NC0000396_03_NCDENR DEP 02_24_2015_20150823

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
February 24, 2015
Mr. Harry Sideris
Senior Vice -President
Environment, Health, and Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, NC 28202
Re: Asheville Steam Electric Generating Plant
NPDES Permit No. NC0000396 — Buncombe County, North Carolina
Conditional Approval of Revised Groundwater Assessment Work Plan
Dear Mr. Sideris:
Donald R. van der Vaart
Secretary
On December 31, 2014, the Division of Water Resources (Division) received the revised
Groundwater Assessment Plan (GAP) for the above listed facility. The revised GAP was submitted
in response to the Division's Review of Groundwater Assessment Work Plan letter dated November
4, 2014 regarding requirements of the Coal Ash Management Act 2014 — G.S. 130A -309.209(a). A
review of the plan has been completed and several deficiencies or items requiring clarification were
noted. In order to keep the site assessment activities on a timely schedule, the Division has approved
the revised GAP under the condition that the following deficient items are addressed in the
Groundwater Assessment Report:
• Comment Section 5.3 Hydrogeologic Site Characteristics:
The Division recognizes the extent to which groundwater and constituent underflow
occurs at the unnamed tributary along the southern property as a data gap. Duke Energy
should be prepared to collect additional field data and conduct sensitivity analyses for the
groundwater flow and transport model to address this site condition.
A report titled "Draft Design Hydrogeologic Report" (2007, Golder & Associates NC,
Inc.) was listed in the Section 11.0 references. Data from this report should be used in
conceptual site understanding, site assessment, and comprehensive site assessment (CSA)
report development. If other reports relevant to groundwater contamination and (or)
hydrogeologic assessment exist, they should also be used and documented in the CSA
report.
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Phone: [phone] Internet: hftp:Owww.ncwater.org
An Equal Opportunity \ Affirmative Action Employer— Made in pad by recycled paper

Asheville Steam Electric Generating Plant
February 24, 2015
Page 2 of 4
• Comment Section 6.2 Preliminary Statistical Evaluation Results
The revised GAP states that new background well data will be pooled with other existing
background well data representative of site conditions for statistical analysis. Refer to
EPA 530/R-09-007, 2009 for guidance on pooling of data used for statistical analysis.
• Comment Section 7.1.1 Ash and Soil Borings:
Add an additional location for soil boring 50 feet into bedrock at CB -8 and at MW -21
and include sampling for inorganic analyses, index property sampling, and Kd test
sampling. The bedrock boring at MW -21 may take the place of the proposed bedrock
boring at MW -22.
If wet site conditions prohibit soil boring and monitor well installation at MW -21 as
depicted on Figure 5, this location should be moved to a more stable ground surface near
CB -5. Information with respect to soil and water chemistry from this area is needed to
close a data gap south-southwest of the site near the supply wells on Bear Leah Trail.
• Comment Section 7.1.2:
At all well cluster locations; priority should be given to installing a well screened across
partially weathered rock (PWR), or the transition zone, regardless of the thickness of the
interval, if this zone is present. This is particularly important because the transition zone
often represents the zone of highest hydraulic conductivity at a given location.
• Comment Section 7.1.2.2 Ash Basins:
Well clusters within ash ponds should also include, in addition to a shallow and a bedrock
well, a PVR well if this zone exists.
• Comment Section 7.1.2 Groundwater Monitoring Wells:
Add an additional location for shallow and PWR monitoring well installation and
sampling in the immediate vicinity of CB -8.
Add an additional location for shallow monitoring well installation and sampling in the
immediate vicinity of CB -3R.
Add an additional location for shallow and bedrock monitoring well installation and
sampling in the immediate vicinity of GW -1.
Add an additional location for PWR and bedrock monitoring well installation and
sampling in the immediate vicinity of CB -1.
Add an additional location for shallow and bedrock monitoring well installation and
sampling in the immediate vicinity of CB -9.
Several shallow monitor well locations listed in Table 6 are not shown on Figure 5 (for
example, MW -12, MW -18S, MW -19S, MW -20, and MW -21S). Please ensure that these
wells are installed and sampled. If a shallow well already exists at a given location and it
produces data of acceptable quality (low turbidity, for example), it may be used in place
of the newly proposed shallow well (for example, CB -6 may be used in place of MW-

