NC0004987_Other_20160503

,0& DUKE
ENERGY.
April 28, 2016
Jeffrey O. Poupart
Water Quality Permitting Section Chief
Division of Water Resources
Department of Environmental Quality
State of North Carolina
1617 Mail Service Center
Raleigh, NC 27699-1617
Harry K. Sidens
Senior Vice President
Environmental, Health & Safety
526 S Church Street
Mail Code ECUP
Charlotte, NC 28202
[phone]
RECEIVED/NCDEQ/DWR
MAY 0 3 1016
Water Quality
Permitting Section
Subject: March 2, 2016 Insufficiency of Discharge Assessment Plans — Duke Energy Carolinas,
LLC and Duke Energy Progress, LLC
Dear Mr. Poupart:
This responds to your letter of March 2, 2016 to Duke Energy Carolinas, LLC and Duke Energy
Progress, LLC on March 2, 2016 regarding Duke Energy's proposed Discharge Assessment
Plans.
With regard to your letter describing changes in Section 3.2.2 Observation and Sampling:
• The discussion must include a statement noting that jurisdictional determinations regarding
the extent of waters of the United States and their relationship with identified seeps at the
subject facilities will be obtained from the United States Army Corps of Engineers (USA
COE).
Duke Energy does not yet have jurisdictional determinations from the US Army Corps of
Engineers for the relevant areas at all of the twelve sites mentioned in your letter. We submitted
applications for jurisdictional determinations in September, October, and November 2015 and
have since worked with the Corps of Engineers to schedule site visits and provide draft plats for
approval. Nonetheless, the timing of the approved jurisdictional determinations is up to the
Corps and outside of Duke's control. To date, out of these twelve sites, only Buck has an
approved jurisdictional determination, but we do not yet have the signed plats.
We will submit the maps you have requested for each site on a rolling basis, within a reasonable
period after the jurisdictional determinations are complete. In order to address the changes
described in your March 2, 2016 letter, we have added the following text at the start of Section
3.2.2.
Jurisdictional determinations regarding the extent of waters of the United States and
their relationship with identified seeps at the subject facilities will be obtained from the
United States Army Corps of Engineers (USA COE). Until jurisdictional determinations
are finalized by USA COE, preliminary information will be used to evaluate the seeps as
described in the section below.

The second change in Section 3.2.2 described in your letter is as follows.
The schedule for water quality sampling of the seeps and related jurisdictional waters must
be more frequent than the semi-annual basis stated in the proposed DAPs. DWR
recommends a monthly monitoring schedule, consistent with the conditions described in the
DAPs' general assessment requirements, for all identified seeps that will continue for twelve
(12) months. After that time, monitoring may be reduced to a semi-annual basis until such
monitoring becomes a requirement of the NPDES permit.
We do not believe sampling monthly as part of a revised Discharge Assessment Plan is
warranted. For the larger receiving waters, data is available from sampling associated with
NPDES permits that demonstrates the lack of impact on the larger surface waters of the state.
In addition, we are conducting weekly observations of all AOWs on a dam or dike slope,
and providing the analytical results to DEQ. We recommend the
sampling any new seeps, p g yt
sampling frequency under the DAPs remain at twice/year with the weekly inspections of dam
slopes for any new seeps with data provided to DEQ. We recommend that we collectively focus
our resources on the completion of all of the NPDES Wastewater Permits for the Duke Energy
sites and implement appropriate sampling frequency for each of the permitted seeps in that
document.
However, in order to address the changes described in your March 2, 2016 letter, we have
added the following text in Section 3.2.2.
In addition to 9
samPlin conducted with the semi-annual assessments, additional seep
.
sampling will be conducted at locations and at a frequency as determined through
discussions with NC DEQ personnel.
We would like to work with DEQ to achieve alignment of the various (present and future)
documents involving required seep activities including:
• Discharge Assessment Plans
• Discharge Identification Plans
• NPDES Wastewater Permits
• EPA requirements
• Any future legal agreements with either DEQ or EPA
Duke Energy is committed to providing the Department with additional information to facilitate
-'i the issuance of new NPDES Wastewater permits. The issues are complex and require special
consideration, as illustrated by the time elapsed since the permit applications were submitted.
We look forward to working with you further to resolve the issues identified here on a mutually
acceptable schedule.
Sincerely,
Harry Sideris
Senior Vice President
Environmental, Health and Safety

