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HomeMy WebLinkAboutNC0004961_Appx A - Regulatory Correspondence_201710312017 Comprehensive Site Assessment Update October 2017 Riverbend Steam Station SynTerra APPENDIX A REGULATORY CORRESPONDENCE NCDEQ Expectations Document (July 18, 2017) Completed NCDEQ CSA Update Expectations Check List NORR Letter NPDES Wastewater Permit #NC004961 NCDEQ Correspondence - Revised Interim Monitoring Plan DEQ Background Location Approvals - July 7, 2017 Zimmerman to Draovitch September 1, 2017 DEQ PBTV Approval Attachments - September 1, 2017 2017 Comprehensive Site Assessment Update October 2017 Riverbend Steam Station NCDEQ EXPECTATIONS DOCUMENT ()ULY 18, 2017) SynTerra DRAFT Review of Draft Final Updated CSA Table of Contents submitted by Duke Energy July 18, 2017 The Updated Comprehensive Site Assessment Report(CSAs) must meet the requirements of 02L .0106 (g), CAMA, and general guidelines provided in the Notice of Regulatory Requirements letter from DEQ to Duke on August 13, 2014. Pursuant to 02L .0106 (g), the CSAs shall: • Identify the source and cause of contamination, • Identify imminent hazards and document actions taken to mitigate them, • Identify all receptors, • Define the horizontal and vertical extent of contamination, • Understand all significant factors affecting contaminant transport, • Understand geological and hydrogeological factors influencing the movement, chemical, and physical character of the contaminants. It is the expectation that the CSA report be a stand-alone document that integrates, interprets, and presents all data/information collected to date. The table of contents submitted on 7/18/17 should be revised as necessary to ensure that the following comments are reflected in the CSA report. 1. Site history • Facility description, geographic setting, surrounding land use, permitting history, and compliance boundaries and permitted sampling, etc. • ash related history • history prior to Duke ownership • history of waste releases unrelated to coal ash 2. Identification of source areas' 3. Identification of potential receptors • Surface water o Is the SW used as drinking water supply? if so, what is the distance to intake? • Supply wells o Need map and table showing all receptors identified o Has each identified supply well been abandoned and connected to alternative permanent water? ' Large ash basins or other waste areas may need to be divided into separate smaller source areas if, for example, contaminant transport is toward different sets of receptors. Where appropriate, some source areas may be strategically combined based on geographic proximity (for example, conjoining or overlapping source areas), common source characteristics and impacts, common receptors, and a shared proposed remedy. The Regional Office should be consulted when identifying source areas for purposes of CSA and CAP development. Page 1 of 8 • Evaluation: Are COls in supply wells above 2L/IMAC/background and sourced by ash? 4. Raw data collected to date • A separate orthophoto base map2 should be provided for each of the following: o All GW monitoring and supply wells ■ Show screened interval (ft) and most recent concentration of boron and COls (ug/L) (use different color font for each flow unit) o All SW, seep, and effluent channel (permitted) sample locations ■ Show most recent results of boron and COls (ug/L) o All SW locations sampled specifically to determine whether contaminated GW is causing 2B violations ■ Show most recent results of boron and COls (ug/L); use bold font for values that exceeded 2B standards (ug/L) o All solid phase sample locations, to include ash, soil, and sediment locations ■ Show sample depth (ft bls) and corresponding concentration of COls (mg/kg) o Location, flow unit, screened/open interval (ft bls), and value (ft/d) of hydraulic conductivity (k) measurements (use different color font for each flow unit) o Location, depth (ft bls), and flow unit of soil -water pairs (use different color font for each flow unit) o Location, depth (ft bls), flow unit, and value of HFO measurements (use different color font for each flow unit) o Location, depth (ft bls), and flow unit of sorption coefficient (Kds) measurements (use different color font for each flow unit) o Location, flow unit, and value of pH measurements (use different color font for each flow unit) o Location, flow unit, and value of Eh measurements (mV) (use different color font for each flow unit) o Location of vertical gradient calculations between shallow/TZ unit and BR unit, showing value (+ is downward gradient, - is upward gradient) Cross section maps showing ash position, hydrostratigraphy, screen/open intervals, water level, and groundwater boron and COI concentrations (ug/L) o inset should show location (in plan view) of the cross section Summary data tables: o properties for ash, fill, alluvium, soil/saprolite, deep, and bedrock units, as applicable, including: ■ Porosity ■ Specific storage ■ Permeability (field, lab, historic) ■ Mineralogy and oxides ■ Physical Methodology, computations, etc. may be referenced, as applicable o hydraulic conductivities (k, in ft/d), sorted by flow unit, along with well identifier, flow unit, and screened/open interval (ft bls) o sorption coefficients (Kd), sorted by COI then flow unit, along with boring location identifier, flow unit, and depth (ft bls) 2 All base maps should include2 to 4 foot topographic contours, all surface water features, all jurisdictional wetlands, all source areas along with waste boundaries and compliance boundaries if applicable, all monitor wells, and, where scale allows, all supply wells. Page 2 of 8 • Appendices o Raw data tables showing chemistry results for: ■ all GW, SW, and seep sample events (appendix and digital excel file) ■ all ash, soil, sediment, and whole rock chemistry results (appendix and digital excel file) ■ all SPLP samples (appendix and digital excel file) ■ lat/long, flow unit (if applicable), etc. should be included for each sample location ■ current "master spreadsheet" format may be used ■ lab QC data may be referenced if it has already been provided in a separate report o Summary table of monitor well construction details showing well, location (decimal degree lat/long), screen/open interval, depth to water, date installed, flow unit being monitored, date abandoned if applicable, etc. o Water level measurements from all wells and current and historical measurement events (appendix and digital excel file) ■ List of wells that were dry during sampling or measurement attempts, along with its flow unit, screened/open interval, and date o Sorption coefficient testing - methodology, raw data, and computations may be referenced o Boring logs and well construction records ■ Include all assessment, historic, CCR, or other wells installed to date ■ Each log should be quality controlled for accuracy and include static WL information. o Geophysical logs, rose diagrams, lineament map o Soil and rock photos o Most recent pre -ash basin USGS topographic map, with superimposed source areas o Screening level risk assessment ■ Human health ■ Ecological o Flow and transport model o Geochemical model o GW-SW mixing model, if applicable 5. Site conceptual model • Overview of the major components, including source(s), hydrologic boundaries, migration pathway(s), receptors, etc. • Regional geology and how it is affecting GW flow, GW quality, and contaminant transport at the site • Hydrostratigraphy (flow units) o Flow properties and heterogeneities of each unit ■ Discuss hydraulic conductivities and vertical gradients (refer to maps in 4. above) ■ Describe where flow units pinch out in each unit, as applicable ■ Discuss fractured bedrock heterogeneities across the site, including ranges of hydraulic conductivities and porosities ■ Discuss maximum depth of investigation and observed fracture density with depth; compare this to the depths of proximate supply wells Page 3 of 8 • Areas of recharge and discharge • Flow directions o Potentiometric map (summer) of shallow/TZ unit o Potentiometric map (winter) of shallow/TZ unit o Potentiometric map (summer) of bedrock unit o Potentiometric map (winter) of bedrock unit ■ Potentiometric maps should utilize and show all facility wells, should clearly show all blue line tributaries, wetlands, and other SWs, and should indicate areas where a flow unit pinches out as applicable o Evaluation: Do seasonal or tidal influences effect GW flow or GW chemistry? 6. Background concentrations (PBTVs) of soil and groundwater. • Piper diagrams for shallow b/g, deep b/g, and bedrock b/g, along with well labels for plotted points • List PBTVs for soil • List PBTVs for groundwater, by flow unit • Methodology (appendix) • Description of background wells (why those chosen are appropriate for use) and soil sample locations (appendix) • Table of all raw background data showing strikethroughs of unused high pH, high turbidity, autocorrelated, and outlier data (appendix; digital excel file) 7. Contaminant assessment For each source area, • History of ash placement • Area, depth, and volume of ash (include also the area, depth, and volume of saturated/submerged ash) • Status of source removal or control • Orthophoto base map (large scale, 1 inch — 100 feet) showing waste boundary, compliance boundary if applicable, 2 to 4 ft topographic contours, all blue line surface water and wetland features, along with the following: o subset of supply well and SW receptors from 3. above that are potentially susceptible to contaminant migration from this particular source area ■ Include inset table with list of supply wells and SW receptors for this source area o monitor wells, supply wells, and SW, seep, ash, soil, and sediment locations ■ Indicate most recent value (ug/L) for boron and for each COI, and whether its concentration is increasing, decreasing, stable, or unknown • Evaluation: Show a vertical gradient isopleth map and discuss vertical gradients and their effect on GW flow • List COls (constituents above 02L/IMAC/background) for each flow unit beyond compliance boundary (or that are within bedrock monitor wells within or beyond compliance boundary if receptors are potentially at risk) • List pH and Eh ranges found in: pore water, d/g shallow unit, d/g TZ unit, and d/g BR unit • Evaluation: Explain the geochemical controls on COls that do not behave as a plume (Fe, Mn, etc.). Page 4 of 8 Evaluation: Use the pH, Eh, Kd, and HFO results to discuss the expected capacity of the subsurface to sorb cationic COls and anionic COls occurring from source to receptor within each of the flow units. • Provide the following "data inventory": o (a) have background concentrations been formally established for all COls in soil and groundwater? o (b) for each source area, how many wells within each flow system are located along the contaminant plume centerline? Along a cross sectional transect that is perpendicular to the plume centerline? o (c) how many wells in (b) above are screened across the most contaminated vertical interval of a given flow unit or are screened across the full thickness of the flow unit? o (d) is the d/g edge of the plume centerline measured or is this location obstructed by a major SW or other access issue? If so, is it measured by wells that are screened across each flow unit? o (d) what is the length of record and how many valid sample events are available for wells listed in (b), (c), and (d) above? o (e) does turbidity, well construction (for example, grout contamination, etc.), or well "break in" issues preclude the use of data in (b), (c), and (or) (d)? o (f) for each source area and within each flow unit, how many spatial locations were sampled for solid phase chemistry and were these locations associated with "end member" (maximum and minimum) groundwater concentrations for each contaminantl"? How many of these spatial locations are associated with (b) or (c) above? o (g) given that iron hydroxide (HFO) content is a good indicator of retention capacity for most metal contaminants, how many locations in (f) was HFO measured? For each COI in this particular source area, o Evaluation: Were wells properly positioned and screened to measure the horizontal and vertical extent of the plume? If so, describe the horizontal and vertical plume extent using plan view and cross sectional maps. o Has the plume migrated to any supply wells, SW receptors, or GW future use areas? o Has the plume migrated to any supply wells, SW receptors, or GW future use areas at concentrations above 2L/IMAC/background? o Evaluation: Were wells positioned and screened to measure the maximum concentrations migrating from source to receptor along the longitudinal plume centerline? If so, describe the plume characteristics is space and time as it flows along the centerline, through the identified flow units, and discharges into the nearest supply well or SW receptor. o Evaluation: Use maps, graphs, statistics, and mass movement or balance equations to show whether the plume is expanding and whether the plume is moving. ■ Show the COI -distance plot of wells positioned along a plume centerline from source to farthest d/g location (closest to receptor or future use area. Ill Measuring the solid phase contaminant concentrations in locations of both low and high groundwater C01 concentrations are important in understanding the sorptive capacity of the system. This is particularly true in the case of non -linear isotherm adsorption models that describe most metals. That is, a soil has a limited ability to sorb contaminant mass due, for example, to limited sorption sites, so a soil can become less efficient at removing mass at higher dissolved concentrations. Page 5 of 8 ■ If applicable, show COI -distance plots at different timepoints to demonstrate potential plume expansion or migration. ■ If applicable and sufficient sample events are available, use single -well linear regression or Mann-Kendall/Theil-Sen type trend statistics to show increasing or decreasing trends at selected d/g monitor wells. o Describe the soil -water pairs and Kd lab test sample results. Describe where they were collected, why those locations were selected, and whether those locations are reflective of high and low COI concentrations in a given flow unit. o Show concentration isopleths for each COI, including contours of concentrations below and well above the 2L/IMAC (choose — five contours per COI, from "moderately low" to "high") o Show stacked boron -time plots of wells positioned along a plume centerline from source to farthest d/g location (closest to receptor) Summary of corrective actions taken to date, if applicable • Describe preliminary corrective action alternatives for this source area f:� .. u . •.Cal • Description of model • Model construction — domain, layers, boundary conditions, recharge and discharge areas, supply wells, hydraulic conductivities, stream conductances, etc. o Layer thicknesses in cross section (show vertical scale in feet) o Location of supply wells outside model domain • Calibration method o List of target wells used in calibration o List of monitor wells not used in calibration and the rationale for each that was omitted • Calibration results (where mapped, superimpose on orthophoto base map described above) o Hydraulic conductivity zones versus measured values for the zone o List of simulated versus observed heads (include wells and SW features) o List of simulated versus observed vertical gradients from well pair locations o List of simulated versus observed discharge to streams o Potentiometric surface ■ Simulated for each flow layer ■ Observed, shallow ■ Observed, deep ■ Observed, BR o Flow paths (particle tracks) from each source area o Reverse flow paths (particle tracks) from SW receptors o Reverse flow paths (particle tracks) from supply wells (because supply wells are usually open from casing (at —50 to 75 ft) down to 200 to 500 feet, release particles in all simulated bedrock layers) • Quantitative sensitivity analyses to key inputs at various selected d/g locations • Describe the most significant model limitations 9. Transport model • Description of model • Model construction — boundary conditions, time steps, initial conditions, etc. o Source loading, per layer o Background concentrations, per layer Page 6 of 8 o Initial Kds, per layer o Dispersivities, per layer o Effective porosities, per layer • Calibration method o List of target wells used in calibration o List of monitor wells not used in calibration and the rationale for each that was omitted o Calibrated Kds, per layer • Calibration results (where mapped, superimpose on orthophoto base map described above) o List of simulated versus observed concentrations in target wells o List of simulated concentrations in SW discharge locations as shown using particle tracks released from source areas o List of simulated versus observed concentrations in selected well pair locations • Boron isopleth map ■ Simulated for each flow layer ■ Observed, shallow ■ Observed, deep ■ Observed, BR • For each source area, the time, direction, and distance of contaminant travel must be predicted under existing conditions and under any other contemplated source control measure (for example, engineered cap and (or) excavation). For these scenarios, the following figures are expected: o (a) a concentration -time plot for each COI corresponding to the following locations: (i) nearest supply well, (ii) nearest future groundwater use area, and (iii) nearest surface water. ■ In the plot margin, the following information should be provided: the time it takes for the COI to reach (i), (ii), and (iii), the time it takes for the COI to reach (i), (ii), and (iii) at its 2L/IMAC concentration, the time it takes for the COI to reach (i), (ii), and (iii) at its maximum concentration, and the time it takes for the COI to reach (i), (ii), and (iii) at a concentration that is back below the 2L/IMAC concentration. o (b) a map superimposed on the requested base map showing the maximum predicted migration distance, at any detectable concentration, of each COI. o (c) a map superimposed on the requested base map showing the maximum predicted migration distance, at the 2L/IMAC standard concentration, of each COI. • Quantitative sensitivity analyses to key inputs at various selected d/g locations and times • Describe the most significant model limitations 10. Geochemical model for COls controlled primarily by geochemistry • Conceptual model based on observed site data o Describe geochemical controls on COI levels in each source area using site data o Assumptions used in developing the model o Discuss data used to develop the model ■ For example, how are mineral or adsorption concentrations in fractured media converted to PHREEQC concentrations representing reaction along the fractures? ■ How were modeled reactive mineral concentrations interpolated between or extrapolated from the limited number of data collected Page 7 of 8 o Discuss what the COI concentrations are most sensitive to (pH, Eh, iron/aluminum oxide content, Kd, distance from source, etc.) o Describe the most significant limitations of the model • Numerical model (PHREEQC or PHREEQC 1-D Transport model) o Description of model o Purpose of model o Model construction o Discuss data used to develop the flow model o Results with comparison to observed well data (PHREEQC model) or to longitudinal flow path transect data (PHREEQC 1-D Transport model) o Sensitivity analysis (to pH, Eh, Kd, COI concentration, total dissolved ion content, iron/aluminum oxide content, Kd, distance from source, etc.) o Describe the most significant limitations of the model 11. GW-SW mixing model • Description of model • Purpose of model • Model construction o Show on map the precise SW locations where model output (simulated SW concentration) was obtained o List and discuss data used to construct model ■ Permitted effluent discharge concentrations should be considered in the model construction o Assumptions • Results • Sensitivity analysis (to GW contaminant concentrations, permitted effluent concentrations, location where SW output was obtained, stream flow, nearby effluent loading to the SW, etc.) • Describe the most significant limitations of the model Page 8 of 8 2017 Comprehensive Site Assessment Update October 2017 Riverbend Steam Station COMPLETED NCDEQ CSA UPDATE EXPECTATIONS CHECK LIST SynTerra 2017 Comprehensive Site Assessment Update - Appendix A October 2017 Riverbend Steam Station SynTerra NCDEQ CSA Update Expectations — Check List NCDEQ provided expectations for elements to be included in the CSA Update, in addition to those provided in the NORR (August 2014) guidance. This guide is provided to assist locating the requested elements in this CSA Update Report: Report1 0 NCDEQ Expectations 11. Site History Facility description, geographic setting, surrounding land use, permitting history, and compliance Section 2.0 boundaries and permitted sampling, etc. ash related history Section 2.0 history prior to Duke ownership Section 2.1 history of waste releases unrelated to coal ash Section 2.7 1Large ash basins or other waste areas may need to be Sections 2.3, 2.4, divided into separate smaller source areas if, for and 3.0 example, contaminant transport is toward different sets of receptors. Where appropriate, some source areas may be strategically combined based on geographic proximity (for example, conjoining or overlapping source areas), common source characteristics and impacts, common receptors, and a shared proposed remedy. The Regional Office should be consulted when identifying source areas for purposes of CSA and CAP development. 