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HomeMy WebLinkAboutNC0003417_Submittal of Revised Sampling and Analysis Plan_20161118Richard E. Baker, Jr. Director EHS-CCP Environmental Programs 526 S. Church Street Mail Code: EC13K Charlotte, NC 28202 Mr. David May North Carolina Department of Environmental Quality Washington Regional Office 943 Washington Square Mall Washington, NC 27889 Subject: Duke Energy Progress, LLC HF Lee Energy Complex NPDES Permit NC0003417 Revised Sampling and Analysis Plan – Hurricane Matthew Response Wayne County Dear Mr. May: On November 9, 2016, Duke Energy received the Plan of Action Review from The Department of Environmental Quality (DEQ) Division of Water Resources (DWR). The review letter was in response to Duke Energy’s Plan of Action submitted to DWR on October 27, 2016. Duke Energy has attached an update to the Sampling and Analysis Plan that incorporates changes resulting from DEQ’s review as well as Duke Energy’s review of current sampling results. Duke Energy has performed sampling of the Neuse River in the area around the HF Lee Plant for six weeks following Hurricane Matthew. To date, Duke Energy has not seen any appreciable differences in the water quality above the inactive basins and downstream of the inactive basins. Duke Energy proposes to continue the current sampling plan until December 1, 2016, and requests that the Division allow for the cessation of surface sampling on December 1, 2016. After that date, Duke Energy will summarize and evaluate the findings of all sampling events in a report and submit it to DWR Washington Regional Office on January 31, 2017. If there are any questions regarding this response, Mr. Steve Cahoon via phone at (919) 546- 7457 or via email at steve.cahoon@duke-energy.com. Sincerely, Richard E. Baker, Jr. Director – Environmental Programs - CCP Attachments 1 H. F. LEE POST-FLOOD SAMPLING AND ANALYSIS PLAN 1.0 INTRODUCTION On October 8, 2016, rains from Hurricane Matthew brought extreme flooding to most of eastern North Carolina. The flood waters from Matthew eclipsed Neuse River flood stage levels from Hurricane Floyd in 1999. Duke Energy’s decommissioned H. F. Lee Plant (Lee Plant), including the inactive ash basins, was inundated and submerged under the flowing flood waters. From the basins, an estimated 2 to 2.5 cubic yards of coal combustion residual (CCR) material (primarily buoyant, inert cenospheres) was released to the flood waters overlying the Neuse River. Duke Energy began conducting daily surface water sampling for the extensive priority pollutants as soon as it was safe to access at the plant site. The data generated to date were transmitted with Duke’s October 27, 2016 letter to DEQ. Based on Duke Energy’s evaluation of the data it is proposed that surface water sampling be continued for the next several weeks at a reduced frequency and for a reduced list of parameters. To date, only three data points have been measured above the NC 2B limits. In addition to the surface water sampling described above, this monitoring plan proposes the initiation of two rounds of sediment/water sampling intended to confirm that there were no short-term environmental impacts to the Neuse River from the release of CCR materials associated with the flooding event. 2.0 PURPOSE The purpose of this sampling plan is to confirm that no environmental impacts resulted from the release of CCR material to the Neuse River during flooding conditions associated with Hurricane Matthew. This plan has been developed in response to a request by the North Carolina Department of Environmental Quality (NCDEQ) to develop a Plan of Action. Water samples will be collected until the week ending December 2, 2016, to continue to assess surface water quality, and sediment samples will be collected to look for evidence of CCR related constituents in depositional areas of the Neuse River. 2 3.0 OBJECTIVES The objectives of this sampling plan are to continue surface water sampling to confirm the absence of water quality impacts and provide an assessment of the presence and relative concentration of CCR materials in sediment in the vicinity and downstream of the Lee Plant that were mobilized by flood waters from Hurricane Matthew. 4.0 NATURE OF STUDY The assessment will include surface water sampling, sediment sampling and analysis of ash related constituents in water and sediments of the Neuse River. Surface water sampling will continue at four designated locations (see attached) for a reduced number of parameters through December 1. Samples will be collected on Mondays and Thursdays at the following locations: 1) Neuse River – Upstream Inactive Ash Basins – located at the Ferry Bridge Rd crossing over the Neuse. 