NC0024406_Ash Basin Discharge to The Dan River_19950525

Duke Power Company _
Electric System Support Depottment
` 13339 Haggis Ferry Road
Huntersoille, NC28078-7929
4�ZEN3Nq.
sFavtic�
May 25, 1995
North Carolina Department of Environment,
Health and Natural Resources
Division of Environmental Management
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Re: Belews Creek Steam Station
Ash Basin Discharge to The Dan River
Mr Juan Mangles:
Per our telephone conversation of May 25, please find enclosed the above
referenced Engineering Report dated June 10, 1983 and letter concerning the
plan for Phase III monitoring of the Dan River.
If you have any further questions or need additional information, please contact
me at [phone].
-311LL8/lA�
Susan P Covington
Assistant Scientist
Water Protection
Printed on recycled paper
6r

Duke Power Company
Fossil Production Department
P 0. Bm• 3.31:5.9
` 922 South Church Street
Charlotte, N.C. =82.12
DUKE POWER
October 3, 1989
Mr. R. Paul Wilms, Director
North Carolina Division of Environmental Management
P. O. Box 27687
Raleigh, North Carolina 27611-7687
Subject: Duke Power Company/Belews Creek Steam Station
Public Notice Comments/NPDES No. NCO024406
File: BC -704.21
Dear Sir:
i
(704).773-4011
Duke Power has reviewed the September 7, 1989 public notice and draft
NPDES permit proposed for issuance to the above referenced facility. We submit
the following comments for consideration in final determinations regarding the
proposed permit.
Duke Power objects to the note at the end of the toxicity testing section
which reads "Failure to achieve test conditions as specified in the cited
document, such as minimum control organism survival and appropriate environ-
mental controls, shall constitute an invalid test and will require immediate
retesting (within 30 days of initial monitoring event). Failure to submit
suitable test results.will constitute non-compliance with monitoring require-
ments." As presently worded, the Department would attempt to penalize a
permittee, without any evidence that the permittee's effluent is toxic, merely
because the permittee has been unable to conduct a valid test. The unfairness
of this is even more apparent when one considers the fact that most permittees
will probably be using third -party laboratories to conduct these tests. All
laboratories that are conducting these tests should be certified by the State
of North Carolina. Thus, North Carolina has another mechanism to address its
concern regarding valid monitoring 'results. Its avenue is through the labora-
tory certification. However, it is manifestly unfair to penalize a permittee,
without any evidence that its effluent is toxic or is otherwise not in compli-
ance, when the permittee has done all that is within its ability to conduct a
valid test and to submit valid test results.
While the State of North Carolina may feel quite comfortable in the
reproducibility of the acute and chronic toxicity testing, there have. been a
number of studies that show at the very least that the reproducibility of this
type of monitoring is less than the reproducibility of other monitoring
requirements'appearing in the NPDES permit. Where the Department has chosen to
employ a test which is dependent, in part, upon the survival and procreation
of organisms very sensitive to even minor changes in their environment, the
State should recognize that good faith efforts on the part of permittees to
comply with monitoring requirements should not subject the permittee to the
possibility of non-compliance.

