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HomeMy WebLinkAboutNC0000396_Renewal Application_20230607ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Richard Brown Duke Energy Progress LLC 100 E Davie St Raleigh, NC 27603 Subject: Permit Renewal Application No. NC0000396 Asheville Steam Electric Power Plant Buncombe County Dear Permittee: NORTH CAROLINA Environmental Quality June 07, 2023 The Water Quality Permitting Section acknowledges the June 7, 2023 receipt of your permit renewal application and supporting documentation. Your application will be assigned to a permit writer within the Section's NPDES WW permitting branch. Per G.S. 150B-3 your current permit does not expire until permit decision on the application is made. Continuation of the current permit is contingent on timely and sufficient application for renewal of the current permit. The permit writer will contact you if additional information is required to complete your permit renewal. Please respond in a timely manner to requests for additional information necessary to allow a complete review of the application and renewal of the permit. Information regarding the status of your renewal application can be found online using the Department of Environmental Quality's Environmental Application Tracker at: https•//deq nc gov/permits-regulations/permit-guidance/environmental-application-tracker If you have any additional questions about the permit, please contact the primary reviewer of the application using the links available within the Application Tracker. ec: WQPS Laserfiche File w/application Sincerely Cynthia Demery Administrative Assistant Water Quality Permitting Section North Carolina Department of Environmental Quality I Division of Water Resources Asheville Regional Office 12090 US. Highway 70 1 Swannanoa, North Carolina 28778 d+� 828.2%.4500 (� DUKE ENERGY-, Fed Ex Tracking 772244132490 File 12520A/ENV-30-32 May 31, 2023 RECEIVED Keith Douthit Plant General Manager Asheville Combined Cycle Station Duke Energy Progress ASVL PLT 146 Duke Energy Lane Arden, NC 28704 o: 828-650-0620 f 828-650-0701 keith.douthit@duke-energy.com Dr. Sergei Chernikov NC Division of Water Resources JUN 0 7 2023 1617 Mail Services Center Raleigh, NC 27699-1617 NCDEQ/DWR/NPDES Subject: Duke Energy Progress, LLC Asheville Steam Electric Generating Plant (Asheville Combined Cycle Station) NPDES Permit No. NC0000396 Buncombe County Permit Renewal Application Dear Dr. Chernikov: Duke Energy Progress, LLC, (Duke) requests the subject permit be renewed and reissued. The above referenced permit expires on November 30, 2023. As required by North Carolina Administrative Code 15A NCAC 2H.0105(e), this permit renewal is being submitted at least 180 days prior to expiration of the current permit. The Asheville Plant has undergone numerous updates and transitions from the time the NPDES permit was renewed and reissued in 2018. The former coal fired plant has been demolished and removed, a new Combined Cycle Generating station with 2 combustion turbines, 2 steam turbines with direct draft cooling towers has been constructed and brought online, all ash basins have been excavated and closed out, and the excavated ash placed into an onsite lined landfill. As other former coal ash facilities, the Groundwater Corrective Action plan has been submitted to address legacy contamination at the site, and the final task of dam decommissioning will be complete within the next six (6) months. For this reason, we are requesting several updates to the existing permit. Please find enclosed the renewal application package (one original and two copies): • EPA Form 1 • EPA Form 2C • Site Map and Compliance Boundary showing the location of all outfalls • Line Flow chart and treatment technologies • Supplemental information with Outfall description of sources of pollution and treatment technologies • List of Process Chemicals • Water Quality Instream Monitoring • 316(b) Report • Fish Tissue Sampling • Ash Basin Closure and Corrective Action Plans Duke Energy Asheville Combined Cycle station NC0000396 NPDES Renewal Application Cover letter page 2 With reissuance, Duke requests the following modifications: • Revise Outfall 001 frequency and parameters • Revise Outfall 002 frequency and parameters • Remove Outfalls 001A, 001C • Remove Outfalls 004 and 005 • Remove Outfall 101 • Remove Instream monitoring and Fish Tissue Sampling Please see the supplement section at tab 1 for outfall description and details on the requested changes. Due to seasonality (typically May to October) of Outfall 002, no Form 2C data was able to be collected in April 2023. Once the seasonal discharge occurs and a representative sample can be collected, an Addendum with relevant Form 2C data for Outfall 002 will be submitted. Duke Energy requests notification or acknowledgement that this NPDES permit renewal application is complete. Should you have any questions regarding this submittal or require additional information, please contact Ms. Teresa Williams at (828) 650-0610 or Mr. Don Safrit at (984) 209-0940. 1 certify under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. 1 am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations Sincerely, Keith Douthit Plant General Manager Asheville Combined Cycle Station Enclosure: Renewal Application Package cc: Landon Davidson, Asheville Regional Office — NC DEQ DWR Fed Ex 772244195738 Eric Fleet, DWR Water Sciences Section Fed Ex 772252257543 Teresa Williams, Duke Energy —via email Don Safrit, P.E., Duke Energy - via email Duke Energy Progress, LLC Asheville Combined Cycle Station NPDES Permit #NC0000369 Renewal Application TABLE OF CONTENTS 1 SUPPLEMENTAL INFORMATION 1.1 Outfall request/descriptions 1.2 List of Process Chemicals 2 EPA FORM 1 2.1 Site Maps 2.2 Continuation sheet 3 EPA FORM 2C 3.1 Section 2 Line drawing 3.2 Section 3 Average Flows and Treatment 3.3 Section 9 Biological Toxicity Test 3.4 Section 10 Contract Analysis 4 INSTREAM MONITORING 5 316B REPORT 6 FISH TISSUE STUDY 7 UPDATED COMPLIANCE BOUNDARY A.(19.) 7.1 ASH BASIN CLOSURE 7.2 CORRECTIVE ACTION PLAN 7.3 SURFACE WATER MONITORING ii 1 Page 1 SUPPLEMENTAL INFORMATION SUPPLEMENTAL INFORMATION 1.1 Outfall Request/Descriptions Asheville Combined Cycle Station Supplemental Information NC0000396 Asheville Combined Cycle Station Supplemental Information NC0000396 Introduction and Background Duke Energy Progress, LLC. is submitting this supplemental information in support of the NPDES permit renewal package for the Asheville Combined Cycle Station (Plant). This submittal is intended to detail all the site changes since closure of the 1964 ash basin and demolition of the former coal fired steam plant. Supplemental information is also provided for the following: 1. A modified process flow to Outfall 001 with removal of the former ash basin 2. A request to reduce toxicity sampling and coal ash related constituents 3. A request to remove internal Outfalls 001A and 001C 4. A request to remove instream monitoring of outfall 001UP and 001DN 5. Discussion of thermal mixing zone study and a request to modify temperature monitoring 001E 6. A request to remove Outfalls 004 and 005 7. A request to remove Outfall 101 due to the ash basin closure 8. A request to clarify and modify requirements at Outfall 002 9. Compliance with CWA Section 316(b) In total, there will remain two final external outfalls to waters of the State: Outfalls 001 and 002. The process flows to Outfall 001 have changed and these changes have been documented with the NC DEQ DWR, NPDES regulatory permitting agency and DEMLR and as described below. There are clarifications to Outfall 002; specifically, that the outfall does not introduce heat from Evaporative cooling. To facilitate compliance with the NPDES permit, Form 1 general information & Form 2C tables, flow diagram, maps, and environmental reports for the renewal package are included in this application package. A review of other NC Combined Cycle facilities, with former Coal Ash, was conducted during preparation of this submittal. The most recent station, the Dan River Combined Cycle, NC0003468. For purposes of this NPDES permit renewal, NC DEQ DWR should be aware that leachate from the lined coal ash landfill discharges to the Metropolitan Sewerage District of Buncombe County (MSD Buncombe County) via a Permit to Discharge Treated Groundwater G-038-21. No aspects of the landfill leachate system discharge to surface waters or associated NPDES permit outfalls. Likewise, the majority of site industrial stormwater management is address via an individual industrial stormwater (ISW NPDES Permit No. NCS000575) issued by NC DEQ DEMLR. Outfalls 001 and 002 do contain industrial stormwater comingled with their discharges. The ISW is currently undergoing renewal and similar updates to reflect current post -coal site conditions. Thus, the Form 2F is not included in this application since it is being processed separately. Please also note the facility address change from 200 CP&L Drive, Arden, NC to 46 Duke Energy Lane, Arden, NC, 28704 Asheville Combined Cycle Station Supplemental Information NC0000396 Outfall 001 Previous Condition At Coal Plant shutdown, the wastewater from the rim ditch process and contact/interstial water in the 1964 basin was treated in the lined rim ditch system, then routed to the lined retention basin, then to physical chemical treatment and finally decanted to a settling pond outside of the 1964 Ash Basin. The settling pond serves as the monitoring point for Outfall 001 of the Plant's NPDES permit. Water discharge from this settling pond is routed directly to the French Broad River through the permitted outfall. Flows from the new Combined Cycle comingled at the settling pond. After Coal Plant shutdown, it became apparent the settling pond was oversized for future flows when only the Combined Cycle station remained. The Combined Cycle did not require additional treatment and the station began designing a modification to the pond. This modification is to occur in 2023. Removal of the 1964 Ash Basin and post closure flows Ash removal in the 1964 Ash Basin began prior to Coal Plant Shutdown and was required by the Mountain Energy Act to be completely removed by August of 2022. In 2020, an onsite landfill was constructed to store the remaining coal ash. Leachate from the now closed landfill is discharged to Metropolitan Sewage District of Buncombe County (MSD). As ash removal progressed, a modification to discharge flows from the 1964 basin to outfall 101 was made in 2022. These flows would include surfaced groundwater and non -industrial stormwater once the 1964 dam was breached. As the surfaced groundwater was separated from remaining ash, sampling revealed that it should be directed and monitoring with outfall 001 (as it currently was being done), rather than be discharged toward outfall 101. Underdrains were constructed within the 1964 basin with a wet well that will direct pumping to outfall 001 in the near future. Treatment for pH will be employed as needed. Only non -industrial stormwater will flow from the former ash basin once stabilization and dam decommissioning is completed, where outfall 101 currently exists. Outfall 001— Current/Future state of Combined Cycle Station operation Outfall 001 will be compromised of approximately 95% Cooling tower blowdown with remaining volumes coming from 1964 underdrains and stormwater from fuel unloading containments processed through an oil water separator. The Combined Cycle process uses raw water from Lake Julian that is put through an ultrafiltration (UF) process before being stored in the service water tanks. There are internal processes in place to reuse water within the cooling towers. These are described as follows. The OF backwash is collected in a sump and then pumped into the cooling tower basin for re -use in the condenser circulating water system. Some of this water will be present in the cooling tower blowdown. Demineralized water for Heat Recovery Steam Generator (HRSG) makeup and Combustion Turbine Generator (CTG) operation is put through a Reverse Osmosis (RO) process, which has a reject flow that is collected in the OF backwash sump and then pumped into the cooling tower basin. Both the OF and RO share a common clean -in -place (CIP) system. The chemical solution waste from the CIP system is discharged to the Neutralization tank. Neutralization waste is discharged in the OF backwash sump and then pumped to the cooling tower basin. Asheville Combined Cycle Station Supplemental Information NC0000396 The cooling towers dissipate waste heat through evaporation and the concentration of dissolved solids is controlled via blowdown to the common wastewater collection sump. The cooling towers will be treated with dispersant, corrosion inhibitor, and sodium hypochlorite. Each cooling tower utilizes side stream filters to limit the accumulation of solids in the basin. Cooling tower blowdown, 3% of Circulating Water System, is treated with sodium bisulfite for residual chlorine removal. HRSG Blowdown is routed to the cooling tower for re -use in the condenser circulating water system. Cycles of concentration range from 5 to 10, depending on condition, with reuse of plant process as much as possible. Various plant equipment, including fuel oil storage tanks, transformers, etc., requires containment areas for spills. Storm water collected in these areas is visually inspected for the presence of oil and is either released through the storm drains system or routed through the plant drains to an oil water separator. The discharge from the oil water separators is recycled back into Circulating Water via Side Stream filter backwash sump. Domestic wastes are connected to an on -site lift station and pumped into the MSD sewer system permitted by WQ0039618 — NC DEQ Wastewater (sewer) Extension Permit. The cooling towers blowdown is sent to a wastewater collection sump where it is then pumped to the existing manhole #1. Which is located north of the station. Manhole #1 flows to outfall 001 settling pond where this flow combines with surfaced groundwater from the former 1964 basin. The settling pond (Outfall 001) is currently undergoing a modification to accommodate the reduction in flows from the completion of the ash pond decommissioning projects and also account for the lower flows from the Combined Cycle station. Requested revisions to Outfall 001 due to removal of Coal Ash Frequency of sampling be reduced to Monthly. The following parameters and limits be removed: Mercury, Arsenic, Selenium, Beryllium, Cadmium, Chromium, Copper, Fluoride, Lead, Nickel, Silver, Zinc, Bromides, TDS, Hardness and Conductivity. Condition A.8 and Note 4 Chronic Toxicity frequency be reduced to quarterly sampling. Remove Note 5, 6, and 7 with removal of coal ash discharge. 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. Therefore, if the effluent measurement exceeds 50 NTU, the Permittee shall sample upstream and downstream turbidity in the receiving waterbody, within 24 hours, to demonstrate the existing turbidity level in the receiving waterbody was not increased. All data shall be reported on the DMRs. (See 15A NCAC 28.0211 (21)). The facility shall continuously monitor TSS concentration, and the dewatering pump shall be shutoff automatically when one-half of the Daily Maximum limit (15 minutes average) is exceeded. Asheville Combined Cycle Station Supplemental Information NC0000396 Pumping will be allowed to continue if interruption might result in a dam failure or damage. The continuous TSS monitoring is only required when the pumps are employed for dewatering. The facility shall continuously monitor pH and the dewatering pump shall be shutoff automatically when 15 minutes running average pH falls below 6.1 standard units or rises above 8.9 standard units. Pumping will be allowed to continue if interruption might result in a dam failure or damage. The continuous pH monitoring is only required when the pumps are employed for dewatering. Remove additional notes from Outfall 001 with removal of coal ash discharge: If any one of these pollutants (As, Se, Hg, Ni, and Pb) reaches 85% of the allowable monthly average effluent discharge concentration during dewatering, the facility shall immediately discontinue discharge of the wastewater and report the event to the DWR Asheville Regional Office and DWR Complex NPDES Permitting via telephone and e-mail. The rate for lowering the liquid level in a coal ash pond shall not exceed one (1) foot per day unless a higher rate is supported to the satisfaction of DEMLR and in accordance with NCAC, Title 15A, Subchapter 2K. By January 31, 2020, there shall be no discharge of pollutants in fly ash transport water. This requirement only applies to fly ash transport water generated after January 31, 2020. By January 31, 2020, there shall be no discharge of pollutants in bottom ash transport water. This requirement only applies to bottom ash transport water generated after January 31, 2020. The facility shall treat the wastewater discharged from the ash pond using physical -chemical treatment, if necessary, to assure state Water Quality Standards are not contravened in the receiving stream. Duke Energy shall notify DWR Complex NPDES Permitting and DWR Asheville Regional Office, in writing, within seven calendar days of installing additional physical -chemical treatment at this Outfall. Thermal Mixing Zone Study and Outfall 001E A thermal mixing zone study was completed for the Asheville Steam Electric Plant for Outfall 001 in 2018 prior to the Combined Cycle coming online. For the duration of the existing permit until this application, the flows from the combined cycle are combined with ash pond decommissioning contact flows and the current "combined cycle only" condition is representative of the future. Based on the elimination of Special Condition A.(12.), Duke requests modification of the current instream thermal mixing zone NPDES permit for Outfall 001 (Note 8)/Outfall 001E: The facility shall not exceed the instream water temperature of 29 C at the location approximately 41 meters downstream of Outfall 001 and at the location approximately 8 meters from Outfall on the tronsect across the river. The facility shall not exceed 2.8 C rise above the background temperature, the difference will be determined between a t4e- upstreGP9 location upstream of Outfall 001 i.4and the downstream location 41 meters downstream of Outfall 001. Asheville Combined Cycle Station Supplemental Information NC0000396 These recommended edits may be temporary, as Duke Energy is interested in receiving a temperature limit established only at the representative point of discharge as a monthly grab sample. There are safety concerns associated with our current instream monitoring location. We plan to develop a revised thermal mixing zone model and will submit such results and recommendations soon. Once the revised mixing zone request is approved by DWR and the Outfall 001 temperature limit and monitoring location has been set, the condition above may be removed from the permit. Removal of Internal Outfall 001A and 001C Flow to outfall 001 is primarily made up of cooling tower blowdown. Therefore, since the two upstream cooling tower blowdown internal outfalls 001A and 001C are similar and their waste streams will be monitored at outfall 001, it is requested that these two internal outfalls be removed from the permit. Part I A. (6) Internal Outfoll 001A — Cooling Tower blowdown and HRSG blowdown 1. Remove since no longer applicable/needed captured at outfall 001 Part IA. (7) Internal Outfall 001C— Cooling Tower blowdown and HRSG blowdown 1. Remove since no longer applicable/needed captured at outfall 001 Removal of Outfall 001 Upstream and 001 Downstream Remove Condition A. (12.) Instream Monitoring since the site has completely transitioning from a coal- fired facility to a coal -free combustion turbine site. Note — The Instream Monitoring Report for the previous review timeframe is included in tab 4. Removal of Outfall 004 & 005 With shutdown and demolition of the former Coal Plant, internal Outfalls 004 & 005 will no longer be needed or exist. Please remove the following reference from the permit. Part I A. (3) Internal Outfall 004 — Chemical Metal Cleaning Treatment System 2. Remove since no longer applicable/needed. Part I A. (4) Internal Outfall 005 — Treated FGD Wet Scrubber Wastewater 2. Remove since no longer applicable/needed. Clarifications for Outfall 002 Part I A. (2) Outfall 002 — Evaporator System Discharge — request change name to Evaporative to match system description. Request Outfall 002 be modified as follows: Temperature limit of 44.4 C can be removed. Since the evaporative cooling system does not generate a heat load to the receiving stream, Duke Energy requests temperature be removed from the Outfall 002. The process description should use "Evaporative" as opposed to "Evaporator". The Evaporative Cooling system cools air entering the inlet filter house. The cooler air in warmer months allows for more complete combustion within the Combustion Turbine unit. The service water blows down to add fresh service water based on conductivity. No chemicals or other processes are introduced. Asheville Combined Cycle Station Supplemental Information NC0000396 Outfall 002 also combines industrial stormwater at its discharge. This stormwater is not included in the individual stormwater permit (NCS000575) because it also contains industrial process water. Remove Total Chromium and Total Copper— Non Detected for entire permitted period. Remove mixing zone defined as all of Lake Julian — No thermal influence. (Note: due to seasonality (typically May to October) of Outfall 002, no Form 2C data was able to be collected in April 2023. Once the seasonal discharge occurs and a representative sample can be collected, an Addendum with relevant Form 2C data for Outfall 002 will be submitted.) Removal of Outfall 101 Part I A. (5) Outfall 101— Toe Drain Effluent - Remove since no longer applicable/needed. With Clean Closure of the 1964 Ash Basin, the process source of pollution has been removed. Legacy groundwater contamination is address in the Corrective Action Plan, and Surface Water Assessment Plan in compliance with CAMA rules. Surfaced groundwater within the 1964 basin continues to be pumped to outfall 001. See tab 7 for Ash Basin Closure documentation. CWA Section 316(b) Modify Condition A. (10.) Clean Water Act Section 316(b). The 316(b) submittal is included in tab 5. Once deemed acceptable by NC DEQ DWR, Duke would appreciate acknowledgement of such via issuance of the renewed permit with the following (or similar) statement: Based on evaluation of the 316(b) study reports, the Department concludes that the existing configuration at Asheville represents BTA for meeting the impingement and entrainment requirements of the Rule. The permittee shall submit the appropriate study reports with the renewal application for this permit. The permittee shall comply with the Cooling Water Intake Structure Rule per 40 CFR 125.95. Remaining Requested changes to existing permit conditions not addressed above: Remove Condition A. (9.) Clean Water Act Section 316(a) Thermal Variance since it is no longer needed for any of the discharges associated with the Asheville Plant. Remove Condition A. (11) Structural Integrity Inspections of Ash Pond Dam since excavation of the ash ponds was completed in accordance with the North Carolina Coal Ash Management Act (CAMA) of 2014, HB 630 of 2016, and the Senate Bill 716; Mountain Energy Act of 2015. Breaching of the dam is underway and will be completed within the next six months. Following such activities, the dam will no longer be subject to NC DEQ DEMLR oversight since the structure will no longer be considered a dam and exempt from the Dam Safety Law of 1967. Remove Condition A. (15) Fish Tissue Monitoring Near Ash Pond Discharge since the site will be completely transitioning from a coal-fired facility to a coal -free combustion turbine site in the next several months. Note — The Fish Tissue Monitoring Report for the previous review timeframe is included as tab 6. SUPPLEMENTAL INFORMATION 1.2 List of Process Chemicals Supplemental information 1.2 List of Process Chemicals Chemical Average stored Location Frequency Purpose Quantity AMMONIUM 24,000 gal. Ammonia Storage Nox Emission control HYDROXIDE 19% 400 gal. (2) Tanks As needed Boiler pH control PB1 & P62 Turbine Oxygen scavenger Building SULFURIC ACID 93% 400 gal. ACC Water Treatment OF cleaning Building As needed SODIUM HYDROXIDE 400 gal. ACC Water Treatment pH control 25% Building As needed 3D TRASAR 3DT487- 800 gal. ACC Water Treatment Inhibitor and dispersant (Phosphoric Acid) Building Outside As needed NALCO 7408- Sodium 800 gal. ACC Water Treatment Dechlorination Bisulfite Building As needed SODIUM 400 gal. ACC Water Treatment Disinfection HYPOCHLORITE Building As needed 12.5% AFFF - FIRE 1,200 gallons ACC Fuel Unloading Emergency Response SUPPRESSION FOAM As needed NALCO BT-3000 800 gallons Boiler Feed Pump As needed Boiler pH control Building Eliminox 55 gallons Auxiliary Boiler As needed Oxygen scavenger Permatreat PC-191 T 400 gallons ACC Water Treatment As needed Anti-scalent for RO Building System Citric Acid 50% 400 ACC Water Treatment As needed OF cleaning Building Nalco 8158 200 ACC Water Treatment As needed coagulant Building Cat -floc 8103 2500 ACC Water Treatment As Needed coagulant Building 2 EPA FORM 1 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 OMB No. 2040-0004 NC0000396 NC0000396 Asheville Combined Cycle U.S. Environmental Protection Agency Form \=.EPA Application for NPDES Permit to Discharge Wastewater NPDES GENERAL INFORMATION SECTION• 'D Applicants Not Required to Submit Form 1 1.1 Is the facility a new or existing publicly owned 1.1.2 Is the facility a new or existing treatment works 1.1.1 treatment works? treating domestic sewage? If yes, STOP. Do NOT complete © No If yes, STOP. Do NOT © No Form 1. Complete Form 2A. complete Form 1. Complete Form 2S. 1.2 Applicants Required to Submit Form 1 .= 1.2.1 Is the facility a concentrated animal feeding 1.2.2 Is the facility an existing manufacturing, operation or a concentrated aquatic animal commercial, mining, or silvicultural facility that is a production facility? currently discharging process wastewater? oYes 4 Complete Form 1 No Yes 4 Complete Form ❑ No a and Form 2B. 1 and Form 2C. r- 1.2.3 Is the facility a new manufacturing, commercial, 1.2.4 Is the facility a new or existing manufacturing, mining, or silvicultural facility that has not yet commercial, mining, or silvicultural facility that commenced to discharge? discharges only nonprocess wastewater? Yes -+ Complete Form 1 No ❑ Yes 4 Complete Form �✓ No and Form 2D. 1 and Form 2E. U) CD 1.2.5 Is the facility a new or existing facility whose discharge is composed entirely of stormwater Q associated with industrial activity or whose discharge is composed of both stormwater and non-stormwater? Yes -* Complete Form 1 No and Form 2F unless exempted by 40 CFR 122.26(b)(14)(x) or SECTION D.- • • i Facility Name 2.1 Asheville Combined Cycle Station (formerly known as Asheville Steam Electric Plant) 0 2.2 EPA Identification Number 0 v 0 2.3 Facility Contact Name (first and last) Title Phone number a Keith Douthit GMII Regulated Stations (828) 650-0620 Q rn Email address .E- keith.douthit@duke-energy.com d 2.4 Facility Mailing Address W Street or P.O. box z 46 Duke Energy Ln City or town State ZIP code Arden NC 28704 EPA Form 3510-1 (revised 3-19) Page 1 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 NC0000396 NC0000396 Asheville Combined Cycle OMB No, 2040-0004 N 2.5 Facility Location Street, route number, or other specific identifier Q 0 46 Duke Energy Ln rn 0 County name County code (if known) Buncombe E _j City or town State ZIP code z Arden NC 28704 9D-ECTION 3. SIC AND NAICS CODES Description (optional) 3.1 SIC Code(s) 4911 Electric Services y m 0 U U U z 3.2 NAICS Codes) Description (optional) -a 221112 Fossil Fuel Electric Power Generation U Name of Operator 4.1 Duke Energy Progress, LLC 0 4.2 Is the name you listed in Item 4.1 also the owner? Cz 0 ❑✓ Yes ❑ No 0 w Z 4.3 Operator Status R ❑ Public —federal ❑ Public —state ❑ Other public (specify) o ❑✓ Private ❑ Other (specify) 4.4 Phone Number of Operator (828)650-0620 4.5 Operator Address Street or P.O. Box E 46 Duke Energy Lane City or town State ZIP code 0 U Arden NC 28704 a Q Email address of operator 0 keith.douthit@duke-energy.com SECTION1 5.1 Is the facility located on Indian Land? J ❑ Yes ❑ No EPA Form 3510-1 (revised 3-19) Page 2 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 NC0000396 NC0000396 Asheville Combined Cycle OMB No.2040-0004 0 _?ECTION 6. EXISTING ENVIRONMENTAL1 5 6.1 Existing Environmental Permits (check all that apply and print or type the corresponding permit number for each) Q) ❑ NPDES (discharges to surface ❑ RCRA (hazardous wastes) ❑ UIC (underground injection of r_ water) fluids) r NC0000396 NCD000830638 = E w o ❑✓ PSD (air emissions) ❑ Nonattainment program (CAA) ❑ NESHAPs (CAA) 11-628-22A Asheville -Buncombe AQA w El Ocean dumping (MPRSA) ❑ Dredge or fill (CWA Section 404) ❑✓ Other (specify) See Attachment 7.1 Have you attached a topographic map containing all required information to this application? (See instructions for M specific requirements.) M ❑✓ Yes ❑ No ❑ CAFO—Not Applicable (See requirements in Form 2B.) U) m c ca 7 m w O N 7 w Z 8.1 Describe the nature of your business. The Asheville Combined Cycle Station is an electric generating facility consisting of two simple cycle combustion turbines and two combined cycle combustion turbines 9.1 1 Does your facility use cooling water? L d ❑✓ Yes ❑ No -+ SKIP to Item 10.1. 9.2 Identify the source of cooling water. (Note that facilities that use a cooling water intake structure as described at o, w 40 CFR 125, Subparts I and J may have additional application requirements at 40 CFR 122.21(r). Consult with your '7' NPDES permitting authority to determine what specific information needs to be submitted and when.) 0 -he V c Lake Julian / French Broad River 10.1 Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(m)? (Check all that apply. Consult with your NPDES permitting authority to determine what information needs to be submitted and when.) d ❑ Fundamentally different factors (CWA ❑ Water quality related effluent limitations (CWA Section Section 301(n)) 302(b)(2)) ❑ Non -conventional pollutants (CWA ❑ Thermal discharges (CWA Section 316(a)) Section 301(c) and (g)) ❑✓ Not applicable EPA Form 3510-1 (revised 3-19) Page 3 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 OMB No. 2040-0004 NC0000396 NC0000396 Asheville Combined Cycle Station SECTION• 1 In Column 1 below, mark the sections of Form 1 that you have completed and are submitting with your application. 11.1 For each section, specify in Column 2 any attachments that you are enclosing to alert the permitting authority. Note that not all applicants are required to provide attachments. Column 1 Column 2 ❑✓ Section 1: Activities Requiring an NPDES Permit ❑ w/ attachments ❑✓ Section 2: Name, Mailing Address, and Location ❑ w/ attachments ❑✓ Section 3: SIC Codes ❑ wl attachments ❑✓ Section 4: Operator Information ❑ w/ attachments ❑ Section 5: Indian Land ❑ w/ attachments .. ❑✓ Section 6: Existing Environmental Permits ❑✓ w/ attachments ❑✓ Section 7: Map ❑✓ watopographic El w/ additional attachments mp co o ❑✓ Section 8: Nature of Business ❑ w/ attachments ❑✓ Section 9: Cooling Water Intake Structures ❑✓ w/ attachments ❑ Section 10: Variance Requests ❑ w/ attachments v c Mn❑✓ Section 11: Checklist and Certification Statement ❑ w/ attachments Y d 11.2 Certification Statement U I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. 1 am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Name (print or type first and last name) Official title Keith Douthit GM II Regulated Stations Signature Date signed EPA Form 3510-1 (revised 3-19) Page 4 EPA Form 1 2.1 Site Map Outfall 001, Subbasin: 04-03-02 Latitude:35°28'03" Longitude:82°32'W -receiving Stream: French Broad River, Class B ►utfall 002, Subbasin: 04-03-02 Latitude: 35°28'10" Longitude: 82°32'20" Receiving Stream: Lake Julian, Class C Facility Location NC0000396 - Asheville Steam Electric Gen. Plant Buncombe County x NPDES OUT:F Rol 1 �41vKo • O� ol alp e + �t r , _► , LEGEND ♦ NPDES OUTFALL LOCATION (APPROXIMATE) 1964ASH BASIN WASTE BOUNDARY e • 1982 ASH BASIN WASTE BOUNDARY + r COMPLIANCE BOUNDARY DUKE ENERGY PROGRESS PROPERTY LINE _�'. `- • STREAM AND FLOW DIRECTION (TWT 2016) HOvr R ' . WETLAND (TWT 2016) �► ; : r. FORMER FLUE GAS DESULFURIZATION (FGD) WETLANDS SURFACE WATER FLOW DIRECTION NOTES: 1. THE DEPICTED STREAMS AND WETLANDS DATA WERE APPROVED BY THE US ARMY CORPS OF ENGINEERS (USACE) ON MAY 19, 2016 - JURISDICTIONAL DETERMINATION SAW-2014-00189. TAYLOR WISEMAN AND TAYLOR (TWT) PERFORMED THE SURVEY OF THE FEATURES. ? 2. ALL BOUNDARIES ARE APPROXIMATE. + 3. PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY PROGRESS, L-C. -i;�' �! •b• e, : 4. AERIAL IMAGERY OF THE FORMER 1964 BASIN FROM DUKE ENERGY VIA r PROPELLER, COLLECTED APRIL 24, 2023. SURROUNDING AERIAL IMAGERY OBTAINED FROM GOOGLE EARTH PRO, COLLECTED JANUARY 28, 2021. 5. DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE PLANE COORDINATE SYSTEM FIPS 3200 (NAD83). FIGURE 1 p SITE LAYOUT MAP ASHEVILLE STEAM ELECTRIC PLANT i,4 ARDEN, NORTH CAROLINA EPA Form 1 2.2 Continuation Sheet from section 6.1 Existing Environmental Permits 1. WQ0039618 - NC DEQ Wastewater (sewer) Extension Permit 2. STW2016-00040 - Buncombe County Stormwater Permit 3. USACOE SAW-2007-04111 NW12 - Drought condition French Broad River withdrawal permit 4. NC DEQ Water Withdrawal Authorizations 0033-0002 and 0033-0016 3 EPA FORM 2C EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 NC0000396 NC0000396 Asheville Combined Cycle Station OMB No. 2040-0004 Form U.S. Environmental Protection Agency ZC \—/EPA Application for NPDES Permit to Discharge Wastewater NPDES EXISTING MANUFACTURING, COMMERCIAL, MINING, AND SILVICULTURE OPERATIONS SECTIO 1. OUTFALL LOCATION 1.1 Provide information on each of the facility's outfalls in the table below. Outfa ° Nu ber Receiving Water Name Latitude Longitude 0 001 French Broad River 35` 28' 03" 82° 32' 56" J W 4! 002 Lake Julian 35' 28' 10 82' 32' 20" 0 0 SECTION a, 2.1 Have you attached a line drawing to this application that shows the water flow through your facility with a water 3 balance? (See instructions for drawing requirements. See Exhibit 2C-1 at end of instructions for example.) Cc o ❑✓ Yes ❑ No SECTION• 3.1 For each outfall identified under Item 1.1, provide average flow and treatment information. Add additional sheets if necessary. **Outfall Number** 001 Operations Operation Average Flow Cooling Tower Blowdown 0.677 mgd CD E 1964 Basin Under drain System 0.029 mgd cc w mgd -o cc y mgd 3 0 Treatment Units U- d Description Code from Final Disposal of Solid or (include size, flow rate through each treatment unit, Table 2C-1 Liquid Wastes Other Than a' retention time, etc.) b Discharge Dechlorination 2-E Landfill Discharge to Surface Water 4-A EPA Form 3510-2C (Revised 3-19) Page 1 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 NC0000396 NC0000396 Asheville Combined Cycle Station OMB No. 2040-0004 3.1 **Outfall Number** 002 Cont. Operations Contributing to Flow Operation Average Flow Evaporative Cooling Water 0.08 mgd mgd mgd mgd Treatment Description Units Code from Final Disposal of Solid or (include size, flow rate through each treatment unit, Table 2C-1 Liquid Wastes Other Than retention time, etc.) by Discharge Discharge to Surface Water 4-A NA c c 0 U Y i QCi G Y a> **Outfall Number** Operations Contributing to Flow 0 Operation Average Flow U- mgd R a mgd mgd mgd Treatment Description Units Code from Final Disposal of Solid or (include size, flow rate through each treatment unit, Table 2C-1 Liquid Wastes Other Than retention time, etc.) by Dischar e 3.2 Are you applying for an NPDES permit to operate a privately owned treatment works? E ❑ Yes ❑✓ No 4 SKIP to Section 4. n 3.3 Have you attached a list that identifies each user of the treatment works? ❑ Yes ❑ No EPA Form 3510-2C (Revised 3-19) Page 2 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 NC0000396 NC0000396 Asheville Combined Cycle Station OMB No.2040-0004 SECTION• 1 4.1 Except for storm runoff, leaks, or spills, are any discharges described in Sections 1 and 3 intermittent or seasonal? ❑✓ Yes ❑ No 4 SKIP to Section 5. 4.2 Provide information on intermittent or seasonal flows for each applicable outfall. Attach additional pages, if n cessary. Freq uency Flow Rate Outfall Operation Duration Average Average Long -Term Maximum Number (list) Days/Week Months/Year Average Dail Evaporative Cooling 5-7 days/week 5 months/year 0.080 mgd 0.161 mgd 150 days y 002 days/week months/year mgd mgd days c LL days/week monthslyear mgd mgd days days/week monthslyear mgd mgd days a`> days/week monthslyear mgd mgd days c days/week monthslyear mgd mgd days days/week monthslyear mgd mgd days days/week monthslyear mgd mgd days days/week months/year mgd mgd days SECTION•••• • 1 Do any effluent limitation guidelines (ELGs) promulgated by EPA under Section 304 of the CWA apply to your facility? 5.1 ❑✓ Yes ❑ No 4 SKIP to Section 6. y 5.2 Provide the following information on applicable ELGs. i ELG Category ELG Subcategory Regulatory Citation w m M Steam Electric Steam Electric Power Industry 40 CFR 423 cc Qc2 n Q 5.3 Are any of the applicable ELGs expressed in terms of production (or other measure of operation)? ❑ Yes ❑✓ No 4 SKIP to Section 6. 0 22 5.4 Provide an actual measure of daily production expressed in terms and units of applicable ELGs. j Outfall Operation, Product, or Material Quantity per Day Unit of Measure Number d Uf R m C O w t) 7 O a EPA Form 3510-2C (Revised 3-19) Page 3 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 NC0000396 NC0000396 Asheville Combined Cycle Station OMB No. 2040-0004 SECTION-• 1 6.1 Are you presently required by any federal, state, or local authority to meet an implementation schedule for constructing, upgrading, or operating wastewater treatment equipment or practices or any other environmental programs that could affect the discharges described in this application? ❑ Yes ❑✓ No 4 SKIP to Item 6.3. 6.2 Brieflyidentifyeach applicable project in the table below. a Affected Final Compliance Dates E Brief Identification and Description of Outfalls Source(s) of c Project (list outfall Discharge Required Projected n number E y d "8 W L CL a you attached sheets describing any additional water pollution control programs (or other environmental projects Lve t may affect your discharges) that you now have underway or planned? (optional item) Yes ❑ No ❑✓ Not applicable SECTION See the instructions to determine the pollutants and parameters you are required to monitor and, in turn, the tables you must complete. Not all applicants need to complete each table. Table A. Conventional and Non -Conventional Pollutants 7.1 Are you requesting a waiver from your NPDES permitting authority for one or more of the Table A pollutants for any of your outfalls? ❑ Yes ❑✓ No 4 SKIP to Item 7.3. 7.2 If yes, indicate the applicable outfalls below. Attach waiver request and other required information to the application. Outfall Number Outfall Number Outfall Number 7.3 Have you completed monitoring for all Table A pollutants at each of your outfalls for which a waiver has not been e requested and attached the results to this application package? 0 No; a waiver has been requested from my NPDES ✓❑ Yes ❑permitting authority for all pollutants at all outfalls. Table B. Toxic Metals, Cyanide, Total Phenols, and Organic Toxic Pollutants 7.4 Do any of the facility's processes that contribute wastewater fall into one or more of the primary industry categories listed in Exhibit 2C-3? (See end of instructions for exhibit.) ❑✓ Yes ❑ No 4 SKIP to Item 7.8. 3 7.5 Have you checked "Testing Required" for all toxic metals, cyanide, and total phenols in Section 1 of Table B? w ✓❑ Yes ❑ No 7.6 List the applicable primary industry categories and check the boxes indicating the required GC/MS fraction(s) identified in Exhibit 2C-3. Required GC/MS Fraction(s) Primary Industry Category Check applicable boxes. Steam Electric 0 Volatile 121 Acid ❑ Base/Neutral ❑ Pesticide ❑ Volatile ❑ Acid ❑ Base/Neutral ❑ Pesticide ❑ Volatile ❑ Acid ❑ Base/Neutral ❑ Pesticide EPA Form 3510-2C (Revised 3-19) Page 4 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 NC0000396 NC0000396 Asheville Combined Cycle Station OMB No. 2040-0004 7.7 Have you checked "Testing Required" for all required pollutants in Sections 2 through 5 of Table B for each of the GC/MS fractions checked in Item 7.6? ❑✓ Yes ❑ No 7.8 Have you checked "Believed Present" or "Believed Absent' for all pollutants listed in Sections 1 through 5 of Table B where testing is not required? ✓❑ Yes ❑ No 7.9 Have you provided (1) quantitative data for those Section 1, Table B, pollutants for which you have indicated testing is required or (2) quantitative data or other required information for those Section 1, Table B, pollutants that you have indicated are "Believed Present' in your discharge? ✓❑ Yes ❑ No 7.10 Does the applicant qualify for a small business exemption under the criteria specified in the instructions? ❑ Yes 4 Note that you qualify at the top of Table B, ❑✓ No then SKIP to Item 7.12. = 7.11 Have you provided (1) quantitative data for those Sections 2 through 5, Table B, pollutants for which you have 0 determined testing is required or (2) quantitative data or an explanation for those Sections 2 through 5, Table B, pollutants you have indicated are "Believed Present' in your discharge? y `—' ✓❑ Yes ❑ No 4; Table C. Certain Conventional and Non -Conventional Pollutants V3 7.12 Have you indicated whether pollutants are 'Believed Present' or "Believed Absent' for all pollutants listed on Table C for all outfalls? U Y ❑✓ Yes ❑ No 7.13 Have you completed Table C by providing (1) quantitative data for those pollutants that are limited either directly or indirectly in an ELG and/or (2) quantitative data or an explanation for those pollutants for which you have indicated `Believed Present'? ❑✓ Yes ❑ No W Table D. Certain Hazardous Substances and Asbestos 7.14 Have you indicated whether pollutants are 'Believed Present' or "Believed Absent' for all pollutants listed in Table D for all outfalls? ✓❑ Yes ❑ No 7.15 Have you completed Table D by (1) describing the reasons the applicable pollutants are expected to be discharged and (2) by providing quantitative data, if available? Q Yes ❑ No Table E. 2,3,7,8-Tetrachlorodibenzo- -Dioxin 2,3,7,8-TCDD 7.16 Does the facility use or manufacture one or more of the 2,3,7,8-TCDD congeners listed in the instructions, or do you know or have reason to believe that TCDD is or may be present in the effluent? ❑ Yes -+ Complete Table E. ❑ No 4 SKIP to Section 8. 7.17 Have you completed Table E by reporting qualitative data for TCDD? ❑ Yes ❑ No SECTIONOR MANUFACTURED TOXICSi 8.1 Is any pollutant listed in Table B a substance or a component of a substance used or manufactured at your facility as an intermediate or final product or byproduct? w ❑ Yes ❑✓ No 4 SKIP to Section 9. ! U) 8.2 List the pollutants below. L 1. 4. 7. 0 m y 2. 5. 8. 3. 6. 9. EPA Form 3510-2C (Revised 3-19) Page 5 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 NC0000396 NC0000396 Asheville Combined Cycle Station OMB No. 2040-0004 MCTION 9. BIOLOGICAL• I 9.1 Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made within the last three years on (1) any of your discharges or (2) on a receiving water in relation to your discharge? ❑✓ Yes ❑ No -+ SKIP to Section 10. U) .r N 9.2 Identify the tests and their ourposes below. ' Test(s) Purpose of Test(s) Submitted to NPDES Date Submitted x Permitting Authority? 0 See Attachment ✓❑ Yes ❑ No U M O O ca ❑ Yes ❑ No ❑ Yes ❑ No �',ECTION 10. CONTRACT ANALYSES (40 10.1 Were any of the analyses reported in Section 7 performed by a contract laboratory or consulting firm? ❑✓ Yes ❑ No 4 SKIP to Section 11. 10.2 Provide information for each contract laboratory or consulting firm below. Laboratory Number 1 Laboratory Number 2 Laboratory Number 3 Name of laboratory/firm See Attachment Laboratory address a w U f0 Y 0 Phone number Pollutant(s) analyzed SECTIOND• • •- • r 11.1 Has the NPDES permitting authority requested additional information? ❑ Yes ✓❑ No 4 SKIP to Section 12. 0 E 11.2 List the information requested and attach it to this application. 0 c 1. 4. co a 0 2. 5. -a a 3. 