NC0004987_Appendix A_Introduction_20150908

Introduction
• NCDENR NORR Letter
• Summary of Work Plan Submittals and
NCDENR-Duke Energy
Correspondence
• Revised Groundwater Assessment
Work Plan

NCDENR NORR Letter

A 4
A=(WA
4AF1
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
August 13, 2014
CERTIFIED MAIL 7004 2510 0000 3651 1168
RETURN RECEIPT REQUESTED
Paul Newton
Duke Energy
526 South Church Street
Charlotte, NC 28202
Subject: Notice of Regulatory Requirements
Title 15A North Carolina Administrative Code (NCAC) 02L .0106
14 Coal Ash Facilities in North Carolina
Dear Mr. Newton:
Chapter 143, North Carolina General Statutes, authorizes and directs the Environmental
Management Commission of the Department of Environment and Natural Resources to protect
and preserve the water and air resources of the State. The Division of Water Resources (DWR)
has the delegated authority to enforce adopted pollution control rules.
Rule 15A NCAC 02L .0103(d) states that no person shall conduct or cause to be conducted any
activity which causes the concentration of any substance to exceed that specified in 15A NCAC
02L .0202. As of the date of this letter, exceedances of the groundwater quality standards at 15A
NCAC 02L .0200 Classifications and Water Quality Standards Applicable to the Groundwaters
of North Carolina have been reported at each of the subject coal ash facilities owned and
operated by Duke Energy (herein referred to as Duke).
Groundwater Assessment Plans
No later than September, 26 2014 Duke Energy shall submit to the Division of Water Resources
plans establishing proposed site assessment activities and schedules for the implementation,
completion, and submission of a comprehensive site assessment (CSA) report for each of the
following facilities in accordance with 15A NCAC 02L .0106(g):
Asheville Steam Electric Generating Plant
Belews Creek Steam Station
Buck Steam Station
Cape Fear Steam Electric Generating Plant
Cliffside Steam Station
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Phone: [phone] Internet: www.ncdenr.gov
An Equal Opportunity 1 Affirmative Action Employer— Made in part by recycled paper

Mr. Paul Newton
August 12, 2014
Page 2 of 3
Dan River Combined Cycle Station
H.F. Lee Steam Electric Plant
Marshall Steam Station
Mayo Steam Electric Generating Plant
Plant Allen Steam Station
Riverbend Steam Station
Roxboro Steam Electric Generating Plant
L.V. Sutton Electric Plant
Weatherspoon Steam Electric Plant
The site assessment plans shall include a description of the activities proposed to be completed
by Duke that are necessary to meet the requirements of 15A NCAC 02L .0106(g) and to provide
information concerning the following:
(1) the source and cause of contamination;
(2) any imminent hazards to public health and safety and actions taken to mitigate
them in accordance to 15A NCAC 02L .0106(f);
(3) all receptors, and significant exposure pathways;
(4) the horizontal and vertical extent of soil and groundwater contamination and all
significant factors affecting contaminant transport; and
(5) geological and hydrogeological features influencing the movement,. chemical, and
physical character of the contaminants.
For your convenience, we have attached guidelines detailing the information necessary for the
preparation of a CSA report. The DWR will review the plans and provide Duke with review
comments, either approving the plans or noting any deficiencies to be corrected, and a date by
which a corrected plan is to be submitted for further review and comment or approval. For those
facilities for which Duke has already submitted groundwater assessment plans, please update
your submittals to ensure they meet the requirements stated in this letter and referenced
attachments and submit them with the others.
Receptor Survey
No later than October 14t', 2104 as authorized pursuant to 15A NCAC 02L .0106(g), the DWR is
requesting that Duke perform a receptor survey at each of the subject facilities and submitted to
the DWR. The receptor survey is required by 15A NCAC 02L .0106(g) and shall include
identification of all receptors within a radius of 2,640 feet (one-half mile) from the established
compliance boundary identified in the respective National Pollutant Discharge Elimination
System (NPDES) permits. Receptors shall include, but shall not be limited to, public and private
water supply wells (including irrigation wells and unused or abandoned wells) and surface water
features within one-half mile of the facility compliance boundary. For those facilities for which
Duke has already submitted a receptor survey, please update your submittals to ensure they meet
the requirements stated in this letter and referenced attachments and submit them with the others.
If they do not meet these requirements, you must modify and resubmit the plans.

Mr. Paul Newton
August 12, 2014
Page 3 of 3
The results of the receptor survey shall be presented on a sufficiently scaled map. The map shall
show the coal ash facility location, the facility property boundary, the waste and compliance
boundaries, and all monitoring wells listed in the respective NPDES permits. Any identified
water supply wells shall be located on the map and shall have the well owner's name and
location address listed on a separate table that can be matched to its location on the map.
Failure to comply with the State's rules in the manner and time specified may result in the
assessment of civil penalties and/or the use of other enforcement mechanisms available to the
State.
We appreciate your attention and prompt response in this matter. If you have any questions,
please feel free to contact S. Jay Zimmerman, Water Quality Regional Operations Section Chief,
at [phone].
2hn
ierely,
E. Skvarla, III
Attachment enclosed
cc: Thomas A. Reeder, Director, Division of Water Resources
Regional Offices — WQROS
File Copy

August 12, 2014
GUIDELINES FOR COMPREHENSIVE SITE ASSESSMENT
This document provides guidelines for those involved in the investigation of
contaminated soil and/or groundwater, where the source of contamination is from:
■ Incidents caused by activities subject to permitting under G.S. 143-215.1
■ Incidents caused by activities subject to permitting under G.S. 87-88
■ Incidents arising from agricultural operations, including application of
agricultural chemicals, but not including unlawful discharges, spills or
disposal of such chemicals
Comprehensive Site Assessment (CSA)
NOTE: Regional Offices may request additional information in support of the CSA to aid
in their review and will not approve the CSA if any of the elements specified below have
not been included or have not been sufficiently addressed
Minimum Elements of the Comprehensive Site Assessment Report:
A. Title Page
• Site name, location and Groundwater Incident number (if
assigned) and Permit Number;
• Date of report;
• Responsible Party and/or permiee, including address and
phone number;
• Current property owner including address and phone
number;
• Consultant/contractor information including address and
phone number;
• Latitude and longitude of the facility; and
• Seal and signature of certifying P.E. or P.G., as appropriate.
B. Executive Summary
The Executive Summary should provide a brief overview of the pertinent
site information (i.e., provide sufficient information to acquaint the reader
with the who, what, when, where, why and how for site activities to date).
1. Source information:
Type of contaminants
2. Initial abatement/emergency response information.
1