Marshall Steam Station Ash Basin
Topographic Map and
Discharge Assessment Plan
NPDES Permit NCO04987
April 29, 2016
r

Duke Energy Carolinas, LLC I Discharge Assessment Plan 01
Marshall Steam Station Ash Basin
! CONTENTS
Contents
l
Paae
Contents
' ................................................... Figures and Tables..................................................................ii
Section1 - Introduction..............................................................................................................
1
Section 2 - Site Background.......................................................................................................
3
2.1 Plant Description..................................................................................................3
2.2 Ash Basin Description .............................3
2.3 Site Geologic/Soil Framework..............................................................................3
2.4 Topographic Map and Identification of Discharges ...............................................
- 2.4.1 Engineered Drainage System for Earthen Dam........................................5
2.4.2 Non -Engineered Seep Identification.........................................................5
Section 3 - Discharge Assessment Plan.....................................................................................
6
3.1 Purpose of Assessment.......................................................................................6
3.2 Assessment Procedure........................................................................................6
3.2.1 General Assessment Requirements.........................................................6
3.2.2 Observation and Sampling.......................................................................7
3.2.3 Evaluation................................................................................................9
3.2.4 Assessment Reporting.............................................................................9
Section4 — References.............................................................................................................10

Duke Energy Carolinas, LLC I Discharge Assessment Plan ���
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FIGURES AND TABLES
Figures and Tables
Figure 1 — Site Location Map
Figure 2 — Topographic Map
Table 1 — Seep and Associated Discharge Locations and Descriptions
Table 2 — Laboratory Analytical Methods
Table 3 — Marshall Steam Station — Example of Surface Water/Seep Monitoring Flow and
Analysis Results Table

r -1
Duke Energy Carolinas, LLC I Discharge Assessment Plan 1 �
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SECTION 1 - INTRODUCTION
l
Section 1 - Introduction
The purpose of this document is to address the requirements of North Carolina General Statute
(GS)130A-309.210(a) topographic map and (b) Assessment of Discharges from Coal
Combustion Residuals Surface Impoundments to the Surface Waters of the State, as modified
by North Carolina Senate Bill 729, for the Marshall Steam Station (MSS) ash basin operated
under National Pollutant Discharge Elimination System (NPDES) Permit NC0004987.
The following requirements are contained in General Statute (GS) 130A-309.210(a):
(1) The owner of a coal combustion residuals surface impoundment shall identify all
discharges from the impoundment as provided in this subsection. The requirements for
identifying all discharges from an impoundment set out in this subsection are in addition
to any other requirements for identifying discharges applicable to the owners of coal
combustion residuals surface impoundments.
(2) No later than December 31, 2014, the owner of a coal combustion residuals surface
impoundment shall submit a topographic map that identifies the location of all (i)
outfalls from engineered channels designed or improved for the purpose of collecting
water from the toe of the impoundment and (ii) seeps and weeps discharging from the
impoundment that are not captured by engineered channels designed or improved for
the purpose of collecting water from the toe of the impoundment to the Department.
The topographic map shall comply with all of the following.
a. Be at a scale as required by the Department.
b. Specify the latitude and longitude of each toe drain outfall, seep, and weep.
c. Specify whether the discharge from each toe drain outfall, seep, and weep is
(; continuous or intermittent.
d. Provide an average flow measurement of the discharge from each toe drain outfall,
seep, and weep including a description of the method used to measure average flow.
e. Specify whether the discharge from each toe drain outfall, seep, and weep identified
reaches the surface waters of the State. If the discharge from a toe drain outfall,
seep, or weep reaches the surface waters of the State, the map shall specify the
latitude and longitude of where the discharge reaches the surface waters of the
State.
f. Include any other information related to the topographic map required by the
Department.
The following requirements are contained in General Statute (GS) 130A-309.210(b):
b) Assessment of Discharges from Coal Combustion Residuals Surface Impoundments to
the Surface Waters of the State. The owner of a coal combustion residuals surface
impoundment shall conduct an assessment of discharges from the coal combustion
,I

