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HomeMy WebLinkAboutRevised Interim Monitoring Network_20170517ROY COOPER Governor MICHAEL S. REGAN Secretaq S. JAY ZIMMERMAN Director May 1, 2017 Paul Draovitch Senior Vice President Environmental, Health & Safety Duke Energy 526 South Church Street Mail Code EC3XP Charlotte, North Carolina 28202 Subject: Response to the February 2, 2017 Letter from Duke Energy Revised Interim Monitoring Plans for 14 Duke Energy Facilities Dear Mr. Draovitch: The North Carolina Department of Environmental Quality (DEQ) has received and reviewed your February 2, 2017 letter that was in response to our letters dated December 21, 2016 and January 11, 2017 regarding facility Interim Monitoring Plans. DEQ has considered Duke Energy's comments and is providing the attached revised Interim Monitoring Plans for the respective facilities. Due to ongoing internal discussions regarding DEQ's position on surface water sampling, the attached plans only contain references to groundwater monitoring locations. Once a final internal position has been determined, DEQ may elect to provide Duke Energy with surface sampling locations to incorporate into the revised Interim Action Plans. For clarification, we have also provided the minimum expected groundwater sampling analyte list. The attached revised facility Interim Monitoring Plans shall be conducted on a quarterly basis commencing the third quarter of calendar year 2017 pursuant to 15A NCAC 02L .0 110, until Corrective Action Plans are accepted for the individual facilities or as directed otherwise by DEQ. The quarterly sampling events will be conducted in conjunction with planned compliance monitoring sampling events for three quarters during the calendar year, supplemented with an additional sampling event conducted at each facility in order to provide four rounds of monitoring data to evaluate seasonal fluctuations during a year -long timeframe. If sampling an individual groundwater location is problematic, please call the Regional Office that manages the facility to discuss issues. Any changes to interim monitoring network and sampling requirements must be discussed with the respective Regional Offices and coordinated by official correspondence from the DEQ Central Office. Document the results of the four quarters of sampling and analysis during the calendar year as an annual interim monitoring plan report for each subject coal ash facility submitted by April 3 01h of State of North Carolina I Environmental Quality I Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center I Raleigh, North Carolina 27699-1636 919-707-9129 - - - - - - - - - - - - - - - - - - - - - - - - - the following year. The respective annual monitoring reports shall include figures, tables, cross - sections, maps, and time -series plots in a manner that provides an integrated, comprehensive interpretation of site conditions and plume status. Reports submitted in a data summary format will not be approved as an acceptable documentation of the monitoring program. In order to optimize the groundwater monitoring at each facility, DEQ will be removing the groundwater monitoring condition from the NPDES permits as they are reissued. Duke Energy shall continue to monitor the compliance wells separately under the individual NPDES permits until the NPDES permits are reissued with no groundwater monitoring condition. At that time, the compliance wells shall continue to be monitored per the attached revised interim monitoring plans under the authority of 15A NCAC 02L .0110. The DEQ is open to consider further optimization of the interim monitoring plan program following a qualitative and quantitative review of site -specific data. A thorough analysis of spatial and temporal trends related to contaminant distribution that include determination of background conditions and identification of areas impacted by coal ash residuals must be provided as a decision framework to support improvements to long-term monitoring programs. If you have any questions, please feel free to contact Steve Lanter at (919) 807-6444. Sincerely, S. Jay i erman, P.G., Director Division of Water Resources Attachments: Revised Interim Monitoring Plans for the 14 coal ash facilities cc: WQROS Regional Offices WQROS Central File Copy Revised Allen Steam Station Interim Monitoring Plan — Groundwater Only Sample for Wells to be Sampled Radionuclides Regional Office Notes M AB-1 OD AB-10S AB-11D x AB-12D AB-12S Recommend redevelopment due to elevated turbidity. AB-13D x Radionuclide sample requested by MRO AB-13S x Radionuclide sample requested by MRO AB-14BR AB-14D Recommend redevelopment due to elevated turbidity. AB-IR AB-2 AB-20D AB-20S Recently installed and should be added to IGWMP - Based on review of analytical (submitted on 2/20/2017), water quality at AB-2 I BRL is AB-21BRL x acceptable and this location appears to vertically delineated (pending background for Cr6+, V) Radionuclide sample requested by MRO Based on review of analytical (submitted on 2/20/2017), AB-21D has water quality issues (i.e., grout contamination). Since this well is located along a major flow transect beneath the basin this AB-21D x well should be reinstalled to more accurate reflect site conditions beneath the basin in the deep flow layer. Radionuclide sample requested by MRO AB-21 S x Radionuclide sample requested by MRO AB-21 SL x Radionuclide sample requested by MRO Recently installed and should be added to IGWMP - Recommend redevelopment due to water quality AB-22BR issues. Also, due to observed concentrations of Boron a lower bedrock well is warranted for vertical delineation at this location. AB-22D AB-22S Recommend redevelopment due to elevated turbidity. Allen Steam Station Page 1 of 9 May 1, 2017 Location not delineated horizontally or vertically. GWA-23D located upgradient, has water quality issues and therefore does not provide valid analytical for determination of horizontal delineation. Also, this location needs vertical AB-23BRU delineation due to Arsenic exceedances observed in the shallow well thus warranting reinstallation. Based on review of analytical (submitted on 2/20/2017) AB-23BRU continues