August 12, 2014
3. Receptor information:
•
Water supply wells;
•
Public water supplies (wells, surface water intakes);
•
Surface water bodies;
•
Wellhead protection areas;
•
Deep aquifers in the Coastal Plain physiographic region;
•
Subsurface structures; and
•
Land use.
4. Sampling/investigation results:
•
Nature and extent of contamination;
•
Maximum contaminant concentrations;
•
Site hydrogeology.
5. Conclusions
and recommendations.
C. Table of Contents
• First page number for each section listed.
• List of figures (all referenced by number and placed in a
single section following contents text).
• List of tables (all referenced by number and placed in a single
section following contents text).
• List of appendices.
D. Site History and Source Characterization
• Provide a history of property ownership and use. Indicate
dates of ownership, uses of the site, and potential sources of
contaminants.
• Discuss the source(s) of contamination, including primary
and secondary sources.
• For permitted activities, describe nature of activity, permitted
waste, application of all instances of
over-application/irrigation of wastes or water
• Summarize assessment activities and corrective actions
performed to date including emergency response, initial
abatement, primary and secondary source removal.
• Discuss geographical setting and present/future surrounding
land uses.
E. Receptor Information
Provide a site map showing labeled well locations within a

August 12, 2014
minimum of 1500 feet of the known extent of contamination.
Key to the table and maps described.
NOTE: As the known extent of contamination changes, the
receptor survey must be updated to reflect the change. This
applies throughout the Receptor Information section.
• In table format, list all water supply wells, public or private,
including irrigation wells and unused wells, (omit those that
have been properly abandoned in accordance with 15A
NCAC 2C .0100) within a minimum of 1500 feet of the known
extent of contamination. Note whether well users are also
served by a municipal water supply.
• For each well, include well number, well owner and user
names, addresses and telephone numbers, use of the well,
well depth, well casing depth, well screen interval, and
distance from source of contamination;
NOTE: It will often be necessary to conduct any or all of the
following in order to ensure reliability in a water supply well
survey.
o Call the city/county water department to inquire about
city water connections,
o Visit door-to-door (make sure that you introduce
yourself and state your purpose to residents prior to
examining their property) to obtain accurate
description of water usage, and if some residents are
not at home, ask surrounding neighbors who are
home about the water usage at those residences.
Even if a public water line is available, some
residents still use their well water and are not
connected to the public water system; and
o Search for water meters and well houses.
• Site map showing location of subsurface structures (e.g.,
sewers, utility lines, conduits, basements, septic tanks,
drain fields, etc.) within a minimum of 1,500 feet of the known
extent of contamination;
• Table of surrounding property owner addresses;
• Discuss the availability of public water supplies within a
minimum of 1,500 feet of the source area, including the
distance and location to the nearest public water lines and
the source(s) of the public water supply;
3

August 12, 2014
• Identify all surface water bodies (e.g., ditch, pond, stream,
lake, river) within a minimum of 1,500 feet of the source of
contamination;
• Determine the location of any designated wellhead protection
areas as defined in 42 USC 300h-7(e) within a minimum of
1,500 feet of the source of contamination. Identify and
discuss the location of the water supply well(s) for which the
area was designated a wellhead protection area, and the
extent of the protected area. Include information about the
well owner, well -construction specifications (especially at
screened intervals), pumping rate and pumping schedule.
Information regarding designated wellhead. protection areas
may be obtained by contacting the Public Water Supply
Section at [phone];
• Discuss the uses and activities (involving possible human
exposure to contamination) that could occur at the site and
adjacent properties. Examples of such activities and uses
include but are not limited to use of a property for an office,
manufacturing operation, residence, store, school, gardening
or farming activities, recreational activities, or undeveloped
land;
• Determine whether the contaminated area is located in an
area where there is recharge to an unconfined or
semi -confined deeper aquifer that is being used or may be
used as a source of drinking water. Based on a review of
scientific literature on the regional hydrogeology and well
construction records and lithological logs for deeper wells in
the area, identify and describe the deep aquifers underlying
the source of contamination. Include information on the depth
of the deep aquifer in relation to the surficial saturated zone,
the lithology and hydraulic conductivity of the strata between
the surficial aquifer and the deeper aquifer, and the
difference in groundwater head between the surficial aquifer
and the deeper aquifer. Discuss the local and regional usage
of the deep aquifer and the draw down from major pumping
influences. Also, specify the distance from the source of
contamination to major discharge areas such as streams and
rivers. Cite all sources and references used for this
discussion.
NOTE: This requirement (last bullet) only pertains to
4

August 12, 2014
contamination sources in the Coastal Plain physiographic region
as designated on a map entitled "Geology of !North Carolina"
published by the Department in 1985. However,
recharge/discharge, hydraulic conductivity, lithology, head
difference, etc. is also important information at mountains
and piedmont sites.
F. Regional Geology and Hydrogeology
Provide a brief description of the regional geology and hydrogeology. Cite
all references.
G. Site Geology and Hydrogeology
• Describe the soil and geology encountered at the site. Use
the information obtained during assessment activities (e.g.,
lithological descriptions made during drilling, probe surveys,
etc.). This information should correspond to the geologic
cross sections required in N. below; and
• Based on the results of the groundwater investigation,
describe the site hydrogeology, including a discussion of
groundwater flow direction, hydraulic gradient, hydraulic
conductivity and groundwater velocity. Discuss the effects of
the geologic and hydrogeological characteristics on the
migration, retardation, and attenuation of contaminants.
H . Soil Sampling Results
Using figures and tables to the extent possible, describe all soil sampling
performed to date and provide the rationale for sample locations, number
of samples collected, etc. Include the following information:
• Location of soil samples;
• Date of sampling;
• Type of soil samples (from excavation, borehole, Geoprobe,
etc.);
• Soil sample collection procedures (split spoon, grab, hand
auger, etc.)
• Depth of soil samples below land surface;
• Soil sample identification
• Soil sample analyses;
• Soil sample analytical results (list any contaminant detected
above the method detection limit); and
5