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Duke Energy Carolinas, LLC I Discharge Assessment Plan 1 1
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SECTION 1 - INTRODUCTION
_ residuals surface impoundment to the surface waters of the State as provided in this
subsection. The requirements for assessment of discharges from the coal combustion
residuals surface impoundment to the surface waters of the State set out in this
subsection are in addition to any other requirements for the assessment of discharges
from coal combustion residuals surface impoundments to surface waters of the State
applicable to the owners of coal combustion residuals surface impoundments.
(1) No later than December 31, 2014, the owner of a coal combustion residuals surface
impoundment shall submit a proposed Discharge Assessment Plan to the
Department. The Discharge Assessment Plan shall include information sufficient to
allow the Department to determine whether any discharge, including a discharge
from a toe drain outfall, seep, or weep, has reached the surface waters of the State
and has caused a violation of surface water quality standards. The Discharge
Assessment Plan shall include, at a minimum, all of the following:
a. Upstream and downstream sampling locations within all channels that could
potentially carry a discharge.
b. A description of the surface water quality analyses that will be performed.
c. A sampling schedule, including frequency and duration of sampling activities.
d. Reporting requirements.
e. Any other information related to the identification of new discharges required by
the Department.
(2) The Department shall approve the Discharge Assessment Plan if it determines that
the Plan complies with the requirements of this subsection and will be sufficient to
protect public health, safety, and welfare; the environment, and natural resources.
(3) No later than 30 days from the approval of the Discharge Assessment Plan, the
owner shall begin implementation of the Plan in accordance with the Plan's
schedule.
The North Carolina Senate Bill 729 establishes the submittal date of this topographic map and
Discharge Assessment Plan no later than December 31, 2014.
The topographic map, developed to satisfy the requirements of GS1 30A-309.21 0(a), was
utilized as the basis for developing the assessment procedures presented in this plan, required
' by GS1 30A-309.21 0(b).
2

Duke Energy Carolinas, LLC I Discharge Assessment Plan 01
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SECTION 2 - SITE BACKGROUND
i
Section 2 - Site Background
2.1 Plant Description
MSS is a four -unit, coal-fired electric generating plant with a capacity of 2,090 megawatts
located in Catawba County, North Carolina, near the community of Terrell. The site is located
north of NC Hwy 150, east of Sherrills Ford Road and south of Island Point Road, and the
surrounding area generally consists of residential properties, undeveloped land, and Lake
Norman (Figure 1).
2.2 Ash Basin Description
The ash basin system consists of a single cell impounded by an earthen dike located on the
southeast end of the ash basin. The ash basin system was constructed in 1965 and is located
approximately 2,000 feet northeast of the power plant. The area contained within the ash basin
waste boundary, which is shown on Figure 2, is approximately 382 acres in area.
The full pond elevation for the MSS ash basin is approximately 790 feet. The normal pond
elevation of Lake Norman is approximately 760 feet.
The ash basin is operated as an integral part of the station's wastewater treatment system and
receives inflows from the ash removal system, coal pile runoff, landfill leachate, flue -gas
desulfurization (FGD) wastewater, the station yard drain sump, stormwater flows, and station
i wastewater. Due to variability in station operations and weather, inflows to the ash basin are
highly variable. Inflows from the station to the ash basin are discharged into the northwest
portion of the ash basin.
The discharge from the ash basin is through a concrete discharge tower located in the eastern
portion of the ash basin. The concrete discharge tower drains through a 30-inch-diameter, slip-
; - lined corrugated metal pipe which discharges into Lake Norman. The ash basin pond elevation
is controlled by the use of concrete stoplogs in the discharge tower.
2.3 Site Geologic/Soil Framework
MSS and its associated ash basin system are located in the Charlotte terrane of the Piedmont
physiographic province (Piedmont). The Piedmont province is bounded to the east and
southeast by the Atlantic Coastal Plain and to the west by the escarpment of the Blue Ridge
Mountains, covering a distance of 150 to 225 miles (LeGrand, 2004).
The topography of the Piedmont region is characterized by low, rounded hills and long, rolling,
i
northeast -southwest trending ridges (Heath, 1984). Stream valley to ridge relief in most areas
ranges from 75 to 200 feet. Along the Coastal Plain boundary, the Piedmont region rises from
an elevation of 300 feet above mean sea level, to the base of the Blue Ridge Mountains at an
elevation of 1,500 feet (LeGrand, 2004).
Charlotte terrane bedrock consists primarily of igneous and metamorphic bedrock. The fractured
bedrock is overlain by a mantle of unconsolidated material known as regolith. The regolith
includes, where present, the soil zone (a zone of weathered, decomposed bedrock known as
-- 3