3. Identification of Potential Receptors Duke to provide information on where new water lines Appendix D & are planned, estimated new water line taps, and Section 4.0 projected location for filtration systems. Duke and DEQ will work together to provide most recent analytical analysis for inclusion in CSA. Surface water : Sections 4.0 & Is the SW used as drinking water supply? if so, what is 4.4 the distance to intake? Supply wells: Figure 4-4 & Need map and table showing all receptors identified Table 4-1 Has each identified supply well been abandoned and Section 4.0 connected to alternative permanent water? Evaluation: Are COIs in supply wells above Section 14.3 2L/IMAC/back round and sourced b ash? Page 1 of 13 Tables - Shaded Blue Figures - Shaded Green CAP - Shaded Red 2017 Comprehensive Site Assessment Update - Appendix A October 2017 Riverbend Steam Station SynTerra NCDEQ CSA Update Expectations - Check List .. Figures: • All GW monitoring and supply well locations Figure 2-4 & Figure 4-4 • Show screened interval (ft. bgs.) and flow unit (use Figure 14-51 different color call out box for each flow unit) • Location, flow unit, and value of pH and Eh measurements • Most recent concentration of boron and COIs (ug/L) • Hydraulic conductivity (k) measurement value (ft/d) if available for corresponding well screen interval • All SW, AOW seep and effluent channel (permitted) Figure 14-52 sample locations — Show most recent results of boron and COIs (ug/L) • All solid phase sample locations, to include ash, soil, Figure 14-50 and sediment locations • Show sample depth (ft. bgs.) and flow unit • Concentration of COIs (mg/kg) • Location, depth (ft. bgs.) and flow unit of soil -water pairs shown as blue color font • Location, depth (ft. bgs.), flow unit for HFO measurements and value (mg/Kg) • Location, depth (ft. bgs.), flow unit for sorption coefficient (Kds) measurements and value (mL/g) • Location of vertical gradient calculations between Figure 11-37 shallow/TZ unit and BR unit, showing value (+ is downward gradient, - is upward gradient) • Cross section maps showing ash position, Figures 6-3 to 6-7 hydrostratigraphy, screen/open intervals, water level, and • Groundwater boron and COI concentrations (ug/L) Figures 11-41 to 11-64 • Inset should show location (in plan view) of the Figures 6-2 to 6- cross section 7, & 11-41 to 11- 64 Page 2 of 13 Tables - Shaded Blue Figures - Shaded Green CAP - Shaded Red 2017 Comprehensive Site Assessment Update - Appendix A October 2017 Riverbend Steam Station SynTerra NCDEQ CSA Update Expectations - Check List Summary Solid Phase properties for ash, fill, alluvium, Tables 3-1, 3-2, data tables: soil/saprolite, deep, and bedrock units, as applicable, 6-1, 6-2, 6-3, 6-4, including: 6-5, 6-6, 6-7, 6- 11, 6-12, 6-13, 6- - Porosity 14, 6-15, 6-17, & — Specific storage 6-18 — Permeability (field, lab, historic) — Mineralogy and oxides — Physical Methodology, computations, etc. may be referenced, as applicable hydraulic conductivities (k, in ft/d), sorted by flow unit, Table 6-16 along with well identifier, flow unit, and screened/open interval (ft bls) sorption coefficients (Kd), sorted by COI then flow unit, Table 11-1 along with boring location identifier, flow unit, and depth (ft bls) Raw data • all GW, SW, and seep sample events (appendix and Appendix B tables showing digital excel file) chemistry • all ash, soil, sediment, and whole rock chemistry results for: results (appendix and digital excel file) • all SPLP samples (appendix and digital excel file) • lat/long, flow unit (if applicable), etc. should be included for each sample location • current "master spreadsheet" format may be used • lab QC data may be referenced if it has already been provided in a separate report Summary table of monitor well construction details Table 2-1 showing well, location (decimal degree lat/long), screen/open interval, depth to water, date installed, flow unit being monitored, date abandoned if applicable, etc. • Water level measurements from all wells and current Table 6-8 and historical measurement events (appendix and digital excel file) • List of wells that were dry during sampling or measurement attempts, along with its flow unit, screened/open interval, and date Page 3 of 13 Tables - Shaded Blue Figures - Shaded Green CAP - Shaded Red 2017 Comprehensive Site Assessment Update - Appendix A October 2017 Riverbend Steam Station SynTerra NCDEQ CSA Update Expectations - Check List NPV "W • Expectations Report Sorption coefficient testing - methodology, raw data, Appendix C, G and computations may be referenced • Boring logs and well construction records Appendix F — Include all assessment, historic, CCR used for CAMA, or other wells installed to date — Each log should be quality controlled for accuracy and include static WL information. — Combined file Alpha -numeric sorting Geophysical logs, rose diagrams, lineament map Figures 6-14 & 6- 15 Soil and rock photos Appendix F Most recent pre -ash basin USGS topographic map, with Figure 1-1 & 2-2 superimposed source areas Screening level risk assessment — Human health Section 12.1 — Ecological Section 12.2 Flow and transport model Section 13.1 Geochemical model Section 13.2 GW-SW mixing model, if applicable Section 13.3 •.-i Overview of the major components, including source(s), Sections 4.0, 6.0, hydrologic boundaries, migration pathway(s), receptors, 12114 etc. Regional geology and how it is affecting GW flow, GW Section 5.0 & quality, and contaminant transport at the site 14.0 Hydrostratigraphy (flow units) • Flow properties and heterogeneities of each unit Section 6.2.1 • Discuss hydraulic conductivities and vertical Sectiona 6.5 & gradients (refer to maps in 4. above) 6.4 • Describe where flow units pinch out in each unit, as Figures 6-3 to 6-7 applicable • Discuss fractured bedrock heterogeneities across the Sections 6.5 & site, including ranges of hydraulic conductivities and 6.9 porosities • Discuss maximum depth of investigation and Section 11.1 & observed fracture density with depth; compare this 14.3 to the depths of proximate supply wells Page 4 of 13 Tables - Shaded Blue Figures - Shaded Green CAP - Shaded Red 2017 Comprehensive Site Assessment Update - Appendix A October 2017 Riverbend Steam Station SynTerra NCDEQ CSA Update Expectations - Check List • Areas of recharge and discharge (Include on vertical Figure 11-37 & gradient isocon figure) Section 6.3 • Flow directions Figures 6-8 to 6- - Potentiometric map (summer) of shallow/TZ unit 13 — Potentiometric map (winter) of shallow/TZ unit — Potentiometric map (summer) of bedrock unit — Potentiometric map (winter) of bedrock unit Potentiometric maps should utilize and show all facility wells, should clearly show all blue line tributaries, wetlands, and other SWs, and should indicate areas where a flow unit pinches out as applicable Evaluation: Do seasonal or tidal influences affect Section 14.1 GW flow or GW chemistry? 6. Background concentrations (PBTVs) of soil and groundwate Piper diagrams for shallow b/g, deep b/g, and bedrock Figures 10-1 to b/g, along with well labels for plotted points 10-3 List PBTVs for soil Table 7-2 List PBTVs for groundwater, by flow unit Table 10-2 Methodology (appendix) Appendix H Description of background wells (why those chosen are Section 10.1 & appropriate for use) and soil sample locations Appendix H (appendix) Table of all raw background data showing strikethroughs Table 10-1 & of unused high pH, high turbidity, autocorrelated, and Appendix B, H outlier data (appendix; digital excel file) Page 5 of 13 Tables - Shaded Blue Figures - Shaded Green CAP - Shaded Red 2017 Comprehensive Site Assessment Update - Appendix A October 2017 Riverbend Steam Station SynTerra NCDEQ CSA Update Expectations - Check List Report For each source History of ash placement Section 3.0 area Area, depth, and volume of ash (include also the area, Section 3.1 depth, and volume of saturated/submerged ash) Status of source removal or control Section 2.8 Orthophoto base map (large scale, 1 inch - 100 feet) Figure 2-1 showing waste boundary, compliance boundary if applicable, 2 to 4 ft topographic contours, all blue line surface water and wetland features, along with the following: - subset of supply well and SW receptors from 3. Figures 2-8, 4-3, above that are potentially susceptible to 4-4, 4-6, & 4-7 contaminant migration from this particular source area - Include inset table with list of supply wells and Table 4-1 SW receptors for this source area - monitor wells, supply wells, and SW, seep, ash, Figures 2-1, 2-4, soil, and sediment locations 4-3, 4-3, 14-50, 14-51, 14-52 - Indicate most recent value (ug/L) for boron and Figures 14-37 to for each COI, and whether its concentration is 14-49 increasing, decreasing, stable, or unknown Evaluation: Show a vertical gradient isopleth map Figure 11-37, and discuss vertical gradients and their effect on Section 11.1, & GW flow 14-1 List COIs (constituents above 02L/IMAC/background) Section 10.3 for each flow unit beyond compliance boundary (or that are within bedrock monitor wells within or beyond compliance boundary if receptors are potentially at risk) List pH and Eh ranges found in: pore water, d/g shallow Figure 14-51 unit, d/g TZ unit, and d/g BR unit Section 10.2 Evaluation: Explain the geochemical controls on Sections 13.1 & COIs that do not behave as a plume (Fe, Mn, etc.). 13.2 Evaluation: Use the pH, Eh, Kd, and HFO results to Sections 13.1 & discuss the expected capacity of the subsurface to 13.2 sorb cationic COIs and anionic COIs occurring from source to receptor within each of the flow units. Page 6 of 13 Tables - Shaded Blue Figures - Shaded Green CAP - Shaded Red 2017 Comprehensive Site Assessment Update - Appendix A October 2017 Riverbend Steam Station SynTerra NCDEQ CSA Update Expectations - Check List "W I NCDEQ Expectations Report� Provide the (a) have background concentrations been formally Sections 7.1 and following "data established for all COIs in soil and groundwater? 10.1 inventory" (b) for each source area, how many wells within each Section 11.1.1 flow system are located along the contaminant plume centerline? Along a cross sectional transect that is perpendicular to the plume centerline? (c) how many wells in (b) above are screened across Section 11.1 and the most contaminated vertical interval of a given flow Figures 11-41 to unit or are screened across the full thickness of the flow 11-64 unit? (d) is the d/g edge of the plume centerline measured or Section 11.1 and is this location obstructed by a major SW or other Figures 11-41 to access issue? If so, is it measured by wells that are 11-64 screened across each flow unit? (d) what is the length of record and how many valid Section 10.0 & sample events are available for wells listed in (b), (c), Appendix B and (d) above? (e) does turbidity, well construction (for example, grout Section 10.0 & contamination, etc.), or well "break in" issues preclude Appendix B the use of data in (b), (c), and or (d)? (f) for each source area and within each flow unit, how Sections 7 & 11, many spatial locations were sampled for solid phase Figure 14-50 chemistry and were these locations associated with "end member" (maximum and minimum) groundwater Section 11.2 concentrations for each contaminantEll? How many of these spatial locations are associated with (b) or (c) above? [1] Measuring the solid phase contaminant concentrations in locations of both low and high groundwater COI concentrations are important in understanding the sorptive capacity of the system. This is particularly true in the case of non -linear isotherm adsorption models that describe most metals. That is, a soil has a limited ability to sorb contaminant mass due, for example, to limited sorption sites, so a soil can become less efficient at removing mass at higher dissolved concentrations. (g) given that iron hydroxide (HFO) content is a good Section 11.2, indicator of retention capacity for most metal Figure 14-50 contaminants, how many locations in (f) was HFO measured? Page 7 of 13 Tables - Shaded Blue Figures - Shaded Green CAP - Shaded Red 2017 Comprehensive Site Assessment Update - Appendix A October 2017 Riverbend Steam Station SynTerra NCDEQ CSA Update Expectations - Check List For each COI in this particular source area Evaluation: Were wells properly positioned and Section 11.1.1 screened to measure the horizontal and vertical Figures 11-41 to extent of the plume? If so, describe the horizontal 11-64 and vertical plume extent using plan view and cross sectional maps. Has the plume migrated to any supply wells, SW Section 13.0 receptors, or GW future use areas? Has the plume migrated to any supply wells, SW Sections 13.0 & receptors, or GW future use areas at concentrations 14.3 above 2L/IMAC/background? Evaluation: Were wells positioned and screened Section 11.1 to measure the maximum concentrations migrating from source to receptor along the longitudinal plume centerline? If so, describe the plume characteristics in space and time as it flows along the centerline, through the identified flow units, and discharges into the nearest supply well or SW receptor. Evaluation: Use maps, graphs, statistics, and Section 11.1, mass movement or balance equations to show 13.1, & 15.2 whether the plume is expanding and whether the plume is moving. Show the COI -distance plot of wells positioned along a Figures 6-3 & 11- plume centerline from source to farthest d/g location 38 to 11-40 (closest to receptor or future use area. If applicable, show COI -distance plots at different Section 13.1 timepoints to demonstrate potential plume expansion or migration. If applicable and sufficient sample events are available, NA use single -well linear regression or Mann-Kendall/Theil- Sen type trend statistics to show increasing or decreasing trends at selected d/g monitor wells. Describe the soil -water pairs and Kd lab test sample Figure 14-50, results. Describe where they were collected, why those Sections 6.7 & locations were selected, and whether those locations are 13.1.2 reflective of high and low COI concentrations in a given flow unit. Page 8 of 13 Tables - Shaded Blue Figures - Shaded Green CAP - Shaded Red 2017 Comprehensive Site Assessment Update - Appendix A October 2017 Riverbend Steam Station SynTerra NCDEQ CSA Update Expectations - Check List Show concentration isopleths for each COI, including Figures 11-1 to contours of concentrations below and well above the 11-36 2L/IMAC (choose — five contours per COI, from "moderately low" to "high") Show stacked boron -time plots of wells positioned along Figures 11-38 to a plume centerline from source to farthest d/g location 11-40 (closest to receptor) Summary of corrective actions taken to date, if Section 2.8 applicable Describe preliminary corrective action alternatives for Sections 15.3 & this source area 15.4 • Description of model Section 13 (Summary) • Model construction - domain, layers, boundary Section 13 conditions, recharge and discharge areas, supply (Summary) wells, hydraulic conductivities, stream conductances, etc. — Layer thicknesses in cross section (show vertical scale in feet) — Location of supply wells outside model domain • Calibration method To Be Provided in CAP — List of target wells used in calibration — List of monitor wells not used in calibration and the rationale for each that was omitted • Calibration results (where mapped, superimpose on To Be Provided in orthophoto base map described above) CAP — Hydraulic conductivity zones versus measured values for the zone — List of simulated versus observed heads (include wells and SW features) — List of simulated versus observed vertical gradients from well pair locations — List of simulated versus observed discharge to streams — Potentiometric surface Page 9 of 13 Tables - Shaded Blue Figures - Shaded Green CAP - Shaded Red 2017 Comprehensive Site Assessment Update - Appendix A October 2017 Riverbend Steam Station SynTerra NCDEQ CSA Update Expectations - Check List ■ Simulated for each flow layer ■ Observed, shallow ■ Observed, deep ■ Observed, BR — Flow paths (particle tracks) from each source area — Reverse flow paths (particle tracks) from SW receptors — Reverse flow paths (particle tracks) from supply wells (because supply wells are usually open from casing (at —50 to 75 ft) down to 200 to 500 feet, release particles in all simulated bedrock layers) • Quantitative sensitivity analyses to key inputs at To Be Provided in various selected