August 12, 2014
• Identify any sample analytical results that exceed the
applicable cleanup levels.
NOTE: Information related to H. above should correspond to the
sampling location and sampling results maps required in N. below.
I . Groundwater Sampling Results
Using figures and tables to the extent possible describe the groundwater
sampling performed to date and provide the rationale for sample locations
(based on source and contaminant type), number of samples collected,
etc. Include the following information:
• Location of groundwater samples and monitoring wells;
• Date of sampling;
• Groundwater sample collection procedures (bailer, pump,
etc.);
• Groundwater sample identification and whether samples
were collected during initial abatement, CSA, etc.;
• Groundwater sample analyses;
• Groundwater sample analytical results (list any contaminant
detected above the method detection limit; and
• Identify all sample analytical results that exceed 15A NCAC
2L or interim standards.
NOTE: Information related to 1. above should correspond to the
sampling location and sampling results maps required in N. below.
J. Hydrogeological Investigation
Describe the hydrogeological investigation performed including all
methods, procedures and calculations used to characterize site
hydrogeological conditions. The following information should be discussed
and should correspond to the maps and figures required below:
• Groundwater flow direction;
• Hydraulic gradient (horizontal and vertical);
• Hydraulic conductivity;
• Groundwater velocity;
• Contaminant velocity;
• Slug test results; *
• Aquifer test results;
• Plume's physical and chemical characterization; and
• Fracture trace study if groundwater in bedrock is impacted.
6

August 12, 2014
* Check with the Regional Office prior to performing these tests
and study to see if necessary for the site.
K. Groundwater Modeling Results
Groundwater modeling or predictive calculations may be necessary at
some sites (source area proximate to surface water, source area located
within wellhead protection area or source area overlying semi -confined or
unconfined deeper Coastal Plain aquifer) to verify, based on site specific
hydrogeological conditions, whether groundwater contamination poses a
risk to receptors. For contamination shown to pose a risk to receptors,
groundwater modeling may be necessary to determine an appropriate
cleanup level for contaminated groundwater. Modeling should illustrate the
input data used to complete the model and will generally be required for
natural attenuation proposals (see Groundwater Modeling Policy at
http://portal. ncdenr.org/web/wq/aps/a-wr)ro/policy).
NOTE: Input data for models should be derived from site specific
information with limited assumptions or estimates. All assumptions and
estimated values including biodegradation rates must be conservative
(predict reasonable worst -case scenarios) and must be well documented.
L. Discussion
• Nature and extent of contamination, including primary and
secondary source areas, and impacted groundwater and
surface water resources;
• Maximum contaminant concentrations;
• Contaminant migration and potentially affected receptors
M. Conclusions and Recommendations
If corrective action will be necessary, provide a preliminary evaluation of
remediation alternatives appropriate for the site. Discuss the remediation
alternatives likely to be selected. Note that for impacts to groundwater
associated with permitted activities, corrective action pursuant to 15A
NCAC 2L .0106(k), (1) and (m) is not applicable, unless provided for
pursuant to 15A NCAC 2L .0106(c) and (e) or through a variance from the
Environmental Management Commission (EMC).
N. Figures
9 71/2 minute USGS topographic quadrangle map showing an area

August 12, 2014
within a minimum of a 1,500-foot radius of the source of
contamination and depicting the site location, all water supply wells,
public water supplies, surface water intakes, surface water bodies,
designated well head protection areas, and areas of recharge to
deeper aquifers in the Coastal Plain that are or may be used as a
source for drinking water;
Site map locating source areas, site boundaries, buildings, all water
supply wells within a minimum of 1,500 feet, named
roads/easements/right-of-ways, subsurface utilities, product or
chemical storage areas, basements and adjacent properties, scale
and north arrow;
At least two geologic cross sections through the saturated and
unsaturated zones intersecting at or near right angles through the
contaminated area using a reasonable vertical exaggeration.
Indicate monitoring well/sample boring/sample locations and
analytical results for soil samples. Identify the depth to the water
table. Provide a site plan showing the locations of the cross
sections;
■ Site map(s) showing the results of all soil sampling conducted.
Indicate sampling identifications, sampling depths, locations and
analytical results;
■ Site map(s) showing the results of all groundwater sampling
conducted. Indicate sampling locations, monitoring well
identifications, sample identifications, and analytical results;
Separate groundwater contaminant iso-concentration contour maps
showing total volatile organic compound concentrations, total
semi -volatile organic compound concentrations and concentrations
for the most extensive contaminant. Maps should depict the
horizontal and vertical extent. Contour line for applicable 2L
standard should be shown in bold;
■ Site map(s) showing the elevation of groundwater in the monitoring
wells and the direction of groundwater flow. Contour the
groundwater elevations. Identify and locate the datum (arbitrary
8

August 12, 2014
1000, USGS, NGVD) or benchmark. Indicate the dates that water
level measurements were made. There should be one map for each
series of water level measurements obtained;
■ Groundwater contaminant iso-concentration contour cross-section;
and
■ Site map(s) showing the monitoring wells.
NDTE: If possible, use a single base map to prepare site maps using a
map scale of 9 inch = 40 feet (or a smaller scale for large sites, if
necessary). Maps and figures should include conventional symbols,
notations, labeling, legends, scales, and north arrows and should
conform to generally accepted practices of map presentation such as
those enumerated in the US Geological Survey pamphlet, "Topographic
Maps".
O. Tables
List all water supply wells, public or private, including irrigation wells
and unused wells, (omit those that have been properly abandoned
in accordance with 15A NCAC 2C .0100) within a minimum of 1500
feet of the known extent of contamination For each well, include the
well number (may use the tax map number), well owner and user
names, addresses and telephone numbers, use of the well, well
depth, well casing depth, well screen interval and distance from the
source of contamination;
List the names and addresses of property owners and occupants
within or contiguous to the area containing contamination and all
property owners and occupants within or contiguous to the area
where the contamination is expected to migrate;
■ List the results for groundwater samples collected including sample
location; date of sampling; sample collection procedures (bailer,
pump, etc.); sample identifications; sample analyses; and sample
analytical results (list any contaminant detected above the method
detection limit in bold); and
List for each monitoring well, the monitoring well identification
9

