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HomeMy WebLinkAboutWV0400057_Requestion for Well Variance_20220516May 9, 2022 Mr. Jim Gonsiewski North Carolina Department of Environmental Quality Division of Water Quality, Aquifer Protection Section 450 Hanes Mill Road, Suite 300 Winston-Salem, North Carolina 27105 Sent via email jim.gonsiewski@ncdenr.gov Subject: Application for Permit to Construct Recovery (Extraction) Wells Duke Energy Carolinas, LLC Belews Creek Steam Station Belews Creek, NC 27009 Dear Mr. Gonsiewski: Duke Energy Carolinas, LLC (Duke Energy), is submitting the enclosed application package to obtain a permit to install 49 recovery (extraction, EX) wells as part of the full-scale groundwater remediation system at the Belews Creek Steam Station (Site), located in Belews Creek, North Carolina (Figure 1). As part of a pilot study, twenty-three groundwater extractions wells were installed under well permit WV0400056 in the Fall of 2020. As detailed in the Corrective Action Plan (CAP) Update Report (SynTerra, 2019) and the Demonstration of 02L Compliance for the Belews Creek Ash Basin technical memorandum (Tech Memo) (SynTerra, 2020), Duke Energy is implementing a multi -component CAP, including source control through excavation of the Ash Basin and capping of existing on -site landfills, groundwater corrective action, and an effectiveness monitoring plan to track progress during and after groundwater corrective action. The groundwater CAP includes provisions for a robust groundwater remediation program that consists of using groundwater extraction wells combined with clean water infiltration wells and associated treatment to address constituents of interest (COI) concentrations in groundwater greater than applicable standards at or beyond the Geographic Limitation of the Ash Basin. As discussed in the CAP Update (SynTerra 2019), groundwater in the area of the Site occurs in three interconnected hydrostratigraphic zones: • The shallow flow zone in soils and saprolite (saprolite zone), • The transition flow zone (referred to as "deep" in some previous reports); and • The bedrock flow zone. Groundwater flow and transport modeling suggest site -related COI are present from the saprolite into the bedrock flow zone. Based on the distribution of COI and the vertical hydraulic connection through the saprolite, transition, and bedrock zones, Duke Energy is proposing to install 49 extraction wells with well screen and/or sand pack across all three zones (Table 1). Figures 2 and 3 illustrate the approximate Mr. Jim Gonsiewski May 9, 2022 locations of the proposed extraction wells. Final locations will be determined in the field during construction and surveyed by a licensed surveyor. Given the interconnectivity of the hydrostratigraphic zones and consistent with the pilot study well construction (permit WV0400056), Duke Energy is requesting a variance from 15A NCAC 02C .0108 North Carolina Well Construction Standards in accordance with 15A NCAC 02C .0105 based on the following: • Construction of extraction wells with screens across the three water -bearing units will allow for more effective remediation of groundwater. • Site -related COI are present in groundwater in all three zones. • Corrective action to address these COI in groundwater is also proposed in all three zones. • Extraction of groundwater provides the necessary hydraulic connection between the COI - affected groundwater zones and the proposed clean water infiltration, which targets the saprolite and transition zones. • The proposed well construction is not expected to generate a potential risk to human health or groundwater. • Due to expected low well yield in some areas (less than two gallons per minute), constructing recovery wells to extract water from a specific water -bearing unit would not provide sufficient well yield to effectively remediate groundwater at the site. • Water supply wells are not located within 500 feet of the proposed extraction wells. The Application for Permit to Construct a Recovery Well System is attached, as well as additional supporting information provided for your review and approval. We appreciate the NCDEQ's timely review of this submittal package as we proactively implement the groundwater remediation strategy for this Site. Please contact Mr. Scott Davies (980.373.6563) with any questions or concerns regarding this application. Sincerely, (5'con t-Z2a (,,, Scott E. Davies, P.G. Project Director Copies: Bob Wyrick, PG, AECOM Enclosures: Attachments North Carolina Department of