Asheville Steam Electric Generating Plant
February 24, 2015
Page 3 of 4
19S) as long as the new PWR/bedrock wells are clustered in the immediate vicinity of the
existing shallow well.
Some shallow wells associated with PWR/bedrock locations are not listed in either Table
6 or Figure 5 (for example, MW -1, MW -2, and MW -4). Ensure that these shallow wells
are installed and sampled if a soil/saprolite zone exists at these locations.
• Comment Section 7.2 Ash Pore Water and Groundwater Sampling and Analysis:
For the radium/uranium groundwater sampling, a) add location ABMW-7BR, b) add
locations ABMW-7S and -71), if installed, c) remove location ABMW-8BR, d) add
locations ABMW-2S and -21), if installed, and e) add locations MW -24S and -24D, if
installed.
• Comment Section 7.3.1 Surface Water Samples and 7.3.2 Sediment Samples:
Include an additional surface water and sediment sample from Lake Julian that will
potentially serve as another background location.
• Comment Section 7.6 Site Conceptual Model:
The geologic cross section C -C' (Figure 5) should be revised to cut through CB -9, MW -
12, MW -9, and MW -16. Add a geologic cross section E -E' that cuts through ABMW-4,
MW -7, and MW -18. Also add a geologic cross section at each modeled transect.
• Comment Section 7.8.2:
Add the following Kd sample locations to the list in paragraph 2, p. 54: MW -21
(alluvium), CB -8 (saprolite, PV,/R), and any others needed in support of transect
evaluation, modeling, and CAP development.
• Comment Section 9.0 CSA Report:
Provide the following additional maps in the CSA report: a) a shaded relief map created
from LIDAR DEMs and b) a site wide orthophoto map showing fill areas. Include site
boundaries, impoundments, water supply wells, and all facility monitor wells on both
maps.
In addition, technical direction that will serve as the basis of expectations for completion of the site
assessment is provided at Attachment 1. Failure to address the deficient items stated above will
result in Duke Energy not being in compliance with the stated statues. Per G.S. 130A -309.209(a) (3)
and (4), you must begin implementation of the revised GAP on March 6, 2015 and the Groundwater
Assessment Report is due on August 23, 2015. It is our understanding that Duke Energy may have
to obtain additional permits to facilitate installation of certain monitoring wells. In the event permits
are needed for this purpose, Duke Energy should take all steps necessary consistent with the law to
avoid delaying completion of the assessment report.
If you have any questions, please contact Ted Campbell at [phone].

Asheville Steam Electric Generating Plant
February 24, 2015
Page 4 of 4
Sincerely,
C) dv.lv'zr�
S. Jay Zimmerman, P.G., Acting Director
Division of Water Resources
cc: WQROS—ARO
WQROS Central Files
DENR Secretary - Don van der Vaart
Synterra (Attn: Kathryn Webb) —148 River Street, Suite 220, Greenville, SC 29601

Attachment 1
Page 1 of 6
Duke Energy GAP Review Issues
The items identified in this Groundwater Assessment Plan (GAP) review summary are provided for
general discussion for the various parties to agree upon technical direction and content in the revised
GAPS, comprehensive site assessments (CSAs), and corrective action plans (CAPS).
Groundwater Monitoring
1. A schedule for continued groundwater monitoring is mandated by the Coal Ash Management
Act 2014. An interim plan should include at least two rounds of groundwater samples collected
and analyzed in 2015. The analytical results of the first round of data collected in 2015 would be
included in the CSA report, while the results of the second round would be submitted as a CSA
addendum. After CSA data can be evaluated, a plan for continued groundwater monitoring can
be developed for implementation in 2016.
2. Sites impacted by inorganics are typically managed using a tiered site analysis which includes
four elements as referenced in EPA/600/R-07/139:
• Demonstration of active contaminant removal from groundwater & dissolved plume
stability;
• Determination of the mechanism and rate of attenuation;
• Determination of the long-term capacity for attenuation and stability of immobilized
contaminants, before, during, and after any proposed remedial activities; and
• Design of performance monitoring program, including defining triggers for assessing
the remedial action strategy failure, and establishing a contingency plan.
This reference and the framework described above should be used as applicable to meet
the corrective action requirements found in 15A NCAC 02L.0106.
3. Because of uncertainty concerning the site's ability to attenuate contaminants over the long
term given potentially changing geochemical conditions, there is a need to address the elements
of the tiered site analysis described above and collect appropriate samples as part of the CSA,
CAP development, and continued groundwater monitoring.
4. The Division of Water Resources (Division) Director is responsible for establishing background
levels for COPCs in groundwater. This determination is based on information and data provided
by the responsible party and may include formal statistical testing using background wells with
at least four rounds of data. Wells identified as "background" are subject to periodic review
based on a refined understanding of site chemistry and hydrogeologic conditions. In general,
each facility must have a background well or wells screened or open to each of the dominant
flow systems that occur at the site and are associated with groundwater contamination. Any
questions concerning adequacy of background monitoring locations or conditions at the
facilities should be directed to the Regional offices.