August 12, 2014
numbers, date water levels were obtained, elevations of the water
levels, the land surface, top of the well casing, screened interval
and bottom of the well.
P Appendices
• Boring logs and lithological descriptions;
• Well construction records;
• Standard procedures used at site for sampling, field equipment
decontamination, field screening, etc.;
• Laboratory reports and chain -of -custody documents;
• Copies of any permits or certificates obtained, permit number,
permitting agency, and
• Modeling data and results;
• Slug/pumping test data; and
• Certification form for CSA
10

August 12, 2014
DIVISION OF WATER RESOURCES
Certification for the Submittal of a Comprehensive Site Assessment
Responsible Party and/or Permittee:
Contact Person:
Address:
City: State: Zip Code:
Site Name:
Address:
City: State: Zip Code:
Groundwater Incident Number (applicable):
I, , a Professional Engineer/Professional Geologist
(circle one) for (firm or
company of employment) do hereby certify that the information indicated below is
enclosed as part of the required Comprehensive Site Assessment (CSA) and that
to the best of my knowledge the data, assessments, conclusions,
recommendations and other associated materials are correct, complete and
accurate.
(Each item must be initialed by the certifying licensed professional)
1. The source of the contamination has been identified. A list of all
potential
sources of the contamination are attached.
2. Imminent hazards to public health and safety have been identified.
3. Potential receptors and significant exposure pathways have been
identified.
4. Geological and hydrogeological features influencing the movement
of groundwater have been identified. The chemical and physical character of the
contaminants have been identified.
5. The CSA sufficiently characterizes the cause, significance and
extent of groundwater and soil contamination such that a Corrective Action Plan
can be developed. If any of the above statements have been altered or items not
initialed, provide a detailed explanation. Failure to initial any item or to provide
written justification for the lack thereof will result in immediate return of the CSA to
the responsible party.
(Please Affix Seal and Signature)
11

Summary of Work Plan Submittals and NCDENR-Duke
Energy Correspondence

e��
w_
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
March 12, 2015
Mr. Harry Sideris
Senior Vice -President
Environment, Health, and Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, NC 28202
Re: Marshall Steam Station
NPDES Permit No. NC0004987 — Catawba 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 DWR's Review of Groundwater Assessment Work Plan letter dated November 4,
2014. A review of the plan has been completed and several deficiencies or items requiring
clarification were noted. Therefore, 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 initial site conceptual model (ISCM) section of the revised GAP does not provide a
clear, cohesive description of how constituents of potential concern (COPCs) may migrate
from the source(s) to the receptors through various pathways. It is acknowledged that there
is information available to develop an ISCM, but the data are not presented in a manner such
as groundwater elevation maps, geologic maps, cross -sections that depict detailed site
conditions, flow diagrams, or in a tabulated format to illustrate where data gaps may exist.
Duke Energy should incorporate all existing data at the site and be prepared to collect
additional data if the Division determines that additional data gaps exist. Continued site
conceptual model development should follow guidelines similar to those presented in the
American Standards Testing Measures E1689 - 95(2014) Standard Guide for Developing
Conceptual Site Models for Contaminated Sites to direct data collection, data interpretation,
and model development efforts.
1611 Mail Service Center, Raleigh, North Carolina 27699-1611
Phone: [phone] \ Internet: http:Owww.ncwater.org/
An Equal Opportunity 1A(firtnadve Action Employer— Made in part by recycled paper

Marshall Steam Station
March 12, 2015
Page 2 of 3
• Comment 7.1.4 Bedrock Monitoring Wells:
The Division suggests installing bedrock monitoring wells at several locations in order to
provide data for assessment of multiple flowpath transects across the site. A bedrock
monitoring well is recommended near the compliance boundary in the vicinity of well cluster
MW-14S/D based on analytical results obtained from those locations that suggest a possible
coal ash signature. Installation of a bedrock monitoring well in the vicinity of the MW-7S/D,
MW-8S/D, and MW-9S/D well clusters is recommended in order to provide a monitoring
location downgradient of the active ash basin adjacent to Lake Norman. In addition, bedrock
monitoring wells are recommended in the immediate vicinity of proposed well clusters at
AB-6S/D, AB- 15S/SL/D, and AL-2S/D so bedrock groundwater can be characterized in the
ash basins and landfill.
• Comment Section 7.2 Groundwater Sampling and Analysis:
Direction provided in the EPA Region 1 Low Stress Purging and Sampling Procedure for the
Collection of Groundwater Samples from Monitoring Wells (2010) should be followed
strictly and any deviations from the procedure must be approved by the Division and
documented accordingly. For example, samples should not be collected until pH is stabilized
within t 0.1 for three consecutive readings rather than f 0.2 written in the GAP.
Temperature and specific conductivity readings should stabilize within 3% for three
consecutive readings before samples are collected instead of 10% noted in the GAP. Also
note that if the pumping rate is so low that the flow-through-cell/chamber volume cannot be
replaced in a 5 minute interval, the time between measurements should be increased
accordingly.
Speciation of inorganics from groundwater samples should be focused on wells strategically
located along flowpath transects. Collection of data along multiple flowpaths will refine the
assessment of water geochemistry and development of flow and transport models.
The Division recommends analyzing samples for radionuclides from wells monitoring well
locations MW-14S/D because of elevated concentrations of boron, iron, manganese and
sulfate detected during previous sampling events. Other well locations recommended for
collecting and analyzing samples for radionuclides include MW-6S and MW-7S so
groundwater can be assessed for these constituents beneath the landfill and downgradient of
the active ash basin, respectively.
• Comment Table 5 — Groundwater, Surface Water, and Seep Parameters and Constituent
Analytical Methods:
Low level Vanadium listed as having a detection limit unit of mg/L. This is likely just a
typographical error but the units should be in µg/L rather than mg/L.
• Comment Section 7.3.1 Surface Water Samples, 7.3.2 Seep Samples and 7.2.2 Speciation
of Select Inorganics:
The GAP text indicates that review of the NCDENR March 2014 seep and surface water
sampling analytical data will be incorporated into assessment plans to evaluate seep and
surface water sample locations at the facility.