Environmental Quality (DEQ) — Division of Water Resources (DWR) VARIANCE APPLICATION FOR WELL CONSTRUCTION STANDARDS: WATER SUPPLY WELLS UNDER 15A NCAC 02C .0107 All water supply wells not considered "Private Drinking Water Wells'' and including irrigation, industrial, and commercial wells. WELLS OTHER THAN WATER SUPPLY UNDER 15A NCAC 02C .0108 Including monitoring and recovery wells. PRIVATE DRINKING WATER WELLS UNDER 15A NCAC 02C .0300 Print clearly or type information. Illegible submittals will be returned as incomplete. DATE: 05/09 , 2022 Existing permit number (if applicable) N/A Issued Date: N/A Exp. Date: N/A Permit No. for new projects (to be completed by DWR/DPH) A. WELL OWNER(S) — For single family residences, list all persons appearing on property deed. For all others, list name of the business/government agency and person and title with delegated signature authority: Duke Energy Carolinas, LLC; Mr. Scott Davies Project Director Mailing Address: 526 South Church St Mail Code EC12J City: Charlotte State: NC Zip Code: 28202 County: Mecklenburg Day Tele No.: 980-373-6563 Ce11 No.: 704-661-6823 EMAIL Address: scott.davies@a,duke-energy.com Fax No.: B. PHYSICAL LOCATION OF WELL SITE (1) Parcel Identification Number (PIN) of well site: 6982642715, 6982185694 County: Stokes (2) Physical Address (if different than mailing address): Belews Creek Steam Station 3195 Pine Hall Road City: Walnut Cove C. WELL DRILLER INFORMATION (if known) Well Drilling Contractor's Name: Brian Thomas NC Well Drilling Contractor Certification No.: 2581-A Company Name: City: Statesville County: Stokes Zip Code: 27009 Geologic Exploration, Inc. Contact Person: Steve Taylor State: NC Zip Code:28625 County: Iredell Day Tele No.: 704-872-7686 Cell No.: 704-902-4211 EMAIL Address: staylor(@,gexnc.com Fax No.: GW-22V Variance Request Form Rev. 7-13-2020 Page 1 D. REASON FOR VARIANCE REQUEST — Include type of well(s) to be constructed; rule for which the variance is being requested; description of how the alternate construction will not endanger human health and welfare and the environment; and reason why construction and/or operation in accordance with the standards is not technically feasible and/or provides equal or better protection of the groundwater (refences to attached documents are acceptable). Groundwater flow and transport modeling suggest site -related constituents of interest (COIs) are present from the saprolite into the bedrock flow zone. Based on the distribution of COIs and the vertical hydraulic connection through the saprolite, transition, and bedrock zones, Duke Energy is proposing to install 49 extraction wells with well screen and/or sand pack across all three zones (Table 1). Corrective action to address these COIs in groundwater is also proposed in all three zones. Extraction of groundwater provides the necessary hydraulic connection between the COI - affected groundwater zones and the proposed clean water infiltration, which targets the saprolite and transition zones. This same approach was previously approved by the NCDEO for the recovery wells installed as part of the pilot test in 2020. The proposed well construction is not expected to generate a potential risk to human health or groundwater. Due to expected low well yield (less than two gallons per minute), constructing recovery wells to extract water from a specific water -bearing unit would not provide sufficient well yield to effectively remediate groundwater at the site. E. ATTACHMENTS — Provide the following information as attachments to this application: (1) A map showing general location of the property (including road names, NC State Route Number, distances, any key landmarks, etc.) sufficient for finding the well location. (2) Detailed site map with scale showing location of proposed well relevant to septic system(s), building foundations, property lines, water bodies, potential sources of contamination, other wells, etc. (3) Submit a copy of the local well permit application and site evaluation map (if applicable). (4) Any other information relevant to the variance request such as a well construction diagram showing proposed well liner or atypical construction materials/methods. F. SIGNATURE(S) 5C-et& Z7a Signature(s) of Well/Property Owner(s) Scott Davies, Project Director, Duke Energy Print or Type Well/Property Owner(s) Signature of Person Responsible for Well Construction (Typically, the well driller) Steve Taylor Print or Type Name of Person Responsible for Well Construction (Typically, the well driller) Signature of County