Duke Energy Carolinas, LLC I Discharge Assessment Plan ���
— Marshall Steam Station Ash Basin
SECTION 2 -SITE BACKGROUND
saprolite) and, where present, alluvium. Saprolite, the product of chemical and mechanical
weathering of the underlying bedrock, is typically composed of clay and coarser granular
material up to boulder size and may reflect the texture of the rock from which it was formed. The
weathering product of granitic rocks are quartz rich and sandy textured; whereas, rocks poor in
quartz and rich in feldspar and other soluble minerals form a more clayey saprolite. The regolith
serves as the principal storage reservoir for the underlying bedrock (LeGrand, 2004).
r A transition zone may occur at the base of the regolith between the soil-saprolite and the
unweathered bedrock. This transition zone of partially weathered rock is a zone of relatively
high permeability compared to the overlying soil-saprolite and the underlying bedrock (LeGrand,
2004).
I
Groundwater flow paths in the Piedmont are almost invariably restricted to the zone underlying
the topographic slope extending from a topographic divide to an adjacent stream. LeGrand
describes this as the local slope aquifer system. Under natural conditions, the general direction
of groundwater flow can be approximated from the surface topography (LeGrand, 2004).
Groundwater recharge in the Piedmont is derived entirely from infiltration of local precipitation.
Groundwater recharge occurs in areas of higher topography (i.e., hilltops) and groundwater
discharge occurs in lowland areas bordering surface water bodies, marshes, and floodplains
(LeGrand, 2004).
The ash basin is situated between the MSS to the south, primarily residences and undeveloped
land to the north, and undeveloped land and Lake Norman to the east. A topographic divide is
located along Sherrills Ford Road to the west and along Island Ford Road to the north. The
topography at the site generally slopes downward from that divide toward Lake Norman. The
geology/groundwater conditions at the site are expected to be generally consistent with the
- characteristics of the conceptual groundwater model developed by LeGrand for the Piedmont
region.
2.4 Topographic Map and Identification of Discharges
A topographic map is presented in Figure 2 to meet the requirements of GS 130A-309.210(a) in
the identification of outfalls from engineered channels, as well as seeps and weeps.
Seepage is the movement of wastewater from the ash basin through the ash basin
embankment, the embankment foundation, the embankment abutments, basin rim, through
t_ residual material in areas adjacent to the ash basin. A seep is defined in this document as an
expression of seepage at the ground surface. A weep is understood to have the same meaning
as a seep.
Indicators of seepage include areas where water is observed on the ground surface and/or
where vegetation suggests the presence of seepage. Seepage can emerge anywhere on the
downstream face, beyond the toe, or on the downstream abutments at elevations below normal
pool. Seepage may vary in appearance from a "soft," wet area to a flowing "spring." Seepage
may show up first as only an area where the vegetation is lusher and darker green than
surrounding vegetation. Cattails, reeds, mosses, and other marsh vegetation often become
established in a seepage area. However, in many instances, indicators of seeps do not
r
,l