6, EPA Form 3510-2C (Revised 3-19) Page 6 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 NC0000396 NC0000396 Asheville Combined Cycle Station OMB No.2040-0004 SECTIONI CERTIFICATION STATEMENT (40 In Column 1 below, mark the sections of Form 2C that you have completed and are submitting with your application. 12.1 For each section, specify in Column 2 any attachments that you are enclosing to alert the permitting authority. Note that not all applicants are required to com lete all sections or provide attachments. Column 1 Column 2 ✓❑ Section 1: Outfall Location ❑✓ wl attachments ❑✓ Section 2: Line Drawing ✓❑ wl line drawing ✓❑ w/ additional attachments Section 3: Average Flows and w/ list of each user of ❑✓ w/ attachments ❑ privately owned treatment Treatment works ❑✓ Section 4: Intermittent Flows ❑ w/ attachments ❑ Section 5: Production ❑ w/ attachments w/ optional additional ❑ Section 6: Improvements ❑ wl attachments ❑ sheets describing any additional pollution control tans ❑ w/ request for a waiver and ❑ w/ explanation for identical supporting information outfalls d wl small business exemption wl other attachments ❑ ❑ d request ❑ Section 7: Effluent and Intake ❑✓ w/ Table A ❑✓ wl Table B = Characteristics cc ❑✓ w/ Table C ❑✓ wl Table D :c d wl Table E w/ analytical results as an ❑ ❑ Q attachment ❑ Section 8: Used or Manufactured ❑ w/attachments y Toxics ❑ Section 9: Biological Toxicity ✓❑ w/ attachments Tests c� ❑✓ Section 10: Contract Analyses ✓❑ wl attachments ❑ Section 11: Additional Information ❑ w/ attachments Section 12: Checklist and ❑ w/ attachments Certification Statement 12.2 Certification Statement I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Name (print or type first and last name) Official title Keith Douthit GM II Regulated Stations Signature Date signed EPA Form 3510-2C (Revised 3-19) Page 7 This page intentionally left blank. EPA Identificatior fiber NPDES Perr amber acility Name NC0000396 NC0000396 Asheville 7 Waiver Requested (if applicable) Units (specify) Effluent Intake (optional) Pollutant Maximum Dail Y Discharge (required) Maximum Monthly Y Discharge (if available) Lon Term Average Dail 9 Y Discharge (if available) Number of Analyses Long Term Average Value Number of Analyses ❑ Check here if you have applied to your NPDES permitting authority for a waiver for all of the pollutants listed on this table for the noted outfall. 1' Biochemical oxygen demand (BODS) ❑ Concentration mg/L 2.0 1 <2.0 1 Mass lb/Day 11.8 <55 2. Chemical oxygen demand (COD) ❑ Concentration mg/L 58 1 <20 1 Mass lb/Day 342 <550 3. Total organic carbon (TOC) O Concentration mg/L 21 1 2.3 1 Mass lb/Day 123.6 63.2 4. Total suspended solids (TSS) ❑ Concentration mg/L <2.5 1 <3.0 1 Mass lb/Day <14.7 <82.5 5. Ammonia (as N) ❑ Concentration mg/L <0.10 1 <1.0 1 Mass lb/Day <0.59 <27.5 6. Flow ❑ Rate mgd 0.706 Est 3.294 Est Temperature (winter) ❑ °C °C 21.73 90 7. Temperature (summer) ❑ °C °C 25.89 90 pH (minimum) ❑ Standard Units s.u. 8.02 1 7.33 1 8. pH (maximum) 0 Standard Units S.U. 8.58 1 This page intentionally left blank. EPA Identification N NPDES Pen mber Facility Name NC0000396 NC0000396 Asheville I ro 0:1 ;1:[ z191W'ff_'1 Z I exal WYM Z 1 M=77Presence or Absence Intake check one ( ) Effluent (optional) 7CASNumber, Testing Units Long -Term Re uired q Believed Believed (specify) Maximum Maximum Average Number of Long- Term Number Present Absent Daily Monthly Daily Analyses Average of Discharge Discharge Discharge Value Analyses (required) (if available) (if available) ❑ Check here if you qualify as a small business per the instructions to Form 2C and, therefore, do not need to submit quantitative data for any of the organic toxic pollutants in Sections 2 through 5 of this table. Note, however, that you must still indicate in the appropriate column of this table if you believe any of the pollutants listed are present in your discharge. Section 1. Toxic Metals, Cyanide, and Total Phenols Concentration ug/L <2.0 1 <2.0 1 1.1 Antimony, total (7440-36-0) � ❑ O Mass lb/Day <0.0118 <0.055 Concentration ug/L <2.0 1 <2.0 1 1.2 Arsenic, total (7440-38-2) � ❑ o Mass lb/Day <0.0118 <0.055 1.3 Beryllium, total (7440-41-7) Concentration ug/L <0.40 1 <0.40 1 Mass lb/Day <0.00236 <0.011 � El 1.4 Cadmium, total (7440-43-9) Concentration ug/L <0.50 1 <0.50 1 Mass lb/Day <0.00295 <0.0137 O El� 1.5 Chromium, total (7440-47-3) Concentration ug/L <5.0 1 <5.0 1 Mass lb/Day <0.0295 <0.137 O ❑ O Concentration ug/L 6.9 1 <5.0 1 1.6 Copper, total (7440-50-8) ❑ D Mass lb/Day 0.0407 <0.137 Concentration ug/L <1.0 1 <1.0 1 1.7 Lead, total (7439-92-1) 0 ❑ 0 Mass lb/Day <0.00589 <0.0275 1.8 Mercury, total (7439-97-6) Concentration ng/L 1.41 1 <0.500 1 Mass lb/Day 0.00000831 <0.0000137 0 0 � Concentration ug/L <5.0 1 <5.0 1 1.9 Nickel, total (7440-02-0) � ❑ � Mass lb/Day <0.0295 <0.137 Concentration ug/L <5.0 1 <5.0 1 1.10 Selenium, total (7782-49-2) o ❑ o Mass lb/Day <0.0295 <0.137 1.11 Silver, total (7440-22-4) Concentration ug/L <1.0 1 <1.0 1 Mass lb/Day <0.00589 <0.0275 0 ❑ � EPA Identification Nr, NPDES Perr mber Facility Name NC0000396 NCOOuu3yb Asheville • • • • • •• r • rr Presence or Absence (check one) Effluent Intake (optional) Poll utant/Parameter (and CAS Number, if available) Testing Required Units (specify) Believed Present Believed Absent Maximum Daily Discharge Maximum Monthly Discharge Long -Term Average Daily Discharge Number of Analyses Long- Term Average Value Number of Analyses (required) (if available) (if available) 1.12 Thallium, total (7440-28-0) ❑ ❑ ❑ Concentration ug/L <0.50 1 <0.50 1 Mass lb/Day <0.00295 <0.0137 1.13 Zinc, total (7440-66-6) O O ❑ Concentration mg/L 0.20 1 <0.020 1 Mass lb/Day 1.18 <0.55 1.14 Cyanide, total (57-12-5) O ❑ O Concentration mg/L <0.010 1 <0.010 1 Mass lb/Day <0.0589 <0.275 1.15 Phenols, total O O ❑ Concentration ug/L 200 1 82 1 Mass lb/Day 1.18 2.25 Section 2. Organic Toxic Pollutants (GC/MS Fraction - Volatile Compounds) 2.1 Acrolein (107-02-8) ❑ El Concentration ug/L <5.0 1 <5.0 1 Mass lb/Day <0.0295 <0.137 2.2 Acrylonitrile (107-13-1) � ❑ � Concentration ug/L <5.0 1 <5.0 1 Mass lb/Day <0.0295 <0.137 2.3 Benzene (7143-2) ❑ El Concentration ug/L <1.0 1 <1.0 1 Mass lb/Day <0.00589 <0.0275 2.4 Bromoform (75-25-2) El El FA Concentration ug/L <1.0 1 <1.0 1 Mass lb/Day <0.00589 <0.0275 2.5 Carbon tetrachloride (56-23-5) El ElConcentration ug/L <1.0 1 <1.0 1 Mass lb/Day <0.00589 <0.0275 2.6 Chlorobenzene (108-90-7) FA El 0 Concentration ug/L <1.0 1 <1.0 1 Mass lb/Day <0.00589 <0.0275 2.7 Chlorodibromomethane (124-48-1) 0 EI 0 Concentration ug/L <1.0 1 <1.0 1 Mass lb/Day <0.00589 <0.0275 2.8 Chloroethane (75-00-3) � ❑ 0 Concentration ug/L <2.0 1 <2.0 1 Mass lb/Day <0.0118 <0.055 EPA Identification Nt NPDES Per imber Facility Name NC0000396 NC0000396 Asheville Presence or Absence (check one) Effluent Intake (optional) Believed Present Pt Believed Absent Maximum Daily Discharge Maximum Monthly Discharge Long -Term Average Daily Discharge Number of Analyses Long- Term Average Value Number of Analyses Pollutant/Parameter (and CAS Number, if available) Testing Required Units (specify) 1 1 (required) (if available) (if available) 2.9 2-chloroethylvinyl ether (110-75-8) Concentration ug/L <5.0 1 <5.0 1 Mass lb/Day <0.0295 <0.137 2.10 Chloroform (67-66-3) � 0 � Concentration ug/L 2.5 1 <1.0 1 Mass lb/Day 0.0147 <0.0275 211 Dichlorobromomethane (75-27-4) M Concentration ug/L <1.0 1 <1.0 1 Mass lb/Day <0.00589 <0.0275 2.12 1,1-dichloroethane (75-34-3) 0 � � Concentration ug/L <1.0 1 <1.0 1 Mass lb/Day <0.00589 <0.0275 2.13 1,2-dichloroethane (107-06-2) O Li o Concentration ug/L <1.0 1 <1.0 1 Mass lb/Day <0.00589 <0.0275 2.14 1,1-dichloroethylene (75-35-4) Concentration ug/L <1.0 1 <1.0 1 Mass lb/Day <0.00589 <0.0275 2.15 1,2-dichloropropane (78-87-5) El El 0 Concentration ug/L <1.0 1 <1.0 1 Mass lb/Day <0.00589 <0.0275 2.16 1,3-dichloropropylene (542-75-6) Concentration ug/L <1.0 1 <1.0 1 Mass lb/Day <0.00589 <0.0275 2.17 Ethylbenzene (100-41-4) � El� Concentration ug/L <1.0 1 <1.0 1 Mass lb/Day <0.00589 <0.0275 2.18 Methyl bromide (74-83-9) � � � Concentration ug/L <2.0 1 <2.0 1 Mass lb/Day <0.0118 <0.055 2.19 Methyl chloride (74-87-3) Concentration ug/L <2.0 1 <2.0 1 Mass lb/Day <0.0118 <0.055 2.20 Methylene chloride (75-09-2) t7 El � Concentration ug/L <1.0 1 <1.0 1 Mass lb/Day <0.00589 <0.0275 2 21 1.1,2,2- tetrachloroethane (79-34-5) Concentration ug/L <1.0 1 <1.0 1 Mass Ib/Day <0.00589 <0.0275 EPA Identification M NPDES Perr mber Facility Name NC0000396 NC0000396 Asheville • . • • . • - • - •Jill I' III ip illi��ll�l • 1 Presence or Absence Intake check one ( ) Effluent (optional) Pollutant/Parameter Testing Units Long -Term (and CAS Number, if Required (specify) Maximum Maximum Average Long- Number available) Believed Believed Daily Monthly Daily Number of Term of Present Absent Analyses Average Discharge Discharge Discharge Value Analyses (required) (if available) (if available) Tetrachloroethylene Concentration ug/L <1.0 1 <1.0 1 2.22 (127-18-4) O ❑ 6] Mass Ib/Day <0.00589 <0.0275 Concentration ug/L <1.0 1 <1.0 1 2.23 Toluene (108-88-3) p ❑ 0 Mass Ib/Day <0.00589 <0.0275 1,2-trans-dichloroethylene Concentration ug/L <1.0 1 <1.0 1 2.24 10 0 o Mass lb/Day <0.00589 <0.0275 (156-60-5) 1,1,1-trichloroethane Concentration ug/L <1.0 1 <1.0 1 2.25 o 13 Mass lb/Day <0.00589 <0.0275 (71-55-6) 1,1,2-trichloroethane Concentration ug/L <1.0 1 <1.0 1 2.26 ❑ 10 Mass Ib/Day <0.00589 <0.0275 (79-00-5) Concentration ug/L <1.0 1 <1.0 1 2.27 Trichloroethylene (79-01-6) � � 0 Mass Ib/Day 1 <0.00589 <0.0275 Concentration ug/L <1.0 1 <1.0 1 2.28 Vinyl chloride (75-01-4) o ❑ 13 Mass Ib/Day <0.00589 <0.0275 Section 3. Organic Toxic Pollutants (GC/MS Fraction - Acid Components) Concentration ug/L <1.6 1 <1.6 1 3.1 2-chlorophenol (95-57-8) o � o Mass lb/Day <0.00943 <0.044 2,4-dichlorophenol Concentration ug/L <1.6 1 <1.6 1 3.2 (120-83-2) 17 ❑ 0 Mass Ib/Day <0.00943 <0.044 2,4-dimethylphenol Concentration ug/L <1.6 1 <1.6 1 3.3 (105-67-9) ❑ 13 Mass Ib/Day <0.00943 <0.044 4,6-dinitro-o-cresol Concentration ug/L <8.0 1 <8.0 1 3.4 (534-52-1) 17 Li 0 Mass Ib/Day <0.0471 <0,22 Concentration ug/L <8.0 1 <8.0 1 3.5 2,4-dinitrophenol (51-28-5) p � � Mass I Ib/Day 1 <0.0471 1 <0.22 EPA Identification N NPDES Perr mber Facility Name NC0000396 NC0000396 Asheville Presence or Absence (check one) Pollutant/Parameter Testing (and CAS Number, if Re uired available) 4 Believed Believed Present Absent 3.6 12-nitrophenol (88-75-5) 37 4-nitrophenol (100-02-7) 3.8 p-chloro-m-cresol (59-50-7) O 3.9 Pentachlorophenol (87-86-5) o Phenol 3.10 0 (108-95-2) 2,4,6-trichlorophenol 3.11 (88-05-2) ❑ Section 4. Organic Toxic Pollutants (GCS 4.1 Acenaphthene (83-32-9) ❑ 4.2 Acenaphthylene (208-96-8) ❑ 4.3 Anthracene (120-12-7) ❑ 4.4 Benzidine (92-87-5) ❑ 4.5 jl3enzo (a) anthracene (56-55-3) ❑ 4.6 113enzo (a) pyrene (50-32-8) ❑ Units (specify) ❑ (Z Concentration Mass ❑ O Concentration Mass ❑ 0 Concentration Mass ❑ a Concentration Mass ❑ U Concentration Mass ❑ 0 Concentration Mass Fraction - Base /Neutral Compounds) ❑ O Concentration Mass ❑ 0 Concentration Mass Concentration Mass Concentration Mass ❑ a Concentration Mass Concentration Mass Effluent Intake (optional) Maximum Daily Discharge (required) Maximum Monthly Discharge (if available) Long -Term Average Daily Discharge (if available) Number of Analyses Long- Term AverageValue Number of Analyses ug/L <3.2 1 <3.2 1 Ib/Day <0.0189 <0.088 ug/L <8.0 1 <8.0 1 lb/Day <0.0471 <0.22 ug/L <1.6 1 <1.6 1 lb/Day <0.00943 <0.044 ug/L <8.0 1 <8.0 1 lb/Day <0.0471 <0,22 mg/L <0.0050 1 0.23 1 lb/Day <0.0295 6.32 ug/L <1.6 1 <1.6 1 lb/Day <0.00943 <0.044 ug/L <1.6 1 <1.6 1 lb/Day <0.00943 <0.044 ug/L <1.6 1 <1.6 1 lb/Day <0.00943 <0.044 ug/L <1.6 1 <1.6 1 lb/Day <0.00943 <0.044 ug/L <8.0 1 <8.0 1 lb/Day <0.0471 <0.22 ug/L <1.6 1 <1.6 1 lb/Day <0.00943 <0.044 ug/L <1.6 1 <1.6 1 lb/Day <0.00943 <0.044 EPA Identification N NPDES Pen mber Facility Name NC0000396 NCOODU39b Asheville Presence or Absence Intake (check one) Effluent (optional) Pollutant/Parameter Testing Units Long -Term (and CAS Number, if available) Required q (specify) Maximum Maximum Average Long- Number Believed Believed Daily Monthly Daily Number of Term of Present Absent Analyses Average Discharge Discharge Discharge Value Analyses (required) (if available) (if available) 3,4-benzofluoranthene Concentration ug/L <1.6 1 <1.6 1 4.7 (205-99-2) El ❑ El Mass lb/Day <0.00943 <0.044 Concentration ug/L <1.6 1 <1.6 1 4.8 Benzo (ghi) perylene (191-24-2) EJ ❑ 121 Mass lb/Day <0.00943 <0.044 Benzo (k) fluoranthene (207-08- Concentration ug/L <1.6 1 <1.6 1 4.9 9) ❑ ❑ Mass lb/Day <0.00943 <0.044 Bis (2-chloroethoxy) methane Concentration ug/L <1.6 1 <1.6 1 4.10 (111-91-1) ❑ ❑ El Mass lb/Day <0.00943 <0.044 Bis (2-chloroethyl) ether (111-44- Concentration ug/L <1.6 1 <1.6 1 4.11 4) ❑ ❑ 0 Mass lb/Day <0.00943 <0.044 Bis (2-chloroisopropyl) ether (102 Concentration ug/L <1.6 1 <1.6 1 4.12 80-1) ❑ ❑ 121 Mass lb/Day <0.00943 <0.044 Bis (2-ethylhexyl) phthalate (117- Concentration ug/L <8.0 1 <8.0 1 4.13 81-7) ❑ ❑ Mass lb/Day <0.0471 <0.22 4-bromophenyl phenyl ether (101 Concentration ug/L <1.6 1 <1.6 1 4.14 55-3) ❑ ❑ Mass lb/Day <0.00943 <0.044 Concentration ug/L <1.6 1 <1.6 1 4.15 Butyl benzyl phthalate (85-68-7) El 121 Mass lb/Day <0.00943 <0.044 4.16 2-chloronaphthalene (91-58-7) Concentration ug/L <1.6 1 <1.6 1 ❑ El FA Mass lb/Day <0.00943 <0.044 4.17 4-chlorophenyl phenyl ether Concentration ug/L <1.6 1 <1.6 1 (7005-72-3) ❑ ❑ Mass lb/Day <0.00943 <0.044 4.18 Chrysene (218-01-9) Concentration ug/L <1.6 1 <1.6 1 El ❑ 121 Mass lb/Day <0.00943 <0.044 4.19 Dibenzo (a,h) anthracene (53-70- Concentration ug/L <1.6 1 <1.6 LEE] 3) El ❑ Cl Mass lb/Day <0.00943 <0.044 EPA Identification N NPDES Pern mber Facility Name N C0000396 N C0000396 Asheville OMOMSUMMILIM Presence or Absence Intake check one ( ) Effluent (optional) PollutantlParameter Testing Units Long -Term (and CAS Number, if Required q Believed Believed (specify) Maximum Maximum Average Long- Number available) Daily Monthly Daily Number of Term of Present Absent Analyses Average Discharge Discharge Discharge Value Analyses (required) (if available) (if available) Concentration ug/L <1.0 1 <1.0 1 4.20 11,2-dichlorobenzene (95-50-1) 11 0 El Mass lb/Day <0.00589 <0.0275 1,3-dichlorobenzene Concentration ug/L <1.0 1 <1.0 1 4.21 (541-73-1) El 0 El Mass lb/Day <0.00589 <0.0275 4.22 1,4-dichlorobenzene Concentration ug/L <1.0 1 <1.0 1 (106-46-7) E El Mass lb/Day <0.00589 <0.0275 4.23 13,3-dichlorobenzidine Concentration ug/L <8.0 1 <8.0 1 (91-94-1) Mass lb/Day <0.0471 <0,22 Diethyl phthalate Concentration ug/L <1.6 1 <1.6 1 4.24 (84-66-2) Mass lb/Day <0.00943 <0.044 Dimethyl phthalate Concentration ug/L <1.6 1 <1.6 1 4 25 (131-11-3) ElMass lb/Day <0.00943 <0.044 4.26 Di-n-butyl phthalate Concentration ug/L <1.6 1 <1.6 1 (84-74-2) El 0 Mass lb/Day <0.00943 <0.044 4.27 2,4-dinitrotoluene Concentration ug/L <3.2 1 <3.2 1 (121-14-2) E B Mass lb/Day <0.0189 <0.088 2,6-dinitrotoluene Concentration ug/L <3.2 1 <3.2 1 4.28 (606-20-2) El Mass lb/Day <0.0189 <0.088 4.29 Di-n-octyl phthalate Concentration ug/L <1.6 1 <1.6 1 (117-84-0) Mass lb/Day <0.00943 <0.044 4.30 1,2-Diphenylhydrazine Concentration ug/L <1.6 1 <1.6 1 (as azobenzene) (122-66-7) E Mass lb/Day <0.00943 <0.044 4.31 Fluoranthene Concentration ug/L <1.6 1 <1.6 1 (206-44-0) E El Mass lb/Day <0.00943 <0.044 4.32 Fluorene Concentration ug/L <1.6 1 <1.6 1 (86-73-7) 0 Mass lb/Day <0.00943 <0.044 EPA Identification Ni NPDES Pern nber Facility Name NC0000396 NC0000396 Asheville Presence or Absence check one ( ) Effluent tional) 7Long- Pollutant/Parameter Testing Units Long -Term (andtake CAS Number, if Required q Believed Believed (specify) Maximum Maximum Average Number available) Daily Monthly Daily Number of Term of Present Absent Analyses Average Discharge Discharge Discharge Value Analyses (required) (if available) (if available) 4.33 Hexachlorobenzene Concentration ug/L <1.6 1 <1.6 1 (118-74-1) El ❑ L'i Mass lb/Day <0.00943 <0.044 4.34 Hexachlorobutadiene Concentration ug/L <1.6 1 <1.6 1 (87-68-3) El L1 E Mass lb/Day <0.00943 <0.044 4.35 Hexachlorocyclopentadiene Concentration ug/L <8.0 1 <8.0 1 (77-47-4) 0 El B Mass lb/Day <0.0471 <0.22 4.36 Hexachloroethane Concentration ug/L <1.6 1 <1.6 1 (67-72-1) El ❑ 0 Mass lb/Day <0.00943 <0.044 Indeno (1,2,3-cd) pyrene Concentration ug/L <1.6 1 <1.6 1 4.37 (193-39-5) Mass lb/Day <0.00943 <0.044 Isophorone Concentration ug/L <1.6 1 <1.6 1 4.38 (78-59-1) El El EdMass lb/Day <0.00943 <0.044 Naphthalene Concentration ug/L <1.6 1 <1.6 1 4.39 (91-20-3) ❑ El E Mass lb/Day <0.00943 <0.044 Nitrobenzene Concentration ug/L <1.6 1 <1.6 1 4.40 (98-95-3) El ❑ Mass lb/Day <0.00943 <0.044 N-nitrosodimethylamine Concentration ug/L <1.6 1 <1.6 1 4.41 (62-75-9) El ❑ Mass lb/Day <0.00943 <0.044 4 42 N-nitrosodi-n-propylamine Concentration ug/L <1.6 1 <1.6 1 (621-64-7) 0 0Mass lb/Day <0.00943 <0.044 4.43 N-nitrosodiphenylamine Concentration ug/L <1.6 1 <1.6 1 (86-30-6) ❑ El o Mass lb/Day <0.00943 <0.044 4.44 lPhenanthrene Concentration ug/L <1.6 1 <1.6 1 (85-01-8) El 0 U Mass lb/Day <0.00943 <0.044 4.45 Pyrene ncentration [Moss ug/L <1.6 1 <1.6 1 (129-00-0) El El lb <0.00943 <0.044 EPA Identification N r NPDES Perr mber Facility Name NC0000396 NC0000396 Asheville Presence or Absence Intake (check one) Effluent (optional) Pollutant/Parameter Testing Units Long -Term (and CAS Number, if Required q (specify) Maximum Maximum Average Long- Number available) Believed Believed Daily Monthly Daily Number of Term of Present Absent Analyses Average Discharge Discharge Discharge Value Analyses (required) (if available) (if available) Concentration ug/L <1.6 1 <1.6 1 4.46 11,2,4-trichlorobenzene (120-82-1) 0 0 Mass lb/Day <0.00943 <0.044 Aldrin Concentration ug/L <0.040 1 <0.040 1 51 (309-00-2) El 0 EDMass lb/Day <0.000236 <0.0011 a-BHC Concentration ug/L <0.040 1 <0.040 1 5.2 (319-84-6) El 0 2 Mass lb/Day <0.000236 <0.0011 Concentration ug/L <0.040 1 <0.040 1 5.3 10-13HC (319-85-7) 0 0 El Mass lb/Day <0.000236 <0.0011 5.4 y-BHC Concentration ug/L <0.040 1 <0.040 1 (58-89-9) El 0 El Mass lb/Day <0.000236 <0.0011 6-13HC Concentration ug/L <0.040 1 <0.040 1 5.5 (319-86-8) El 0 F±1 Mass lb/Day <0.000236 <0.0011 Chlordane Concentration ug/L <0.40 1 <0.40 1 5.6 (57-74-9) 1-] El El Mass lb/Day <0.00236 <0.011 4,4'-DDT Concentration ug/L <0.040 1 <0.040 1 5.7 (50-29-3) 0 El E1 Mass lb/Day <0.000236 <0.0011 4,4'-DDE Concentration ug/L <0.040 1 <0.040 1 5.8 (72-55-9) El 0 Mass lb/Day <0.000236 <0.0011 4,4'-DDD Concentration ug/L <0.040 1 <0.040 1 5.9 (72-54-8) Mass lb/Day <0.000236 <0.0011 Dieldrin Concentration ug/L <0.040 1 <0.040 1 5.10 (60-57-1) El 0 Mass lb/Day <0.000236 <0.0011 5.11 a-endosulfan Concentration ug/L <0.040 1 <0.040 1 (115-29-7) 0 0 Mass lb/Day <0.000236 <0.0011 EPA Identification N r NPDES Perr mber Facility Name NC0000396 NC000039b Asheville Pollutant/Parameter (and CAS Number, if available) Testing Required q Presence or Absence (check one) Units (specify) Effluent Intake (optional) Believed Present Believed Absent Maximum Daily Discharge (required) Maximum Monthly Discharge (if available) Long -Term Average Daily Discharge (if available) Number of Analyses Long- Term Average Value Number of Analyses 512 R-endosulfan (115-29-7) El El EI Concentration ug/L <0.040 1 <0.040 1 Mass lb/Day <0.000236 <0.0011 5.13 Endosulfan sulfate (1031-07-8) Concentration ug/L <0.040 1 <0.040 1 Mass lb/Day <0.000236 <0.0011 5.14 Endrin (72-20-8) El El El Concentration ug/L <0.040 1 <0.040 1 Mass lb/Day <0.000236 <0.0011 5.15 Endrin aldehyde (7421-93-4) El 0 o Concentration ug/L <0.040 1 <0.040 1 Mass lb/Day <0.000236 <0.0011 5.16 Heptachlor (76-44-8) Concentration ug/L <0.040 1 <0.040 1 Mass lb/Day <0.000236 <0.0011 5.17 Heptachlor epoxide (1024-57-3) Concentration ug/L <0.040 1 <0.040 1 Mass lb/Day <0.000236 <0.0011 5.18 PCB-1242 (53469-21-9) El 0 Concentration ug/L <0.40 1 <0.40 1 Mass lb/Day <0.00236 <0.011 5.19 PCB-1254 (11097-69-1) El E Concentration ug/L <0.40 1 <0.40 1 Mass lb/Day <0.00236 <0.011 5.20 PCB-1221 (11104-28-2) El 0 Concentration ug/L <0.40 1 <0.40 1 Mass lb/Day <0.00236 <0.011 5.21 PCB-1232 (11141-16-5) El E Concentration ug/L <0.40 1 <0.40 1 Mass lb/Day <0.00236 <0.011 5.22 IPCB-1248 (12672-29-6) 0 E Concentration ug/L <0.40 1 <0.40 1 Mass lb/Day <0.00236 <0.011 5.23 IPCB-1260 (11096-82-5) El D Concentration ug/L <0.40 1 <0.40 1 Mass lb/Day <0.00236 <0.011 5.24 PCB-1016 (12674-11-2) � El� Concentration ug/L <0.40 1 <0.40 1 Mass lb/Day <0.00236 1 <0.011 EPA Identification N r NPDES Pern tuber Facility Name NC0000396 NC000039b Asheville Presence or Absence Intake check one ( ) Effluent (optional) Pollutant/Parameter Testing Units Long -Term (and CAS Number, if Required q (specify) Maximum Maximum Average Long- Number available) Believed Believed Daily Monthly Daily Number of Term of Present Absent Analyses Average Discharge Discharge Discharge Value Analyses (required) (if available) (if available) Concentration ug/L <0.40 1 <0.40 1 IToxaphene 5.25 g001-35-2 ( ) Mass lb/Day <0.00236 <0.011 This page intentionally left blank. EPA Identification IS �r NPDES Pern mber Facility Name NC0000396 NC0000396 Asheville Presence or Absence Intake check one ( ) Effluent (optional) Pollutant/Parameter Units Long -Term (and CAS Number, if available) (specify) Maximum Maximum Average Long- Number Believed Believed Number of Term Present Absent Daily Monthly Daily Analyses Average of Discharge Discharge Discharge Value Analyses (required) (if available) (if available) ❑ Check here if you believe all pollutants on Table C to be present in your discharge from the noted outfall. You need not complete the "Presence or Absence" column of Table C for each pollutant. ❑ Check here if you believe all pollutants on Table C to be absent in your discharge from the noted outfall. You need not complete the "Presence or Absence" column of Table C for each pollutant. Bromide Concentration mg/I <0.20 1 <2.0 1 1 (24959-67-9) ❑ 0 Mass lb/Day <1.18 54.9 Chlorine, total Concentration mg/L <0.028 1 2' residual Ej ❑ Mass lb/Day <0.165 Concentration AUMI <25 1 <25 1 3. Color o ❑ Mass lb/Day NA NA Concentration CFU/100 ml <2.0 1 1 1 4. Fecal Coliform ❑ � Mass lb/Day NA NA Fluoride Concentration mg/L 0.32 1 <0.10 1 5' (16984-48-8) o ❑ Mass lb/Day 1.89 <2.75 Concentration mg/L 0.45 1 0.062 1 6. Nitrate -nitrite 41 El Mass lb/Day 2.65 1.7 Nitrogen, total Concentration mg/L 2.15 1 0.23 1 7 organic (as N) E1 ❑ Mass lb/Day 12.66 6.32 Concentration mg/L <5.0 1 <5.0 1 8. Oil and Grease ❑ o Mass lb/Day <29.5 <137 Phosphorus (as P), Concentration mg/L 4.3 1 <0.050 1 9. total (7723-14-0) 0 ❑ Mass Ib/Day 25.3 <1.37 Sulfate (as SO4) Concentration mg/I 27 1 2.9 1 10. (14808-79-8) o ❑ Mass lb/Day 158.98 79.67 mg/L <1.0 1 <1.0 1 USulfide (as S) (as S) DConcentration ❑ � Mass lb/Day <5.89 <27.5 EPA Identification P ar NPDES Perrr mber =acility Name NC0000396 NC0000396 Asheville Presence or Absence Intake check one ( ) Effluent (optional) Pollut7ailable Units Long -Term (and C (specify) Maximum Maximum Average Long- Number Believed Believed Daily Monthly Daily Number of Term of Present Absent Analyses Average Discharge Discharge Discharge Value Analyses (required) (if available) (if available) (as Concentration mg/L 2.0 1 2.0 1 12.Sulfite (14265-45o El Mass lb/Day 11.8 55 Concentration mg/L <0.1 1 <0.1 1 13. Surfactants Ej 0 Mass lb/Day <0.59 <2.75 Aluminum, total Concentration mg/L <0.40 1 <0.40 1 14. (7429-90-5) ❑ [A Mass lb/Day <2.36 <11 Barium, total Concentration mg/L 0.10 1 <0.025 1 15. (7440-39-3) 0 0 Mass lb/Day 0.589 <0.687 Boron, total Concentration mg/L 0.052 1 <0.050 1 16. (7440-42-8) o ❑ Mass lb/Day 0.306 <1.37 Cobalt, total Concentration ug/L <5.0 1 <5.0 1 17 (7440-48-4) 0 D Mass lb/Day <0.0295 <0.137 Iron, total Concentration mg/L 0.14 1 <0.10 1 18 (7439-89-6) 111 ❑ Mass lb/Day 0.825 <2.75 Magnesium, total Concentration mg/L 15 1 <5.0 1 19 (7439-95-4) LA ❑ Mass lb/Day 88.4 <137 Molybdenum, total Concentration ug/L <10 1 <10 1 20 (7439-98-7) O El Mass lb/Day 1 <0.0589 <0.275 Manganese, total Concentration mg/L 0.021 1 0.026 1 21. (7439-96-5) 0 0 Mass lb/Day 0.124 0.715 Tin, total Concentration mg/L <0.050 1 <0.050 1 22 (7440-31-5) ❑ 0 Mass lb/Day <0.295 <1.37 total Concentration mg/L <0.050 1 <0.050 1 23. ITitanium, (7440-32-6) 0 Mass lb/Day <0.295 <1.37 EPA Identification t er NPDES Perry mber :acility Name NC0000396 NC0000396 Asheville • • 9 • • • - • . • 1 1 Presence or Absence check one ( ) Effluent Intake (optional) Pollutant/Parameter Units Long -Term (and CAS Number, if available) Believed Present Believed Absent (specify) Maximum Daily Discharge Maximum Monthly Discharge Average Daily Discharge Number of Analyses Long- Term Average Value Number of Analyses (required) (if available) (if available) 24. Radioactivity Alpha, total 1-1 n Concentration Mass Beta, total Concentration Mass Radium, total 171 Concentration Mass Radium 226, total t] Concentration Mass This page intentionally left blank. EPA Identification )er NPDES Perm mber 3cility Name NC0000396 NC0000396 Asheville -�• • iI Presence or Absence (check one) Reason Pollutant Believed Present in Discharge MS • U, Available Quantitative Data (specify units) Pollutant Believed Present Believed Absent 1 Asbestos ❑ 0 2. Acetaldehyde ❑ O 3. Allyl alcohol ❑ 0 4• Allyl chloride ❑ 0 5• Amyl acetate ❑ El 6• Aniline ❑ 0 7. Benzonitrile ❑ 0 8. Benzyl chloride ❑ 0 9• Butyl acetate ❑ O 10. Butylamine ❑ 0 11. Captan ❑ 0 12. Carbaryl ❑ 0 13. Carbofuran ❑ 171 14. Carbon disulfide ❑ O 15. Chlorpyrifos ❑ O 16. Coumaphos ❑ O 17. Cresol ❑ 0 18. Crotonaldehyde ❑ 19. Cyclohexane 0 171 EPA Identification ber NPDES Perry mber acility Name NC0000396 NC0000396 Asheville -�• Pollutant - • Presence or Absence (check one) Reason Pollutant Believed Present in Discharge • �� Available Quantitative Data (specify units) Believed Present Believed Absent 20. 2,4-D (2,4-dichlorophenoxyacetic acid) ❑ C1 21. Diazinon ❑ 0 22• Dicamba ❑ 0 23. 1 Dichlobenil ❑ El 24• Dichlone ❑ o 25. 2,2-dichloropropionic acid ❑ 10 26. Dichlorvos ❑ 0 27- Diethyl amine ❑ Ej 28 Dimethyl amine ❑ o 29. Dintrobenzene ❑ 30. Diquat ❑ o 31. Disulfoton ❑ O 32. Diuron ❑ El 33. Epichlorohydrin ❑ El 34. Ethion ❑ EI 35. Ethylene diamine ❑ EI 36. Ethylene dibromide ❑ El 37. Formaldehyde ❑ EI 38. Furfural I ❑ o EPA Identification ber NC0000396 NPDES Pern, mber NC0000396 3cility Name Asheville - • • • Presence or Absence (check one) . Reason Pollutant Believed Present in Discharge • Available Quantitative Data (specify units) Pollutant Believed Present Believed Absent 39. Guthion ❑ N 40. Isoprene ❑ M 41. Isopropanolamine ❑ 0 42. Kelthane ❑ 0 43. Kepone ❑ O 44. Marathion ❑ C] 45. Mercaptodimethur ❑ O 46- Methoxychlor ❑ 0 47. Methyl mercaptan ❑ (] 48. Methyl methacrylate ❑ O 49. Methyl parathion ❑ 121 50. Mevinphos ❑ O 51. Mexacarbate ❑ O 52. Monoethyl amine ❑ FA 53. Monomethyl amine ❑ El 54. Naled ❑ O 55. Naphthenic acid ❑ O 56. Nitrotoluene ❑ O 57 Parathion 1 ❑ ❑ EPA Identification ber NPDES Perm mber icility Name NC0000396 NC0000396 Asheville Presence or Absence (check one) Reason Pollutant Believed Present in Discharge Available Quantitative Data (specify units) Pollutant Believed Present Believed Absent 58. Phenolsulfonate 7 EI 59. Phosgene ❑ EI 60. Propargite ❑ El 61. Propylene oxide ❑ p 62. Pyrethrins ❑ EI 63. Quinoline ❑ p 64. Resorcinol ❑ p 65. Strontium ❑ p 66. Strychnine ❑ EI 67. Styrene ❑ p 68. 214,5-T (2,4,5- trichlorophenoxyacetic acid) ❑ 0 69. TIDE (tetrachlorodiphenyl ethane) ❑ EI 70 2,4,5-TP [2-(2,4,5-trichlorophenoxy) propanoic acid] ❑ 0 71. Trichlorofon ❑ O 72. Triethanolamine ❑ o 73. Triethylamine ❑ EI 74. Trimethylamine ❑ EI 75. Uranium ❑ 0 76. Vanadium 0 0 EPA Identification ber NPDES Perrr mber icility Name N C0000396 N C0000396 Asheville Presence or Absence (check one) Available Quantitative Data Pollutant Reason Pollutant Believed Present in Discharge Believed Believed (specify units) Present Absent 77. Vinyl acetate i 78. Xylene ❑ EI 79. Xylenol ❑ 7 80. Zirconium ❑ I p Sampling shall be conducted according to sufficiently sensitive test procedures (i.e., methods) approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or required under 40 CFR chapter I, subchapter N or O. See instructions and 40 CFR 122.21(e)(3). This page intentionally left blank. EPA Identification N !r NPDES Perrr 'nber --acility Name NC0000396 NC0000396 Asheville OM I TCDD Presence or Absence Pollutant Congeners (check one) Results of Screening Procedure Used or Believed Believed Manufactured Present Absent rM 2,3,7,8-TCDD ❑ 1 ❑ F ' Sampling shall be conducted according to sufficiently sensitive test procedures (i.e., methods) approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or required under 40 CFR chapter I, subchapter N or O. See instructions and 40 CFR 122.21(e)(3). EPA Form 2C 3.1 Section 2 Line drawing 1 I Intake Lake Structure Julian 3 Existing Unit 3 and 4 A Simple Cycle Demineralized Water Storaoe Tanks Simple Cycle I CTG Water Wash Transfer Truck Domestic flows City of Asheville Public water Potable and Sanitary Svstems Public Sewer System (MSD) 2 Equipment Drains Sump Outfall 002 Lanod ing Simple Cycle to ►mwater Drains Lake ift station42 Julian 38 Unit 07/08 Water Sup—� Simple 18 Cycle CTG Demineralized =injectioonx Water Water Tanks Injection I Evaporation Filter Press (Shared) 29 19 OF E CTG Wash Water 19 I Transfer Truck later Unit 7/8 TB / rator WTB drains sump T Oil -Water Unit 5/6 TB --< Separator drain sump Settling French Broad River Basin/ Chanel 41 Outfall 001 Basin faced 3ter Attachment A — Process Flow Diagram Duke Energy Progress, LLC Asheville Combined Cycle Station Buncombe County, May 2023 EPA Form 2C 3.2 Section 3 Average Flows and Treatment Duke Energy Progress, Inc. Asheville Combined Cycle Plant — NPDES Permit Number NC0000396 Form 2C - Item 2.1-A Flow, Sources of Pollution, and Treatment Technologies Stream Name Average Flow Comments 1 Total Facility Raw Water Supply 3.294 MGD Lake Julian 2 Raw Water to Unit 05/06 1.647 MGD Average 3 Raw Water to Unit 07/08 1.647 MGD Average 4 Raw Water to Ultrafiltration 0.160 MGD Estimated 5 Cooling Tower Makeup 1.335 MGD Estimated 6 Cooling Tower Evaporation and Drift 0.921 MGD Estimated g Raw Water to Service Water Tank 0.151 MGD Estimated 9 Ultrafiltration Reject & Strainer Backwash 0.021 MGD Estimated 10 Service Water to Users 0.072 MGD Estimated 11 Condenser Circ Water Quench Water to Boiler Blowdown Tank 0.006 MGD Estimated 12 Service Water to Two -Pass Reverse Osmosis Skids 0.148 MGD Estimated 13 Reverse Osmosis Permeate to Mixed Bed Demineralizer 0.108 MGD Estimated 14 Reverse Osmosis Reject 0.040 MGD Estimated 15 Demineralized Water System Makeup 0.108 MGD Estimated 16 Service Water Users to Oil Water Separator 0.072 MGD Estimated 17 Service Water to Unit 3 & 4 Evaporative Cooling &Cycle Makeup 0.080 MGD Estimated Seasonal 18 CTG NOx Injection Water 0.255 MGD Estimated 19 CTG Wash Water 0.001 MGD Episodic 20 Boiler Makeup 0.016 MGD Estimated 21 Boiler Blowdown 0.007 MGD Estimated 22 Boiler Blowdown Tank Evaporation & Losses 0.003 MGD Estimated 23 Quenched Boiler Blowdown Sump Flow 0.019 MGD Estimated 24 Sample Panel Flow 0.009 MGD Estimated 25 Unit 05/06 Oil Water Separator Flow 0.072 MGD Estimated Duke Energy Progress, Inc. Asheville Combined Cycle Plant— NPDES Permit Number NC0000396 Form 2C - Item 2.1-A Flow, Sources of Pollution, and Treatment Technologies Stream Name Average Flow Comments 26 Total Facility Wastewater to Plant Discharge 0.677 MGD Estimated 27 Side -Stream Filter Flow (Circulating water) 2.753 MGD Estimated 28 Side -Stream Filter Backwash Flow 0.0244 MGD Estimated 29 Sludge to Transfer Truck 0.009 MGD Episodic 30 OF Backwash Sump discharge flow 0.050 MGD Estimated 31 Side -Stream Filtrate (Circ water return) 2.390 MGD Estimated 32 Unit 07/08/WTB Oil water separator Flow 0.114 MGD Estimated 34 Filter Press Supernatant 0.001 MGD Estimated 37 Sludge Filter Press Supernatant 0.001 MGD Estimated 38 Standby Demin Trailer Flow 0.164 MGD Estimated 39 Cooling Tower Blowdown ( per unit) 0.338 MGD Average 40 Post ash basin surfaced groundwater 0.029 MGD Estimated 41 Outfall 001 0.706 MGD Estimated 42 Outfall 002 0.080 MGD Estimated Seasonal EPA Form 2C 3.3 Section 9 Biological Toxicity Test Chronic Toxicity testing has been conducted at Outfall 001 monthly since the last permit renewal issued in November 2018. The table below documents the dates and results. OUTFALL 001 Toxicity Testing eDMR Parameter Code TGP3B THP36 eDMR Parameter Code TGP3B THP3B Parameter (CERI7DPF) Chronic Toxicity (Pass/Fail) (CER7DCHV) Chronic Toxicity (ChV) Parameter (CERI7DPF) Chronic Toxicity (Pass/Fail) (CER7DCHV) Chronic Toxicity (ChV) Unit pass/fail % Unit pass/fail % Sample Freq Monthly Monthly Sample Freq Monthly Monthly 12/11/18 >7.2 04/06/21 PASS 01/15/19 >7.2 05/04/21 PASS 02/05/19 >7.2 06/08/21 PASS 03/05/19 >7.2 07/13/21 PASS 04/09/19 PASS 08/10/21 PASS 05/07/19 PASS 09/07/21 PASS 06/04/19 PASS 10/05/21 PASS 07/16/19 PASS 11/09/21 PASS 08/13/19 PASS 12/07/21 PASS 09/03/19 PASS 01/04/22 PASS 10/01/19 PASS 02/01/22 PASS 11/12/19 PASS 03/01/22 PASS 12/10/19 PASS 04/12/22 PASS 01/14/20 PASS 05/03/22 PASS 02/11/20 PASS 06/07/22 PASS 03/10/20 PASS 07/12/22 PASS 04/07/20 PASS 08/02/22 PASS 05/05/20 PASS 09/13/22 PASS 06/09/20 PASS 10/11/22 PASS 07/14/20 PASS 11/01/22 PASS 08/04/20 PASS 12/13/22 PASS 09/08/20 PASS 01/17/23 PASS 10/06/20 11/03/20 PASS PASS 02/07/23 PASS 03/21/23 PASS 12/01/20 PASS 04/11/23 PASS 01/05/21 PASS 02/02/21 PASS 03/09/21 PASS EPA Form 2C 3.4 Section 10 Contract Analysis Certified Labs used by Asheville Plant for NPDES monitoring: LABORATORY NC STATE LAB # Asheville Combined Cycle Station NC Field Lab #5055 6 Duke Energy Lane Arden, NC 28704 Pace Analytical Services Asheville NC Wastewater Certification #40 2225 Riverside Drive Asheville, NC 28804 Duke Energy Analytical Lab NC Wastewater Certification #248 13339 Hagers Ferry Road Huntersville, NC 28078-7929 Environmental Testing Solutions, Inc. NC Biological Analysis Certification #037 P.O. Box 7565 sheville, NC 28802 4 INSTREAM MONITORING Instream Monitoring Data 12/2018 INSTREAM OUTFALL 001 through 01002 4/2023 71870 00010 00010 < 2.8°C increase in background eDMR Parameter Code Parameter Total Arsenic Total Bromide Temperature Temp - 001E Calculated Temp. Difference (001-Upstream) Unit µjL mg/L °C "C T Sample Freq Monthly Monthly Monthly Monthly Monthly Sample ID Date Collected Downstream 12/05/18 <0.10 <0.10 7.6 Upstream 12/05/18 <0.10 <0.10 7.8 Downstream 01/08/19 <0.10 <0.10 9.5 Upstream 01/08/19 <0.10 <0.10 9.4 Downstream 02/05/19 <0.10 <0.10 9.2 Upstream 02/05/19 <0.10 <0.10 8.9 Downstream 03/06/19 <0.10 <0.10 7.0 Upstream 03/06/19 <0.10 <0.10 6.5 Downstream 04/02/19 <0.10 <0.10 11.2 Upstream 04/02/19 <0.10 <0.10 10.6 Downstream 05/08/19 0.10 <0.10 18.7 Upstream 05/08/19 <0.10 <0.10 17.6 Downstream 06/12/19 0.17 <0.10 19.7 Upstream 06/12/19 0.15 <0.10 19.0 Downstream 07/14/19 0.27 <0.10 23.8 - Upstream 07/14/19 0.27 <0.10 22.6 21.7 -0.9 Downstream 08/01/19 0.26 <0.10 22.8 - Upstream 08/01/19 0.18 <0.10 21.6 22.0 0.4 Downstream 09/12/19 0.21 <0.10 24.8 - Upstream 09/12/19 0.17 <0.10 22.7 22.0 -0.7 Downstream 10/01/19 0.35 <0.10 21.5 - Upstream 10/01/19 0.33 <0.10 21.1 Downstream 10/07/19 - - 18.2 - Upstream 10/07/19 - - 18.0 18 0.0 Downstream 11/13/19 0.12 <0.10 6.9 - Upstream 11/13/19 <0.10 <0.10 7.4 7.4 0.0 Downstream 12/05/19 <0.10 <0.10 5.9 - Upstream 12/05/19 <0.10 <0.10 5.8 6 0.2 Downstream 01/08/20 <0.10 <0.10 7.5 - Upstream 01/08/20 <0.10 <0.10 7.1 6.5 -0.6 Downstream 02/03/20 <0.10 <0.10 7.3 - Upstream 02/03/20 <0.10 <0.10 7.6 7.4 -0.2 Downstream 03/03/20 0.18 <0.10 8.6 - Upstream 03/03/20 0.32 <0.10 8.8 8.7 -0.1 Downstream 04/01/20 <0.10 <0.10 11 - Upstream 04/01/20 <0.10 <0.10 11.3 11.3 0.0 Instream Monitoring Data 12/2018 INSTREAM OUTFALL 001 through 01002 4/2023 71870 00010 00010 < 2.8°C increase in background eDMR Parameter Code Parameter Total Arsenic Total Bromide Temperature Temp -001E Calculated Temp. Difference (001-Upstream) Unit µg/L mg/L T °C °C Sample Freq Monthly Monthly Monthly Monthly Monthly Downstream 05/07/20 <0.10 <0.10 14 - Upstream 05/07/20 <0.10 <0.10 13.5 13.9 0.4 Downstream 06/08/20 0.19 <0.10 21.5 - Upstream 06/08/20 0.14 <0.10 20.8 21 0.2 Downstream 07/07/20 0.13 <0.10 22.5 - Upstream 07/07/20 0.14 <0.10 21.8 21.6 -0.2 Downstream 08/13/20 0.65 <0.10 22.3 - Upstream 08/13/20 0.40 <0.10 21.7 22 0.3 Downstream 09/01/20 0.12 <0.10 22.1 - Upstream 09/01/20 0.28 <0.10 21.3 21.5 0.2 Downstream 10/09/20 <0.10 <0.10 15.2 - Upstream 10/09/20 <0.10 <0.10 15.1 15.1 0.0 Downstream 11/04/20 <0.10 <0.10 10.7 - Upstream 11/04/20 <0.10 <0.10 10.2 9.5 -0.7 Downstream 12/02/20 <0.10 <0.10 6.1 - Upstream 12/02/20 <0.10 <0.10 6.3 6.6 0.3 Downstream 01/06/21 <0.10 <0.10 6.5 - Upstream 01/06/21 <0.10 <0.10 6.2 6.0 -0.2 Downstream 02/02/21 <0.10 <0.10 2.8 - Upstream 02/02/21 <0.10 <0.10 3.2 3.1 -0.1 Downstream 03/02/21 <1.0 <0.10 9.4 - Upstream 03/02/21 <1.0 <0.10 9.1 8.9 -0.2 Downstream 04/01/21 <1.0 <0.10 10.5 - Upstream 04/01/21 <1.0 <0.10 10.5 10.3 -0.2 Downstream 05/05/21 <1.0 <0.10 15.1 - Upstream 05/05/21 <1.0 <0.10 15 15.2 0.2 Downstream 06/07/21 <1.0 <0.10 22 - Upstream 06/07/21 <1.0 <0.10 21.7 21.7 0.0 Downstream 07/07/21 <1.0 <0.10 23.4 - Upstream 07/07/21 <1.0 <0.10 22 22.2 0.2 Downstream 08/04/21 <1.0 <0.10 219 - Upstream 08/04/21 <1.0 <0.10 20.9 20.9 0.0 Downstream 09/01/21 <1.0 <0.10 20.6 - Upstream 09/01/21 1 <1.0 I <0.10 20.2 20.8 0.6 Downstream 10/08/21 <1.0 <0.10 17.6 - Upstream 10/08/21 <1.0 <0.10 17.5 17.5 0.0 Instream Monitoring Data 12/2018 through 4/2023 INSTREAM OUTFALL 001 eDMR Parameter Code 01002 71870 01025 C0034 01040 70295 00900 01049 COMER 01147 00070 01090 00010 00010 < 2.8°C increase in background Parameter Total Arsenic Total Bromide Dissolved Cadmium Total Chromium Dissolved Copper TDS Total Hardness as (CaC031 Dissolved Lead Field Blank Mercury Total Mercury Total Selenium Turbidity Dissolved Zinc Temperature Temp -001E Calculated Temp. Difference (001-Upstream) Unit µg/L mg/L µg/L µg/L µg/L mg/L mg/L µg/L ng/L ng/L µg/L NTU µg/L °C °C °C Sample Freq Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly Downstream 11/04/21 <1.0 <0.10 <0.20 <1.0 <2.0 47.0 9.96 <1.0 <0.50 2.13 <2.0 1.9 <10.0 9.6 - Upstream 11/04/21 <1.0 <0.10 <0.20 <1.0 <2.0 33.0 10.00 <1.0 <0.50 1.06 <2.0 2.0 <10.0 9.6 9.5 -0.1 Downstream 12/01/21 <1.0 <0.10 <0.20 <1.0 <2.0 30.0 9.92 <1.0 <0.50 <0.50 <2.0 1.5 <10.0 4.1 - Upstream 12/01/21 <1.0 <0.10 <0.20 <1.0 <2.0 33.0 10.50 <1.0 <0.50 <0.50 <2.0 1.9 <10.0 4.2 4.6 0.4 Downstream 01/05/22 <1.0 <0.10 <0.20 <1.0 <2.0 33.0 10.00 <1.0 <0.50 1.96 <2.0 6.6 <10.0 7.6 - Upstream 01/05/22 <1.0 <0.10 <0.20 <1.0 <2.0 40.0 9.91 <1.0 <0.50 1.92 <2.0 7.2 <10.0 7.2 6.6 -0.6 Downstream 02/03/22 <1.0 <0.10 <0.20 1.3 <2.0 49.0 11.50 <1.0 <0.50 1.26 <2.0 8.8 <10.0 4.2 - Upstream 02/03/22 <1.0 <0.10 <0.20 <1.0 <2.0 42.0 10.90 <1.0 <0.50 0.999 <2.0 3.7 <10.0 3.9 4 0.1 Downstream 03/02/22 <1.0 <0.10 <0.20 <1.0 <2.0 35.0 9.70 <1.0 <0.50 1.10 <2.0 6.7 <10.0 9.2 - Upstream 03/02/22 <1.0 <0.10 <0.20 <1.0 <2.0 36.0 9.75 <1.0 <0.50 1.08 <2.0 4.4 <10.0 7.6 7.8 0.2 Downstream 04/04/22 <1.0 <0.10 <0.20 <1.0 <2.0 31.0 8.15 <1.0 <0.50 1.78 <2.0 7.5 <10.0 12.3 Upstream 04/04/22 <1.0 <0.10 <0.20 <1.0 <2.0 <25.0 8.14 <1.0 <0.50 1.28 <2.0 5.4 <10.0 11.8 12.3 0.5 Downstream 05/05/22 <1.0 <0.10 <0.20 <1.0 <2.0 <25.0 8.84 <1.0 <0.50 1.11 <2.0 3.6 <10.0 20.0 Upstream 05/05/22 <1.0 <0.10 <0.20 <1.0 <2.0 <25.0 9.35 <1.0 <0.50 0.986 <2.0 6.6 <10.0 18.4 18.5 0.1 Downstream 06/06/22 <1.0 <0.10 <0.20 2.6 <2.0 25.0 8.34 <1.0 <0.50 3.19 <2.0 9.8 <10.0 20.3 Upstream 06/06/22 <1.0 <0.10 <0.20 2.6 <2.0 26.0 8.38 <1.0 <0.50 3.10 <2.0 8.8 <10.0 19.2 19 -0.2 Downstream 07/11/22 <1.0 <0.10 <0.20 1.4 <2.0 40.0 9.95 <1.0 <0.50 8.30 <2.0 47.4 <10.0 20.5 Upstream 07/11/22 <1.0 <0.10 <0.20 1.1 <2.0 <25.0 9.46 <1.0 <0.50 4.68 <2.0 34.7 <10.0 20.4 20.4 0.0 Downstream 08/03/22 <1.0 <0.10 <0.20 <1.0 <2.0 30.0 10.60 <1.0 <0.50 3.06 <2.0 17 <10.0 22 Upstream 08/03/22 <1.0 <0.10 <0.20 <1.0 <2.0 <25.0 9.42 <1.0 <0.50 3.52 <2.0 16 <10.0 21.8 21.8 0.0 Downstream 09/07/22 <1.0 <0.10 <0.20 1.6 <2.0 26.0 9.66 <1.0 0.917 8.70 <2.0 31 <10.0 21.3 Upstream 09/07/22 <1.0 <0.10 <0.20 1.3 <2.0 25.0 9.38 <1.0 <0.50 7.61 <2.0 28 <10.0 21 21.2 0.2 Downstream 10/04/22 <1.0 <0.10 <0.20 <1.0 <2.0 44.0 9.70 <1.0 <0.50 1.10 <2.0 5.1 <10.0 1 15.8 Upstream 10/04/22 <1.0 <0.10 <0.20 <1.0 <2.0 35.0 10.40 <1.0 <0.50 1.11 <2.0 3.2 <10.0 14.3 13.7 -0.6 Downstream 11/01/22 <1.0 <0.10 <0.20 <1.0 4.3 33.0 10.10 <1.0 <0.50 1.60 <4.0 5.6 <10.0 13.3 Upstream 11/01/22 <1.0 <0.10 <0.20 <1.0 <2.0 33.0 10.30 <1.0 <0.50 1.68 <4.0 5.6 <10.0 12 12 0.0 Downstream 12/07/22 <1.0 <0.10 <0.20 <1.0 2.6 27.0 11.00 <1.0 <0.50 2.83 <2.0 19 <10.0 10 Upstream 12/07/22 <1.0 <0.10 <0.20 <1.0 3.3 <25.0 10.60 <1.0 <0.50 2.36 <2.0 13 <10.0 10 9.8 -0.2 Downstream 01/04/23 <1.0 <0.10 <0.20 2.6 <2.0 46.0 13.50 <1.0 <0.50 7.18 <2.0 92 <10.0 10.5 Upstream 01/04/23 <1.0 <0.10 <0.20 <1.0 <2.0 37.0 11.80 <1.0 <0.50 5.42 <2.0 35 <10.0 10.4 10.6 0.2 Downstream 02/07/23 <1.0 <0.10 <0.20 <1.0 <2.0 30.0 9.58 <1.0 <0.50 1.46 <2.0 4.2 <10.0 6.0 Upstream 02/07/23 <1.0 <0.10 <0.20 <1.0 <2.0 31.0 9.48 <1.0 <0.50 3.51 <2.0 4.1 <10.0 5.7 5.8 0.1 Downstream 03/01/23 <1.0 <0.10 <0.20 <1.0 <2.0 <25.0 8.63 <1.0 0.916 2.82 <2.0 6.4 <10.0 11.3 11.5 0.2 Upstream 03/01/23 <1.0 <0.10 <0.20 <1.0 <2.0 <25.0 8.69 <1.0 <0.50 2.38 <2.0 5.1 <10.0 11.2 Downstream 04/04/23 <1.0 <0.10 <0.20 <1.0 <2.0 <25.0 20.7 <1.0 <0.50 1.81 <2.0 5.1 <10.0 11.2 11 -0.2 Upstream 04/04/23 <1.0 <0.10 <0.20 <1.0 <2.0 <25.0 9.48 <1.0 <0.50 2.92 <2.0 3.5 <10.0 10.9 5 316B REPORT Clean Water Act § 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Arden, NC NPDES Permit NC0000396 Duke Energy I Environmental Operations 526 South Church Street Charlotte NC 28202 May 2023 DUKE *4.1' ENERGY- 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Contents ExecutiveSummary ....................................................................................................................................... 7 1 Introduction......................................................................................................................................10 2 Source Water Physical Data [§122.21(r)(2)].....................................................................................14 2.1 Description of Source Waterbody[§122.21(r)(2)(i)]..............................................................................14 2.2 Characterization of Source Waterbody[§122.21(r)(2)(ii)].....................................................................19 2.3 Locational Maps [§122.21(r)(2)(iii)].......................................................................................................21 3 Cooling Water Intake Structure Data [§ 122.21(r)(3)]...................................................................... 22 3.1 Description of CWIS Configuration [§122.21(r)(3)(i)]............................................................................22 3.2 Latitude and Longitude of CWIS§122.21(r)(3)(ii)]................................................................................25 3.3 Description of CWIS Operation [§122.21(r)(3)(iii)]................................................................................25 3.4 Description of Intake Flows and Water Balance [§122.21(r)(3)(iv)]......................................................27 3.5 Engineering Drawings of CWIS [§122.21(r)(3)(v)]..................................................................................27 4 Source Water Baseline Biological Characterization Data[§122.21(r)(4)].........................................28 4.1 List of Available Biological Data [§122.21(r)(4)(i)].................................................................................29 4.2 List of Species and Relative Abundance in the vicinity of CWIS[§122.21(r)(4)(ii)]................................29 4.3 Identification of Species and Life Stages Susceptible to Impingement and Entrainment [§122.21(r)(4)(iii)]..................................................................................................................................32 4.4 Identification and Evaluation of Primary Growth Period [§122.21(r)(4)(iv)].........................................37 4.5 Data Representative of Seasonal and Daily Activities of Organisms in the Vicinity of CWIS [§122.21(r)(4)(v)]...................................................................................................................................39 4.6 Identification of Threatened, Endangered, and Other Protected Species Susceptible to Impingement and Entrainment at CWIS [§122.21(r)(4)(vi)]..................................................................41 4.7 Documentation of Consultation with Services[§122.21(r)(4)(vii)]........................................................43 4.8 Methods and QA Procedures for Field Efforts [§122.21(r)(4)(viii)].......................................................4 4.9 Definition of Source Water Baseline Biological Characterization Data[§122.21(r)(4)(ix)]....................43 4.10 Identification of Protective Measures and Stabilization Activities [§122.21(r)(4)(x)] ...........................43 4.11 List of Fragile Species [§122.21(r)(4)(xi)]...............................................................................................43 4.12 Information Submitted to Obtain Incidental Take Exemption or Authorization from Services [§122.21(r)(4)(xii)]..................................................................................................................................45 5 Cooling Water System Data[§122.21(r)(5)]...................................................................................... 