Attachment 1
Page 2 of 6
5. Delineation of the groundwater contaminant plume associated with coal combustion residuals is
a requirement of the investigation and if off-site monitoring wells are ultimately required to
perform this task, then it is expected that these activities will be completed as part of the
groundwater assessment activities and included in the final report. Documentation of the effort
to gain off-site access, or right of way permits, will be provided if off-site access is denied or
alternate means of assessing the area were not available within the allocated timeframe (such
as within right-of-ways).
Site Assessment
Data Requirements and Sampling Strategy
1. Robust data collection is warranted to support timely completion of site assessments and
subsequent corrective action plans because of the impending deadlines for completion of CSAs
and CAPs, scale and geologic complexity of the sites, the challenges of modeling heterogeneous
systems, and site proximity to potential human and sensitive ecosystem receptors.
2. Robust data collection will be focused along strategically positioned flowpath transect(s) - from
ash pond source to potential receptor—as an efficient approach for model development
(analytical, geochemical, groundwater flow, and transport) in support of risk assessment and
CAP development. Data collected to support evaluation of site conditions along the flowpath
transects should be located along or defensibly proximate to the modeled transects.
3. The dataset developed along proposed flowpath transects will include any information needed
to determine constituent concentrations, conduct Kd tests, and perform batch geochemical
modeling in multiple flow horizons as appropriate. This data will include a) solid phase sample
collection for Kd measurement and batch geochemical modeling, inorganic analysis and
speciation, and other parameters identified in General Comment #4 of the November 4, 2014
GAP comments issued by DWR, b) solution phase sample collection for total and dissolved
inorganic analysis of total concentrations, small pore filtration for dissolved samples, etc., and c)
slug, constant/falling head, and packer testing. The solid phase sample mineralogy, total
concentration results, re-dox measurements, and other geochemical parameters will be used as
input for equilibrium speciation calculations of redox sensitive constituents calculated by
PHREEQC or similar program (EPA/540/5-92/018). This geochemical modeling will be performed
to identify potential mineral phases, estimated species speciation and concentrations, and will
be performed varying key solubility controlling parameters to predict mineral phases,
speciation, and concentrations under varying conditions. Solid samples for Kd tests from
locations where moderately to strongly reducing conditions are anticipated shall be frozen upon
collection and tested in glove box conditions (EPA/600/R-06/112). Refer to EPA/600/R-07/139
Section III for the data collection and characterization needed to support the four -tiered analysis
discussed above.
4. Speciations for groundwater and surface water samples should include Fe, Mn, and any COPCs
whose speciation state may affect toxicity or mobility (e.g. As, Cr, Se, or others if applicable).
This speciation will apply for groundwater samples collected at wells located along proposed