Duke Energy Carolinas, LLC I Discharge Assessment Plan �♦�
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SECTION 2 -SITE BACKGROUND
necessarily indicate the presence of seeps. Areas of apparent iron staining and/or excess iron
l
bacteria may also indicate the presence of a seep.
Locations of seepage at the ground surface adjacent to the ash basin have been identified and
are shown in Figure 2. These areas include the earthen embankment which impound the ash
basin as well as adjacent areas where water from the ash basin may have infiltrated into the
underlying residual materials and expressed as seepage.
2.4.1 Engineered Drainage System for Earthen Dam
Earth dams are subject to seepage through the embankment, foundation, and abutments.
Seepage control is necessary to prevent excessive uplift pressures, instability of the
downstream slope, piping through the embankment and/or foundation, and erosion of material
by migration into open joints in the foundation and abutments. The control of seepage is
performed by the use of engineered drains such as blanket drains, trench drains, and/or toe
drains. In certain cases, horizontal pipes may be installed into the embankment to collect and
control seepage. It is standard engineering practice to collect the seepage and convey seepage
away from the dam.
The MSS ash basin dam (CATAW-054) was constructed with a drainage system, which is
monitored by Duke Energy. The drainage features associated with the ash basin dam are
shown as required by GS 130A-309.210(a)(2)(i) on Figure 2.
2.4.2 Non -Engineered Seep Identification
Topographic maps of the site were reviewed to identify regions of the site where there was a
potential for ash -basin -related seepage to be present. These regions were determined by
comparing ash basin full pond elevations to adjacent topography with ground surface elevations
lower than the ash basin full pond elevation. HDR staff performed site observations within these
identified areas as part of NPDES inspections during the reapplication process during August
2014 and documented locations where seepage was apparent at the time of the site visit.
These seeps are identified as required by GS 130A-309.210(a)(2)(ii) on Figure 2.

Duke Energy Carolinas, LLC I Discharge Assessment Plan �1J�
Marshall Steam Station Ash Basin
SECTION 3 - DISCHARGE ASSESSMENT PLAN
Section 3 - Discharge Assessment Plan
3.1 Purpose of Assessment
The purpose of the assessment is to determine whether existing, known discharges from toe
drain outfalls, seeps, and weeps associated with the coal combustion residuals surface
impoundment (ash basin) have reached the surface waters of the State and have caused a
violation of surface water quality standards as required by North Carolina General Statute 130A-
309.210(b).
Figure 2 and Table 1 present the background and downstream sampling locations to be
considered as part of this Discharge Assessment Plan (DAP). These locations may be
assessed by comparing surface water sampling analytical results of the associated background
location with the corresponding downstream location. For discharges located at the toe of a
dam, an upstream location within the channel may not have been possible to isolate for
comparison given the proximity to the ash basin, which would have the same chemical
composition as the discharge itself. As such, the upstream location was established upstream of
the ash basin and is considered "background." For discharges located a distance from the ash
basin, an identified upstream or "background" location for sampling may be compared to the
downstream portion of the discharge channel. The background and downstream sampling
locations are shown on Figure 2 with "B" and "D" identifiers, respectively, and the corresponding
seep locations associated with the sampling locations are indicated on Table 1.
3.2 Assessment Procedure
The assessment procedure associated with the Marshall ash basin is provided within this
section. In addition to the specific requirements for the assessment, Section 3.2 also provides
the general requirements, the frequency of assessment, documentation requirements, and a
description of the surface water quality analyses that will be performed.
I,
i 3.2.1 General Assessment Requirements
Assessments are to be performed in three phases as follows:
• Observation and Sampling (assessment site visit)
• Evaluation
• Assessment Reporting
The assessment site visit shall be performed when the background and downstream locations
are accessible and not influenced by weather events. Locations on or adjacent to the ash basin
embankments should be performed within two months after mowing, if possible. In addition, the
assessment site visit should not be performed if the following precipitation amounts have
occurred in the respective time period preceding the planned assessment site visit:
Precipitation of 0.1 inches or greater within 72 hours or
Precipitation of 0.5 inches or greater within 96 hours.
The assessments shall be performed under the direction of a qualified Professional Engineer or
Professional Geologist on a semi-annual basis during two nonadjacent quarters. The date of the