` Mr. R. Paul Wilms
October 3, 1989
Page two
If the permittee has chosen to use a certified and reputable laboratory
for its testing, and if the permittee has diligently attempted to retest
within the 30 -day period, and if there is no 'evidence that the permittee's
effluent is not in compliance, then there should be no sanction against the
permittee. Even if the laboratory is responsible for the invalid test, the
State's recourse should be against the laboratory and not against the
permittee who has been diligent and responsible in this manner.
Thus, Duke reiterates its position that the most appropriate resolution
of this' matter would be to strike in its entirety the final sentence of the
note which follows the toxicity testing portions in these permits.
However, as an alternative, Duke proposes the following language: "Fail-
ure to achieve test conditions as .specified in the cited document, such as
minimum control organisms survival and appropriate environmental controls,
shall constitute an invalid test and will require immediate retesting (within
30 days of initial monitoring event). Failure to submit suitable test results
will constitute non-compliance with monitoring requirements, but willnot
subject the permittee to civil penalty if permittee has diligently attempted
to conduct a suitable retest and.has engaged the services of a laboratory with
valid certification under North Carolina's laboratory certification program."
With regard to Part II, paragraph 8 in the "boiler plate" 'language, it
conflicts with North .Carolina General Statute 150B-9, which provides,for the
continuation of the license or permit if the application to renew was timely
filed and the agency has not made a final decision on the application. Thus,
this provision.should be rewritten to conform to state law.
Condition U of . the draft permit requires submittal of a study plan for
Phase III monitoring of the Dan River. We have attached with these comments
,our proposed sampling regime for your approval, to begin upon issuance of the
subject NPDES permit. This sampling plan is essentially identical to the
monitoring plan recommended in the August 11, 1988 letter from Steve Tedder.
Thank you for the opportunity to comment during this proceeding.
Very truly yours,
90,
. Fayssoux, Manager
Fossil Technical Services
RSC/JOF:mp
bac w/enclosure
Belews Creek Steam
Station
G. S. Rice
W. T. Horton

Sampling Regime for Dan River
(Phase III)
PARAMETERS LOCATIONS FREQUENCY
710 720 731 732
WATER CHEMISTRY X X X X Quarterly
In-situ:
Temp, DO, pH, sp cond
Elemental Analyses:
As, Cd, Cu. Se, Zn
Other:
Ca, TSS, Alk, SO
SEDIMENT CHEMISTRY X X X X Annually
CSpring)
Elemental Analvses:
As. Se
MACAOINVERTEERATES- X X Annually
CSummer)
Community Composition
Elemental Analyses:
As, Cu, Se, Zn
F I SH (Red breast Sunfish, Golden X X X A n n u a I I y
Redhorser- Catfish) (Fa I I )
Elemental Analyses:
Se, Zn Cin muscle)

•
MAW POWER COMP -ANY
3189 GE' NE,I?Al. 01elpi( ,j'i�s TELEPHONE, AREA 704
422SOUTH CHURCH STREET 373.4011
C1-1ARL0'1'rE,. N. C. 28242
June 10, 1983
at,. PRO041
�O IME HOZ
Mr. Russell D. Radford JUN 13 1983 p
n Q
N. C. Division of Environmental Management 5
8003 North Point Boulevard
Winston-Salem, North Carolina 27106 �� SEFOJ%Oge
Re: Belews Creek Steam Station
Engineering Report
File Nos: BC -1407.08, GAH-0207
Dear Mr. Radford:
Please find attached the above referenced Engineering Report addressing the
engineering and environmental matters discussed in our meeting of May 5, 1983.
Per our telephone conversation of June 6, 1983, we are presently evaluating
the acid addition treatment question, and we will forward our evaluation of
this to you by June 30, 1983.
Please note that the NPDES application is being sent to you under separate
cover.
If you have any questions regarding this matter, please feel free to contact
Matt LaRocque at [phone].
Yours truly,
S. B. Hager, Chief Engineer
Civil/Environmental Division
&I ju�
By: J. R. Hendricks
Principal Engineer
JRH/MGL/mdc
Attachments
cc w/atts: Mr. Bi l l Mil.ls �C .I. c kkaw-'
Mr. Steve Tedder
Mr. B. E. Davis 6°wn
Mr. W. D. Adair
Mr. R. F. Edmonds
.).
Mr. D. W. Anderson
Mr. M. G. LaRocque