46 5.1 Description of Cooling Water System Operation [§122.21(r)(5)(i)].......................................................46 5.2 Design and Engineering Calculations [§122.21(r)(5)(ii)]........................................................................52 5.3 Description of Existing Impingement and Entrainment Reduction Measures [§122.21(r)(5)(iii)] .........53 6 Chosen Method(s) of Compliance with Impingement Mortality Standard [§122.21(r)(6)].............. 55 6.1 Design TSV.............................................................................................................................................56 6.2 Requirements of Make-up Water Minimization for Closed -Cycle Recirculating System.......................56 7 Entrainment Performance Studies [40 CFR § 122.21(r)(7)].............................................................. 58 7.1 Site -Specific Studies [40 CFR §122.21(r)(7)(i)].......................................................................................58 7.2 Studies Conducted at Other Locations [40 CFR§122.21(r)(7)(ii)]..........................................................58 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 8 Operational Status [§ 122.21(r)(8)]...................................................................................................59 8.1 Description of Operating Status [§ 122.21(r)(8)(i)]................................................................................59 8.2 Major Upgrades in Last Fifteen Years....................................................................................................60 8.3 Descriptions of Consultation with Nuclear Regulatory Commission [§122.21(r)(8)(ii)] ........................60 8.4 Other Cooling Water Uses for Process Units[§122.21(r)(8)(iii)]............................................................61 8.5 Description of Current and Future Production Schedules [§122.21(r)(8)(iv)].......................................61 8.6 Description of Plans or Schedules for New Units Planned within 5 years [§122.21(r)(8)(v)] ................61 9 References.........................................................................................................................................62 Appendices.................................................................................................................................................. 66 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Tables Table 1-1. Facility and Flow Attributes and Permit Application Requirements....................................................11 Table 1-2. Summary of §316(b) Rule for Existing Facilities Submittal Requirements..........................................13 Table 2-1. Annual Mean Concentration for Select Parameters Documented in Surface Water Samples ............ 18 Table 2-2. Summary of Input Parameters for TSV Calculations of CWIS on Lake Julian.......................................20 Table 3-1. Original and Repurposed Cooling Water Intake Structure Components.............................................23 Table 3-2. Cooling Water Intake Structure Coordinate Information...................................................................25 Table 3-3. Number of Hours of Unit 05/06 Cooing System Operation at ACC in 2020-2022..............................26 Table 3-4. Number of Hours of Unit 07/08 Cooling System Operation at ACC in 2020-2022 .............................26 Table 3-5. Monthly Withdrawals (MG) from ACC Intake during 2020-2022 to Support Plant Operations .......... 27 Table 3-6. List of Engineering Drawings for ACC Intakes......................................................................................27 Table 4-1. Relative Abundance of Fish Collected in Electrofishing Samples on Lake Julian.................................31 Table 4-2. Entrainment Potential for Fish Species Identified in Lake Julian.........................................................33 Table 4-3. Known Spawning and Recruitment Period of select Species with Documented Occurrence .............38 Table 4-4. Seasonal and Daily Activities of select Species Present in Lake Julian.................................................39 Table 4-5. Rare, Threatened, or Endangered Aquatic Species Listed and Record of Occurrence in Lake Julian..41 Table 4-6. List of Fragile Species and their Occurrence near Asheville Combined Cycle Station .........................44 Table 5-1. Water Balance Associated Flows for the ACC......................................................................................50 Table5.2 Calculated TSV.......................................................................................................................................52 Table 6-1. Site -Specific Design of ACC Closed -Cycle Cooling System...................................................................57 Table 8-1. Annual Capacity Factors (%) at ACC Unit 05/06, 2020-2022...............................................................60 Table 8-2. Annual Capacity Factors (%) at ACC Unit 07/08, 2020-2022...............................................................60 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Figures Figure 2-1. Map of French Broad -Holston Basin Hydrologic Unit Code 06010105....................................... Figure 2-2. Duke Energy Progress Environmental Monitoring Program Water Quality Sampling Stations.. Figure 2-2. Asheville Combined Cycle Station Site Location Map................................................................. Figure 3-1. Asheville Combined Cycle Cooling Water Intake Structure on Lake Julian ................................. Figure 3-2. Layout of the Repurposed Lake Julian Cooling Water Intake Structure (not to scale) ................ Figure 3-3. Photograph of a 1-inch Hexagonal Mesh Screen Panel Employed at the Cooling Water Intake Figure 4-1. Shoreline Habitat Types and Locations Sampled with Nighttime Electrofishing in Lake Julian .. Figure 5-1. Water Balance Diagram of the Asheville Combined Cycle Station .............................................. ......16 ......17 iv 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Appendices Appendix A. Asheville Combined Cycle Station § 122.21(r)(2)-(8) Submittal Requirement Checklist. Appendix B. Asheville Combined Cycle Station, Pertinent Engineering Drawings. Appendix C. Asheville Combined Cycle Station, Engineering Calculations for Through Screen Velocity. v 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Abbreviations °C degrees Celsius °F degrees Fahrenheit AIF actual intake flow AOI area of influence BTA Best Technology Available CCC closed cycle cooling CFR Code of Federal Regulations cfs cubic feet per second cm centimeter COC cycles of concentration CPUE catch per unit effort CTMU cooling tower makeup CWA Clean Water Act MIS Cooling Water Intake Structure DIF design intake flow Director NPDES Director DO dissolved oxygen Duke Energy Duke Energy Carolinas, LLC EPA Environmental Protection Agency ESA Endangered Species Act EPRI Electronic Power Research Institute fps feet per second ft foot/feet ft msl feet above mean sea level gpm gallons per minute HUC Hydrologic Unit Code IPAC Information for Planning Conservation m meter µm micron µS/cm microSiemens per centimeter m3 cubic meters MGD million gallons per day mm millimeters MW megawatts MWIS makeup water intake structure NCDENR-DWQ North Carolina Department of Environment and Natural Resources — Department of Water Quality NCDNCR North Carolina Department of Natural and Cultural Resources NDCT natural draft cooling tower NPDES National Pollutant Discharge Elimination System OTC once -through cooling POA percent open area PVC polyvinyl chloride Rule Clean Water Act §316(b) rule TL total length TSV through -screen velocity USEPA U.S. Environmental Protection Agency USFWS U.S. Fish and Wildlife Service USGS U.S. Geological Survey vi 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Executive Summary On August 15, 2014, regulations implementing §316(b) of the final Clean Water Act (CWA) rule for existing facilities (the Rule) were published in the Federal Register with an effective date of October 14, 2014. Facilities subject to the Rule are required to develop and submit technical material, in accordance with §122.21(r), that will be used by the National Pollutant Discharge Elimination System (NPDES) permit Director (Director) to make a Best Technology Available (BTA) determination for the facility. Duke Energy Progress, LLC (DEP) constructed a new combined cycle unit at the existing Asheville Steam Electric Plant (Asheville Plant) in Buncombe County, North Carolina. The generation capacity of the former Asheville Plant was replaced with the Asheville Combined Cycle Station (ACC), consisting of two combined cycle power blocks with a summer/winter net electrical generating capacity of 250 MW/280 MW per block. The ACC utilizes closed -cycle mechanical draft cooling towers, which reduce cooling water withdrawals from the coal-fired units average of 225 MGD to an average of 2.85 MGD and eliminates the thermal input to Lake Julian. The ACC utilizes the existing CWIS on Lake Julian for raw water supply, including cooling tower make-up water. The new ACC is defined as a "new unit" at an existing facility' per 40 CFR 125.92(u). To meet the impingement mortality and entrainment reduction standards in §125.94(e), the ACC is equipped with closed -cycle recirculating mechanical draft cooling towers. The §122.21(r) submittal material provided herein supports a conclusion that the ACC will fully meet the new unit BTA standards at §125.94(e) for impingement and entrainment reductions and minimizes potential adverse environmental impacts. Based on the §122.21(r) submittal material provided herein, ACC's chosen method of compliance with the Impingement Mortality Standard is operation of a closed -cycle recirculating system. Further, ACC requests that the Department designated the closed -cycle system as Best Technology Available (BTA) for entrainment reduction. Given that ACC currently employs closed -cycle cooling as described below, no further impingement or entrainment controls are necessary to comply with the standards. Impingement BTA The final Rule, at §125.94(c), requires existing facilities to employ one of seven impingement BTA alternatives'. ACC already employs one of these alternatives: ' The Rule states in § 125.92(u) that a "New unit means a new 'stand-alone' unit at an existing facility where construction of the new units begins after October 14, 2014, and that does not otherwise meet the definition of a new facility at § 125.83 or is not otherwise already subject to subpart I of this part. A stand-alone unit is a separate unit that is added to a facility for either the same general industrial operation or another purpose. A new unit may have its own dedicated cooling water intake structure, or the new unit may use an existing or modified cooling water intake structure." 2 Or under specific circumstances one of nine alternatives, which includes §125.94(c)(11) and (12) in addition to §125.94(c)(1)-(7). 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station • Primary impingement BTA—Closed-cycle cooling with mechanical draft cooling towers are utilized to provide makeup water which is consistent with a closed -cycle recirculating system (CCRS) defined at §125.92(c) and meets the BTA Standards for Impingement Mortality at §125.94(c)(1). Accordingly, this is ACC's preferred option for complying with the impingement standard. Of note, the ACC raw water intake is configured such that the design through -screen velocity is less than the 0.5 feet/second (fps) standard in the Rule. Entrainment BTA The Rule does not prescribe BTA for entrainment but does require BTA to be determined by the permitting authority on a site -specific basis. Based on information presented here, ACC requests that the Department designate closed -cycle cooling as BTA for entrainment based on the following: When compared against the factors in 40 C.F.R. § 122.25(f), closed -cycle cooling provides benefits to entrainment relative to once -through cooling (OTC) without additional costs. ACC utilizes closed -cycle cooling, which minimizes entrainment through flow reduction. Using actual cooling tower flows during the 2020-2022 period, the withdrawal reduction is 99%. Furthermore, the actual cooling tower flows (2.85 MGD) during the 2020-2022 period are substantially less than the 125 MGD threshold for a permittee to provide a comprehensive review of any entrainment impacts. Statements made by the United States Environmental Protection Agency (EPA) in the preamble to the Rule support a conclusion that closed -cycle cooling is appropriate for designation as BTA for entrainment: "Although this rule leaves the BTA entrainment determination to the Director, with the possible BTA decisions ranging from no additional controls to closed -cycle recirculating systems plus additional controls as warranted, EPA expects that the Director, in the site -specific permitting proceeding, will determine that facilities with properly operated closed -cycle recirculating systems do not require additional entrainment reduction control measures. I (emphasis added) This conclusion is further reiterated in the Response to Public Comments document, where EPA states: "EPA has made it clear that a facility that uses a closed -cycle recirculating system, as defined in the rule, would meet the rule requirements for impingement mortality at § 125.94(c)(1). This rule language specifically identifies closed -cycle as a compliance alternative for the [impingement mortality] performance standards. EPA expects the Director would conclude that such a facility would not be subject to additional entrainment controls to meet BTA.1'4 (emphasis added) 3 79 Fed. Reg. 48344 (15 August 2014) 4 Response to Comments, Essay 14, p. 62. 8 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Overall, entrainment at the facility is likely to be low and is not expected to involve federally protected species or their designated critical habitat. Potential impacts to fish and shellfish populations due to entrainment is also extremely unlikely due to the operation and configuration of the intake. Based on these findings, the existing closed -cycle cooling is the best technology available for reduction of entrainment at this facility. 9 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 1 Introduction Section 316(b) was enacted under the 1972 Clean Water Act (CWA), which also introduced the National Pollutant Discharge Elimination System (NPDES) permit program. Certain facilities with NPDES permits are subject to §316(b) requirements, which require the location, design, construction, and capacity of the facility's cooling water intake structure (CWIS) to reflect Best Technology Available (BTA) for minimizing potential adverse environmental impacts. On August 15, 2014, regulations implementing §316(b) of the final CWA rule (Rule) for existing facilities were published in the Federal Register with an effective date of October 14, 2014. The Rule applies to existing facilities that withdraw more than 2 million gallons per day (MGD) from waters of the United States, use at least 25 percent of that water exclusively for cooling purposes, and have or require an NPDES permit. Facilities subject to the Rule are required to develop and submit technical material that will be used by the NPDES Director (Director) to evaluate an applicants' preferred technology for compliance with the impingement standard and to make a site -specific Best Technology Available (BTA) determination regarding entrainment for the facility. The actual intake flow (AIF)' and design intake flow (DIF)6 at a facility determines which submittals will be required. As shown in Table 1-1, facilities with an AIF of 125 MGD or less have fewer application submittal requirements and will generally be required to select from the impingement compliance options contained in the final Rule. Facilities with an AIF in excess of 125 MGD are required to address both impingement and entrainment, and provide specific entrainment studies, which may involve extensive field studies and the analysis of alternative methods to reduce entrainment (§122.21(r)(9)-(13)). The §316(b) compliance schedule under the Rule is dependent on the facility's NPDES permit renewal date. Facilities were required to submit their §316(b) application material to their Director with their next permit renewal application unless that permit renewal application was due prior to July 14, 2018, in which case an alternate schedule could have been requested. 5 AIF is defined as the average volume of water withdrawn on an annual basis by the cooling intake structure over the past 3 years initially and past 5 years after Oct. 14, 2019. The calculation of AIF includes days of zero flow. AIF does not include flows associated with emergency and fire suppression capacity. 6 DIF is defined as the value assigned during the CWIS design to the maximum instantaneous rate of flow of water the CWIS is capable of withdrawing from a source waterbody. The facility's DIF may be adjusted to reflect permanent changes to the maximum capabilities of the cooling water intake system to withdraw cooling water, including pumps permanently removed from service, flow limit devices, and physical limitations of the piping. DIF does not include values associated with emergency and fire suppression capacity or redundant pumps (i.e., back- up pumps). 10 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Table 1-1. Facility and Flow Attributes and Permit Application Requirements. Facility and Flow Attributes Permit Application Requirements Existing facility with DIF greater than 2 MGD and §122.21(r)(2)-(13) AIF greater than 125 MGD. Existing facility with DIF greater than 2 MGD and AIF less than 125 MGD. §122.21(r)(2)-(8) Existing facility with DIF of 2 MGD or less, or less than 25 percent of AIF used for cooling Director Best Professional Judgment purposes. New units at existing facility. §122.21(r)(2), (3), (5), (8), and (14) and applicable paragraphs (r)(4), (6), and (7) of §122.21(r) The new ACC is defined as a "new unit" at an existing facility' per 40 CFR 125.92(u). The new ACC has a DIF greater than 2 MGD and an AIF less than 125 MGD and, therefore, is not required to submit information detailed in §122.21(r)(10)-(r)(13) of the Rule. Appendix A provides a checklist summary of the specific requirements under each of the §122.21(r)(2)-(8) and (r)(14) submittal requirements and how each is addressed in this report or why it is not applicable to ACC. Based on the Rule, facilities with an AIF of 125 MGD or less have fewer application submittal requirements and will generally be required to select from the impingement compliance options contained in the Rule. Facilities with an AIF in excess of 125 MGD are required to address both impingement and entrainment, and provide specific entrainment studies, which may involve extensive field studies and the analysis of alternative methods to reduce entrainment (§122.21(r)(9)-(13)). The decommissioned Duke Energy Progress, LLC (DEP) Asheville Steam Electric Plant (Asheville Plant) was located on Lake Julian in Buncombe County, North Carolina. Once -through cooling water from the former plant was withdrawn from the CWIS on Lake Julian. Supplemental water to maintain water levels in Lake Julian was withdrawn from an intake located on the adjacent French Broad Rivers. Per Section 2 of the Mountain Energy Act, the Asheville Plant was decommissioned prior to the January 29, 2020 deadline, replaced by the new Asheville Combined Cycle Plant (ACC). The revised NPDES permit to authorize ACC discharges was effective July 1, 2019. ' The Rule states that "New unit" means a new "stand-alone" unit at an existing facility where construction of the new units begins after October 14, 2014, and that does not otherwise meet the definition of a new facility at § 125.83 or is not otherwise already subject to subpart I of this part. A stand-alone unit is a separate unit that is added to a facility for either the same general industrial operation or another purpose. A new unit may have its own dedicated cooling water intake structure, or the new unit may use an existing or modified cooling water intake structure." a Supplemental water to maintain Lake Julian elevation continues to be withdrawn as needed from the French Broad River. 11 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station The former coal-fired Asheville Plant was replaced with two natural gas -fired combined cycle power blocks, each with one combustion turbine, one heat recovery steam generator (HRSG), and one steam turbine. The ACC employs close -cycled recirculating mechanical draft cooling towers, which significantly reduced water withdrawal and removed thermal impacts to Lake Julian. The new ACC units utilize the existing CWIS on Lake Julian for raw water supply, including cooling tower make-up; therefore, the CWIS on Lake Julian is the point of compliance for the Rule. The existing river intake on the French Broad River will continue to be used for occasional withdrawals to maintain Lake Julian surface water elevation. 12 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Table 1-2. Summary of §316(b) Rule for Existing Facilities Submittal Requirements for §122.21(r)(2)-(8) and (14). Submittal Requirements at §122.21(r) Submittal Description (2) Source Water Physical Data Characterization of the source waterbody including intake area of influence. (3) Cooling Water Intake Structure Data Characterization of the cooling water intake system; includes drawings and narrative; description of operation; water balance. Characterization of the biological community in the vicinity of the intake; life history summaries; susceptibility to impingement (4) Source Water Baseline Biological and entrainment; existing data; identification of missing data; Characterization Data threatened and endangered species and designated critical habitat summary for action area; identification of fragile fish and shellfish species list (<30 percent impingement survival). Narrative description of cooling water system and intake structure; proportion of design flow used; water reuse (5) Cooling Water System Data summary; proportion of source waterbody withdrawn (monthly); seasonal operation summary; ;existing impingement mortality and entrainment reduction measures; flow/MW efficiency. Provides facility's proposed approach to meet the impingement Chosen Method of Compliance with mortality requirement (chosen from seven available options); (6) Impingement Mortality Standard provides detailed study plan for monitoring compliance, if required by selected compliance option; addresses entrapment where required. Provides summary of relevant entrainment studies (latent (7) Entrainment Performance Studies mortality, technology efficacy); can be from the facility or elsewhere with justification; studies should not be more than 10 years old without justification; new studies are not required. Provides operational status for each unit; age and capacity utilization for the past 5 years; upgrades within last 15 years; (8) Operational Status uprates and Nuclear Regulatory Committee relicensing status for nuclear facilities; decommissioning and replacement plans; current and future operation as it relates to actual and design intake flow. Identifies the chosen compliance method for the new unit; based on the method selected will provide information to (14) New Units demonstrate closed -cycle cooling or entrainment reductions that are commensurate with closed -cycle cooling; may also include additional data and information, as determined by the Director. 13 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 2 Source Water Physical Data [§122.21(r)(2)] The information required to be submitted per 40 CFR §122.21(r)(2), Source Water Physical Data, is as follows: (i) A narrative description and scaled drawings showing the physical configuration of all source water bodies used by the facility, including areal dimensions, depths, salinity and temperature regimes, and other documentation that supports the applicant's determination of the waterbody type where each cooling water intake structure is located; (ii) Identification and characterization of the source waterbody's hydrological and geomorphological features, as well as the methods used to conduct any physical studies to determine the intake's area of influence within the waterbody and the results of such studies; Locational maps; and, (iv) For new offshore oil and gas facilities that are not fixed facilities, a narrative description and/or locational maps providing information on predicted locations within the waterbody during the permit term in sufficient detail for the Director to determine the appropriateness of additional impingement requirements under §125.134(b)(4). Each of these requirements is described in the following subsections. 2.1 Description of Source Waterbody [§122.21(r)(2)(i)] The ACC withdraws raw water for cooling purposes at the existing CWIS on Lake Julian, the source waterbody. Lake Julian and the adjacent French Broad River are located within the French Broad - Holston River basin, which includes watersheds in North Carolina and Tennessee. The North Carolina portion of the French Broad -Holston River basin is 2,830 square miles and lies entirely in the Blue Ridge ecoregion. The French Broad River originates in Transylvania County, North Carolina, and flows north for 210 miles through western North Carolina into Tennessee, where it joins the Holston River near Knoxville to form the Tennessee River (NCDEQ 2017). The French Broad -Holston River basin is predominantly forested; however, it also contains some of the most populated urban areas in the region, including the mountain municipalities of Asheville, Waynesville, Hendersonville, and Black Mountain, North Carolina. Lake Julian was created to serve as part of the cooling system for the Asheville Plant by impounding Powell's Creek, a tributary of the French Broad River (North Carolina State Board of Health 1963). The freshwater lake reached full -pool elevation in June 1963 and the Asheville Plant began commercial operation in 1964. The shoreline -situated CWIS is located within an intake cove on the main body of Lake Julian. Coal fired operations officially ceased and the combined cycle plant went online 2019/2020. Historically cooling water for the coal-fired units was circulated from the main body of the lake through the plant and into the discharge arm. The water from the discharge arm returned to the intake side of the lake via an opening underneath the railroad trestle (Figure 1-1). The main body of the lake has a surface area of 215 acres, a maximum depth of 108 feet, and a mean depth of 30 feet. Average surface 14 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station water elevation on Lake Julian is approximately 2,160 feet above mean sea level (ft msl). The average impounded volume (at elevation 2,160) is approximately 8,819 acre-feet. Land use in Lake Julian's 4.8-square mile watershed is primarily residential and urban. Lake Julian is a relatively steep -sided, deep lake and prior to the retirement of the coal-fired units devoid of aquatic vegetation and other types of naturally occurring underwater structure, resulting in less than optimal shallow -water fish habitat (Progress Energy 2013). The lake has since seen an increase of aquatic vegetation, covering nearly 60% of the littoral zone sampled in 2021 (DEP 2021b). The increase in mainly native aquatic vegetation is due in part to the recent absence of the non-native herbivorous Blue Tilapia. The cessation in reject heat from steam electric generation to lake Julian has significantly reduced the likelihood of Blue Tilapia over -wintering in the small mountain reservoir (Sections 2.2.3 and 4.2.1). Artificial structures (submerged and cabled trees, fish reefs, etc.) have been placed along shorelines by DEP during periodic fish habitat enhancement activities to improve fish habitat in Lake Julian. Cooling tower make-up water for the ACC units is withdrawn from the existing CWIS on Lake Julian with the cooling tower blowdown being discharged to an existing outfall on the French Broad River. As such, the remainder of this document is focused on Lake Julian, the source waterbody for the ACC CWIS, for establishing compliance with the Rule's impingement and entrainment BTA standards. 2.1.1 Water Quality Water quality data from Lake Julian has been periodically collected by DEP since 1973 as part of an Environmental Monitoring Program (Program). The Program has included periodic data collections targeting water chemistry, phytoplankton, zooplankton, benthic invertebrates, and fish communities (DEP 2023). Water quality sampling for Lake Julian is performed on alternate months (i.e., January, March, May, July, September, and November) at Stations GS2 and D2 (see Figure 2-2). These data are summarized in the following section. Water quality sampling for location GS2 ceased at the end of 2020 following the retirement of the coal-fired units. Water quality and limnological data collected from Lake Julian (Station D2 - near the CWIS) from 2012- 2021 under the Program (DEP 2023) are summarized in Table 2-1. 15 316(b) Compliance Submittal Requirements Asheville Combined Cvcle Station CZ g,h LEGEND Boone Fayette 8 Digit Hydrologic Units Station Location 06010101 - North Fork Holston French Broad -Holston River �J Basin G6010102 - South Fork Holston Raleigh County Boundaries 06010103 -Watauga State Boundaries wyomng Summers 06010104 -Holston CATA SOURCE: MCCC-0 :]1i Mercer 06010105 - Upper French Broad MoDowell 46010106 -Pigeon - _k _­1 f 06010107 - Lower French Broad 0 Miles 25 Giles gland 06010108 - Nolichucky Tazewell U f . t5e f• m N Knox Russell Harlan - Smyth Wythe Bell Whitley �' F nw Scott �ri ashington LPe �g,� Carroll Grayson Clabome Hancock Swim E Haw Johnson All,ghany Um u cn _ r�tw. ._ 40 °"'� R Ashe Surry )(I, Washington rribten A R Greene Sevieri Blount if Bur, mhe $Yiin - Graham Jackson dens Cherokee Macon Trans y is Clay � '— —_ Greenville Towns Rabun Pickens ,lmcn Oconee Whie Habersham Anderson uga VPilkes • *w' Caldwell Alexander Iredell Burke IcOowell Catawba .Asheville Combined -" Cycle Station LinWn ,wa Mid4an Pennsylvania a inois Indiana Ohio West V'rgisia Maryland Debw3 `c lissoun Kentucky Virginia Tennessee i North Camlha rkansas South Cara9ina WssissippiAlabama Georgia ouisiana *bnda Figure 2-1. Map of French Broad -Holston Basin Hydrologic Unit Code 06010105 16 �.:.Or LEGEND f 0 River intake ,u s , . W �3uhrnerged Cuiuert... fish Reefs • Lake Julian oz C'vV1S- Discharge 4 - 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Table 2-1. Annual Mean Concentration for Select Parameters Documented in Surface Water Samples Collected in Lake Julian (Station 1132) (DEP 2022b) Parameter 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 Water Temperature (°C) 24.9 21.5 22.7 23.7 23.7 23.6 22.7 22.5 17.0 16.8 Specific Conductance 110 90 73 82 91 86 80 89 92 87 (PS/cm) Dissolved oxygen (mg/L) 8.1 8.5 7.6 7.5 7.6 7.9 8.2 7.8 8.8 9.1 Total dissolved solids (mg/L) 50 39 44 42 58 40 40 59 57 48 Turbidity (NTU) 2.6 2.6 2.0 1.8 3.0 2.3 1.9 1.2 1.3 0.8 Secchi depth (m) 2.9 2.3 3.9 4.2 3.7 3.2 3.2 3.5 6.4 9.3 Chlorophyll a (Ng/L) 9.9 4.6 3.6 2.2 6.4 3.9 4.0 3.8 1.3 2.5 Nutrients (mg/L) Ammonia-N 0.022 0.031 0.02 0.07 0.016 0.024 0.03 0.024 0.033 0.035 Nitrate + nitrite-N 0.03 0.12 0.24 0.15 0.15 0.04 0.13 0.2 0.14 0.11 Total nitrogen 0.14 0.35 0.45 0.33 0.32 0.36 0.21 0.48 0.43 0.37 Total phosphorus 0.012 0.106 0.012 0.016 0.008 <0.005 0.008 0.006 <0.01 0.02 Total organic carbon (mg/L) 2.5 3.0 2.4 1.8 1.9 1.8 1.9 1.8 1.9 1.7 Ions (mg/L) Calcium 8.9 5.6 2.0 2.8 4.6 3.8 1.8 3.9 5.2 6.3 Chloride 10 8.5 9.3 11.0 11.9 11.3 12.3 12.0 10.7 10.4 Magnesium 2.6 2.3 2.4 2.2 2.5 2.4 2.2 2.3 2.3 2.3 Sodium 5.9 5.0 6.0 7.0 7.9 8.0 8.0 7.6 6.7 6.4 Sulfate 8.2 5.7 5.9 5.2 5.0 4.3 4.0 4.2 4.1 3.4 Total alkalinity (mg/L as CaCO3) 25 20 20 11 18 16 10 30 20 24 Hardness (mg equiv. CaCo3/L) 33 24 24 16 22 19 13 19 23 25 mg/L: milligrams per liter; m: meter; NTU: nephelometric turbidity units pg/L: micrograms per liter; CaCO3/L: calcium carbonate The mean annual nutrient concentrations (i.e., ammonia-N, nitrate+nitrite-N, total nitrogen, total phosphorus, total organic carbon) measured in Lake Julian from 2012 to 2021 were consistent both spatially and temporally, with the exception of total nitrogen. Mean total nitrogen concentrations were elevated in 2014, 2019, and 2020 compared to the remaining data years (i.e., 2012, 2013, 2015, 2016, 2017, 2018 and 2021). Lake Julian has been determined to have low biological productivity (oligotrophic conditions) based on the monthly calculated North Carolina Trophic State Index scores by NCDEQ (NCDEQ 2018b). No adverse trends were observed for water chemistry characteristics of Lake Julian during the period of monitoring. Water clarity (transparency) depth as measured by Secchi disk in Lake Julian was consistently between 2.3 and 3.5 meters (m) during coal fired operation (2012-2019). Once the new combined cycle units went online (2020-2021) water clarity depth as measured by Secchi disk increased to 6.4 and 9.3 respectfully (see Table 2-1). Turbidity was also low with an average of 2.0 NTU across all years. The 18 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station annual mean concentrations of total dissolved solids were consistent over the monitoring period and displayed normal variation typically observed in comparably sized reservoirs in the region. Thermal stratification typically develops during the spring/summer months in the main body of the lake resulting in low dissolved oxygen (DO) conditions (i.e., less than 4 mg/L) in the hypolimnion (the bottom strata of a thermally stratified reservoir or lake). Typically, by November, oxygenated water returns to the deeper portions of Lake Julian after lake turn over (DEP 2023). Historical DO concentrations were consistently greater than 4 mg/L (minimum DO required by most healthy fish) in the epilimnion (DEP 2023). Mean specific conductance data were consistent across the data collection period, with values between 73 micro -Siemens per centimeter (µS/cm) in 2014 to 110 VS/cm in 2012 (Table 2-1). The range of values documented for Lake Julian between 2012 and 2021 is consistent with freshwater systems in the region (DEP 2023). The annual mean surface water temperatures recorded at Station D2 exhibited minimal inter -annual variation during coal fired operation (2012-2019), ranging between 21.5 degrees Celsius (°C) (2013) and 24.9°C (2012) (see Table 2-1). With the commencement of the ACC, blow -down and other byproducts of the units were routed to an existing outfall on the French Broad River and the thermal discharge into Lake Julian was terminated. As a result, the annual average water temperatures in Lake Julian were reduced to 17.0°C (2020) and 16.8°C (2021), more reflective of a small, mountain watershed. 2.2 Characterization of Source Waterbody [§122.21(r)(2)(ii)] To identify and characterize the primary source waterbody (i.e., Lake Julian), the following resources were reviewed: • Duke Energy Environmental Monitoring Program 2012-2021 (DEP 2023). • Ecoregions of North Carolina (Griffith et al. 2002). Data were compiled, synthesized, and are summarized below. 2.2.1 Hydrology Lake Julian is located within the French Broad -Holston Basin, which is divided into eight U.S. Geological Survey hydrologic units, each designated by a Hydrologic Unit Code (HUC). Lake Julian lies within the Upper French Broad River subbasin HUC 06010105 (Figure 2-1). The drainage area of the Upper French Broad River subbasin is approximately 1,864 square miles. 2.2.2 Geomorphology Lake Julian is located within the Blue Ridge Level III ecoregion and, more specifically, the Broad Basins (Level IV) of the Blue Ridge ecoregion. The Blue Ridge ecoregion extends from southern Pennsylvania to northern Georgia and varies in topography from narrow ridges to hilly plateaus to more mountainous areas with high peaks. The mostly forested slopes, high -gradient streams, and rugged terrain occur over a mix of igneous, metamorphic, and sedimentary bedrock (Griffith et al. 2002). 19 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 2.2.3 Determination of Area of Influence — Desktop Calculations Cooling tower make-up water is withdrawn at the Lake Julian CWIS which is comprised of four identical intake bays. Each bay will be equipped with a submersible pump with a design capacity of approximately 1,800 gallons per minute (gpm) (2.6 MGD). The ACC consists of two units (Unit 05/06 and Unit 07/08) that are designed to operate with two pumps (one per unit), with the remaining two pumps providing redundant pumping capacity. As a result, the combined DIF capacity for the new ACC units will be 3,600 gpm (5.2 MGD). However, the provided DIF is improbable due to pump logic configuration which allows only one pump for each unit to operate. The CWIS is equipped with 1-inch hexagonal mesh fixed screens attached to the upstream face of the bar racks and oriented perpendicular to the direction of flow. In addition, new %-inch mesh fixed screens will be installed on the downstream side of the 1-inch hexagonal mesh panels as additional protection for the new submersible pumps. TSV calculations for were performed for the new %-inch mesh screens under low water surface elevations (2,158.0 feet). Inputs used to perform TSV calculations are provided in Table 2-2; the TSV calculation package is provided in Appendix C. The average TSV for the new %-inch mesh screen panels at design flows and low water surface elevation is 0.09 fps (Table 2-2). This calculated TSV is considerably lower than the 0.5 fps threshold used as the BTA standard for impingement mortality (§125.94(c)(2)). Impingement at the CWIS on Lake Julian is negligible because the impingement A01 does not extend beyond the face of the screen. Table 2-2. Summary of Input Parameters for TSV Calculations of CWIS on Lake Julian TSV Calculation Inputs New 1/4-inch Mesh Fixed Screens Unit 05/06 Unit 07/08 Number of screens 2 2 Elevation at bottom of intake (feet) 2,144 2,144 High water surface elevation (ft msl) 2,165 2,165 Low water surface elevation (ft msl) 2,158 2,158 Screen width (feet) 9 feet 2 inches 9 feet 2 inches Mesh size (L) (inches) 0.25 0.25 Mesh size (W) (inches) 0.25 0.25 Mesh gauge number 16 16 Cooling Water Pump Max Rating (gpm) 2900 2900 Cooling Water Pump 2 Max Rating (gpm) 2900 2900 Cooling Water Pump 1 Design Rating (gpm) 1,800 1,800 Cooling Water Pump 2 Design Rating (gpm) 1,800 1,800 TSV at max pump rating and low water surface elevation (fps) 0.14 0.14 TSV at design pump rating and low water surface elevation (fps) 0.09 0.09 20 Ashe ille _ +vannanoa t V A., ��Candle&: • �.. � ••; Biltmore Forest • -, -�-VF,airview "Bent Creek �' =Arden ' t •a fetcher ' '� 4 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 3 Cooling Water Intake Structure Data [§ 122.21(r)(3)] The information required to be submitted per 40 CFR §122.21(r)(3), Cooling Water Intake Structure Data, is outlined as follows: (i) A narrative description of the configuration of each of the cooling water intake structures and where it is located in the waterbody and in the water column; (ii) Latitude and longitude in degrees, minutes, and seconds for each of the cooling water intake structures; (iii) A narrative description of the operation of each of the cooling water intake structures, including design intake flows, daily hours of operation, number of days of the year in operation and seasonal changes, if applicable; (iv) A flow distribution and water balance diagram that includes all sources of water to the facility, recirculating flows, and discharges; and (v) Engineering drawings of the cooling water intake structure. Each of these requirements is described in the following subsections. 3.1 Description of CWIS Configuration [§122.21(r)(3)(i)] Cooling water for the ACC is supplied though the CWIS on Lake Julian situated on the southern shoreline of the western arm of Lake Julian (Figure 3-1). The following sections provide additional information on the configuration and operation of the CWIS on Lake Julian. 22 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Figure 3-1. Asheville Combined Cycle Cooling Water Intake Structure on Lake Julian, Buncombe County, North Carolina The approximately 60-foot-wide CWIS on Lake Julian was originally constructed for the Asheville Plant and has been repurposed for the ACC. The CWIS is comprised of four equally -sized intake bays (referred to as Intake Bays 1, 2, 3, and 4). A summary of the original CWIS major components and those that have been repurposed or replaced is provided in Table 3-1. The general layout of the repurposed CWIS is shown in Figure 3-2. The opening of each of the four intake bays is approximately 21 feet high by 9 feet, two inches wide with an invert elevation of 2,144 ft msl (see drawing G-171048 in Appendix B). Each bay is equipped with a bar rack, two sets of fixed mesh screen panels (1-inch and %-inch), and a submersible make-up cooling water pump. Table 3-1. Original and Repurposed Cooling Water Intake Structure Components Description of Major CWIS Components Unit 05/06 Unit 07/08 Number of intake bays 2 2 Intake bay dimensions 21 feet high x 9 feet, 2 inches wide 21 feet high x 9 feet, 2 inches wide Elevation at bottom of intake (feet) 2,144 2,144 1-inch hexagonal mesh fixed screen panel 2 2 Bar racks 2 2 Y..-inch mesh fixed screen panel 2 2 Once -through condenser cooling water pump capacity (gpm) 2 x 48,300 2 x 61,500 Submersible make-up cooling water pump capacity (gpm) 2 x 1,800* 2 x 1,800* *Units 05/06 and 07/08 are designed to operate using one 1,800 gpm each, the remaining pump is for backup 23 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Figure 3-2. Layout of the Repurposed Lake Julian Cooling Water Intake Structure (not to scale) Near the entrance of the CWIS, 1-inch hexagonal mesh screens (comprised of 19-gauge wire) are overlain on the exterior side of the bar racks (3/8-inch-thick steel bars with 3-inch on center spacing) to help prevent large debris from entering the structure, as illustrated in Figure 3-3. The new %-inch mesh (16-gauge wire) fixed screen panels are located approximately 16.5 feet downstream of the bar racks in the slots formerly used for traveling screens (see drawing G-171048 in Appendix B). The new screens are on the upstream side of the new submersible cooling water make-up pumps and provide an added layer of protection from debris that is able to pass through the outer 1-inch hexagonal mesh screens and bar racks. 24 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Figure 3-3. Photograph of a 1-inch Hexagonal Mesh Screen Panel Employed at the Cooling Water Intake Structure on Lake Julian Each bay is equipped with a submersible pump with a design capacity of approximately 1,800 gpm (2.6 MGD). Raw water is withdrawn from Lake Julian, where it passes through the 1-inch hexagonal mesh screen panels, bar racks, and Y4-inch mesh screen panels before entering the submersible pumps. Design drawings for the Lake Julian CWIS are provided in Appendix B. 3.2 Latitude and Longitude of CWIS [§122.21(r)(3)(ii)] The latitude and longitude (in degrees, minutes, and seconds) of the CWIS on Lake Julian is provided in Table 3-2. Table 3-2. Cooling Water Intake Structure Coordinate Information (Source: DEP 2005, DEP 2007) Intake Latitude Longitude Intake on Lake Julian 35°28'20.7" N 82°32'35.4" W 3.3 Description of CWIS Operation [§122.21(r)(3)(iii)] The ACC facility operates as a base load facility with year-round condenser cooling water operations. The ACC operates by utilizing one 1,800 gpm (2.6 MGD) capacity pump per Unit (power block) for a total facility DIF of 5.2 MGD. Raw water pump 5A or 56$ supplies raw water, including cooling water, to Unit 05/06 and raw water pump 7A or 7B supplies raw water, including cooling water, to Unit 07/08 (Figure s Each of the power blocks are operated with cooling water supplied from one of the two pumps dedicated to the power block. For example, with Units 05/06 only one of the two pumps (5A or 513) will be actively pumping water at any given time. The remaining pump serves as a redundant pump to maintain operations during scheduled or unplanned repairs to the other pump. 25 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 3-2). Note only two pumps (one for each power block) will be operational at any one time, with the remaining two pumps providing redundant pumping capacity. Table 3-3. Number of Hours of Unit 05/06 Cooing System Operation at ACC in 2020-2022. 