Duke Energy Carolinas, LLC I Discharge Assessment Plan L-♦n
Marshall Steam Station Ash Basin J
SECTION 3 - DISCHARGE ASSESSMENT PLAN
initial assessment site visit shall be selected no later than 30 days from the approval of the
Discharge Assessment Plan and should fall within one of the semi-annual timeframes.
Additional seep locations that may have been identified and documented in an Identification of
New Discharge report(s) shall be reviewed prior to performing an assessment site visit, if
available.
3.2.2 Observation and Sampling
Jurisdictional determinations regarding the extent of waters of the United States and their
relationship with identified seeps at the subject facilities will be obtained from the United States
Army Corps of Engineers (USAGE). Until jurisdictional determinations are finalized by USACE,
preliminary information will be used to evaluate the seeps as described in the section below.
The initial assessment site visit should be performed to document baseline conditions of the
discharge channel, including location, extent (i.e., dimensions of affected area), and flow of
each discharge. Discharge channel background and downstream locations should be verified
using a Global Positioning System (GPS) device. Photographs should be taken from vantage
points that can be replicated during subsequent semi-annual assessments.
Initial and subsequent assessment site visits shall document a minimum of the following to
respond to the requirements in 130A-309.21 0.1 (b):
• Record the most recent ash basin water surface elevation and compare to the seep and
outfall and associated discharge location surface water elevations.
• For each discharge channel, the observer shall note the following as applicable on the
day of the assessment site visit:
o Is the discharge channel flowing at the time of the assessment site visit?
o Does the discharge channel visibly flow into a Water of the U.S. at the time of the
assessment site visit?
o How far away is the nearest Water of the U.S.?
o Document evidence that flow has or could reach a Water of the U.S. (e.g.,
description of flow, including extent and/or direction) and describe the observed
condition. Evidence that flow could or has reached a Water of the U.S. may be
indicated by an inspection of the adjacent and downstream topographic drainage
features.
o Observe and document the condition of the discharge channel and outfall of the
engineered channel or seep location with photographs. Photographs are to be
taken from similar direction and scale as photographs taken during the initial
assessment site visit.
• Record flow rate within the discharge channel, if measureable, using the following
methods:

Duke Energy Carolinas, LLC I Discharge Assessment Plan L1�
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SECTION 3 - DISCHARGE ASSESSMENT PLAN
i I
o Timed -volumetric method: Collect a volume of water from the discharge of the PVC
pipe directly into an appropriately sized container. Measure volumes (in mL) in the
field utilizing a graduated container. Record the amount of time (in seconds)
needed to collect the volume of water and calculate the flows (in MGD) for the
timed volume.
o A V-notch weir apparatus will be installed, if necessary, during the initial
( assessment site visit to impound seepage at locations with a defined channel.
Once the impounded seep reaches equilibrium discharge, flows will be measured
using the timed -volumetric method described above.
o Area -velocity method: Measure point velocities and water depth at a minimum of
20 stations along a transect setup perpendicular to the direction of flow using a
Swoffer® 3000 flow meter mounted to a standard United States Geologic Survey
(USGS) top -set wading rod. Utilize the average velocity and cross -sectional area of
the wetted channel to calculate flows in MGD.
Collect water quality samples using the following methods:
o Collect background and downstream samples during a period with minimal
preceding rainfall to minimize potential effects of stormwater runoff. Sampling
procedures should prevent the entrainment of soils and sediment in water samples
that can result in analytical results not being representative of the flow. Because
Areas of Wetness (AOWs)/seeps often have poorly defined flow channels and
minimal channel depth, conventional grab samples collected directly into laboratory
containers or intermediate vessels is not possible without disturbance and
entrainment of soils and sediments. Further, many AOWs are contiguous with low-
lying areas subject to surface water runoff and resulting heavy sediment loading
during storm events or are near surface waters subject to flooding such that
representative samples of the AOW cannot be obtained. If the facility is unable to
obtain an AOW sample due to the dry, low flow or high flow conditions preventing
the facility from obtaining a representative sample, a "no flow" result or "excessive
flow" will be recorded.
o After collection, samples will be preserved and stored according to parameter -
specific methods and delivered to the laboratory under proper Chain -of -Custody
i__J (COC) procedures.
o Analytical parameters for analysis include: Fluoride, Arsenic, Cadmium, Copper,
Chromium, Nickel, Lead, Selenium, and Mercury. This list includes all parameters
previously identified for seep sampling at Duke Energy power plants for which
relevant stream water quality standards are in place. (This list is responsive to the
statutory requirement for the discharge assessment to allow determination whether
discharges from toe drain outfalls, seeps, or weeps have reached surface waters
and caused a violation of surface water quality standards.) Analyses shall be
conducted by Duke Energy's Huntersville Analytical Laboratory (NC Wastewater
Certification #248) and Pace Analytical Laboratories (NC Wastewater Certification