ENGINEERING REPORT
Belews Creek Steam Station
Ash Basin Discharge To The Dan River
Duke Power Company
Design Engineering
Charlotte, NC

planned for.installation between Precipitator 2A and the storage silos. The location
of the storage silos and piping can be seen in the attached Figure 1.
Combined storage silo capacity of 3000 tons would be installed between Precipitator
2A and the existing fly ash sales silos. These silos would be cone -bottomed and of
steel construction with individual ash conditioners elevated for direct loading into
dump trucks. Arrangement would also provide for parallel traffic flow from each
disposal silo and from the sales facility. The silo facility would be equipped
with sufficient baghouse venting capability to receive fly ash from all four
precipitator sections simultaneously. The design for each of the four fly ash
conveying pipelines would incorporate sufficient valves and connections to allow
the reception of fly ash from any precipitator section into either of the new silos
or directly into the existing sales silos. Plant fly ash control systems would be
modified to allow selective collection and segregation of ash into the silos
while at the.same time maintaining the flexibility of continuous removal of fly
ash from the precipitators. The new silo facility will incorporate intersilo
transfer equipment to further enhance reliability and allow the future possibility
of loading fly ash from the vent disposal silos into dry bulk tankers for railcars.
All fly ash for disposal would be dampened using conventional pre -wetter systems
to mix the fly ash and water. The fly ash would then be loaded at approximately
15% - 20% moisture into large off-road vehicles. These vehicles are expected to
carry approximately 30 - 35 tons each. Trucks would turn around at the silos and
out to cross Route 1809. All trucks would then continue along a road to be built
on Duke property, parallel to Route.1809. Fly ash will be hauled on a one to
two shift basis, as needed, depending on plant load. Further, all_ roads will be
upgraded. The in -plant roads and the road leading to the intersection will be
upgraded by the application of an additional four inches of asphalt. The
intersection of the main highway will be covered in concrete, thus ensuring the
county and state a minimal problem from crossing traffic. The road leading
across Duke property to the landfill will be constructed by stabilizing 24 inches
of fly ash and soil. The road will be maintained with a bottom ash cover.
The new landfill will include cofferdams which serve to control water runoff from
the area during landfill construction and will become the final toe of the landfill
upon closure and coverage with soil. The site will be cleared and prepared in
sections with full upgrading of each area for operation as a landfill. A well or.
other.water source will be maintained to control dust in the landfill.

The conversion from a wet sluice system to a damp disposal system offers the
advantage of having no excess water to be treated and discharged. The only water
used in the system will be totally contained within the landfill, thus minimizing
any potential environmental problems. 'In addition, this type of landfilling
technique requires the minimum amount of land to.dispose of the maximum quantity
of fly ash possible.
New Discharge Tower and Disposition of Old Tower
The proposed method of discharging the ash basin effluent to the Dan River consists
of a new conventional ash discharge tower (Figure 2) containing a 30" diameter
sluice gate with an invert elevation of approximately E1. 734+6. Water levels would
be controlled by stoplogs and maximum flow would.be controlled by the sluice gate.
The sluice gate would also allow the discharge to be withheld. To prevent floating
ash from discharging to the river, a skimmer would be provided. The discharge would
be routed around the western end of the ash dam, to a stilling basin, and finally
to the Dan River by way of an effluent channel. (Figure 3) A parshall flume would
be provided after the stilling basin for flow measurement. Also, riprap would be
provided for approximately the first 100 feet of the effluent channel.
It is proposed that the present system of ash basin discharge to i3elews Lake be
maintained until such time that Se levels are reduced to acceptable levels. .Also,
this discharge is necessary to serve as an emergency spillway for flood conditions,
and to allow infrequent discharge to the lake should severe and prolonged drought
conditions require such a release to maintain minimum water levels in the lake.
Water Chemistry Description.
1. Ash Basin Water .Quality
Historical data for the Belews Creek ash basin indicate that levels
of most constituents are within water quality standards in the effluent.
Only arsenic -and selenium have consistently exceeded standards: levels
of these elements have ranged near 20-60 ug/l and 80-130 ug/1,
respectively since installation of the sulfur -trioxide fl.ue gas
conditioning system at Belews Creek in 1978-1979 (Cumbie, 1980).
Therefore,.further discussion will be limited to these substances.