2020-2022 Month 2020 2021 2022 Average January 736 744 707 729 February 687 672 624 611 March 529 743 743 672 April 287 80 24 130 May 119 152 0 90 June 226 539 606 457 July 744 711 743 733 August 744 744 744 744 September 500 720 720 647 October 744 505 744 664 November 538 278 721 512 December 552 565 611 576 Total Number of Hours 6406 6453 6987 6615 Table 3-4. Number of Hours of Unit 07/08 Cooling System Operation at ACC in 2020-2022. 2020-2022 Month 2020 2021 2022 Average January 594 744 744 694 February 511 537 587 545 March 195 585 575 452 April 672 703 687 687 May 498 742 744 661 June 684 720 720 708 July 742 664 744 717 August 740 609 707 685 September 595 551 378 508 October 82 346 5 144 November 590 721 534 615 December 744 707 744 732 Total Number of Hours 6647 7629 7169 7148 26 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 3.4 Description of Intake Flows and Water Balance [§122.21(r)(3)(iv)] Monthly average water withdrawals from 2020 through 2022 are provided in Table 3-5. The average withdrawal for this period was 2.6 MGD from the raw water intake compared to a DIF of 5.2 MGD. The Water Balance Diagram for ACC is provided in Table 5-1. Table 3-5. Monthly Withdrawals (MG) from ACC Intake during 2020-2022 to Support Plant Operations. Month 2020 2021 2022 2020-2022 Average January 34.2 74.9 98.5 69.2 February 36.4 67.4 87.3 63.7 March 45.4 80.1 102.6 76.0 April 47.2 63.6 89.1 66.6 May 60.2 70.8 94.7 75.2 June 69.0 84.4 110.7 88.1 July 88.8 90.1 117.9 99.0 August 91.9 90.1 120.1 100.7 September 76.1 80.2 101.3 85.8 October 57.9 64.1 85.4 69.1 November 67.1 69.4 98.0 78.2 December 69.1 82.3 96.5 82.6 Annual Average 62.0 76.4 100.2 79.5 3.5 Engineering Drawings of CWIS [§122.21(r)(3)(v)] A list of design drawings for the CWIS on Lake Julian is provided in Table 3-6 and the drawings are provided in Appendix B. Table 3-6. List of Engineering Drawings for ACC Intakes Structure Type Drawing No. Drawing Title CWIS on Lake Julian As -built C-219-D Concrete Intake Structure CWIS on Lake Julian (Unit 1 Plan &Sections G-170903 Cooling Water System Intake - Intake) MAS SH NO 1 CWIS on Lake Julian Plan & Sections G-171048 Intake Steel & Screens Y..-inch Mesh Fixed Screen General Arrangement E117624 Static Screen Panel 27 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 4 Source Water Baseline Biological Characterization Data [§122.21(r)(4)] The information required to be submitted per 40 CFR §122.21(r)(4), Source Water Baseline Biological Characterization, is outlined as follows: (i) A list of the data supplied in paragraphs (r)(4)(ii) through (vi) of this section that are not available, and efforts made to identify sources of the data; (ii) A list of species (or relevant taxa) for all life stages and their relative abundance in the vicinity of CWIS; (iii) Identification of the species and life stages that would be most susceptible to impingement and entrainment; (iv) Identification and evaluation of the primary period of reproduction, larval recruitment, and period of peak abundance for relevant taxa; (v) Data representative of the seasonal and daily activities of biological organisms in the vicinity of CWIS; (vi) Identification of all threatened, endangered, and other protected species that might be susceptible to impingement and entrainment at a cooling water intake structure(s); (vii) Documentation of any public participation of consultation with Federal or State agencies undertaken in development of the plan; (viii) Methods and QA procedures for any field efforts; (ix) In the case of the owner or operator of an existing facility or new unit at an existing facility, the Source Water Baseline Biological Characterization Data is the information included in (i) through (xii); (x) Identification of protective measures and stabilization activities that have been implemented, and a description of how these measures and activities affected the baseline water condition in the vicinity of CWIS; (xi) List of fragile species as defined at 40 CFR 125.92(m) at the facility; and (xii) Information submitted to obtain incidental take exemption or authorization for its cooling water intake structure(s) from the U.S. Fish and Wildlife Service or the National Marine Fisheries Service. Each of these requirements is described in the following subsections. 28 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 4.1 List of Available Biological Data [§122.21(r)(4)(i)] The biological data needed to prepare the information required under 40 Code of Federal Regulations (CFR) §122.21(r)(4) are available. The 2012-2021 Environmental Monitoring Report (DEP 2023) was used to develop the baseline biological characterization of the source waterbody, Lake Julian. This report was developed utilizing the existing, available data for Lake Julian. As the selected ACC technology is fully compliant with the Rule, no impingement or entrainment studies were performed in support of the development of this compliance documentation. No additional studies were performed to support the baseline biological characterization for the proposed ACC. 4.2 List of Species and Relative Abundance in the vicinity of CWIS [§122.21(r)(4)(ii)] Since 1973, DEP has performed periodic sampling of the fish community at multiple locations within Lake Julian (Figure 4-1). The objectives of the Lake Julian Environmental Monitoring Program (Program) are to assess the lake's overall water quality and the fishery community and document the introductions and/or possible impacts of non-native or exotic species to the lake. The following sections summarize the data collected from Lake Julian under the Program. 4.2.1 Lake Julian Environmental Monitoring Program Under the Program, as described in Section 2, data are collected and used to characterize the fish community in Lake Julian. Data from sampling activities performed on Lake Julian from 2012 through 2021 are summarized below. Historically DEP, previously Carolina Power & Light Company (CP&L), performed nighttime boat electrofishing at 30 shoreline sampling locations in Lake Julian, representing 6 shoreline habitat types (CP&L 2001). These long-term sampling locations are shown on Figure 4-1. The entire length of the shoreline for each sampling location was sampled and catch rates were adjusted to number per hour of sampling time. Since 2012, annual nighttime boat electrofishing sampling has been performed, consisting of a spring and fall sample at 16 shoreline locations in Lake Julian representing the same 6 shoreline habitat types (DEP 2023). The entire length of the shoreline for each sampling location was sampled and catch rates were adjusted to number per hour of sampling time. The only exceptions are 2013, 2017, and 2020 no sampling occurred. Additionally, sampling only occurred once per year in 2019 (spring) and 2021 (fall). Relative abundance for the species collected during electrofishing of Lake Julian (2012-2021) is summarized in Table 4-1. Species composition in Lake Julian has remained fairly consistent, varying between 12 species in 2019 and 16 species in 2014. Length frequency data indicated that recreational species such as Bluegill (Lepomis macrochirus), Redear Sunfish (Lepomis microlophus), Redbreast Sunfish (Lepomis auratus), Largemouth Bass (Micropterus salmoides), and Alabama Bass (Micropterus henshalli) exhibit both adequate reproduction and recruitment for a self-sustaining population. 29 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Figure 4-1. Shoreline Habitat Types and Locations Sampled with Nighttime Electrofishing in Lake Julian, 2012- 2021(CP&L 2001, DEP 2023) 30 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Table 4-1. Relative Abundance of Fish Collected in Electrofishing Samples on Lake Julian, 2012, 2014, 2015, 2016, 2018, 2019, 2021(DEP 2023). Scientific Name Common Namea 2012 2014 Relative Abundance (Percent) 2015 2016 2018 2019c 2021c Lepomis macrochirus Bluegill (R) 76.2 58.7 39.2 45.7 45.8 48.7 34.5 Lepomis spp. Hybrid Sunfish (R) 10.8 12.5 11.4 16.4 12.1 6.5 5.3 Lepomis auratus Redbreast Sunfish (R) 0.4 1.7 2.4 4.4 6.5 8.2 9.2 Lepomis cyanellus Green Sunfish (R) 5.0 9.0 17.4 13.1 7.1 3.1 8.9 Lepomis gulosus Warmouth (R) 0.1 1.5 1.7 0.5 0.1 0.1 0.9 Lepomis microlophus Redear Sunfish (R) 1.5 2.6 5.7 5.4 7.5 7.7 2.7 Micropterus salmoides Largemouth Bass (R) 1.4 3.2 3.2 3.9 4.0 7.9 12.4 Micropterus henshallib Alabama Bass (R)b 1.2 5.6 6.4 4.8 10.1 9.9 25.2 Micropterus sp. Largemouth Bass x Alabama Bass Hybrid (R) - - - < 0.1 - - 0.1 Pomoxis nigromaculatus Black Crappie (R) < 0.1 < 0.1 < 0.1 - 0.2 0.1 0.1 Ictalurus punctatus Channel Catfish (R) 1.0 1.6 2.2 2.1 1.1 3.3 0.6 Ameiurus platycephalus Flat Bullhead (R) - - - - < 0.1 - <0.1 Dorosoma petenense Threadfin Shad (F) < 0.1 1.0 7.7 3.0 3.6 - - Dorosoma cepedianum Gizzard Shad (F) - - - < 0.1 - - - Alosa pseudoharengus Alewife (F) < 0.1 - - - - - - Tilapia aurea Blue Tilapia (E) 2.3 2.5 2.5 0.7 2.0 4.5 Pterygoplichthys pardolis Amazon Sailfin Catfish (E) - < 0.1 0.1 - < 0.1 0.1 Ctenopharyngodon idella Grass Carp (S) - - - < 0.1 - - Gambusia holbrooki Eastern Mosquitofish (F) - < 0.1 - - - - Carassius auratus Goldfish (F) - < 0.1 < 0.1 - - - Etheostoma flabellare Fantail Darter (F) - - - - - - < 0.1 a) R: Recreational; F: Forage; E: Exotic, non-native; S: Stocked b) Previously referred as Spotted Bass (Micropterus punctulatus) c) 2019 sampled in spring and 2021 sampled in the fall. 31 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 4.2.2 Conclusions from Lake Julian Sampling Program Long-term fish community monitoring results indicate the fish community is not dominated by pollution - tolerant species, but rather by native sunfish (centrarchids) and other recreational species from multiple size classes indicating a biological community with the capacity to sustain themselves through cyclic seasonal changes (DEP 2023). Two exotic (non-native) species were also documented in Lake Julian, (i.e., Blue Tilapia [Tilapia aurea] and Amazon Sailfin Catfish [Pterygoplichthys pordalis]). The Amazon Sailfin Catfish was first documented during 1997 and was most recently collected in 2019, although relative abundance was low at 0.1 percent (DEP 2022b). In 1965, Blue Tilapia were experimentally stocked by the North Carolina Wildlife Resources Commission to provide additional forage for Largemouth Bass. Blue Tilapia subsequently became established in Lake Julian; however, results from periodic electrofishing studies consistently indicate low relative abundance (varying between 0.7 to 4.5 percent from study data collected between 2012 and 2019). Changes associated with operation of the ACC facility (i.e., elimination of the thermal plume in Lake Julian) did not result in an adverse environmental impact to the native aquatic organisms in Lake Julian because they are naturally adapted to the ambient conditions of Lake Julian (a small, mountain lake). However, populations of the exotic Blue Tilapia and Amazon Sailfin Catfish are expected to be reduced or eliminated from Lake Julian with the removal of the thermal inputs from the retired coal fired station. During our sampling post thermal discharge (2021), no Blue Tilapia or Amazon Sailfin Catfish were observed. Additionally, Threadfin Shad, a fragile species that typically experiences varying levels of winter mortality in response to cold shock were absent in the 2019 and 2021 surveys. As such, the removal of thermal inputs may result in winter mortalities or potentially lead to the reduction and potential elimination of this species in Lake Julian. 4.3 Identification of Species and Life Stages Susceptible to Impingement and Entrainment [§122.21(r)(4)(iii)] 4.3.1 Impingement The degree of vulnerability to impingement exhibited by adult and juvenile fish species depends upon biological and behavioral factors including seasonal fish community structure, spawning effects on distribution, habitat surrounding intake structures, high flow events, and attraction to the flow associated with the intake. In addition, swimming speed, intake velocity, screen mesh size, trash rack spacing, and other intake configurations will also affect the susceptibility to impingement. For example, clupeids have high susceptibility to impingement based on multiple factors such as schooling behavior, distribution in the water column, negative rheotactic response to intake flows, and poor swimming performance in winter months due to lower water temperatures (Loar et al 1978). No ongoing or historical impingement studies have been performed at the CWIS on Lake Julian. The ACC makeup cooling water is withdrawn from Lake Julian through fixed mesh screen panels with a TSV of much less than 0.5 fps; thus, the ACC closed -cycle cooling system design is fully compliant with Compliance Alternative 2 (§125.94(c)(2)). As such, no species or life stages are anticipated to be 32 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station susceptible to impingement at the Lake Julian CWIS. In addition, the ACC's closed -cycle recirculating cooling water system (CCRS) is compliant with §125.94(e)(1). 4.3.2 Entrainment Ichthyoplankton, which is defined as the egg and larval life stage of fishes, exhibit the highest degree of susceptibility to entrainment based on body size and swimming ability. Therefore, an organism will spend only a portion of its life cycle susceptible to entrainment, as larger juvenile and adult life stages are excluded by screens at the CWIS. Life history characteristics can influence the vulnerability of a fish species to entrainment. For example, broadcast spawners have free-floating eggs which drift with water currents and can be entrained in a CWIS; however, species with adhesive eggs or nest building species will be less susceptible to entrainment of early life stages. DEP has regularly performed electrofishing surveys in Lake Julian near the CWIS. Historical electrofishing sampling results for Lake Julian were used to determine species composition of Lake Julian and to identify those species potentially susceptible to entrainment at the CWIS on Lake Julian. The evaluation of species -specific susceptibility to entrainment is presented in Table 4-2. Based on the anticipated make-up water withdrawal volumes that will be required for operation of the ACC, and the calculated TSV values presented in Section 3, interactions with aquatic organisms are expected to be limited, with an extremely low potential for adverse environmental impacts. Two species in Lake Julian are considered "potential to be" susceptible to entrainment, Gizzard and Threadfin Shad (Table 4-2) are broadcast spawners with high fecundity. While there is some potential for species in Lake Julian to be susceptible to entrainment, the low TSV and low make-up water withdrawal rate at this facility are expected to minimize entrainment and related potential for adverse impacts to the biological community. Table 4-2. Entrainment Potential for Fish Species Identified in Lake Julian Species Habitat Use/Preference Potential for Entrainment' (Common Name) Centrarchidae Construct nests around vegetation Unlikely due to water depth in the vicinity of the CWIS, Black Crappie close to other nests demersal and adhesive eggs, parental care of nest until larvae swim -up Nest generally constructed in shallow Unlikely due to water depth in the vicinity of the CWIS, Bluegill waters demersal and adhesive eggs, parental care of nest until larvae swim -up Green Sunfish Construct nests around vegetation Unlikely; limited quantity of vegetation available in the vicinity of the CWIS Largemouth Bass Nest constructed in shallow areas of Unlikely due to water depth in the vicinity of the CWIS one to six feet Redbreast Sunfish Construct nests over silt -free or lightly Unlikely; specific substrate type not present silted sand and gravel in cover 33 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Species Habitat Use/Preference Potential for Entrainment* (Common Name) Unlikely due to water depth in the vicinity of the CWIS, Redear Sunfish Nest generally constructed in shallow demersal and adhesive eggs, parental care of nest until waters larvae swim -up Unlikely due to water depth in the vicinity of the CWIS, Alabama Bass Nest builder demersal and adhesive eggs, parental care of nest until larvae swim -up Warmouth Construct nests in cover Unlikely; no cover near intake Cichlidae Nest builders and young develop Unlikely due to habitat preference, life history Blue Tilapia inside of female requirements, and reproduction tendency Clupeidae Alewife Broadcast spawners Unlikely due to low numbers Gizzard Shad Broadcast spawners Potential, broadcast spawner increases susceptibility Threadfin Shad Broadcast spawners Potential, broadcast spawner increases susceptibility Cyprinidae Lays adhesive eggs in shallow Unlikely due to absence of shallow, vegetated habitat in Goldfish vegetation, introduced species the vicinity of the CWIS Demersal eggs, stocked populations Grass Carp are triploid and sterile. Illegal to stock Unlikely; stocked species are triploid and sterile this species unless triploid Ictaluridae Brown Bullhead Females lay eggs in dark shallow areas Unlikely due to habitat preference under rocks and inside logs Cavity nesters, found in large open Channel Catfish areas with woody debris, bank Unlikely due to habitat preference cavities; moderate currents Flat Bullhead Cavity nesters Unlikely due to habitat preference Loricariidae Amazon Sailfin Unlikely due to habitat preference and life history Catfish Lay eggs in burrows and guard eggs requirements Poeciliidae Eastern Young develop inside female Unlikely because they are live -breeders Mosquitofish *TSV below 0.5 fps at the CWIS will minimize potential for entrainment for all species based on their ability for avoidance of the intake. Species with floating eggs would continue to have some susceptibility to entrainment. The retirement of the Asheville Plant and operation of the new ACC reduces the potential for entrainment on Lake Julian and results in a reduction of total withdrawal volumes at the intake structure. The change from once -through cooling to closed -cycle cooling therefore has a reduced potential impact on the health of the fishery and reduces the potential for entrainment on Lake Julian. 34 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 4.3.3 Life History Information for Species Susceptible to Entrainment A subset of species present in Lake Julian with the likelihood to be entrained was selected for detailed life history descriptions including reproduction, recruitment, and peak abundance. Threadfin Shad and Gizzard Shad were selected as target species because of their respective reproduction strategy (i.e., broadcast spawner or floating eggs). Bluegill was also selected as a target species because it was the most abundant species in historical electrofishing collections, is a substantial contributor to the recreational fishery, and is an important forage species for game fish. Other selected species that contribute to the recreational fishery of Lake Julian and were among the most dominant species collected in historical electrofishing sampling include Green Sunfish, Largemouth Bass, and Alabama Bass. Of the selected species, Gizzard Shad is recognized as having the highest potential for entrainment at the CWIS. • Threadfin Shad Spawning occurs in shallow waters such as near shorelines or riverbanks. Threadfin Shad spawn from April to Jul in water temperatures above 16°C between dawn and sunrise. Spawning occurs near the shoreline and over aquatic plants and other submerged objects with eggs that are demersal and adhesive. Threadfin Shad are sensitive to sudden changes in water temperature and oxygen content resulting in frequent die -offs in late summer and winter. • Gizzard Shad Gizzard Shad spawning can occur from mid -March to late August, with peak population spawning in May and June at water temperatures ranging from 15.6-22.8'C (Wallus et al. 1990). They spawn in large schools and their adhesive eggs are deposited on roots, fibers, and debris along the shore (Miller 1960). Gizzard Shad are extremely prolific spawners and can deposit as many as 400,000 eggs at one time (Tomelleri and Eberle 1990). • Bluegill Bluegill occur in most rivers and lakes in the southeastern U.S. and are frequently found in backwater habitats containing vegetation and woody debris. Bluegill spawn at water temperatures between 19.4 and 26YC (Cornish and Welke 2004; Spotte 2007). The spawning season begins in spring or early summer when the water temperature reaches approximately 21.1°C with the peak of spawning in the mid -Atlantic region occurring in May or June. Individual fish may spawn several times within the same season (Rohde et al. 1994). Bluegill are colonial breeders in the sense that spawning fish build nests that are usually in close proximity to each other. Males construct nests that are approximately 1-foot in diameter in shallow water (i.e., depths of 1 to 3 feet). The eggs from several females can be fertilized and deposited in the nest, which is then defended by the male until the eggs have hatched. Because the nests are located in shallow depths, water level fluctuations can severely impact successful reproduction as nests can be stranded by low water level or disrupted by strong wave action. The adhesive eggs hatch after 72 hours 35 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station at 22.2°C and 34 hours at 26.7°C (Cornish and Welke 2004). The yolk sac is absorbed when larvae are 6 millimeters long, at which time they leave the nest and move into littoral vegetation. Fry are free swimming after approximately 10 days (Carlander 1977). Fecundity ranges from 2,000 to 8,000 eggs at age 3 and up to 60,000 eggs at ages 4 to 8. • Green Sunfish Green Sunfish have a wide tolerance to many different aquatic conditions. They prefer smaller, low - velocity streams and ponds but can inhabit lakes with weedy shorelines and shallow rivers. Green Sunfish are tolerant to both turbid and clear water (Etnier and Starnes 1993). Green Sunfish have an extended spawning period from June to August during which time a single male will construct several nests (Hunter 1963). Green Sunfish are prolific colonizers and are tolerant of warm, turbid water making them the most abundant and adaptable of all the sunfishes. Spawning occurs when the water temperature rises above 21°C. Bluegill and Green Sunfish have similar fecundity rates and produce approximately up to 50,000 eggs. Eggs hatch after 1 to 2 days and generally stay with the male for 5 to 7 days for protection before the fry become independent. • Largemouth Bass Largemouth Bass spawn when water temperatures reach 15.6-23.9 °C (Heidinger 1975). The male builds a nest in substrate typically comprised of rocky sand or gravel and cleared of organic debris and silt (Emig 1966; Rohde et al. 1994; Pflieger 1997). The nests are 2 two 3 feet in diameter and usually widely spaced (i.e., 30 feet apart) unless the available nesting area is limited. Nests are built in areas of no current or wave action (Pflieger 1997) at depths of 1 to 15 feet. Males remain at the nest to fan the eggs to keep them silt -free and to protect the young for up to two weeks (Pflieger 1997). Eggs hatch in 2 to 5 days (Emig 1966) and the fry form tight schools over the nest and begin to feed in five to eight days. The schools break up approximately 1 month after hatching when the young bass are approximately one inch long. Growth rates are variable and depend on the lake productivity and food availability. Largemouth Bass typically mature at about ages 1 to 2 in the region (Carlander 1977; Rohde et al. 1994), or when they reach approximately 10 inches long (Pitlo et al. 2004). • Alabama Bass Alabama Bass were once thought to be a subspecies of Spotted bass (M. punctulatus). Morphological characteristics and DNA analyses revealed that was not the case and taxonomic revision was necessary (Rider et al. 2015). The natural range of the Alabama Bass is the Mobile River basin of Alabama, Georgia, and Mississippi. Illegal introductions by anglers were made in basins in South Carolina, North Carolina, and Tennessee. Unlike Largemouth Bass that thrive in shallow turbid reservoirs Alabama Bass prefer clear reservoirs with rocky substrate. Although little has been described we assume young males construct nests in shallow littoral areas (Rider et al. 2015). Spawning occurs in late spring, typically April. Males then guard the fry for a short period of time. It is reported that fecundity of Alabama Bass is less than Largemouth Bass ranging from 1,500 to 7,200 eggs. 36 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 4.4 Identification and Evaluation of Primary Growth Period [§122.21(r)(4)(iv)) Fish are cold blooded, thus primary growth occurs when water temperatures are 10°C or above. The conventional view on seasonal variation in fish growth in North America is that growth is fastest in the spring and early summer, slows in the late summer and fall, and virtually stops in the winter (Gebhart and Summerfelt 1978). The majority of fishes will have their highest densities shortly after the hatch occurs when larvae are concentrated, and natural mortality has not yet reduced numbers. Feeding competition is especially important during late spring through early summer when the bulk of fish are in their early life stages and are more susceptible to starvation (May 1974). This is a critical stage in development, where larval fish have a short time period to initiate exogenous feeding before starving (Ehrlich 1974; Miller et al. 1988). Fish reproduction for the species in Lake Julian occurs via external fertilization', which is principally controlled by water temperatures. Fish reproduction has the potential to produce high yields; however, mortality rates can also be high compared to other organisms. Additionally, a majority of fish spawn only once a year regardless of prior success. Fecundity, the number of eggs a female produces, can vary depending on the life history of the species. Species -specific spawning information is summarized in Section 4.4 of this report (Seasonal and Daily Activities of Organisms in the Vicinity of the CWIS). Monitoring data collected on Lake Julian indicate the presence of multiple size classes indicating good reproductive success. Generally, larval recruitment to the juvenile life stage in North Carolina begins in November and continues until April or May, depending on the life history strategy of individual species (Page and Burr 2011). As a result, peak larval fish entrainment also commonly occurs during the period immediately prior to larval recruitment to the juvenile or young -of -year stage. During this period, the smaller larval stage fish are less adept at maintaining their position in currents compared to larger fish and are more susceptible to entrainment. The majority of the native fish species present in Lake Julian are nest builders; the eggs remain in the nest and newly hatched larvae do not travel far from the nest. Others are broadcast spawners with demersal and adhesive eggs that stick to the substrate. 4.4.1 Period of Peak Abundance for Relevant Taxa Fish spawning is a direct function of water temperature, and most activity is constrained to the spring and early summer months. As a result, an influx of egg, larval, and juvenile fishes occur in Lake Julian each year when water temperatures begin to rise. Under ACC operations, spawning is anticipated to initiate around March or April. As such, peak abundance for most early life stages and juvenile fishes in 9 The release of both sperm and egg outside of an organism is defined as external fertilization. 37 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Lake Julian is expected to occur between April and June depending on each species' unique spawning habitats, as presented in Table 4-2. Table 4-3. Known Spawning and Recruitment Period of select Species with Documented Occurrence in Lake Julian, North Carolina (Sources: Rider et al. 2015; Rohde et al. 1994; Rohde et al. 2009; Etnier and Starnes 1993) Name Common Name Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Black Crappie Bluegill Green Sunfish Largemouth Bass Largemouth X Centrarchidae Alabama Bass Hybrid Redbreast Sunfish Redear Sunfish Alabama Bass Warmouth ■ Gizzard Shad Clupeidae Threadfin Shad Goldfish Cyprinidae Grass Carp Brown Bullhead Ictaluridae Channel Catfish Flat Bullhead Poeciliidae Eastern Mosquitofish ■ ® Gray -shaded months indicate the known spawning Darker -shaded months and recruitment period. indicates period of potential ■ peak abundance. Note: The data presented here represent the spawning and recruitment windows that are typical of the region and that are anticipated for Lake Julian after operations of ACC begin. 38 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 4.5 Data Representative of Seasonal and Daily Activities of Organisms in the Vicinity of CWIS [§122.21(r)(4)(v)] There are no diadromous fish species in Lake Julian. Most species undergo short or local migrations for spawning and/or overwintering. Table 4-3 summarizes seasonal (i.e., spawning) and daily (i.e., feeding and habitat preference) activities for species observed in Lake Julian. Table 4-4. Seasonal and Daily Activities of select Species Present in Lake Julian (Sources: Rider et al. 2015; Rohde et al. 2009; Rohde et al. 1994; Etnier and Starnes 1993) Species (Common Name) Seasonal Activities/Spawning Migration Daily Activities/Daily Migration/Habitat Centrarchidae Usually found in vegetated areas of backwaters in streams Spawning occurs from late February to early May. and rivers in ponds and reservoirs. Prefer clearer and cooler Black Crappie Nests are constructed in shallow water sometimes in waters than White Crappie. Young Black Crappie feed on close proximity to each other. aquatic insects and small fishes and adults feed primarily on fishes. Tolerant of many conditions and utilize most of the habitats Spawning occurs from May through the end of available to the species in North Carolina. Natural habitats Bluegill summer (typically August) with a peak generally in are pools in creeks and rivers, swamps, oxbow lakes, June. Colonies of nests are constructed by males in impoundments, and ponds, with cover of vegetation, shallow water areas on variable substrates. submerged wood, or rocks. Their diet consists of aquatic insects, small fishes, and crayfishes. Prefer slow pools and backwaters of low- and moderate Spawning occurs from April through August. Colonies gradient streams and rivers, but also occur in ponds, lakes, Green Sunfish of nests are almost always constructed near shelter and reservoirs. Highly tolerant of conditions such as turbidity such as a log or clump of vegetation. and drought and can rapidly colonize new habitats. Food preferences are aquatic insects and small fishes. Spawning occurs late April to June. Nests are Largemouth Bass generally located in sand or gravel at the base of logs, stumps, and emergent vegetation along shorelines. Spawning generally occurs from late May through the end of July, with a peak in June. Nests are larger Redbreast Sunfish saucer -shaped depressions swept out in a substrate of coarse sand and gravel and typically made in shallow water. Occupy a wide variety of habitats. Prefer warm, calm, and clear water and thrive in slow streams, farm ponds, lakes, and reservoirs. Adults feed on fishes, frogs, and almost any other animal of appropriate size. Typically found in pools and backwaters of streams and rivers of low to moderate gradient where the species is usually associated with woody debris, stumps, and undercut banks. Preferred foods include terrestrial insects, aquatic insects, small clams, and fishes. Spawning generally occurs from late spring to early Found in a variety of habitats in ponds, lakes, reservoirs, swamps, sluggish streams, small rivers, and backwaters often Redear Sunfish summer. Nests are constructed in colonies in shallow in or near vegetation and over a mud or sand bottom. Prefer waters. to feed on hard invertebrates such as snails and small clams. Spawning occurs in late spring, typically April. The Alabama Bass males construct nests in littoral areas and guard fry for a short time. Spawning occurs from late spring through mid- Warmouth summer. Males construct solitary, circular nests in silty debris usually associated with some type of cover in shallow water. Cichlidae Blue Tilapia 1 Young develop inside of female Prefer reservoirs and medium to larger streams and rivers. Often inhabit deeper water and found on rocky points and bluffs. Primarily piscivorous but a large portion of their diet comprised of crayfishes. Prefer sluggish or still waters of streams, swamps, bays, and reservoirs, especially in shallow and well vegetated areas. They eat only crayfishes and insects. Nest builders 39 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Species Seasonal Activities/Spawning Migration Daily Activities/Daily Migration/Habitat (Common Name) Clupeidae Spawning occurs in the spring, from March through Inhabit fresh and saltwater ecosystems. In freshwater Alewife May, usually near the surface and in large landlocked systems (like Lake Julian), Alewife school in pelagic regions of the waterbody following prey, primarily aggregations. zooplankton. Inhabit lakes, ponds, pools, and backwaters of low -gradient Spawning occurs in the spring and summer, from streams. Gizzard Shad are filter feeders, consuming Gizzard Shad March through August, usually near the surface and copepods, cladocerans, phytoplankton and zooplankton. in large aggregations. Feeding activity is highest during the day with minimal activity at night. Spawning occurs in aggregations at near surface Inhabit a variety of habitats but is considered a pelagic Threadfin Shad depths often over structure. Eggs are demersal and schooling fish. Filter feeders that strain the plankton from the adhere to vegetation and brush. mid -water column, open water. Cyprinidae Spawning occurs in the spring and summer. Adhesive This benthic species is commonly found in still water of lakes, Goldfish eggs are scattered. reservoirs, ponds, rivers, and quite streams dominated by vegetation. It tolerant clear or turbid waters. During spawning season, Grass Carp will migrate up Found in quiet or slow -moving waters, in ponds, lakes, pools, Grass Carp rivers. They typically lay eggs over shoals and a large and backwaters of larger rivers. Young are known to eat female can produce more than a million eggs. small invertebrates and microcrustaceans while adults are omnivorous. Ictaluridae Occur over soft substrates in pools, slow -moving creeks, and Brown Bullhead Spawning begins in April and May and continues into any -sized rivers and in various lentic habitats. They are late summer; adults build circular, shallow nests. bottom feeders with a wide variety of diet consisting of crustaceans, insects, worms, algae, mollusks, and fishes. Channel Catfish Spawning begins in April and May and continues into early summer. Flat Bullhead Spawning occurs in June and July, at water temperatures of 21-24'C. Loricariidae Inhabit a wide range of habitats from small to large creeks, rivers, reservoirs, and ponds. The species can occur over a range of substrates. The young feed on plankton and aquatic insect larvae while juveniles and adults prefer crayfishes, mollusks, immature mayflies, and caddisflies. Occupy a variety of habitats. Adults are more common in slow areas of rivers with a mud or sand bottom and organic debris. The young frequently inhabit smaller, clearer streams. Prefer aquatic insects, small fishes, and snails. Amazon Sailfin Introduced species that excavates riverbanks to Catfish create burrows in which an attracted female will lay Feeds on algae, benthic organisms, and detritus. and guard her eggs. 1 Likely not currently present within Lake Julian due to the reduced discharge of heat. Water column migration or diel vertical migration in Lake Julian is typical for fish species that inhabit lacustrine environments. During a daily cycle, zooplankton and fish exhibit synchronized movements up and down in the water column and this movement is referred to as diel vertical migration (Brierley 2014). Diel vertical migration in freshwater fish is primarily triggered by the diel change in light intensity, with declining illumination at dusk triggering the ascent to the surface and increasing illumination at dawn triggering the descent back to deeper water (Mehner 2012). This is the typical pattern for many species; however, reverse migration can also occur. Additional triggers for vertical migration include hydrostatic pressure and water temperature, which may guide fish into particular water layers at night 40 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station (Mehner 2012). Pelagic (open water) organisms use diel vertical migration to balance the competing objectives of growing quickly and minimizing predation risk. In fish species that perform diel vertical migration, there are two similar ecological traits: 1) they are planktivorous; and 2) they require cold or cool water and live primarily in the pelagic zone of deep, thermally stratified lakes (Mehner 2012). In Lake Julian, diel vertical migration can be considered characteristic of many freshwater fish species, particularly juveniles or species that are small in adulthood. 4.6 Identification of Threatened, Endangered, and Other Protected Species Susceptible to Impingement and Entrainment at CWIS [§122.21(r)(4)(vi)] The Rule requires the permittee to document the presence of federally listed species and designated critical habitat in the action area (see 40 CFR 125.98[f]). For the purpose of defining listed species, the action area is defined as Lake Julian. A desktop review of available resources was performed to develop a list of species with protected, endangered, or threatened status that might be susceptible to impingement and entrainment at the CWIS on Lake Julian. The USFWS' map -based search tool (Information for Planning and Consultation [IPaC]) was used to identify state or federally listed rare, threatened, or endangered (RTE) aquatic species or critical habitat designations within Lake Julian. The North Carolina Natural Heritage Program was consulted for state -protected species. Because the ACC is located in a freshwater environment, marine and anadromous federally listed species and designated critical habitat under National Marine Fisheries Service jurisdiction were not considered. State or federally listed RTE aquatic species or critical habitat designations for Buncombe County, North Carolina, are provided in Table 4-5. Federal species of concern and candidate species were omitted from the list (unless they were also state threatened or endangered), as there are no requirements to address those species under the Rule or Section 7 of the Endangered Species Act. Table 4-5. Rare, Threatened, or Endangered (RTE) Aquatic Species Listed for Buncombe County, North Carolina, and Record of Occurrence or Potential to Occur in Lake Julian Scientific Name Common Name Status* Record of occurrences or potential to occur in Lake Julian Polyodon FSC, No record of occurrence in Lake Julian. athula s P Paddlefish SE Very low - believed extirpated from the region, never collected in electrofishing samples taken near the CWIS Erimonax Spotfin No record of occurrence in Lake Julian. monachus Chub FT, ST Very low - believed extirpated from the region, never collected in electrofishing samples taken near the CWIS 41 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Scientific Common Status" Record of occurrences or potential to occur in Lake Julian Name Name No record of occurrence in Lake Julian. Very low - occurs in lotic habitat (riverine), never documented in Alasmidonta Appalachian FE, SE Lake Julian and host fish not documented in Lake Julian; not raveneliana Elktoe io collected in recent survey of French Broad River (Alderman 201510, NCDNCR 2022) No record of occurrence in Lake Julian. Very low - occurs in lotic habitat (riverine), never documented in Fusconaia Longsolid SE Lake Julian and host fish not documented in Lake Julian; not subrotunda collected in recent survey of French Broad River (Alderman 2015, NCDNCR 2022) No record of occurrence in Lake Julian. Very low - occurs in lotic habitat (riverine), never documented in Lake Julian; not collected in recent survey of French Broad River Strophitus (Alderman 2015). Although host fish species (which may include ST undulatus Creeper Green Sunfish, Creek Chub, Channel Catfish, Largemouth Bass, Black bullhead (Ameiurus melas), Yellow Perch (Perca flavescens), and Spotfin Shiner (Cyprinella spiloptera) exist, the general habitat of Lake Julian would be unsuitable (NCDNCR 2022) *Status: FE- federal endangered, FT -federal threatened, FSC- federal species of concern, SE - state endangered, ST- state threatened. The following materials were reviewed to develop the species list in Table 4-5: • IPAC (https://ecos.fws.gov/ipac/) (USFWS 2022) for the search area shown on Figure 4-2, and North Carolina Department of Natural and Cultural Resources (NCDNCR) Natural Heritage Program (http://www.ncnhp.org/data/species-community-search) (topographic maps used: Skyland, NC) (NCDNCR 2022). Historical electrofishing results for Lake Julian are discussed in Section 4.1 of this report. No federally or state -listed species were collected during the historical electrofishing sampling of Lake Julian. Several factors will contribute to the protective nature of the ACC's cooling system toward aquatic species, such as closed -cycle cooling (BTA), a CWIS design and TSV below 0.5 fps, and the minimal amount of make-up water withdrawn from Lake Julian in support of the ACC units. The repurposed Lake Julian CWIS uses fixed mesh screen panels with a TSV of much less than 0.5 fps, resulting in a negligible potential for impingement. Operating as a CCRS substantially reduces intake volume and is also reflected in the Rule as an impingement mortality BTA. In addition, the ACC's closed -cycle configuration is compliant with §125.94(e)(1) for entrainment BTA for new units at existing facilities. io Results of a 2015 mussel survey performed in the upstream and downstream vicinity of the Asheville Plant river intake structure on the French Broad River did not collect any specimens federal or state -listed mussels (Alderman 2015). 42 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 4.7 Documentation of Consultation with Services [§ 122.21(r) (4) (vi i )] In preparing this response package for compliance with the Rule, there has been neither public participation, nor coordination undertaken with the Services. DEP has not submitted information to obtain incidental take exemption or authorization from the Services. 4.8 Methods and QA Procedures for Field Efforts [§122.21(r)(4)(viii)] Data presented in this report were compiled from DEP's historical and ongoing Environmental Monitoring Program on Lake Julian. Copies of reference documents will be made available upon request. 4.9 Definition of Source Water Baseline Biological Characterization Data [§122.21(r)(4)(ix)] Data presented in this report were compiled from Duke Energy's historic and ongoing Environmental Monitoring Program. 4.10 Identification of Protective Measures and Stabilization Activities [§122.21(r)(4)(x)] DEP has performed habitat improvements in Lake Julian to provide additional cover for juvenile and small fishes and to increase angling success by recreational users. During March 2010, an artificial concrete reef was constructed in approximately 25 feet of water on the north side of Lake Julian, east of the planned ACC footprint (Figure 2-2). In June of 2017, discarded Christmas trees were added to the artificial reef to improve the fishery habitat within the lake and provide additional fish attraction areas, away from the facility, for shoreline and boat anglers (DEP 2022b). Additional shoreline habitat enhancement efforts (1998 and 2002) have included the felling and cabling of trees along targeted sections of shoreline (Progress Energy 2013). The design of the ACC cooling water system (i.e., use of closed -cycle cooling) and the cooling water intake (i.e., TSV less than 0.5 fps) are anticipated to minimize impingement and greatly reduce entrainment. 