qualified, and authorized bylaw to administer oaths, in said
County and State; that he/she is authorized to make this affidavit and sworn
statement; that the notice or other legal advertisement, a copy of which is attached
hereto, was published in the Hickory Daily Record on the following dates:
05/22/2016
and that the said newspaper in which such notice, or legal advertisement was
published, was a newspaper meeting all the requirements and qualifications of
Section 1-597 of the General Statutes of North Carolina
Assistant Bookkeeper
Newspaper reference: 0000221789
Sworn to and subscribed before me, this c!U day of 2016
Notmy An'
�OTgR�
My Commission expires: G e2Cj
n —U B
THIS IS NOT A BILL. PLEASE PAY FROM INVOICE. THANK YOU X11 4 co
• � 111111 t �

limitation on the thermal component
of the discharge. The proposed var-
iance imposes a monthly average
limit of 34.4 degrees C (94 degrees
F) for the period from July 1 through
October 31, and a monthly average
limit of 33.3 degrees C (92 degrees
F) for the period from November 1
through June 30. On the basis of the
N.C. Administrative Code Section:
15A NCAC 213.0208 (2) (b) and other
lawful standards and regulations,
the N.C. Division of Water Resources
proposes to continue the 316(a) var-
iance in conjunction with renewal of
the permit
The draft wastewater permit and re-
lated documents are available online
at: https-//deq.nc.gov/about/divisio
ns/water-resources/water-
resources-hot-topics/dwr-coal-ash-
regulation/duke-energy-npdes-
perm its-fo r-faci lities-with-coal-ash-
ponds/duke-energy-npdes-
modifications-renewals. Printed cop-
ies of the draft permit and related
documents may be reviewed at the
department's Mooresville Regional
Office. To make an appointment to
review the documents, please call
704-663-1699.
Public comment on the draft permit
modification should be mailed to:
Wastewater Permitting, Attn: Mar-
shall Permit, 1617 Mail Service Cen-
ter, Raleigh, N.C., 27699-1617. Public
comments may also be submitted by
email to: publiccommentsCncdenr.g
ov. Please be sure to include "Mar-
shall" in the email's subject line.
PUBLIC HEARING
The N.C. Department of Environmen-
tal Quality will hold a public hearing
to accept comments on the draft
permit at 6 p.m. Wed., June 22 at the
Catawba Valley Community College
East Wing Auditorium. The auditori-
um is located next to the library on
the college's main campus, 2550
Hwy. 70 Southeast, Hickory, N.C.
Speaker registration begins at 5 p.m.
Publish: May 22, 2016