d/g locations CAP • Describe the most significant model limitations To Be Provided in CAP • Description of model Section 13.1 (Summary) • Model construction - boundary conditions, time Section 13.1 steps, initial conditions, etc. (Summary) — Source loading, per layer — Background concentrations, per layer — Initial Kds, per layer — Dispersivities, per layer — Effective porosities, per layer • Calibration method Section 13.1 — List of target wells used in calibration (Summary) — List of monitor wells not used in calibration and the rationale for each that was omitted — Calibrated Kds, per layer Page 10 of 13 Tables - Shaded Blue Figures - Shaded Green CAP - Shaded Red 2017 Comprehensive Site Assessment Update - Appendix A October 2017 Riverbend Steam Station SynTerra NCDEQ CSA Update Expectations - Check List 7W • Calibration results (where mapped, superimpose on To Be Provided in orthophoto base map described above) CAP — List of simulated versus observed concentrations in target wells — List of simulated concentrations in SW discharge locations as shown using particle tracks released from source areas — List of simulated versus observed concentrations in selected well pair locations • Boron isopleth map To Be Provided in — Simulated for each flow layer CAP — Observed, shallow — Observed, deep — Observed, BR • For each source area, the time, direction, and To Be Provided in distance of contaminant travel must be predicted CAP under existing conditions and under any other contemplated source control measure (for example, engineered cap and (or) excavation). For these scenarios, the following figures are expected: — (a) a concentration -time plot for each COI corresponding to the following locations: (i) nearest supply well, (ii) nearest future groundwater use area, and (iii) nearest surface water. ■ In the plot margin, the following information should be provided: the time it takes for the COI to reach (i), (ii), and (iii), the time it takes for the COI to reach (i), (ii), and (iii) at its 2L/IMAC concentration, the time it takes for the COI to reach (i), (ii), and (iii) at its maximum concentration, and the time it takes for the COI to reach (i), (ii), and (iii) at a concentration that is back below the 2L/IMAC concentration. — (b) a map superimposed on the requested base map showing the maximum predicted migration distance, at any detectable concentration, of each COI. — (c) a map superimposed on the requested base map showing the maximum predicted migration distance, at the 2L/IMAC standard concentration, of each COI. Page 11 of 13 Tables - Shaded Blue Figures - Shaded Green CAP - Shaded Red 2017 Comprehensive Site Assessment Update - Appendix A October 2017 Riverbend Steam Station SynTerra NCDEQ CSA Update Expectations - Check List • Quantitative sensitivity analyses to key inputs at To Be Provided in various selected d/g locations and times CAP • Describe the most significant model limitations To Be Provided in CAP • Conceptual model based on observed site data Section 13.2 (Summary) — Describe geochemical controls on COI levels in each source area using site data — Assumptions used in developing the model — Discuss data used to develop the model ■ For example, how are mineral or adsorption concentrations in fractured media converted to PHREEQC concentrations representing reaction along the fractures? ■ How were modeled reactive mineral concentrations interpolated between or extrapolated from the limited number of data collected — Discuss what the COI concentrations are most sensitive to (pH, Eh, iron/aluminum oxide content, Kd, distance from source, etc.) — Describe the most significant limitations of the model • Numerical model (PHREEQC or PHREEQC 1-D To Be Provided in Transport model) CAP — Description of model — Purpose of model — Model construction — Discuss data used to develop the flow model — Results with comparison to observed well data (PHREEQC model) or to longitudinal flow path transect data (PHREEQC 1-D Transport model) — Sensitivity analysis (to pH, Eh, Kd, COI concentration, total dissolved ion content, iron/aluminum oxide content, Kd, distance from source, etc.) — Describe the most significant limitations of the model Page 12 of 13 Tables - Shaded Blue Figures - Shaded Green CAP - Shaded Red 2017 Comprehensive Site Assessment Update - Appendix A October 2017 Riverbend Steam Station SynTerra NCDEQ CSA Update Expectations - Check List • Description of model Section 13.3 (Summary) • Purpose of model Section 13.3 (Summary) • Model construction To Be Provided in — Show on map the precise SW locations where CAP model output (simulated SW concentration) was obtained — List and discuss data used to construct model ■ Permitted effluent discharge concentrations should be considered in the model construction — Assumptions • Results To Be Provided in CAP • Sensitivity analysis (to GW contaminant To Be Provided in concentrations, permitted effluent concentrations, CAP location where SW output was obtained, stream flow, nearby effluent loading to the SW, etc. • Describe the most significant limitations of the model To Be Provided in CAP Page 13 of 13 Tables - Shaded Blue Figures - Shaded Green CAP - Shaded Red 2017 Comprehensive Site Assessment Update October 2017 Riverbend Steam Station NORR LETTER SynTerra A 4 A=(WA 4AF1 NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory John E. Skvarla, III Governor Secretary August 13, 2014 CERTIFIED MAIL 7004 2510 0000 3651 1168 RETURN RECEIPT REQUESTED Paul Newton Duke Energy 526 South Church Street Charlotte, NC 28202 Subject: Notice of Regulatory Requirements Title 15A North Carolina Administrative Code (NCAC) 02L .0106 14 Coal Ash Facilities in North Carolina Dear Mr. Newton: Chapter 143, North Carolina General Statutes, authorizes and directs the Environmental Management Commission of the Department of Environment and Natural Resources to protect and preserve the water and air resources of the State. The Division of Water Resources (DWR) has the delegated authority to enforce adopted pollution control rules. Rule 15A NCAC 02L .0103(d) states that no person shall conduct or cause to be conducted any activity which causes the concentration of any substance to exceed that specified in 15A NCAC 02L .0202. As of the date of this letter, exceedances of the groundwater quality standards at 15A NCAC 02L .0200 Classifications and Water Quality Standards Applicable to the Groundwaters of North Carolina have been reported at each of the subject coal ash facilities owned and operated by Duke Energy (herein referred to as Duke). Groundwater Assessment Plans No later than September, 26 2014 Duke Energy shall submit to the Division of Water Resources plans establishing proposed site assessment activities and schedules for the implementation, completion, and submission of a comprehensive site assessment (CSA) report for each of the following facilities in accordance with 15A NCAC 02L .0106(g): Asheville Steam Electric Generating Plant Belews Creek Steam Station Buck Steam Station Cape Fear Steam Electric Generating Plant Cliffside Steam Station 1636 Mail Service Center, Raleigh, North Carolina 27699-1636 Phone: 919-807-64641 Internet: www.ncdenr.gov An Equal Opportunity 1 Affirmative Action Employer— Made in part by recycled paper Mr. Paul Newton August 12, 2014 Page 2 of 3 Dan River Combined Cycle Station H.F. Lee Steam Electric Plant Marshall Steam Station Mayo Steam Electric Generating Plant Plant Allen Steam Station Riverbend Steam Station Roxboro Steam Electric Generating Plant L.V. Sutton Electric Plant Weatherspoon Steam Electric Plant The site assessment plans shall include a description of the activities proposed to be completed by Duke that are necessary to meet the requirements of 15A NCAC 02L .0106(g) and to provide information concerning the following: (1) the source and cause of contamination; (2) any imminent hazards to public health and safety and actions taken to mitigate them in accordance to 15A NCAC 02L .0106(f); (3) all receptors, and significant exposure pathways; (4) the horizontal and vertical extent of soil and groundwater contamination and all significant factors affecting contaminant transport; and (5) geological and hydrogeological features influencing the movement,. chemical, and physical character of the contaminants. For your convenience, we have attached guidelines detailing the information necessary for the preparation of a CSA report. The DWR will review the plans and provide Duke with review comments, either approving the plans or noting any deficiencies to be corrected, and a date by which a corrected plan is to be submitted for further review and comment or approval. For those facilities for which Duke has already submitted groundwater assessment plans, please update your submittals to ensure they meet the requirements stated in this letter and referenced attachments and submit them with the others. Receptor Survey No later than October 14t', 2104 as authorized pursuant to 15A NCAC 02L .0106(g), the DWR is requesting that Duke perform a receptor survey at each of the subject facilities and submitted to the DWR. The receptor survey is required by 15A NCAC 02L .0106(g) and shall include identification of all receptors within a radius of 2,640 feet (one-half mile) from the established compliance boundary identified in the respective National Pollutant Discharge Elimination System (NPDES) permits. Receptors shall include, but shall not be limited to, public and private water supply wells (including irrigation wells and unused or abandoned wells) and surface water features within one-half mile of the facility compliance boundary. For those facilities for which Duke has already submitted a receptor survey, please update your submittals to ensure they meet the requirements stated in this letter and referenced attachments and submit them with the others. If they do not meet these requirements, you must modify and resubmit the plans. Mr. Paul Newton August 12, 2014 Page 3 of 3 The results of the receptor survey shall be presented on a sufficiently scaled map. The map shall show the coal ash facility location, the facility property boundary, the waste and compliance boundaries, and all monitoring wells listed in the respective NPDES permits. Any identified water supply wells shall be located on the map and shall have the well owner's name and location address listed on a separate table that can be matched to its location on the map. Failure to comply with the State's rules in the manner and time specified may result in the assessment of civil penalties and/or the use of other enforcement mechanisms available to the State. We appreciate your attention and prompt response in this matter. If you have any questions, please feel free to contact S. Jay Zimmerman, Water Quality Regional Operations Section Chief, at (919) 807-6351. 2hn ierely, E. Skvarla, III Attachment enclosed cc: Thomas A. Reeder, Director, Division of Water Resources Regional Offices — WQROS File Copy 2017 Comprehensive Site Assessment Update October 2017 Riverbend Steam Station SynTerra NPDES WASTEWATER PERMIT ##NCOO4961 Water Resources ENVIRONMENTAL QUALITY PAT MCCRORY Govei�ior• DONALD R. VAN DER VAART Secrela� S. JAY ZIMMERMAN Director• Febtuaiy 12, 2016 Mt. Hatay Sideris, Senior Vice President Environmental, Health and Safety Duke Energy Carolinas, LLC Mail Code EC13K P.O. Box 1006 Charlotte, North Carolina 28201-1006 Subject: NPDES Permit Issuance Permit No. NC0004961 Rivetbend Steam Station Gaston County 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 Ap44i18, 2015 ul Lincolnton seeking -comments on the Draft permit. Tlus Final permit incorporates recommendations of the DWR Hearing Officer, EPA, as well as other changes. Listed below are all changes from the Draft permit: • The Outfall 010eliminated and the Special Condition A. (16.) was updated to meet the requirements of The Water QualitjT Standard Regulatory Revisions Final Rule that has become effective on October 20, 2015. • Fish tissue monitoring was increased to annually from once every five years to address the EPA comment. Please see Special Condition A. (12.). • The Additional Conditions and Definitions Special Condition was added to the permit to address the EPA comment. Please see Special Condition A. (20.). • Measurement frequency was changed from "Episodic" to "Per discharge event" (Outfall 002A) to address the EPA comment. • The Flow limit was added for Outfall 002 (dewatering phase) to address the EPA comment. • The automatic pump shutoff requirements for TSS limit exceedance was added for Outfall 002 to address the EPA comment. • The variance from Monthly Average TSS limit (Outfall 002 and Outfall 011) %vas eliminated to address the EPA comment. State of North Carolina I Environmental Quality I Water Resources 1617 Mail service Center � Raleigh, North Carolina 27699-1611 919 707 9000 • Monitoring frequency tot all parameters was increased to Weekly for Outfall 002 to address the EPA comment. • The specific date of December 31, 2019 replaced 4.5 years for Outfall 002. This change was made to address EPA comment. Please see Special Condition A. (2.). • Clarifying language was added to define the discharge from the ash pond under normal operating conditions to address the Hearing Officer recommendation and the comment from the petmittee. Please see Special Condition A. (2). • The definition of dewatering was added to Special Condition A. (3.). The definition was added to address the Hearing Office recommendation and the comment from the permittee. • The effluent concentration for Whole affluent Toxicity was changed to correct a typo, the correct concentration is 2.7%. Please see footnote to Special Conditions A. (2.) and A. (3). • The footnote describing conditions for monitoring Total Copper and Total Iron was removed (Outfall 011) to correct an error. • Description of the wastewater sources for Outfall 001 and Outfall 002 was updated to reflect the current status of the facility. • Clatif Ting language was added to the Outfall 002 to define the conditions under which the Emits for Total Copper and Total Iron are applicable. This change was made to address the Hearing Officer recommendation. • A distinct outfall was created for each seep with the effluent limits equivalent to the water quality standards, Technology -Based limits (TSS and Oil & Grease) were also added in accordance with the 40 CFR 423. • The monthly seep monitoring was extended to a 12 month period, after which the monitoring will be reduced to quarterly. • The following requirements were added to the Condition A. (2). — Outfall 001: flow limit; use of a floating pump station with free water skimmed from the basin surface using an adjustable weir; daily monitoring of flow; continuous monitoring of TSS with auto pump shut-off if TSS concentration (15 minute average) exceeds half the maximum daily TSS limit (pumping will be allowed to continue if interruption might result in a dam failure or damage); real time pH monitoring with an auto shut-off if the 15-minute running average PH falls below 6.1 standard units or rises above 8.9 standard units; drawdown to no less than three feet above the ash; and monitoring for total chromium, total lead, total cadmium, and total dissolved solids. If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatoiy 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 requited by the Division of Water Resources, the Division of Energy, Mineral, and Land Resources, the Coastal Area Management Act, or any other federal or local governmental permit. If you have any questions on this permit, please contact Sergei Chernikov at 919-807-6386. Sincerely, S. �Lir�herman, P.G. Director, Division of Water Resources Hardcopy: Central Files NPDES Files Mooresville Regional Office, SWPS Email: US EPA, Region N Aquatic Toxicology Unit David Merryman, Catawba Riverkeeper, [david@cataNvbativerkeeper.org] Permit NC0004961 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 provision 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 the Riverbend Steam Station Mount Holly Gaston County to receiving waters designated as the Catawba River (Mountain Island Lake) in the Catawba River Basin in accordance with effluent limitations, monitoring requirements, and other applicable conditions set forth in Parts I, II, III, and Appendix A. This permit shall become effective March 1, 2016. This permit and authorization to discharge shall expire at midnight on February 29, 2020. Signed this day February 12, 2016. S. Jay �;irr� van P, G., Director Division f er Resources By Authority of the Environmental Management Commission Page 1 of 27 Permit NC0004961 SUPPLEMENT TO PERMIT COVER SHEET All previous NI -DES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit 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: • Water from the plant chiller system (outfall 001). • Ash basin discharge (outfall 002) consisting of consisting of stormwater from roof drains and paving, treated groundwater, track hopper sump (groundwater), coal pile runoff, general plant/trailer sanitary wastewater, turbine and boiler rooms sumps, vehicle rinse water, and stormwater from pond areas, upgradient watershed, and miscellaneous stormwater flows. • Yard sump overflow (outfall 002A). • 12 potentially contaminated groundwater seeps (outfalls 101-112). • Wastewater, stormwater and groundwater (outfall 011). From a facility located at Riverbend Steam Station, Mount Holly in Gaston County, and 2. Discharge wastewater from said treatment works at the location specified on the attached map into the Catawba River, which is classified WS-IV and B-CA waters in the Catawba River Basin, Page 2 of 27 Permit NC0004961 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 plant chiller system from outfall 001. Such discharges shall be limited and monitored3 by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequenc Sample Type I Sample Location' Flow, MGD Monthly Pump Logs Influent or Effluent Temperature (OF) Monthly Grab Effluent Temperature (OF)2 89.6 (320C) Monthly Grab Downstream Notes: 1. Downstream sampling point: downstream at Mountain Island Lake. If samples are collected below the water surface, the Permittee will record the sample depth on the DMR form. 2. The ambient temperature shall not exceed 89.60F (32.00C) and is defined as the daily average downstream water temperature. When the Riverbend Station effluent temperature is recorded below 89.60F (32.00C), as a daily average, then monitoring and reporting of the downstream water temperature is not required. In cases where the Permittee experiences equipment problems and is unable to obtain daily temperatures from the existing temperature monitoring system, the temperature monitoring must be reestablished within five working days. 3. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.) . Chlorination of the once through condenser cooling water, discharged through outfall 001, is not allowed under this permit. Should Duke Energy wish to chlorinate its condenser cooling water, a Division permission must be requested and received prior to commencing chlorination. There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 3 of 27 Permit NC0004961 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 002-normal operation) [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 Pond Discharge (removing the free water above the settled ash layer that does not involve mechanical movement of the ash). Such discharves shall be limited and mnnitorPrl6 by fhP ParmiffaP aQ yr ;f;,l T.o1..r.. EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily ; Maximum Measurement Frequency Sample Type Sample Location Flow 5.74 MGD Daily Pump logs or estimate Influent or Effluent Total Suspended Solidse 23,0 mg/L 75.0 mg/L Weekly Grab Effluent Oil and Grease 11.0 mg/L 15.0 mg/L Weekly Grab Effluent Total Copper' 1.0 mg/L 1.0 mg/L Weekly Grab Effluent Total Iron' 1.0 mg/L 1.0 mg/L Weekly Grab Effluent Total Arsenic 52.5 g/L 72.5 lag/L Weekly Grab Effluent Total Selenium 68.0 g/L 127.5 g/L Weekly Grab Effluent Nitrate/nitrite as N 0.65 mg/L 0.85 mg/L Weekly Grab Effluent Total Arsenic 10.5 lag/L7 14.5 lag/L7 Weekly Grab Effluent Total Selenium 13.6 lag/L7 25.5 lag/L7 Weekly Grab Effluent Total Mercury Nitrate/nitrite as N 47.0 ng/1.5 0.13 mg/L7 47.0 ng/1.5 0.17 mg/L7 Weekly Weekly Grab Grab Effluent Effluent Total Phosphorus, mg/L Weekly Grab Effluent Total Nitrogen (NO2 + NO3 + TKN), mg/L Weekly Grab Effluent pH2 Weekly Grab Effluent Chronic Toxicity3 Monthly Grab Effluent Turbidity4, NTU Weekly Grab Effluent Total Chromium, lag/L Weekly Grab Effluent Total Cadmium, g/L Weekly Grab Effluent Total Lead, g/L Weekly Grab Effluent TDS, mg/L MT I Weekly Grab Effluent ivvLco. 1. The limits for total copper and total iron only apply when chemical metal cleaning wastewaters are being discharged. 2. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. The facility shall conduct a real time pH monitoring with an auto shut-off if the 15-minute running average pH falls below 6.1 standard units or rises above 8.9 standard units. 3. Whole Effluent Toxicity shall be monitored by chronic toxicity (Ceriodaphnia) P/F at 2.7%. Tests shall be conducted in January, April, July and October (see Part A.(6.) for details). 4. The discharge from this facility shall not cause turbidity in the receiving stream to exceed 50 NTU. If the instream turbidity exceeds 50 NTU due to natural background conditions, the discharge cannot cause turbidity to increase in the receiving stream. NTU - Nephelometric Turbidity Unit. 5. The facility shall use EPA method 1631E. 6. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). 7. The TBEL limits shall be met no later than December 31, 2019. This time period is provided in order for the facility to budget, design, and construct the treatment system. Permit might be re -opened to implement the final EPA Effluent Guidelines and more stringent limits might be added. 8. The facility shall continuously monitor TSS concentration and the dewatering pump shall be shutoff automatically when the one half of the Daily Maximum limit (15 minutes average) is Page 4 of 27 Permit NC0004961 exceeded. Pumping will be allowed to continue if interruption might result in a dam failure or damage. The facility is allowed to drawdown the wastewater in the lagoon to no less than three feet above the ash. The facility shall use of a floating pump station with free water skimmed from the basin surface using an adjustable weir. The metal cleaning waste, coal pile runoff, ash transport water, domestic wastewater, and low volume waste shall be discharged into the ash settling pond. No chemicals, cleaners, or other additives may be present in the vehicle wash water to be discharged from this outfall. There shall be no discharge of floating solids or visible foam in other than trace amounts. The level of water in the pond should not be lowered more than 1 ft/week, unless approved by the DEQ Dam Safety Program, Page 5 of 27 Permit NC0004961 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 commencement date of the dewatering operations and lasting until expiration,' the Permittee is authorized to discharge from outfall 002 -Ash Pond Discharge (Dewatering-removing the interstitial water). Such discharges shall be limited and monitored by the Permittee as specified below; 'EFFLUENT CHARACTERISTICS ;LIMITS MONITORING REQUIREMENTS Monthly:.. Average:: Daily :Maximum Measurement Frequency Sample Type ' Sample Location Flow 1.45 MGD Weekly Pump logs or estimate Influent or Effluent Total Sus ended Solids 23.0 mglL 75.0 mg/L Weekl Grab Effluent Oil and Grease 11.0 mg/L 15.0 mg/L Weekly Grab Effluent Total Copper2 1.0 mg/L 1.0 mglL Weekly Grab Effluent Total Iron2 1,0 mg/L 1,0 mg/L Weekly Grab Effluent Total Arsenic 10.5 lag/L 14,5 faglL Weekly Grab Effluent Total Selenium 13.6 fag/L 25.5 g/L Weekl Grab Effluent Total Aluminum 3.18 mg/L 3.18 mg/L Weekl Grab Effluent Total Mercury 47.0 nglLs 47.0 ng/L6 Weekl Grab Effluent Nitrate/nitrate as N 0.13 mg/L 0.17 mg/L Weekly Grab Effluent Total Phosphorus, mglL Weekly Grab Effluent Total Nitrogen (NOz + NO3 + TKN), mg/L Weekly Grab Effluent Fi3 Weekl Grab Effluent Chronic Toxicity4 Weekl Grab Effluent Turbidity5, NTU Weekly Grab Effluent Notes: 1. The facility shall continuously monitor TSS concentration and the dewatering pump shall be shutoff automatically when the limits are exceeded. 2. The limits for total copper and total iron only apply when chemical metal cleaning wastewaters are being discharged. 3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 4. Whole Effluent Toxicity shall be monitored by chronic toxicity (Ceriodaphnia) P/ F at 2.7%. Tests shall be conducted in January, April, July and October (see Part A.(6.) for details). 5. The discharge from this facility shall -not cause turbidity in the receiving stream to exceed 50 NTU. If the instream turbidity exceeds 50 NTU due to natural background conditions, the discharge cannot cause turbidity to increase in the receiving stream. NTU - Nephelometric Turbidity Unit. 6. The facility shall use EPA method 1631E. 7. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). The metal cleaning waste, coal pile runoff, ash transport water, domestic wastewater, and low volume waste shall be discharged into the ash settling pond. No chemicals, cleaners, or other additives may be present in the vehicle wash water to be discharged from this outfall. There shall be no discharge of floating solids or visible foam in other than trace amounts. The level of water in the pond should not be lowered more than 1 ft/week unless approved by the DEQ Dam Safety Program. Page 6 of 27 Permit NC0004961 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 Overflows. Such discharges shall be limited and monitored3 by the Permittee as specified below: EFFLUENT LIMITS MONITORING REQUIREMENTS CHARACTERISTICS Monthly Daily Measurement Sample Type Sample Location Average Maximum Frequency Flow, MGD Per discharge Estimate Effluent event Total Suspended Solids 23.0 mg/L 75.0 mg/L Per discharge Grab Effluent event Oil and Grease 11.0 mg/L 15.0 mg/L Per discharge Grab Effluent event Fecal Coliform, CPU/100 mL Per discharge Grab Effluent event Total Copper2 1.0 mg/L 1.0 mg/L Per discharge Grab Effluent event Total Iron2 1.0 mg/L 1.0 mg/L Per discharge Grab Effluent event pH4 Per discharge Grab Effluent event ivotes: 1. Effluent samples shall be collected prior to the discharge to the receiving stream. 2. The limits for total copper and total iron only apply when chemical metal cleaning wastewaters are being discharged. 3. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). 4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 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" SHOULD BE CLEARLY WRITEN ON THE FRONT OF THE DMR, ALL SAMPLES SHALL BE OF A REPRESENTATIVE DISCHARGE. Page 7 of 27 Permit NC0004961 A. (5.) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY) (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 2.7%. The permit holder shall perform at a minimum, quarteral monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or subsequent versions or "North Carolina Phase If Chronic Whole Effluent Toxicity Test Procedure" (Revised- December 2010) or subsequent versions. Effluent sampling for this testing must be obtained during representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter 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 permit condition 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. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Water Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Assessment of toxicity compliance is based on the toxicity testing quarter, which is the three month time interval that begins on the first day of the month in which toxicity testing is required by this permit and continues until the final day of the third month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Page 8 of 27 Permit NC0004961 A. (6.) 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 a Biocide Worksheet 101 is not necessary for the introduction of a new biocide into an outfall currently being tested for toxicity. A. (7.) SPECIAL CONDITIONS The following special conditions are applicable to all outfalls regulated by NC0004961: • There shall be no discharge of polychlorinated biphenyl compounds. • 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 the 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. • The Permittee shall report all visible discharges of floating materials, such as an oil sheen, to the Director when submitting DMRs A. (S.) PERMIT TERMS The following are applicable to all outfalls regulated by NC0004961: • It has been determined from information submitted that the plans and procedures in place at Riverbend Steam Station are equivalent to that of a BMP. A. (9.) ASH SETTLING BASIN Beginning on the effective date of this permit and lasting until expiration, there shall be no discharge of plant wastewater to the ash pond unless the Permittee provides and maintains at all times a minimum free water volume (between the top of the sediment level and the minimum discharge elevation) equivalent to the sum of the maximum 24-hour plant discharges plus all direct rainfall and all runoff flows to the pond resulting from a 10-year, 24-hour rainfall event, when using a runoff coefficient of 1.0. During the term of the permit, the Permittee shall remove settled material from the ponds or otherwise enlarge the available storage capacities in order to maintain the required minimum volumes at all times. The Permittee shall determine and report to the permit issuing authority the following on an annual basis: 1) the actual free water volume of the ash pond, 2) physical measurements of the dimensions of the free water volume in sufficient detail to allow validation of the calculated volume, and 3) a certification that the required volume is available with adequate safety factor to include all solids expected to be deposited in the pond for the following year. Present information indicates a needed volume of 86.2 acre-feet in addition to solids that will be deposited to the ash pond; any change to plant operations affecting such certification shall be reported to the Director within five days. NOTE: In the event that adequate volume has been certified to exist for the term of the permit, periodic certification is not needed. Page 9 of 27 Permit NC0004961 A.(10.) GROUNDWATER MONITORING WELL CONSTRUCTION AND SAMPLING 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. A$ (11.) STRUCTURAL INTEGRITY INSPECTIONS OF ASH POND DAM The facility shall meet the dam design and dam safety requirements per 15A NCAC 2K, A. (12.) FISH TISSUE MONITORING NEAR ASH POND DISCHARGE The facility shall conduct fish tissue monitoring annually and submit the results with the NPDES permit renewal application. The objective of the monitoring is to evaluate potential uptake of pollutants by fish tissue near the Ash Pond discharge. The parameters analyzed in fish tissue shall be arsenic, selenium, and mercury. The monitoring shall be conducted in accordance with the Sampling Plan approved by the Division. A. (13.) INSTREAM MONITORING The facility shall conduct semiannual instream monitoring (one upstream and one downstream of the ash pond discharge) for arsenic, selenium, mercury (method 1631E), chromium, lead, cadmium, copper, zinc, total hardness, and total dissolved solids (TDS). Instream monitoring should be conducted at the stations that have already been established through the BIP monitoring program: B (upstream of the Outfall 002) and C (downstream of the Outfall `002). The monitoring results shall be submitted with the NPDES permit renewal application. A. (14.) ASH POND CLOSURE The facility shall prepare an Ash Pond Closure Plan in anticipation of the facility closure. This Plan shall be submitted to the Division one month prior to the decommissioning of the ponds. A. (15.) PRIORITY POLLUTANT ANALYSIS 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. A. (16.) SEEP POLLUTANT ANALYSIS The facility identified 12 unpermitted seeps (all non -engineered) from the ash settling basin, of which 10 of the seeps have been classified as "jurisdictional waters" by the United States Army Corps of Engineers. Jurisdictional Water Seeps. For the jurisdictional water seeps, the facility shall determine within 90 days from the effective date of the permit 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. (21.)2 A. (22.), A. (23.), A. (24.), A. (25.), A. (26.), A. (27.), A. (28.), A. (29.), A. (30.), A. (31.), and A. (32.). If any of the water quality standards are exceeded (with the exception of the Action Level standards), the facility shall be considered in violation of the Clean Water Act until one of the options below is fully implemented. The facility shall, 1) Submit a complete application for 404 Permit (within 30 days after determining that a water quality standards 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 and submit the modeling results to the Division within 120 days from the effective date of the permit. Within 180 days from the completion of the dewatering Page 10 of 27 Permit NCO004961 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 effective date of the permit. The "Effluent Channel' designation should be established by the DEQ Regional Office personnel prior to the issuance of the permit and appropriate 404 permit shall be obtained. 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. If jurisdictional water seeps contravene Action Level Standard, the facility shall conduct a Whole Effluent Toxicity Test (WET test). If the WET result passes, the facility shall be considered in compliance with the state water quality standards. If the WET test fails and the Toxicity Identification Evaluation determines that the parameter contravening the water quality standard is responsible for the failure the facility shall be considered in violation and, shall implement one of the 3 options identified above. Non -Jurisdictional Water Seeps For the non jurisdictional water seeps the facility shall demonstrate that they will not violate water quality standards in the receiving stream or that the seep does not discharge to jurisdictional waters or that the seep does not carry pollutants indicating ash characteristics and submit this demonstration to the Division within 90 days from the effective date of the permit. If such demonstration is not possible or not approved by the Division, the facility shall choose one of the 3 options identified above. New Identified Seeps If new seeps are identified, the facility shall follow the procedures outlined above for either I urisdictional waters or non jurisdictional waters. The deadlines for new seeps shall be calculated from the date of the seep discovery. Table 1. List of Identified Seeps The permittee has identified 12 potentially contaminated seeps in the areas adjacent to the Mountain Island Lake. The locations of the seeps are identified on the map attached to the permit. SeeU Coordinates and Assigned Outfall NumhPrc Seep ID * Latitude Longitude Outfall number S-1 35.365 -80.967 101 S-2 35.365 -80.966 102 S-3 36.369 -80.965 103 S-4 35.371 -80.963 104 S-5* 35.370 -80.963 105 S-6 35.367 -80.958 106 S4 35.367 -80.957 107 S-8* 35.365 -80.956 108 S-9 35.371 -80.963 109 S-10 35.369 -80.960 110 5-11 35.369 -80.960 111 5-12 35.368 -80.959 112 1Von jurisdictional seeps Page 11 of 27 Permit NC0004961 A. (17.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS (State Enforceable Only) [G.S. 143-215.1(b)] Proposed 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 Division anticipates that these regulations will be adopted and is beginning implementation in late 2013. NOTE: This special condition supplements or supersedes the following sections within Part II of this permit (Standard Conditions for NPDES Permits): • Section B. (11.) • Section D. (2.) • Section D. (6.) • Section E. (5.) Signatory Requirements Reporting Records Retention Monitoring Reports 1. Reporting fSupersedes Section D. (2.) and Section E (5 L(a)1 Beginning no later than 270 days from the effective date of this permit, the permittee shall begin reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. Monitoring results obtained during the previous months) 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 DENR / DWR /Information Processing Unit ATTENTION: Central Files /eDMR 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. Requests for temporary waivers from the NPDES electronic reporting requirements 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 using eDMR. Temporary waivers shall be valid for twelve (12) months and shall thereupon expire. At such time, DMRs shall be submitted electronically to the Division unless the permittee re -applies for and is granted a new temporary waiver by the Division. Information on eDMR and application for a temporary waiver from the NPDES electronic reporting requirements is found on the following web page: http: / /portal.ncdenr.org/web/wq/admin/bogf ipu/edmr Page 12 of 27 Permit NC0004961 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. 2. six" my Requirements Vaupplements Section B 111 l (b) and supersedes Section B (11.) ldE 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 fI, Section B. (11.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. 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: / /portal. ncdenr. ors J web/ wq/ admin/ bogLpu/ 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 attachmer2ts 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. " 3. Records Retention Su lements Section The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies 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 122.4l]. A. (18.) APPLICABLE STATE LAW (State Enforceable Only) This 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. Page 13 of 27 Permit NC0004961 A. (19.