to have water quality issues (i.e., grout contamination) and should be reinstalled. AB-23S Recommend monitoring pH — historically observed fluctuating. Recently installed and should be added to IGWMP - Based on review of analytical (submitted on . AB-24BR 2/20/2017), water quality at AB-24BR is acceptable and location appears to be vertically delineated (pending background for Mn, V) Based on review of analytical (submitted 2/20/2017), AB-24D has water quality issues (i.e., AB-24D grout contamination). This well is located along a major flow transect beneath the basin and should be reinstalled to more accurately represent groundwater quality at this location. AB-24S AB-24SL Recommend monitoring pH — historically observed fluctuating. GWA-3BR has consistently had pH >10 since installation and therefore is not representative of actual site conditions. Because of the above mentioned issues as well as purposes of modeling (geochem. and fate and transport), it is recommended that AB-25BR be reinstalled. Based on review of analytical (submitted on 2/20/2017) AB-24BR (pending background AB-25BR X determination for Mn and V) provides delineation to the west of AB-25 BR; but GWA-3BR continues to have water quality issues and at this time does not provide delineation to the east toward the river. GWA-3BR should be reinstalled to delineate exceedances observed at AB-25BR. Once AB- 25BR is reinstalled this location will be reevaluated to determine if additional vertical delineation is warranted. Radionuclide sample requested by MRO Allen Steam Station Page 2 of 9 May 1, 2017 GWA-3BR has consistently had pH >10 since installation and therefore is not representative of actual site conditions. Because of the above mentioned issues as well as purposes of Modeling (geochem. and fate and transport), it is AB-25BRU X recormuended that AB-25BRU be reinstalled. Based on review of analytical (submitted on 2/20/2017), AB-25BRU continues to have water duality issues and should be reinstalled. Radionuclide sample requested by MRO AB-25S X Radionuclide sample requested by MRO AB-25SL X Radionuclide sample requested by MRO AB-26S Recently installed and should be added to IGWMP — Based on review of analytical (submitted on AB-27BR 2/20/2017), elevated concentration of total chromium was observed thus warranting installation of a lower bedrock well for vertical delineation. AB-27D Recommend redevelopment due to elevated turbidity. AB-27S Due to water quality issues at this location, AB-28D discontinue sampling. AB-30D is in close proximity and is representative of site conditions. AB-28S AB-29D AB-29S Due to water quality issues at this location, AB-29SL discontinue sampling. AB-29S does not have water quality issues and is representative of site conditions. AB-2D AB-30D AB-30S Recommend redevelopment due to elevated turbidity. AB-31 S AB-32D AB-32S pH has been observed fluctuating and has had turbidity issues. Recommend redevelopment and AB-33D X reevaluation during next sampling event to determine path forward. Radionuclide sample requested by MRO AB-33S X Radionuclide sample requested by MRO Allen Steam Station Page 3 of 9 May 1, 2017 AB-34D AB-34S Based on review of analytical (submitted on 2/20/2017), water quality at AB-35BR is acceptable and location appears to be vertically delineated AB-35BR X (pending background for Mn and V). Reinstallation is not warranted at this time. Radionuclide sample requested by MRO AB-35D has consistently had pH >/= 10 since installation and therefore is not representative of actual site conditions. Because of the above mentioned issues as well as purposes of modeling (geochem. and fate and transport), it is recommended that AB-35D be reinstalled since it is AB-35D X located along a major flow transect. Based on review of analytical (submitted on 2/20/2017), AB-35D continues to have water quality issues and should be reinstalled. Radionuclide sample requested by MRO AB-35S X Radionuclide sample requested by MRO AB-36D Monitor pH AB-36S AB-37D AB-37S Recently installed and should be added to IGWMP - Based on review of analytical (submitted on AB-38BR 2/20/2017), water quality at AB-38BR is acceptable and location appears to be vertically delineated (pending background for Co, Mn, and V). AB-38D AB-38S AB-39D AB-39S AB-4BR X AB-4D X AB-4S X AB-5 AB-6A X AB-6R X AB-9D X AB-9S X BG-1D X BG-ID has water quality issues and warrants reinstallation. Since this well is not viable sample Allen Steam Station Page 4 of 9 May 1, 2017 location at the present GWA-26S/D should remain in the sampling program until BG-ID is reinstalled and deemed representative of background conditions at the site. Based on review of analytical (submitted on 2/20/2017), BG-1D continues to have water quality issues and should be reinstalled. GWA-26S/D should remain in the IGWMP. Radionuclide sample requested by MRO BG-1 S X Radionuclide sample requested by MRO Slated for reinstallation, but does not appear to have BG-2BR X been replaced based on review of analytical (submitted on 2/20/2017). BG-2D X BG-2S X BG-3D BG-3S BG-4BR BG-41) Recommend redevelopment due to elevated turbidity. Monitor pH. BG-4S Slated for reinstallation, but does not appear to have GWA-14D been replaced based on review of analytical (submitted on 2/20/2017). GWA-14S GWA-15D GWA-15S GWA-16D GWA-16S GWA-17D X Radionuclide sample requested by MRO GWA-17S X Radionuclide sample requested by MRO Due to the observed upward trend of conductivity at the AB-1R location and uncertainty in regard to what is effecting water quality at this location, GWA-18S/D should remain in the sampling program to continue to assess potential impact from the basin. Also, it is located along a major flow GWA-18D transect so for purposes of modeling (geochem. and fate and transport) it should continue to be sampled. Based on review of analytical (submitted on 2/20/2017), GWA-18D has water quality issues (pH 9.4 and has been observed trending upward since installation) and reinstallation is recommended. Allen Steam Station Page 5 of 9 - May 1, 2017 Due to the observed upward trend of conductivity at the AB-lR location and uncertainty in regard to what is effecting water quality at