NC0024406_SOC WQ S18-009 amendment application_20190416

DUKE
ENERGY
April 16, 2019
Linda Culpepper, Director
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: SOC amendment application
Belews Creek Steam station
NC0024406
EMC SOC WQ S 18-009
Dear Ms. Culpepper,
Paul Draovitch, P.E.
Senior Vice President
Envlronrnentat, Health & Safety
526 S, Church Street
Mall Code EC3XP
Charlotte, NC 2tt2t)2
Enclosed please find an application for amendment of the subject Consent Order. A check in the
amount of $400.00 for the application fee is being hand delivered to your office by our staff in
Raleigh.
If there are any questions about this matter please feel free to contact Shannon Langley at (919)
546-2439 or [e-mail].
Sincere ,
Paul Draovitch, P.E. Senior Vice President
Environmental Health & Safety
Enclosures
cc: Jim Wells • w/enclosures via email
Richard Baker w/enclosures via email
Joyce Dishmon/Filenet — w/enclosures via email
Reginald Anderson — w/enclosures via email
Shannon Langley — w/enclosures via email
www,dukcaenLrgy.com

STATE OF NORTH CAROLINA
DEPARTRIENT OF ENVIRONMENT AND NATURAL RESOURCES
D1IVISION OF WATER RESOURCES
APPLICATION FOR AN AMENDMENT TO A SPECIAL ORDER BY CONSENT
I. GENERAL INFORMATION:
Applicant (corporation, individual, or other): Duke Enerev Carolinas LLC
2. Owner Phone: [phone] (or)
1 Owner Email: aul.draovitch@duke-ever .com
4. Facility Name (must be the same as name on the original SOC):
Belews Creek Steam Station
5. Original SOC No. / Issuance Date: EMC SOC WO_S 18-009
6. NPDES Permit No. (if applicable): NCO024406
5. Application Date: Aril 16 2019
II. SOC COMPLIANCE HISTORY:
Please attach a listing of all violations this facility has had under this Order. Include jgy violation
of interim dates, relaxed permit parameters, and existing permit limits.
SEE ATTACHED DOCUMENT
III. ADDITIONAL FLOW OR REALLOCATION OF EXISTING FLOW:
Only facilities owned by a unit of government may request to add additional flow to the treatment
system as part of this SOC Amendment in accordance with NCGS 143-215.67(b).

Additional flow may be allowed under an SOC amendment only in specific circumstances. These
circumstances may include eliminating discharges that are not compliant with an NPDES or Non -
discharge permit as specified in the original SOC. These circumstances do not include failure to
perform proper maintenance on treatment systems, collection systems or disposal systems. When
requesting additional flow, the facility must include its justification and supporting documentation.
If the requested additional flow is non -domestic, the facility must be able to demonstrate the ability
to effectively treat the waste and dispose of residuals. The applicant must provide a detailed
analysis of all constituents in the proposed non -domestic wastewater.
The total domestic additional flow requested: N/A gallons per day.
The total non -domestic additional flow requested: N/A gallons per day.
The total additional flow (sum of the above); N/A gallons per day.
If a reallocation of existing additional flow is needed the facility must provide justification as to
why this reallocation is needed.
Any additional flow that may be allowed will be determined by an analysis of projected
adverse impacts on the wastewater treatment facility and/or surface waters.
IV. WHY AN SOC AMENDMENT IS NEEDED:
Please provide a detailed explanation as to why the SOC amendment is being requested. Include
actions already taken to avoid noncompliance with the existing SOC. Also provide details on
activities that were delayed.
SEE ATTACHED DOCUMENT
THE DIVISION OF WATER RESOURCES WILL NOT ACCEPT THIS APPLICATION
PACKAGE UNLESS ALL OF THE APPLICABLE ITEMS ARE INCLUDED WITH THE
SUBMITTAL.
Required Rents;
a. One original and two copies of the completed and appropriately executed application
form„ along with all required attachments.
• If the SOC Amendment is for a City / Town, the person signing the SOC must be a
ranking elected official or other duly authorized employee.

• If the SOC Amendment is for a Corporation / Company / Industry / Other, the
person signing the SOC must be a principal executive officer of at least the level of
vice-president, or his duly authorized representative.
• If the SOC Amendment is for a School District, the person signing the SOC must
be the Superintendent of Schools or other duly authorized employee.
Note: Reference to signatory requirements in SOCs may be found in the North
Carolina Administrative Code [TISA NCAC 2H .I206(a)(3)].
b. The non-refundable Special Order by Consent (SOC) processing fee of $400.00. A
check must be made payable to The Department of Environment and Natural
Resources.

APPLICANT'S CERTIFICATION:
(NO MODIFICATION TO THIS CERTIFICATION IS ACCEPTABLE)
I, Paul Draovitch, P.E. , attest this application for a Special
Order by Consent (SOC) amendment has been reviewed by me and is accurate and complete to
the best of my knowledge. I understand if all required parts of this application are not completed
and if all required supporting information and attachments are not included, this application
package may be returned as incomplete. (Please be advised that the return of this application does
not prevent DWR from collecting all outstanding penalties upon request). Furthermore, I attest
by my signature that I fully understand that an upfront penalty, which may satisfy as a full
settlement for past violations, may be imposed. {Nate: Reference to upfront penalties in
Special ders by Consent may be found in the North Carolina Administrative Code [T15A NCAC
2H .1206( )(3)], }
Date
Signature of Signing Official
Senior Vice President, Environmental. Health & Safety _
Printed Name of Signing Official
THE COMPLETED AMENDMENT APPLICATION PACKAGE, INCLUDING ALL
SUPPORTING INFORMATION, SHOULD BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER RESOURCES
POINT SOURCE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1617
IF THIS APPLICATION IS FOR A NON -DISCHARGING SYSTEM, THEN SEND TO:
NORTH CAROLINA DIVISION OF WATER RESOURCES
AQUIFER PROTECTION SECTION
1636 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1636