1 �
Duke Energy Carolinas, LLC I Discharge Assessment Plan 01
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SECTION 3 - DISCHARGE ASSESSMENT PLAN
# 12). Laboratory analytical methods used for each constituent are provided in
Table 2.
o Seep in -situ measurements: In -situ field parameters (temperature and pH) shall be
measured utilizing calibrated field meters either at the discharge of the seep
directly, at the discharge of the flow measurement devices, or in the water pool
created behind the device, if sufficient water depth did not exist at the device
discharge.
o Lake Norman and Ash Basin Sample Collection Method: Water quality samples
and in -situ measurements from the Lake Norman shall be collected at a location
upstream and downstream of the ash basin. Additionally, water samples and in -situ
measurements shall be collected from an in -process ash basin location. The grab
samples shall be collected from the river and basin's surface (0.3 m) directly into
appropriate sample bottles.
• In addition to sampling conducted with the semi-annual assessments, additional seep
sampling will be conducted at locations and at a frequency as determined through
discussions with NC DEQ personnel.
3.2.3 Evaluation
Evaluation of the data from the initial assessment site visit will establish baseline conditions and
will serve as the basis for comparison for subsequent assessment site visit results. Evaluation of
observations and sampling results shall include location, extent (i.e., dimensions of affected
area), and flow of each discharge. The analytical results of the upstream and downstream
locations shall be compared to the 15A NCAC 2B standards for surface water quality upon
receipt to identify potential exceedances.
3.2.4 Assessment Reporting
Each assessment site visit shall be documented by the individual performing the assessment,
as described in Section 3.2.2 to meet the requirements in 130A-309.21 0.1 (b). The report should
contain site background, observation and sampling methodology, and a summary of the
observations and descriptions of the discharge channels observed, changes in observations
compared to previous assessment events, estimates of flows quantities, and photographs of
discharges and outfalls of engineered channels designed or improved for collecting water from
the impoundment. Photographs are to be numbered and captioned. The flow and analytical
results shall be recorded and presented in tables similar to the examples provided as Tables 1
and 3. The analytical results shall be compared to the 15A NCAC 2B standards for surface
water quality and exceedances highlighted. This information shall be compiled, reviewed, and
submitted to NC DEQ within 90 days from the Observation and Sampling event.

Duke Energy Carolinas, LLC I Discharge Assessment Plan ���
Marshall Steam Station Ash Basin
SECTION 4 — REFERENCES
Section 4 — References
Heath, R.C. 1984. "Ground -water regions of the United States." U.S. Geological Survey Water -
Supply Paper 2242, 78 p.
LeGrand, Harry, Sr. 2004. A Master Conceptual Model for Hydrogeological Site
Characterization in the Piedmont and Mountain Region of North Carolina, North Carolina
Department of Environment and Natural Resources.
North Carolina Department of Environment and Natural Resources. 2007. Dam Operation,
Maintenance, and Inspection Manual, North Carolina Department of Environment and
Natural Resources, Division of Land Resources, Land Quality Division, 1985 (Revised
2007).
10

FIGURES
Fig
TABLES

DAF-
SITE LOCATION MAP SEPTEMBER 30, 2014
MARSHALL STEAM STATION
DUKE ENERGY CAROLINAS, LLC FIGURE
CATAWBA COUNTY, NORTH CAROLINA 1