After the dry fly ash system begins operation,the influent to the ash
basin will be bottom ash sluice water and yard sump water. Therefore,
the character of the basin will change to become basically that of a'
bottom ash settling basin. Due to the coarse, sand -like nature of
the bottom ash, little or no chemical leaching.by sluice water occurs.
The chemistry of the bottom ash sluice water is almost entirely dictated
by the Belews Lake water used for sluicing purposes. Belews Lake water
currently contains some 8-12 ug/l selenium. This concentration should
decline to undetectable levels over a 2-3 year period following removal
of ash basin effluent from the reservoir. Therefore, the ultimate
selenium concentration in the ash pond should be below 10 ug/1. For
conservatism, projections are based on the assumption that the ash basin
should stabilize near 10 ug/l total selenium.
Although arsenic concentrations in Belews Creek ash basin effluent have
historically ranged as high as 200 ug/l or more, arsenic has been even
more strongly.affected by the sulfur -trioxide system than selenium, and
current levels are near 25 ug/1. Since bottom ash sluice water should not
contain appreciable quantities of arsenic, and arsenic is barely detectable
in Belews Lake water, we project that -arsenic concentrations in the ash
basin will approach zero when the dry fly ash system begins operation,
and this element will not be considered further.
2. Selenium Mass Discharges - Ash Basi.n
During the period immediately following operation of the dry fly ash system;
selenium concentrations in the ash basin should decline from an -initial
value near 130 pg/l to an assumed equilibrium value near 10 ug/1.
Assumption of a simple first -order decay process leads to the concentration
decay curves in Figure 4, which indicate that the 10 ug/l concentration
should be reached within some 250-350 days after operation of the dry system,
under average operating conditions. Curves shown in Figure 4 for decay were
calculated assuming that loss of selenium from the system occurs by 1) a com-
bination of discharge in the effluent and sorption/sedimentation loss to sed.i.-
ments (solid curve) or 2) by discharge in the effluent only, with no loss by
sorption/sedimentation (broken curve). Rate constants for these decay
curves were derived based on historical ash basin and effluent monitoring
data.

Discharge Scenarios - Transition Period
Two scenarios have been developed for handling the ash basin
effluent discharge during this.transition period from the
mixed wet fly ash/bottom ash system to the wet bottom ash/dry
fly ash system. These are summarized as follows:
Scenario 1: Ash basin effluent would be immediately discharged
to Dan River. Initial selenium concentration - 130 ug/1,
declining to -10 ug/l in -250 days. Selenium mass to the river
�p would be ,3 x present load over same time period from Belews
n Lake dam X(60 cfs at 7.5 ug/1).
Scenario 2: Discharge remains to Belews Lake until the ash
basin selenium concentration and the concentration of selenium
in Belews Lake decline in concert to values such that the
combined load to the Dan River from the ash basin plus the dam
would not significantly exceed the previously experienced load
from the dam discharge alone.. The maximumload to the Dan River
occurred in 1977 at a lake selenium concentration of approximately
20 ug/l. Assuming a 66 cfs average flow at 20 ug/l gives a maximum
daily load of 3.2 kg/day. Table 1 shows the selenium concentration
trends in the ash basin and in Belews Lake. These projections
indicate that, assuming the dry fly ash system goes into
operation in the fall when the water column becomes mixed in Belews
Lake due to the fall overturn (November), a combination of daily
mass discharges not exceeding 3.2 kg/day is reached after about 90
days. This scenario would call for initial discharge to the Dan
River in early March of the following year. Approximately 267 kg
of selenium, or 0.11x the present annual load of 2438 kg, would.
enter Belews Lake during the 90 days, assuming that the ash basin
concentration is 130 ug/l at t = o in November.
Alternatively, the sustained load to the Dan River during the period
1978 -present has resulted from summer mean Belews Lake selenium
concentrations of about 12 ug/1, or a daily load of approximately
1.9 kg/day._ From Table 1, it is. -seen that a combination of daily
mass discharges not exceeding 1.9 kg/day would be reached after
about 220 days. This scenario would thus call for initial discharge