this location GWA-18S GWA-18S/D should remain in the sampling program to continue to assess potential impact from the basin and it is located along a major flow transect so for purposes of modeling (geochem. and fate and transport) it should continue to be sampled. GWA-19S/D should remain in the sampling program as 273 (South Point Rd) being a topographic divide is in question in regards to the DBR flow layers. This location is also located along a major flow transect so for purposes of GWA-19D modeling (geochem. and fate and transport) it should continue to be sampled. Based on review of analytical (submitted on 2/20/2017), GWA-19D has water quality issues (pH 10.3 has been observed trending upward since installation) and reinstallation is recommended. GWA-19S/D should remain in the sampling program as 273 (South Point Rd) being a topographic divide is in question in regards to the GWA-19S DBR flow layers. This location is also located along a major flow transect so for purposes of modeling (geochem. and fate and transport) it should continue to be sampled. GWA-1BR X GWA-lD X GWA-1 S X Recommend redevelopment due to elevated pH GWA-21BR X (9.5) and then reevaluate for determination of replacement. Slated for reinstallation, but does not appear to have GWA-21D X been replaced based on review of analytical (submitted on 2/20/2017). GWA-21 S X GWA-22D GWA-22S Recommend redevelopment due to elevated turbidity. Due to proximity of WSWs, GWA-23D should be reinstalled to monitor deep flow layer for potential influence from the basin. GWA-23D Based on review of analytical (submitted on 2/20/2017), GWA-35D continues to have water quality issues and should be reinstalled. Allen Steam Station Page 6 of 9 May 1, 2017 GWA-23S Based on review of analytical (submitted on 2/20/2017), GWA-24BR continues to have water quality issues and should be reinstalled as GWA-24BR previously reconunended. This location is in close proximity to WSWs located west of the basin and provides invaluable data. This well should be reinstalled. Based on review of analytical (submitted on GWA-24D 2/20/2017), water quality at GWA-24D is acceptable and location appears to be vertically delineated (pending background for V, Cr6f). Based on review of analytical (submitted on 2/20/2017), GWA-24S still has not been sampled to GWA-24S date due to insufficient water volume. This location is in close proximity to WSWs located west of the basin and provides invaluable data. This well should be reinstalled. BG-1D has water quality issues and warrants reinstallation. Since this well is not viable sample location at the present GWA-26S/D should remain in the sampling program until BG-1D is reinstalled and deemed representative of background GWA-26D conditions at the site. Based on review of analytical (submitted on 2/20/2017), GWA-26D should continue to be included in the IGWMP. Note: Recoimnend monitoring pH (observed fluctuating above standard) — may be beneficial to redevelop well. BG-ID has water quality issues and warrants reinstallation. Since this well is not viable sample location at the present GWA-26S/D should remain in the sampling program until BG-I D is reinstalled GWA-26S and deemed representative of background conditions at the site. Based on review of analytical (submitted on 2/20/2017), GWA-26S should continue to be included in the IGWMP. GWA-2D X GWA-2S X GWA-3BR has consistently had pH >10 since installation and therefore is not representative of GWA-3BR X actual site conditions (located along major flow transect). Based on review of analytical (submitted on Allen Steam Station Page 7 of 9 May 1, 2017 2/20/2017), GWA-3BR should be reinstalled for delineation of exceedances observed at AB-25BR. GWA-31) X Recommend redevelopment due to elevated turbidity and fluctuating pH. GWA-3S X Recently installed and should be added to IGWMP - Based on review of analytical (submitted on GWA-4BR X 2/20/2017) water quality at GWA-4BR is acceptable and location appears to be vertically delineated (pending background for Mn, V). GWA-4D X GWA-4S X Slated for reinstallation, but does not appear to have GWA-5BR X been replaced based on review of analytical (submitted on 2/20/2017). GWA-5D X GWA-5S X Historically, GWA-6BR has not exhibited water quality issues (elevated pH), however, based on GWA-6BR X review of analytical (submitted on 2/20/2017), this location has pH >12. Recommend reevaluation during next sampling event for determination of path forward. GWA-6DA X GWA-6S X GWA-7D X GWA-7S X GWA-8D GWA-8S Recommend redevelopment due to elevated GWA-91) X turbidity. Radionuclide sample requested by MRO GWA-9S X Radionuclide sample requested by MRO Recently installed and should be added to IGWMP - Based on review of analytical (submitted on 2/20/2017) water quality at GWA-9BR is GWA-9BR X acceptable and location appears to be vertically delineated (pending background for Mn, V). Radionuclide sample requested by MRO Allen Steam Station Page 8 of 9 May 1, 2017 Minimum Parameters to be Analyzed Aluminum Boron Copper Mercury Selenium Thallium Alkalinity Cadmium Hexavalent Molybdenum Sodium (total) TOC (total) Chromium Total Antimony Calcium Iron Nickel Strontium Combined Uranium Arsenic Chloride Lead Potassium Sulfate TSS (total) Barium Chromium Magnesium Radium 226 Sulfide Vanadium Beryllium Cobalt Manganese Radium 228 TDS Zinc Allen Steam Station Page 9 of 9 May 1, 2017 Revised Asheville Steam Electric Plant Interim Monitoring Plan — Groundwater Only Wells to be Sampled Sample for Radionuclides (X) Regional Office Notes ABMW-11BR AMW-03B X AMW-1B X AMW-2A AMW-213 water level only APZ-30 water level only B-1 water level only B-1-A water level only B-2 water level only CB-1 X CB-1BR water level only CB-1BRL water level only CB -ID X CB-8BR X CB-81) water level only CB-9BR X CB-9SL X GW-lBR GW-1D GW-2 X GW-3 X GW-4 X GW-5 X MW-3D X MW-5BR MW-5D MW-8S X MW-10 X MW-11 MW-11D MW-13BR MW-13D MW-14BR MW-15A X MW-15BR water level only MW-15D X MW-16A X Asheville Steam Electric Plant Page 1 of 2 May 1, 2017 MW-16BR X MW-17A X MW-18BR X MW-18BRL X MW-18D X MW-19BR water level only MW-20A MW-21D X MW-22BR X MW-22D X MW-23BR MW-23DL MW-23DU MW-24S X MW-6BR X MW-6D X