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 011) [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 011 - Former Stormwater Outfall 1. Such discharges shall be limited and monitored3 by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample Type Sample Location Flow, MGD Monthly Pump logs or estimate Influent or Effluent Total Suspended Solids 23.0 mg/L 75.0 mg/L MonthlyGrab Effluent Oil and Grease 11.0 mg/L 15.0 mg/L Annually Grab Effluent Total Arsenic, pg/L Quarterly Grab Effluent Total Selenium, lug/L Quarterly Grab Effluent Total Mercury4, ng/L Quarterly Grab Effluent Nitrate/nitrate as N, mg/L Quarterly Grab Effluent Total Phosphorus, mg/L Semi-annually Grab Effluent Total Nitrogen (NO2 + NO3 + TKN), mg/L Semi-annually Grab Effluent pH1 Monthly Grab Effluent Turbidity2, NTU Monthly Grab Effluent 1. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 2. The discharge from this facility shall not cause turbidity in the receiving stream to exceed 50 NTU. If the instream turbidity exceeds 50 NTU due to natural background conditions, the discharge cannot cause turbidity to increase in the receiving stream. NTU - Nephelometric Turbidity Unit, 3. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). 4. The facility shall use EPA method 1631E. There shall be no discharge of floating solids or visible foam in other than trace amounts. A. (20.) 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. 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 1229416))a 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. Page 14 of 27 Permit NC0004961 A. (21.) 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 as snecified hPlnwe EFFLUENT CHARACTERISTICS LIMITS ' MONITORING REQUIREMENTS Monthly Average Daily Maximum' Measurement Frequency Sample Type Sample Location Flow, MGD Monthly/Quarterly Estimate Effluent H3 Monthly/Quarterly Grab Effluent Fluoride 1.8 mg/L 1.8 mg/L Month' /Quarter) Grab Effluent Total Mercur 4, ng/L Monthly/Quarterly Grab Effluent Total Barium 1.0 mg/L 1,0 mg/L Monthly/Quarterly Grab Effluent Total Iron, mg/L Monthly/Quarterly Grab Effluent Total Manganese, fag/L Monthly/Quarterly Grab Effluent Total Zinc, fag/L Monthly/Quarterly Grab Effluent Total Arsenic 10.0 fag/L 50.0 fag/L Monthly/Quarterly Grab Effluent Total Cadmium 2.0 fag/L 15.0 fag/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Chromium 50.0 lag/L 1,022.0 fag/L Month' /Quarterly Grab Effluent Total Copper, g/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Lead, lag/L 25.Opg/L 33.8 fag/L Monthly/Quarterly Grab Effluent Total Nickel 25.0 fag/L 25.0 fag/L Monthly/Quarterly Grab Effluent Total Selenium 5.0 fag/L 56.0 fag/L Monthly/Quarterly Grab Effluent Nitrate as N 10.0 mg/L 10.0 mg/L Monthly/Quarterly Grab Effluent Sulfates 250.0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent Chlorides 250.0 mg/L 250.0 mg/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent TDS 500.0 mg/L 500.0 mg/L Month' /Quarterly Grab Effluent Total Hardness, mg/L 100.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent TSS 30.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent Oil and Grease 15.0 mg/L 20.0 mg/L Monthly/Quarterly Grab Effluent Temperature, OC Monthly/Quarterly Grab Effluent Specific Conductance, pmho/cm Monthly/Quarterly Grab Effluent av ores: 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). 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, the "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 (jl. There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 15 of 27 Permit NCOOO4961 A. (22.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 102) [15A NCAC 02B .0400 et seq., O2B .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 monitored) by the Permittee ae Rnecifieri hainxzr EFFLUENT CHARACTERISTICS LIMITS1 MONITORING REQUIREMENTS Monthly Average Daily Maximum` Measurement Frequency2 ; Sample Type Sample Location Flow, MGD Monthly/Quarterly Estimate Effluent pH3 Monthly/Quarterly Grab Effluent Fluoride 1.8 mg/L 1.8 mg/L Monthly/Quarterly Grab Effluent Total Mercur 4, ng/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Barium 1.0 mg/L 1.0 mg/L Monthly/Quarterly Grab Effluent Total Iron, mg/L Monthly/Quarterly Grab Effluent Total Manganese, lag/L Monthly/Quarterly Grab Effluent Total Zinc, hg/L Monthly/Quarterly Grab Effluent Total Arsenic 10.0 lag/L 50.0 lag/L Monthly/Quarterly Grab Effluent Total Cadmium 2.0 lag/L 15.0 lag/L Monthly/Quarterly Grab Effluent Total Chromium 50.0 log/L 11022.0 lag/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Copper, lag/L Monthly/Quarterly Grab Effluent Total Lead, lag/L 25.Opg/L 33.8 lag/L Monthly/Quarterly Grab Effluent Total Nickel 25,0 lag/L 25.0 lag/L Monthly/Quarterly Grab Effluent Total Selenium 5.0 lag/L 56.0 lag/L Monthly/Quarterly Grab Effluent Nitrate as N 10.0 mg/L 10.0 mg/L Monthly/Quarterly Grab Effluent Sulfates 250.0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent Chlorides 250.0 mg/L 250.0 mg/L Month) /Quarter] Grab Effluent TDS 500.0 mg/L 500,0 mg/L Monthly/Quarter)Monthly/QuarteqL Grab Effluent Total Hardness, mg/L 100.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent TSS, mg/L 30.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent Oil and Grease 15.0 mg/L 20.0 mg/L Monthly/Quarterly Grab Effluent Temperature, OC Monthly/Quarterly Grab Effluent Specific Conductance, lamho/cm Monthly/Quarterly Grab Effluent 1VULCS: 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). 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, the "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 16 of 27 Permit NCOOO4961 A. (23.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 103) [15A NCAC O2B .0400 et seq., O2B .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 103 - Seep Discharge. Such discharges shall be limited and monitored' by the Permittee as sbecified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency2 Sample Type Sample Location Flow, MGD Monthly/Quarterly Estimate Effluent pH3 Month' /Quarterly Grab Effluent Fluoride 1.8 mg/L 1.8 mg/L Month' /Quarterly Grab Effluent Total Mercury4, ng/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Barium 1,0 mg/L 1,0 mg/L Monthly/Quarterly Grab Effluent Total Iron, mg/L Monthly/Quarterly Grab Effluent Total Manganese, fag/L Monthly/Quarterly Grab Effluent Total Zinc, fag/L Monthly/Quarterly Grab Effluent Total Arsenic 10.0 fag/L 50.0 fag/L Monthly/Quarterly Grab Effluent Total Cadmium 2.0 fag/L 15.0 lag/L Monthly/Quarterly Grab Effluent Total Chromium 50.0 fag/L 1,022.0 lag/L Month' /Quarterly Grab Effluent Total Copper, lag/L Monthly/Quarterly Grab Effluent Total Lead, fag/L 25.Ofag/L 33.8 lag/L Monthly/Quarterly Grab Effluent Total Nickel 25.0 fag/L 25.0 fag/L Monthly/Quarterly Grab Effluent Total Selenium 5.0 fag/L 56.0 fag/L Monthly/Quarterly Grab Effluent Nitrate as N 10.0 mg/L 10.0 mg/L Monthly/Quarterly Grab Effluent Sulfates 250.0 mg/L 250.0 mg/L Month' /Quarterly Grab Effluent Chlorides 250,0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent TDS 500.0 mg/L 500.0 mg/L Month' /Qu arterly Grab Effluent Total Hardness, mg/L 100.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent TSS, mg/L 30.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent Oil and Grease 15.0 mg/L 20.0 mg/L Monthly/Quarterly Grab Effluent Temperature, OC Monthly/Quarterly Grab Effluent Specific Conductance, prnho/cm Monthly/Quarterly Grab Effluent Notes: 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). 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, the "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 U). There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 17 of 27 Permit NC0004961 A. (24.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 104) [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 104 - Seep Discharge. Such discharges shall be limited and monitored' by the Permittee »s enerifiPrl hPlnIzr EFFLUENT CHARACTERISTICS LIMITS1 MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequei Sample Type Sample Location Flow, MGD Monthly/Quarterly Estimate Effluent f-13 Monthly/QuarteqL Grab Effluent Fluoride 1.8 mg/L 1.8 mg/L Monthly/Quarterly Grab Effluent Total Mercury4, ng/L Monthly/Quarterly Grab Effluent Total Barium 1.0 mg/L 1.0 mg/L Monthly/Quarterly Grab Effluent Total Iron, mg/L Monthly/Quarterly Grab Effluent Total Manganese, lag/L Monthly/Quarterly Grab Effluent Total Zinc, lag/L Monthly/Quarterly Grab Effluent Total Arsenic 10.0 lag/L 50.0 lag/L Monthly/Quarterly Grab Effluent Total Cadmium 2.0 g/L 15.0 g/L Monthly/Quarterly Grab Effluent Total Chromium 50.0 lag/L 1,022.0 lag/L Monthly/Quarterly Grab Effluent Total Copper, lag/L Monthly/Quarterly Grab Effluent Total Lead, lag/L 25.Olag/L 33.8 lag/L Monthly/Quarterly Grab Effluent Total Nickel 25.0 lag/L 25.0 lag/L Monthly/Quarterly Grab Effluent Total Selenium 5.0 lag/L 56.0 lag/L Monthly/Quarterly Grab Effluent Nitrate as N 10.0 mg/L 10.0 mg/L Monthly/Quarterly Grab Effluent Sulfates 250.0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent Chlorides 250.0 mg/L 250.0 mg/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent TDS 500.0 mg/L 500.0 mg/L Month' /Quarter)y. Grab Effluent Total Hardness, mg/L 100.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent TSS, mg/L 30.0 mg/L 100.0 mg/L Monthly/Quarter]y Grab Effluent Oil and Grease 15.0 mg/L 20.0 mg/L Monthly/Quarterly Grab Effluent Temperature, 0C Monthly/Quarterly Grab Effluent Specific Conductance, lamho/cm Monthly/Quarterly Grab Effluent iv v Ica: 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). 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, the "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 18 of 27 Permit NC0004961 A. (25.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 105) [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 105 - Seep Discharge. Such discharges shall be limited and monitored' by the Permittee as sbecified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average; Daily Maximum" Measurement Frequency2 Sample Type Sample Location Flow, MGD Monthly/Quarterly Estimate Effluent pH3 Month' /Quarterly Grab Effluent Fluoride 1.8 mg/L 1.8 mg/L Monthly/Quarter'Monthly/QuarteqL Grab Effluent Total Mercur 4, ng/L Month' /Quarter' Grab Effluent Total Barium 1.0 mg/L 1.0 mg/L Monthly/Quarterly Grab Effluent Total Iron, mg/L Monthly/Quarterly Grab Effluent Total Manganese, lag/L Monthly/Quarterly Grab Effluent Total Zinc, lag/L Monthly/Quarterly Grab Effluent Total Arsenic 10.0 lag/L 50.0 lag/L Monthly/Quarterly Grab Effluent Total Cadmium 2.0 lag/L 15.0 lag/L Monthly/Quarterly Grab Effluent Total Chromium 50.0 g/L 1,022.0 lag/L Monthly/Quarterly Grab Effluent Total Copper, lag/L Month' /Quarterly Grab Effluent Total Lead, lag/L 25.Opg/L 33.8 lag/L Monthly/Quarterly Grab Effluent Total Nickel 25.0 lag/L 25.0 lag/L Monthly/Quarterly Grab Effluent Total Selenium 5.0 lag/L 56,0 lag/L Monthly/Quarterly Grab Effluent Nitrate as N 10.0 mg/L 10.0 mg/L Monthly/Quarterly Grab Effluent Sulfates 250.0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent Chlorides 250.0 mg/L 250.0 mg/L. Month ly/Quarterly Grab Effluent TDS 500.0 mg/L 500.0 mg/L Monthly/Quarterly Grab Effluent Total Hardness, mg/L 100.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent TSS, mg/L 30.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent Oil and Grease 15.0 mg/L 20.0 mg/L Monthly/Quarterly Grab Effluent Temperature, OC Monthly/Quarterly Grab Effluent Specific Conductance, prnho/cm Monthly/Quarterly Grab Effluent Notes: 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). 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, the "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 19 of 27 Permit NC0004961 A. (26.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 106) [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 106 - Seep Discharge. Such discharges shall be limited and monitored' by the Permittee ns snpr.ifiPr] hPlnure EFFLUENT CHARACTERISTICS LIMITS] MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency2 Sample Type Sample Location Flow, MGD Monthly/Quarterly Estimate Effluent pH3 Monthly/QuarterlyMonthly/Quarterly Grab Effluent Fluoride 1.8 mg/L 1.8 mg/L Monthly/Quarterly Grab Effluent Total Mercury4, ng/L Monthly/Quarterly Grab Effluent Total Barium 1.0 mg/L 1.0 mg/L Monthly/Quarterly Grab Effluent Total Iron, mg/L Monthly/Quarterly Grab Effluent Total Manganese, pg/L Monthly/Quarterly Grab Effluent Total Zinc, pg/L Monthly/Quarterly Grab Effluent Total Arsenic 10.0 pg/L 50.0 pg/L Monthly/Quarterly Grab Effluent Total Cadmium 2.0 Ng/L 15.0 pg/L Monthly/Quarterly Grab Effluent Total Chromium 50.0 g/L 1,022.0 pg/L Month' /Quarterly Grab Effluent Total Copper, pg/L Monthly/Quarterly Grab Effluent Total Lead, pg/L 25.Opg/L 33.8 Ng/L Monthly/Quarterly Grab Effluent Total Nickel 25.0 pg/L 25.0 Ng/L Monthly/Quarterly Grab Effluent Total Selenium 5.0 pg/L 56.0 pg/L Monthly/Quarterly Grab Effluent Nitrate as N 10.0 mg/L 10.0 mg/L Monthly/Quarterly Grab Effluent Sulfates 250.0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent Chlorides 250.0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent TDS 500.0 mg/L 500,0 mg/L Month ly/QuarteqK. Grab Effluent Total Hardness, mg/L 100.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent TSS, mg/L 30.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent Oil and Grease 15.0 mg/L 20,0 mg/L Monthly/Quarterly Grab Effluent Temperature, OC Monthly/Quarterly Grab Effluent Specific Conductance, Hmho/cm Monthly/Quarterly Grab Effluent 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). 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, the "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 O). There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 20 of 27 Permit NCOOO4961 A. (27.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 107) [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 107 - Seep Discharge. Such discharges shall be limited and monitored' by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average; Daily Maximum Measurement Frequencyz Sample Type ( Sample Location Flow, MGD Monthly/Quarterly Estimate Effluent pH3 Month' /Quarterly Grab Effluent Fluoride 1.8 mg/L 1.8 mg/L Monthly/Quarterly Grab Effluent Total Mercur 4, ng/L Monthly/Quarterly Grab Effluent Total Barium 1.0 mg/L 1.0 mg/L Monthly/Quarterly Grab Effluent Total Iron, mg/L Monthly/Quarterly Grab Effluent Total Manganese, pg/L Monthly/Quarterly Grab Effluent Total Zinc, pg/L Monthly/Quarterly Grab Effluent Total Arsenic 10.0 pg/L 50.0 pg/L Monthly/Quarterly Grab Effluent Total Cadmium 2.0 pg/L 15.0 pg/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Chromium 50.0 pg/L 1,022.0 pg/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Copper, Ng/L Month' /Quarterly Grab Effluent Total Lead, pg/L 25.Opg/L 33.8 pg/L Monthly/Quarterly Grab Effluent Total Nickel 25.0 Ng/L 25.0 pg/L Monthly/Quarterly Grab Effluent Total Selenium 5.0 pg/L 56.0 pg/L Monthly/Quarterly Grab Effluent Nitrate as N 10.0 mg/L 10.0 mg/L Monthly/Quarterly Grab Effluent Sulfates 250.0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent Chlorides 250.0 mg/L 250.0 mg/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent TDS 500.0 mg/L 500.0 mg/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Hardness, mg/L 100.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent TSS, mg/L 30.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent Oil and Grease 15.0 mg/L 20,0 mg/L Monthly/Quarterly Grab Effluent Temperature, OC Monthly/Quarterly Grab Effluent Specific Conductance, pmho/cm Monthly/Quarterly Grab Effluent 1Votes: 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). 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, the "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 21 of 27 Permit NC0004961 A. '(28.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 108) [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 108 Seep Discharge. Such discharges shall be limited and monitored' by the Permittee as specified below$ EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum` Measurement Frequency Sample Type Sample Location Flow, MGD Monthly/Quarterly Estimate Effluent pH3 Month ly/Quarterly Grab Effluent Fluoride 1.8 mg/L. 1.8 mg/L Monthly/Quarterly Grab Effluent Total Mercur 4, ng/L Monthly/Quarterly Grab Effluent Total Barium 1.0 mg/L 1.0 mg/L Monthly/Quarterly Grab Effluent Total Iron, mg/L Monthly/Quarterly Grab Effluent Total Manganese, lug/L Monthly/Quarterly Grab Effluent Total Zinc, lug/L Monthly/Quarterly Grab Effluent Total Arsenic 10.0 pg/L 50.0 pg/L Monthly/Quarterly Grab Effluent Total Cadmium 2.0 pg/L 15.0 pg/L Month' /Q arterly Grab Effluent Total Chromium 50.0 Hg/L 1,022.0 fag/L Month' /Quarterly Grab Effluent Total Copper, pg/L Month' /Quarter) y Grab Effluent Total Lead, pg/L 25.ONg/L 33.8 pg/L Monthly/Quarterly Grab Effluent Total Nickel 25.0 Ng/L 25.0 pg/L Month ly/Qu arterly Grab Effluent Total Selenium 5.0 pg/L 56.0 pg/L Monthly/Quarterly Grab Effluent Nitrate as N 10.0 mg/L 10.0 mg/L Monthly/Quarterly Grab Effluent Sulfates 250.0 mg/L 250,0 mg/L Monthly/Quarterl Grab Effluent Chlorides 250,0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent TDS 500.0 mg/L 500,0 mg/L Month ly/Quarterly Grab Effluent Total Hardness, mg/L 100.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent TSS, mg/L 30.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent Oil and Grease 15.0 mg/L 20.0 mg/L Monthly/Quarterly Grab Effluent Temperature, OC Monthly/Quarterly Grab Effluent Specific Conductance, Hmho/cm Monthly/Quarterly Grab Effluent iv ores: 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). 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, the "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 22 of 27 Permit NC0004961 A. (29.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 109) [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 109 - Seep Discharge. Such discharges shall be limited and monitored' by the Permittee as sbecified below: EFFLUENT CHARACTERISTICS LIMITS f MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement FrequenC' 2 Sample Type " Sample Location Flow, MGD Monthly/Quarterly Estimate Effluent pH3 Monthly/Quarterly Grab Effluent Fluoride 1.8 mg/L 1.8 mg/L Monthly/Quarterly Grab Effluent Total Mercury4, ng/L onthly/Quarterly Grab Effluent Total Barium 1.0 mg/L 1,0 mg/L Monthly/Quarterly Grab Effluent Total Iron, mg/L Monthly/Quarterly Grab Effluent Total Manganese, lag/L Monthly/Quarterly Grab Effluent Total Zinc, lag/L Monthly/Quarterly Grab Effluent Total Arsenic 10.0 lag/L 50.0 lag/L Monthly/Quarterly Grab Effluent Total Cadmium 2.0 lag/L 15.0 lag/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Chromium 50.0 lag/L 1,022.0 lag/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Copper, lag/L Monthly/Quarterly Grab Effluent Total Lead, lag/L 2530pg/L 33.8 lag/L Monthly/Quarterly Grab Effluent Total Nickel 25.0 lag/L 25.0 lag/L Mont hly/Quarterly Grab Effluent Total Selenium 5.0 lag/L 56,0 lag/L Monthly/Quarterly Grab Effluent Nitrate as N 10.0 mg/L 10.0 mg/L Monthly/Quarterly Grab Effluent Sulfates 250.0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent Chlorides 250.0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent TDS 500.0 mg/L. 500.0 mg/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Hardness, mg/L 100.