2) Inactive ash basin area – near area of suspected cenosphere release 3) Neuse River near the area of the cooling pond dam breach 4) Downstream cooling pond – collected within the Neuse, south of the site where Stevens Mill road crosses the river Duke Energy will analyze the surface water samples for field parameters (temperature, dissolved oxygen, pH, conductivity, turbidity) and the following metals (dissolved and total phases): Aluminum Total Hardness Antimony Iron Arsenic Lead Barium Nickel Beryllium Selenium Boron Silver 3 Cadmium Thallium Chromium Zinc Copper Mercury (low level) Laboratory analysis for these parameters will use a Practical Quantitation Limit (PQL) that is indicative of laboratory capability and the analytical methodology. Raw lab data will be provided for the analyses identifying all detections and referencing PQL and detection limits for performed analyses. Based on the non-detects for all of the Priority Pollutants collected since Hurricane Matthew, no additional analyses for these parameters is warranted. In accordance with the Department’s November 9, 2016 letter, priority pollutant sample collection and analysis has been discontinued. Sediment sampling will be conducted twice at one upstream (background) site and three downstream sites (Stations DN1, DN2, and DN3) at possible depositional areas downstream of known release points and the results will be analyzed using appropriate approved methods. Water samples will be collected concurrently at the water/sediment interface at these sampling locations. Sampling locations were selected in the field on November 17, 2016 based on river conditions and observations of likely depositional areas. Coordinates for the sampling locations have been updated in Table 1. Data from these locations will be compared to sampling results from the background station (UP1) well above the plant and known release points. Both water and sediments data will be compared to the appropriate screening values (from combination of multiple agency sources) used in the Dan River ash release assessment. Also, where historical data exists, comparisons will be made to pre-release conditions. 5.0 LOCATION AND DURATION OF SEDIMENT SAMPLING The assessment will be conducted at three downstream areas and one upstream area in the Neuse River (Figure 1). For the purposes of this assessment, the sampling areas will be referred to as stations. The survey area within the Neuse River covers approximately 12 kilometers of the river from the upstream Station (UP1) to the downstream- most Station (DN3; See map). Station UP1 is located at the Ferry Bridge Road wildlife access boat ramp and is Duke Energy’s historic background sampling location for the Lee Plant. Data at this station will serve as the upstream reference to which data from the other stations will be compared. Station DN1 is a downstream station located near the inactive ash basins where cenospheres were observed to be migrating from along with the flood waters. Station DN2 is 4 located downstream near the cooling pond breach and Station DN3 is located at the Stevens Mill Bridge (the most downstream sampling location). The downstream locations were selected to be representative of potential depositional areas (i.e., the inside bank of bends where the greatest ash deposition potentially occurred). Also, limited historical water chemistry data, including trace elements, from within the monitoring reach will serve as another dataset to compare data from this monitoring effort to that collected prior to the flooding event. Duke Energy plans to perform this sediment sampling in the Neuse River twice. Should the results of the sampling indicate ash presence in the sediment or a significant difference in ash-related conditions (percent ash, arsenic or selenium values) from upstream to downstream the sampling will be repeated and results evaluated for further action. 6.0 SEDIMENT SAMPLING AND ANALYSIS PLAN 6.1 Limnology The Duke Energy sediment sampling and analysis plan including program, sampling location descriptions, and sampling frequency is described in Tables 1-3. Duke will monitor for the ash indicator analytes arsenic and selenium in both total and dissolved fractions, as well as the other metals listed above for the surface water sampling. The water chemistry samples will be collected from the water column near the sediment-water interface via a submersible sampler (peristaltic pump and hose), transferred to pre-prepared non-metal bottles, field filtered (for dissolved metals), quickly sealed, and returned to the laboratory on ice for analyses. Analyses will be run by a laboratory (Pace Analytical) certified in North Carolina using approved EPA methods (Table 3). The analytical quality assurance and control measures performed by the external contract laboratory will be consistent with their certifications/accreditations and approved SOPs. In addition, one duplicate per sample set (10% duplicate/blank ratio) will be included. Laboratory analysis for these parameters will use a Practical Quantitation Limit (PQL) that is indicative of laboratory capability and the analytical methodology. Raw lab data will be provided for the analyses identifying all detections and referencing PQL and detection limits for performed analyses. The limnological (field) parameter list is appended in Appendix 2. Water quality analysis will be conducted and generally includes temperature, dissolved oxygen, pH, conductivity, and turbidity, which will be measured in the field using a multi-parameter meter with a submersible sonde according 5 to Duke Energy procedure NR00097 (approved by NCDEQ under the Duke Energy Progress Biological Laboratory Certification #006). 