MW-6S X MW-7BR water level only MW-8BR MW-9BR X MW-9D X MW-9S X P-102 water level only P-103 PZ-16 Needs to be replaced and added to IMP. PZ-17D X PZ-17S X PZ-19 X PZ-22 X Minimum Parameters to be Analyzed Aluminum Boron Copper Mercury Selenium Thallium Alkalinity Cadmium Hexavalent Molybdenum Sodium (total) TOC (total) Chromium Total Antimony Calcium Iron Nickel Strontium Combined Uranium Arsenic Chloride Lead Potassium(total) Sulfate TSS Barium Chromium Magnesium Radium 226 Sulfide Vanadium Beryllium Cobalt Manganese Radium 228 TDS Zinc Asheville Steam Electric Plant Page 2 of 2 May 1, 2017 Revised Belews Creek Steam Station Interim Monitoring Plan — Groundwater Only Wells to be Sampled Sample for Radionuclides (X) Regional Office Notes AB-1BR AB -ID AB-1S AB-2D AB-2S AB-3D AB-3S AB-4BR Measure pH, if still high, do not sample AB-4BRD AB-4D AB-4S AB-4SL Measure pH, if still high, do not sample AB-5D AB-5S AB-5SL AB-6D AB-6S AB-6SL AB-7D AB-7S AB-8D AB-8S AB-8SL AB-9BR AB-9BRD AB-9D AB-9S BC-23A BC-28 BCSW-007 BCSW-008 BCSW-018A BCSW-019 BCW W-002 BG-ID BG-1 S X BG-2BR Belews Creek Steam Station Page 1 of 4 May 1, 2017 BG-2D X BG-2S X BG-3D BG-3 S X GWA-10D If pH still high, do not sample. GWA-10S GWA-11D GWA-11S GWA-12BR GWA-12D GWA-12S GWA-16BR GWA-16D If pH still high, do not sample. GWA-16S GWA-17D GWA-17S GWA-18D GWA-18S GWA-18SA GWA-19BR GWA-19D GWA-19S GWA-19SA GWA-1BR X GWA-1 D X GWA-1S X GWA-20BR GWA-20D GWA-20S GWA-20SA GWA-21D GWA-21 S GWA-22D GWA-22S GWA-23D GWA-23S GWA-24BR GWA-24D X GWA-24S X GWA-25BR X GWA-26BR X Belews Creek Steam Station Page 2 of 4 May 1, 2017 GWA-26D X GWA-26S X GWA-27BR GWA-27D GWA-27S GWA-2D GWA-2S GWA-30D X GWA-30S X GWA-31 D GWA-31 S GWA-32D GWA-32S GWA-3D GWA-3 S GWA-4D If the well is still there, please sample. GWA-5BR2 If the well is still there, please sample. GWA-51) If the well is still there, please sample. GWA-5S If the well is still there, please sample. GWA-6D X GWA-6S X GWA-7D X GWA-7S X GWA-8D X GWA-8S X GWA-9BR GWA-9D GWA-9S MW-102D MW-102S MW-104BR MW-104D MW-104S MW-200BR X MW-200D X MW-200S X MW-201BR MW-201D MW-202BR MW-202D MW-202S Belews Creek Steam Station Page 3 of 4 May 1, 2017 MW-203BR MW-203D MW-203S MW-204D MW-204S MW-3 X Minimum Parameters to be Analyzed Aluminum Boron Copper Mercury Selenium Thallium Alkalinity Cadmium Hexavalent Molybdenum Sodium (total) TOC (total) Chromium Total Antimony Calcium Iron Nickel Strontium Combined Uranium Arsenic Chloride Lead Potassium Sulfate TSS (total) Barium Chromium Magnesium Radium 226 Sulfide Vanadium Beryllium Cobalt Manganese Radium 228 TDS Zinc Belews Creek Steam Station . Page 4 of 4 May 1, 2017 Devised Buck Combined Cycle Station Interim Monitoring Plan — Groundwater Only Wells to be Sample for Sampled Radionuclides Regional Office Notes (X) AB -ID Recently installed and should be added to IGWMP — Based on review of analytical (submitted on AB-1 OBR 2/13/2017), Boron was observed in exceedance of 2L standard thus warranting installation of a lower bedrock well for purposes of vertical delineation. AB-101) AB-10S Recommend reinstallation for vertical delineation - pH >10 since well was installed in 2015 (5 sampling events). This well is also located along and major flow transect identified at the site so for modeling purposes this well should be reinstalled. AB-2BR X Based on review of analytical (submitted on 2/13/2017), AB-2BR continues to have water quality issues and reinstallation is warranted for vertical delineation at this location (exceedance of Antimony was observed above IIVIAC). Radionuclide sample added by MRO. AB-21) X Radionuclide sample added by MRO. AB-2S X Radionuclide sample added by MRO. AB-2SL X Radionuclide sample added by MRO. AB-3D AB-3S Discontinue sampling AB-4BR. Based on review of AB-4BR analytical (submitted on 2/13/2017), water quality at AB-4BRL is acceptable (pending background for V, Cr6+). Recently installed and should be added to IGWMP - Based on review of analytical (submitted on AB-4BRL 2/13/2017), water quality at AB-4BRL is acceptable (pending background for V, Cr6+) and this location appears to be vertically delineated. AB-4BRU AB-4S Due to water quality issue (pH trending upward), AB-4SL recommend redevelopment of well and reevaluation during next sampling event for determination of path forward. Buck Combined Cycle Station Page 1 of 6 May 1, 2017 According to historical analytical, this location was only sampled once in R2 and has not been sampled since then. I assume this is due to the high pH indicating grout contamination at this location. Based AB-5BRU X on review of analytical for AB-5S/SL (submitted on 2/13/2017), vertical delineation (As, Cr6+, Fe, Mn, V) is warranted and this well should be reinstalled. Radionuclide sample added by MRO. AB-5S X Radionuclide sample added by MRO. AB-5SL X Radionuclide sample added by MRO. AB-6BRU AB-7BRU AB-7S AB-8BRU AB-8 S Based on review of analytical (submitted on 2/13/2017), AB-9BR has water quality issues (i.e., grout contamination). Exceedances of TDS, Sb, and V were observed. This well can be reinstalled and AB-9BR X results reevaluated to determine if additional vertical. delineation is necessary or a lower bedrock can be installed and AB-9BR abandoned due to water quality issues. Radionuclide sample added by MRO. Based on review of analytical (submitted on 2/13/2017), AB-9BRU has water quality issues (i.e., grout contamination). Exceedances of B, TDS, Sb, and V were observed. AB-9BRU should be reinstalled to evaluate contaminant migration from the AB-9BRU X basin toward the Yadkin River. (Note: this location was documented as AB-9D on the data submittal — recommend updating applicable tables/figures for field staff and ensuring the proper ID is shown on the well tag.) Radionuclide sample added by MRO. Recommend redevelopment of this location due to AB-9S X elevated turbidity. Radionuclide sample added by MRO. AS-lD AS-1 S AS-2D AS-3D AS-3 S Buck Combined Cycle Station Page 2 of 6 May 1, 2017 Slated for reinstallation, but does not appear to have BG-IBR been replaced based on review of analytical (submitted on 2/13/2017). Slated for reinstallation, but does not appear to have BG-lD been replaced