of ash basin effluent to the Dan River by June of -the following
year. 'This would result in discharge o -f- approximately 400 kg of
selenium to Belews Lake during the 220 days, or about 0.16x the
present annual load again assuming the ash basin concentration is
130 ug/l at t = o.
It is important to note that, since.both the ash basin and lake
concentrations would continue to decline, the load to the Dan
River would be further reduced after March or June. Also, when the
lake concentration approaches a postulated equilibrium at or near
background (less than 1 ug/1), the ash basin effluent concentration
could increase to approximately.50 to 100 ug/l without exceeding
the previous 1977 or 1978-1983 loading levels from the Belews Lake
dam.
Selenium mass discharges to Belews Lake and to the Dan River under
each of these scenarios are summarized in Table 2. Selection of
the appropriate strategy will be made after consultation with NCDEM
staff concerning the relative.significance of discharge impact in
the two receiving water systems.
3. Upset Conditions
No major failures in the dry ash handling system preventing ash removal
are anticipated. Due to the redundant design of the system, either unit
can feed to either silo. There will also be a two day silo -storage buffer
capacity.
A spare parts inventory of all major valves will be maintained. The four
to six hour hopper.storage capacity should allow adequate time to perform
emergency repairs. All other routine maintenance will be coordinated with
station outages.
Excursions of water quality variables may occur, however, when or if the wet
fly ash sluice system is operated as back-up during repairs to the dry fly
ash system. However, our calculations indicate that these excursions for
elements of concern (selenium and arsenic) will not exceed approximately
10-15 ug/l (above a postulated 10 ug/l operating level for selenium) for
several days operation. The NPDES permit should allow for these minor

excursions and require notification of the state when they occur.
Water Budget Considerations
Since the proposed action would result in a net withdrawal of water from Belews
Lake, a water budget was calculated to determine the impact of this water loss
on the lake. Operation 'of Belews Creek Steam Station is limited when lake levels
drop below elevation 720. The lowest lake level experienced to date is approximately
elevation 722.
Information used to derive monthly values of discharge per square mile for the
period of January 1949 to December 1978 was taken from Wentworth, North Carolina,
USGS gage and was adjusted for the drainage area of the Belews Lake basin. This
data, together with data from the Greensboro, North Carolina weather station
(including precipitation), was used in the MIT model (Ryan and Harleman 1973) for
cooling pond behavior already adopted and verified for Belews Lake.
Using the computer model with a simulated discharge of 23 cfs (13 cfs - non fly ash
sluice water plus 10 cfs - dam release requirement), -there is approximately a one
in five years chance that the lake elevation will drop to a level which will require
that the ash basin discharge be rerouted. Every year that a return flow is required,
the discharge back to the lake will be necessary for an average length of two months.
Also, the computer results for the five year lowest flow period (1966-1970) indicate
that the lake elevation was drawn down below 722 one time with a 23 cfs discharge.
Duke Power Company proposes that the ash basin effluent discharge be credited against
the required 10.cfs release to the Dan River from the Belews Lake dam. Using the
computer model with a simulated discharge of 13 cfs (10 cfs dam release excluded),.no
return flow is anticipated. The computer results for the five year lowest flow period
(1966-1970) indicate that the 13 cfs discharge never imposed a threat to station
operation.
During actual station operation, the model predicts that the years 1977 and 1981 would
have posed significant problems. In 1977, the calculated lake level would have fallen
below the actual recorded value if the station was requi-red ,to.release 23 cfs even
during low lake level periods. In 1981, the calculated lake level would have fallen
below the actual recorded value throughout the year if the station were subjected to
the same conditions.