4.11 List of Fragile Species [§122.21(r)(4)(xi)] In the Rule, the EPA identifies 14 species of fish as fragile or having post -impingement survival rates of less than 30 percent. Occurrence of fragile species in Lake Julian was evaluated using historical sampling data and is summarized in Table 4-6. 43 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Table 4-6. List of Fragile Species as Defined by the EPA and their Occurrence in Lake Julian and/or the French Broad River near Asheville Combined Cycle Station Scientific Name Common Name Occurrence in Lake Julian in vicinity of ACC CWIS* Alosa pseudoharengus Alewife Yes Alosa sopidissima American Shad No Clupea harengus Atlantic Herring No Anchoa mitchilli Bay Anchovy No Alosa aestivalis Blueback Herring No Pomatomus saltatrix Bluefish No Poronotus triacanthus Butterfish No Dorosoma cepedianum* Gizzard Shad Yes Dorosomo petenense* Threadfin Shad Yes Lutjanus griseus Grey Snapper No Alosa mediocris Hickory Shad No Brevoortia tyrannus Atlantic Menhaden No Osmerus mordox Rainbow Smelt No Etrumeussadina Round Herring No Engraulis eurystole Silver Anchovy No *Threadfin Shad is not included on the EPA Fragile Species list; however, it is in the same family as Gizzard Shad and is documented as having a post -impingement survival rate of less than 30 percent. Alewife and Gizzard Shad were the only species from the list that have been documented in Lake Julian. Threadfin Shad, a closely related species expected to have very low post -impingement survival, have also been documented in electrofishing surveys performed on Lake Julian. Threadfin Shad, Gizzard Shad, and Alewife typically exhibit a greater likelihood for entrainment and impingement at CWIS due to reproductive habits, habitat preferences, and sensitivity to temperature extremes. Mass die -offs of shad species have been documented in response to extreme winter temperatures (at or below 9°C) resulting in large collection events at CWIS (Loar et al. 1978, Griffith 2011). Shad in Lake Julian may experience die -offs during winter months in response to the loss of thermal discharges that have occurred with ACC operations. The facility is fully compliant with BTA alternative §125.94(e). Note however, that the repurposed CWIS has fixed mesh screen panels with a TSV substantially less than 0.5 fps and impingement is anticipated to be negligible at this facility based on the low TSV; therefore, a discussion or assessment of potential fragile species is not provided in this report. 44 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 4.12 Information Submitted to Obtain Incidental Take Exemption or Authorization from Services [§122.21(r)(4)(xii)] DEP has not submitted information to obtain incidental take exemption or authorization from the Services; nor is such an exemption necessary based on the ACC technology to be employed and the lack of any relevant species in Lake Julian. 45 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station 5 Cooling Water System Data [§122.21(r)(5)] The information required to be submitted per 40 CFR §122.21(r)(5), Cooling water system data, is outlined as follows: (i) A narrative description of the operation of the cooling water system and its relationship to cooling water intake structures; the proportion of the design intake flow that is used in the system; the number of days of the year the cooling water system is in operation and seasonal changes in the operation of the system, if applicable; the proportion of design intake flow for contact cooling, non - contact cooling, and process uses; a distribution of water reuse to include cooling water reused as process water, process water reused for cooling, and the use of gray water for cooling; a description of reductions in total water withdrawals including cooling water intake flow reductions already achieved through minimized process water withdrawals; a description of any cooling water that is used in a manufacturing process either before or after it is used for cooling, including other recycled process water flows, the proportion of the source waterbody withdrawn (on a monthly basis); (ii) Design and engineering calculations prepared by a qualified professional and supporting data to support the description required by paragraph (r)(5)(i) of this section; and, (iii) Description of existing impingement and entrainment technologies or operational measures and a summary of their performance, including but not limited to reductions in impingement mortality and entrainment due to intake location and reductions in total water withdrawals and usage. Each of these requirements is described in the following subsections. 5.1 Description of Cooling Water System Operation [§122.21(r)(5)(i)] The ACC utilizes a closed -cycle circulating water system to supply cooling water to the steam surface condenser and auxiliary cooling system to remove heat from the combined cycle unit steam turbine. The circulating water system also provides station service water (e.g., fire water and HRSG wash water). A water balance diagram showing flow distribution at the facility (e.g., cooling water and service water systems) is provided in Figure 5-1 and Table 5-1 presents the average annual and maximum design flows (developed by CB&I North Carolina, Inc. [CB&I]) for the ACC. Raw water pumped from submersible pumps at the repurposed CWIS supplies make-up water to the recirculating cooling towers and other plant needs for the ACC (Units 05/06 and 07/08). Each unit consists of a dual fuel (natural gas/fuel oil) combustion turbine combined with an HRSG that captures the exhaust heat from the combustion turbine unit, generates steam, and delivers the steam to a steam turbine to generate additional power. Each unit is also equipped with a mechanical draft cooling tower. Each cooling tower has five main components: 1) the fans which direct the airflow upward, 2) the heat transfer section made up of corrugated polyvinyl chloride sheets commonly called the "fill", 3) the water distribution system, 4) the drift eliminator section, and 5) the concrete basin which collects water to return to the condensers and auxiliaries. Each of the 50-foot-tall ACC towers consists of four cells, four 200-horsepower fans (one per cell), a 3-pass drift eliminator, and have a total circulating water flow of 65,106 gpm. 46 316(b) Compliance Submittal Requirements Asheville Combined Cycle Station Heated water from each unit's condenser cooling system is routed to the cooling tower via circulating water piping. The heated circulating water is cooled by the cooling tower, collected in a basin beneath the tower, and pumped back to the condenser cooling system where the cycle is repeated. The recirculating cooling water system is designed to operate at 10 COC during typical operations, meaning the circulating water constituents concentrate approximately 10 times or more during operation. The heat transferred to the circulating water in the condenser is rejected to the atmosphere by evaporation in the cooling tower. Evaporation does not carry away solids in the water such as mud, silt, or dissolved solids; therefore, it is necessary to control the COC by continuously discharging some of the circulating water to remove waste and prevent a buildup of solids in the circulating water. This discharge, called blowdown, is routed to the wastewater pump, and discharged to the French Broad River via Outfall 001. 47 4 Ultrafiltration $ '10 -16 Backwash Strainer Se Water/Fire Service Bip,,,�„r and uttraf[Itration Water Tank C ater Users Drains Sump skids 5 17 Existing Simple Cycle E)astirg Savle C Evap Cooling & Storrnwaier Dramas Makeupand lift stalson i Unit 07/06 Raw 38 38 Water Supply Standby ROIDemin Trailers Simple C) 12 Cycle CTG Two -Pass Reverse 3 15 1$ Water Mixed -Bed Derninefalized Infection Osmosis Deriinefalizer Water Tanks CTG Injecti< Atmosphere 14 Evaporationj — —�j H % 72, 20 f--/222,1 19 i Cooling Tower&SG Blowdown HRSGBasinank/SumpOF Backwash Sump CTG Wash (Shared) 30 24 Water Trans 27 Sample 19 3.1 Panel 34 2 $ 32 Oil -Water Unit 7/8 TE Separator WTB drain Sludge Side -stream Filter sips Unit 07108 Thider�r (t per Backwash Sump - F11Len tl p� Cooling Tower pancr Clock) (1 per power pova r block) Slowdown 39) Oil -water U nloc 25 Separator di Fitter Press 37 Una M06 (3ttsrea) Cooling Tower Wastewater Sump Sing &owdown (Shared) Basin! FI CIIC� 2y 39 20 Chanel 4.1 putfall Transfer Tm" 40 Existing Fuel Oil Existing Fuel Oil Post ash basin Area Oil -Water closure surfaced Stormwater Separator groundwater Process Flow Diagrar Progress, LLC Asheville Combined C [This page intentionally left blank] Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station Table 5-1. Water Balance Associated Flows for the ACC Duke Energy Progress, Inc. Asheville Combined Cycle Plant — NPDES Permit Number NCO000396 Form 2C - Item 2.1-A Flow, Sources of Pollution, and Treatment Technologies Stream Name Average Flow Comments 1 Total Facility Raw Water Supply 3.294 MGD Lake Julian 2 Raw Water to Unit 05/06 1.647 MGD Average 3 Raw Water to Unit 07/08 1.647 MGD Average 4 Raw Water to Ultrafiltration 0.160 MGD Estimated 5 Cooling Tower Makeup 1.335MGD Estimated 6 Caoling Tower Evaporation and Drift 0.921 MGD Estimated 8 Raw Water to Service Water Tank 0.151 MGD Estimated 9 Uitrafiltration Reject & Strainer Backwash 0.021 MGD Estimated 10 Service Water to Users 0.072 MGD Estimated 11 Condenser Circ Water Quench Water to Boiler Blowdown Tank 0.006 MGD Estimated 12 Service Water to Two -Pass Reverse Osmosis Skids 0.148 MGD Estimated 13 Reverse Osmosis Permeate to Mixed Bed Demineralizer 0.108 MGD Estimated 14 Reverse Osmosis Reject 0.040 MGD Estimated 15 De mineralized Water System Makeup 0.108 MGD Estimated 16 Service Water Users to Oil Water Separator 0.072 MGD Estimated 17 Service Water to Unit 3 & 4 Evaporative Cooling & Cycle Makeup 0.090 MGD Estimated Seasonal 18 CTG NOx Injection Water 0.255 MGD Estimated 19 CTG Wash Water 0.001 MGD Episodic 20 1 Boiler Makeup 0.016 MGD Estimated 21 Boiler Blowdown 0.007 MGD Estimated 22 Boiler Blowdown Tank Evaporation & Losses 0.003 MGD Estimated 23 1 Quenched Boiler Blowdown Sump Flow 0.019 MGD Estimated 24 Sam le Panel Flow 0.009 MGD Estimated 25 Unit 05/06 Oil Water Separator Flow 1 0.072 MGD I Estimated 50 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station Duke Energy Progress, Inc. Asheville Combined Cycle Plant— NPDES Permit Number NCO000396 Form 2C - Item 2.1-A Flow, Sources of Pollution, and Treatment Technologies Stream Name Average Flow Comments 26 Total Facility Wastewater to Plant Discharge 0.677 MGD Estimated 27 Side -Stream Filter Flow (Circulating water) 2.753 MGD Estimated 28 Side -Stream Filter Backwash Flow 0.0244 MGD Estimated 29 Sludge to Transfer Truck 0.009 MGD Episodic 30 OF Backwash Sump discharge flow 0.050 MGD Estimated 31 Side -Stream Filtrate (Circ water return) 2.390 MGD Estimated 32 Unit 07/08/WTB Oil water separator Flow 0.114 MGD Estimated 34 Filter Press Supernatant 0.001 MGD Estimated 37 Sludge Filter Press Supernatant 0.001 MGD Estimated 38 StandbV Demin Trailer Flow 0.164 MGD Estimated 39 Cooling Tower Blowdown ( per unit) 0.338 MGD Average 40 Post ash basin surfaced jzroundwater 0.02.9 MGD Estimated 41 Outfall 001 0.706 MGD Estimated 42 Outfall 002 0.080 MGD Estimated Seasonal 5.1.1 Temporal Characteristics of Cooling Water System Operation The cooling water system design incorporates two operating scenarios; Average Annual Design and Maximum Flow Design (see Table 5-1). Average Annual Design assumes the ACC would operate using natural gas as the fuel source and operate the cooling towers at 10 COC. This design scenario represents typical or normal operations. The Maximum Flow Design scenario assumes the ACC would operate using fuel oil with 5 COC at the cooling towers. This operating scenario is considered to be a relatively infrequent event, for example, upon startup commissioning and during periods of natural gas curtailment. 5.1.2 Proportion of Design Flow Used in the Cooling Water System As illustrated in the water balance diagram provided on Figure 5-1, an average of 71 gpm per unit will be used for service water (see Stream #7: raw water to ultrafiltration inlet). Therefore, based on the design pumping capacity of 1,800 gpm per unit, approximately 3.9 percent of the raw water coming into ACC is used for service water; the remaining 96.1 percent is used for cooling purposes. 51 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station Based on the AIF of 2.3 MGD (1,597 gpm) presented in Table 3-5, approximately 8.9 percent (71 gpm x 2 units / 1,597 gpm) of the raw water coming into ACC will be used for service water; the remaining 91.1 percent will be used for cooling purposes. 5.1.3 Distribution of Water Reuse The ACC units do not reuse cooling water as process water, reuse process water for cooling purposes, or use grey water for cooling purposes. Therefore, this subsection is not applicable to the ACC units. 5.1.4 Description of Reductions in Total Water Withdrawals The retirement of the Asheville Plant's Units 1 and 2 and replacement with new combined cycle units utilizing a closed -cycle recirculating cooling system has resulted in reductions in total water withdrawals at the Lake Julian CWIS for ACC operations. Conversion of the existing once -through operations to the new combined cycle operations decreases the DIF capacity from 316.2 MGD (i.e., 2 pumps at 48,300 gpm + 2 pumps 61,500 gpm = 219,600 gpm) to 5.2 MGD (i.e., 2 pumps at 1,800 gpm = 3,600 gpm) for a net reduction of 311 MGD, or 98.4 percent. Actual withdrawals are approximately 2.3 MGD on an average annual basis, which would result in a 99 percent reduction in total water withdrawals at the CWIS. 5.1.5 Description of Cooling Water Used in Manufacturing Process Cooling water from the ACC is not used in a manufacturing process, either before or after the water is used for cooling; therefore, this subsection is not applicable to the ACC. 5.1.6 Proportion of Source Waterbody Withdrawn The Lake Julian water surface elevation is dependent on rainfall runoff, natural evaporation, seepage through the dam, and withdrawals to support plant operations. Water from the French Broad River can also be pumped to Lake Julian to support pond elevations. At the normal lake elevation of 2,161 ft msl, Lake Julian's storage capacity is 8,819 acre-feet (2,874 million gallons) (WSP 2015). To determine the proportion of water withdrawn from Lake Julian on a monthly -average basis, the estimated average withdrawal volume needed to support ACC operations was divided by the total capacity of Lake Julian at the normal lake elevation. The proportion of Lake Julian withdrawn for cooling purposes by the ACC plant is approximately 2.4 percent based on an AIF of 2.3 MGD. 5.2 Design and Engineering Calculations [§122.21(r)(5)(ii)] Engineering calculations of TSV for the %-inch mesh fixed screen panels are provided in Appendix C. Table 5.2 Calculated TSV Calculated TSV (fps) One Raw Water Pump 0.09 Two Raw Water Pumps 0.18 52 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station 5.3 Description of Existing Impingement and Entrainment Reduction Measures [§122.21(r)(5)(iii)] Substantial reductions in rates of impingement for the ACC compared to the existing Asheville Plant are accomplished through a TSV of less than 0.5 fps. The TSV calculated for the Lake Julian CWIS for Unit 05/06 and Unit 07/08 meet the BTA standard for new units at an existing facility at §125.94(e). The ACC facility also achieves substantial reductions in entrainment and impingement by means of flow reduction. The underlying assumption for entrainment is that entrainable organisms have limited or no motility and are conveyed passively with water entering the power plant. Therefore, reduction in flow results in a commensurate reduction in entrainment". Reduction in flow will be accomplished by retiring Units 1 and 2. The two new natural gas -fired combined cycle units reduce the DIF at the Lake Julian CWIS by approximately 98.4 percent (as discussed in Section 5.1.4). 5.3.1 Asheville Plant The retirement of existing Unit 1 and Unit 2, coupled with startup of the new ACC units, the total facility DIF has been reduced by approximately 98.4 percent (from 316.2 MGD to 5.2 MGD). This flow reduction results in a commensurate reduction in the potential entrainment and impingement associated with the facility. 5.3.2 The ACC The ACC is compliant with §125.94(e) BTA standards for impingement mortality and entrainment for new units at existing facilities by use of mechanical draft cooling towers which reduce the DIF for the new unit to a level commensurate with a CCRS. The ACC employs the following supplemental measures to reduce impingement mortality and entrainment at the CWIS on Lake Julian: • TSV (provided in Section 2.3) at the Lake Julian CWIS is substantially less than 0.5 fps. • Because the AIF (2.3 MGD) at the Lake Julian CWIS represents a greater than 95 percent reduction in withdrawal rates and the facility -induced TSV at the intake is less than 0.5 fps (regulatory threshold), the A01 for the Lake Julian CWIS's does not extend beyond the surface of the intake screens. • The ACC employs a closed -cycle recirculating cooling water system by utilizing wet mechanical draft cooling towers designed to reduce make-up water requirements. While the number of COCs can change depending on operational conditions, an estimated 10 COC provides a flow reduction of 98.4 percent compared to a once -through system. Since reductions in impingement and entrainment can be assumed to be commensurate with reductions in flow, it is assumed that the use of closed -cycle cooling at the ACC will reduce impingement and entrainment by 98.4 percent. "This is the underlying assumption in EPA's calculation of entrainment reduction associated with closed -cycle cooling —see EPA 2014. 53 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station In addition to the design aspects and operations of the ACC facility, the following are also important considerations in determining BTA standards for impingement mortality and entrainment: • The ACC withdraws water from Lake Julian; a cooling pond (impoundment) permitted and constructed in part on WOTUS for the purpose of providing cooling for electric generation (North Carolina State Board of Health 1963). All of the species identified as potentially subject to entrainment are common to the region. • The species found to have a higher likelihood of entrainment at Lake Julian (Threadfin Shad and Gizzard Shad) comprise a low relative abundance of fish sampled through electrofishing surveys (between 0 and 7.7 percent). As described in Section 4.2, electrofishing studies indicate Lake Julian exhibits a balanced fish community. This suggests Lake Julian contains a sufficient foundation of reproduction, recruitment, and mortality for sustainable predator populations and prey base. Further, Lake Julian supports an active recreational fishery. • No federally listed fish species or critical habitat designations exist within Lake Julian near the CWIS (USFWS 2017). As outlined above and in the section that follows, the operations of the ACC facility reduce impingement mortality and entrainment such that no additional control measures are necessary. 5.3.3 Best Technology Available for Entrainment Although the ACC closed -cycle cooling system is compliant with the BTA requirement for new units at an existing facility (§125.94(e)), the following information is provided to support the conclusion that the retirement of the existing Asheville Plant and operation of the new ACC units has resulted substantial entrainment reduction. The number of organisms that may be entrained is considered to be low. Since entrainment is proportional to flow, reductions in flow equate to commensurate reductions in entrainment. The retirement of Units 1 and 2 reduced the DIF by 98.4 percent (from 316.2 MGD to 5.2 MGD). As a result of the flow -reduction measures, AIF is 2.3 MGD at the ACC. No federally or state -protected species were collected in previous electrofishing sampling on Lake Julian. In addition, according to the USFWS IPAC database, there are neither protected species nor critical habitat designations for Lake Julian (USFWS 2017). 54 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station 6 Chosen Method(s) of Compliance with Impingement Mortality Standard [§122.21(r)(6)] The information required to be submitted per 40 CFR § 122.21(r)(6) is as follows: The owner or operator of the facility must identify the chosen compliance method for the entire facility; alternatively, the applicant must identify the chosen compliance method for each cooling water intake structure at its facility. The applicant must identify any intake structure for which a BTA determination for Impingement Mortality under 40 CFR 125.94 (c)(11) or (12) is requested. The Rule at 40 CFR 125.94(c) gives existing facilities seven BTA options for achieving impingement mortality compliance. These are listed below. A facility needs to implement only one of these options. 1. Operate a closed -cycle recirculating system as defined at 40 CFR 125.92(c)(1) (this includes wet, dry or hybrid cooling towers, a system of impoundments that are not WOTUS, or any combination thereof). 2. Operate a cooling water intake structure that has a maximum design through -screen velocity of 0.5 fps or less. 3. Operate a cooling water intake structure that has a maximum actual through -screen velocity of 0.5 fps or less. 4. Operate an existing offshore velocity cap that is a minimum of 800 feet offshore and has bar screens or otherwise excludes marine mammals, sea turtles, and other large aquatic organisms. 5. Operate a modified traveling screen system such as modified Ristroph screens with a fish handling and return system, dual flow screens with smooth mesh, or rotary screens with fish returns. Demonstrate that the technology is or will be optimized to minimize impingement mortality of all non -fragile species. 6. Operate any combination of technologies, management practices, and operational measures that the Director determines is BTA for reducing impingement. As appropriate to the system of protective measures implemented, demonstrate the system of technologies has been optimized to minimize impingement mortality of all non -fragile species; and 7. Achieve a 12-month performance standard of no more than 24 percent mortality including latent mortality for all non -fragile species. Compliance options 1, 2, and 4 are essentially pre -approved technologies that require minimal additional monitoring after their installation and proper operation. Options 3, 5, and 6 require that more detailed information be submitted to the Director before they can be specified as the BTA to reduce impingement mortality. Options 5, 6, and 7 require demonstrations with field studies that the technologies have been optimized to minimize impingement mortality of non -fragile species. In addition, the Rule provides two other impingement compliance BTA options for which the Director may consider little or no additional controls for impingement mortality (USEPA 2014a). These options apply under very specific circumstances. 55 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station • De minimis rate of impingement — if the rates of impingement at a facility are so low that additional impingement controls may not be justified (Section 125.94(c)(11)); and • Low -Capacity utilization of generating units — if the annual average capacity utilization rate of a 24-month contiguous period is less than 8 percent (Section 125.94(c)(12)). The new ACC units are equipped with a CCRS using mechanical draft cooling towers. A closed -cycle recirculating system satisfies the impingement mortality and entrainment BTA standards for new units at §125.94(e). 6.1 Design TSV It is recognized by the EPA that an intake TSV of 0.5 fps or less establishes a threshold based on the assumption that, at velocities below this value, most healthy impingeable-sized fishes will be able to swim freely and avoid impingement. The ACC cooling tower make-up water is withdrawn at the repurposed Lake Julian CWIS, which is comprised of four identical intake bays. Each bay will be equipped with a new (replacement for historic) submersible pump with a design capacity of approximately 1,800 gallons per minute (gpm) (2.6 MGD). The ACC units are designed to operate with two pumps (the remaining two pumps provide redundant pumping capacity). As a result, the combined DIF capacity for the ACC units is 3,600 gpm (5.2 MGD). The average TSV based on the new Y4-inch mesh screens is 0.09 fps (at low water surface elevation) and the max TSV is 0.18 fps (at low water surface elevation). At DIF the average TSV for new %-inch mesh screens for both units (at low water surface elevations) is lower than the 0.5 fps threshold established by the Rule. As such, the impingement AOI at the ACC is negligible because the area over which the intake -induced velocity is greater than 0.5 fps would not extend beyond the face of the screens. The ACC TSV (which is lower than the 0.5 fps threshold established for impingement BTA) would protect greater than 96 percent of fish from impingement at the CWIS on Lake Julian based on the Rule's Technical Development Document. 6.2 Requirements of Make-up Water Minimization for Closed -Cycle Recirculating System According to the Rule at §125.92, a CCRS is "...designed and properly operated using minimized make-up and blowdown flows withdrawn from a water of the United States to support contact or non -contact cooling uses within a facility...". A CCRS withdraws significantly less water from its source water body than a once -through cooling system. The actual reduction in withdrawal volume depends on the design and operation of the recirculating cooling system. The site -specific design and operating parameters of the closed -cycle cooling system at ACC are presented in Table 6-1. 56 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station Table 6-1. Site -Specific Design of ACC Closed -Cycle Cooling System (CB&I 2018) Design and Operational Parameters Values Condenser cooling water flow and The cooling towers for ACC are designed to cool 65,106 gpm condenser temperature rise (i.e., delta T) with a temperature range of 17.70 Fahrenheit (°F) (-7.940C). COC at which the cooling tower is The circulating water system is currently expected to operate typically operated at 10 COC. Drift eliminator efficiency Drift loss (% of cooling water flow) is estimated to be 0.0005 percent. The design MW rating of ACC is 560 MW (2 power blocks at MW rating of ACC generating blocks 280 MW each). The summer/winter net electrical generating capacity of each block is estimated at 250 MW / 280 MW. Evaporation, drift, and blowdown rates are compiled and summed to determine volume of make-up water withdrawn at the CWIS: where: Make-up flow = Evaporation (E) + Drift (D) + Blowdown (B) E = 0.0008 x Condenser temperature delta T (°F) x Condenser CW flow rate (gpm) D = Drift eliminator efficiency x Condenser cooling water flow (gpm) B = [E-((COC-1) x D1]/(COC-1) Then, make-up flow is compared with condenser cooling water flow (i.e., once -through flow) to determine the degree of flow reduction. Using the cooling tower flow of 65,106 gpm, delta T of 17.7°F (-7.94°C), drift eliminator efficiency of 0.0005 percent and 10 COC (CB&I 2018), the calculations for evaporation, drift, and blowdown rates are as follows: E=0.0008x17.7°Fx65,106gpm =921.9gpm D=0.0005x65,106gpm =32.6gpm B = [921.9 — 1(10-1) x 32.61]/(10-1) = 69.8 gpm Make-up Flow for 10 COC = 921.9 + 32.6 + 69.8 = 1,024.3 gpm Therefore, the calculated total ACC make-up water flow12 for 10 COC is 1,024.3 gpm (1.48 MGD). As a result, the percent flow reduction compared to a once -through cooling system is 98.4 percent ([65,106- 1,024.31/65,106 X 100). DEP anticipates that the make-up water flow to the cooling towers installed at ACC will continue to be minimized to the maximum extent possible within the constraints of practicality, scaling, other operational issues, and the need to comply with NPDES discharge limits. 12 Based on CB&I Document No. ACC00-SP-M-CW-01; represents the total designed capacity for the cooling towers. 57 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station 7 Entrainment Performance Studies [40 CFR § 122.21(r)(7)] The information required to be submitted per 40 CFR § 122.21(r)(7), Entrainment performance studies, is as follows: The owner or operator of an existing facility must submit any previously conducted studies or studies obtained from other facilities addressing technology efficacy, through - facility entrainment survival, and other entrainment studies. Any such submittals must include a description of each study, together with underlying data, and a summary of any conclusions or results. Any studies conducted at other locations must include an explanation as to why the data from other locations are relevant and representative of conditions at your facility. In the case of studies more than 10 years old, the applicant must explain why the data are still relevant and representative of conditions at the facility and explain how the data should be interpreted using the definition of entrainment at 40 CFR 125.92(h). 7.1 Site -Specific Studies [40 CFR §122.21(r)(7)(i)] Site -specific entrainment has not been evaluated for ACC. Site -specific studies are neither required by the Rule nor relevant to the ACC because the facility meets the entrainment BTA standards for new units. 7.2 Studies Conducted at Other Locations [40 CFR §122.21(r)(7)(ii)] As of the date of this report, no entrainment performance studies conducted at other facilities have been determined relevant for documentation in this section. 58 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station 8 Operational Status [§ 122.21(r)(8)] The information required to be submitted per 40 CFR §122.21(r)(8), Operational status, is outlined as follows: (i) For power production or steam generation, descriptions of individual unit operating status including age of each unit, capacity utilization rate (or equivalent) for the previous 5 years, including any extended or unusual outages that significantly affect current data for flow, impingement, entrainment, or other factors, including identification of any operating unit with a capacity utilization rate of less than 8 percent averaged over a 24-month block contiguous period, and any major upgrades completed within the last 15 years, including but not limited to boiler replacement, condenser replacement, turbine replacement, or changes to fuel type; (ii) Descriptions of completed, approved, or scheduled uprates and Nuclear Regulatory Commission relicensing status of each unit at nuclear facilities; (iii) For process units at your facility that use cooling water other than for power production or steam generation, if you intend to use reductions in flow or changes in operations to meet the requirements of 40 CFR 125.94(c), descriptions of individual production processes and product lines, operating status including age of each line, seasonal operation, including any extended or unusual outages that significantly affect current data for flow, impingement, entrainment, or other factors, any major upgrades completed within the last 15 years, and plans or schedules for decommissioning or replacement of process units or production processes and product lines; (iv) For all manufacturing facilities, descriptions of current and future production schedules; and, (v) Descriptions of plans or schedules for any new units planned within the next 5 years Each of these requirements is described in the following subsections. 8.1 Description of Operating Status [§ 122.21(r)(8)(i)] ACC is normally used for base load generation. Plant outages typically occur during the spring (February to May) and/or in the fall/winter (October to December) months. 8.1.1 Individual Unit Age ACC Unit 05/06 and Unit 07/08 began commercial operations in 2020. Therefore, at the time of this report the ACC Units have only 3 years of commercial operations. 8.1.2 Utilization for Previous 5 Years Monthly and annual average capacity factor information for 2020-2022 is provided in Table 8-1 and Table 8-2. Annual average capacity factors during this period ranged from 59.2 to 79.5 percent. Note that during 2020, the units were being optimized for long-term operations. 59 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station Table 8-1. Annual Capacity Factors (%) at ACC Unit 05/06, 2020-2022. Month 2020 2021 2022 January 84.9 97.1 81.2 February 91.6 96.3 84.3 March 66.1 96.3 94.7 April 15.0 6.6 3.0 May 14.3 17.3 0.0 June 29.1 75.4 67.8 July 89.4 86.7 79.0 August 90.2 89.7 91.4 September 61.6 92.1 92.5 October 93.7 63.1 93.0 November 57.7 29.4 96.4 December 52.7 73.8 79.2 Annual Average 62.2 68.6 71.9 Table 8-2. Annual Capacity Factors (%) at ACC Unit 07/08, 2020-2022. Month 2020 2021 2022 January 24.2 97.3 98.2 February 31.5 71.1 83.6 March 9.5 71.7 72.8 April 49.1 90.8 91.1 May 56.1 87.2 93.3 June 83.6 88.4 84.6 July 82.7 79.1 90.6 August 88.1 70.2 85.4 September 71.9 69.1 45.6 October 10.0 39.7 0.1 November 64.9 98.2 74.3 December 101.3 90.6 98.2 Annual Average 59.2 79.5 74.2 8.2 Major Upgrades in Last Fifteen Years The ACC represents a new unit at an existing facility. No major upgrades have been completed that would be applicable to the ACC or its operations. 8.3 Descriptions of Consultation with Nuclear Regulatory Commission [§122.21(r)(8)(ii)] Neither the ACC nor the existing Asheville Plant units are nuclear facilities; therefore, consultation with the U.S. Nuclear Regulatory Commission is not required and was not initiated. 60 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station 8.4 Other Cooling Water Uses for Process Units [§122.21(r)(8)(iii)] The ACC will not use cooling water for process units; therefore, this subsection is not applicable. 8.5 Description of Current and Future Production Schedules [§122.21(r)(8)(iv)] ACC is not a manufacturing facility; therefore, this subsection is not applicable. 8.6 Description of Plans or Schedules for New Units Planned within 5 years [§122.21(r)(8)(v)] There are no plans within the next five years to add additional generation at the ACC. 61 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station 9 References Alderman Environmental Services, Inc. (Alderman). 2015. French Broad River Mussel Surveys. Prepared for Duke Energy. September 22, 2015. Brierley, A. 2014. Diel vertical migration. Current Biology, Volume 24, Issue 22: 111074-111076. November 2014. Carlander, K.D. 1977. Handbook of Freshwater Fishery Biology. Vol. 2. The Iowa State University Press, Ames, IA. 431 pp. Carolina Power and Light (CP&L). 2001. Asheville Steam Electric Plant, 2000 Environmental Monitoring Report. Environmental Services Section, Progress Energy Company. New Hill, North Carolina. June 2001. CB&I North Carolina, Inc (CB&I). 2018. Asheville Combined Cycle Project, Document No.: ACC00-ME- M-WB-01. Prepared for: Duke Energy Progress, LLC. Cornish, M. and K. Welke. 2004. Bluegill (Lepomis macrochirus). In: Pitlo, J.M. Jr. and J.L. Rasmussen (eds.). UMRRC Fisheries Compendium. 3rd Edition. Upper Mississippi River Conservation Committee. Rock Island, Illinois. January 2004. p. 177-180. Duke Energy Progress, LLC (DEP). 2005. §316(b) Supplement to NPDES Permit NC000396 Reissuance Application Package, submitted to NC Division of Water Quality, 2005. . 2007. Asheville Steam Electric Plant, NPDES Permit Renewal Application Package, submitted to NC Division of Water Quality, 2007. 2015. Clean Water Act §316(b) Strategic Plan -Asheville Steam Station. 2017a. North Carolina Integrated Resource Plan, September 1, 2017. 2021b. Unpublished data from Lake Julian Aquatic Plant Survey 2021. 2023. 2012-2021 Asheville Environmental Monitoring Report. Duke Energy Progress, LLC., New Hill, NC. Ehrlich, K. F. 1974. Chemical changes during growth and starvation of herring larvae. Pages 301-323 in J. H. S. Blaxter, editor. The early life history of fish. Springer-Verlag, New York. Electric Power Research Institute (EPRI). 2004. Using Computational Fluid Dynamics Techniques to Define the Hydraulic Zone of Influence of Cooling Water Intake Structure. 1005528. EPRI, Palo Alto, CA. . 2007. Cooling Water Intake Structure Area -of -Influence Evaluations for Ohio River Ecological Research Program Facilities. 1015322. EPRI, Palo Alto, CA. Emig, J.W. 1966. Largemouth bass. In: A. Calhoun (ed.). Inland Fisheries Management. State of California, Department of Fish and Game. 62 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station Etnier, D. and W. Starnes. 1993. The Fishes of Tennessee. Knoxville: The University of Tennessee Press. 1993. Gebhart, G. E., and R.C. Summerfelt. 1978. Seasonal Growth of Fishes in Relation to Conditions Of Lake Stratification. "Oklahoma Cooperative Fishery Research Unit 58 (1978): 6-10. Oklahoma State University, Stillwater, Oklahoma. Golder Associates. 2005. Crystal River Energy Complex Proposal for Information Collection. NPDES Permit No. FL0000159. Prepared for Progress Energy. Griffith, G.E., J.M. Omemik, J.A. Comstock, M.P. Schafale, W.H. McNab, D.R. Lenat, D.R. and T.F. MacPherson. 2002. Ecoregions of North Carolina. U.S. Environmental Protection Agency, Corvallis, Oregon. (map scale 1:1,500,000). Griffith, J.S. 2011. Effects of Low Temperature on the Survival and Behavior of Threadfin Shad, Dorosoma petenense. Transactions of the American Fisheries Society, Vol. 107 (1). Heidinger, R.C. 1975. Life history and biology of the Largemouth Bass. Pages 11-20 In: R.H. Stroud and H. Clepper (eds.). Black Bass Biology and Management. Sport Fishing Institute, Washington, D.C. Hunter, J.R. 1963. The Reproductive Behavior of the Green Sunfish, Lepomis cyanellus. Zoological 48(1): 13-24. Loar, J.M., J.S. Griffith, and K.D. Kumar. 1978. An analysis of factors influencing the impingement of threadfin shad at power plants in the southeastern United States. Pages 245-255 in L.D. Jensen, editor. Fourth national workshop on entrainment and impingement. EA Communications, Melville, New York. Leonard, P.M., and D.J. Orth. 1988. Use of habitat guilds of fishes to determine instream flow requirements. North American Journal of Fisheries Management 8:399-409. May, R. C. 1974. Larval mortality in marine fishes and the critical period concept. Pages 3-19 in J. H.S. Blaxter, editor. The early life history of fish. Springer-Verlag, New York. Mehner, T. 2012. Diel vertical migration of freshwater fishes — proximate triggers, ultimate causes and research perspectives. Freshwater Biology, 57: 1342-1359. Miller, R.R. 1960. Systematics and biology of the gizzard shad (Dorosoma cepedianum) and related fishes. U.S. Fish and Wildlife Service, Bulletin 60: 371-392. Miller, T.J., Crowder, L.B., Rice, J.A., Marshall, E.A. 1988. Larval size and recruitment mechanisms in fishes: toward a conceptual framework. Canadian Journal of Fisheries and Aquatic Sciences 45:1657-1670 p. North Carolina Department of Environmental Quality (NCDEQ). 2017. French Broad River Basin Documents. Accessed March 6, 2017. https://deg.nc.gov/about/divisions/`mitigation- services/dms-planning/watershed-planning-documents/french-broad-river-basin. 63 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station . 2018a. Water Withdrawal and Transfer Registration Annual Water Use Reports. Accessed August 7, 2018. http://www.ncwater.org/Permits and Registration/Water Withdrawal and Transfer Regi stration/report. . 2018b. Lake and Reservoir Assessments French Broad River basin. Accessed October 28, 2022. North Carolina Department of Natural and Cultural Resources (NCDNCR). 2022. North Carolina Natural Heritage Program. Accessed October 28, 2022. North Carolina State Board of Health. 1963. Permit for Impounding and Maintenance of Impounded Water, North Carolina State Board of Health, Sanitary Engineering Division. Raleigh, North Carolina. July 12, 1963. Page, L.M. and B.M. Burr. 2011. A field guide to freshwater fishes of North America north of Mexico. Boston : Houghton Mifflin Harcourt. Pflieger, W.L. 1997. The Fishes of Missouri. Missouri Department of Conservation, Jefferson City, MO. 372 pp. Pitlo, J., D. Dieterman, and G. Jones. 2004. Largemouth bass (Micropterus salmoides). In: Pitlo, J.M. Jr. and J.L. Rasmussen (eds.). UMRRC Fisheries Compendium. 3rd Edition. Upper Mississippi River Conservation Committee. Rock Island, Illinois. January 2004. pp. 169-173. Progress Energy Carolinas, Inc. (Progress Energy). 2010. NPDES Permit Renewal Request Asheville Steam Electric Plant. Permit Number: NC0000396—Attachment #2. 2013. Asheville Steam Electric Plant, 2010-2011. Environmental Monitoring Report. Water and Natural Resources Section Environmental Services Department, Progress Energy Carolinas, Inc. New Hill, North Carolina. April 2013. Rider, S and Maceina, M. 2015. Alabama Bass Micropterus henshalli Hubbs & Baily, 1940. American Fisheries Society Symposium 82: 83-91. Rohde, F.C., R.G. Arndt, D.L. Lindquist, and J.F. Parnell. 1994. Freshwater Fishes of the Carolinas, Virginia, Maryland, & Delaware. The University of North Carolina Press. Chapel Hill, NC. 222 PP. Rohde, F. C., R. G. Arndt, J. W. Foltz, and J. W. Quattro. 2009. Freshwater Fishes of South Carolina. University of South Carolina Press, Columbia, SC. 430 pp. Spotte, S. 2007. Bluegills: Biology and Behavior. American Fisheries Society, Bethesda, Maryland. 214 PP• Tomelleri, J.R. and M.E. Eberle. 1990. Fishes of the Central United States. University Press of Kansas. Kansas. U.S. Environmental Protection Agency (EPA). 2014. Technical Development Document for the Final Section 316(b) Existing Facilities Rule. EPA-821-R-14-002. Washington, DC. 64 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station U.S. Fish and Wildlife Service (USFWS). 2022. Information for Planning and Conservation Data Search. Accessed October 28, 2022. https://ecos.fws.gov/ipac/user/login. Wiegel, Robert L. 1964. Oceanographic Engineering, Prentice -Hall, Inc. Englewood Cliffs, NJ. WSP. 2015. Bathymetric Survey Asheville Cooling Lake (Lake Julian). Arden, NC. 65 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station Appendices Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station Appendix A. Asheville Combine Cycle Station §122.21(r)(2) — (8), (14) Submittal Requirement Checklist. Citation Title 40 CFR Requirement Provided in Report? 122.21(r) (2)(i) Narrative description and scaled drawings of source waterbody. Yes N T a Identification and characterization of the source waterbody's Yes, note that no CU hydrological and geomorphological features, as well as the physical studies were 3 0 (2)(ii) methods used to conduct any physical studies to determine conducted to intake's area of influence within the waterbody and the results determine the area of such studies. of influence 0 Ln (2)(iii) Locational maps. Yes m ( 3)(i) Narrative description of the configuration of each CWIS and Yes where it is located in the waterbody and in the water column. c � o (3)(ii) Latitude and Longitude of CWIS. Yes m(3)(iIi) c Narrative description of the operation of each CWIS. Yes � o ;. u "' (3)(iv) Flow distribution and water balance diagram. Yes m v (3)(v) Engineering drawing of CWIS. Yes A list of the data supplied in paragraphs (r)(4)(ii) through (vi) of Yes, but not (4)(i) this section that are not available and efforts made to identify applicable because all sources of the data. data are available. o (4)(ii) A list of species (or relevant taxa) for all life stages and their Yes relative abundance in the vicinity of CWIS. c 0 (4)(iii) Identification of the species and life stages that would be most Yes susceptible to impingement and entrainment. Identification and evaluation of the primary period of MO (4)(iv) reproduction, larval recruitment, and period of peak abundance Yes 0o for relevant taxa. 0 _o Co (4)(v) Data representative of the seasonal and daily activities of Yes biological organisms in the vicinity of CWIS. M m Identification of all threatened, endangered, and other (4)(vi) protected species that might be susceptible to impingement and Yes �o 3 entrainment at cooling water intake structures. v Documentation of any public participation or consultation with �° Federal or State agencies undertaken in development of the v (4)(vii) plan. Yes, but not applicable. A-1 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station Citation Title 40 CFR Requirement Provided in Report? 