based on review of analytical (submitted on 2/13/2017). Need to evaluate V exceedance observed (historically elevated). BG-IS BG-2D X Radionuclide sample added by MRO. BG-2S X Radionuclide sample added by MRO. Radionuclide sample added by MRO. BG-3BRU X (Note: this location was documented as BG-3D on the data submittal — recolm-nend updating applicable tables/figures for field staff and ensuring the proper ID is shown on the well tag.) BG-3S X Radionuclide sample added by MRO. pH appears to be fluctuating above standard — GWA-1013 recommend redevelopment and reevaluation for upcoming sampling event. GWA-IOS GWA-11D GWA-11S GWA-12BRU X GWA-12S X GWA- I 3D has water quality issues, however, MW- 13D is in close proximity to GWA- I 3D and receptors GWA-13D and has no water quality issues. MW-1 3D should be utilized for sampling — discontinue sampling GWA- 13D. GWA-13SR Slated for installation, but does not appear to have been installed based on review of analytical GWA-14BR X (submitted on 2/13/2017). Radionuclide sample added by MRO. Due to close proximity of well to WSWs and GW flow direction observed on maps this well should be reinstalled to monitor potential migration in the deep flow layer from ash basin toward receptors. GWA-14D X Based on review of analytical (submitted 2/13/2017), GWA- I 4D should be reinstalled due to water quality issues (i.e., grout contamination). Radionuclide sample added by MRO. GWA-14S X Radionuclide sample added by MRO. Buck Combined Cycle Station Page 3 of 6 May 1, 2017 Due to elevated concentration of Cobalt, additional horizontal and vertical delineation is warranted for GWA-15D X this location. A bedrock well should be installed at this location and a S/D well pair should be installed to the east of GWA-15S/D. GWA-15S X GWA-16BR X Installation pending property access GWA-16D X Installation pending property access GWA-16S X Installation pending property access GWA-17S According to historical analytical, this location was only sampled twice, in R5 and R7, and has not been sampled since then. I assume this is due to the high GWA-18D X pH indicating grout contamination at this location. Based on review of analytical (sampled 9/28/2016), vertical delineation (TDS, Cr(tot), Sb, Fe) is warranted and this well should be reinstalled. GWA-18S X pH appears to be fluctuating above standard — GWA-19D X recommend redevelopment and reevaluation for upcoming sampling event. GWA-19S X pH appears to be fluctuating above standard — GWA-1D X recommend redevelopment and reevaluation for upcoming sampling event. GWA-1 S X GWA-20D X GWA-20S X GWA-22D X Based on review of analytical (submitted on 2/13/2017), GWA-2BR has water quality issues (i.e., GWA-2BR X grout contamination). This well is located on a major flow transect and is protective of nearby receptors and should be reinstalled at this location. GWA-2BRU X GWA-2S X GWA-3BR X GWA-3BRU X GWA-3S X GWA-4D X GWA-4S X GWA-5BRU X GWA-5 S X Based on review of analytical (submitted on GWA-6BR X 2/13/2017), exceedances of SO4 and TDS were observed at GWA-6BR. Due to the observed Buck Combined Cycle Station Page 4 of 6 May 1, 2017 exceedances, vertical delineation at this location is warranted. A lower bedrock well should be installed at this location to further evaluate concentrations of SO4 and TDS. Radionuclide sample added by MRO. GWA-6BRU X GWA-6S X GWA-7D X GWA-7S X GWA-8D GWA-9BR historically had water quality issues, but based on review of analytical (submitted on 2/13/2017), water quality at GWA-9BR is acceptable GWA-9BR X and appears to be vertically delineated (pending background for V). Radionuclide sample added by MRO. GWA-9D X GWA-9S X Compliance monitoring well — was not sampled in R8, but is sampled 3x/year per NPDES pennit. Exceedances of SO4 and TDS have been observed in each sampling event to date. GWA-12S/BRU MW-1 OD provides horizontal delineation for this location, but vertical delineation is warranted. Installation of a lower bedrock at GWA-6BR as reconunended above can be utilized to provide vertical delineation at this location. Recently installed and should be added to IGWMP - Based on review of analytical (submitted on 2/13/2017), exceedance of Boron was observed at MW-1 IBR X MW-11BR. Due to the Boron exceedance (leading edge constituent), vertical delineation at this location is warranted. A lower bedrock well should be installed at this location to further evaluate Boron concentrations. Compliance monitoring well — historically had water MW-11D X quality issues (turbidity above 10 NTU). Recommend redevelopment of well in attempt to reduce turbidity. MW-1 1 S X MW-12D MW-12S MW-13D MW-1D MW-IS MW-2S Buck Combined Cycle Station Page 5 of 6 May 1, 2017 MW-2D MW-3D X MW-3S X MW-4D MW-4S MW-5D MW-5S MW-6BR X pH appears to be trending upward (currently at 9). Recommend redevelopment and evaluation. MW-6D X MW-6S X MW-7D MW-7S MW-8BR X Recently installed and should be added to IGWMP — Based on review of analytical (submitted on 2/13/2017), MW-8BR has water quality issues (i.e., grout contamination). This location should be reinstalled to provide accurate data south of Cell 1. MW-8D X MW-8S X MW-9D X MW-9S X Minimum Parameters to be Analyzed Aluminum Boron I Copper Mercury Selenium Thallium Alkalinity Cadmium Hexavalent Molybdenum Sodium (total) TOC (total) Chromium Total Antimony Calcium Iron Nickel Strontium Combined Uranium Arsenic ChloridePotassium Sulfate TSS (total)Lead (total) Barium Chromium Magnesium. Radium 226 Sulfide Vanadium Beryllium Cobalt Manganese Radium 228 TDS Zinc Buck Combined Cycle Station Page 6 of 6 May 1, 2017 Revised Cape Fear Stearn Electric Plant Interim MonitorinI4 Plan - Groundwater Only Wells to be Sampled Sample for Radionuclides (X) Regional Office Dotes ABMW-1 X ABMW-lBR X ABMW-1 S X ABMW-2SL ABMW-2SU ABMW-3 X ABMW-3BR ABMW-3SR X ABMW-4 X ABMW-4S X ABMW-5BR ABMW-5 S BGMW-4 X BGTMW-4 X CMW-01 X CMW-02 CMW-03 X CMW-5R not yet installed CMW-06 X CMW-07 X CMW-08 X CTMW-01 X CTMW-02 CTMW-07 CTMW-08 X MW-09 MW-09BR MW-10 X MW-IOBR X MW-1 OBRL MW-10D MW-11 X MW-12 X MW-12BR MW-13 MW-15BR X MW-15SL X Cape Fear Stearn Electric Plant Page 1 of 3 May 1, 2017 MW-15SU X MW-16BR X MW-16S X MW-17BR