NC0004961_App for Specail Order by Consent EMC SOC WQ S16-005_20160715

WaterResources
ENVIRONMENTAL QUALITY
July 15, 2016
PAT MCCRORY
Governor
DONALD R VAN DER VAART
Secretary
S. JAY ZIMMERMAN
Mr. Harry K. Sideris, Senior Vice -President — Environmental, Health & Safety
Duke Energy Carolinas, LLC
526 South Church Street FRECEIVED
Mail Code EC3XP
Charlotte, NC 28202 J U L 19 Z U 16
CENTRALFILES
Subject: Non Refundable ProcessingFee DWa SECTION
Special Order by Consent
EMC SOC WQ S16-005
Duke Energy Carolinas, LLC — Riverbend Steam Station WWTP
NPDES Permit Number NC0004961
Gaston County
Dear Mr. Sideris:
Director
This is to acknowledge receipt of your application for a Special Order by Consent (SOC), accompanied
by your check number 10000150223 in the amount of $400.00. These items were received in our
office on July 14, 2016.
If you have any questions concerning the SOC, please contact Jeff Poupart, Chief of the Water Quality
Permitting Section at [phone], or via email at [e-mail]; or you may contact me
at [phone] (e-mail: bob. sledge@ncdenr. gov).
Sincerely,
t
fobdge
Compliance & Expedited Permitting Unit
cc: Mooresville Regional Office w/attachment
SOC Files w/attachment
Central Files w/attachment
ec: Jeff Poupart
Jay Zimmerman
Shannon Langley
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919-707-9000

Y
NKE
GY
July 12, 2016
Mr. Jeffrey Poupart
North Carolina Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Application for Special Order by Consent
Duke Energy Carolinas, LLC.
Riverbend Steam Station
Permit #: NC0004961
Gaston County
Dear Mr. Poupart,
Harry K. Sidens
Senor Vice President
Environmental, Health 6 Safety
526 S. Church Street
Mail Code, EC3XP
Charlotte, NC 28202
[phone]
Duke Energy Carolinas, LLC (Duke Energy) is submitting herewith application for Special
Order by Consent for the Riverbend Station. A completed application (in triplicate) and check in
the amount of $400.00 for the nonrefundable application fee are enclosed.
Should you have any questions regarding this letter or require additional information, please
contact Mr. Shannon Langley at (919) 5462439 or at [e-mail].
"1 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. 1 am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations. "
Sincerely,
l
Harry Sideris
SVP- Environmental, Health & Safety
Enclosures
Duke Energy cc: Richard Baker, Jim Wells, Matt Hanchey, Shannon Langley, Brad Loveland

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
APPLICATION FOR A SPECIAL ORDER BY CONSENT (SOC)
I. PERMIT RELATED INFORMATION:
1. Applicant (corporation, individual, or other): Duke Energy Carolinas, LLC.
2. Print or Type Owner's or Signing Official's Name and Title:
Harry K. Sideris, Senior Vice President
3. Facility Name (as shown on Permit): Riverbend Steam Station
4. Owner Phone: [phone]
5. Owner Email: [e-mail]
4. Application Date: July 12, 2016
5. NPDES Permit No. (if applicable): N00004961
(or)
6. Name of the specific wastewater treatment facility (if dierenl from L3. above):
Riverbend Steam Station
II. PRE -APPLICATION MEETING:
Prior to submitting this completed application form, applicants must meet with the appropriate
regional office staff to discuss whether or not an SOC is appropriate for this situation. Please
note the date this meeting occurred and who represented the permittee:
Representative: various discussions held with DEQ management over several months Date: various
III. ADDITIONAL FLOW OR FLOW REALLOCATION:
In accordance with NCGS 143-215.67(b), only facilities owned by a unit of government may
request additional flow.
Additional flow may be allowed under an SOC only in specific circumstances. These
circumstances may include eliminating discharges that are not compliant with an NPDES or
Non -discharge permit. These circumstances do not include failure to perform proper
maintenance of treatment systems, collection systems or disposal systems. When requesting
additional flow, the facility must include its justification and supporting documentation.