Attachment 1
Page 3 of 6
flowpath transects and in wells where these constituents exceed 2L groundwater standards as
well as for surface water samples collected within ash impoundments.
S. Solid phase samples shall be analyzed for: minerals present, chemical composition of oxides,
hydrous Fe, Mn, and AL oxides content; moisture content; particle size analysis; plasticity;
specific gravity; porosity; permeability, or other physical properties or analyses needed to
provide input to a chosen model. The Division reserves the right to request analysis for organic
carbon content, organic carbonate content (as appropriate if site conditions warrant), or ion
exchange capacities, if needed to complete the site assessment process.
6. In addition to conducting the SPLP leachable inorganic compounds analysis for selected ash
samples to evaluate the potential for leaching of constituents to groundwater, the leachable
analysis should also be conducted for some soil samples from locations beneath the ash ponds,
within the plume, and outside the plume to evaluate potential contributions from native soils.
7. In addition to collecting solid phase samples onsite for Kd procedures, soil samples should be
also collected from unaffected soils within groundwater flow pathway to evaluate Kd(s) or
hydrous ferrous oxide.
8. Rock samples for laboratory analyses should be collected as commented in General Comment 4
of the November 4, 2014 GAP comments issued by DWR. This GAP review comment indicated
that the sample(s) collected from bedrock well soil and rock cores shall be analyzed, at a
minimum, for the following: type of material, formation from which it came, minerals present,
chemical composition as oxides, hydrous Fe, Mn, and Al oxides content, surface area, moisture
content, etc.; however, these analyses were not mentioned in the GAP. The Division reserves
the right to request analysis for organic carbon content, organic carbonate content, and ion
exchange capacity if needed to complete the site assessment process.
9. The coal ash and soil analyte lists should match the groundwater analyte lists.
10. Total uranium analysis should be analyzed where total radium is analyzed for groundwater.
11. If analytical results from a seep sample exceed 2L standards, then the area in the vicinity of the
sample location should be investigated for groundwater contamination. If analytical results
from a surface water sample exceed 2B standards, then the area in the vicinity of the sample
location should be investigated for groundwater contamination.
12. Surface water/seep samples should be collected during baseflow conditions and that the
groundwater monitoring (water levels and sampling) should occur at about the same time.
13. Measurement of streamflow in selected perennial streams is expected as needed in support of
simulation/calibration of flow and transport models; major rivers that serve as groundwater
divides are not included in this expectation.
Conceptual Model Elements
1. In the CSA report, data gaps remaining should be specifically identified and summarized.
2. Site heterogeneities should be identified and described with respect to: a) their nature, b)
their scale and density, c) the extent to which the data collection successfully characterizes
them, d) how the modeling accounts for them, e) and how they affect modeling uncertainty.

Attachment 1
Page 4 of 6
3. The impact of data gaps and site heterogeneities should be described in relation to the
elements developed in the Site Hydrogeologic Conceptual Model and Fate and Transport
Model subsections.
4. For sites in the Piedmont or Mountains, the CSA Report should include a subsection within the
Site Geology and Hydrogeology Section titled 'Structural Geology'. This section should
describe: a) foliations, b) shear zones, c) fracture trace analysis, and d) other structural
components anticipated to be relevant to flow and contaminant transport at the site.
5. Duke Energy will include a poster -sized sheet(s) (ANSI E) combining tabulated analytical
assessment results (groundwater, surface water, and leachate samples); multiple sheets may
be needed to present the data. This should be provided in addition to the individual analytical
results tables that will be prepared for the CSA reports. Any questions concerning format or
content of the analytical result summaries should be directed to the Regional offices.
Geochemical Modeling
1. The Division agrees that a geochemical model "coupled" to a 3-D fate and transport model is
inappropriate given the size and complexity of the sites and the extremely large amount of data
required to calibrate such a model. Rather, a "batch" geochemical model approach should be
sufficient for successfully completing the site assessment and/or corrective action plan.
2. Samples collected for "batch" geochemical analysis should be focused along or defensibly
proximate to flowpath transects.
3. To support successful batch geochemical modeling, dissolved groundwater samples collected
along a contaminant flowpath transect should be obtained using a 0.1 um filter. This will help
ensure a true dissolved phase sample. Note that the dissolved samples are for assessment
purposes only and may not be used for purposes of compliance monitoring. If there is
uncertainty about which areas/wells will be used in the batch geochemical modeling, the initial
round of assessment sampling at the facility can utilize the 0.45 um filter until the contaminant
flow path transects are selected. Once determined, Duke Energy can go back and re -sample the
wells needed for geochemical modeling using the 0.1 um filter. It is recognized that the use of a
0.1 um filter will be difficult for wells with elevated turbidity; in this case, it is recommended
that Duke Energy use two filters in series (the water initially passes through a 0.45 um filter to
remove larger particles prior to passing through the 0.1 um filter). Information for a disposable
0.1um field filter designed specifically for sampling groundwater for metal analysis is provided at
the following link: http://www.vosstech.com/index.php/products/filters. If field comparisons of
0.1 versus 0.45 micron filtration at several transect wells at a given site show no significant
differences between the two methods, then 0.45 micron filters may be used for evaluating the
dissolved phase concentrations at that site.
4. In support of the objectives of General Comment #2 of the November 4, 2014 GAP comments
issued by DWR, Duke Energy should add a column titled 'relative redox' to the analytical results
tables to record the geochemical conditions for that location/sample date. The redox
determination should be based on observed DO, ORP, and any other relevant measures and
presented for historic and new samples (wells, ash pore water, surface waters, etc.). Relative