Under the proposed plan, the required discharge will be provided through the new ash
basin discharge location approximately 3.5 miles upstream of the Belews Creek
confluence with the Dan River. Normal Belews Lake overflow will continue to discharge
through the existing spillway structure along with associated seepage from the dam,
thus resulting .in approximately 1 to 2 cfs minimum flow. In addition, Duke Power
owns all the land along Belews Creek from the dam to the Dan River.
Regarding impact of reduced flow on fish populations, a reduction of the minimum
low flow in Belews Creek below the Belews Lake dam from 10 cfs (based on.the
present minimum release requirement) to a value of 1 to 2 cfs (from dam leakage and
minor tributary flow) would reduce .the habitability of the stream for fish in a
segment of approximately 0.1 mi length, extending from the dam spillway to a point
near the Highway 1138 bridge. A reconnaisance electroshocking effort in this area
on July 30, 1981, resulted in collection of a total'of 36 individual fish of 13
different species. This indicated presence of a diverse, indigenous fish community
in this stream segment which consists.of a series of.riffles and pools. Four sun-
fish beds were also observed. Fish standing crops are undoubtedly maintained by
movement of fish up from the.lower section of Belews Creek and from the Dan River..
Although reduced minimum flow would restrict the available habitat in the 0.1 mi
segment, refuge pools would still be. available, and stagnation would not occur due
to the assured dam leakage flow. This transient loss of marginal habitat would
not have an important impact on the fishable population in Belews Creek between the
dam and the Dan River, since the river itself maintains water levels in the stream
and deep pools exist below the 1138 bridge. Therefore, it is concluded that the
proposed flow reduction would have negligible impact on fishery resources in Belews
Creek:\
With the concurrence of DEM and the NCWRC, Duke proposes to experimentally reduce
the Belews Lake dam discharge to 5 cfs and zero cfs during brief periods during
the summer of 1983 in order to better define the impact of minimum flow reductions
in Belews Creek. The results of these trials would assist in the -resolution of
this question.
Effluent Channel From the Ash Basin to the Dan River
In order for this channel to be classified as an effluent channel, Duke must meet
the conditions of .land ownership, prevention of offensive conditions, and prevention
of fish attraction upstream. Duke Power Company owns all the land along the

that one site is above the ash basin effluent, and three sites are below. The
final site is to be located at the Virginia state line.
The proposed monitoring plan will involve Phases I -III. Phase I will encompass
baseline sampling for the Dan River prior to discharge of bottom ash sluice water.
Phase II will encompass 'monitoring.of the Dan River for two years after ash basin
effluent is discharged to the River. Phase III will be determined based on results of
Phase II monitoring and consultation with NCDNRCD.
Conclusions
0
1. Duke Power proposes to install dry fly ash handling facilities at
Belews Creek Steam Station along with a provision for ash disposal
by landfill.
2. Duke Power proposes a new ash discharge tower for ultimate discharge
to the Dan River. It is also proposed that the present system of ash
discharge to Belews Lake be maintained if necessary.
3. Both of the initial discharge proposals in Scenario 2 would result in
selenium loading (1.9 to 3.2 kg/day) which are near the natural background
load in the Dan River (approximately 1 to 2 kg/day at 1 ug/l, 500 cfs
average flow). Our experience with Belews Lake has shown that extreme
retention time and localized accumulation in sediments, coupled with
increased loading at 30 to 40 times natural loads, are system properties
which made, the lake respond as it did to ash basin selenium input. The
Dan River does not possess these properties.- The projected selenium loads,
even at the initial discharge concentrations, will not greatly exceed
natural background, and will decline further over time. Therefore, initial
discharge to the Dan River at 90 days, the option which will result in the
.minimum load to the more sensitive Belews Lake system, is the preferred option.
4. Duke Power proposes a condition for upsets in the NPDES'permit to allow
for minor excursions.
5. Duke Power proposes that the new ash basin effluent discharge be credited
against the required 10 cfs release to the Dan River from the Belews Lake
dam. Normal Belews Lake overflow will continue to discharge through the

existing spillway structure along with associated seepage from.the dam,
thus resulting in approximately 1 to 2 cfs minimum flow. This minimum flow
would have negligible impact on fishery resources in Belews Creek. Also,
Duke proposes to experimentally reduce the Belews Lake dam discharge to 5
cfs and zero cfs during brief periods of the summer of 1983 in order to
better define the minimum flow reduction impact in Belews Creek.
6. Duke Power proposes that the channel from the ash basin to the Dan River
be classified as an effluent channel.
7. Duke Power proposes a monitoring plan for the Dan River to include four sites
with one site being upstream and three sites downstream. The final site is
to be located at the Virginia state line.