If the requested additional flow is non-domestic, the facility must be able to demonstrate the
ability to effectively treat the waste and dispose of residuals. The applicant must provide a
detailed analysis of the constituents in the proposed non-domestic wastewater.
The total domestic additional flow requested: N/A gallons per day.
The total non-domestic additional flow requested: N/A gallons per day.
The total additional flow (sum of the above): N/A gallons per day.
Please attach a detailed description or project listing of the proposed allocation for additional
flow, with an explanation of how flow quantities were estimated. Further, any additional flow
requested must be justified by a complete analysis, by the permittee, that additional flow will not
adversely impact wastewater collection/treatment facilities or surface waters.
IV. NECESSITY NARRATIVE:
Please attach a narrative providing a detailed explanation of the circumstances regarding the
necessity of the proposed SOC. Include the following issues:
• Existing and/or unavoidable future violations(s) of permit conditions or limits(s),
• The existing treatment process and any process modifications that have been made to
date to ensure optimum performance of existing facilities,
• Collection system rehabilitation work completed or scheduled (including dates),
• Coordination with industrial users regarding their discharges or pretreatment facilities.
Identify any non-compliant significant industrial users and measure(s) proposed or
already taken to bring the pretreatment facilities back into compliance. If any industrial
facilities are currently under consent agreements, please attach these agreements,
• Date and outcome of last Industrial Waste Survey,
• Whether or not the facility is acting as a regional facility receiving wastewater from other
municipalities having independent pretreatment programs.
V. CERTIFICATION:
The applicant must submit a report prepared by an independent professional with expertise in
wastewater treatment. This report must address the following:
• An evaluation of existing treatment units, operational procedures and recommendations
as to how the efficiencies of these facilities can be maximized. The person in charge of
such evaluation must sign this document.
• A certification that these facilities could not be operated in a manner that would achieve
compliance with final permit limits. The person making such determination must sign
this certification.
• The effluent limits that the facility could be expected to meet if operated at their
maximum efficiency during the term of the requested SOC (be sure to consider interim
construction phases).
• Any other actions taken to correct problems prior to requesting the SOC.
2

VI. PREDICTED COMPLIANCE SCHEDULE:
The applicant must submit a detailed listing of activities along with time frames that are
necessary to bring the facility into compliance. This schedule should include milestone dates for
beginning construction, ending construction, and achieving final compliance at a minimum. In
determining the milestone dates, the following should be considered:
• Time for submitting plans, specifications and appropriate engineering reports to DWR for
review and approval.
• Occurrence of major construction activities that are likely to affect facility performance
(units out of service, diversion of flows, etc.) to include a plan of action to minimize
impacts to surface waters.
• Infiltration/inflow work, if necessary.
• Industrial users achieving compliance with their pretreatment permits if applicable.
• Toxicity Reduction Evaluations (TRE), if necessary.
VII. FUNDING SOURCES IDENTIFICATION:
The applicant must list the sources of funds utilized to complete the work needed to bring the
facility into compliance. Possible funding sources include but are not limited to loan
commitments, bonds, letters of credit, block grants and cash reserves. The applicant must show
that the funds are available, or can be secured in time to meet the schedule outlined as part of this
application.
If funding is not available at the beginning of the SOC process, the permittee must submit a copy
of all funding applications to ensure that all efforts are being made to secure such funds.
Note: A copy of the application should be sufficient to demonstrate timeliness unless regional
office has reason to request all information associated with securing funding.
THE DIVISION OF WATER RESOURCES WILL NOT ACCEPT THIS APPLICATION
PACKAGE UNLESS ALL OF THE APPLICABLE ITEMS ARE INCLUDED WITH THE
SUBMITTAL.
Reguired Items:
a. One original and two copies of the completed and appropriately executed application
form, along with all required attachments.
• If the SOC is for a City / Town, the person signing the SOC must be a ranking
elected official or other duly authorized employee.
• If the SOC is for a Corporation / Company / Industry / Other, the person signing
the SOC must be a principal executive officer of at least the level of vice-
president, or his duly authorized representative.
• If the SOC is for a School District, the person signing the SOC must be the
Superintendent of Schools or other duly authorized employee.
C,