Attachment 1
Page 5 of 6
redox designations may include "iron reducing", "sulfate reducing", mildly oxidizing, moderately
oxidizing, etc. and should be footnoted with a statement about the degree of confidence in the
designation based on amount and quality of available data.
5. Duke Energy shall also evaluate: a) spatial geochemical trends across the facility and along
selected flow paths, b) temporal geochemical trends where observable (such as for compliance
boundary wells), along with the likely reason for the change (e.g. increase in seasonal recharge,
pond de -watering and subsequent reversal of groundwater flow direction, inundation of well
from river at flood stage, etc.) in support of the CAP. This evaluation step will require a
comparison of geochemical conditions over time with rainfall data, notable ash capping,
dewatering, disposal/removal, or other plant operations, etc. The quality of existing
geochemical data will be evaluated using field notes, calibration records, and consistency in
redox measurements (e.g. eH vs. raw ORP).
Groundwater Models
1. The technical direction for developing the fate and transport modeling will follow guidelines
found in Groundwater Modeling Policy, NCDENR DWO, May 31, 2007, and discussions
conducted between Duke Energy and their consultants with the Division. Ultimate direction for
completion of fate and transport models will be provided by the Division.
2. The CAP Report should include a subsection within Groundwater Modeling Results titled 'Site
Conceptual Model' that succinctly summarizes, for purposes of model construction, the
understanding of the physical and chemical setting of the site and shall include, at a
minimum: a) the site setting (hydrogeology, dominant flow zones, heterogeneities, areas of
pronounced vertical head gradients, areas of recharge and discharge, spatial distribution of
geochemical conditions across the site, and other factors as appropriate), b) source areas and
estimated mass loading history, c) receptors, d) chemical behavior of COPCs, and f) likely
retention mechanisms for COPCs and how the mechanisms are expected to respond to changes
in geochemical conditions.
3. Modeling will be included in the Corrective Action Plan (CAP). The four -tiered analysis
previously referenced and appropriate modeling should be conducted, and the mass flux
calculations described in the EPA/600/R-07/139 should be performed.
4. The CAP Report shall provide separate subsections for reporting groundwater flow models and
fate and transport models.
5. The CAP Report should include subsections within Groundwater Modeling Results titled
'Groundwater Model Development' that describes, for each chosen model: a) purpose of model,
built-in assumptions, model extent, grid, layers, boundary conditions, initial conditions, and
others as listed in Division guidance. Include in this section a discussion of heterogeneities and
how the model(s) account for this (e.g. dual porosity modeling, equivalent porous media
approach, etc.). Separate subsections should be developed for the groundwater flow model,
fate and transport model, and batch geochemical models, respectively.
6. CAP Reports should include a subsection within Groundwater Modeling Results titled
'Groundwater Model Calibration' that describes, for each model used, the process used to

Attachment 1
Page 6 of 6
calibrate the model, the zones of input and calibration variables (for example, hydraulic
conductivities) that were used, the actual (measured) versus modeled results for all key
variables, and others. Separate subsections should be developed for the groundwater flow
model, fate and transport model, and batch geochemical model(s), respectively.
7. CAP Reports should include a subsection within Groundwater Modeling Results titled
'Groundwater Model Sensitivity Analysis' that describes, for each model used, the process used
to evaluate model uncertainty, variable ranges tested, and the key sensitivities. Separate
subsections should be developed for the groundwater flow model, fate and transport model,
and batch geochemical model(s), respectively.
Development of Kd Terms
1. Kd testing and modeling in support of CAP development should include all COPCs found above
the NCAC 15A 02L .0106(8) standards in ash leachate, ash pore water, or compliance boundary
well groundwater samples.
2. The selected Kd used in transport modeling often will profoundly affect the results. Duke
Energy should acknowledge this concept and document within the transport modeling section(s)
of the CAP all widely recognized limitations inherent in the estimation of the Kd term.
Risk Assessment
1. Provide references for guidance and potential sampling methodology related to conducting a
baseline ecological risk assessment or habitat assessment, if warranted.