6.2 Percent Ash and Trace Element Monitoring in Sediments The primary potential environmental impacts would be from CCRs settling to the river bottom where accumulation of trace elements in the various compartments of the aquatic ecosystem could occur. Therefore, percent ash will be determined at the four sampling locations in this monitoring plan. Duke Energy does not anticipate significant quantities of ash to be present in the river sediments based on ours as well as NCDEQ’s experience with the Dan River ash release. If very low ash percentages (0- 1%) are found, this sampling will be discontinued. Along with percent ash, arsenic and selenium concentrations in sediments will be evaluated using EPA Method 6020. The results will be compared against the sediment analyte/screening values list in Appendix 2. Sediment samples will also be analyzed for the metals listed in Section 4.0. Note that the low level mercury method is not applicable to sediments so mercury will be analyzed using the standard mercury method. The sediment sampling locations will be selected based on Duke Energy’s extensive experience with the Dan River monitoring program. We found that ash settles primarily in depositional areas along the inside banks of river bends. If there is accumulation these areas are the most likely places where significant accumulation would occur. Exact sample locations were selected in the field on November 17, 2016. Samples will be collected by plastic core tubes in which approximately 12 inches of bottom sediments are taken, photographed, and the first six inches collected for percent ash and trace element analysis. The samples will be returned and sent to the appropriate external laboratory for analysis. 7.0 DATA MANAGEMENT All data generated under this sampling plan will be recorded electronically and uploaded to the Duke Energy long-term database. All data will undergo internal QA/QC protocols to ensure accuracy of the stored data. When used, GPS data will be presented as decimal degree coordinates. Geographical Information System (GIS) will be utilized when appropriate along with compatible programs for two- dimensional graphic display for presentation or reporting purposes. 6 8.0 REPORTING A written report from the sampling plan and results will be provided to NCDEQ before the end of 2016 after all analyses have been completed and the results are available. Based on the results, a decision will be made regarding continuation or termination of sampling. 7 Figure 1. H. F. Lee environmental monitoring program sampling locations designations. 8 Table 1. H. F. Lee sediment monitoring program sample location designations and descriptions. Sampling Station Sampling Program Description Decimal Degree Coordinates Upstream (Downstream) UP Limnology and Sediments Neuse River upstream of H. F. Lee Plant and all release points Lat. 35.35560° Long. -078.14027° DN1 Limnology and Sediments Neuse River near the inactive ash basin release point Lat. 35.37852° Long. -078.10150° DN2 Limnology and Sediments Neuse River near the cooling pond breach Lat. 35.37600° Long. -078.05774° DN3 Limnology and Sediments Neuse River at the Stevens Mill Bridge Lat. 35.35890° Long. -078.07748° 9 Table 2. H. F. Lee surface water and sediment monitoring program. Program Frequency Location Surface water quality (aluminum, antimony, arsenic, barium, beryllium, boron, cadmium, chromium, copper, iron, lead, nickel, selenium, silver, thallium, zinc, mercury) Water quality (Field parameters: temperature, pH, dissolved oxygen, specific conductance, turbidity) Two per week through December 1, 2016 Twice -Neuse River – Upstream Inactive Ash Basins – located at the Ferry Bridge Rd crossing over the Neuse. -Inactive ash basin area – near area of suspected cenosphere release -Neuse River near the area of the cooling pond dam breach -Downstream cooling pond – collected within the Neuse, south of the site where Stevens Mill road crosses the river Stations UP, DN1, DN2, and DN3 (surface only) Water chemistry (sediment-water interface) Twice Stations UP, DN1, DN2, and DN3 (sediment-water interface) Percent Ash (sediment) Twice (to determine ash presence and the need to continue sampling; if needed weekly sampling will continue until all samples are non-detect for percent ash) Stations UP, DN1, DN2, and DN3 Trace elements (sediment) Twice (As and Se will be co-sampled as along with percent ash samples as long as they are collected) Stations UP, DN1, DN2, and DN3 10 Table 3. Field sampling and laboratory methods for the H. F. Lee sediment sampling program. Program Method Water quality Temperature, dissolved oxygen, pH, specific conductance, and turbidity will be measured with a calibrated multiparameter instrument. Measurements will be taken from surface from the surface only at river stations. Water chemistry Samples will be taken with a nonmetallic sampler, transported to the laboratory on ice, and then analyzed according to EPA methods and or Standard Methods (SM). Parameters include dissolved and total aluminum, arsenic, and selenium (EPA 200.8). Percent ash Field sampling followed by polarized light microscopy (Method OPT.023.2). Trace elements All media, except water, will processed according to EPA Method 3050B EPA and analyzed by EPA Method 6020. Quality control will be achieved by analytical standards, replicate and spiked samples, and certified reference materials. 11 Appendix 1 12 13 Appendix 2 14 Water Chemistry Screening Values ANALYTE (MDL) SCREENING VALUES-Aquatic Life/Human Health Analytical Methodology Arsenic (As) (µg/L) 50/10 EPA 200.8, Rev. 5.4 1994 (Aqueous) Selenium (Se) (µg/L) 5/NA EPA 200.8, Rev. 5.4 1994 (Aqueous) 15 Sediment Screening Values ANALYTE (MDL wet µg/g) SEDIMENT SCREENING VALUES (μg/g wet weight) Arsenic (0.013) 9.8 Selenium (0.075) 2