Note: Reference to signatory requirements in SOCs may be found in the North
Carolina Administrative Code [T15A NCAC 2H .1206(a)(3)].
b. The non-refundable Special Order by Consent (SOC) processing fee of $400.00. A
check must be made payable to The Department of Environment and Natural
Resources.
c. An evaluation report prepared by an independent consultant with expertise in
wastewater. (in triplicate)
APPLICANT'S CERTIFICATION:
(NO MODIFICATION TO THIS CERTIFICATION IS ACCEPTABLE)
I, Harry K. Sideris , attest this application for a Special Order by
Consent (SOC) has been reviewed by me and is accurate and complete to the best of my
knowledge. I understand if all required parts of this application are not completed and if all
required supporting information and attachments are not included, this application package may
be returned as incomplete. (Please be advised that the return of this application does not prevent
DWR from collecting all outstanding penalties upon request). Furthermore, I attest by my
signature that I fully understand that an upfront penalty, which may satisfy as a full
settlement of outstanding violations, may be imposed. (Note: Reference to upfront penalties
in Special Orders by Consent may be found in the North Carolina Administrative Code [T15A
NCAC 2H .1206(c)(3)].}
Signature oMigning Official
Printed Wame of Signing Official
THE COMPLETED APPLICATION PACKAGE, INCLUDING THE ORIGINAL AND TWO
COPIES OF ALL SUPPORTING INFORMATION AND MATERIALS, SHOULD BE SENT
TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER RESOURCES
POINT SOURCE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1617
IF THIS APPLICATION IS FOR A NON -DISCHARGE SYSTEM, THEN SEND TO:
NORTH CAROLINA DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
1636 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1636
4

Duke Energy Carolinas, I.I.C.
Application for Special Order by Consent
Supplemental information
Riverbend Steam Station
NPDES Permit #: NC0004961
Gaston County
July, 2016
Duke Energy application for Special Order by Consent
Riverbend Steam Station
NPDES Permit #: NC0004961
Gaston County
Page i of 7

Table of Contents
1. Section IV. Necessity narrative
2. Section V. Certification (To be submitted under separate cover)
3. Section VI. Predicted Compliance Schedule
4. Section VII. Funding Sources Identification
S. Non-refundable application fee of $400.00
Duke Energy application for Special Order by Consent
Riverbend Steam Station
NPDES Permit #: NC0004961
Gaston County Page 2 of 7

Application Section IV. Necessity Narrative
Existing and/or unavoidable future violations(s) of permit conditions or
limits(s):
Duke Energy anticipates future violations of limits on Total Hardness and pH in Outfalls 101
through 112. Outfalls 101 through 112 are designated in the NPDES permit for Riverbend
Steam Station as discharges of wastewater that has migrated from the impoundment via seepage
into groundwater. While travelling through groundwater, this wastewater interacts with soils,
biota, and stormwater in ways that cannot be controlled by Duke Energy. The interactions result
in ranges of pH and Total Hardness that are consistent with naturally occurring conditions and
that, due to natural variability, can be anticipated to fall outside of permit limits from time to
time.
Duke Energy is addressing these discharges by closing the impoundments and implementing
groundwater corrective action in accordance with the North Carolina Coal Ash Management Act
of 2014 ("CAMA"). CAMA requires the impoundments to be closed and all ash excavated by
August 1, 2019. Duke Energy has begun bulk dewatering from the impoundments and
anticipates that excavation will begin this fall. Dewatering will reduce the hydrologic head
driving groundwater to the outfalls, and excavation will remove the source material for the
pollutants. However, natural flow patterns may result in continued discharges at some locations.
The existing treatment process and any process modifications that have been
made to date to ensure optimum performance of existing facilities:
The wastewater generated by the site is treated in the sites ash basin. pH adjustment is
performed if necessary to assure that discharges from the ash basin through outfall XXX is
within permit limits. pH of wastewater in and leaving the ash basin falls within the permit
requirements of 6.0 and 9.0 standard units. Adjustment of pH is usually required because the
basin has a pH above 9.0.
The pH of seepage outfalls as identified in the Riverbend NPDES permit are influenced by
conditions in the soil and may from time to time fall below 6.0 standard units as is typical for
small flows. Additionally, seepage outfalls included in the Riverbend permit do not have the
capability to include pH adjustment.
Likewise, as related to hardness, discharges from the ash basin and the facility have shown no
reasonable potential to cause the contravention of water quality standards for hardness in the
receiving waters of Mountain Island lake. Hardness is applicable to receiving waters classified
as "water supply" and in the case of the Riverbend permit this standard is applied to the small
receiving streams that flow into Mountain Island lake. Hardness has no known health or
Duke Energy application for Special Order by Consent
Riverbend Steam Station
NPDES Permit #: NC0004961
Gaston County Page 3 of 7