MW-17SL X MW-17SU X MW-18S X MW-19S MW-20BR MW-20S MW-21 BR MW-21 SL X MW-21 SU X MW-22BR MW-22S MW-23BR MW-23D X MW-23S X MW-24D X MW-24S X MW-5BRR MW-6BR X MW-9 X MW-9BR X PZ-1 PZ-10 PZ-2 PZ-3D PZ-3S PZ-4 PZ-5 X PZ-6 PZ-7 PZ-8 Cape Fear Steam Electric Plant Page 2 of 3 May 1, 2017 Minimum Parameters to be Analyzed Aluminum Boron Copper Mercury Selenium Thallium Alkalinity Cadmium Hexavalent Molybdenum Sodium (total) TOC (total) Chromium Total Antimony Calcium Iron Nickel Strontium Combined Uranium Arsenic Chloride Lead Potassium Sulfate TSS (total) Barium Chromium Magnesium Radium 226 Sulfide Vanadium Beryllium Cobalt Manganese Radian 228 TDS Zinc Cape Fear Steam Electric Plant Page 3 of 3 May 1, 2017 Revised James E. Rogers Energy Complex Interim Monitoring Plan — Groundwater Only Wells to be Sampled Sample for Radionuclides (X) Regional Office Notes AB-1D AB-1 S AB-2D AB-2S AB-3BR AB-3I AB-3 S X AB-3 SL X AB-4BR AB-4D AB-4S X AB-4SL X AB-5BR AB-5BRU AB-5S X AB-6BR AB-6I7 AB-6S X AS -ID AS-1 SB AS-2BR AS-2D X AS-2S X AS-3BRU AS-4D AS-4S AS-5BRU AS-5 S AS-6D AS-6S AS-7D AS-7S X BG-ID X BG-1 S X BG-2D X CCPMW-ID X CCPMW-1S X James E. Rogers Energy Complex Page 1 of 5 May 1, 2017 CLMW-1 X CLMW-2 CLMW-3D X CLMW-3S X CLMW-5D CLMW-5 S CLMW-6 CLP-1 water level only CLP-2 water level only GWA-lOD GWA-10S GWA-11BRU X GWA-11 S X GWA-12BRU GWA-12S GWA-13BR GWA-14BR GWA-14D GWA-14S GWA-1BRU GWA-20BR X GWA-20D X GWA-20S X GWA-21BR X GWA-21 BRU X GWA-21 D GWA-21 S X GWA-22D GWA-22S X GWA-23D GWA-24BR GWA-24D GWA-24S GWA-25S GWA-25D water level only GWA-26S GWA-26D water level only GWA-27BR X GWA-27D-A X GWA-28BR GWA-28BRU James E. Rogers Energy Complex Page 2 of 5 May 1, 2017 GWA-289 GWA-29D X GWA-2BR X GWA-2BRU X GWA-2S X GWA-30BR GWA-30BRU water level only GWA-30S GWA-31BR-A GWA-31D GWA-32D GWA-32BR water level only GWA-33BR GWA-33D GWA-33S GWA-34S GWA-35D GWA-35S GWA-36D X GWA-36S X GWA-37D GWA-37S GWA-38D GWA-38S GWA-39S water level only GWA-3D X GWA-40S water level only GWA-42S water level only GWA-43D GWA-43 S GWA-44BR GWA-44D GWA-44S GWA-45D GWA-45S GWA-46D GWA-47D GWA-48BR GWA-48S GWA-4D X GWA-4S X James E. Rogers Energy Complex Page 3 of 5 May 1, 2017 GWA-5BRU GWA-5 S GWA-6S GWA-61) water level only IB-3D I3-3S X MW-lOD MW-10S MW-11D MW-11 S X MW-20D MW-20DR MW-21 BR MW-21 D MW-22BR MW-22DR MW-23D MW-23DR MW-23S MW-24D X MW-24DR X MW-25DR MW-2D-A MW-30D X MW-30S X MW-32BR X MW-32D X MW-32S X MW-34S MW-54BRU MW-36BRU MW-36S MW-38BR X MW-38D X MW-38S X MW-40BRU MW-40S MW-42D MW-42S MW-8D MW-8S X James E. Rogers Energy Complex Page 4 of 5 May 1, 2017 U5-lD U5-1 S U5-2BR U5-2D X U5-2S-SL-A X U5-3D U54D U54S U5-5BR U5-5D X U5-6D U5-6S U5-8BR U5-8D U5-8S Minimum Parameters to be Analyzed Aluminum Boron Copper Mercury Selenium Thallbim Alkalinity Cadmium lent Hexavauomium Molybdenum Sodium (total) TOC (total) Cl Total Antimony Calcium Iron Nickel Strontium Combined Uranium Arsenic Chloride Lead Potassium (total) Sulfate TSS Barium Chromium Magnesium Radium 226 Sulfide Vanadium Beryllium Cobalt Manganese Radium 228 TDS Zinc James E. Rogers Energy Complex Page 5 of 5 May 1, 2017 Revised Ilan River Combined Cycle Station Interim Monitoring ]Plan — Groundwater Only Wells to be Sampled Sample for Radionuclides (X) Regional Office Notes AB-10D Measure pH, if still high, not sample. AB-10S AB-lOSL AB-15S AB-25BR AB-25D AB-25 S AB-30BR AB-30D AB-30S AB-35BR AB -SD AB-5S AS-12S AS-2D AS-8BR AS-8D BG-ID X Measure pH, if still high, not sample. BG-1 OD X BG-10S X BG-1 OBR X BG-5D BG-5S GWA-101) GWA-12D GWA-12S GWA-14D GWA-14S GWA-15D GWA-16D GWA-16S GWA-17D GWA-18D X GWA-20D GWA-20S GWA-4D GWA-4S Dan River Combined Cycle Station Page 1 of 3 May 1, 2017 GWA-513R GWA-5BRD GWA-61) x GWA-6S x GWA-71) GWA-7S GWA-8BR GWA-81) GWA-8S GWA-9D x GWA-9S x MW-10 x MW-10D x MW-11 x MW-1 ID x MW-12 x MW-12D x MW-21D MW-21S MW-22BR x MW-22D x MW-22S x MW-23BR MW-23D MW-308BR MW-310BR MW-*31 1BR MW-314BR MW-315BR MW-317BR MW-317BRL MW-318D MW-9 MW-91) OW-308D OW-310D Dan River Combined Cycle Station Page 2 of 3 May 1, 2017 Minimum Parameters to be Analyzed Aluminum Boron Copper Mercury Selenium Thallium Alkalinity Cadmium Hexavalent Molybdenum Sodium (total) TOC (total) Chromium Total Antimony Calcium Iron Nickel Strontium Combined Uranium Arsenic Chloride Lead Potassium (total) Sulfate TSS Barium Chromium Magnesium Radium 226 Sulfide Vanadium Beryllium Cobalt Manganese Radium 228 TDS Zinc Dan River Combined Cycle Station Page 3 of 3 May 1, 2017 Revised. H. F. Fee Energy Complex Interim Monitoring Plan — Groundwater Only Wells to be Sampled Sample for Radionuclides (X) Regional Office Notes ABMW-1 ABMW-1 S X AMW-11 BC AMW-11 S X AMW-12BC AMW-12S AMW-13BC AMW-13S AMW-14BC AMW-14S AMW-15BC AMW-15S AMW-16BC AMW-17BC AMW-17S AMW-18S X AMW-6RBC AMW-9BC BGMW-10 BGMW-9 BW-1 CCR-100S X CMW-10 CMW-5 CMW-6R CMW-7 CMW-8 CTMW-1 CW-1 CW-2 CW-3 CW-4 DMW-1 DMW-2 DMW-3 IABMW-1 IABMW-1 S X H. F. Lee Energy Complex Page 1 of 2 May 1, 2017 IABMW-2S IABMW-3 IABMW-3S X IMW-04BC IMW-05BC IMW-lBC IMW-1 S X IMW-2BC IMW-3BC IMW-3S X IMW-4S X IMW-5S X LLMW-1 LLMW-1 S LLMW-2 LLMW-2S MW-1 MW-2 MW-3 X SMW-3 SMW-4 SMW-5 Minimum Parameters to be Analyzed Aluminum Boron Copper Mercury Selenium Thallium Alkalinity Cadmium xavalent Molybdenum Sodium (total) TOC (total) Chromium Total Antimony Calcium Iron Nickel Strontium Combined Uranium Arsenic Chloride Lead potassium Sulfate TSS (total) Barium Chromium Magnesium Radium 226 Sulfide Vanadium Beryllium Cobalt Manganese Radium 228 TDS Zinc H. F. Lee Energy Complex Page 2 of 2 May 1, 2017 Revised Marshall Steam Station Interim MonitorinI4 Plan — Groundwater Only Sample for Wells to be Sampled Radionuclides Regional Office Notes M Recently installed and should be added to IGWMP — Based on review of analytical AB-IOBR (submitted 2/13/2017), water quality at this location is acceptable and location appears to vertically delineated (pending background for Fe, Mn, Cr6+) AB-10D AB_10S AB-10SL -1 1D AB-1 I S Recently installed and should be added to IGWMP — Based on review of analytical (submitted 2/13/2017), water quality is AB-12BR x acceptable and location appears to be vertically delineated. Radionuclide sample added by