Literature - Cited
Cumbie, P.M. 1978. Belews Lake Environmental Study Report: Selenium and Arsenic
Accumulation. Duke Power Company Tech. Rep. Ser. No. 78-04. Duke Power Company,
Charlotte, North Carolina. 64 pp.
Cumbie, P.M. 1980. Effects of pH Adjustment and SO Fly Ash Conditioning on the
Belews Creek Steam Station Ash Basin Effluent. Duke Power Company Tech. Rep.
Ser. No. 80-01. Duke Power Company, Charlotte, North Carolina. 62 pp.
Ryan, P.J. and D.R.F. Harleman. 1973. An Analytical and Experimental Study of
Transient Cooling Pond Behavior, Report 161, Ralph M. Parson Laboratory,
Massachusetts Institute of Technology, Cambridge, Massachusetts. 439 pp.

I- EXIST. ASH LINE
AND 5 -NEW ASH
LINES IN TRENCH
2 -EXIST. 12" DIA.
METER SILOS
EXIST.
TRUCK SCALE
2. -NEW 1500 TON
CAPACITY STORAGE
SILOS WITH ASH
CONDITIONING
UNLOADERS - -- -
FIGURE
LOCATION OF LOADOUT SILO
FOR BELEWS CREEK DRY FLY
ASH DISPOSAL FACILITY

30°,� RC
u
E .770+
EL. 769 +6
761
EL. 744+4
30"R( RCP
� � B
INV. EL. F
736+6 EL. 736 +0
EL.734+6
SLUICE GATE
STOP LOG
7/SLUICE GATE
"STOP LOG
B SECTION
FIGURE 2
NEW ASH BASIN
DISCHARGE TOWER

19�9 �G
S�Pg�a
PROPOSED DISCHARGE
TOWER GAP g
ASH BASIN ASH DIKE
MAX.W.S. EL. 760
SLUCE LINE
NORTH
0 1000 2000
r I
ACCESS4c�
SCALE-FEET
COAL ROADry S HARGETOWER AND
FF UENT RETURN
BELEWS LAKE
FIGURE 3 LAYOUT OF ASH BASIN WITH PROPOSED DISCHARGE TOWER

130
100
E
W
Figure 4 : Selenium concentration in Belews
Creek ash basin effluent as a
function of time after initial
operation of the dry fly ash system,
assuming losses from both discharged
effluent and sorption/sedimentation
(solid line) or assuming loss from
discharged effluent.only (broken line).
50 100 150 200
Days -T
250 300

NCI VA
W
J cr.
W
= ZO >
Ill o W DAN RIVER
Y a w /STEAM
0 0 � o STATION
a
DAN RIVER
710.0j 720.0 730.0.732.0
PROPOSED 713.0
ASH BASIN
DISCHARGE
POINT
-i
NC I V A KILOMETER 0 10 20 30 40
m
Figure 5 SCHEMATIC DIAGRAM OF THE DAN RIVER AND PROPOSED SAMPLING
LOCATIONS.

Table 1. Calculated selenium concentrations in Belews Lake and the Belews Creek
ash basin as a function of time in days following initial operation of
the dry fly ash system, assumed to begin at the time of the fall over-
turn in Belews -Lake.
1 Assume 14 cfs discharge, (Se)o' ='130 pg/l,(Se)final = 10 ug/l
2'Assume 66 cfs average discharge, (Se
)o 9. ug/1, (Se)final = natural
background equilibrium at t = Co.
Ash
Basin 1
Belews
Lake 2
t, days
(Se),ug/.l
Se mass/day.
t, days
(Se), ug/l
Se mass/day
discharged, kg
discharged, kg
0
130.
4.45
0
9.2
1.49
35
90
3.08
30
= 9.3
1.50
90
50
1.71
90
9.4
1.52
120
40
1.37
120
9.3
1.49
150
30
1..03
.150
9.1
1.46
190
20
0.68
180
8.8
1.43
220
15
0.51
210
8.6
1.39
260
10
0.34
240
8.4
1.35
1 Assume 14 cfs discharge, (Se)o' ='130 pg/l,(Se)final = 10 ug/l
2'Assume 66 cfs average discharge, (Se
)o 9. ug/1, (Se)final = natural
background equilibrium at t = Co.