environmental risks. The following information is extracted from a document produced by the
SCDHEC on drinking water (SCDHEC CR -006453 11/09).
Hardness in drinking water:
Causes
The amount of naturally occurring calcium and magnesium compounds dissolved by the water as
it filters through the earth will determine its hardness Hardness varies with location and the
types of minerals and rocks in the earth.
Effects:
Despite all of the problems it causes, hard water is not considered to be a health hazard.
Moderate amounts of hardness are desirable because of the protective coating it produces on
exposed metal surfaces. Excessively hard water, however, will cause a hard, chalky scale (boiler
scale) to form when the water is heated. Water heaters are especially affected by hardness. The
boiler scale will accumulate on the heating elements, reducing their heating capacity, and
eventually causing them to burn -out. Hard water will form a while, powdery residue on
plumbing fixtures, and will cause spots on dishes. Because calcium and magnesium compounds
are not very soluble in cold water, ice made from hard water may contain white particles.
Vegetables cooked in hard water may be tough. More soap must be added to a hard water to
produce a lather. With very hard water, soap will form a sticky "curd, " which is difficult to
remove from fabrics and containers.
Laundry washed in hard water will be stiff and dingy. Hair becomes dull and limp when washed
in bard water.
Collection system rehabilitation work completed or scheduled (including dates): N/A
Coordination with industrial users regarding their discharges or pretreatment facilities: N/A
Identify any non-compliant significant industrial users and measure(s) proposed or already
taken to bring the pretreatment facilities back into compliance: N/A
Date and outcome of last Industrial Waste Survey: N/A
Whether or not the facility is acting as a regional facility receiving wastewater from other
municipalities having independent pretreatment programs: N/A
Duke Energy application for Special Order by Consent
Riverbend Steam Station
NPDES Permit t NC0004961
Gaston County
Page 4 of 7

Section V. Certification
Submitted under separate cover.
Duke Energy application for Special Order by Consent
Riverbend Steam Station
NPDES Permit #: NC0004961
Gaston County
Page 5 of 7

Section VI. Predicted compliance schedule
Under the Order, Duke proposes to undertake the following activities.
1. Within 30 days of the finalization of the Order, submit request for effluent channel
designation related to seeps at Riverbend. (MET)
2. Within 30 days of receipt of effluent channel designation, as applicable, submit a
permit application to the United States Army Corps of Engineers. The application
will seek to improve the channel to the extent needed. Activities required for
improvement and/or modification to each channel will vary and be specific to each
channel. The activities may range from rip rap lining of the channel, installation of
conveyance piping etc. to no significant modification at all.
3. Duke will provide needed information for DEQ to perform Reasonable Potential
Analysis (RPA) on seeps in relation to receiving waters of the Catawba River.
4. Within 90 days of receipt of all permits needed to Improve the effluent channels at
Riverbend, Duke will begin the process of effluent channel modification
construction.
S. Within 90 days of beginning effluent channel modifications, Duke will complete
effluent channel modification construction.
6. Upon completion of effluent channel modifications and modification of the NPDES
permit limits based on the submitted evaluation of NPDES permit RPA with receiving
waters being the Catawba River, Duke will comply with modified limits for
discharges to the Catawba River via effluent channels. Between the effective date of
the Order and the date of modified RPA based limits, Duke will comply with modified pH
and Hardness limits for Outfalls 101-112 as follows:
Parameter
Permit Limit
Interim Limits (SOC)
pH
6.0-9.0
4.0-9.0
Total Hardness
100.0 mg/L monthly average
100.0 mg/L daily average
200 mg/L monthly average
200 mg/L daily average
7. If any new seep discharges are discovered after the effective date of the Order they shall be
subject to the same requirements.
8. During the term of the Order, Duke will submit quarterly reports due January 31,
April 30, July 31 and October 31 of each year that the Order is in effect.
Duke Energy application for Special Order by Consent
Riverbend Steam Station
NPDES Permit #: NC0004961
Gaston County
Page 6 of 7

Section VII. Funding Source Identification
Duke Energy will provide adequate funds to engineer, permit and implement the
proposed activities listed in Section VI. As detailed in the company's filings with the
Securities and Exchange Commission (available at http:/Lwww.duke-
enerey.com/investors/default.asp), Duke Energy Carolinas has sufficient resources to fund
the activities, without the need for external funding sources.
Duke Energy application for Special Order by Consent
Riverbend Steam Station
NPDES Permit #: NC0004961
Gaston County
Page 7 of 7