Attachments
Application for amendment to Special Order by Consent
Belews Creek Steam station
'Permit Number: NCO024406
Consent Order #: EMC SOC WQ S 18-009
April 2019

SOC application Section II
SOC Compliance History
The facility has complied with all interim dates under the SOC. The facility is on
target to comply with all future compliance dates in the Order. Specifically:
Progress is being made towards relocation of the outfall from the Lined Retention
basin away from the newly classified "unnamed tributary" to the main stem of the
Dan River. Construction began on the new line on March 15, 2019.
Progress is being made in decanting the ash basin. Decanting of the basin began
on March 27, 2019. This action was required to comply with terms of Consent
Order "EMC SOC WQ S 18-004".
Engineering work continues related to relocating outfall I I I flows to the Dan
River via outfall new pipeline that is being constructed.
The facility has noted the Interim Action Level UAL) for total hardness is set at a
level that is lower than historic discharge concentrations of the ash basin and
request that it be modified to a level attainable based on sampling data from the ash
basin and the Lined retention basin.
The facility has started up the new Lined retention basin treatment system built to
replace the ash basin and eliminated flows to the ash basin to comply with the
Federal CCR rule. The facility has begun decanting the ash basin as required by
Consent Order EMC SOC WQ S 18-004.
Since the removal of bottom ash sluice water and startup of these activities, the
facility has noted the following results very close to interim limits and slight
exceedences of interim limits:
Date
Location
Constituent y
Result
% of limit
March 28
LRB
Selenium
81.9 u
96.4%
April 2
LRB
Selenium
85.4 ug/l
100.005%
April 9
LRB
Selenium
89.4 u l
105.2%
March 28
Ash basin
Selenium
23.0 ug/l
92%
Februai 15'
Ash basin
Selenium
19.2 ug/l
'Sampe taken before effective date of SOC but not considered in interim limit development.

Duke Energy has assembled personnel to quickly evaluate short-term measures
that can be implemented to address these items ahead of relocation of the outfall to
the Dan River. A detailed evaluation is underway. A detailed, daily process
sampling plan was implemented to more closely identify the source of elevated
selenium. Initial results from this evaluation have identified the FGD landfill
leachate as a contributor of the selenium load to the Lined retention basin.
Subsequently, this flow has been isolated and is not being discharged to the LRB
as of the date of this submittal. We are evaluating the potential to handle this flow
through some additional treatment in addition to limiting the flow through landfill
operational modifications as appropriate and possible. Additional smaller sources
are also being evaluated to identify and implement ways to further reduce the load
of selenium.

SOC application Section IV
Whv an SOC amendment is needed
An amendment to the SOC is needed to modify the Interim Action Level (IAL) for
total hardness and interim Iimits for selenium. The SOC provides a compliance
schedule for Duke Energy to redirect flows away from an unnamed tributary. In
the interim, the SOC provides alternate discharge limits and IALs that will allow
the plant to continue to operate while this redirection work is being conducted.
The IALs were set at a level that is more stringent than set in prior permits but that
would allow discharges in an acceptable range consistent with historical data.
Recent sampling data from the ash basin and Lined Retention Basin included with
this submittal demonstrates the existing total hardness is higher than the IAL
included in the SOC. Additionally, flows from the Lined retention basin — the
system built to replace the ash basin — will typically have lower flow rate than the
historic flow from the ash basin but higher total water hardness given the fact that
the Flue gas desulfurization (FGD) wastestream comprises a higher percentage of
the flow after the removal of ash sluice flows. The FGD system consists of
blowdown from a limestone slurry air emissions system required for air quality
compliance.
Water Hardness has no known health or environmental risks. In general, increased
water hardness levels decrease the bioavailability of hardness dependent metals.
The following information on water hardness is extracted from a "A Summary of
North Carolina Water Quality Standards 2007-2014"' published by the Forth
Carolina Department of Environmental and Natural Resources dated April 2015.
The calcium and magnesium ions that contribute to water hardness are known to lower
the toxicity of some metals by competing with the dissolved metal ions for binding sites
on an aquatic organism ........ The higher the water hardness (indicating more hardness
related ions are present) the lower the toxicity of some metals.

Duke Energy requests that IAL's and interim limits be re-evaluated based on the
data that has been gathered that was not utilized in the development of the interim
limits for the facility.
As discussed above, the startup of the new wastewater treatment system resulted in
higher than predicted selenium concentrations. A team has been assembled to
evaluate not only the source but short term and long-term mitigation needs. In
light of the immediate actions taken upon identifying this condition after system
startup, Duke requests that the interim limits be adjusted while we continue to
work to make progress on addressing both the short term and long term needs to
correct this initial condition.
Figure 1. Process control data from the ash basin showing historic water
hardness levels compared to the IAL
WM
900
EDO
700
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MS
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Table I. Potential Hardness calculated Vj
- seleWIN
Asti basin
LRB Inlet FGD WWT LRB Effluent Decanting
GPM 2,600 600 3,200 3,400
Hardness -
(Ppm) 616 13,400 3,013 936
ictions
tomingling of
LRB%Decanting
6,600
1,943
Table 2. Lined retention basin initial sampling results for total