Marshall Steam Station
March 12, 2015
Page 3 of 3
• Comment 7.9.2 Development of Kd Terms
It is expected that additional solid phase samples will be collected and analyzed for Kd
determination as well as physical properties at strategic locations along flowpath
transects. These data will refine the assessment of water geochemistry and development
of flow and transport models.
Locations where NCDENR's March 2014 seep and surface water sampling data indicated
exceedances or elevated concentrations of iron, manganese and other constituents of
concern should be incorporated into the assessment's seep/surface water sampling plans
with speciation of analytical data sufficient to support delineation and modeling efforts.
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 statutes. Per G.S. 130A-309.209(a)
(3) and (4), you must begin implementation of the revised GAP on March 22, 2015 and the
Groundwater Assessment Report is due on September 8, 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 Bruce Parris at [phone].
Sincerely,
S. Zi erman, P.G.,
Director, Division of Water Resources
cc: WQROS — MRO
WQROS Central Files
DENR Secretary - Don van der Vaart
HDR (Attn: William Miller) 440 South Church Street, Suite 1000, Charlotte, NC 28202

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 November4, 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 collected
from along from proposed flowpath transects will be handled and preserved in order to
eliminate exposure to ambient air in the field. Kd samples should be collected in plastic bags
and sealed with a conventional vacuum plastic bag sealer. The samples will be then placed on
ice in a cooler for transport and kept out of direct sunlight. Once received by the analytical
laboratory, the Oxidation -Reduction Potential (ORP) of the sample will be measured using an
ORP probe and meter in accordance with ASTM method G200-19 (Reapproved 2014). Based on
this ORP measurement, either normal or "glove -box" processing of a sample will be applied

Attachment 1
Page 3 of 6
(EPA/600/R-06/112). An additional sample will be retained, pending confirmation of subsequent
ORP and DO testing. ORP and dissolved oxygen will be measured in the groundwater monitoring
wells subsequently installed at these sample locations. In the event that the groundwater field -
measured ORP and DO reveal reducing conditions, the additionally -retained sample will be
subject to glove box processing for the Kd analyses. 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
flowpath transects and in wells where these constituents exceed 2L groundwater standards as
well as for surface water samples collected within ash impoundments.
5. 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. These analyses for physical properties will be conducted at up
to 15 locations along proposed flowpath transects where Kd samples are collected. Solid phase
samples at up to 15 additional locations will be collected and analyzed for hydrous ferric oxide
(HFO) content. At these additional locations where HFO content is analyzed, analyses for
physical properties will not be performed. Solid phase samples will be analyzed for total organic
content from the same locations where samples are collected for Kd determination. Solid phase
samples will be analyzed for total organic carbonate content from the same locations where
samples are collected for Kd determination only at facilities located in the coastal plain.
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 pathways 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.

Attachment 1
Page 4 of 6
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.
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.
S. 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

Attachment 1
Page 5 of 6
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.i)hp/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
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

Attachment 1
Page 6 of 6
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
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(g) 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.

CSA GUIDELINE ADJUSTMENTS DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
Note to NCDENR Reviewers:
Proposed CSA Guideline Adjustments are indicated as follows:
• Proposed deletions are shown as crimson colored strike through text
• Proposed additions are shown as blue -colored text.
NCDENR Division of Water Resources Position:
Clarification of certain items in the Comprehensive Site Assessment (CSA) Guidelines submitted
on August 13, 2014 is provided by the Division of Water Resources (Division) in order to
facilitate completion of the groundwater assessments at the Duke Energy Coal Ash
Impoundments. The Division does not intend to change the CSA Guidelines, which were provided
to Duke Energy to ensure compliance with NCAC 2L standards and technical direction presented
in the Coal Act Management Act Senate Bill 729 (CAMA). If a change to the CSA Guidelines
proposed by Duke Energy leads to more clarity, the Division will consider the merit of the
proposed changes on a site -by -site basis while reviewing the CSA report document. If the
Division determines the data and related reporting are inadequate, then additional information
may be requested to complete the site assessments.
This document provides guidelines for those involved in the investigation of contaminated soil
and/or groundwater, where the source of contamination is from:
• Incidents caused by activities subject to permitting under G.S. 143-215.1.
• Incidents caused by activities subject to permitting under G.S. 87-88.
• Incidents arising from agricultural operations, including application of agricultural
chemicals, but not including unlawful discharges, spills or disposal of such
chemicals.
COMPREHENSIVE SITE ASSESSMENT (CSA)
NOTE: Regional Offices may request additional information in support of the CSA to aid in their review
and will not approve the CSA if any of the elements specified below have not been included or have not
been sufficiently addressed.
Minimum Elements of the Comprehensive Site Assessment Report:
A. Title Page
• Site name, location and Groundwater Incident number (if assigned) and Permit
Number;
• Date of report;
• Responsible Party and/or permittee, including address and phone number;
• Current property owner including address and phone number;
• Consultant/contractor information including address and phone number;
• Latitude and longitude of the facility; and
• Seal and signature of certifying P.E. or P.G., as appropriate.
Page 1 of 15

CSA GUIDELINE ADJUSTMENTS DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
B. Executive Summary
The Executive Summary should provide a brief overview of the pertinent site information (i.e.,
provide sufficient information to acquaint the reader with the who, what, when, where, why and
how for site activities to date).
1. Source Information:
• Type of contaminants
2. Initial abatement/emergency response information.
3. Receptor Information:
• Water supply wells;
• Public water supplies (wells, surface water intakes);
• Surface water bodies;
• Wellhead protection areas;
• Deep aquifers in the Coastal Plain physiographic region;
• Subsurface structures; and
• Land use.
4. Sampling/Investigation Results:
• Nature and extent of contamination;
• Maximum contaminant concentrations;
• Site Hydrogeology.
S.
Conclusions and Recommendations.
C. Table of Contents
• First page number for each section listed.
• List of figures (all referenced by number and placed in a single section following
contents text).
• List of tables (all referenced by number and placed in a single section following
contents text).
• List of appendices.
D. Site History and Source Characterization
• Provide a history of property ownership and use. Indicate dates of ownership, uses
of the site, and potential sources of contaminants.
• Discuss the source(s) of contamination, including primary and secondary sources.
• For permitted activities, describe nature of activity, permitted waste, application of
all instances of over-application/irrigation of wastes or water
• Summarize assessment activities and corrective actions performed to date including
emergency response, initial abatement, primary and secondary source removal.
Page 2 of 15