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent TSS, mg/L 30.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent Oil and Grease 15.0 mg/L 20.0 mg/L Monthly/Quarterly Grab Effluent Temperature, OC Monthly/Quarterly Grab Effluent Specific Conductance, lamho/cm Monthly/Quarterly Grab Effluent ayotes: 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). 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 4 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, the "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 23 of 27 Permit NC0004961 A. (30.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 110) [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 110 - Seep Discharge. Such discharges shall be limited and monitoredi by the Perm ittep ac gnprrifiari hPInIXTO EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency2 Sample Type Sample Location Flow, MGD Monthly/Quarterly Estimate Effluent H3 Month ly/Quarterly Grab Effluent Fluoride 1.8 mg/L 1.8 mg/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Mercury4, ng/L Month/ /Quarterly Grab Effluent Total Barium 1.0 mg/L 1.0 mg/L Monthly/Quarterly Grab Effluent Total Iron, mg/L Monthly/Quarterly Grab Effluent Total Manganese, lag/L Monthly/Quarterly Grab Effluent Total Zinc, lag/L Monthly/Quarterly Grab Effluent Total Arsenic 10.0 lag/L 50.0 lag/L Monthly/Quarterly Grab Effluent Total Cadmium 2.0 g/L 15.0 lag/L Monthly/Quarterly Grab Effluent Total Chromium 50.0 lag/L 1,022.0 lag/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Copper, g/L Monthly/Quarterly Grab Effluent Total Lead, lag/L 25.Olag/L 33.8 lag/L Monthly/Quarterly Grab Effluent Total Nickel 25.0 tag/L 25.0 lag/L Monthly/Quarterly Grab Effluent Total Selenium 5.0 lag/L 56.0 lag/L Monthly/Quarterly Grab Effluent Nitrate as N 10.0 mg/L 10.0 mg/L Monthly/Quarterly Grab Effluent Sulfates 250.0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent Chlorides 250.0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent TDS 500.0 mg/L 500.0 mg/L Month/ /Quarterly Grab Effluent Total Hardness, mg/L 100.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent TSS, mg/L 30.0 mg/L 100.0 mg/L Month/ /Quarterly Grab Effluent Oil and Grease 15.0 mg/L 20.0 mg/L Monthly/Quarterly Grab Effluent Temperature, OC Monthly/Quarterly Grab Effluent Specific Conductance, prnho/cm Monthly/Quarterly Grab Effluent iv u yes: 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). 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, the "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 24 of 27 Permit NC0004961 A. (31.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 111) [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 111 - Seep Discharge. Such discharges shall be limited and monitored) by the Permittee ar enPoifiPA }vPln�x.• EFFLUENT " CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average; Daily Maximum Measurement Frequen, Sample Type Sample Location Flow, MGD Monthly/Quarterly Estimate Effluent pH3 Monthly/Quarterly Grab Effluent Fluoride 1.8 mg/L 1.8 mg/L Monthly/Quarter) Grab Effluent Total Mercur 4, ng/L Monthly/Quarterly Grab Effluent Total Barium 1.0 mg/L 1.0 mg/L Monthly/Quarterly Grab Effluent Total Iron, mg/L Monthly/Quarterly Grab Effluent Total Manganese, lag/L Monthly/Quarterly Grab Effluent Total Zinc, lag/L Monthly/Quarterly Grab Effluent Total Arsenic 10.0 lag/L 50,0 lag/L Monthly/Quarterly Grab Effluent Total Cadmium 2.0 Ng/L 15.0 lag/L Monthly/QuarteqL Grab Effluent Total Chromium 50.0 lag/L 11022.0 g/L Monthly/Quarterly FGrab Effluent Total Copper, g/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Lead, lag/L 25.Opg/L 33.8 lag/L Monthly/Quarterly Grab Effluent Total Nickel 25.0 lag/L 25.0 tag/L Monthly/Quarterly Grab Effluent Total Selenium 5.0 lag/L 56.0 lag/L Monthly/Quarterly Grab Effluent Nitrate as N 10.0 mg/L 10.0 mg/L Monthly/Quarterly Grab Effluent Sulfates 250.0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent Chlorides 250.0 mg/L 250.0 mg/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent TDS 500.0 mg/L 500.0 mg/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Hardness, mg/L 100.0 mg/L. 100.0 mg/L Monthly/Quarterly Grab Effluent TSS, mg/L 30.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent Oil and Grease 15.0 mg/L 20.0 mg/L Monthly/Quarterly Grab Effluent Temperature, OC Month ly/Quarterly Grab Effluent Specific Conductance, famho/cm AT 1 Monthly/Quarterly Grab Effluent ivvLc�-J. 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.) . 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, the "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 25 of 27 Permit NC0004961 A. (32.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Outfall 112) [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 112 - Seep Discharge. Such discharges shall be limited and monitored' by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequencyz Sample Type Sample Location Flow, MGD Monthly/Quarterly Estimate Effluent H3 Month ly/Quarterly Grab Effluent Fluoride 1.8 mg/L 1.8 mg/L Monthly/Quarterly Grab Effluent Total Mercur 4, ng/L Monthly/Quarterly Grab Effluent Total Barium 1.0 mg/L 1.0 mg/L Monthly/Quarterly Grab Effluent Total Iron, mg/L Monthly/Quarterly Grab Effluent Total Manganese, tag/L Monthly/Quarterly Grab Effluent Total Zinc, tag/L Monthly/Quarterly Grab Effluent Total Arsenic 10.0 tag/L 50.0 tag/L Monthly/Quarterly Grab Effluent Total Cadmium 2.0 tag/L 15.0 tag/L Monthly/Quarterly Grab Effluent Total Chromium 50.0 g/L 1,022.0 tag/L Monthly/Quarterly Grab Effluent Total Copper, tag/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Lead, pg/L 25.Opg/L 33.8 tag/L Monthly/Quarterly Grab Effluent Total Nickel 25.0 tag/L 25.0 tag/L Monthly/Quarterly Grab Effluent Total Selenium 5.0 pg/L 56.0 tag/L Monthly/Quarterly Grab Effluent Nitrate as N 10.0 mg1L 10.0 mg/L Monthly/Quarterly Grab Effluent Sulfates 250.0 mg/L 250.0 mg/L Monthly/Quarterly Grab Effluent Chlorides 250.0 mg/L 250.0 mg/L Monthly/Qua terl Grab Effluent TDS 500.0 mg/L 500.0 mg/L Monthly/QuarterlyMonthly/Quarterly Grab Effluent Total Hardness, mg/L 100.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent TSS, mg/L 30.0 mg/L 100.0 mg/L Monthly/Quarterly Grab Effluent Oil and Grease 15.0 mg/L 20.0 mg/L Monthly/Quarterly Grab Effluent Temperature, OC Monthly/Quarterly Grab Effluent Specific Conductance, pmho/cm Monthly/Quarterly Grab Effluent Notes: 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A. (18.). 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, the "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 26 of 27 Permit NC0004961 Appendix A Plan for Identification of New Discharges (attached). Page 27 of 27 Duke Energy Corporation Riverbend Steam Station State Grid/Ouad: F15SW/Mt. Island Lake, NC Receiving St reams: Catawba River Sub -Basin: 03-0&33 Stream Class: WS4V & B-CA Permitted Flow: Not limited Drainage Basin: Catawba River Basin Latitude (001): 35021' 28" N Longitude (001): 800 58' 12" W Latitude (002): 35022' 06" N Longitude (002): 80057' 31" W Latitude (002A): 35021' 51" N Longitude (002A): 800 58' 11" W Latitude (011): 35021' 38" N Longitude (011): 800 58' 38" W Map not to scale Facility Location NOY'tj2 NPDES Perinit No. NC0004961 Gaston Coun 2017 Comprehensive Site Assessment Update October 2017 Riverbend Steam Station NCDEQ CORRESPONDENCE - REVISED INTERIM MONITORING PLAN SynTerra Water Resources Environmental Quality October 19, 2017 Paul Draovitch Senior Vice President Environmental, Health & Safety Duke Energy 526 South Church Street Mail Code EC3XP Charlotte, North Carolina 28202 Subject: Revised Interim Monitoring Plans for 14 Duke Energy Facilities Fourth Quarter 2017 Dear Mr. Draovitch: ROY COOPER Governor MICHAEL S. REGAN Secretary S. JAY ZIMMERMAN Director The North Carolina Department of Environmental Quality (DEQ) is providing the attached revised Interim Monitoring Plans (IMPs) for the respective coal ash facilities. Per our agreement, the DEQ will be providing Duke Energy with updated IMPs quarterly until the individual facility Corrective Action Plans are approved. Also, per our agreement, Duke Energy will include and begin sampling any newly installed groundwater assessment wells as part of the facility IMP and the DEQ will formally include it in the subsequent updated quarterly IMP. The attached IMPs only contain references to groundwater monitoring locations. Sampling at surface water locations that were identified as part of the May 1, 2017 communication from DEQ to Duke Energy regarding revised IMPs at the facilities is expected to continue pending further notice. DEQ may elect to provide Duke Energy with additional surface sampling locations to incorporate into the revised IMPs at a future time. For clarification, we have also provided the minimum expected groundwater sampling analyte list. The attached revised facility IMPs shall be conducted on a quarterly basis commencing the fourth quarter of calendar year 2017 pursuant to 15A NCAC 02L .0110, until Corrective Action Plans are accepted for the individual facilities or as directed otherwise by the DEQ. The quarterly sampling events will be conducted in conjunction with planned compliance monitoring sampling events for three quarters during the calendar year, supplemented with an additional sampling event conducted at each facility in order to provide four rounds of monitoring data to evaluate seasonal fluctuations during a year -long timeframe. If sampling an individual groundwater location is problematic, please call the Regional Office that manages the facility to discuss issues. Any changes to IMPs and sampling requirements must be discussed with the respective Regional Offices and coordinated by official correspondence from the DEQ Central Office. Since Duke Energy will submit updated Comprehensive Site Assessments in the near future, the requirement for an annual monitoring report submitted by April 30th for each respective coal State of North Carolina I Environmental Quality I Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center I Raleigh, North Carolina 27699-1636 919-707-9129 facility as set forth in the May 1, 2017 letter will be extended to a date in 2018 that will be later defined. In order to optimize the groundwater monitoring at each facility, DEQ will be removing the groundwater monitoring condition from the NPDES permits as they are reissued. Duke Energy shall continue to monitor the compliance wells separately under the individual NPDES permits until the NPDES permits are reissued with no groundwater monitoring condition. At that time, the compliance wells shall continue to be monitored per the attached revised IMPs under the authority of 15A NCAC 02L .0110. The DEQ is open to consider further optimization of the IMPS following a qualitative and quantitative review of site -specific data. A thorough analysis of spatial and temporal trends related to contaminant distribution that include determination of background conditions and identification of areas impacted by coal ash residuals must be provided as a decision framework to support improvements to long-term monitoring programs. If you have any questions, please feel free to contact Steve Lanter at (919) 807-6444. Sincerely, S. Jay Zimmerman, P.G., Director Division of Water Resources Attachments: Revised Interim Monitoring Plans for the 14 coal ash facilities cc: WQROS Regional Offices WQROS Central File Copy Revised Riverbend Steam Station Interim Monitoring Plan — Groundwater Only Wells to be Sampled Sample for Radionuclides X Regional Office Notes AB -ID Measure pH, if still >10, not sample. AB -IS AB-2D AB-2S AB-8D AB-8S BG-1DA BG-1 S BG-2BR BG-2D BG-2S BG-3D BG-3S BG-4BR X BG-4D X BG-4S X BG-5BR BG-5D C-1BRUA C-1 S C-2D C-2S GWA-10BRU Measure pH, if still >10, not sample. GWA-10S GWA-11D GWA-11 S GWA-12D X GWA-12S X GWA-13D GWA-13S GWA-14D GWA-14S GWA-15D GWA-15S X GWA-1BRU GWA-1 S GWA-20BR Measure pH, if still >10, not sample. Riverbend Steam Station Page I of 3 October 1, 2017 GWA-20DA GWA-20S GWA-21BR GWA-21D GWA-21 S GWA-22BR-A X GWA-22D X GWA-22S X GWA-23BR Measure pH, if still >10, not sample. GWA-23DA GWA-23S GWA-2BR X GWA-2BRU X Measure pH, if still >10, not sample. GWA-2S X GWA-3BR GWA-3D GWA-3S-A GWA-4BR Measure pH, if still >10, not sample. GWA-4D X GWA-4S X GWA-5D GWA-5S GWA-6D X Measure pH, if still >10, not sample. GWA-6S X GWA-7BR GWA-7D GWA-7S GWA-8D X GWA-8S X GWA-9BR X GWA-9D X GWA-9S X MW-10 X MW-11DR MW-11 SR MW-13 MW-14 X MW-15 MW-15BR MW-15DA MW-lD Riverbend Steam Station Page 2 of 3 October 1, 2017 MW-lS MW-2D MW-2S-A MW-3D MW-3S MW-4D MW-4S MW-5D MW-5S MW-6D MW-6S MW-7BRA X MW-7D X MW-7SR X MW-8D MW-8I MW-8S MW-9 X MW-9BRA X MW-9DA X Minimum Parameters to be Analyzed Aluminum Boron Copper Mercury Selenium Thallium Alkalinity Cadmium Hexavalent Molybdenum Sodium Total Organic Chromium Carbon Total Antimony Calcium Iron Nickel Strontium Combined Uranium Total Arsenic Chloride Lead Potassium Sulfate Suspended Solids Barium Chromium Magnesium Radium 226 Sulfide Vanadium Total Beryllium Cobalt Manganese Radium 228 Dissolved Zinc Solids Riverbend Steam Station Page 3 of 3 October 1, 2017 2017 Comprehensive Site Assessment Update October 2017 Riverbend Steam Station SynTerra DEQ BACKGROUND LOCATION APPROVALS - J U LY 7, 2017 Water Resources Environmental Quality July 7, 2017 Paul Draovitch Senior Vice President Environmental, Health & Safety Duke Energy 526 South Church Street Mail Code EC3XP Charlotte, North Carolina 28202 ROY COOPER Governor MICHAEL S. REGAN Secretary S. JAY ZIMMERMAN Director Subject: Duke Energy Submittal - Background Soil and Groundwater Statistical Methodology for 14 Duke Energy Facilities a -mails submitted May 26, 2017 Dear Mr. Draovitch: The North Carolina Department of Environmental Quality (DEQ) has received and reviewed the May 26, 2017 a -mails from Duke Energy providing background soil and groundwater datasets. These site -specific data were compiled following direction provided in an April 28, 2017 letter from DEQ to address technical concerns related to site assessment and corrective action along with revisions to the Statistical Methods for Developing Reference Background Concentrations for Groundwater and Soil at Coal Ash Facilities (HDR Engineering, Inc. and Synterra Corporation, January 2017) technical memorandum (TM). Attached are reviews of the soil and groundwater datasets for each Duke Energy coal ash facility. These reviews identify data that are appropriate for inclusion in the statistical analysis to determine background threshold values for both media following the methodology outlined in the TM. Additional requirements related to soil and groundwater background determinations are specified for each facility. With approval of these background datasets, preliminary background determinations for each media are expected to be completed and provided within 30 days of receipt of this letter for those facilities that will submit Comprehensive Site Assessments (CSAs) by October 31, 2017. For all other facilities that will submit CSAs later, preliminary background determinations for each media are due within 60 days of receipt of this letter. If you have any questions, please feel free to contact Steve Lanter at (919) 807-6444. Sincerely, S. Jayinlerman, P.G., Director Division of Water Resources Attachments: DEQ Background Dataset Reviews for the 14 coal ash facilities cc: WQROS Regional Offices WQROS Central File Copy State of North Carolina I Environmental Quality I Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center I Raleigh, North Carolina 27699-1636 919-707-9129 Allen Steam Station Groundwater • The following background wells are appropriate for use: o BG-lS, BG-2S/D, BG-4S/DBR, GWA-19S, GWA-21SBR, GWA-23S, and GWA-26S/D • The following background wells are NOT appropriate for use: o BG-lD — Recently reinstalled due to water quality issues and reevaluation as background location is necessary before being included. o BG-2BR — Recently reinstalled due to water quality issues and reevaluation as background location is necessary before being included. (Note: while there does appear to be a topographic divide additional evaluation is needed to determine if this is just a shallow divide or if it is indeed a divide for all flow layers.) o AB-4S/DBR — Groundwater elevations below the nearest pond elevation has been observed in several sampling events since installation of AB-4S/D. Due to the potential for groundwater flow from the basin toward/through the well cluster this location should NOT be considered a background location. AB-4BR should also NOT be considered a background location (potential vertical migration from the unconsolidated zone). (Note: Duke will evaluate further regarding pond elevation utilized for assessment.) o GWA-21D —Recently reinstalled due to water quality issues and reevaluation as background location is necessary before being included. • All identified sample event dates are appropriate for use. • The dataset for the shallow flow layer meets the minimum requirement of 10 samples after excluding samples. • The dataset for the deep flow layer does NOT meet the minimum requirement of 10 samples after excluding samples. Additional samples are require . • The dataset for the bedrock flow layer does NOT meet the minimum requirement of 10 samples after excluding samples. Only 4 valid samples, but when additional evaluation regarding nearest pond elevation used for the AB-4S/DBR locations is provided additional samples may be available for inclusion. • All identified outliers are acceptable and should be removed from the background dataset. Soil • The following background samples are appropriate for use: o BG-lD (1.0-2.0), BG-lD (9.0-10.5), BG-1D (19.0-20.5), BG-lD (45-50), BG-2D (1.0-2.5), BG-2D (8.5-10.0), BG-2D (18.0-20.0), BG-3D (1-2.5), BG-3D (13.5- 15), BG-3D (18.5-20), GWA-14D (10.0-12.0), GWA-8D (38.5-40), and GWA-8D (48.5-50) • The following background samples are NOT appropriate for use: o GWA-15D —Sample is at or immediately adjacent to the waste boundary west of the ash storage area and was also collected in fill material (according to boring log). Allen Steam Station Pagel of 2 o GWA-5D —Sample is at or immediately adjacent to the waste boundary east of the ash basin (immediately downgradient) and was also collected in fill material (according to the boring log). • The dataset meets minimum requirement of 10 samples after excluding samples. • The reporting limits for Antimony and Thallium were above the IHSB PSRG Protection of Groundwater values. Therefore, the number of useable values in the background dataset is severely limited for these constituents. Additional samples analyzed at a lower detection limit for these parameters are necessary. • Please state whether any background sample included fill material. Samples containing fill should be omitted from the raw background dataset. • All identified outliers are acceptable and should be removed from the background dataset. Allen Steam Station Page 2 of 2 Asheville Steam Electric Plant Groundwater • All