MRO. AB-12D x Radionuclide sample added by MRO. AB_12S x Radionuclide sample added by MRO. AB-12SL x Radionuclide sample added by MRO. AB-13D AB-13S AB_14D AB_14S AB-15BR AB-15D AB-15S AB-15SL AB-16D AB_16S AB_17D AB_17S AB_18D AB_18S Based on review of analytical (submitted 2/13/17), exceedance of standard for Boron was AB-IBR x observed (historically has not been above standard, but concentrations have been trending upward since installation). Further evaluation of this exceedances is warranted. Reconunend re - Marshall Steam Station Page 1 of 6 May 1, 2017 evaluating after next round of sampling and if Boron continues to exceed standard at this location a lower bedrock well will be warranted for vertical delineation. AB-1D X AB-1 S X AB-20D Recommend additional development due to elevated pH. Will reevaluate next round of sampling. AB-20S AB-21 D AB-21 S AB-2D X AB-2S X AB-3D AB-3 S AB-4D AB-4S AB-4SL AB-5BR X AB-5D X AB-5 S X AB-6BR Based on review of analytical (submitted 2/13/2017), AB-6BR has water quality issues (i.e., grout contamination) and exceedance of Barium was observed. This well should be reinstalled to more accurately represent groundwater quality at this location. AB-6D AB-6S AB-7D AB-7S AB-8D AB-8S AB-9BR AB-9D AB-9S AL-1BR X Recently installed and should be added to IGWMP — Based on review of analytical (submitted 2/13/2017), water quality is acceptable and this location appears to be vertically delineated. Radionuclide sample added by MRO. .AL-1 D X Marshall Steam Station Page 2 of 6 May 1, 2017 AL-1 S X AL-2BR Recently installed and should be added to IGWMP — Based on review of analytical AL-2BRL (submitted 2/13/2017), water quality is acceptable and this location appears to be vertically delineated. AL-2D AL-2S Recently installed and should be added to IGWMP — Based on review of analytical AL-3BR (submitted 2/13/2017), Boron exceedance was observed thus warranting vertical delineation at this location. AL-3D AL-3 S Recently installed and should be added to IGWMP — Based on review of analytical AL-4BR (submitted 2/13/2017), Boron exceedance was observed thus warranting vertical delineation at this location. AL-4D Slated for reinstallation, but does not appear to have been replaced based on review of analytical BG-1BR X (submitted on 2/13/2017). Radionuclide sample added by MRO. BG-ID X Radionuclide sample added by MRO. BG-1 S X Radionuclide sample added by MRO. BG-2BR X Radionuclide sample added by MRO. Recommend redevelopment due to elevated BG-2S X turbidity. Radionuclide sample added by MRO. BG-3BR X Radionuclide sample added by MRO. Observed exceedance of Barium, based on location of this background well it is Highly unlikely this is attributable to ash handling at the BG-31) X site. Further evaluation of exceedance is warranted. Radionuclide sample added by MRO. Observed exceedances of Barium and Cr(tot), based on location of this background well it is BG-3S X highly unlikely this is attributable to ash handling at the site. Further evaluation of these exceedances is warranted. Marshall Steam Station Page 3 of 6 May 1, 2017 Recommend redevelopment due to elevated turbidity. Radionuclide sample added by MRO. GWA-1BR X Recommend redevelopment due to elevated turbidity. GWA-lD X GWA-1 S X Slated for reinstallation, but does not appear to GWA-21) have been replaced based on review of analytical (submitted on 2/13/2017). GWA-2S GWA-3D GWA-3S GWA-4D GWA-4S GWA-5D GWA-5S GWA-6D X GWA-6S X GWA-7D GWA-7S GWA-8D GWA-8S GWA-9BR GWA-10D GWA-10S GWA-11BR X No analytical available, well was not installed prior to sampling event. Based on review of analytical (submitted 2/13/2017), Boron exceedance was observed thus GWA-11D X warranting a bedrock well for vertical delineation at this location. A bedrock well was previously recommended for installation and was installed after this sampling event. Based on review of analytical (submitted 2/13/2017), Boron, Selenium and sulfate exceedances were observed thus warranting horizontal delineation toward the east near the GWA-11 S X cove. A shallow well was previously recommended to be installed downgradient of GWA-11 S/D near the cove for purposes of horizontal delineation. This location will be difficult to access due to very soft ground due to the proximity of the lake. A shallow well should Marshall Steam Station Page 4 of 6 May 1, 2017 be installed for evaluation and determination if additional assessment is necessary. GWA-12BR X GWA-12D X In previous sampling events water quality issues were not observed, however, during this sampling event water quality issues have been observed. Further evaluation of this is warranted during next round sampling for determination of path forward. GWA-12S X GWA-13DA Based on review of analytical (submitted 2/13/2017), water quality remains an issue at this location. It was recently redrilled and has been sampled twice (pH>9). Recommend redevelopment and reevaluation during next sampling event to determine path forward. GWA-13S GWA-14D No analytical available, well was not installed prior to sampling event. GWA-14S No analytical available, well was not installed prior to sampling event. GWA-15S X No analytical available, well was not installed prior to sampling event. MS-8 MS-10 X MS-1 I MS-13 Mw- 1 MW-IOD X MW-10S X MW-I ID MW-1 I S MW-12D MW-12S MW-13D MW-13S MW-14BR X MW-14D X MW-14S X MW-2 MW-3 MW-4 X MW-4D X MW-5 MW-6D X Marshall Steam Station Page 5 of 6 May 1, 2017 MW-6S X MW-7 Water level only MW-7S X MW-7D X MW-7S X MW-BD X MW-8S X MW-9D X MW-9S X OB-1 (Dry Ash Basin) OB-1 (Dry Ash Landfill) Water level only Minimum Parameters to be Analyzed Aluminum Boron . Copper Mercury Selenium Thallium Alkalinity Cadmium Hexavalent Molybdenum Sodium (total) TOC (total) Chromium Total Antimony Calcium Iron Nickel Strontium Combined Uranium Arsenic Chloride Lead Potassium Sulfate TSS (total) Barium Chromium Magnesium Radium 226 Sulfide Vanadium Beryllium Cobalt Manganese Radium 228 TDS Zinc Marshall Steam Station Page 6 of 6 May 1, 2017 Revised Mayo Steam Electric Plant Interim Monitoring Plan — Groundwater Only Wells to be Sampled Sample for Radionuclides (X) Regional Office Notes ABMW-1 X ABMW-2 ABMW-2BR ABMW-2BRL