Environmental Health Specialist (for Private Water Wells) Print or Type Full Name and Title of County Environmental Health Specialist (for Private Water Wells) Per 15A NCAC 02C .0118 the Secretary of the Division of Water Resources or the Division of Public Health may require submittal of information deemed necessary to make a decision on the variance, may impose conditions as part of the decision, and shall respond in writing to the request within 30 days of receipt of the variance request. A variance applicant who is dissatisfied with the decision of the Director may commence a contested case by filing a petition as described in G.S. 150B-23 within 60 days after receipt of the decision. GW-22V Variance Request Form Rev. 7-13-2020 Page 2 rjc 'II • `ASH BASIN GEOGRAPHIC LIMITATION . J\�r .S PINE HALL Z._ j '`� /r ``• y f ROAD LANDFILL L_A,. .),4 • ,�`I (CLOSED)Y STRUCTURAL FILL NOTES: 1. 2018 USGS TOPOGRAPHIC MAP, BELEWS LAKE QUADRANGLE, OBTAINED FROM THE USGS STORE AT https://store.usgs.gov/map-locator. 2. THE LOCATIONS OF ALL BOUNDARIES, REMEDtATION AND MONITORING WELLS, AND WETLANDS WERE PROVIDED BY SYNTERRA CORPORATION AND ORIGINALLY DOCUMENTED IN THE CORRECTIVE ACTION PLANUPDATE (DECEMBER 2019)AND THE DEMONSTRATION OF 02L COMPLIANCE FOR THE BELEWS CREEK ASH BASIN BY DECEMBER 31, 2019 TECHNICAL MEMORANDUM (MARCH 2020)AND SHOULD BE CONSIDERED APPROXIMATE. l> NERGY. CAROLINAS STOKES COUNTY KINSTON:ALEM C.. (CLOSED) BELEWS LAKE 1 BELEWS CREEK STEAM STATION \ "9.c\ FGD LANDFILL -.1.7„, /1( • FIGURE 1: SITE LOCATION MAP BELEWS CREEK STEAM STATION PILOT TEST WORK PLAN BELEWS CREEK, NORTH CAROLINA DRAWN BY: G. Palmer REVISED BPATE: CHECKED BY: APPROVED BY: PROJECT MANAGER: DATE: 03f302022 DATE: DATE: GRAPHIC SCALE 1,000 0 1,000 2,000 (IN FEET) 2 ! & § 0 | F, |) ,. s WC/MX3220,3..4N derv!1011M.A111351.:18011',On L0,1 26_. v.inrotS IA411 120,J. avry F.1140011131,9•.1.011.WA IDJ SEZSf 505,910,3133N, Y:3`38,, ,,, 1003tl31, 01 IYf'.Dae>ev0 tM x:daep :W.rv1;.aLeMven Wh+d (CO0 kSO103tl}3nO03Y 3N1g3�:L 11330nth5M33m0 >�'evall CI1tUOi GWd nel lil'tO UQZ101139df1YJ A� canes lsal a N i. x zt E r o,vR<S8R9S88R2882R88$8S8Si8vv 140 140 140 150 140 140 140 140 140 140 r c ino0 `cur u m L F Length (1t) Length (ft) 0 10 1'' 10 10 10 10 ®' 10 20 10 20 10 20 10 20 10 20 10 20 10 20 10 20 10 20 10 20 10 20 10 20 10 20 10 20 I 10 20 10 20 10 20 10 �� 20 10 20 10 20 10 20 10 20 10 20 10 20 10 20 10 20 10 20 10 20 10 20 10 g H E Stu u� d 0 f0 o m 2 cyt E n ❑ 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 t0 0 0 0 0 0 0 ❑ E. c d o _ Ri�4RiR8RRRS.c4irRR8RRRRRmrRiRiRiaiRiR888raiR8213,92RR.r4:�i�iRi�`iSiRRRRRR FJ d O L_ N _ Q L OF m 180 170 180 180 180 180 170 180 p p F F p F W W F F F b 180 180 G i00 $$ C 0 0 0 _ 170 180 180 180 O O 170 170 n F F F F F F F O CC F n GG CC n n N 0 E 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N S.S$9:,FFFFs535S53953FFFFFFFFFFFFF FFFFFFFFFgd. .7"" d C o� Tr.: N W « O V NY pppGC��OO O V V NOYY GGGG OY Y Y 40 40 OOOOaaOOaa CO C OO V V t0YNC0i nsq S89 $4RI K3RR NNNN NN mqn u ao Fo1^ "Egz R8R8882RR E E s W U 08 05 RRRRSi4$999@RRRRRS882 RRRRRRRRRRRRRRRRR ammmaxxxcemmaatemmmmamcewmcgtxcgmrnmmceqg(g1 W t G 21 11 I� I t�N a $%%f f N $$ %%%44 I� I� 1 2%2a21 1 1� I�N(�I�I�N rara S O ❑ xx E W xn XXXx.9x..xx W W W W W W T�XRX/4X W XXXX W W XX W W X4X XXq W W X�X7x7x� 6 W W. qXXVxj W W xx'x4x W 'X�X'x9,TXilxi4x4 W W W W W W xWx 'xx�x9x W W Ux-94x'x�x''xx¢ W W W W X3xYxgxgx W W W W XnXgxx W W X,XKKxxgXx W W 6 W W W °X? W W AECOM Client: Duke Energy Project Number: 60680712 WELL ID: See Table Site Location: Belews Creek, NC Date Installed: Proposed Well Location: Proposed Coords: Proposed Inspector: Method: Air Rotary Contractor: TBD GENERALIZED PROPOSED EXTRACTION WELL CONSTRUCTION DIAGRAM Measuring Point for Surveying & Water Levels Cement, Bentonite, Bentonite Slurry Grout, or Native Materials 5 % Cement % Bentonite % Native Materials Depth from G.S. (feet) Elevation(feet) Datum 0.0 Top of Riser Pipe Ground Surface (GS) 0.0 _Top of Cement 0.75 ft Bo ehole Diamete : Describe Measuring Point: Land Surface Riser Pipe: Length 150 ft Inside Diameter (ID) 6-in Type of Material PVC Bottom of Steel Guard Pipe Top of Bentonite Bentonite Seal Thickness Top of Sand 10ft NA 40 ft 50 ft Top of Screen 150 ft Stabilized Water Level Screen: Length 20 ft Inside Diameter (ID) 6-in Slot Size 0.01 in Type of Material PVC TypelSize of Sand Sand Pack Thickness up to 150 ft #2 Bottom of Screen Bottom of Tail Pipe: PVC Threaded Plug Bottom of Borehole 10-in Approved: Unknown 170 ft 175 ft 175 ft Signature Date