identified background wells are appropriate for use. o MW-101 CB-01, CB-09, CB-09SL, NM-24S, CB-011), AMW-03B, and CB-09BR o Duke Energy recommended adding wells GW-I, GW-1D, and GW-1BR to the background dataset. Based on a review of the information provided, these wells may be added to the background dataset. If these wells are added, the new raw background dataset should be re -submitted to DWR. • The datasets for each flow layer meets the minimum requirement of at least 10 samples. • All identified sample event dates are appropriate for use. • All identified outliers are acceptable and should be removed from the background dataset. o If GW-1, GW-ID, and GW-1BR are added to the background dataset then re -test the new dataset for outliers and re -submit to the DWR, including strikethroughs of outliers and other unusable data (e.g high pH, high turbidity, autocorrelated data. Soil • The following background samples are appropriate for use: o CB-01 SB (7-8), CB-01 SB (30-31), CB-09 SB (1-2), CB-09 SB (25-27), GW-01 SB (1-2), MW-11SB (1.5-2), MW-12 SB (1.5-2), MW-13SB (1.5-2), MW-13SB (14.5-15), MW-14SB (1.5-2), MW-22 (1-2), MW-23BR (2-3), and NM-24SB (1- 2) • The following background samples are NOT appropriate for use: o MW-08 and MW-09 — Samples are at or immediately adjacent to the waste boundary and should not be used as background locations, even though the samples were collected above the seasonal high water table. o CB-08, MW-03, MW-05, and MW-07 — Downgradient of site contamination. o MW-13SB (22-22.5) — Sample was collected 3-feet below the water table and should not be used. • The dataset meets the minimum requirement of at least 10 samples after excluding samples. • The reporting limits for Antimony, Thallium, and Selenium were above the IHSB PSRG Protection of Groundwater values. Therefore, the number of useable values in the background dataset is severely limited for these constituents. Additional samples analyzed at a lower detection limit for these parameters are necessary. • Please state whether any background sample included fill material. Samples containing fill should be omitted from the raw background dataset. • All identified outliers are acceptable and should be removed from the background dataset. Asheville Steam Electric Plant Page 1 of 1 Belews Creek Steam Station Groundwater • All identified background wells are appropriate for use: o BG-2S, BG-3S, MW-202S, MW-3, BG-1D, BG-2D, BG-3D, BG-202D, BG-2BR- A, and MW-202BR • The datasets for the shallow and deep flow layers meet the minimum requirement of 10 samples. • The dataset for the bedrock flow layer does NOT meet the minimum requirement of 10 samples. Additional samples are required. • All identified sample event dates are appropriate for use. • All identified outliers are acceptable and should be removed from the background dataset. Soil • All identified background samples are appropriate for use: o BG-1D (1-2), BG-1D (11), BG-1D (21), BG-lD (31), BG-2D (1-2), BG-2D (10- 12), BG-2D (20-22), BG-2D (30-32), BG-3S (1-2), BG-3S (10-12), BG-3S (20- 22), GWA-3D (34-35.5), GWA 4S (45-47), GWA-12D (10-12), GWA-12D (15- 17), GWA-12D (20-22), and GWA-12D (25-27) • The dataset meets the minimum requirement of 10 samples. • The reporting limits for Antimony, Thallium, and Selenium were above the IHSB PSRG Protection of Groundwater values. Therefore, the number of useable values in the background dataset is severely limited for these constituents. Additional samples analyzed at a lower detection limit for these parameters are necessary. • Please state whether any background sample included fill material. Samples containing fill should be omitted from the raw background dataset. • All identified outliers are acceptable and should be removed from the background dataset. Belews Creek Steam Station Page 1 of 1 Buck Combined Cycle Station Groundwater • The following background wells are appropriate for use. o BG-18, BG-2S/D, BG-3SBRU, NM-6S/D, GWA-lS, MW-613R, and MW-8S/D • The following background wells are NOT appropriate for use: o BG-1D/BR— Recently reinstalled due to water quality issues and reevaluation as background location is necessary before being included. o BG-2BR — Recently reinstalled due to water quality issues and reevaluation as background location is necessary before being included. o MW-8BR — Recently reinstalled due to water quality issues and reevaluation as background location is necessary before being included. • All identified sample event dates are appropriate for use. • The datasets for each flow layer meets the minimum requirement of 10 samples after excluding samples. • All identified outliers are acceptable and should be removed from the background dataset. Soil The following background samples are appropriate for use: o BG-lD (1-2), BG-1D (9.8-11.2), BG-1D (16.4-17.9), BG-2D (2), BG-2D (10-11.5), BG-2D (13.5-15), BG-3BRU (1-2), BG-3BRU (10-10.5), BG-3BRU (20-20.5), GWA- lOD (3.0), and GWA-11D (19-20.5) The following background samples are NOT appropriate for use: o GWA-11) — Sample was collected from 0.3-0.6 ft. bgs. Per IHSB Guidance, these samples were taken too shallow. o GWA-6BRU — Sample is located downgradient of the Cells 2 and 3 and within 1 foot of the water table. o GWA-7D — Sample is located downgradient of the Cells 2 and 3 and within 1 foot of the water table. o GWA-91) — Sample is located downgradient of Cell 1, both sample intervals were collected in fill material (according to boring log) and one sample interval was collected within 1 foot of the water table. o GWA-12S —Sample is located downgradient of the ash basin. o GWA-22D — Sample is located downgradient of Cell 1 and sample interval was collected in fill material (according to boring log). • The dataset meets minimum requirement of 10 samples after excluding samples. • The reporting limits for Antimony, Thallium, and Selenium were above the IHSB PSRG Protection of Groundwater values. Therefore, the number of useable values in the background dataset is severely limited for these constituents. Additional samples analyzed at a lower detection limit for these parameters are necessary. • Please state whether any background sample included fill material. Samples containing fill should be omitted from the raw background dataset. • All identified outliers are acceptable and should be removed from the background dataset. Buck Combined Cycle Station Page 1 of 1 Cane Fear Steam Electric Plant Groundwater • All identified background wells are appropriate for use: o MW-15SU, MW-15SL, MW-16S, MW-09, MW-9BR, MW-15BR, and MW-16BR • The datasets for all flow layers meet the minimum requirement of 10 samples. • The following sample event dates are NOT appropriate for use: o MW-15BR ■ 3/2/16 — Less than 60 days from previous sample. • All identified outliers are acceptable and should be removed from the background dataset. Soil • The following background samples are appropriate for use: o BG-01(Geosyntec)(2.0-2.5), BG-02(Geosyntec)(2.0-2.5), BG-03(Geosyntec)(2.0- 2.5), MW-09 SB(2-3), MW-09 SB (6-7), and MW-22 SB (3-4) • The following background samples are NOT appropriate for use: o MW-05BR SB(0-2), MW-09 SB(0-2), MW-l0BR SB(0-2), MW-12BR SB(0-2), MW-15 SB(0-2), MW-20 SB(0-2), MW-22 SB(0-2), and MW-23 SB(0-2) — Per IHSB Guidance, these samples were taken too shallow. o BG-04(Geosyntec)(2.0-2.5) and BG-05(Geosyntec)(2.0-2.5) — Samples taken down -gradient of 1985 Ash Pond. • The dataset does NOT meet the minimum requirement of 10 samples. Additional samples are required. • Please state whether any background sample included fill material. Samples containing fill should be omitted from the raw background dataset. • All identified outliers are acceptable and should be removed from the background dataset. Cape Fear Steam Electric Plant Page 1 of I James E. Rogers Energy Complex Groundwater • All identified background wells are appropriate for use. o BG-1S, CCPMW-1S, MW-305, MW-325, GWA-245, GWA-255, GWA-30S, BG- 1D, MW-24D, MW-32D, GWA-24D, MW-32BR, CCPMW-ID, MW-24DR, GWA-24BR, GWA-30BR, MW-22BR, and MW-22DR • The datasets for all flow layers meet the minimum requirement of 10 samples. • All identified sample event dates are appropriate for use. • The following outliers are NOT appropriate for use and should be removed from the background dataset: Soil o Total Dissolved Solids — 10,700,000 ug/L (saprolite) o Total Dissolved Solids — 4,410,000 ug/L (saprolite) o Total Dissolved Solids—407,000 ug/L (transition zone) o Total Dissolved Solids—116,000 ug/L (transition zone) o Iron — 31200 ug/L (transition zone) o Vanadium — 3 ug/L (transition zone) The following background samples are appropriate for use: o BG-ID (3.5-5), BG-ID (8.5-10), BG-2D (3.5-5), BG-2D (8.5-10), BG-2D (18.5- 20), BG-2D (28.5-30), MW-30D (3.5-5.5), MW-30D (8.5-10), MW-30D (18.5-20), MW-30D (28.5-30), MW-32D (3.5-5), MW-32D (8.5-10), MW-32D (18.5-20), MW-32S (22.5-24), MW-42D (28.5-30), and GWA-25D (8.5-10) The following background samples are NOT appropriate for use: o BG-lS (3.5-5), BG-IS (8.5-10), MW-30S (4-5), MW-30S (9-10), MW-30S (19- 20), and MW-30S (28-29), — Only analyzed for TOC. o GWA-1 OD — Located at or immediately adjacent to the waste boundary at Units 1- 4 basin. o GWA-31D (7), GWA-31D (8.7), and GWA-31BR — Located at or immediately adjacent to and downgradient of the waste boundary at Unit 5 basin and are adjacent to a road and parking lot. o MW-38D (33.5-35) — This location is downgradient of the Unit 5 Inactive Ash Basin and adjacent to the Broad River. o GWA-3D (48.5-50) — Location is downgradient of the Unit 5 Inactive Ash Basin. o GWA-12BRU (20-23.5) — Location is immediately downgradient of Units 1-4 Inactive Ash Basin. May be close to water table and is near the Broad River. o GWA-21BRU (5) — This sample may be immediately above the water table and more importantly, the location is potentially downgradient of a basin and is situated adjacent to the Broad River where there a potentially significant fluctuations of water levels by a discharge point. o GWA-22S (3-5) — Location is side gradient of the Active Ash Basin and adjacent to the Broad River. The sample was collected within the screen interval of the well. James E. Rogers Energy Complex Page 1 of 2 o GWA-27D (13.5-15) and GWA-27D (24.9) — Location is adjacent to and downgradient of the impoundment. The sample was collected within the screened interval of the well. o NM-40BRU (3.5-5) — Location is adjacent to and downgradient of the Unit 5 Inactive Ash Basin and near the Broad River, and the sample was collected from within the screened interval. o GWA-61) (28.5-30) — Location is immediately downgradient of Unit 5 Inactive Ash Basin and may be close to water table and is near the Broad River. • The dataset meets the minimum requirement of 10 samples after excluding samples. • The reporting limits for Antimony, Thallium, and Selenium were above the IHSB PSRG Protection of Groundwater values. Therefore, the number of useable values in the background dataset is severely limited for these constituents. Additional samples for these three parameters are necessary. • Please state whether any background sample included fill material. Samples containing fill should be omitted from the raw background dataset. • The following outlier is NOT appropriate for use and should be removed from the background dataset: o MW-32S (22.5-24) ■ Arsenic — 7.9 mg/kg James E. Rogers Energy Complex Page 2 of 2 Dan River Combined Cycle Station Groundwater • The following background wells are appropriate for use: o GWA-9S, BG-11), GWA-9D, MW-231), MW-23BR, BG-5S, BG-51), BG-IOS, BG-101), and BG-10BR o GWA-9S/D and BG-IOS/D/BR appear to be appropriate for use; however, further evaluation will be needed to determine whether these wells are truly located up - gradient of the ash storages. • The following background wells are NOT appropriate for use: o GWA-12S/D —It appears that coal ash constituent boron, have been detected in soil samples taken from this well. o MW-20S/D — This well could be impacted by groundwater flowing from the storage 1 area. • The datasets for the shallow and deep flow layers meet the minimum requirement of 10 samples after excluding samples. • The dataset for the bedrock flow layer does NOT meet the minimum requirement of 10 samples. Additional samples are required. • All identified sample event dates are appropriate for use. o Provisional background threshold value for hexavalent chromium (shallow flow layer), vanadium (shallow flow layer), and radionuclides (shallow flow layer) are based on a limited dataset. Additional samples are required. • All identified outliers are acceptable and should be removed from the background dataset. Soil The following background samples are appropriate for use: o BG-513(1-2), GWA-2D(19-20), GWA-9D(20-21.5), GWA-1O1)(9-10), SB-1(1-2), SB-1(10-11.5), SB-1(15-16.5), SB-1(20-21.5), SB-1(25-26.5), SB-2(1-2), SB- 2(10-11.5), SB-2(20-21.5), SB-2(30-31.25), SB-2(35-36), SB-2(65-65.3), SB-3(1- 2), SB-3(10-11), SB-3(20-21.5), and SB-3(35-36.5) The following background samples are NOT appropriate for use: o BG-1D(0-2) — Per IHSB Guidance, this sample was taken too shallow. o GWA-3D(5-6.5) — Sample taken in close proximity to Ash Storage 1. o GWA-6S(9-11) — Sample taken down -gradient of Ash Basin Primary Cell o GWA-10D(19-20) and GWA-10D(25) — Samples taken down -gradient of Ash Storage 2. o GWA-1113(10-11.5) — Sample taken down -gradient of Ash Storage 1. Th dataset meets minimum requirement of 10 samples after excluding samples. The reporting limits for Antimony, Thallium, and Selenium were above the IHSB PSRG Protection of Groundwater values. Therefore, the number of useable values in the background dataset is severely limited for these constituents. Additional samples analyzed at a lower detection limit for these parameters are necessary. Dan River Combined Cycle Station Page 1 of 2 • Please state whether any background sample included fill material. Samples containing fill should be omitted from the raw background dataset. • All identified outliers are acceptable and should be removed from the background dataset. Dan River Combined Cycle Station Page 2 of 2 H. F. Lee Enerev Complex Groundwater • The following background wells are appropriate for use: o AMW-11S, AMW-12S, AMW-13S, AMW-17S, IMW-01S, IMW-03S, AMW- 11BC, AMW-12BC, AMW-13BC, AMW-16BC, IMW-01BC, IMW-02BC, and IMW-03BC. o AMW-016BC —The location maybe near the contact with the Black Creek. Please confirm. The datasets for the surficial and Cape Fear flow layers meets the minimum requirement of 10 samples. The dataset for the Black Creek flow layer does NOT meet the requirement of 10 samples. Additional samples are required. The following sample event dates are NOT appropriate for use. o AMW-12S ■ 3/1/16 — Less than 60 days from previous sample. o AMW-13S ■ 3/1/16 —Less than 60 days from previous sample. o AMW-12BC ■ 3/1/16 — Less than 60 days from previous sample. o AMW-13BC ■ 3/1/16 — Less than 60 days from previous sample. o IMW-0lBC ■ 3/4/16 — Less than 60 days from previous sample. o IMW-02BC • 3/3116 — Less than 60 days from previous sample. • All identified outliers are acceptable and should be removed from the background dataset. Soil The following background samples are NOT appropriate for use: o AMW-12 SB (5-6) — Sample may have been taken within 1 foot of the seasonal high water table. o IMW-05 SB (0-2.5) and IMW-05 SB (4-6). This location is in very close proximity to the southeast corner of Inactive Basin 3 and possibly influenced by the presence of the ash basin. Per IHSB Guidance, these samples were taken too shallow. o AMW-18 SB (0-2.5) and AMW-18 SB (3-5). Samples were collected from the core of the plume migrating from the Active Basin. o AMW-04 SB (1-2) and AMW-04 SB (4-5). Samples are located at the western end of the Active Basin, adjacent to the Neuse River. o AMW-16BC (19-21). o AMW-11 (0-2), AMW-12 SB (0-2), AMW-13 SB (0-2), and AMW-16BC (0-2) - Per IHSB Guidance, these samples were taken too shallow. H. F. Lee Energy Complex Pagel of 2 • The dataset does NOT meet the requirement of 10 samples. Additional samples are required. • The reporting limits for Antimony and Thallium were above the IHSB PSRG Protection of Groundwater values. Therefore, the number of useable values in the background dataset is severely limited for these constituents. Additional samples analyzed at a lower detection limit for these parameters are necessary. • Please state whether any background sample included fill material. Samples containing fill should be omitted from the raw background dataset. • All identified outliers are acceptable and should be removed from the background dataset. H. F. Lee Energy Complex Page 2 of 2 Marshall Steam Station Groundwater • The following background wells are appropriate for use. o GWA-4S/D, GWA-5S/D, GWA-6S/D, GWA-8S/D, GWA-12SBR, BG-3BR, MS- 10, MW-4, and MW-4D • The following background wells are NOT appropriate for use: o BG-lBR — Recently reinstalled due to water quality issues and reevaluation as background location is necessary before being included. o GWA-12D — Recently reinstalled due to water quality issues and reevaluation as background location is necessary before being included. • The datasets for each flow layer meets the minimum requirement of 10 samples after excluding samples. • All identified sample event dates are appropriate for use. • All identified outliers are acceptable and should be removed from the background dataset. Soil • The following background samples are appropriate for use: o BG-3D(1-2), BG-313(10-12), GWA-2DA(3-5), GWA-2DA(8-10), GWA-4D(52- 53), GWA-5D(27.5-29.0), GWA-14S(3-5), and GWA-14S(8-10) • The following background samples are NOT appropriate for use: o GWA-1BR — Sample is within the waste boundary downgradient of the ash basin and coal pile. o MW-14BR — Sample is located downgradient of the ash basin and Phase I Landfill (unlined). • The dataset does NOT meet minimum requirement of 10 samples. Additional background samples are required. • The reporting limits for Antimony and Thallium were above the IHSB PSRG Protection of Groundwater values. Additional samples analyzed at a lower detection limit for these parameters are necessary. • Please state whether any background sample included fill material. Samples containing fill should be omitted from the raw background dataset. • All identified outliers are acceptable and should be removed from the background dataset. Marshall Steam Station Page 1 of 1 Mayo Steam Electric Plant Groundwater • The following background wells are appropriate for use: o MW-125, BG-02, MW-12D, BG-Ol, MW-13BR, and MW-14BR • The following background wells are NOT appropriate for use: o MW-IOBR • The dataset for the surficial flow layer does NOT meet the minimum requirement of 10 samples. Additional samples are needed. • The datasets for the transition zone and bedrock flow layers meets the minimum requirement of 10 samples. o Provisional background threshold values for radionuclides in the transition zone flow layer are based on a limited dataset. Additional samples are