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Discharge Sampling
Discharge Location Coordinates
Latitude
Longitude
ID Deectiption (MGD) and Method
Latitude Longitude
Location
Northeast of active ash
0.0019
35*36.712' 80'57.621' Continuous timed -volumetric
basin; tributary to Lake
Norman
1-D
35*36.635'
80*57.549'
1$
East of active ash basin;
35*42.560'
80*21.566'
No Flow
N/A
sheet flow to Lake Norman
2-D
35*35.977'
80*57.812'
(APPROXIMATE) LEGEND:
79 MW-10S DUKE ENERGY PROPERTY BOUNDARY
1
ASH BASIN WASTE BOUNDARY
LANDFILL/STRUCTURAL FILL BOUNDARY
ASH BASIN COMPLIANCE BOUNDARY
ASH BASIN COMPLIANCE BOUNDARY COINCIDENT
WITH DUKE PROPERTY BOUNDARY
STREAM
I TOPOGRAPHIC CONTOUR (4-FT INTERVAL)
s R.
r ASH BASINWf-
COMPLIANCE GROUNDWATER
4� MONITORING WELL
SEEP SAMPLE LOCATION
ht .+
�. A NPDES OUTFALL LOCATION
DISCHARGE SAMPLING LOCATION
BACKGROUND SAMPLING LOCATIONS
TOPOGRAPHIC MAP WITH IDENTIFIED
SEEPS AND OUTFALLS
DUKE ENERGY CAROLINAS, LLC
MARSHALL STEAM STATION ASH BASIN
NPDES PERMIT #NC0004987
CATAWBA COUNTY, NORTH CAROLINA
DATE
DECEMBER, 2014
FIGURE
2

Table 1— Marshall Steam Station Ash Basin — Seep and Associated Discharge Locations and Descriptions
Discharge Location
Location Coordinates
Flow
Coordinates. ,
Seep /
(NAD )
Flow
Measurement
Background
. Discharge Location and Discharge Sampling
(NAD'83)
Discharge
Description
(MGD) and
Location
Location
ID
Method
Latitude
Longitude
Latitude
Longitude
0.0019
Northeast of active ash basin; tributary to Lake
S-1
35*36.712'
80*57.621'
Continuous
Norman
35*36.635'
80057.549'
timed -volumetric
1-D
1-B
East of active ash basin; sheet flow to Lake
S-2
35*42.560'
80*21.566'
No Flow
N/A
Norman
35*35.977'
80°57.812'
2-D
Notes:
— 1. Location coordinates (degrees) for seep sampling locations are approximate and are in NAD 83 datum
2. Flow description for each seep sample location is based on observation during site visits performed by HDR on August 26, 2014; Flow measurements and
analytical samples were collected on September 4, 2014
3. Location coordinates for seep sampling locations are approximate

Table 2 — Laboratory Analytical Methods
Parameter,
Method
Reporting
Limit
Units •
Laboratory
Fluoride (F)
EPA 300.0
1
mg/I
Duke Energy
Mercury (Hg)
EPA 245.1
0.05
Ng/I
Duke Energy
Arsenic (As)
EPA 200.8
1
Ng/I
Duke Energy
Cadmium (Cd)
EPA 200.8
1
Ng/I
Duke Energy
Chromium (Cr)
EPA 200.8
1
Ng/I
Duke Energy
Copper (Cu)
EPA 200.8
1
Ng/I
Duke Energy
Lead (Pb)
EPA 200.8
1
Ng/I
Duke Energy
Nickel (Ni)
EPA 200.8
1
Ng/I
Duke Energy
Selenium (Se)
EPA 200.8
1
Ng/I
Duke Energy

Table 3 — Marshall Steam Station — Example Surface Water/Seep Monitoring Flow and Analysis Results Table
Parameter
Units
S-1
Lake Norman
Upstream
Lake Norman
Downstream
FI - Fluoride
mg/l
<0.5
N/A
N/A
Hg - Mercury (71900)
Ng/l
<0.05
<0.05
<0.05
As - Arsenic (01002)
pg/I
<1
<1
<1
Cd - Cadmium (01027)
Ng/l
<1
<1
<1
Cr - Chromium (01034)
pg/l
<1.47
<1
<1
Cu - Copper (01042)
Ng/l
1
2.46
5.06
Pb - Lead (01051)
Ng/l
<1
<1
<1
Ni - Nickel (01067)
Ng/I
<1.93
N/A
N/A
Se - Selenium (01147)
Ng/l
<4.58
<1
<1
pH
S.U.
6.55
N/A
N/A
Temperature
°C
21.5
N/A
N/A
Flow
MGD
0.0019
N/A
N/A
Notes:
1. Flow measurements at S1 were collected on September 4, 2014
2. Seep S2 was not sampled due to absence of flow during this monitoring event
3. Lake Norman samples were collect on August 5, 2013
4. N/A indicates not applicable

F)?
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Charlotte, NC 28202-2075
[phone]
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