CSA GUIDELINE ADJUSTMENTS
DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
Discuss geographical setting and present/future surrounding land uses.
E. Receptor Information
Note to NCDENR Reviewers:
With respect, the language as -is versus as -proposed of Section E did not lend itself well to "internal"
editing. Respectfully again, please receive/review as presented, with the languages at least in close
proximity, to hopefully help facilitate your review. L. Armstrong
FoF each well, include well nun4beF, weil owner and useF narnes, addFesses and
telephone nuniber-s, use of the well, well depth, well casing depth, weil scFeen
interval, sta P Ee-fyA-PA seurrEeavf eeirtamination;
AO
Page 3 of 15

CSA GUIDELINE ADJUSTMENTS DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
activities,• Di-se-u-s-s the u-se-S -and -activities (involving possible human expesuFe to
C-AptAmipAtien) that eauld- eeeur _At the Site and- adjaeent pFeper-ties. Examples of
h activities and uses include but aFe not limited to use of a pFeper-ty for an office,
ve-Atien-al _Ae.ivities, or- undeveloped land;
the stFata between the sur-ficial aquifeF and the deeper- aquifeF, and the diffeFenee
gFE)undwater head thP_ SUFficial aquifer -And the deepeF aquifer. -Pi-seuss, t
influenees. Also, specify the distance from the sour-ee of contamination to major -
discharge areas sueh as stFeams and FiveFs. Cite all souFees and Fefer-ences used foT-
t h i S, ,l;
d�ffiFenee, etc-. is also important inoFmGtien Gt mountains 6ind piedment sites.
• Consistent with the DWR's August 13, 2014 Notice of Regulatory Requirement:
The CSA Report will include information obtained from the Drinking Water Well
and Receptor Survey Report submitted September 2014, the Supplement to
Drinking Water Supply Well and Receptor Survey Report submitted November
2014, and updated information obtained between these noted reports and
submittal of the CSA Report. The receptor survey is required by 15A NCAC 02L
.0106(g) and shall include identification of all receptors within a radius of 2,640
feet (one-half mile) from the established compliance boundary identified in the
respective National Pollutant Discharge Elimination System (NPDES) permits.
Receptors shall include, but shall not be limited to, public and private water
supply wells (including irrigation wells and unused or abandoned wells) and
surface water features within one-half mile of the facility compliance boundary.
The results of the receptor survey shall be presented on a sufficiently scaled
map. The map shall show the coal ash facility location, the facility property
boundary, the waste and compliance boundaries, and all monitoring wells listed
in the respective NPDES permits. Any identified water supply wells shall be
located on the map and shall have the well owner's name and location address
listed on a separate table that can be matched to its location on the map.
• Consistent with Senate Bill 729:
Page 4 of 15

CSA GUIDELINE ADJUSTMENTS DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
• The CSA Report will identify all drinking water supply wells within one-half mile
down -gradient from the established compliance boundary of the impoundment
and submit the Survey to the Department. Information including well locations,
the nature of water uses, available well construction details, and information
regarding ownership of the wells will be provided for the above noted wells.
• The CSA Report will include the Duke Energy Laboratory analytical results from
the drinking water supply wells required to be sampled by the Department.
NCDENR Division of Water Resources Position:
The Division does not intend to change the CSA Guidelines. Specific information is
expected in order to evaluate site conditions at and in the vicinity of the coal ash ponds
that are germane to significant exposure pathways and potential receptors. Several of
sub -elements proposed for deletion in Section E are related to identification and
characterization of potential environmental receptors (human and ecological) and
determination of the limits of the study area or system boundaries, which are key
elements of a conceptual model as stated in standard industry practice reference ASTM
E1689 Guide for Developing Conceptual Site Models for Contaminated Sites. The Division
will evaluate the content of Section E Receptor Information along with components of the
refined conceptual site models presented in the CSA reports with respect to receptor and
exposure pathway information to determine if the data are adequate to meet CAMA
requirements for groundwater assessment and corrective action. If the Division considers
the data provided in the CSA reports are inadequate, additional data may be requested.
Data presentation -does not have to follow a prescriptive format; however,
documentation of relevant water supply well receptor information is expected by the
Division to support evaluation of potential risk to receptors and conceptual site models.
Data requirements related to Section E Receptor Information that should be considered
include:
The Division acknowledges the difficulty with determining the known extent of
contamination at this time since potential plume assessments are not complete.
With this in mind, the Division expects all drinking water wells located 2,640-feet
downgradient from the established compliance boundary be documented in the
CSA reports as specified in the CAMA requirements. The Division may request
additional data after review of well receptor and water quality data in a CSA
report.
In general, subsurface utilities are expected to be mapped within 1500-ft of the
known extent of contamination in order to evaluate the potential for preferential
pathways. An explanation must be provided in the CSA report if the subsurface
utility mapping requirements are modified. Details concerning site conditions such
the possibility of a shallow, perched, or fluctuating water table resulting from site
operations intercepting subsurface utilities must be documented. If the utility
mapping requirements are modified, Duke Energy must be able to document that
the subsurface utilities are not potential preferential pathways for contaminant
migration in the CSA reports.
Page 5 of 15