122.21(r) Yes, but not (4)(viii) Methods and CIA procedures for any field efforts. applicable as no new data have been collected. In the case of the owner or operator of an existing facility or new Yes, noted in report (4)(ix) unit at an existing facility, the Source Water Baseline Biological that (i) through (xii) Characterization Data is the information included in (i) through provide this (xii). information. Identification of protective measures and stabilization activities that have been implemented, and a description of how these (4)(x) Yes measures and activities affected the baseline water condition in the vicinity of CWIS. List of fragile species as defined at 40 CFR 125.92(m) at the Yes, but not required (4)(xi) facility. because new unit at an existing facility Information submitted to obtain Incidental take exemption or authorization for its cooling water intake structure(s) from the Yes, but not (4)(xii) U.S. Fish and Wildlife Service or the National Marine Fisheries applicable. Service. Narrative description of the operation of the cooling water (5)(i) Yes system and its relationship to CWIS. (5)(i) Number of days of the year the cooling water system is in Yes, anticipated operation and seasonal changes in the operation of the system. seasonal operations (5)(i) Proportion of the design intake flow that is used in the system. Yes 0 E v Proportion of design intake flow for contact cooling, non -contact (5)(i) cooling, and process uses. Yes v Y mDistribution of water reuse to include cooling water reused as (5)(i) process water, process water reused for cooling, and the use of not applicable 0 gray water for cooling. in Description of reductions in total water withdrawals including (5)(i) cooling water intake flow reductions already achieved through Yes minimized process water withdrawals. Description of any cooling water that is used in a manufacturing (5)(i) process either before or after it is used for cooling, including not applicable other recycled process water flows. A-2 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station Citation Title 40 CFR Requirement 122.21(r) (5)(i) Proportion of the source waterbody withdrawn (on a monthly basis). Design and engineering calculations prepared by a qualified (5)(ii) professional and supporting data to support the description required by paragraph (r)(5)(i) of this section. Description of existing impingement and entrainment (5)(iii) technologies or operational measures and a summary of their performance. Identification of the chosen compliance method for the entire CWIS or each CWIS at its facility. Impingement Technology Performance Optimization Study for Modified Travelling Screen. L Y Two years of biological data collection. (6)(i) E '^ o u 0 o ° o Demonstration of Operation that has been optimized to P minimize impingement mortality. L � Q) v Complete description of the modified traveling screens and I on C associated equipment. v n r E Impingement Technology Performance Optimization Study for i Systems of Technologies as BTA for Impingement Mortality. (6)(ii) Minimum of two years of biological data measuring the reduction in impingement mortality achieved by the system. v Site -specific studies addressing technology efficacy, through (7)(i) plant entrainment survival, and other impingement and C m entrainment mortality studies. c LL,c E � (7)(ii) Studies conducted at other locations including an explanation of a how they relevant and representative. Provided in Report? Yes Yes N/A Yes None Available None Available None Available A-3 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station Citation Title 40 CFR Requirement Provided in Report? 122.21(r) (7)(iii) Studies older than 10 years must include an explanation of why None Available the data are still relevant and representative. (8)(i) Description of individual unit age, utilization for previous 5-year, Yes, where relevant major upgrades in last 15 years. Descriptions of completed, approved, or scheduled uprates and Yes, but not (8)(ii) Nuclear Regulatory Commission relicensing status of each unit at applicable. nuclear facilities. Ln c 0 (8)(iii) Other cooling water uses and plans or schedules for Yes, but not decommissioning or replacing units. applicable. Q O (8)(iv) For all manufacturing facilities, descriptions of current and Yes, but not future production schedules. applicable. (8)(v) Descriptions of plans or schedules for any new units planned Yes within the next 5 years. A-4 Appendix B. Asheville Combined Cycle Station, Pertinent Engineering Drawings C-219-D — Concrete Intake Structure Plan G-170903 — Circulating Water System Intake G-171048 — Intake Steel and Screens E117624 — Static Screen General Arrangement B-1 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station B-2 DFTAIL CO WMt R M V 31- M f. 'r!" M Ur FA r.cfy 41;-, r'TZ­:se;. 21T.-IMER +WVILLF ATUM V•THN DM < ENMY C;*". T co F. 1p A W=wrofY tee• J_.oj ]u 1=9iS 17S jj fauusa° am+alma .'SS r Y••ri ..»,s• •�, �nmw w ? woi - •fl MA K W{t 120 • ICINVH 5NU3•i OA.r - -- - -' i-�`' •, •.... wnw.f 71 +1 � _fir. 'MINK „rwr'In,rr ... snlifw n..v �- a I •ate.- 130 ....M� W_'� r-r logs IA,•UT TiY, e ICH 11-�1 1735 A -A 1= kw O 110 16 u•q ae u xx �'wil•. W y. ali_� �.tianw�rno•e L G.D311 Y - N37r75 asaro7 r f °--mIng ."Ift "Id �i•.u. w.0 I{ IJ( aAla V�SkNII 1+M __ .nor"i 19' \r 1-1 1736 wf{� T. -V133ti MwG-0 .L�3t 3-0 1�35 L.+i 9-9 L]gf awur•iwroirtr•i lDgf �r�,.. "�`�'�' n ..--—_----.... -— .. —• -.�.�, � � :� � rw rag IL `ate..,. ....".'.:�f;1 �a.�'ow'iL.:.""m�:.�..:'•~•...w�" r K.� .H.,ia::r•I--I .v.;!"n^.� :uax.'c'a.ni aoi w"vi Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station SH 44 Ulk-3 i, M Appendix C: Engineering Calculations for Through -Screen Velocity Asheville Combined Cycle Makeup Structure Through -Screen Velocity Calculations Mike Smallwood, 5/09/2023 NOTE: only one pump per unit can operate (pumps are 100%capacity); therefore two pumps operating per unit Is an implausible scenario. Operating Flow, Flow, Conversions Pumps gpm cfs Data Source cfs to gpm = 448.8 SA 1800 4.01 2023 Asheville 316(b) report, Table 3-1 58 1800 4.01 same 7A 1800 4.01 same 7B I800 4.01 same Structure Bays Bays 1 Asheville Raw Water Intake Structure General Arrangement (Drawing ACC00-GA•P-IS.00.PL-01) pumps/bat 2 same Width, ft 9.17 Asheville Static Screen General Arrangement (Beaudrey Drawing E117624) Depth, ft 20.0 same Invert, ft 2144.0 same Waterbody Low water level 2158.0 feet Beaudrey drawing E117624 High water level 2165.0 feet same Static Screens Wetted depth, low 14.0 feet Beaudrey drawing E117624 (calculated value) Wetted depth, high 21.0 feet Beaudrey drawing E117624 (calculated value) Screen width 9.2 feet Beaudrey drawing E117624 Screen open area 0.64 see open area calculation Through -Screen Velocity Formula (low elevation = 14.0 feet wetted depth) V=Q/(WD"OA) Q = 6.46 cfs (one pump), 12.92 cis (two pumps) WD = screen area for flow = 71.04 ft 2 (@ 14.0 feet wetted depth) OA = 0.64 note: see "low WD calcs" tab for detail Calculations (low elevation =14.0 feet wetted depth) 0.09 fps, one pump 0.19 fps, two pumps Screen Open Area Formula (W*L)/I(IN+D)"(L+d)) width of mesh opening, Inches (0.25) L = vertical length of mesh opening, Inches (0.25) D = vertical wire diameter, inches (0.063) horizontal wire diameter, Inches (0.063) A = (0.25.0.25)/[(0.25+0.063) • (0.25+0.063)) 0." Note: assumes wire gauge number = 16 c-1 Clean Water Act §316(b) Compliance Submittal Asheville Combined Cycle Station Asheville CC Makeup Structure Screen Frame Open Area Cakulauons Mike Smallwood, 3/06/2023 "Low Elevation" scenario Source: Beaudrey drawing E217624 A A = lower screen, bottom perimeter with seal z 9.17 3 = lower screen, top perimeter = 9.17' C z lower screen, side perimeter = 2.27' D intermediate screen, bottom perimeter z 9.17 E = intermediate screen, side perimeter = 223 Conversions mm to it 0.003281 F : lower screen, vertical supports LW G - lower sheen, horizontal support = M, H : intermediate screen, vertical support = 190 1 - intermediate screen, horizontal support = 8&T Assumption: a8 perimeter framing for each screen panei is 2.0(0.167 feet( face width Assumption: a8 support framing is 1S" (0.125 feet) face width Assumptiom seal attached to tower screen adds no additional depth A (Lower parsecs) open area: 36.05 1`12 B (Intermediate panels), frame open area 3499 ft2 Perimeter z A+B+2C 3.92 ft2 Perimeter = 2D+2E 3.81 ft2 A=9.17'x M167• 1.53 h2 2D=2x9.17S0-167z 306 ft2 8-9.37 x0.167= 1.53 ft2 2E-2x2_23'.0.167z D.74 ft2 X z 2 x L27 x (L167' 0.76 ft2 Support = 7H + 31 4.98 f12 Support +7F+36 4.98 h2 7H-7x190'xD.125'= L66 f12 7F = 7 x 1.90" x 0,125' 1 6G h2 3H z 3x8.84'.D. 125' z 332 W 36=3x8.MxD.M' 3.32 h2 Panel Frame =D'E 2CL45ft2 Panel Frame z AC 20.82 1112 Panels = 3 toUl Purls z 3 total Panel height z 223 feet Panel freight z 2.27 feet Tool freight = &69 feet Total height z 6.81 feet Total frame z 6137 1`12 Total frame= 62,43 ft2 Totsl frame open, area = lower frame open area + intermedate frame open area z 7LD4 Low Water Level Is (0) 8 panels (3) A panels W n vertical supports . 7 n horizontal supports s 3 C (Intermediate panels) Lame open area: ODD perimeter - 213•2E 0.00 1112 2D z 2x9.17'x0.167' z O.OD ft2 2E a 2x3.32'xD.125' - DAD ft2 Support = I + 3H 0.00 ft2 7H z 7x1.9t1'x(LU5' a D.OD 112 3H= 3x8.84'x0.12S'z 0.00 ft2 Frame - D'E DAD ft2 Panels= 3 tout Parcel height * O.0D fern Nate: assume no wider enters C panels C-2 6 FISH TISSUE MONITORING Asheville Combined -Cycle Station i Fish Tissue Monitoring of the French Broad River Buncombe County, North Carolina (2019-2022) NPDES Permit No. NC0000396 Duke Energy Progress May, 2023 Table of Contents Page 1.0 Introduction..................................................................................................................... 1 2.0 Methods............................................................................................................................ 1 2.1 Study Site.................................................................................................................... 1 2.2 Target Species............................................................................................................. 1 2.3 Field Sampling Methods............................................................................................. 2 2.4 Laboratory Process and Analysis................................................................................ 2 3.0 Results and Discussion.................................................................................................... 2 3.1 Arsenic........................................................................................................................ 3 4.0 Summary.......................................................................................................................... 4 5.0 References........................................................................................................................ 4 List of Tables Table Page 3-1 Numbers and total length ranges (mm) of species of fish collected for trace element analysis in the three sampling areas of the French Broad River during 2019-2022 ......... 3 3-2 Means and ranges of trace elements in fish muscle tissue collected from three sampling locations in the French Broad River during 2019-2022.................................... 4 List of Figures Figure Page 1 French Broad River trace element monitoring locations .................................................. 5 Appendices Appendix A: Arsenic, mercury, and selenium concentrations (wet weight) in axial muscle of fish from the French Broad River 2019-2022. Appendix B: Baseline mercury and selenium concentrations (wet weight) in axial muscle of fish from the French Broad River during August and November 2004. Fish Tissue Monitoring of the French Broad River Near Asheville Combined Cycle Station (2019-2022) 1.0 Introduction Duke Energy Progress (DEP) owns and operates the Asheville Combined -Cycle Station (Asheville Station) located on the east side of the French Broad River in Buncombe County, Arden, North Carolina. As currently required by the Asheville Station's National Pollutant Discharge Elimination System (NPDES) Permit No. NC0000396 (current through November 30, 2023), Special Condition A. (15): "The facility shall conduct fish tissue monitoring annually and submit the results with the NPDES permit renewal application. The objective of this monitoring is to evaluate potential uptake of pollutants by fish tissue near the ash pond discharge. The parameters analyzed in fish tissue shall include arsenic, selenium, and mercury. The monitoring shall be conducted in accordance with the sampling plan approved by the Division. " Fish tissue monitoring was originally only required for mercury and selenium after Flue Gas Desulfurization (FGD) operations commenced in December of 2005. Operation of the FGD system discontinued when the coal fired generation system was decommissioned in 2019. Electric generation has transitioned away from coal fired generation to natural gas (combustion turbines). This data report is submitted to provide an overview of the sampling conducted during the permit cycle and to fulfill the NPDES permit renewal application. 2.0 Methods 2.1 Study Site Fish were collected from three locations within the French Broad River (Figure 1). These locations were adjacent to the Asheville Station discharge (Station DI), 6.2 kilometers upstream of the discharge (Station UP) and 10.8 kilometers downstream of the discharge (Station DN). 2.2 Target Species Sunfish (Lepomis) and black bass (Micropterus spp.)/rock bass (Ambloplities spp.) were targeted for collection based on prior sampling experience, likely availability, potential for human consumption, and general trophic level. An attempt was made to collect ten fish per target species with the understanding that six would satisfy permit requirements. As recommended by the U.S. Environmental Protection Agency (USEPA) an attempt was made to limit the smallest fish to 75% of the largest fish total length by species depending on availability (USEPA 2000). 2.3 Field Sampling Methods Fish were collected using electrofishing procedures specified in the Duke Energy Environmental Science Field Programs procedures (ESFP-SW-0200, Rev. 0 and ESFP-SW-0600, Rev. 0) which were approved by the North Carolina Department of Environmental Quality under the DEP Biological Laboratory Certification (# 006). Only live fish that showed little or no signs of deterioration were retained for analysis, put in a labeled bag, and placed on ice until frozen. Ancillary fisheries data including species, total length (nun), and total weight (g) were also recorded. Fish collected were transferred to a freezer daily and maintained frozen until processing at the DEP New Hill Trace Element Laboratory. Associated water quality data including water temperature, dissolved oxygen, and specific conductance were recorded daily at the surface at each sampling location (available on request). 2.4 Laboratory Processing and Analysis All fish samples were processed individually and analyzed in the trace element laboratory according to procedures ESFP-SW-0601, Rev. 0 and ESFP-SW-0602 Rev. 0. Fish were thawed and skeletal muscle was fileted off using a carbon -steel scalpel. Muscle tissue from each individual fish was homogenized, weighed to the nearest 0.001 g, and completely dried in a desiccator. The dried weight was recorded and used to calculate a dry weight to fresh (wet) weight ratio for that fish. Approximately 0.1 g of dried tissue was analyzed for each fish using X- ray fluorescence. Quality control was achieved utilizing analytical standards, replicates, and certified reference materials. Following analysis, residual processed samples were archived and will be kept for at least two years in the event re -analysis is needed. 3.0 Results and Discussion During the study period (2019-2022), 209 individuals representing seven species were captured and analyzed from the French Broad River (Table 3-1). These species included Smallmouth Bass Micropterus dolomieu, Largemouth Bass M. salmoides, Alabama Bass M. henshalli, Rock Bass Amboplities rupestris, Redbreast Sunfish Lepomis auritus, Bluegill L. macrochirus, and Redear Sunfish L. microlophus. A full list of individual fish and associated trace element concentrations 2 (wet weight) is presented in Appendix A. In addition to the length and weight of each fish, the dry -to -wet weight ratios are presented on individual fish to convert the arsenic, mercury, and selenium concentrations wet weight values back to dry weight values as desired. The 2004 baseline data (prior to the flue gas desulfurization system installation for the coal-fired plant) are also presented for comparison purposes (Appendix B). Table 3-1. Numbers and total length ranges (mm) of species of fish collected for trace element analysis in the three sampling areas of the French Broad River during 2019-2022. Number UP Range Number DI Range Number DN Range Smallmouth Bass 15 192-377 24 170-473 22 219-420 Black bass Lar emouth Bass g 13 248-488 3 178-212 8 454-245 (Micropterus)l Rock bass Alabama Bass 1 230 1 390 - (Amboplities) Rock Bass 4 186-225 3 154-220 4 175-212 Redbreast Sunfish 33 161-203 26 125-205 32 145-225 Sunfish Bluegill 3 177-185 8 140-177 5 138-194 (Lepomis) Redear Sunfish 3 184-208 - 1 170 3.1 Arsenic All fish collected during 2019-2022 at the three sample locations were well below the USEPA screening value for recreational anglers of 1.2 µg/g (wet weight) for arsenic (USEPA 2000; Table 3-2). 3.2 Mercury One of 111 sunfish species collected during 2019-2022 was above the USEPA recreational screening value of 0.4 µg/g (wet weight) for mercury (USEPA 2000; Table 3-2). Of the 98 black bass collected 40 were above the 0.4 µg/g mercury screening value. Of these 40 exceedances 16 were from UP, 13 from DI, and 13 from DN. 3.3 Selenium All fish collected during 2019-2022 at the three sample locations were well below the USEPA screening value for recreational anglers of 20 µg/g (wet weight) (USEPA 2000; Table 3-2). K Table 3-2. Means and ranges of trace elements in fish muscle tissue collected from three sampling locations in the French Broad River during 2019-2022. All values are in µg/g wet weight, and the USEPA screening values are shown next to each element. When concentrations were less than the reporting limit, the reporting limit value was used for analysis. Arsenic (1.2) Selenium (20) Mercury (0.4) Mean Range Mean Range Mean Range UP Black bass 0.15 0.12-0.20 0.36 0.23-0.53 0.47 0.09-1.16 Sunfish 0.14 0.12-0.16 0.52 0.30-2.36 0.12 <0.06-0.71 DI Black bass 0.16 0.12-0.20 0.33 0.22-0.67 0.37 0.07-0.77 Sunfish 0.14 0.12-0.16 0.51 0.23-1.22 0.10 <0.06-0.35 DN Black bass 0.15 0.12-0.20 0.39 0.20-0.54 0.34 <0.06-0.72 Sunfish 0.14 0.12-0.15 0.48 0.33-0.66 0.14 <0.06-037 4.0 Summary When considered altogether, it does not appear that any pattern of arsenic, mercury, or selenium accumulation in fish tissues existed during the 2019-2022 NPDES permit cycle attributable to the Asheville Plant operations or in the French Broad River within the reach sampled. Furthermore, no fish tissue from any location or from any year exceeded the USEPA recreational screening values for arsenic or selenium. Fish having tissue that did exceed the screening value for mercury appear to be randomly distributed and unrelated to plant operations. The mercury results seen during this NPDES permit cycle are also comparable to the 2004 baseline data, indicating that mercury levels have remained relatively stable in the reach of the French Broad River sampled. Fish tissue samples were collected every year with at least six fish from each trophic level at three designated locations in accordance with the state approved study plan satisfying the fish tissue monitoring requirement of the NPDES permit. 5.0 References USEPA. 2000. Guidance for assessing chemical contaminant data for use in fish advisories. Vol. 1. Fish sampling and analysis. Third edition. EPA 823-B-00-007. United States Environmental Protection Agency, Office of Water, Washington, DC. 4 A * Airr+^k C=t.xa-Cyc* Statwn Fah Tsa�e Vo r.try Laaeoas .�Re-ere r�a� Rim Lake x!at 2 Miles 0 1 2 Klometers Asheville Combined -Cycle Station MPDES Permit rfC0000345 Figure 1. French Broad River trace element monitoring locations. DUKE ENERGY, Appendix A Arsenic, mercury, and selenium concentrations (wet weight) in axial muscle of fish from the French Broad River 2019-2022. Exceedances of screening values are highlighted. 2022 Fish Species Locations Month Length Weight As (µg/g) Hg (µg/g) Se (µg/g) Dry -to -Wet' (MM) (g) Weight Ratio Smallmouth Bass UP June 335 432 0.17 0.74 0.32 0.20 Smallmouth Bass UP June 236 169 0.15 0.29 0.33 0.20 Smallmouth Bass UP October 299 339 0.15 0.56 0.35 0.20 Smallmouth Bass UP October 192 104 0.14 0.18 0.26 0.20 Alabama Bass UP June 230 164 0.14 0.30 0.43 0.21 Rock Bass UP June 212 230 0.15 0.45 0.36 0.20 Largemouth Bass UP June 334 493 0.15 0.25 0.30 0.20 Largemouth Bass UP June 248 188 0.15 0.21 0.28 0.20 Largemouth Bass UP June 342 550 0.12 0.37 0.31 0.20 Largemouth Bass UP October 279 319 0.15 0.62 0.36 0.21 Redbreast Sunfish UP June 171 114 0.15 0.07 0.33 0.20 Redbreast Sunfish UP June 170 93 0.15 0.27 0.46 0.20 Redbreast Sunfish UP June 189 148 0.13 0.10 0.38 0.19 Redbreast Sunfish UP June 200 169 0.12 0.19 2.36 0.20 Redbreast Sunfish UP June 173 106 0.15 0.14 0.39 0.21 Redbreast Sunfish UP June 175 114 0.14 < 0.06 0.38 0.20 Redbreast Sunfish UP June 161 82 0.15 0.08 0.44 0.20 Bluegill UP June 185 118 0.15 0.08 0.30 0.19 Bluegill UP June 177 113 0.14 0.28 0.36 0.20 Redear Sunfish UP June 208 176 0.16 0.11 0.46 0.21 Smallmouth Bass DI June 360 762 0.16 0.26 0.26 0.21 Smallmouth Bass DI June 310 437 0.16 0.35 0.32 0.21 Smallmouth Bass DI June 194 115 0.16 0.19 0.33 0.21 Smallmouth Bass DI June 400 851 0.15 0.51 0.24 0.20 Smallmouth Bass DI June 228 164 0.16 0.24 0.34 0.21 Smallmouth Bass DI October 270 271 0.16 0.16 0.26 0.21 Smallmouth Bass DI October 281 307 0.15 0.23 0.27 0.21 Rock Bass DI June 154 79 0.14 0.09 0.40 0.20 Rock Bass DI June 161 93 0.12 0.07 0.30 0.19 Rock Bass DI October 220 202 0.16 0.30 0.29 0.21 Redbreast Sunfish DI June 194 144 0.14 0.08 0.39 0.20 Redbreast Sunfish DI June 155 73 0.13 0.07 0.48 0.20 Redbreast Sunfish DI June 143 53 0.14 0.13 0.39 0.20 Redbreast Sunfish DI June 139 54 0.14 0.11 0.52 0.20 Redbreast Sunfish DI June 162 102 0.15 0.08 0.40 0.21 Redbreast Sunfish DI June 145 75 0.12 0.06 0.29 0.17 Redbreast Sunfish DI October 138 45 0.13 0.06 0.34 0.19 Redbreast Sunfish DI October 136 43 0.13 0.13 0.36 0.19 Bluegill DI June 177 115 0.13 0.08 0.25 0.19 Bluegill DI June 141 58 0.14 < 0.06 0.86 0.21 Smallmouth Bass DN June 303 377 0.16 0.38 0.36 0.21 Smallmouth Bass DN June 420 906 0.14 0.63 0.34 0.20 Smallmouth Bass DN June 364 622 0.16 0.72 0.34 0.20 Smallmouth Bass DN June 235 175 0.15 0.20 0.33 0.21 Smallmouth Bass DN June 243 201 0.16 0.18 0.31 0.21 Rock Bass DN June 175 106 0.14 0.07 0.34 0.21 Largemouth Bass DN June 406 1089 0. l3 0.50 0.20 0.18 Largemouth Bass DN June 454 1100 0.13 0.72 0.38 0.17 Largemouth Bass DN June 251 216 0.13 0.22 0.29 0.19 Largemouth Bass DN June 245 176 0.13 0.17 0.29 0.19 Redbreast Sunfish DN June 145 69 0.14 0.15 0.53 0.20 Redbreast Sunfish DN June 212 182 0.13 0.17 0.44 0.19 Redbreast Sunfish DN June 219 214 0.14 0.21 0.37 0.19 Redbreast Sunfish DN June 201 167 0.14 0.22 0.39 0.20 Redbreast Sunfish DN June 175 125 0.14 < 0.06 0.33 0.21 Redbreast Sunfish DN June 213 211 0.15 0.27 0.45 0.21 Bluegill DN June 138 61 0.15 0.07 0.33 0.21 Bluegill DN June 144 61 0.15 < 0.06 0.40 0.21 Bluegill DN June 140 65 0.14 0.06 0.37 0.20 Redear Sunfish DN June 170 92 0.15 0.11 0.59 0.21 2021 Fish Species Locations Month Length Weight As (µg/g) Hg (µg/g) Se (µg/g) Dry -to -Wet' (MM) (g) Weight Ratio Redbreast Sunfish UP June 182 135 0.14 0.71 0.62 0.20 Redbreast Sunfish UP June 190 145 0.13 0.23 0.46 0.19 Redbreast Sunfish UP June 187 142 0.13 0.10 0.51 0.19 Redbreast Sunfish UP June 171 106 0.14 0.09 0.40 0.20 Redbreast Sunfish UP June 197 156 0.14 0.12 0.42 0.20 Redbreast Sunfish UP June 185 143 0.13 0.07 0.42 0.19 Redbreast Sunfish UP June 188 145 0.16 0.14 0.42 0.20 Redbreast Sunfish UP June 180 139 0.16 0.09 0.60 0.20 Redbreast Sunfish UP June 200 179 0.14 0.17 0.56 0.20 Redbreast Sunfish UP June 185 154 0.15 0.09 0.42 0.19 Smallmouth Bass UP June 306 358 0.14 0.74 0.41 0.17 Smallmouth Bass UP June 286 324 0.15 0.75 0.40 0.19 Smallmouth Bass UP June 275 336 0.17 0.65 0.36 0.21 Smallmouth Bass UP June 326 471 0.16 1.09 0.36 0.20 Smallmouth Bass UP June 377 791 0.16 0.45 0.30 0.20 Rock Bass UP June 225 288 0.15 0.52 0.38 0.19 Smallmouth Bass UP August 373 709 0.20 0.75 0.35 0.22 Smallmouth Bass UP August 370 624 0.20 1.16 0.46 0.22 Smallmouth Bass UP August 265 246 0.17 0.76 0.42 0.21 Smallmouth Bass UP August 200 115 0.15 0.21 0.38 0.21 Redbreast Sunfish DI June 196 165 0.15 0.35 0.48 0.22 Redbreast Sunfish DI June 202 193 0.14 0.21 0.48 0.20 Redbreast Sunfish DI June 165 106 0.15 0.12 0.74 0.21 Redbreast Sunfish DI June 171 106 0.14 0.06 0.44 0.20 Bluegill DI June 148 66 0.14 0.07 0.42 0.20 Redbreast Sunfish DI June 156 59 0.13 0.13 0.49 0.18 Redbreast Sunfish DI June 151 65 0.14 0.09 0.64 0.20 Bluegill DI June 150 67 0.13 0.06 0.30 0.19 Bluegill DI June 139 58 0.13 0.06 0.34 0.19 Redbreast Sunfish DI June 125 38 0.16 0.07 0.72 0.20 Smallmouth Bass DI June 425 1032 0.15 0.53 0.23 0.19 Smallmouth Bass DI June 314 390 0.15 0.56 0.27 0.19 Smallmouth Bass DI June 387 792 0.16 0.74 0.24 0.20 Smallmouth Bass DI June 370 697 0.17 0.67 0.42 0.21 Largemouth Bass DI June 178 83 0.14 0.10 0.34 0.20 Largemouth Bass DI June 212 124 0.14 0.25 0.36 0.20 Alabama Bass DI June 390 660 0.17 0.28 0.67 0.21 Smallmouth Bass DI June 410 952 0.16 0.57 0.22 0.20 Smallmouth Bass DI June 445 1142 0.14 0.54 0.23 0.18 Redbreast Sunfish DN June 209 190 0.14 0.07 0.42 0.20 Redbreast Sunfish DN June 216 200 0.14 0.09 0.40 0.20 Redbreast Sunfish DN June 225 237 0.14 0.37 0.50 0.20 Redbreast Sunfish DN June 208 179 0.13 0.25 0.53 0.19 Redbreast Sunfish DN June 209 184 0.13 0.12 0.42 0.19 Redbreast Sunfish DN June 192 145 0.13 0.18 0.42 0.19 Redbreast Sunfish DN June 177 100 0.13 0.17 0.42 0.19 Redbreast Sunfish DN June 179 113 0.14 0.35 0.48 0.20 Redbreast Sunfish DN June 212 197 0.14 0.20 0.54 0.20 Redbreast Sunfish DN June 158 80 0.14 0.12 0.42 0.20 Rock Bass DN June 205 167 0.15 0.13 0.51 0.19 Rock Bass DN June 191 134 0.15 0.16 0.36 0.19 Rock Bass DN June 212 205 0.14 0.21 0.46 0.20 Smallmouth Bass DN June 274 292 0.13 0.41 0.38 0.19 Smallmouth Bass DN June 277 289 0.16 0.45 0.46 0.20 Smallmouth Bass DN June 354 617 0.16 0.60 0.36 0.20 Smallmouth Bass DN June 349 560 0.15 0.63 0.34 0.19 Smallmouth Bass DN August 378 588 0.17 0.65 0.40 0.21 Smallmouth Bass DN August 275 218 0.16 0.22 0.36 0.20 Largemouth Bass DN August 360 634 0.13 0.20 0.31 0.18 2020 Fish Species Locations Month Length Weight As (µg/g) Hg (µWg) Se (µg/g) Dry -to -Wet' (inm) (g) Weight Ratio Redbreast Sunfish UP June 187 138 0.15 0.08 0.41 0.21 Redbreast Sunfish UP June 188 135 0.14 0.1 0.65 0.20 Redbreast Sunfish UP June 190 142 0.14 0.09 0.56 0.20 Redbreast Sunfish UP June 188 143 0.14 0.11 0.39 0.20 Redbreast Sunfish UP June 184 113 0.15 0.11 0.46 0.20 Redbreast Sunfish UP June 193 142 0.13 0.08 0.51 0.19 Redbreast Sunfish UP September 168 86 0.15 0.13 0.48 0.20 Redbreast Sunfish UP September 181 118 0.15 0.09 0.41 0.19 Redbreast Sunfish UP September 169 91 0.15 0.07 0.44 0.21 Redear Sunfish UP September 185 104 0.16 0.12 0.57 0.21 Smallmouth Bass UP June 311 410 0.16 0.72 0.44 0.19 Smallmouth Bass UP June 267 259 0.15 0.93 0.49 0.20 Rock Bass UP June 195 155 0.15 0.09 0.49 0.20 Rock Bass UP June 186 142 0.19 0.16 0.53 0.23 Largemouth Bass UP June 344 568 0.15 0.29 0.44 0.19 Largemouth Bass UP June 378 933 0.15 0.35 0.29 0.19 Largemouth Bass UP September 297 402 0.14 0.21 0.31 0.20 Bluegill DI June 145 61 0.14 0.06 0.40 0.20 Bluegill DI June 140 53 0.13 0.07 0.35 0.19 Bluegill DI September 172 113 0.16 0.10 0.70 0.20 Redbreast Sunfish DI September 185 128 0.13 0.09 0.48 0.19 Redbreast Sunfish DI September 205 164 0.14 0.16 0.58 0.19 Redbreast Sunfish DI September 150 70 0.13 0.07 0.47 0.19 Smallmouth Bass DI June 170 170 0.15 0.14 0.38 0.20 Smallmouth Bass DI June 215 215 0.15 0.43 0.43 0.20 Smallmouth Bass DI June 237 237 0.15 0.21 0.40 0.20 Smallmouth Bass DI June 230 230 0.15 0.14 0.33 0.20 Smallmouth Bass DI September 365 365 0.19 0.42 0.34 0.22 Largemouth Bass DI June 182 182 0.13 0.15 0.29 0.19 Redbreast Sunfish DN June 185 166 0.14 0.16 0.65 0.20 Redbreast Sunfish DN June 196 172 0.15 0.08 0.58 0.21 Redbreast Sunfish DN June 200 193 0.14 0.09 0.54 0.20 Redbreast Sunfish DN June 213 201 0.13 0.08 0.55 0.20 Redbreast Sunfish DN June 206 220 0.14 0.09 0.47 0.20 Redbreast Sunfish DN September 211 130 0.12 0.14 0.51 0.19 Redbreast Sunfish DN September 190 150 0.13 0.14 0.5 0.19 Redbreast Sunfish DN September 196 106 0.15 0.16 0.56 0.20 Redbreast Sunfish DN September 177 93 0.12 0.07 0.34 0.18 Bluegill DN June 164 166 0.14 0.16 0.65 0.20 Smallmouth Bass DN June 228 145 0.20 0.15 0.16 0.46 Smallmouth Bass DN June 241 185 0.19 0.23 0.14 0.48 Smallmouth Bass DN June 239 171 0.20 0.18 0.15 0.48 Smallmouth Bass DN June 219 129 0.19 0.16 0.16 0.46 Smallmouth Bass DN June 252 210 0.20 0.16 0.16 0.54 Largemouth Bass DN June 257 227 0.20 0.26 0.14 0.41 Smallmouth Bass DN September 290 247 0.24 0.42 0.20 0.50 2019 Fish Species Locations Month Length Weight As (µg/g) Hg (µg/g) Se (µg/g) Dry -to -Wet' (Min) (g) Weight Ratio Redbreast Sunfish UP June 190 159 0.15 0.08 0.47 0.20 Redbreast Sunfish UP June 190 149 0.13 0.07 0.59 0.19 Redbreast Sunfish UP June 196 158 0.14 < 0.06 0.46 0.20 Redbreast Sunfish UP June 203 166 0.15 0.06 0.46 0.20 Redbreast Sunfish UP June 186 138 0.14 0.08 0.49 0.20 Redbreast Sunfish UP June 180 123 0.14 < 0.06 0.65 0.21 Largemouth Bass UP October 488 1700 0.16 0.52 0.44 0.20 Largemouth Bass UP October 488 1700 0.15 0.18 0.33 0.20 Largemouth Bass UP October 415 1225 0.15 0.28 0.28 0.20 Bluegill UP November 184 130 0.16 < 0.06 0.49 0.20 Redear Sunfish UP November 184 118 0.16 0.09 0.65 0.21 Redbreast Sunfish UP November 171 80 0.14 0.07 0.45 0.20 Largemouth Bass UP November 286 278 0.13 0.18 0.26 0.20 Largemouth Bass UP November 280 246 0.14 0.17 0.30 0.20 Largemouth Bass UP November 349 636 0.14 0.33 0.23 0.20 Redbreast Sunfish DI June 182 135 0.14 0.07 0.47 0.20 Redbreast Sunfish DI June 178 99 0.13 0.08 1.06 0.19 Redbreast Sunfish DI June 165 84 0.14 0.08 0.62 0.19 Redbreast Sunfish DI October 200 128 0.13 0.07 0.23 0.20 Redbreast Sunfish DI October 200 128 0.13 0.15 0.84 0.19 Redbreast Sunfish DI October 188 122 0.14 0.14 0.44 0.19 Redbreast Sunfish DI October 182 91 0.12 0.11 1.27 0.19 Redbreast Sunfish DI October 179 94 0.14 0.10 0.36 0.19 Smallmouth Bass DI June 384 703 0.19 0.47 0.48 0.21 Smallmouth Bass DI June 306 297 0.15 0.80 0.49 0.19 Smallmouth Bass DI June 290 291 0.16 0.28 0.32 0.20 Smallmouth Bass DI October 438 1016 0.16 0.51 0.21 0.21 Smallmouth Bass DI October 283 274 0.17 0.37 0.29 0.21 Smallmouth Bass DI October 473 1406 0.17 0.65 0.30 0.22 Redbreast Sunfish DN October 180 91 0.14 < 0.06 0.55 0.21 Redbreast Sunfish DN October 192 122 0.15 0.37 0.60 0.18 Redbreast Sunfish DN October 193 125 0.15 0.09 0.58 0.20 Redbreast Sunfish DN October 200 156 0.14 0.07 0.52 0.20 Redbreast Sunfish DN October 178 99 0.13 0.14 0.62 0.21 Redbreast Sunfish DN October 186 122 0.13 0.08 0.60 0.19 Redbreast Sunfish DN October 221 172 0.14 0.08 0.56 0.19 Bluegill DN October 193 150 0.13 0.10 0.35 0.20 Largemouth Bass DN October 327 460 0.14 0.21 0.37 0.20 Largemouth Bass DN October 268 217 0.14 0.19 0.41 0.19 Smallmouth Bass DN October 395 768 0.14 < 0.06 0.34 0.20 Smallmouth Bass DN October 329 422 0.15 0.53 0.41 0.21 Smallmouth Bass DN October 385 592 0.16 0.69 0.45 0.19 Smallmouth Bass DN October 245 177 0.15 0.12 0.54 0.20 Smallmouth Bass DN October 395 768 0.17 0.61 0.36 _ 0.22 'To convert to a dry weight, divide the wet weight concentrations by the dry -to -wet weight ratio Appendix B Baseline mercury and selenium concentrations (wet weight) in axial muscle of fish from the French Broad River during August and November 2004.1 Exceedances of screening values are highlighted. Locations Month Length Weight Hg Se Dry -to -Wet' Fish (inm) (g) (µgig) (µg/g) Weight Ratio Species Smallmouth bass UP August 246 201 0.87 0.39 0.22 Smallmouth bass UP August 297 370 0.49 0.36 0.21 Smallmouth bass UP August 346 620 0.44 0.22 0.22 Smallmouth bass UP August 445 1,300 1.66 0.31 0.24 Smallmouth bass UP August 370 744 1.49 0.30 0.20 Redbreast sunfish UP August 172 106 < 0.18 0.28 0.20 Redbreast sunfish UP August 160 87 0.32 0.24 0.20 Redbreast sunfish UP August 145 72 < 0.27 0.39 0.30 Redbreast sunfish UP August 149 60 < 0.17 0.25 0.21 Redbreast sunfish UP August 190 160 0.12 0.32 0.20 Black redhorse UP August 372 540 < 0.15 0.26 0.21 Black redhorse UP August 380 550 < 0.17 0.19 0.21 Black redhorse UP August 410 790 0.53 0.26 0.20 Black redhorse UP August 413 843 0.54 0.24 0.19 Black redhorse UP August 415 989 0.40 0.30 0.20 Black redhorse UP August 405 863 0.46 0.30 0.20 Largemouth bass DI August 475 1,725 0.74 1.23 0.21 Largemouth bass DI August 395 611 < 0.16 1.46 0.20 Largemouth bass DI August 405 795 0.17 0.21 0.21 Smallmouth bass DI August 263 223 0.52 0.32 0.22 Smallmouth bass DI August 355 565 0.54 4.14 0.22 Smallmouth bass DI August 374 871 0.27 0.47 0.23 Smallmouth bass DI August 368 802 0.74 0.25 0.22 Smallmouth bass DI August 440 1,300 0.99 0.45 0.22 Redbreast sunfish DI August 136 52 < 0.19 3.81 0.21 Redbreast sunfish DI August 183 108 < 0.17 3.61 0.19 Redbreast sunfish DI August 164 80 0.20 0.57 0.20 Redbreast sunfish DI August 182 128 < 0.15 0.69 0.19 Redbreast sunfish DI August 177 109 0.74 1.23 0.20 Redbreast sunfish DI August 149 58 <0.16 1.46 0.20 Black redhorse DI August 375 < 0.18 0.26 0.30 0.22 Black redhorse DI August 383 0.25 0.25 0.30 0.21 Black redhorse DI August 457 0.52 0.48 0.50 0.20 Black redhorse DI August 465 0.76 0.21 0.20 0.21 Black redhorse DI August 493 0.69 0.21 0.20 0.21 Black redhorse DI August 475 0.43 0.77 0.80 0.20 Black redhorse DI November 410 <0.18 0.26 0.20 0.20 Smallrouth bass DN November 277 265 0.29 0.57 0.21 Smallmouth bass DN November 295 410 0.32 0.15 0.21 Smallmouth bass DN November 310 460 0.77 0.35 0.22 Smallmouth bass DN November 347 620 0.68 0.33 0.22 Smallmouth bass DN November 345 750 0.40 0.29 0.22 Bluegill DN August 135 59 < 0.16 0.33 0.20 Redbreast sunfish DN August 162 66 0.32 0.83 0.20 Redbreast sunfish DN August 175 96 < 0.18 0.76 0.22 Redbreast sunfish DN August 185 139 0.25 0.31 0.19 Redbreast sunfish DN August 198 156 < 0.15 0.27 0.19 Redbreast sunfish DN August 273 324 0.54 0.19 0.21 Redbreast sunfish DN August 126 46 < 0.14 0.41 0.20 Redbreast sunfish DN August 187 170 0.12 0.73 0.20 Redbreast sunfish DN August 199 154 < 0.16 0.93 0.20 Black redhorse DN August 365 509 < 0.2 0.50 0.20 Black redhorse DN August 356 518 0.1 0.30 0.20 Black redhorse DN August 375 651 < 0.2 0.80 0.20 Black redhorse DN August 395 755 < 0.2 0.50 0.20 Black redhorse DN August 388 810 0.5 0.40 0.21 Black redhorse DN August 423 _ _ 910 < 0.2 0.40 0.19 I Arsenic was not required by permit during baseline monitoring. 2 To convert to a dry weight, divide the wet weight concentrations by the dry -to -wet weight ratio 7 UPDATED COMPLIANCE BOUNDARY • e NPDES OUTFALL 001 7r, \ <r � >• u A ✓.C• ;a RETIRED ASHEVILLE t STEAM ELECTRIC PLANT , FORMER COAL PILE g. 4 FORMER i . RIM DITCH �� � VED�IC iASHEVILLE COMBINED TLING CYCLE STATION )ND S n�j••,• �1Fe FORMER 1982 ASH BASIN R' a C� • Lam■ •• J / �� . i • ` ".irR7i1 • ' `� I s NPDES OUTFAL' GG ,i f �s♦yam � • J / LEGEND ♦ NPDES OUTFALL LOCATION (APPROXIMATE) 1%4 ASH BASIN WASTE BOUNDARY ti I 1982 ASH BASIN WASTE BOUNDARY 1.0000 — COMPLIANCE BOUNDARY DUKE ENERGY PROGRESS PROPERTY LINE �• ►— STREAM AND FLOW DIRECTION (TWT 2016) WETLAND (TWT 2016) Z FORMER FLUE GAS DESULFURIZATION (FGD) WETLANDS SURFACE WATER FLOW DIRECTION a NOTES: 1. THE DEPICTED STREAMS AND WETLANDS DATA WERE APPROVED BY THE US ARMY CORPS OF ENGINEERS (USACE) ON MAY 19, 2016 - JURISDICTIONAL DETERMINATION SAW-2014-00189. TAYLOR WISEMAN AND TAYLOR (TWT) PERFORMED THE SURVEY OF THE FEATURES. Y f 2. ALL BOUNDARIES ARE APPROXIMATE. f 3. PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY PROGRESS, LLC. 4. AERIAL IMAGERY OF THE FORMER 1964 BASIN FROM DUKE ENERGY VIA PROPELLER, COLLECTED APRIL 24, 2023. SURROUNDING AERIAL IMAGERY OBTAINED FROM GOOGLE EARTH PRO, COLLECTED JANUARY 28, 2021. 5. DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE i PLANE COORDINATE SYSTEM FIPS 3200 (NAD83). • x' (' DUKE ENERGY PROGRESS WnTerm .A �'. GRAPHICSCALE a 300 0 300 600 ON FEET) FIGURE 1 DRAWN BY:T KING DATE: 03/24/2020 SITE LAYOUT MAP REVISED BY: T. KING DATE. 05/18/2023 ASHEVILLE STEAM ELECTRIC PLANT CHECKED BY: K. FERRI DATE: 05/18/2023 AR.DEN. NORTH CAROLINA APPROVED BY: K. FERRI DATE: 05/18/2023 PROJECT MANAGER: K. FERRI - 7.1 Ash Basin Closure • Coal Ash Excavation Plan, Asheville Steam Electric Generating Plant submitted on December 12, 2019. • Ash Removal Verification Report -1964 Ash Basin - Asheville Steam Electric Plant dated August 31, 2022. • Email from Ashley Healy to Eric Smith and Poonam Giri with the subject, Asheville - 1964 Ash Basin Coal Ash Tons Excavated and Dispositioned sent on September 13, 2022. • Email from Ashley Healy to Eric Smith with the subject, Asheville - 1964 Ash Basin Coal Ash Torts Excavated and Dispositioned sent on September 15, 2022. • Email from Ashely Healy to Eric Smith with the subject, Duke Energy Asheville - 1964 Ash Basin - Ash Removal Verification Report Submittal sent on September 30, 2022. Based on correspondence received by DEQ from Duke Energy, the dewatering of the 1964 Ash Basin was completed on May 13, 2016, and ash removal was completed on June 23, 2022. Field verification of coal ash removal met the objectives of sample collection and analysis consistent with the recommended technical direction outlined in DEQ's CCR Surface Impoundment Closure Guidelines for Protection of Groundwater. The final field excavation totals of the coal combustion residuals transported from the facility for ultimate handling and the amounts, in tons, sent to each permitted facility are documented per the September 13, 2022, email from Ashley Healy to Eric Smith and Poonam Giri (documented above) as follows: • Beneficial Reuse (Roanoke Cement - 6071 Catawba Rd, Troutville, VA) - 69,280 tons (basin ash) • On -Site Landfill - 1,448,746 tons (basin ash) • R&B Landfill (610 Bennett Rd, Homer, Georgia) - 1,282,102 tons (basin ash) • 1964 Ash Basin Lined Rim Ditch (1964 Ash Stack) - 283,230 tons (production ash) Duke Energy also notes the following regarding the tonnages listed above: • The 1964 Ash Stack tonnages that were excavated from the 1982 Ash Basin are not included. This total was included in the total tonnages for the 1982 Ash Basin (Documentation of Compliance with Coal Ash Management Act for 1982 Ash Basin June 8, 2021, letter from NCDEQ). • Excavated total tonnage from Flue Gas Desulfurization Wetlands (non -ash), formerly located within the 1964 Ash Basin, is not included. Based on the documentation provided above, DEQ hereby concurs that Duke Energy has complied with Sections 3(b) and 3(c) of CAMA with the exception of 3.(c)(3), which is still in progress. Section 3(c)(3) states, "If restoration of groundivaler quality is degraded as a result of'the impoundment, corrective action to restore groundwater quality shall he implemented by the owner or operator as provided in G.S. 130A-309.20[9]." D_ E Q �� North Carolina Department of Environmental Quality 217 West Jones Street 1 1601 Mall Service Center I Raleigh. North Carolina 27699-1601 e�w��%.