required. • The following sample event dates are NOT appropriate for use: o BG-01 Soil ■ 11/3/2015 —Less than 60 days from previous sample. ■ 1/8/2016 — Less than 60 days from previous sample. • 9/8/2016 — Less than 60 days from previous sample. ■ 3/28/17 — Less than 60 days from previous sample. o MW-10BR ■ 1M16 —Less than 60 days from previous sample. ■ 9/7/16 —Less than 60 days from previous sample. o MW-13BR ■ 1/7/2016 — Less than 60 days from previous sample. • 9/6/2016 — Less than 60 days from previous sample. All identified outliers are acceptable and should be removed from the background dataset. The following background samples are appropriate for use: o MW-08BR (0.75-1.25), MW-08BR (25.5-26), MW-IOBR (0.75-1.0), MW-12D (1- 2), MW-12D (25-26), SB-01 (1-2), and SB-01 (13.5-14.5) The following background samples are NOT appropriate for use: o MW-03BR (0.8-1.25) and MW-15BR (0.5-1) — Samples taken down -gradient of Ash Basin. o MW-11BR (0-2) and MW-13BR (0-2) —Per IHSB Guidance, these samples were taken too shallow. o SB-02 (0.5-2) and SB-02 (11.0-12.5) — Boring log indicates the presence of coal ash. o SB-03 (5-6) and SB-03 (17-18.5) — Boring log indicates the presence of coal ash. o SB-05 and SB-06. Sample locations were adjacent to the 1981 landfill. The dataset does NOT meet the minimum requirement of 10 samples. Additional samples required. Mayo Steam Electric Plant Page 1 of 2 • The reporting limits for Antimony and Thallium were above the IHSB PSRG Protection of Groundwater values. Therefore, the number of useable values in the background dataset is severely limited for these constituents. Additional samples analyzed at a lower detection limit for these parameters are necessary. • Please state whether any background sample included fill material. Samples containing fill should be omitted from the raw background dataset. • All identified outliers are acceptable and should be removed from the background dataset. Mayo Steam Electric Plant Page 2 of 2 Riverbend Steam Station Groundwater • The following background wells are appropriate for use: o BG-lS, MW-7SR, MW-7D, BG-4S, GWA-14S, BG-41), BG-5D, and BG-5BR o MW-71) was listed under the shallow flow laver. Please re-evaluate. • The following background wells are NOT appropriate for use: o GWA-5S — Groundwater water elevations were similar and sometime lower than the historical water elevation of ash basin. Also, the wells are within compliance boundary and not far from the waste boundary. • The datasets for shallow meets the minimum requirement of 10 samples after excluding samples. • The datasets for the deep and bedrock flow layers does NOT meet the minimum requirement of 10 samples. Additional samples are required. • All identified sample event dates are appropriate for use. • All identified outliers are acceptable and should be removed from the background dataset. Soil • The following background samples are appropriate for use: o BG-lD (5-6), BG-1D (14-15), BG-lD (24-25), BG-2D (3.5-5), BG-2D (48-49), BG- 3D (3-5), BG-31) (18.5-20), BG-3D (23-24), GWA-51) (58.5-60), GWA-6D-1(43.5- 45), GWA-6D-2(48.5-50), GWA-21D(3.5-5), GWA-211)(8.5-10), GWA-21D(18.5- 20), GWA-21D(48.5-50), MW-7BR(43.5-45), and OB-2(38.5-40.0) • The following background samples are NOT appropriate for use: o GWA-3D(18.5-19) — Sample taken down -gradient of Ash and Cinder Storage Areas. o GWA-7S(7.0-8.0) — Sample taken down -gradient of Ash Basins. o GWA-8D(8.5-10) — Sample taken down -gradient of Ash Basins. o GWA-9D (1), GWA-10S (8-9), and NM-15D (3.5-5) — Downgradient location and maybe within the High Seasonal Water Table. o GWA-20D(40-41.5) — Sample taken in close proximity to Ash Storage Area. o GWA-22D(38.5-40.0) — Sample taken in close proximity to Ash Storage Area. o GWA-23D(33.5-35) — Sample taken within the waste boundary of the Ash Storage Area. o OB-1(33.5-35.0) — Sample taken inclose proximity to Ash Basin. • The dataset meets the minimum requirement of 10 samples after excluding samples. • The reporting limits for Antimony, Thallium, and Selenium were above the IHSB PSRG Protection of Groundwater values. Therefore, the number of useable values in the background dataset is severely limited for these constituents. Additional samples analyzed at a lower detection limit for these parameters are necessary • Please state whether any background sample included fill material. Samples containing fill should be omitted from the raw background dataset. • All identified outliers are acceptable and should be removed from the background dataset. Riverbend Steam Station Page 1 of 1 Roxboro Steam Electric Plant Groundwater • The following background wells are appropriate for use: o BG-1, MW-15D, MW-18D, BG-01BR MW-IOBR, MW-14BR, MW-15BR, MW- 18BR, and MW-19BRL • The following background wells are NOT appropriate for use: o MW-13BR, MW-16BR, and MW-17BR • The datasets for all flow layers meet the minimum requirement of 10 samples after excluding samples. • The following sample event dates are NOT appropriate for use: o BG-01 ■ 9/8/2016 — Less than 60 days from previous sample. ■ 11/16/16 —Less than 60 days from previous sample. o BG-01BR ■ 7/9/15 — Less than 60 days from previous sample. o MW-17BR • 11/10/16 —Less than 60 days from previous sample. All identified outliers are acceptable and should be removed from the background dataset. Soil • The following background samples are appropriate for use: o MW-08 (14-16), MW-08 (21-23), MW-13BR (22-24), MW-14BR (1-1.25), MW- 14BR (31-31.5), MW-14BR (37.5-38), MW-17 (29-31), MW-18 (31-33), and MW- 18 (37-38) • The following background samples are NOT appropriate for use: o MW-07 (0-2), MW-08 (0-2), MW-IOBR (0-2), MW-13BR (0-2), MW-15 (0-2), MW-16 (0-2), and MW-18 (0-2) — Per IHSB Guidance, these samples were taken too shallow. • The dataset does NOT meet the minimum requirement of 10 samples. Additional samples are required. • The reporting limits for Antimony and Thallium were above the IHSB PSRG Protection of Groundwater values. Samples for these two parameters need to be reported below these values. • Please state whether any background sample included fill material. Samples containing fill should be omitted from the raw background dataset. • All identified outliers are acceptable and should be removed from the background dataset. Roxboro Steam Electric Plant Page 1 of 1 �n L. V. Sutton Energy Complex Groundwater • All identified background wells are appropriate for use: o MW-05A, MW-0513, MW-3713, MW-0413, MW-05C, MW-08, MW-37C, MW-05CD, MW-05D, MW-37D, MW-05E, and MW-37E o Lower Surficial Aquifer — An adequate dataset has been provided for all constituents, with the exception chromium (VI). Additional samples are planned for collection to bring the total number of valid chromium (VI) samples to ten by second quarter 2017. • The datasets for the upper and lower surficial flow layer meet the minimum requirement of 10 samples. • The dataset for the Upper Peedee flow layer does NOT meet the minimum requirement of 10 samples. Additional samples are planned for collection to bring the total number of valid samples to ten (second quarter 2017 at the earliest). It was agreed upon to use a pH of less than or equal to 9.7 S.U. as the upper threshold for these zones in the Peedee aquifer. • The dataset for the Lower Peedee flow layer does NOT meet the minimum requirement of 10 samples. New and replacement wells have been added to the groundwater monitoring network (MW-5R-E, MW-8E, MW-41E). Additional samples are planned for collection to bring the total number of valid samples to 10 (second quarter 2017 at the earliest). It was agreed upon to use a pH of less than or equal to 9.7 S.U. as the upper threshold for these zones in the Peedee aquifer. • All identified sample event dates are appropriate for use. • All identified outliers are acceptable and should be removed from the background dataset. Soil • The following background samples are appropriate for use: o AW-02C (10-11) and MW-37C (4-6) • The following background sample are NOT appropriate for use: o AW-01C (0-2), AW-02C (0-2), AW-03C (0-2), AW-04C (0-2), AW-06D (0-2), AW- 07D (0-2), MW-37C (0-2), SMW-01C (0-2), SMW-02C (0-2), SMW-03C (0-2), SMW-04C (0-2), SMW-05C (0-2), and SMW-06D (0-2) — Per IHSB Guidance, these samples were taken too shallow. o AW-05C (4-6) and AW-05C (9-11) —Samples are down -gradient of the ash pond. • The dataset does NOT meet the minimum requirement of 10 samples. Additional samples are require . • The reporting limits for Antimony, Cobalt, and Thallium were above the IHSB PSRG Protection of Groundwater values. Therefore, the number of useable values in the background dataset is severely limited for these constituents. Additional samples analyzed at a lower detection limit for these parameters are necessary. • Please state whether any background sample included fill material. Samples containing fill should be omitted from the raw background dataset. • All identified outliers are acceptable and should be removed from the background dataset. L. V. Sutton Energy Complex Page 1 of 1 W.H. Weatherspoon Power Plant Groundwater • All identified background wells are appropriate for use. o BW-02S, BW-03S, CCR-101-13G, MW-01, BW-03I, and BW-03D • The dataset for the surficial flow layer meets the minimum requirement of 10 samples • The dataset for the Lower Yorktown does NOT meet the minimum requirement of 10 samples. Additional samples are required. • The dataset for the PeeDee does NOT meet the minimum requirement of 10 samples. Additional samples are required. • The following sample event dates are NOT appropriate for use. o BW-03S ■ 3n116 — Less than 60 days from previous sample. • All identified outliers are acceptable and should be removed from the background dataset. Soil No soil background data was provided. Please coordinate the collection of background soil data with the DWR Fayetteville Regional Office. W. H. Weatherspoon Power Plant Page 1 of I 2017 Comprehensive Site Assessment Update October 2017 Riverbend Steam Station SynTerra ZIMMERMAN TO DRAOVITCH SEPTEMBER 1, 2017 Water Resources Environmental Quality September 1, 2017 Paul Draovitch Senior Vice President Environmental, Health & Safety Duke Energy 526 South Church Street Mail Code EC3XP Charlotte, North Carolina 28202 ROY COOPER Governor MICHAEL S. REGAN Secretary S. JAY ZINIMERMAN Director Subject: Approval of Provisional Background Threshold Values for Riverbend Steam Station Dear Mr. Draovitch: The North Carolina Department of Environmental Quality's Division of Water Resources (DWR) has reviewed Duke Energy's calculated provisional background threshold values (PBTVs) for soil and groundwater for the subject facility. DWR calculated PBTVs based on the vetted background data in the letter to Duke Energy dated July 7, 2017, using the Revised Statistical Methods for Developing Reference Background Concentrations for Groundwater and Soil at Coal Ash Facilities dated May 26, 2017. It should be noted that Duke Energy supplied additional data on August 8, 2017, and September 1, 2017, on which their final calculations were based. Per 15A NCAC 02L .0202(b)(3), where naturally occurring substances exceed the established standard, the standard shall be the naturally occurring concentration as determined by the Director. Therefore, PBTVs that are calculated to be above the 15A NCAC 02L .0202 groundwater standards or Interim Maximum Allowable Concentrations (IMACs) and accepted by DWR shall become the enforceable groundwater standard. Otherwise, the enforceable groundwater standards shall be those listed under 15A NCAC 02L .0202(h) including any effective IMACs. The attachments document DWR's concurrence/non-concurrence with Duke Energy's calculated PBTVs for groundwater and soil. For all Duke Energy's calculated PBTVs that DWR finds acceptable, DWR hereby approves those values. If DWR does not find the Duke Energy's calculated PBTVs acceptable, justification is provided on the attachments. Duke Energy will be responsible to provide revised values for DWR to review and approve. Please note that the approved PBTVs are based on the current data available. DWR recognizes that, as new data is gathered going forward, the approved PBTVs may be refined. Thus, there will be need for a periodic review of the data and recalculation of the PBTVs. The timeframes for the periodic review will established by DWR at a later date and any revised PBTVs will be subject to approval by the DWR's Director. State of North Carolina I Environmental Quality I Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center I Raleigh, North Carolina 27699-1636 919-707-9129 Along with the specific comments provided on the attachments, DWR offers the following general comments with regards to the PBTVs Outliers are identified with three statistical lines of evidence; Box Plots, Q-Q Plots, and 95% Significance Levels. Based on these lines of evidence, if Duke Energy chooses not to exclude an outlier, then additional rationale or justifications shall be provided. The PSRG for Chromium shall be the more conservative value for Chromium (VI) which is 3.8 mg/kg. If you have any questions, please contact Shuying Wang (Winston-Salem Regional Office) at (336) 776-9800 or Steve Lanter (Central Office) at (919) 807-6444. Sincerely, S. Ja:M' merman, P.G., Director Division of Water Resources Attachments cc: WSRO WQROS Regional Office Supervisor WQROS Central File Copy 2017 Comprehensive Site Assessment Update October 2017 Riverbend Steam Station DEQ PBTV APPROVAL ATTACHMENTS - SEPTEMBER 1, 2017 SynTerra Riverhead Steam Station - Groundwater Provisional Bac round Threshold Values Parameter Reporting Units Duke lsnergy Calculated PBTVs Plow Unit 15A NCAC 02L Standard or IMAC DWR Concurrence (Acceptable/Not Acceptable) Comments Flow Unit Shallow Deep Bedrock Shallow Deep Bedrock H S.U. 4.9 - 7.0 4.9 - 7.0 7.6 - 7.8 6.5-9.5 Acceptable Acceptable Acceptable Not evaluated because the values are below the groundwater standards or no standard is established. Alkalinity m L 93.1 139 139 NE Acceptable Acceptable Acce table Aluminum µg/L 172.2 _ 1204 too NE Acceptable Acceptable Acceptable Antimony µ 1 1.1 2.9 1 Acceptable Acceptable Not Acce table Only four observations ave vailable. Use 21JIMAC until more data are available. Arsenic 1 1 2.9 10 Acceptable Acceptable Acce ble Not evaluated because the values are below the groundwater standards or no standard is established. Barium µ L 561 84.4 135 700 Acceptable Acceptable Acce table Beryllium ilgli, I 1 0.1 4 Acceptable Acceptable Acceptable Bicarbonate mg/L 93 1 147 139 NE Acceptable Acceptable Acceptable Boron _ N I) ND 50 700 Acceptable Acceptable Acceptable Cadmium _ ND ND 0.08 2 Acceptable Acceptable Acceptable Calcium mg/L _ 18.8 32.9 46.7 NE Acceptable Acceptable Acceptable Carbonate mg/L _ND ND 10.7 5 16 NE 250 Acceptable Acceptable Acceptable Acceptable Acceptable Acceptable Chloride mg/L _ 3.242 Chromium VI _ 1.097 0.9 0.16 NA Acceptable Acceptable Acceptable Chromium µg/L 14 5 1.5 10 Not Acceptable Acceptable Acceptable Shallow should be 5 (or 2L) because 14 was identified as an outlier. Cobalt 11.64 0.517 0.088 1 Not Acceptable Acceptable Acceptable Shallow should be 2.3 because 11.3, 9.4, and 8.5 were identified as outliers. Copper µg/L I 5 5 0.5 1000 Acceptable Acceptable Acceptable Not evaluated because the values are below the groundwater standards or no standard is established. Iron pgfL _ I278 56.3 125 300 Not Acceptable Acceptable Acceptable Shallow should be 950 because 1890 was identified as an outlier. Lead Magnesimn p mg/L 1 3.49 ND 6.81 0.1 7.46 15 NE Acceptable Acceptable Acceptable Acceptable Acceptable Acceptable Not evaluated because the values are below the groundwater standards or no standard is established. Manganese 481 7.9 24.5 50 Acceptable Acceptable Acceptable Memo ND ND 0.2 1 Acceptable Acceptable Acceptable Not evaluated because the values are below the groundwater standards or no standard is established. Methane pg/L 29.63 6 41.7 NE Acceptable Acceptable Acceptable Molybdenum µ 3.9 7.3 10 NE Acceptable Acceptable Acceptable Nickel 5 5 0.87 100 Acceptable Acceptable Acceptable Nitrate + Nitrite m -N/L 0,23 0.1 0.02 11* Acceptable Acceptable Acceptable Potassium mg/L 5 5 4.57 NE Acceptable Acceptable Acceptable Selenium Sodium µg/L mg/L ND 12.8 1.3 17 03 23.7 20 NE Acceptable Acceptable Acceptable Acceptable Acceptable Acceptable Strontium WL 293 697 961 NE Acceptable Acceptable Acceptable Sulfate mg/L 2.3 21.9 29 250 Acceptable Acceptable Acceptable Sulfide mg/L ND 0.1 2 NE Acceptable Acceptable Acceptable TDS mg/L 73 179 223 500 Acce table Acceptable Acce table Thallium 0.2 0.2 0.1 0.2 Acceptable Acceptable Acceptable TOC mg/L 9 1 NA NE Acceptable Acceptable Acceptable Vanadium 2.223 9.74 0.33 0.3 Acceptable Acceptable Acceptable Zinc 18 10 10 1000 Acce table Acce table Acce table Not evaluated because the values are below the groundwater standards or no standard is established. Radium (Total) I pCi/L 0.8 NA 0.494 NE Acceptable Acceptable Acceptable Uranium (Total) mL 1 0.005 0.009 0.00099 NE Acceptable Acceptable Acceptable NA - Not Applicable ND - Not Detected NE - Not Established mg/L -milligrams per liter pCi/L - p¢ocuries per liter Radium (Total) - Radium-226 and Radium-228 combined -The ISA NCAC 02L Standard is 10 mg/L for Nitrate and 1 mg/L for Nitrite (added for a total of I I mg/L) S.U. - Standard Unit TOC - Total Organic Carbon TDS - Total Dissolved Solids µglint, - micrograms per milliliter µg/L - micrograms per liter Uranium (Toal) - Cranium-233, Uranium-234, Uranium-236, and Uranium-238 combined Riverbend Steam Station - Soil Provisional Background Threshold Values Parameter Reporting Units Duke Energy Calculated PB.fvs PSRG Protection of Groundwater DWR Concurrence (Acceptable/Not Acceptable) Comments H S.U. 4. 3 - a .7 NE Acceptable Aluminum m 31151 NE Acceptable Antimony mg/kg O.F, 0.9 Acceptable Arsenic mg/kg 3.8 5.8 Acceptable Barium my �kg 190 580 Acceptable Beryllium mg/kgmg/kg 1.655 63 Acceptable Boron mglkg 2.3 45 Acceptable Cadmium mg/kg 0.03 3 Acceptable Calcium mg/kg 410 NE Acceptable Chloride mg/kgmg/kg 12 NE Acceptable Chromium mg/kgmg/kg 20 360000- 3.8 Acceptable Use the PSRG for Chromium (IV) of 3.8 m to be more conservative. Cobalt mg/kgmg/kg 5R.61 0.9 Not Acceptable PBTV for Cobalt should be 46.5 without any identified outliers Copper mg/kg 33.09 700 Acceptable Iron mg/kg 40150 150 Acceptable Lead mg/kgmg/kg 11.29 270 Acceptable Magnesium mglkg 760 NE Acceptable Manganese mg/kgmg/kg 1867 65 Acceptable Mercury mgkg 0.099 1 Acceptable Molybdenum mg/kgmg/kg 1.829 NE Acceptable Nickel mg/kgmg/kg 10.23 130 Acceptable Nitrate as N) mg/kgmg/kg 025 NE Acceptable Potassium mg/kg 2440 NE Acceptable Selenium mWkg 1 576 2.1 Acceptable Sodium mg/kg 4'7 NE Acceptable Strontium m Ix. 34 NE Acceptable Sulfate m 12 250 Acceptable Thallium mg/kg 0.166 0.28 Acceptable Vanadium mglkg 112 t 6 Acceptable Zinc mgfkg _ _ _ 60.45 1200 Acceptable NA - Not applicable (dataset contains zero valid samples) ND - Non -Detect NE - Not Established mg/kg - millittrams per kilobmam S.U. - Standard Unit