CSA GUIDELINE ADJUSTMENTS DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
• A determination of whether the contaminated area is located in an area where
there is recharge to an unconfined or semi -confined deeper aquifer that is being
used or may be used as a source of drinking water is expected by the Division. The
groundwater assessment findings may indicate a continuous confining unit cannot
be delineated beneath across the Coastal Plain sites; therefore, potential impacts
to deeper aquifers should be evaluated.
• The Division maintains that all surface water bodies (e.g., ditch, pond, stream, lake,
river) within a minimum of 1,500 feet of the source of contamination be identified
as these features relate to identification of potential receptors and exposure
points, both key elements of a conceptual site model.
F. Regional Geology and Hydrogeology
• Provide a brief description of the regional geology and hydrogeology. Cite all
references.
G. Site Geology and Hydrogeology
• Describe the soil and geology encountered at the site. Use the information obtained
during assessment activities (e.g., lithological descriptions made during drilling,
probe surveys, etc.). This information should correspond to the geologic cross
sections required in N. below; and
• Based on the results of the groundwater investigation, describe the site
hydrogeology, including a discussion of groundwater flow direction, hydraulic
gradient, hydraulic conductivity and groundwater velocity. Discuss the effects of the
geologic and hydrogeological characteristics on the migration, retardation, and
attenuation of contaminants.
H. Soil Sampling Results
• Using figures and tables to the extent possible, describe all soil sampling performed
to date and provide the rationale for sample locations, number of samples collected,
etc. Include the following information:
• Location of soil samples;
• Date of sampling;
• Type of soil samples (from excavation, borehole, Geoprobe, etc.);
• Soil sample collection procedures (split spoon, grab, hand auger, etc.)
• Depth of soil samples below land surface;
• Soil sample identification
• Soil sample analyses;
• Soil sample analytical results (list any contaminant detected above the method
detection limit); and,
• Identify any sample analytieal Fesults that exceed the applicable eleanup levels.
Page 6 of 15

CSA GUIDELINE ADJUSTMENTS DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
• Identify any soil sample analytical results that exceed the EPA Region 9 Regional
Screening Levels.
NOTE. Information related to H. above should correspond to the sampling location and sampling
results maps required in N. below.
NCDENR Division of Water Resources Position:
The Division does not agree with the proposal to identify soil analytical results that exceed
EPA Region 9 soil screening levels. Instead, the Division is in the process of finalizing clean
closure guidelines for cleanup that will meet protection of groundwater criteria for 2L
standards, which will include soil screening levels. Details related to the partial draft
guidelines are provided below:
Clean Closure Guidelines
The Division's goal is that facilities remediate all discharges or releases of constituents to
unrestricted use levels.
• For groundwater, the unrestricted use level is the North Carolina Division of Water
Quality, 2L groundwater standard (2L) or site -specific background concentration.
• For soil, the unrestricted use level is either the site -specific background concentration
or the lowest of a soil screening level (SSL) protective of groundwater.
Determining Soil Screening Levels for Clean Closure Soil Remediation Goals
The methodology the Division recommends for calculating unrestricted use levels or soil
screening levels (SSLs) for contaminant migration to groundwater was developed in the
Preliminary Soil Remediation Goals (PSRG) document (identified below)to identify chemical
concentrations in soil with the potential to migrate and contaminate groundwater.
• SSLs protective of groundwater are calculated with a soil leachate model using default
values from 15A NCAC 21, groundwater standard or the 2L groundwater interim maximum
allowable concentration as target groundwater concentrations and take into consideration
fate and transport parameters.
• The Preliminary Soil Remediation Goals (PSRG) table contains a column with soil
remediation goals titled (Protection of Groundwater PSRG) that should be used in
evaluating soil -to -groundwater values that meet and are protective of the 15A NCAC 2L
groundwater quality standards. A link to the IHSB PSRG table can be found here:
http://portal.ncdenr.org/c/document librarylget file?uuid=Of601ffa-574d-4479-bbb4-
253af0665bf5&groupId=38361. Please note that the Division of Waste Management
updates this table during the first and third quarter of each calendar year.
• A transport model is included in the PSRG table for calculating other soil values not
specifically listed in the table in order to meet Protection of Groundwater Criteria. Rule 15A
NCAC 2L .0202 (c) does specify substances that are not permitted in groundwater and
indicates that even those which are not specifically listed in the rule are not allowed above
the practical quantitation limit (PQL), unless they are naturally occurring. The approved
laboratory method PQL for the substance can be used in the equation if there is no
specifically listed 15A NCAC 21, standard.
Page 7 of 15

CSA GUIDELINE ADJUSTMENTS DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
• Background concentrations of naturally occurring metals in soil at a site can be
established using EPA guidance for comparing background and chemical concentrations in
soil for CERCLA sites: httl2://www.epa.gov/oswer/riskassessment/12df/background.pdf
I. Groundwater Sampling Results
Using figures and tables to the extent possible describe the groundwater sampling performed to
date and provide the rationale for sample locations (based on source and contaminant type),
number of samples collected, etc. Include the following information:
• Location of groundwater samples and monitoring wells;
• Date of sampling;
• Groundwater sample collection procedures (bailer, pump, etc.);
• Groundwater sample identification and whether samples were collected during
initial abatement, CSA, etc.;
• Groundwater sample analyses;
• Groundwater sample analytical results (list any contaminant detected above the
method detection limit; and,
• Identify all sample analytical results that exceed 15A NCAC 2L or interim standards.
NOTE. Information related to L above should correspond to the sampling location and sampling
results maps required in N. below.
J. Hydrogeological Investigation
Describe the hydrogeological investigation performed including all methods, procedures and
calculations used to characterize site hydrogeological conditions. The following information should
be discussed and should correspond to the maps and figures required below:
• Groundwater flow direction;
• Hydraulic gradient (horizontal and vertical);
• Hydraulic conductivity;
• Groundwater velocity;
• Contaminant velocity;
• Slug test results*;
• Aquifer test results*;
• Plume's physical and chemical characterization; and
• Fracture trace study if groundwater in bedrock is impacted*.
NOTE. Check with the Regional Office prior to performing these tests and study to see if necessary
for the site.
Page 8 of 15