++ow� % 919.707.8600 Duke Energy is expected to comply with other closure requirements concerning groundwater corrective action for Asheville as required by CAMA and in conformance with Title 15A of the North Carolina Administrative Code 02L .0100 General Considerations of the Groundwater Classifications and Standards Rules. Any remaining soil contamination shall be addressed by the facility corrective action plan and incorporated into the groundwater fate and transport modeling. The date of this letter shall also serve as the beginning date for the 30-year post -closure monitoring period for the subject basin. If you have any questions, please contact Eric Smith at (919) 707-3669 or Edward Mussler at (919) 707-8281. Sincerely, kGrzyP75 Director Division of Water Resources Sincerely, Digitally signed by Edward F. Mussler 4 III i Date: 2022.10.17 14 0429-04'00' Edward F. Mussler III, P.E. Chief, Solid Waste Section Division of Waste Management cc: Landon Davidson — ARO Regional Office (electronic) Ted Campbell — ARO Regional Office (electronic) Sushma Masemore — DEQ (electronic) Toby Vinson — DEMLR (electronic) Ed Sullivan — Duke Energy (electronic) John Toepfer — Duke Energy (electronic) Scott Davies — Duke Energy (electronic) Ashley L. Healy — Duke Energy (electronic) GWRS Central Office File Copy North Carolina Department of Environmental Quality 217 West Jones Street 11601 Mail Service Center I Raleigh. North Carolina 27699-1601 919.707.8600 (� DUKE ENERGY: November 18, 2022 Ms. Sushma Masemore, P.E. Assistant Secretary for the Environment North Carolina Department of Environmental Quality 1613 Mail Service Center Raleigh, North Carolina 27699-1613 Jessica L. Bednarcik Senior Vice President Environmental Health & Safety Coal Combustion Products 526 South Church Street, ST06K Charlotte, NC 28202 o: 704.382, 8768 c: 704.907.8628 jessica.bednarcik@duke-energy.com Subject: Updated Corrective Action Plan Report for the Asheville Steam Electric Plant, Arden, Buncombe County, North Carolina, NPDES Permit No. NC0000396 Dear Ms. Masemore: Duke Energy is pleased to submit the enclosed updated Corrective Action Plan (CAP) for the Asheville Steam Electric Plant. As specified in the North Carolina Department of Environmental Quality (NCDEQ) electronic mail dated March 7, 2022, this updated CAP incorporates multi -media data collected in and around the former 1964 Ash Basin, former 1982 Ash Basin, and former coal pile area inclusive through Quarter 12022. The enclosed updated CAP recommends the following corrective actions at Asheville: • Source removal by excavation combined with monitored natural attenuation (MNA) as a polishing remedy along with a groundwater use restriction for the areas that include the former 1964 Ash Basin and former 1982 Ash Basin, as required by the Coal Ash Management Act of 2014, Session Law 2014-122 (CAMA); • Source removal by excavation and application of hydrated lime combined with MNA as a polishing remedy along with a groundwater and land use restrictions for an area that includes the former coal pile area; and • Implementation of an Effectiveness Monitoring Plan (EMP) with a five-year review period to monitor the effectiveness of corrective action. Source removal by excavation is the active groundwater remedy for the three source areas listed above. MNA is proposed as a polishing remedy for use in the areas with limited constituents of interest (COI) beyond the ash basin compliance boundary and in the vicinity of the former coal pile area. The use of MNA is based on generally stable or decreasing COI concentration trends in groundwater samples collected at the site and lack of COls above applicable standards in potential receptor areas (i.e., surface water). A groundwater use restriction is also proposed as an institutional control to prevent installation of water supply wells in a portion of the former coal pile area; CAMA already requires such designation of groundwater use restrictions. RECEIVED Ri;11DING ASMARTER FNFRGYF11T11RF" JUN U 7 2023 NCDEQ/DWR/NPDES Ms. Sushma Masemore, P.E. November 18, 2022 Page 2 As detailed in the enclosed updated CAP, source removal by excavation began at the site in 2007 and completed June 2022, approximately 5,304,504 tons of ash have been excavated from the former 1982 Ash Basin and approximately 3,083,898 tons of ash have been excavated from the former 1964 Ash Basin, while all coal was removed from the former coal pile area shortly after plant retirement in 2020. As specified in the NCDEQ letters dated June 8, 2021, and October 17, 2022, the 1982 Ash Basin and 1964 Ash Basin are in compliance with closure requirements of CAMA Sections 3(b) and 3(c) with the exception of 3(c)(3), which the enclosed updated CAP report addresses. The COI concentrations downgradient of the source areas vary but are generally stable or decreasing based on groundwater data collected to date. Evidence of conditions favorable for natural attenuation are indicated via multiple lines of evidence that include time trend analysis, geochemical evaluation and groundwater flow and transport modeling. The reduction in hydraulic head and mass contribution from the former source areas is anticipated to be sufficient for natural attenuation processes to reduce COI concentrations beyond the compliance boundary and in the vicinity of the former coal pile area. Effectiveness monitoring is proposed to confirm the stable or decreasing COI concentration trends currently indicated. The enclosed updated CAP report also concludes there is no evidence of unacceptable risks to humans and wildlife at Asheville attributed to coal or coal ash constituent migration in groundwater from the ash basins and former coal pile area. This conclusion is further supported by decades of water quality and biological assessments conducted by Duke Energy as part of NPDES and other site monitoring programs. If you have any questions on the enclosed information, please contact Ed Sullivan at 980-373-3719. Sincerely, ` J' essica L. Bednarcik Senior Vice President EHS and CCP Enclosure: Updated Corrective Action Plan, Asheville Steam Electric Plant cc: Ted Campbell — NCDEQ Asheville Regional Office Karen Higgins — NCDEQ Central Office Ed Sullivan — Duke Energy Jason Tillotson —Arcadis G&M of North Carolina, Inc. 7.3 Surface Water Monitoring ROY COOPER Governor ,IZABETH S. B1SER xetary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality January 9, 2023 Jessica Bednarcik, Senior Vice President Environmental, Health & Safety Duke Energy 526 South Church Street Mail Code EC3XP Charlotte, North Carolina 28202 Subject: Surface Water Evaluations Allen Steam Station, Asheville Steam Electric Plant, Belews Creek Steam Station, Buck Combined Cycle Station, Cape Fear Steam Electric Plant, James E. Rogers Energy Complex (Formerly Cliffside Steam Station), Dan River Combined Cycle Station, H. F. Lee Energy Complex, Marshall Steam Station, Mayo Steam Electric Plant, Riverbend Steam Station, Roxboro Steam Electric Plant, L. V. Sutton Energy Complex, and W. H. Weatherspoon Power Plant Dear Ms. Bednarcik: Per the Updated Corrective Action Plan (CAP) Conditional Approval letters or Updated Comprehensive Site Assessment (CSA) Comment letters for the subject sites, the North Carolina Department of Environmental Quality (DEQ) stated that it would provide additional comments and direction regarding surface water in an upcoming separate correspondence. This letter shall satisfy that comment and the surface water evaluation provided herein will assist Duke Energy with the preparation of required Surface Water Assessment Plans for the subject facilities. Please note that DEQ has previously provided surface water comments for the Roxboro Steam Electric Plant (Roxboro) in DEQ's Corrective Action Plan Update Conditional Approval and Additional Information Request Letter dated April 27, 2021. The evaluation for Roxboro provided in this correspondence shall supersede those comments. Methodolg& Evaluations were conducted by the DEQ Division of Water Resources (DWR). For each of the subject facilities, surface water data was evaluated for each sample location as identified in the facility's comprehensive data spreadsheet as noted below. Sample data were compared to surface water quality standards established in 15A NCAC 02B .0211 through .0225 (2B Standards), In - stream Target Values (ISTVs) calculated per 15A NCAC 02B .0208, and the U.S. Environmental Protection Agency's National Recommended Water Quality Criteria (EPA NRWQC). For the purpose of these evaluations, the 2B Standards took precedence over EPA NRWQC, and the EPA DNorth Carolina Department of Environmental Quality Di%isioo of Water Resources _ �� 512 North Salisbury Street 1611 Mail Service Center Raleigh. North Carolina 27699-1611 1 /� 919,707.9000 an Surface Water Evaluations Duke Energy January 9, 2023 NRWQC took precedence over ISTVs. DWR did not evaluate any surface water samples that were categorized as an "Area of Wetness" except if it was determined to be a non-dispositioned seep by Duke Energy in the comprehensive data spreadsheets as referenced below. Surface Water Data Used for Evaluation DEQ used the surface water data from Duke Energy's comprehensive data spreadsheets that are submitted to the DEQ DWR on a quarterly or semi-annual basis. The following is a list of the comprehensive data spreadsheets (as named by Duke Energy) that were used for the evaluation for each facility: • Allen Steam Station — Allen_All Media thru 2022-03 • Asheville Steam Electric Plant —Asheville All Media thru 2022-05 • Belews Creek Steam Station — REVISED _Belews_Comprehensive All Media thru 2022-05 • Buck Combined Cycle Station — Buck All Media thru 2022-03 • Cape Fear Steam Electric Plant — Cape Fear All Media thru 2022-03 san Ash Removal • James E. Rogers Energy Complex (formerly Cliffside Steam Station) — Cliffside_Comprehensive All Media thru 2022-02 • Dan River Combined Cycle Station — Dan River_ Comprehensive All Media thru 2021-12 • H. F. Lee Energy Complex — HF Lee All Media thru 2022-03 • Marshall Steam Station — Marshall All Media thru 2022-03 • Mayo Steam Electric Plant — Mayo All Media thru 2022-06 • Riverbend Steam Station — Riverbend All Media thru 2022-06 • Roxboro Steam Electric Plant — Roxboro All Media thru 2022-05 • L. V. Sutton Energy Complex — Sutton All Media thru 2022-03 • W. H. Weatherspoon Power Plant — Weatherspoon All Media thru 2022-05 These spreadsheets represent the cut-off dates for the data reviewed. Any data submitted after these dates was not evaluated. Letter Package Organization The "Surface Water Evaluation" attachments for each subject facility have two tables. The first table identifies the surface water body and classification for each of the surface water samples collected. The second table contains more specific information for each sampling location including any constituents of interest (COIs) detected above the 2B Standards, ISTVs, and/or EPA NRWQC, along with DWR's comments/observations and required actions. The required actions, if any, are listed in the last column. Included after each site -specific Surface Water Evaluation are two additional attachments that further identify the physical locations of the surface water samples: a map and a list of latitudes and longitudes. The "General Water Quality Required Actions" attachment contains general required actions applicable to all facilities. Page 2 of 4 Surface Water Evaluations Duke Energy January 9, 2023 Summary of Evaluation Results The following table summarizes DWR's findings. Facility Total No. of Surface Water Sampling Sites and Non- Dis ositioned Seeps Evaluated No. of Surface Water Sampling Sites and/or Non-Dispositioned Seeps with Required Actions Allen Steam Station 31 4 Asheville Steam Electric Plant 67 17 Belews Creek Steam Station 46 8 Buck Combined Cycle Station 20 9 Cape Fear Steam Electric Plant 44 2 James E. Rogers Energy Complex (formerly Cliffside Steam Station 48 7 Dan River Combined Cycle Station 29 1 H. F. Lee Energy Complex 33 0 Marshall Steam Station 22 9 Mao Steam Electric Plant 13 4 Riverbend Steam Station 21 3 Roxboro Steam Electric Plant 18 3 L. V. Sutton Energy Complex 24 0 W. H. Weatherspoon Power Plant 20 0 TOTALS 436 67 Required Documents Per the Updated CAP Conditional Approval letters or Updated CSA Comment letters for the subject sites, DEQ required the following from Duke Energy: Develop and submit a Surface Water Assessment Plan for DEQ approval to address monitoring of surface waters at the facility. The Plan shall include monitoring of non- dispositioned seeps to the extent that such monitoring is not part of routine NPDES monitoring. The Plan shall also account for any surface water features that emerge in or downgradient of the footprint of the former coal ash basin(s) during the closure and post - closure period and include a proposed monitoring schedule. If surface water standard exceedances caused by coal combustion residuals are identified or develop during the closure process, DEQ may require that the CAP be revised to address these exceedances. Within 90 days of receiving this letter, Duke Energy shall use the information provided in this letter, including any required actions, to develop a Surface Water Assessment Plan for each of the subject facilities. The Surface Water Assessment Plans shall be considered addendums to the CAPs or CSAs, as appropriate. After receiving the Surface Water Assessment Plans, DEQ will review them for approval or provide additional comments, if necessary. For the seeps at each facility regulated under a Special Order by Consent, the approval of the Surface Water Assessment Plans shall conclude Duke Energy's NPDES monitoring and reporting obligations as stated in the facility -specific Special Order by Consent termination letters. Page 3 of 4 Surface Water Evaluations Duke Energy January 9, 2023 For questions regarding groundwater assessments at each facility, please contact the appropriate DWR Regional Office staff. For questions concerning surface water standards and classifications, please contact Paul Wojoski at (919) 707-3631. For questions concerning the NPDES permits, please contact Sergei Chernikov at (919) 707-3606. Sincerely, Karen Higgins, Chief Water Planning Section Attachments: 1. Allen Steam Station Surface Water Evaluation (plus map and coordinates) 2. Asheville Steam Electric Plant Surface Water Evaluation (plus map and coordinates) 3. Belews Creek Steam Station Surface Water Evaluation (plus map and coordinates) 4. Buck Combined Cycle Station Surface Water Evaluation (plus map and coordinates) 5. Cape Fear Steam Electric Plant Surface Water Evaluation (plus map and coordinates) 6. Cliffside Steam Station Surface Water Evaluation (plus map and coordinates) 7. Dan River Combined Cycle Station Surface Water Evaluation (plus map and coordinates) 8. H. F. Lee Energy Complex Surface Water Evaluation (plus map and coordinates) 9. Marshall Steam Station Surface Water Evaluation (plus map and coordinates) 10. Mayo Steam Electric Plant Surface Water Evaluation (plus map and coordinates) 11. Riverbend Steam Station Surface Water Evaluation (plus map and coordinates) 12. Roxboro Steam Electric Plant Surface Water Evaluation (plus map and coordinates) 13. L. V. Sutton Energy Complex Surface Water Evaluation (plus map and coordinates) 14. W. H. Weatherspoon Power Plant Surface Water Evaluation (plus map and coordinates) 15. General Water Quality Required Actions cc (electronic): WQROS Asheville Regional Office Supervisor WQROS Fayetteville Regional Office Supervisor WQROS Mooresville Regional Office Supervisor WQROS Raleigh Regional Office Supervisor WQROS Washington Regional Office Supervisor WQROS Wilmington Regional Office Supervisor WQROS Winston-Salem Regional Office Supervisor Julie Grzyb — Division of Water Resources Assistant Director Karen Higgins — Water Planning Section Chief Paul Wojoski — Classifications, Standards, & Rules Review Branch Sergei Chernikov — Water Quality Permitting Section Bob Sledge — Water Quality Permitting Section Ed Sullivan — Duke Energy John Toepfer — Duke Energy Scott Davies — Duke Energy Page 4 of 4 Attachment 2 Asheville Steam Station Surface Water Evaluation Facility NPDES Permit: NC0000396 County: Buncombe Special Order by Consent: S 17-010 — Terminated May 18, 2022 Data Source The comprehensive surface water data that was used for this evaluation was current through May 2022 (Asheville All Media thru 2022-05). Classified Surface Waters and Associated Sampling Sites Surface Waters, Classifications, and Associated Sampling Locations Water Body and Location Classification Associated Sam ling Locations FB_DOWN, FB-D/S (downstream), FB-MID (downstream), French Broad River B FB_UP, FB-1, FB-1-A (upstream), FB-2, SW-FB1, SW-FB2, SWFBR-1 SWFBR-2 SWFBR-3 SWFBR-4 Powell Creek C SW-01 SW-7 2012 Lake Julian C SW-07 SWLJ-1 Other flows to Lake Julian C SW-06 Unnamed tributary (South of B SW-13(H1), SW-H2, SW-H3, SW-13 2012, P-01 1982 Basin Wetlands complex (between SW-02, SW-03, SW-04, SW-11 2012, SW-12 2012, F-03-B, highway and French Broad B K-01-A River Undetermined (may flow to SW-01_2012, SW-02_2012, SW-03_2012, SW-04_2012, French Broad River) B SW-05_2012, SW-06 2012, SW-08 2012, SW-09 2012, SW-10 2012, SW-l1. A-01-A. A-01-AA. TD-01 Non- Dis ositioned Seeps Sampling Receiving Classification Description Site Water Body Wetlands Non- Constructed Seep. Point of drainage to French Broad A-01 draining to B River from wetland/braided flow west of I-26. Northernmost French Broad sample locations near river. River Wetlands A-02 draining to B Non- Constructed Seep. Minor seep in wet area just upstream French Broad of A-01. Channeled flow drains toward A-0I location. River Wetlands Non- Constructed Seep. Point of drainage to French Broad B-01 draining to B River from wetland/braided flow west of I-26 and south of A - French Broad 01 River Unnamed Non- Constructed Seep. Point of drainage to French Broad C-01 Tributary to B River from wetland/braided flow west of 1-26 and south of B- the French 01. Broad River Unnamed Non- Constructed Seep. Monitoring location of UT below C-02 Tributaryto B 1964 Ash Basin for effects of general area seepage; site is Page I of 17 the French located just east of culvert under I-26. Stream flow is Broad River conveyed into wetland area draining toward C-01 location. Wetlands D-01 draining to B Non- Constructed Seep. Seep to established channel within French Broad wetlands west of I-26. Channel flows to C-01 location. River Wetlands draining to Non- Constructed Seep. Point of drainage to French Broad E-01 French Broad B River from wetland/braided flow west of I-26 and south of C- River 01 drainage. Wetlands draining to Non- Constructed Seep. Point of drainage to French Broad F-01 French Broad B River from wetland/braided flow west of I-26 and south of E- River 01 drainage. Wetlands draining to Non- Constructed Seep. Point of drainage to French Broad F-02 French Broad B River from wetland/braided flow west of I-26 and south of F- River 01 drainage. Wetlands Non- Constructed Seep. Monitoring location within wetland F-03 draining to B area west of 1-26, at outlet of culvert under I-26. May be French Broad remnant beaver pond. Flows toward F-01 location, then to River French Broad River. Unnamed tributary to Non- Constructed Seep. Monitoring location of UT below the Wetlands, 1982 Ash Basin dam, just east of culvert under I-26, K-01 drains to B conveying flow to wetlands west of I-26. Flows drain through French Broad wetlands past locations. F-03 and F-01 before entering River French Broad River. Wetlands Non- Constructed Seep. Monitoring location for coalescence M-01 draining to Not of seep flows prior to entering culvert under I-26. Flow French Broad Applicable' drains through wetlands to sampling location F-01 before River entering French Broad River. N-01 Unnamed Tributary to C Non- Constructed Seep. Seep to small channel upstream of Powell Creek its confluence with Powell Creek. Wetlands Ponded draining to Not Non- Constructed Seep. Ponded water near dry channel Water F French Broad Applicable' between locations B-01 and C-01. River Unnamed tributary to wetlands, Non- Constructed Seep. Western drain (Drain 1) from 1982 82EO-01 drains to B ash basin. Basin has been excavated and repurposed. Any French Broad flow would drain to K-01 and F-01 locations. River Unnamed tributary to Non- Constructed Seep. Eastern drain (Drain 2) from 1982 82EO-02 wetlands, B ash basin; east weir. Basin has been excavated and drains to repurposed. Any flow would drain to K-01 and F-01 French Broad locations. River ' DEQ has determined this is not a stream. Page 2 of 17 Unnamed tributary to French drain below divider dike between '64 and past '82 DD -Pipe wetlands, Not basin. Flow is into former 1982 basin footprint which was drains to Applicable z recently removed from the NPDES permit. Flow would drain French Broad toward M-01 location and then to sample point at F-01. River 2 This location will need a stream determination by DEQ. Page 3 of 17 Asheville Steam Electric Plant Station — Surface Water Standards Evaluation NPDES General Notes • The update to the permit renewal application submitted in 2014 provided instream sampling data for oil & grease, chemical oxygen demand (COD), chlorides, fluoride, sulfate, mercury, aluminum, barium, boron, calcium, hardness, iron, magnesium, manganese, zinc, antimony, arsenic, cadmium, chromium, copper, lead, molybdenum, nickel, selenium, thallium, total dissolved solids (TDS), total suspended solids (TSS), pH, temperature, specific conductance, and turbidity. The upstream monitoring station was located 5,500 ft. upstream of Outfall 001 and the downstream monitoring station was located 2,900 ft. downstream of the Outfall 001. • The following parameters were below detection level at both monitoring stations: oil & grease, COD, fluoride, mercury, boron, antimony, arsenic, cadmium, chromium, copper, lead, molybdenum, nickel, selenium, and thallium. The rest of the parameters did not indicate a significant difference between the upstream and the downstream monitoring locations except for specific conductance. • The permit requires monthly monitoring in French Broad River for total arsenic, total selenium, total mercury, total chromium, dissolved lead, dissolved cadmium, dissolved copper, dissolved zinc, total bromide, total hardness (as CaCO3), temperature, turbidity, and TDS. Parameters that Water Body Sampling Site Exceed a 2B Comments/Observations Required Actions for Use in Developing a Standard, EPA Surface Water Assessment Plan NRW C, or ISTV Dissolved Oxygen, • Dissolved Oxygen and Turbidity in stream FB_DOWN Turbidity likely due to factors other than contaminated • None groundwater. • Based on analysis of the samples, the 2B FB-D/S None standards were not violated at this sampling • None location during the evaluation period. • Based on analysis of the samples, the 2B FB-MID None standards were not violated at this sampling • None location during the evaluation period. French Broad pH, Dissolved • pH, Dissolved Oxygen, and Turbidity in stream River FB UP — Oxygen, Turbidity likelydue to factors other than contaminated • None groundwater. • Turbidity in stream likely due to factors other than contaminated groundwater. FB-1 Turbidity, Iron • The naturally occurring background • None concentrations for iron are high, therefore no 2B standard violation was observed for iron at this sampling location. • Based on analysis of the samples, the 2B FB-1-A None standards were not violated at this sampling • None location during the evaluation period. Page 4 of 17 • Turbidity in stream likely due to factors other than contaminated groundwater. FB-_ Turbidity, Iron • The naturally occurring background None concentrations for iron are high, therefore no 2B concentrations standard violation was observed for iron at this sampling location. • The naturally occurring background SW -FBI Iron concentrations for iron are high, therefore no 2B None standard violation was observed for iron at this standard sampling location. • Based on analysis of the samples, the 2B SW-FB2 None standards were not violated at this sampling None location during the evaluation period. • Copper exceedance is a transient standard excursion that might be related to the impacts from the boundary conditions. The sampling SWFBR-1 Copper site does not accurately represent instream None conditions. Permit sampling does not show copper standard violations in the main stem of the French Broad River. • Copper exceedance is a transient standard excursion that might be related to the impacts from the boundary conditions. The sampling SWFBR-2 Copper site does not accurately represent instream None conditions. Permit sampling does not show copper standard violations in the main stem of the French Broad River. • Copper exceedance is a transient standard excursion that might be related to the impacts from the boundary conditions. The sampling site does not accurately represent instream conditions. Permit sampling does not show SWFBR-3 Copper, Iron copper standard violations in the main stem of • None the French Broad River. • The naturally occurring background concentrations for iron are high, therefore no 2B standard violation was observed for iron at this sampling location. Page 5 of 17 • Copper exceedance is a transient standard excursion that might be related to the impacts from the boundary conditions. The sampling site does not accurately represent instream conditions. Permit sampling does not show SWFBR-4 Copper, Iron copper standard violations in the main stem of • None the French Broad River. • The naturally occurring background concentrations for iron are high, therefore no 2B standard violation was observed for iron at this sampling location. • The naturally occurring background concentrations for iron and manganese are high, Iron, Manganese, therefore no 2B standard violation was observed SW-0I Zinc for iron and manganese at this sampling • None location. Powell Creek . April 2015 dissolved Zinc value has the appearance of an outlier. • Based on analysis of the samples, the 2B SW-7 2012 None standards were not violated at this sampling None location during the evaluation period. • Turbidity in stream likely due to factors other than contaminated groundwater. • The naturally occurring background Other (flows Turbidity, Iron, concentrations for iron are high, therefore no 2B to Lake SW-06 Copper standard violation was observed for iron at this • None Julian) sampling location. • Isolated copper standard exceedance from a sampling location beyond the estimated extent of contaminated groundwater influence. • pH in stream likely due to factors other than contaminated groundwater. • The naturally occurring background pH, Iron, concentrations for iron are high, therefore no 2B Lake Julian SW-07 Manganese, Zinc standard violation was observed for iron at this None sampling location. • Zinc exceedance is a transient standard excursion that might be related to the impacts from the boundary conditions. The sampling Page 6 of 17 site does not accurately represent instream conditions. Permit sampling does not show zinc standard violations in Lake Julian. • Based on analysis of the samples, the 2B SWLJ-1 None standards were not violated at this sampling • None location during the evaluation period. • Based on analysis of the samples, the 2B SW-13(H1) None standards were not violated at this sampling • None location during the evaluation period. • Based on analysis of the samples, the 2B SW-1-12 None standards were not violated at this sampling • None Unnamed location during the evaluation period. tributary • Based on analysis of the samples, the 2B (South of SW-1-13 None standards were not violated at this sampling • None 1982 Basin) location during the evaluation period. • Based on analysis of the samples, the 2B S W-13 2012 None standards were not violated at this sampling • None location during the evaluation period.. P-0I Turbidity • Turbidity in stream likely due to factors other • None than contaminated groundwater. • pH and Dissolved Oxygen in stream likely due to factors other than contaminated groundwater. pH, Dissolved • The naturally occurring background Oxygen, Iron, concentrations for iron and manganese are high, SW-02 Manganese, Cobalt, therefore no 2B standard violation was observed • None Zinc for iron or manganese at this sampling location. Wetlands • One-time 2015 monitoring of location within complex wetland complex. Nearby outlet locations are (between better options to characterize surface water. highway and • Based on analysis of the samples, the 2B French Broad S W-03 None standards were not violated at this sampling • None River) location during the evaluation period. • pH, Dissolved Oxygen, and Turbidity in stream pH. Dissolved likely due to factors other than contaminated SW-04 Oxygen, Turbidity, groundwater. None Iron, Manganese, • The naturally occurring background Cobalt, Selenium concentrations for iron and manganese are high, therefore no 2B standard violation was observed Page 7 of 17 for iron and manganese at this sampling location. • 2015 monitoring of location within wetland complex. Nearby outlet locations are better options to characterize surface water. • Based on analysis of the samples, the 2B SW-11 2012 None standards were not violated at this sampling • None location during the evaluation period. • Based on analysis of the samples, the 2B S W-12 2012 None standards were not violated at this sampling • None location during the evaluation period. • The naturally occurring background A-01-A Manganese concentrations for manganese are high, therefore • None no 2B standard violation was observed for manganese at this sampling location. • The naturally occurring background A-01-AA Manganese concentrations for manganese are high, therefore • None no 2B standard violation was observed for manganese at this sampling location. • pH in stream likely due to factors other than contaminated groundwater. pH, Manganese, • The naturally occurring background Cadmium, Cobalt, concentrations for manganese are high, therefore Wetlands F-03-B Copper, Nickel, no 2B standard violation was observed for • None complex Zinc manganese at this sampling location. (between • Short tern monitoring to investigate stormwater highway and discharge influence. Standard exceedances not French Broad associated with groundwater impacts. River) • pH and Turbidity in stream likely due to factors other than contaminated groundwater. pH, Turbidity, Iron, • The naturally occurring background Manganese, concentrations for iron and manganese are high, K-01-A Mercury, Cadmium, therefore no 2B standard violation was observed . None Cobalt, Copper, for iron and manganese at this sampling Nickel, Zinc location. • Short term monitoring to investigate stormwater discharge influence. Standard exceedances not associated with groundwater impacts. Page 8 of 17 • Based on analysis of the samples, the 2B S W-01 2012 None standards were not violated at this sampling • None location during the evaluation period. • Based on analysis of the samples, the 2B SW-02 2012 None standards were not violated at this sampling • None location during the evaluation period. • Based on analysis of the samples, the 2B SW-03 2012 None standards were not violated at this sampling • None location during the evaluation period. • Based on analysis of the samples, the 2B SW-04 2012 None standards were not violated at this sampling • None location during the evaluation period. • Based on analysis of the samples, the 2B SW-05_2012 None standards were not violated at this sampling • None location during the evaluation period. Undetermined (may flow to • Based on analysis of the samples, the 2B French Broad SW-06_2012 None standards were not violated at this sampling • None River) location duringthe evaluation period. • Based on analysis of the samples, the 2B SW-08 2012 None standards were not violated at this sampling • None location during the evaluation period. • Based on analysis of the samples, the 2B SW-09 2012 None standards were not violated at this sampling • None location during the evaluation period. • Based on analysis of the samples, the 2B SW-10_2012 None standards were not violated at this sampling • None location during the evaluation period. • Based on analysis of the samples, the 2B SW-1 I None standards were not violated at this sampling • None location during the evaluation period. • Based on analysis of the samples, the 2B TD-01 None standards were not violated at this sampling • None location during the evaluation period. 2B Standard(s) — 15A NCAC 02B .0200 Surface Water Quality Standards EPA NRWQC — Environmental Protection Agency National Recommended Water Quality Criteria ISTV — In -Stream Target Value Page 9 of 17 Asheville Steam Station — Surface Water Standards Evaluation Non-Dis ositioned Seeps) Sample Site Parameters that Exceed a 2B Standard, EPA Comments/Observations Required Actions for Use in Developing a Surface NRW C, or ISTV Water Assessment Plan • The sampling data that was reviewed was determined to have been collected prior to or during the implementation of the SOC; therefore, no evaluation was performed. . Per the SOC termination letter dated May 18, 2022, • On August 14 and 15, 2017, DWR Central Duke Energy shall continue monitoring and reporting Office staff along with Winston-Salem of this seep as established in the SOC until approval A-01 _ Regional Office staff conducted an evaluation of the Surface Water Assessment Plan required in of AOW identified by Duke and Duke's DEQ's Comprehensive Site Assessment comments Asheville Plant in Buncombe County. Staff also dated July 14, 2021. reviewed notes from previous DWR site visit . This seep shall be included in the EMP. (9-28-16), USGS maps, NRCS Soil Survey maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff determined that this seep was classified as a surface water. • The sampling data that was reviewed was determined to have been collected prior to or during the implementation of the SOC; therefore, no evaluation was performed. . Per the SOC termination letter dated May 18, 2022, • On August 14 and 15, 2017, DWR Central Duke Energy shall continue monitoring and reporting Office staff along with Winston-Salem of this seep as established in the SOC until approval A-02 _ Regional Office staff conducted an evaluation of the Surface Water Assessment Plan required in of AOW identified by Duke and Duke's DEQ's Comprehensive Site Assessment comments Asheville Plant in Buncombe County. Staff also dated July 14, 2021. reviewed notes from previous DWR site visit • This seep shall be included in the EMP. (9-28-16), USGS maps, NRCS Soil Survey maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff determined that this seep was classified as a surface water. • The sampling data that was reviewed was • Per the SOC termination letter dated May 18, 2022, determined to have been collected prior to or Duke Energy shall continue monitoring and reporting B-01 _ during the implementation of the SOC; of this seep as established in the SOC until approval therefore, no evaluation was performed. of the Surface Water Assessment Plan required in • On August 14 and 15, 2017, DWR Central DEQ's Comprehensive Site Assessment comments Office staff along with Winston-Salem dated July 14, 2021. Page 10 of 17 C-01 C-02 D-01 Regional Office staff conducted an evaluation of AOW identified by Duke and Duke's Asheville Plant in Buncombe County. Staff also reviewed notes from previous DWR site visit (9-28-16), USGS maps, NRCS Soil Survey maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff determined that this seep was classified as a surface water. The sampling data that was reviewed was determined to have been collected prior to or during the implementation of the SOC; therefore, no evaluation was performed. On August 14 and 15, 2017, DWR Central Office staff along with Winston-Salem Regional Office staff conducted an evaluation of AOW identified by Duke and Duke's Asheville Plant in Buncombe County. Staff also reviewed notes from previous DWR site visit (9-28-16), USGS maps, NRCS Soil Survey maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff determined that this seep was classified as a surface water. The sampling data that was reviewed was determined to have been collected prior to or during the implementation of the SOC; therefore, no evaluation was performed. On August 14 and 15, 2017, DWR Central Office staff along with Winston-Salem Regional Office staff conducted an evaluation of AOW identified by Duke and Duke's Asheville Plant in Buncombe County. Staff also reviewed notes from previous DWR site visit (9-28-16), USGS maps, NRCS Soil Survey maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff determined that this seep was classified as a surface water. The sampling data that was reviewed was determined to have been collected prior to or during the implementation of the SOC; no evaluation was Page 11 of 17 • This seep shall be included in the EMP. Per the SOC termination letter dated May 18, 2022, Duke Energy shall continue monitoring and reporting of this seep as established in the SOC until approval of the Surface Water Assessment Plan required in DEQ's Comprehensive Site Assessment comments dated July 14, 2021. This seep shall be included in the EMP. Per the SOC termination letter dated May 18, 2022, Duke Energy shall continue monitoring and reporting of this seep as established in the SOC until approval of the Surface Water Assessment Plan required in DEQ's Comprehensive Site Assessment comments dated July 14, 2021. This seep shall be included in the EMP. • Per the SOC termination letter dated May 18, 2022, Duke Energy shall continue monitoring and reporting of this seep as established in the SOC until approval of the Surface Water Assessment Plan required in • On August 14 and 15, 2017, DWR Central DEQ's Comprehensive Site Assessment comments Office staff along with Winston-Salem dated July 14, 2021. Regional Office staff conducted an evaluation • This seep shall be included in the EMP. of AOW identified by Duke and Duke's Asheville Plant in Buncombe County. Staff also reviewed notes from previous DWR site visit (9-28-16), USGS maps, NRCS Soil Survey maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff determined that this seep was classified as a surface water. • The sampling data that was reviewed was determined to have been collected prior to or during the implementation of the SOC; therefore, no evaluation was performed. Per the SOC termination letter dated May 18, 2022, • On August 14 and 15, 2017, DWR Central Duke Energy shall continue monitoring and reporting Office staff along with Winston-Salem of this seep as established in the SOC until approval E-01 _ Regional Office staff conducted an evaluation of the Surface Water Assessment Plan required in of AOW identified by Duke and Duke's DEQ's Comprehensive Site Assessment comments Asheville Plant in Buncombe County. Staff also dated July 14, 2021. reviewed notes from previous DWR site visit • This seep shall be included in the EMP. (9-28-16), USGS maps, NRCS Soil Survey maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff determined that this seep was classified as a surface water. • The sampling data that was reviewed was determined to have been collected prior to or during the implementation of the SOC; therefore, no evaluation was performed. • Per the SOC termination letter dated May 18, 2022, • On August 14 and 15, 2017, DWR Central Duke Energy shall continue monitoring and reporting Office staff along with Winston-Salem of this seep as established in the SOC until approval F-01 - Regional Office staff conducted an evaluation of the Surface Water Assessment Plan required in of AOW identified by Duke and Duke's DEQ's Comprehensive Site Assessment comments Asheville Plant in Buncombe County. Staff also dated July 14, 2021. reviewed notes from previous DWR site visit • This seep shall be included in the EMP. (9-28-16), USGS maps, NRCS Soil Survey maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff determined that this seep was classified as a surface water. F-02 _ • The sampling data that was reviewed was • Per the SOC termination letter dated May 18, 2022, determined to have been collected prior to or Duke Energy shall continue monitoring and reporting Page 12 of 17 F-03 K-01 during the implementation of the SOC; therefore, no evaluation was performed. On August 14 and 15, 2017, DWR Central Office staff along with Winston-Salem Regional Office staff conducted an evaluation of AOW identified by Duke and Duke's Asheville Plant in Buncombe County. Staff also reviewed notes from previous DWR site visit (9-28-16), USGS maps, NRCS Soil Survey maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff determined that this seep was classified as a surface water. The sampling data that was reviewed was determined to have been collected prior to or during the implementation of the SOC; therefore, no evaluation was performed. On August 14 and 15, 2017, DWR Central Office staff along with Winston-Salem Regional Office staff conducted an evaluation of AOW identified by Duke and Duke's Asheville Plant in Buncombe County. Staff also reviewed notes from previous DWR site visit (9-28-16), USGS maps, NRCS Soil Survey maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff determined that this seep was classified as a surface water. The sampling data that was reviewed was determined to have been collected prior to or during the implementation of the SOC; therefore, no evaluation was performed. On August 14 and 15, 2017, DWR Central Office staff along with Winston-Salem Regional Office staff conducted an evaluation of AOW identified by Duke and Duke's Asheville Plant in Buncombe County. Staff also reviewed notes from previous DWR site visit (9-28-16), USGS maps, NRCS Soil Survey maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff determined that this seep was classified as a surface water. Page 13 of 17 of this seep as established in the SOC until approval of the Surface Water Assessment Plan required in DEQ's Comprehensive Site Assessment comments dated July 14, 2021. • This seep shall be included in the EMP. Per the SOC termination letter dated May 18, 2022, Duke Energy shall continue monitoring and reporting of this seep as established in the SOC until approval of the Surface Water Assessment Plan required in DEQ's Comprehensive Site Assessment comments dated July 14, 2021. This seep shall be included in the EMP. Per the SOC termination letter dated May 18, 2022, Duke Energy shall continue monitoring and reporting of this seep as established in the SOC until approval of the Surface Water Assessment Plan required in DEQ's Comprehensive Site Assessment comments dated July 14, 2021. This seep shall be included in the EMP. • The sampling data that was reviewed was determined to have been collected prior to or during the implementation of the SOC; therefore, no evaluation was performed. . Per the SOC termination letter dated May 18, 2022, • On August 14 and 15, 2017, DWR Central Duke Energy shall continue monitoring and reporting Office staff along with Winston-Salem of this seep as established in the SOC until approval Regional Office staff conducted an evaluation of the Surface Water Assessment Plan required in M-01 - of AOW identified by Duke and Duke's DEQ's Comprehensive Site Assessment comments Asheville Plant in Buncombe County. Staff also dated July 14, 2021. Duke Energy shall visually inspect this location reviewed notes from previous DWR site visit periodically to determine if conditions have changed (9-28-16), USGS maps, NRCS Soil Survey such that it may warrant DWR staff performing a maps, and the Jurisdictional Wetlands and stream evaluation. Stream Survey for the site. Staff concluded that this seep was not to be stream and therefore not subject to the 2B standards. • The sampling data that was reviewed was determined to have been collected prior to or during the implementation of the SOC; therefore, no evaluation was performed. • Per the SOC termination letter dated May 18, 2022, • On August 14 and 15, 2017, DWR Central Duke Energy shall continue monitoring and reporting Office staff along with Winston-Salem of this seep as established in the SOC until approval N-01 _ Regional Office staff conducted an evaluation of the Surface Water Assessment Plan required in of AOW identified by Duke and Duke's DEQ's Comprehensive Site Assessment comments Asheville Plant in Buncombe County. Staff also dated July 14, 2021. reviewed notes from previous DWR site visit • This seep shall be included in the EMP. (9-28-16), USGS maps, NRCS Soil Survey maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff determined that this seep was classified as a surface water. • The sampling data that was reviewed was determined to have been collected prior to or . Per the SOC termination letter dated May 18, 2022, during the implementation of the SOC; Duke Energy shall continue monitoring and reporting therefore, no evaluation was performed. of this seep as established in the SOC until approval • On August 14 and 15, 2017, DWR Central of the Surface Water Assessment Plan required in Ponded Water F - Office staff along with Winston-Salem DEQ's Comprehensive Site Assessment comments dated July 14, 2021. Regional Office staff conducted an evaluation . Duke Energy shall visually inspect this location of AOW identified by Duke and Duke's Asheville Plant in Buncombe County. Staff also periodically to determine if conditions have changed reviewed notes from previous DWR site visit such that it may warrant DWR staff performing a 9-28-16 , USGS maps, NRCS Soil Survey stream evaluation. Page 14 of 17 82EO-01 82EO-02 maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff concluded that this seep was not to be stream and therefore not subject to the 2B standards. The sampling data that was reviewed was determined to have been collected prior to or during the implementation of the SOC; therefore, no evaluation was performed. On August 14 and 15, 2017, DWR Central Office staff along with Winston-Salem Regional Office staff conducted an evaluation of AOW identified by Duke and Duke's Asheville Plant in Buncombe County. Staff also reviewed notes from previous DWR site visit (9-28-16), USGS maps, NRCS Soil Survey maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff determined that this seep was classified as a surface water. The sampling data that was reviewed was determined to have been collected prior to or during the implementation of the SOC; therefore, no evaluation was performed. On August 14 and 15, 2017, DWR Central Office staff along with Winston-Salem Regional Office staff conducted an evaluation of AOW identified by Duke and Duke's Asheville Plant in Buncombe County. Staff also reviewed notes from previous DWR site visit (9-28-16), USGS maps, NRCS Soil Survey maps, and the Jurisdictional Wetlands and Stream Survey for the site. Staff determined that this seep was classified as a surface water. • The sampling data that was reviewed was determined to have been collected prior to or DD-Pipe _ during the implementation of the SOC; therefore, no evaluation was performed. • This location has not evaluated to determine if it is a stream and subject to 2B standards. Page 15 of 17 Per the SOC termination letter dated May 18, 2022, Duke Energy shall continue monitoring and reporting of this seep as established in the SOC until approval of the Surface Water Assessment Plan required in DEQ's Comprehensive Site Assessment comments dated July 14, 2021. This seep shall be included in the EMP. • Per the SOC termination letter dated May 18, 2022, Duke Energy shall continue monitoring and reporting of this seep as established in the SOC until approval of the Surface Water Assessment Plan required in DEQ's Comprehensive Site Assessment comments dated July 14, 2021. • This seep shall be included in the EMP. • Per the SOC termination letter dated May 18, 2022, Duke Energy shall continue monitoring and reporting of this seep as established in the SOC until approval of the Surface Water Assessment Plan required in DEQ's Comprehensive Site Assessment comments dated July 14, 2021. • Duke Energy shall work with DWR's 401 & Buffer Permitting Branch to determine if this location constitutes a stream. If it is determined to be a stream, then it shall be included in the EMP. If it is determined not to be a stream, then Duke Energy shall visually inspect this location periodically to determine if conditions have changed such that it may warrant DWR staff performing a stream evaluation. 2B Standard(s) — 15A NCAC 02B .0200 Surface Water Quality Standards AOW — Area of Wetness DEQ — North Carolina Department of Environmental Quality DWR — North Carolina Department of Environmental Quality's Division of Water Resources EPA NRWQC — Environmental Protection Agency National Recommended Water Quality Criteria EMP — Effectiveness Monitoring Plan ISTV — In -Stream Target Value SOC — Special Order by Consent The following sample locations were sampled one time for a limited number of constituents of interest. These were not evaluated. 