TABLE 3 CODE TO VARIABLES TO BE ANALYZED, SAMPLING -FREQUENCY
ABBREVIATIONS, AND DESCRIPTIONS OF PROPOSED SAMPLING
LOCATIONS.
Code to Variables Analyzed
Sediment -Total Se and As
Water Chemistry - Temperature; Dissolved Oxygen; pH; Specific
Conductance, Re Total and Soluble Se and As, Total -Cd, Cu, Zn;
Total Suspen a Solids
Body Burdens - Total As, Se , Cd, Cu, Zn
Samplinq Frequency Abbreviations
F = Fall
SP = Spring 0'10,
BM = Bi -monthly (every other month)
J: in , yn'j t4
List of Sampling Locations with Descriptions
Location Description
710.0 Near U.S. - 311 Bridge (upstream of discharge)
713.0 — ''�� Proposed ash basin discharge stream from BCSS
720.0 Backwater area above low head dam near Madison, NC.
_water intake (or below dam for fish if electrofishing
boat cannot be launched at this site)
730.0 Near Dan River Plant Intake
732.0 Mayfield, NC, USGS Gaging Station near NC/VA border.

PHASE I. BASELINE
DAN RIVER SAMPLING
PRIOR TO DISCHARGE OF BCSS
730.0
BOTTOM ASH
SLUICE WATER TO
THE RIVER.
Sp/F
Sp/F
Sp/F
710:0
720.0
730.0
732.0
Sediments
Sp/F
Sp/F
Sp/F
Sp/F
Water Chemistry
B.M.
B.M.
B.M./M*
B.M.
Benthos and Fish
Benthos and Fish
Body Burdens
Sp/F
Sp/F
Sp/F
Sp/F
Benthos and Fish
*Belews Creek
Plant Ash
Basin NPDES Effluent
Data Including.Total
Qualitative Data
Sp/F
Sp/F
Sp/F
Sp/F
*Dan River Plant
NPDES In.take Parameters Including
Total Se and
As.
PHASE II. MONITORING PROGRAM OF DAN RIVER FOR TWO -(2) YEARS
AFTER BCSS ASH BASIN EFFLUENT IS DISCHARGED TO THE RIVER.
PHASE III. DEPENDING ON RESULTS OF PHASE II MONITORING AND CONSULTATION WITH
N.C. REPRESENTATIVES, THE NECESSITY OF AN EXTENT OF.MONITORING THE
DAN RIVER BEYOND PHASE II WILL BE DETERMINED.
710.0
713.0 720.0
730.0
732.0
Sediments
Sp/F
Sp/F
Sp/F
Sp/F
Water Chemistry
B.M.
B.M./M* B.M.
B.M./M**
B.M.
Benthos and ,Fish
Body Burden
Sp/F
Sp/F
Sp/F
Sp/F
Benthos and Fish
Qualitative Data
Sp/F
Sp/F.
Sp/F
Sp/F
*Belews Creek
Plant Ash
Basin NPDES Effluent
Data Including.Total
Se and As
**Dan River Plant Intake
NPDES Parameters Including Total.Se
and As.
PHASE III. DEPENDING ON RESULTS OF PHASE II MONITORING AND CONSULTATION WITH
N.C. REPRESENTATIVES, THE NECESSITY OF AN EXTENT OF.MONITORING THE
DAN RIVER BEYOND PHASE II WILL BE DETERMINED.