ABMW-3 ABMW-3S ABMW-4 X ABMW-4BR ABMW-4D BG-1 X BG-2 X CW-1 CW-1D CW-2 X CW-2D X CW-3 CW-4 CW-5 CW-6 X MW-10BR X MW-11BR MW-12D X MW-12S X MW-13BR MW-14BR MW-15BR water level only MW-16BR X MW-16D X MW-16S MW-2 MW-3 X MW-3BR MW-4 MW-5BR MW-8BR MW-9BR water level only MW-9BRL Mayo Steam Electric Plant Page 1 of 2 May 1, 2017 Minimum Parameters to be Analyzed Aluminum Boron Copper Mercury Selenium Thallium Alkalinity Cadmium Hexavalent Molybdenum Sodium (total) TOC (total) Chromium Total Antimony Calcium Iron Nickel Strontium Combined Uranium Arsenic Chloride Lead Potassium Sulfate TSS (total) Barium Chromium Magnesium Radium 226 Sulfide Vanadium Beryllium Cobalt Manganese Radium 228 TDS Zinc Mayo Steam Electric Plant Page 2 of 2 May 1, 2017 Revised Riverbend Steam Station Interim Monitoring Plan — Groundwater Only Wells to be Sampled Sample for Radionuclides (X) Regional Office Notes AB-1D Measure pH, if still >I 0, not sample. AB-1 S AB-21) AB-2S AB-3BR AB-31) AB-3S AB-41) AB-4S AB-51) AB-5S AB-5SL AB-613RU AB-6S AB-71) AB-71 AB-7S AB-81) AB-8S AS-11) AS-1S AS-2D AS-2S AS-3D AS-3S AS-3SA BG-ID Measure pH, if still >10, not sample. BG-1S BG-2BR BG-21) BG-2S BG-3D BG-3S BG-4BR x BG-4D x BG-4S x BG-5BR Riverbend Steam Station Page 1 of 4 May 1, 2017 BG-5D C-113RU Measure pH, if still >10, not sample. C-1 S C-2D C-2S GWA-10BRU Measure pH, if still >10, not sample. GWA-10D GWA-10S GWA-11D GWA-11 S GWA-12D X GWA-12S X GWA-14D GWA-14S GWA-15D GWA-15S X GWA-1BRU GWA-lD GWA-1 S GWA-20BR Measure pH, if still >10, not sample. GWA-20D Measure pH, if still >10, not sample. GWA-20S GWA-21BR GWA-21D GWA-21 S GWA-22BR GWA-22BR-A X GWA-22D X GWA-22S X GWA-23BR Measure pH, if still >10, not sample. GWA-23D Measure pH, if still >10, not sample. GWA-23S GWA-2BR X GWA-213RU X Measure pH, if still >10, not sample. GWA-2S X GWA-3BR GWA-3D GWA-3S-A GWA-4BR Measure pH, if still >10, not sample. GWA-4D X GWA-4S X Riverbend Steam Station Page 2 of 4 May 1, 2017 GWA-5D GWA-5S GWA-6D X Measure pH, if still >10, not sample. GWA-6S X GWA-7BR GWA-7D GWA-7S GWA-8D X . GWA-8S X GWA-9BR X GWA-9D X GWA-9S X MW-10 X MW-11DR MW-11 SR MW-12 MW-13 MW-14 X MW-15 MW-15BR MW-15D Measure pH, if still >10, not sample. MW-ID MW-1 S MW-2D MW-2S MW-2S-A MW-3D MW-3S MW-4D MW-4S MW-5D MW-5S MW-6D MW-6S MW-7BR X Measure pH, if still >10, not sample. MW-7D X MW-7SR X MW-8D MW-8I MW-8S MW-9 X Riverbend Steam Station Page 3 of 4 May 1, 2017 MW-9BR X Measure pH, if still >10, not sample. MW-9D X Measure pH, if still >10, not sample. Minimum Parameters to be Analyzed Aluminum Boron Copper Mercury Selenium Thallium Alkalinity Cadmium Hexavalent Molybdenum Sodium (total) TOC (total) Chromium Total Antimony Calcium Iron Nickel Strontium Combined Uranium Arsenic Chloride Lead Potassium Sulfate TSS (total) Barium Chromium Magnesium Radium 226 Sulfide Vanadium Beryllium Cobalt Manganese Radium 228 TDS Zinc Riverbend Steam Station Page 4 of 4 May 1, 2017 Revised Roxboro Steam Electric Plant Interim Monitoring Plan — Groundwater Only Wells to be Sampled Sample for Radionuclides (X) Regional Office Notes ABMW-1 X ABMW-lBR X ABMW-2 X ABMW-2BR X ABMW-3 ABMW-3BR ABMW-3BRL ABMW-4 X ABMW-4BR X ABMW-5 X ABMW-5D X ABMW-6 ABMW-6BR ABMW-7 ABMW-7BR ABMW-7BRL BG-I X BG-lBR X BG-IBRL X CW-1 CW-2 X CW-21) X CW-3 CW-31) CW-4 CW-5 X GMW-10 GMW- I I GMW-6 X GMW-7 GMW-8 GMW-9 MW-IBR MW-2BR MW-3BR X MW-4BR MW-4BRL water level only Roxboro Steam Electric Plant Page 1 of 2 May 1, 2017 MW-5BR X MW-5D X MW-6BR X MW-6D X MW-7BR MW-8BR MW-9BR X MW-10BR X MW-11BR X MW-12BR MW-13BR X MW-14BR X MW-15BR X MW-15D X MW-16BR X MW-17BR X MW-18BR X MW-18D X MW-19BRL X MW-2 X MW-20BRL MW-21 BRL water level only MW-22BR MW-22D MW-23BR X MW-24BR MW-25BR MW-26BR Minimum Parameters to be Analyzed Aluminum Boron Copper Mercury Selenium Thallium Alkalinity Cadmium Hexavalent Molybdenum Sodium (total) TOC (total) Chromium Total Antimony Calcium Iron Nickel Strontium Combined Uranium Arsenic Chloride Lead PotassiumSulfate TSS (total) Barium Chromium Magnesium Radium 226 Sulfide Vanadium Beryllium Cobalt . Manganese Radium 228 TDS Zinc Roxboro Steam Electric Plant Page 2 of 2 May 1, 2017 Revised L. V. Sutton Enemy Complex Interim Monitoring Plan — Groundwater Only Wells to be Sample for Radionuclides (X) Regional Office NotesSampled AW-1C AW-2C AW-2D AW-3C X AW-4C X AW-5C AW-5D AW-6D AW-6E AW-7D AW-8C AW-9C AW-9D MW-05C X MW-05CD X MW-05D X MW-05E MW-12 MW-16D MW-20 MW-20D MW-23D X MW-23E X MW-27C X MW-31C X MW-36C X MW-37B X MW-37C X MW-37CD X MW-37D X MW-37E X MW-38B MW-38C X MW-38D X MW-39B MW-39C X MW-39D X MW-40B L. V. Sutton Energy Complex Page 1 of 2 May 1, 2017 MW-40C X MW-40D X MW-41E MW-6C MW-8 X SMW-IC SMW-2C SMW-3C SMW-4C SMW-5C SMW-6C SMW-6D Minimum Parameters to be Analyzed Aluminum Boron Copper Mercury Selenium Thallium Alkalinity Cadmium Hexavalent Molybdenum Sodium (total) TOC (total) Chromium Total Antimony Calcium Iron Nickel Strontium Combined Uranium Arsenic Chloride Lead Potassium Sulfate TSS (total) Barium Chromium Magnesium Radium 226 Sulfide Vanadium Beryllium Cobalt Manganese Radium 228 TDS Zinc L. V. Sutton Energy Complex Page 2 of 2 May 1, 2017 Revised W. H. Weatherspoon Bower Plant Interim Monitoring Plan — Groundwater Only Wells to be Sample for Radionuclides (X) Regional Office NotesSampled ABMW-01 AW-01 D AW-01I AW-01 S AW-02D AW-02S AW-03D AW-03I AW-03S BW-01 BW-02D BW-02I BW-02S X BW-03D X BW-03I X BW-03S X CCR-101-BG CAMA X CW-01 CW-02 CW-03 X MW-01 X MW-02 X MW-03 X MW-04 X MW-05 X MW-06 X MW-07 X MW-08D X MW-08I X MW-08S (OW-8) X MW-33D MW-33I MW-33S MW-41D MW-41I MW-44D MW-44I X W. H. Weatherspoon Power Plant Page 1 of 2 May 1, 2017 MW-44S MW-44SA X MW-49D MW-49I X MW-52 X MW-53D MW-53I MW-54D MW-55D X MW-55I X PW-1 (DEP 2) PZ-01 PZ-02 PZ-03 Minimum Parameters to be Analyzed Aluminum Boron Copper Mercury Selenium Thallium Alkalinity Cadmium Hexavalent Molybdenum Sodium (total) TOC (total) Chromium Total Antimony Calcium Iron Nickel Strontium Combined Uranium Arsenic Chloride Lead Potassium Sulfate TSS (total) Barium Chromium Magnesium Radium 226 Sulfide Vanadium Beryllium Cobalt Manganese Radium 228 TDS Zinc W. H. Weatherspoon Power Plant Page 2 of 2 May 1, 2017