2014007162 2014007178 2014007191 2014007210 AVLLK067 AVLSTR005 AVLSTR054 AVLTD090 2014007163 2014007179 2014007194 2014007211 AVLPOND053 AVLSTR006 AVLSTR056 AVLWTLD008 2014007164 2014007180 2014007199 2014007212 AVLSDO009 AVLSTR007 AVLSTR057 AVLWTLDOIO 2014007165 2014007181 2014007200 2014007235 AVLSDO015 AVLSTR012 AVLSTR060 AVLWTLD058 2014007166 2014007182 2014007201 2014007236 AVLSEEP002 AVLSTR013 AVLSTR061 AVLWTLD059 2014007170 2014007183 2014007202 2014007237 AVLSEEP004 AVLSTR014 AVLSTR063 AVLWTLD062 2014007171 2014007184 2014007203 2014007238 AVLSEEPOII AVLSTR016 AVLSTR064 AVLWW001 2014007172 2014007185 2014007204 2014007239 AVLSEEP019 AVLSTR017 AVLSTR065 AVLWW055 2014007173 2014007186 2014007205 2014007240 AVLSEEP020 AVLSTR018 AVLTD066 AVLWW069 2014007174 2014007187 2014007206 2014007241 AVLSEEP021 AVLSTR023 AVLTD070 AVLWW072 2014007175 2014007188 2014007207 2014007242 AVLSEEP022 AVLSTR024 AVLTD071 AVLWW076 2014007176 2014007189 2014007208 64EO-01+02 AVLSEEP075 AVLSTR051 AVLTD073 CC-01 2014007177 2014007190 2014007209 1 AVLHPND068 AVLSTR003 AVLSTR052 AVLTD074 K-02 SD-01 The following sample locations were sampled two times for a limited number of constituents of interest. These were not evaluated. FLF-SW-02 I LF-SW-03 Page 16 of 17 The following sample locations have several sampling events. No location data is provided. These were not evaluated. N-01 Downstream I Separator Dike The following sample location was within the 1964 Basin and was not evaluated. SW-05 The following sample locations had one sample event and were on the opposite side of the French Broad River to the coal ash impoundment. They each had one sample taken in 2016. They were not evaluated. SW-100 I SW-101 SW-102 1 SW-103 I SW-104 The followina non-disnositioned seens were not evaluated along with the rationale. 64EO-01 Became permitted outfall during NPDES permit renewal. 64EO-02 Became permitted outfall during NPDES permit renewal. 64EO-03 Became permitted outfall during NPDES permit renewal. C-03 Flow drains to 64EO-3, the 1964 engineered outfall collection system. This non -constructed seep flows to a portion of an NPDES wastewater treatments stem. C-05 Flow drains to 64EO-3, the 1964 engineered outfall collection system. This non -constructed seep flows to a ortion of an NPDES wastewater treatments stem. Page 17 of 17 .own moo - ' .. LEGEND • SEEP AND SURFACE WATER SAMPLE LOCATIONS NPDES OUTFALL LOCATION (APPROXIMATE) 1964ASH BASIN WASTE BOUNDARY - - FORMER 1982 ASH BASIN WASTE BOUNDARY - - - COMPLIANCE BOUNDARY DUKE ENERGY PROGRESS PROPERTY LINE —310 STREAM AND FLOW DIRECTION (TWT 2016) FORMER FLUE GAS DESULFURIZATION (FGD) WETLANDS ✓I_;7] WETLAND (TWT 2016) —SURFACE WATER FLOW DIRECTION NOTES: 1. THE DEPICTED STREAMS AND WETLANDS DATA WERE APPROVED BYTHE US ARMY CORPS OF ENGINEERS (USACE) ON MAY 19, 2016 - JURISDICTIONAL DETERMINATION SAW-2014-00189. TAYLOR WSEMAN AND TAYLOR O WT) PERFORMED THE SURVEY OF THE FEATURES. 2. ALL BOUNDARIES ARE APPROXIMATE. 3. PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY PROGRESS, LLC. 4. AERIAL PHOTOGRAPHY OBTAINED FROM NORTH CAROLINA ONE MAP ON FEBRUARY 20, 2020. AERIAL DATED JANUARY 1, 2019. 5. DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE PLANE COORDINATE SYSTEM FIPS 3200 (NAD83). FIGURE 1-2C SITE LAYOUT MAP - SEEP AND SURFACE WATER SAMPLE LOCATIONS 2020 COMPREHENSIVE SITE ASSESSMENT UPDATE ASHEVILLE STEAM ELECTRIC PLANT ARDEN, NORTH CAROLINA Attachment 2c Asheville Steam Electric Plant Location ID Location Description Latitude Longitude A-01-A Upgradient of A-01 AOW location 35.47087000 -82.55259000 A-01-AA Upgradient of A-0I-A surface water location 35.46967000 -82.55207000 F-03-B Downgradient of F-03 AOW location 35.46321000 -82.54694000 FB-01 Upstream of site on French Broad River 35.45752700 -82.54484600 FB-01-A Boat landing off of Pinner Rd 35.45442000 -82.54762000 FB-02 Downstream of site on French Broad River 35.47347900 -82.55437700 FB-D/S French Broad River adjacent to MW-11 35.47348000 -82.55397000 FB-MID French Broad River between MW-16 and MW-17 35.46852000 -82.55164000 French Broad Downstream French Broad Downstream 35.47309000 -82.55421475 French Broad Upstream French Broad Upstream 35.46087000 -82.54694146 K-01-A Upgradient of K-01 AOW location 35.46366000 -82.54527000 SW-01 Powell Creek 35.47427636 -82.55238588 SW-01_2012 Surface water below 1964 basin near toe drain 35.46684059 -82.54858215 SW-02 Within French Broad Flood Plain 35.47265718 -82.55322795 SW-02 2012 Surface water near C-02 35.46705287 -82.54849330 SW-03 Within French Broad Flood Plain 35.47173662 -82.55286131 SW-03_2012 Surface water below 1964 basin near toe 35.46759449 -82.54867755 SW-04 Within French Broad Flood Plain 35.46982699 -82.55200135 SW-04 2012 Surface water near K-02 35.46335794 -82.54429095 SW-05 2012 Surface water at 1982 basin toe drain 35.46399117 -82.54478158 SW-06 Southern arm of Lake Julian 35.46254264 -82.53325978 SW-06 2012 Surface water at 1982 basin toe drain 35.46395773 -82.54473777 Page 1 of 4 Attachment 2c SW-07 Eastern arm of Lake Julian 35.47388006 -82.52658634 SW-07 2012 Surface water below Lake Julian dam 35.47453456 -82.54781245 SW-08 2012 Surface water near M-01 35.46432987 -82.54680475 SW-09 2012 Surface water near M-01 35.46426064 -82.54668758 SW-10 2012 Surface water near M-01 35.46421986 -82.54671862 SW-11 2012 Surface water near D-01 35.46575877 -82.54927121 SW-12 2012 Surface water near C-01 35.46608655 -82.54952340 SW-13 (H1) Surface water near P-01 35.46196635 -82.54440066 SW-13 2012 Surface water near P-01 35.46196635 -82.54440066 SW -FBI French Broad upstream of plant 35.45997371 -82.54524381 SW-FB2 French Broad River near CB-05 35.46108790 -82.54651301 SWFBR-01 Beneath Glenn Bridge RD Bridge 35.45506900 -82.54713900 SWFBR-02 Transmission Right -of -Way S of 1982 basin 35.46245500 -82.54782400 SWFBR-03 N/Downstream of SWFBR-02, W of 1964 basin 35.46521000 -82.54981200 SWFBR-04 Upstream of Outfall 35.47356300 -82.55397100 SW-H2 Pond adjacent to New Rockwood Rd 35.46188695 -82.54073795 SW-H3 Surface water along Spring Hill Cir 35.46177499 -82.53979291 SW-I1 Surface water at 404 Glenn Bridge Rd 35.45712991 -82.54439691 SWLJ-01 Adjacent to Settling Pond in Lake Julian 35.47298600 -82.54514000 TD-01 Toe drain at 1964 basin 35.46697288 -82.54843596 P-01 Upstream of I-26 culvert at SW property corner 35.46185000 -82.54462501 Non-Dispositioned Seeps A 0l Non- Constructed Seep. Point of drainage to French Broad River from wetland/braided flow west of I-26. Northernmost sample locations near river. 35.47125300 -82.55291401 A-02 Non- Constructed Seep. Minor seep in wet area just upstream of A-01. 35.47115500 -82.55259601 Page 2 of 4 Attachment 2c Channeled flow drains toward A-0I location. Non- Constructed Seep. Point of drainage B-01 to French Broad River from 35.46859500 -82.55141801 wetland/braided flow west of I-26 and south of A-01. Non- Constructed Seep. Point of drainage C-01 to French Broad River from 35.46604200 -82.54970101 wetland/braided flow west of 1-26 and south of B-01. Non- Constructed Seep. Monitoring location of UT below 1964 Ash Basin for C-02 effects of general area seepage; site is 35.46689100 -82.54865101 located just east of culvert under I-26. Stream flow is conveyed into wetland area draining toward C-01 location. Non- Constructed Seep. Seep to D-01 established channel within wetlands west 35.46601300 -82.54958401 of I-26. Channel flows to C-01 location. Non- Constructed Seep. Point of drainage E-01 to French Broad River from 35.46506100 -82.54944001 wetland/braided flow west of I-26 and south of C-01 drainage. Non- Constructed Seep. Point of drainage F-01 to French Broad River from 35.46358100 -82.54854001 wetland/braided flow west of I-26 and south of E-01 drainage. Non- Constructed Seep. Point of drainage F-02 to French Broad River from 35.46253300 -82.54749901 wetland/braided flow west of I-26 and south of F-01 drainage. Non- Constructed Seep. Monitoring location within wetland area west of I-26, F-03 at outlet of culvert under 1-26. May be 35.46311400 -82.54717701 remnant beaver pond. Flows toward F-01 location, then to French Broad River. Non- Constructed Seep. Monitoring location of UT below the 1982 Ash Basin K-01 dam, just east of culvert under I-26, 35.46305100 -82.54575101 conveying flow to wetlands west of I-26. Flows drain through wetlands past Noe 3 of 4 Attachment 2c locations. F-03 and F-01 before entering French Broad River. Non- Constructed Seep. Monitoring location for coalescence of seep flows M-01 prior to entering culvert under I-26. Flow 35.46426600 -82.54671201 drains through wetlands to sampling location F-0I before entering French Broad River. Non- Constructed Seep. Seep to small N-01 channel upstream of its confluence with 35.47408800 -82.55153201 Powell Creek. Ponded Water Non- Constructed Seep. Ponded water F near dry channel between locations B-01 35.46723200 -82.55052101 and C-01. Non- Constructed Seep. Western drain 82EO-01 (Drain 1) from 1982 ash basin. Basin has 35.46405800 -82.54484801 been excavated and repurposed. Any flow would drain to K-0I and F-0I locations. Non- Constructed Seep. Eastern drain (Drain 2) from 1982 ash basin; east weir. 82EO-02 Basin has been excavated and repurposed. 35.46405800 -82.54484801 Any flow would drain to K-0I and F-01 locations. French drain below divider dike between '64 and past'82 basin. Flow is into former DD -Pipe 1982 basin footprint which was recently 35.466724 -82.544403 removed from the NPDES permit. Flow would drain toward M-01 location and then to sample point at F-01. Page 4 of 4 Attachment 15 General Surface Water OualW Requirements Applicable to All Facilities For all surface water sampling locations required to be included in the facility Interim Monitoring Plan(II M or Effectiveness Monitoring Plan (EMP) (whichever is applicable), the locations shall: a. be sampled, at a minimum, for the approved site -specific groundwater constituents of interest per the IMPS or EMPs; b. be sampled on a frequency to be approved by the North Carolina Department of Environmental Quality (DEQ) Division of Water Resources (DWR) Regional Office; c. be sampled using an appropriate methodology as approved by the DEQ DWR Regional Office (see note 5 below); and d. include at least one appropriate background location that is sampled for the same approved parameters and at the same approved frequency (note that a background location may be appropriate for multiple downstream locations). 2. For all surface water sampling locations, including areas of wetness, not required to be included in the facility UVIP or EMP: a. Duke Energy shall determine if the location is appropriate for inclusion in the facility HAP or EMP and propose any of those locations to the applicable DEQ DWR Regional Office for approval; b. All surface water sampling points shall be sampled, at a minimum, for the approved site - specific groundwater constituents of interest per the IMPS or EMPs and include at least one appropriate background location that is sampled for the same approved parameters and at the same approved frequency (note that a background location may be appropriate for multiple downstream locations); and c. All proposed sample locations, parameters to be monitored, sampling methodologies (see note 5 below), and sampling frequencies shall be approved by the applicable DEQ DWR Regional Office prior to inclusion in the PAP or EMP. 3. All surface water sampling events shall include: a, sampling for hardness and turbidity, and b. analysis for both total and dissolved metals to determine compliance with 15A NCAC 02B standards, including hardness -based metals compliance. 4. For all surface water locations, including areas of wetness, not proposed or required to be included in the IMPS or END Duke Energy may discontinue sampling unless otherwise directed by DEQ. DEQ may require additional periodic sampling to determine compliance with the 15A NCAC 02B .0200 surface water standards or to evaluate site conditions or the effectiveness of the remedial strategy as excavation and/or closure of the basins progress. 5. Grab sampling for surface water parameters is acceptable for monitoring purposes. However, DEQ may require chronic/acute sampling to determine compliance with 15A NCAC 02B .0200 surface water standards. This will depend on factors such as the concentrations observed and data trends. Please refer to DEQ's Internal Technical Guidance: Evaluating Impacts to Surface Water from Page 1 of 2 Discharging Groundwater Plumes memorandum dated October 31, 2017, and 15A NCAC 02B .0211(11). 6. Any streams that may reform within the limits of an excavated coal ash impoundment will require consultation with DEQ on a case -by -case basis to determine the proper course of action. 7. When a facility's NPDES permit is proposed for termination, Duke Energy and the DEQ DWR Regional Office shall meet prior to its termination to discuss the appropriate next steps regarding any surface water locations and any non-dispositioned seeps that may have been sampled per the NPDES permit. 8. For all seeps that do not have stream classifications and continue to exhibit flow, Duke Energy shall request stream determinations from the DEQ DWR's 401 & Buffer Permitting Branch. If they are detemuned to be streams, then they shall be included in the facility IMP or ENV (whichever is applicable). If they are determined not to be streams, then Duke Energy may discontinue their sampling unless otherwise directed. 9. For all seeps that stop exhibiting flow, Duke Energy shall propose a methodology for their dispositioning. 10. Please note that for any surface water location(s) requiring corrective actions due to coal combustion residual contamination, natural attenuation will not be permitted per 15A NCAC 02L .0111(dx10)(F). Page 2 of 2 From: Healy. Ashley Lisbeth To: Camobell, Ted Cc: Davidson. Landon; Smith, Eric G; Toepfer, John R; Hardin, Tyler; Sullivan. Ed M; Safrit. Don; Williams. Teresa Lynne; Kelly Ferri Subject: Asheville - Surface Water Assessment Flan Date: Tuesday, April 4, 2023 3:47:16 PM Attachments: Asheville Surface Water Assessment Plan Final 04-04-2023.odf g.f -1 On January 9, 2023, Duke Energy received a Surface Water Evaluation letter from the NCDEQ for 14 Duke Energy facilities, including the Asheville :team Bectric Rant. This letter provided the surface water assessment guidance referenced in the 2021 CEA Update - Comments Pevised letter and conditional approval. The letter stated that within 90 days of receipt, Duke Energy shall submit a Surface Water Assessment Ran (S/VAP). The requested Asheville SNAP is attached to this email for NCDEQ review and approval. Please let me know if you have any questionswith this submittal. Ibspec tfully, Ashley Ashley L Healy, PG Waste and Groundwater Programs Mobile: 717-982-0986 Terra Science &Engineering Consultants synterracorp.com SURFACE WATER ASSESSMENT PLAN - APRIL 2023 ASHEVILLE STEAM ELECTRIC PLANT 1.0 BACKGROUND On January 9, 2023, Duke Energy received a Surface Water Evaluation letter (letter) from the North Carolina Department of Environmental Quality (NCDEQ) for 14 Duke Energy facilities, including the Asheville Steam Electric Plant (Asheville or Site) (Figure 1). Per the Comprehensive Site Assessment comment letter for Asheville dated July 14, 2021 (NCDEQ 2021), NCDEQ stated that it would provide additional comments and direction regarding surface water in an upcoming separate correspondence. The January 9, 2023, letter satisfied that comment and provided Duke Energy with a surface water evaluation to assist with the preparation of this Surface Water Assessment Plan (SWAP). The letter stated that within 90 days of receipt, Duke Energy shall use the information provided to develop a SWAP. 2.0 SURFACE WATER SAMPLE LOCATIONS, FREQUENCY, AND METHODOLOGY The following surface water locations are proposed in the January 9, 2023, letter to be monitored at the Site: • A-01 • C-01 • E-01 • F-03 • 82EO-01 • A-02 • C-02 • F-01 • K-01 • 82EO-02 • B-01 • D-01 • F-02 • N-01 (aka N-01 downstream) The locations are presented on Figure 2 and descriptions of the monitoring locations are included on Table 1. N-01 nomenclature changed to N-01 Downstream in November 2018 and remains the same sample location as N-01 presented in the NCDEQ Surface Water Evaluation Letter dated January 9, 2023. N-01 Downstream will continue to be the identification name for this location. Locations A-01, B-01, C-01, F-01, and F-02 are downgradient surface water monitoring locations previously approved by NCDEQ as representative of water quality at upgradient monitoring locations. Location E-01 was identified by NCDEQ to be sampled and is included as such. Monitoring locations A-02, C-02, F-03, K-01, 82EO-01, and 82EO-02 were identified by NCDEQ to be sampled; however, those locations will be sufficiently monitored by sampling at the downstream sampling points. synterracorp.com Surface Water Sampling Assessment Plan — April 2023 Asheville Steam Electric Plant Page 2 of 7 Those locations and their associated downstream sampling locations are described below: • A-02 is located upgradient of A-01 within the same channel. Sample location A-01 is representative of water quality at A-02. • Drainage from C-02 flows downgradient to sample location C-01. Sample location C-01 is representative of water quality at C-02. • Drainage from F-03 flows northwest and converges into the channel where sample location F-01 is located. Drainage from K-01 flows west, past location F-03 and converges into the channel where sample location F-01 is located. Sample location F-01 is representative of water quality at F-03 and K-01. • Constructed seeps 82EO-01 and 82EO-02 are located beneath the former 1982 Ash Basin and drain southwest of K-01, into the channel where sample location F-01 is located. Sample location F-01 is representative of water quality at 82EO-01 and 82EO-02. The former 1964 Ash Basin toe drains discharge into the National Pollutant Discharge Elimination System (NPDES) permitted outfall 101 (Figure 2). Outfall 101 discharges into an unnamed tributary where C-01 and C-02 surface water locations are located. Location C-01 has routinely been used as the representative downgradient monitoring location for flows from C- 02 and D-01. Sampling at C-01 will be discontinued until NPDES outfall 101 is removed because of the downgradient proximity to a permitted wastewater discharge. Sampling at location D-01 will be conducted in the interim. Sampling at C-01, the representative downgradient monitoring location for flows from C-02 and D-01, would resume once the NPDES outfall has been removed. Location D-01 will be transition to an observation location at this time. Duke Energy proposes to collect surface water samples from the following additional locations (Figure 2): • FB Upstream — background location in the French Broad River • FB Downstream — downstream location in the French Broad River • SW-06 —background location in an unnamed tributary that flows into Lake Julian Duke Energy proposes semiannual collection of surface water samples A-01, B-01, C-01, E-01, F- 01, F-02, and N-01 Downstream within the same quarter as the groundwater monitoring events per the current groundwater monitoring plan. Monitoring of background and the French Broad River locations will be conducted during the semiannual collection of downgradient surface water samples. Surface water samples will be collected as grab samples using Duke Energy Water Chemistry Sampling Procedure ESFP-SW-0504 protocol (Duke Energy, 2020) and field water quality parameters will be evaluated using Duke Energy Water Quality Field Procedure protocol (Duke Energy, 2022). synterracorp.com Surface Water Sampling Assessment Plan — April 2023 Page 3 of 7 Asheville Steam Electric Plant 3.0 SAMPLING AND OBSERVATION 3.1 Surface Water Sample Analysis In the General Surface Water Quality Requirements Applicable to All Facilities provided in the letter, NCDEQ stated that surface water samples collected for analysis shall be analyzed for, at a minimum, the approved Site -specific groundwater constituents of interest (COls) per the current groundwater monitoring plan [Interim Monitoring Plan (IMP), Effectiveness Monitoring Plan (EMP), or Optimized Monitoring Plan (OMP)]. Currently at Asheville there are separate COI lists for different source areas at the site (1964 ash basin, 1982 ash basin and the former coal pile) in the groundwater Corrective Action Plan (Arcadis, 2022). Therefore, the surface water samples will be analyzed for the list of constituents provided on Table 2, which represents a compilation of COls associated with the various source areas, including total and dissolved analysis as noted, plus any additional constituents required for calculating total hardness. Surface water samples would not be analyzed for the additional water quality parameters or additional voluntary parameters listed on the current groundwater monitoring plan. The surface water sample and observation locations included in this SWAP will be incorporated into the current groundwater monitoring plan. Following approval of an OMP or EMP for the Site, the list of surface water sample analytes may be updated to reflect the revised COls for the Site. 3.2 Seep Observations NCDEQ concluded that seep locations Ponded Water F and M-01 are not considered jurisdictional streams. Duke Energy believes that DD-Pipe does not represent jurisdictional waters; flow from DD-pipe does not reach waters of the U.S. Therefore, Ponded Water F, M-01 and DD-Pipe are included as observation locations in this SWAP (Table 1). Surface water sample locations to be monitored at downgradient locations (A-02, C-02, F-03, K-01, 82EO-01, and 82EO-02) are included as observation locations in this SWAP. The seep locations will be observed semiannually in conjunction with the surface water sampling. If changes in conditions are observed (such as increased in flow rate, etc.), Duke Energy will notify the NCDEQ. 4.0 REPORTING, EVALUATION, AND DISPOSITIONING The surface water monitoring data and observation descriptions will be presented and evaluated in the Annual Groundwater and Surface Water Monitoring Reports and comprehensive data tables submitted to the NCDEQ quarterly. The surface water monitoring data will be compared to applicable 02B standards; USEPA Nationally Recommended Water Quality Criteria and North Carolina In -Stream Target Values for Surface Waters will be provided for informational purposes. synterracorp.com Surface Water Sampling Assessment Plan — April 2023 Page 4 of 7 Asheville Steam Electric Plant USEPA Nationally Recommended Water Quality Criteria USEPA recommended criteria are not water quality standards because they have not been adopted through rulemaking and they have not been approved by USEPA in the triennial review process. Moreover, the NCDEQ DWR does not consider them to be standards, as reflected in the Surface Water Quality Standards, Criteria & Protective Values spreadsheet, which states, on the USEPA criteria tab, "Below are all Nationally Recommended Water Quality Criteria for which North Carolina does not have a Water Quality Standard for one or more uses." Iron and manganese were specifically removed from 15A NCAC 02B regulations in 2015. During the proceeding review process, it was concluded that, "North Carolina further believes that removal of the standard [iron] from the current 15A NCAC 02B regulations will not cause any adverse effects on water quality and on any designated uses." As for manganese, the "Division of Water Resources has no evidence to conclude that discharges of manganese will impact any beneficial uses of North Carolina's waters." Therefore, "the Environmental Management Commission (EMC) and the Rules Review Commission (RRC), after public notice and review, approved removal of the water quality standards for both iron and manganese." Comparisons with the USEPA National Recommended Water Quality Criteria will be included within Duke Energy's Annual Groundwater and Surface Water Report. As stated by the USEPA, these criteria are not a regulation, nor do they impose a legally binding requirement. Therefore, comparisons with these criteria are only for situational context. The constituents that have corresponding USEPA criteria but do not have NCDEQ 02B criteria are alkalinity, aluminum, antimony, iron, and manganese. Alkalinity The alkalinity criteria are a minimum value established by the USEPA over 30 years ago. It is a measure of the buffering capacity of the water as related to pH and the association of pH and complexing materials with the toxicity of certain pollutants such as certain metals and ammonia. In more recent times these pollutants have the effects of pH (and hardness) constructed into the establishment of the criteria value. Alkalinity is an artifact of past efforts of criteria development. Aluminum Aluminum is ubiquitous. It is the third most abundant element and the most common metal in the earth's crust. Aluminum enters the aquatic environment predominantly from natural sources. This is due to the abundance of aluminum in rocks and soils released by weathering. The USEPA expressed the aluminum criterion as total recoverable aluminum. However, natural water samples may also contain other species of aluminum that are not biologically available (i.e., synterracorp.com Surface Water Sampling Assessment Plan — April 2023 Asheville Steam Electric Plant Page 5 of 7 suspended particles, clays, and aluminosilicate minerals). This creates uncertainty because the total recoverable aluminum concentrations measured in natural waters may overestimate the potential risks of toxicity to aquatic organisms. Antimony Antimony was rarely detected in historical Duke Energy studies. Any detections were well below the USEPA criteria of 640 ug/I for the Human Health criteria. Iron and Manganese Iron and manganese criteria were both withdrawn from the NCDEQ 02B regulation in the last triennial review. The iron criteria of 1,000 ug/I, based on USEPA's aquatic life value, was withdrawn in North Carolina due to the determination that the value was unnecessary and potentially overly protective. North Carolina further stated that they believed that removal of the standard from the current 15A NCAC 02B regulations will not cause adverse effects on water quality and on any designated uses. Manganese was likewise withdrawn from the 02B regulation. Manganese criteria were based on Human Health aspects, but the NCDEQ could not determine that the USEPA values provided any human health protective benefit for North Carolina. North Carolina In -Stream Target Values for Surface Waters In -Stream Target Values are calculated according to the instructions in 15A NCAC 0213.0208. Although calculated according to regulation, the numeric derivations of the narrative standard in .0208 have not themselves been adopted into regulation. As such the published values may be recalculated from time to time based on new research or by further evaluation of existing sources. Duke Energy will provide comparisons against published In -Stream Target Values with the qualification that an exceedance of the published value is not necessarily or automatically a violation of the water quality standard for toxicity and that further review may be required to confirm that the published value complies with .0208. Historical Duke Energy surface water sample results, as well as results of other media, including groundwater, are summarized in comprehensive data submittal spreadsheets that Duke Energy routinely submits to NCDEQ. In accordance with NCDEQ's January 9, 2023, letter, surface water samples will be collected as grab samples. The 02B standards based on acute and chronic toxicity are not applicable to constituent concentrations reported from grab sampling. Calcium and magnesium analysis would be conducted to facilitate total hardness calculations for each sample. Dissolved analysis would be conducted for those constituents that have 02B standards based on the dissolved synterracorp.com Surface Water Sampling Assessment Plan — April 2023 Asheville Steam Electric Plant Page 6 of 7 fraction; however, those dissolved and hardness -dependent 02B standards would not be applicable to the sampling method. Surface water sampling at the downstream locations will continue until: • COI concentrations in those downstream surface water locations are less than applicable comparison criteria in 15A NCAC 02B .0211 through .0255 or less than concentrations observed at background locations for two consecutive monitoring events, or • Sample locations become dry, stagnant, exhibit insufficient flow for sampling, or the locations are otherwise unable to be sampled for two consecutive monitoring events. Seep observations will continue until: • The seep location becomes dry, does not flow to surface water, or is inundated for two consecutive monitoring events, or • The seep is otherwise dispositioned, or • The COI concentrations in downstream surface water sampling locations are less than applicable comparison criteria in 15A NCAC 02B .0211 through .0255 or concentrations observed at background locations for two consecutive monitoring events. Seep locations will be considered dispositioned if seeps are observed to be dry, not flowing to surface waters, or inundated for two consecutive monitoring events. Once downstream surface water sampling locations demonstrate compliance with applicable comparison criteria in 15A NCAC 02B .0211 through .0255 for two consecutive monitoring events, and seep observations have not indicated changing conditions, surface water sampling (including background locations) and seep observations at the Site will cease, and the seeps will be considered dispositioned. synterracorp.com Surface Water Sampling Assessment Plan — April 2023 Asheville Steam Electric Plant ATTACHMENTS Figure 1— Site Location Map Figure 2 —Surface Water Sampling Locations Table 1— Surface Water Sampling and Seep Locations Descriptions Table 2 — Summary of Constituents and Analytical Methods REFERENCES Page 7 of 7 Arcadis (2022). Corrective Action Plan Update —Asheville Steam Electric Plant November 18, 2022. Duke Energy (2016). Standard Operating Procedure for Seep Sampling, ADMP-ENV-EHS-00002, Revision 0, March 24, 2016. Duke Energy (2020). Water Chemistry Sampling Procedure, ESFP-SW-0504, Revision 0, January 1, 2020. Duke Energy (2022). Water Quality Field Procedure, ESFP-SW-0503, Revision 2, January 1, 2022. NCDEQ (2021). 2020 Comprehensive Site Assessment Update - Comments, Asheville Steam Electric Plant, July 16, 2021. synterracorp.com FIGURES tip synTerra Science & Engineering Consultants U NOTES: I ALL BOUNDARIES ARE APPROXIMATE 2 PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY PROURESS J USGS TOPOGRAPHIC MAP. OBTAINED FROM THE ESRI. LAST UPDATED JUNE 2022 t`:IDUKE ENERGY BUNCOMBE COUNTY Aa PROGRESS �wnu .y• f � s -r , i 1 II -• RETIRED ASHEVILLE �• STEAM ELECTRIC PLANT •r % r • FORMER COAL PILE , 1982 ASH BASIN i WASTE BOUNDARY • DUKE ENERGY PROGRESS •� 1 • • PROPERTY BOUNDARY _ ASHEVILLE COMBINED "*I CYCLE STATION FIGURE i SITE LOCATION MAP SURFACE WATER ASSESSMENT PLAN ASHEVILLE STEAM ELECTRIC PLANT ARDEN, NORTH CAROLINA Nl 1. nr f)UIYIHY 1 MAII vf c., f3V-A[)F` f 'RC4W"tl. Alf I HN wf.. H1 K IfAQ, UHE ^) 1, t_'11 AM"til ll.f% K 1I 4HI [Alf n2 22 207, ❑t�ff,7 PRU SELF AfUAUR K II RRI NPDESr.. OUTFALL 001 • r ". �' • �,� n arol :..:i .. OL IL f t LEGEND tip. j H e. ■ SURFACE WATER SAMPLE LOCATION BACKGROUND SURFACE WATER SAMPLE LOCATION . ' • (/fir r'�¢� • SEEP OBSERVATION LOCATION NP'44- . • (.i<Y — 1964 ASH BASIN WASTE BOUNDARY j `x""'• s- - t • ` ' F S - 1982 ASH BASIN WASTE BOUNDARY V � ~ � , 4 �'4' � • '• -DUKE ENERGY PROGRESS PROPERTY BOUNDARY t ' `' •' --► SURFACE WATER FLOW DIRECTION 1 ,�..: - • ~� • ; --►- STREAM (TWT 2016) a . -_ - `' • WETLAND (TWT 2016) LN �. a ^ • NOTES: t • ! .000, •• ^� • •� 1 • - TEMPORARILY MONITOR D-01 UNTIL MONITORING AT THE DOWNGRADIENT .�� ' � � •ern• SAMPLE LOCATION C-01 RESUMES. �R 2 ^ - TEMPORARILY DISCONTINUE MONITORING AT C-01 UNTIL NPDES PERMITTED ^ • OUTFALL 101 HAS BEEN REMOVED. 3 NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) Y 1,- •i • _ 4. THE STREAMS AND WETLANDS JURISDICTIONAL DETERMINATION WAS ' "'� ` • . PERFORMED BY TAYLOR WISEMAN AND TAYLOR ` ,, 5�,,_[>6 (TWi)AND ASSIGNED USACE a w #SAW-201100189. THESE WETLANDS AND STREAMS WERE APPROVED BY THE US ARMY CORPS OF ENGINEERS (USACE I ON MAY 16. 2016 +; u • `, \ �, • 5 ALL LOCATIONS AND BOUNDARIES ARE APPROXIMATE. • '+ . •� • - ' 6. PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY PROGRESS. LLC _ 7 ► F9-UPSTR •!' ' {'' `� 7. AERIAL IMAGERY IS A COMBINATION OF DUKE ENERGY PROPELLER AERIAL r� • PHOTOGRAPHY COLLECTED ON JANUARY 23, 2023 AND GOOGLE EARTH AERIAL R s PHOTOGRAPHY COLLECTED ON OCTOBER 17. 2021. '.' , '•• ° }• `' ` A .H. •+" X'; •"..' }z: , 8. DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE '� K ,�,. �•� PLANE COORDINATE SYSTEM FIPS 3200 (NAD83) 350 i r}_ 'DUKE . j %,•, r �,a , j� .yam FIGURE 2 - E N E R G Y GRAPHIC SCALE IN FEET _ ;.. SURFACE WATER SAMPLE LOCATIONS • `: t"n PROGRESS DRAIN%BY E OROEMANN DATE 02.222023 SURFACE WATER ASSESSMENT PLAN ' :i. " �'' , •k ., REVISED BY E ORDEAIA%% DATE OV31/2023 CHECKED BY. K FERRI DATE. 03, 31,'2023 ASHEVILLE STEAM ELECTRIC PLANT ~`•0� +'?I�y# i APPROVED BY K FERRI LATE 03.3�2023 ARDEN, NORTH CAROLINA PROJECT MANAGER K FERRY i y �� Wr'w.SyrHErracorD com TABLES L, synTerra Science & Engineering Consultants TABLE 1 SURFACE WATER SAMPLING AND SEEP LOCATION DESCRIPTIONS SURFACE WATER ASSESSMENT PLAN ASHEVILLE STEAM ELECTRIC PLANT DUKE ENERGY PROGRESS, LLC, ASHEVILLE, NC Location Classification Description Surface Water Sample Locations Point of drainage from wetlands northwest of the former 1964 ash basin to the French Broad River. NCDEQ determined this A-01 Class B location is classified as surface water and subject to the 02B standards. Point of drainage from wetlands west of the former 1964 ash basin to the French Broad River. NCDEQ determined this B-01 Class B location is classified as surface water and subject to the 02B standards. Point of drainage west of the former 1964 ash basin to the French Broad River. NCDEQ determined this location is classified as C-01 Class B surface water and subject to the 02B standards. Temporarily discontinue sampling at C-01 because of the downgradient proximity to a permitted wastewater discharge. Sampling at C-01 would resume once NPDES outfall 101 has been removed. Point of drainage from wetlands towards surface water sample location C-01. NCDEQ determined this location is classified as D-01 Class B a surface water. Temporarily monitor D-01 until monitoring at C-01 resumes. Point of drainage southwest of the former 1964 ash basin toward the French Broad River. NCDEQ determined this location is E-01 Class B classified as surface water and subject to the 02B standards. Point of drainage from wetlands west of the former 1982 ash basin to the French Broad River. NCDEQ determined this F-01 Class B location is classified as surface water and subject to the 02B standards. Point of drainage from wetlands southwest of the former 1982 ash basin to the French Broad River. NCDEQ determined this F-02 Class B location is classified as surface water and subject to the 02B standards. Seep to small channel north of the former 1964 ash basin that flows into Powell Creek. NCDEQ determined this location is N-01 Downstream' Class C classified as surface water and subject to the 02B standards. FB Downstream Class B Downstream location in the French Broad River. FB Upstream Class B Upstream location in the French Broad River. SW-06 Class C Upstream location in an unnamed tributary that flows into Lake Julian. Seep Observation Locations Point of drainage from former 1982 ash basin towards F-01. NCDEQ determined this location is classified as a surface water. 82E0-01 Class B Monitoring for 82EO-01 will be collected at downgradient sample location F-01. Point of drainage from former 1982 ash basin towards F-01. NCDEQ determined this location is classified as a surface water. 82E0 02 Class B Monitoring for 82EO-02 will be collected at downgradient sample location F-01. Point of drainage towards surface water sample location A-01. NCDEQ determined this location is classified as a surface A-02 Class B water. Monitoring for A-02 will be collected at downgradient sample location A-01. e1of2 TABLE 1 SURFACE WATER SAMPLING AND SEEP LOCATION DESCRIPTIONS SURFACE WATER ASSESSMENT PLAN ASHEVILLE STEAM ELECTRIC PLANT DUKE ENERGY PROGRESS, LLC, ASHEVILLE, NC Location Classification Description Point of drainage towards surface water sample location C-01. NCDEQ determined this location is classified as a surface water. C-02 Class B Monitoring for C-02 will be collected at downgradient sample location C-01. However, temporarily discontinue sampling at C- 01 because of the downgradient proximity to a permitted wastewater discharge. Point of drainage from wetlands toward surface water sample location F-01. NCDEQ determined this location is classified as a F-03 Class B surface water. Monitoring for F-03 will be collected at downgradient sample location F-01. Point of drainage from wetlands toward surface water sample location F-01. NCDEQ determined this location is classified as a K-01 Class B surface water. Monitoring for K-01 will be collected at downgradient sample location F-01. NCDEQ determined this location to be a seep and not classified as surface water; therefore, it is not subject to the 02B M-01 NA standards. However, NCDEQ requested that this location be observed periodically to determine if conditions have changed. French drain below divider dike between the former 1964 and 1982 ash basins. Due to closure of the former 1964 ash basin DD-Pipe NA only minimal flow has been observed. Duke Energy believes that DD-Pipe does not represent jurisdictional waters; therefore, it is included as an observation location in this SWAP. NCDEQ determined this location to be a seep and not classified as surface water; therefore, it is not subject to the 02B Ponded Water F NA standards. However, NCDEQ requested that this location be observed periodically to determine if conditions have changed. Prepared by: KHF Checked by: TJG Notes: NA - Not applicable ' - N-01 nomenclature changed to "N-01 Downstream" in November 2018. Sample location remains the same as N-01 presented in the SOC and the NCDEQ Surface Water Evaluation Letter dated January 9, 2023. NPDES - National Pollutant Discharge Elimination System SWAP - surface water assessment plan Page 2 of 2 TABLE 2 SUMMARY OF CONSTITUENTS AND ANALYTICAL METHODS SURFACE WATER ASSESSMENT PLAN ASHEVILLE STEAM ELECTRIC PLANT DUKE ENERGY PROGRESS, LLC, ARDEN, NC Constituent Units Analytical Methods In Situ Parameters Field pH Standard units Multi -Parameter Water Quality Meter Field Specific Conductance µ0/cm Multi -Parameter Water Quality Meter Field Temperature degrees Celsius Multi -Parameter Water Quality Meter Field Dissolved Oxygen mg/L Multi -Parameter Water Quality Meter Field Oxidation Reduction Potential mV I Multi -Parameter Water Quality Meter Field Turbidity NTU Turbidimeter Laboratory Analyses Aluminum µg/L EPA 200.7 Arsenic^ µg/L EPA 200.8 Beryllium^ µg/L EPA 200.8 Boron µg/L EPA 200.7 Cadmium µg/L EPA 200.8 Cobalt µg/L EPA 200.8 Iron µg/L EPA 200.7 Lithium µg/L EPA 200.8 Magnesium# µg/L EPA 200.7 Manganese µg/L EPA 200.7 Molybdenum µg/L EPA 200.8 Nickel µg/L EPA 200.8 Selenium µg/L EPA 200.8 Strontium µg/L EPA 200.7 Sulfate mg/L EPA 300.0 Thallium µg/L EPA 200.8 (low level) Total Dissolved Solids mg/L SM 2540C-2015 Total Radium pCi/L EPA 903.1 (Radium-226) and EPA 904.0 (Radium-228) Total Uranium µg/mL EPA 6020E Vanadium µg/L EPA 200.8 (low level) Zinc^ µg/L EPA 200.7 Prepared by: KHF Checked by: TWL Notes: Constituent will be analyzed for total recoverable metals (TRM) and dissolved concentrations. "- Magnesium is not a constituent of interest in groundwater at the Site; however, magnesium analysis is required to calculate total hardness. Total Hardness = 2.497 (calcium) + 4.118 (magnesium) µf)/cm - micro -ohms per centimeter µg/L - micrograms per liter mg/L - milligrams per liter µg/mL - micrograms per milliliter pCi/L - picocuries per liter Page 1 of 1 From: Healy. Ashley Lisbeth To: Camobell, Ted Cc: Davidson. Landon; Smith, Eric G; Toeofer, John R: Hardin. Tyler; Sullivan. Ed M; Safrit. Don; Williams. Teresa Lynne; Kelly Ferri Subject: Asheville - Surface Water Assessment Plan Date: Tuesday, April 4, 2023 3:47:16 PM Attachments: Asheville Surface Water Assessment Plan Final 04-04-2023.odf Ted — On January 9, 2023, Duke Energy received a Surface Water Evaluation letter from the NCDEQfor 14 Duke Energy facilities, including the Asheville Steam Electric Plant. This letter provided the surface water assessment guidance referenced in the 2021 CSA Update - Comments Revised letter and conditional approval. The letter stated that within 90 days of receipt, Duke Energy shall submit a Surface Water Assessment Plan (SWAP). The requested Asheville SWAP is attached to this email for NCDEQ review and approval. Please let me know if you have any questions with this submittal. Respectfully, Ashley Ashley L. Healy, P.G. Waste and Groundwater Programs Mobile: 717-982-0986 From: Campbell, Ted To: Healy, Ashley Lisbeth Cc: Davidson. Landon, Smith, Eric G; Toenfer, John R, Hardin, Tyler, Sullivan. Ed M; Safrit. Don; Williams. Teresa Lynne; Kelly Ferri, Campbell, Ted Subject: [EXTERNAL] Asheville - Surface Water Assessment Plan Date: Wednesday, April 26, 2023 10:31:08 AM Attachments: mage001.pna Asheville Surface Water Assessment Plan Final 04-04-2023.0f Ashley - The Asheville F1.gional office has reviewed the %rfaee Water Assessment Ran for the Asheville Facility submitted on April 11, 2023, and approves its implementation with the following comments: Ste-,9,)ecific Comments none General Comments Applicable to Al Facilities • Duke Energy shall request approval from the Pegional Office prior to dispositioning any seep based on the proposed criteria. The Regional Office will review the request and may provide additional conditions or comments based on their determination. Fegardingthe use of 15ANCACO2B.0202 (213Sandards), USEnvironmental Protection Agency National Recommended Water Quality Criteria (EPA NRWQC), and In -stream Target e& L{ �f t s 'rsa'nCn s 5 dal 46■ oz i Aa'n4f of 'r5 i w4 'rkAl' s i Ag'nv j P� { CA.r M V / 'rA'r lz {I N V Qk*' Cle 9f { �.r Arr f QNV' f 4 found on the website at httDs://de .nc. ov/docLimen s/nc-stdstable-07262021 (or the most recent version of this �� � " Qnrj I'C�.C9l�A - s �'n5i v�if �nl'sff m'nPff�■�ir�-�r�6j f OPC�'nL'or� classifications, 2Baandards, EPANRWQQ and ISTVs that the gate of North Carolina employs to protect the designated uses of its surface waters. For the spedfic site waterbody, refer to the designated uses table when dedding which 2B Elandard, EPA NRWQG or ISTVto apply. The most sensitive use must be protected. Reported values that exceed the most sensitive use value shall be flagged. _%rface water samples proposed in larger waterbodies (e.g.. rivers and lakes) shall be collected near the bank for the approved Ms. The Fegional Office reserves the right to request modification the surface water sampling in the Interim Monitoring Ran or Effectiveness Monitoring Ran (whichever is applicable for the site) based on the available data, changes in site conditions, or remedial strategy effectiveness. Let me know if you have any questions. Thanks. Ted R Campbell I t' / o■fj IJ�AC WFBR-01 r SW_ 1041 • 1 • • 1!w r i NPDES OUTFALL f01 •. .y ..r .r�, ,��'�.,,�.�:ti++�. Sy R+�i, y. 5 �... ��Yu�� � �5�i• •t"'ra^..-y` 'i A.i • ,�� ',c. °. �'.,�! �. •�" C ti� t ••✓ It - i � ' - lb • 1 •■ • j' DUKE ENERGY(IN GRAPHIC SCALE 375 0 FEEL) 375 PROGRESS DRAWN BY: C. DAVIS REVISED BY: C. CURRIER DATE:03/24/2020 DATE:11/18/2020 Op CHECKED BY: H. CARTER DATE:11/18/2020 APPROVED BY: G. BARRIER DATE:11/18/2020 r7m PROJECT MANAGER: G. BARRIER LEGEND SEEPAND SURFACE WATER SAMPLE LOCATIONS ♦ NPDES OUTFALL LOCATION (APPROXIMATE) 1964ASH BASIN WASTE BOUNDARY FORMER 1982 ASH BASIN WASTE BOUNDARY COMPLIANCE BOUNDARY DUKE ENERGY PROGRESS PROPERTY LINE )— STREAM AND FLOW DIRECTION (TWT 2016) I FORMER FLUE GAS DESULFURIZATION (FGD) WETLANDS ZZZI WETLAND (TWT 2016) ►SURFACE WATER FLOW DIRECTION NOTES: 1. THE DEPICTED STREAMS AND WETLANDS DATA WERE APPROVED BY THE US ARMY CORPS OF ENGINEERS (USAGE) ON MAY 19. 2016 -JURISDICTIONAL DETERMINATION SAW-2014-00189, TAYLOR WISEMAN AND TAYLOR Owr) PERFORMED THE SURVEY OF THE FEATURES. 2. ALL BOUNDARIES ARE APPROXIMATE. 3. PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY PROGRESS, LLC. 4. AERIAL PHOTOGRAPHY OBTAINED FROM NORTH CAROLINA ONE MAP ON FEBRUARY 20, 2020. AERIAL DATED JANUARY 1, 2019. 5. DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE PLANE COORDINATE SYSTEM FIPS 3200 (NAD83). FIGURE 1-2C SITE LAYOUT MAP - SEEP AND SURFACE WATER SAMPLE LOCATIONS 2020 COMPREHENSIVE SITE ASSESSMENT UPDATE ASHEVILLE STEAM ELECTRIC PLANT ARDEN, NORTH CAROLINA