CSA GUIDELINE ADJUSTMENTS DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
NOTE: Contaminant velocity will be addressed in the Groundwater Model Report portion of the
Corrective Action Plans.
NCDENR Division of Water Resources Position:
The Division agrees with the proposed change in content. Discussion of contaminant velocity is
appropriate for inclusion in the Groundwater Modeling Report portion of the Corrective Action
Plans rather than the CSAs. This is consistent with direction provided in the NCDENR
Groundwater Assessment Plan (GAP) Conditional Letters of Approval.
K. Groundwater Modeling Results
Groundwater modeling or predictive calculations may be necessary at some sites (source area
proximate to surface water, source area located within wellhead protection area or source area
overlying semi -confined or unconfined deeper Coastal Plain aquifer) to verify, based on site specific
hydrogeological conditions, whether groundwater contamination poses a risk to receptors. For
contamination shown to pose a risk to receptors, groundwater modeling may be necessary to
determine an appropriate cleanup level for contaminated groundwater. Modeling should illustrate
the input data used to complete the model and will generally be required for natural attenuation
proposals (see Groundwater Modeling Policy at
http://portal.ncdenr.org/web/wo/apskiwpro/oolicv).
NOTE: Input data for models should be derived from site specific information with limited assumptions
or estimates. All assumptions and estimated values including biodegradation rates must be conservative
(predict reasonable worst -case scenarios) and must be well documented.
NOTE: Groundwater Modeling Results will be included in the Corrective Action Plans per NCDENR
DWR Conditional Approval of Revised Groundwater Assessment Work Plan letters.
NCDENR Division of Water Resources Position:
The Division agrees with the proposed change in content. Direction has been given by the Division to
include groundwater modeling results in the Corrective Action Plans per NCDENR Conditional Approval
of Revised GAP letters. Some discussion related to how site assessment data and the resulting refined site
conceptual model will be incorporated into the groundwater models is appropriate and should be
presented in the CSAs.
L. Discussion
• Nature and extent of contamination, including primary and secondary source areas,
and impacted groundwater and surface water resources;
• Maximum contaminant concentrations; and,
• Contaminant migration and potentially affected receptors.
M. Conclusions and Recommendations
If corrective action will be necessary, provide a preliminary evaluation of remediation alternatives
appropriate for the site. Discuss the remediation alternatives likely to be selected. Note that for
Page 9 of 15

CSA GUIDELINE ADJUSTMENTS DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
impacts to groundwater associated with permitted activities, corrective action pursuant to 15A
NCAC 2L .0106(k), (I) and (m) is not applicable, unless provided for pursuant to 15A NCAC 2L
.0106(c) and (e) or through a variance from the Environmental Management Commission (EMC).
N. Figures
Note to NCDENR Reviewers:
With respect, the language as -is versus as -proposed of Section N did not lend itself well to "internal"
editing. However, we have attempted to place language relative to certain figures (i.e., the USGS Map and
the Site Maps) at least in close proximity, to hopefully help facilitate your review. Respectfully again, we
request your receipt/review as presented.
• The CSA Report Figures will include a 71/2 minute USGS topographic quadrangle map
showing an area within a minimum of 2,640 feet (one-half mile) from the established
compliance boundary identified in the respective National Pollutant Discharge Elimination
System (NPDES) permits. This map will include depiction of the following, as applicable:
• the fossil station property boundary;
• ash basin compliance boundaries;
• 2,640 feet (one-half mile) offset of the ash basin compliance boundaries;
• water supply wells identified in the Drinking Water Well and Receptor Survey
Report submitted September 2014, the Supplement to Drinking Water Supply
Well and Receptor Survey Report submitted November 2014, and updated
information obtained between these noted reports and submittal of the CSA
Report;
• public water supplies;
• surface water intakes;
• surface water bodies;
• designated well head protection areas; and,
• areas of recharge to deeper aquifers in the Coastal Plain that are or may be used
as a source for drinking water.
within a minimum of 1,900 feet, named Feads/easements/Fight of ways, subsuFfa
utilities, pFeduet E)F chem-Jeal ster-age aFeas, basements -and adjacent • Site map leeating seuFee areas, site boundaries, buildings, all water- supply wells
leeations and analytical results for- sail samples. identify the depth to thp watiav
table. PFevide a site plan showing the locations of the eFess inteFseeting at OF near- Fight angles thFough the eopt-arnin-ated- -area usin
Page 10 of 15

CSA GUIDELINE ADJUSTMENTS DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
-------
— -------
. . . . ... .....
..
...
The CSA Report Figures (plan views), as applicable, will be based on like or similar
base maps developed from 2014 aerial photography, with associated
photogrammetric topography. Considered collectively, the CSA Report Figures will
include the following information:
• ash basins and associated compliance boundaries;
• fossil station property boundaries within the limits of the particular map,
• buildings within the limits of the particular map;
• named roads within the limits of the particular map;
• subsurface utilities having a significant impact on groundwater flow and/or
transport from the ash basin;
• product or chemical storage areas associated with ash basin operations; and,
• scale and north arrow.
NOTE: The CSA Report will include adjacent property information obtained from the
Drinking Water Well and Receptor Survey Report submitted September 2014, the Supplement
to Drinking Water Supply Well and Receptor Survey Report submitted November 2014, and
updated information obtained between these noted reports and submittal of the CSA Report.
• soil sample locations and analytical results (subjectively as supportive of
conveying findings while affording depiction clarity);
Page 11 of 15

CSA GUIDELINE ADJUSTMENTS DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
• groundwater sample locations and analytical results (subjectively as supportive
of conveying findings while affording depiction clarity);
• separate groundwater contaminant iso -concentration contour maps for
constituents exceeding 2L standards with contour line for applicable 2L standard
shown bold (or otherwise demarcated);
• separate groundwater elevation contour maps for each holistic series of water
level measurements obtained with:
• elevation of groundwater in the monitoring wells;
• direction of groundwater flow indicated;
• identification of the elevation datum; and,
• date(s) that the water level measurements were made.
• the monitoring wells.
• The CSA Report Figures will include at least two geologic cross sections through the
saturated and unsaturated zones intersecting at or near right angles through the ash
basin(s) as proposed in the approved Proposed Groundwater Assessment Work Plan.
The cross -sections will comprise:
• a reasonable vertical exaggeration;
• boring, monitoring well, soil sample, and/or groundwater sample locations and
analytical results (sample locations and analytical results subjectively as
supportive of conveying findings while affording depiction clarity);
• groundwater contaminant iso-concentrationcontours for constituents exceeding
2L standards;
• depiction of the water table; and,
• a site map showing the locations of the cross sections.
NCDENR Division of Water Resources Position:
The Division does not intend to change the CSA Guidelines. Proposed changes in data
presentation in Section N will be considered during the Division's review of the CSA
reports. If the Division's review of a CSA report indicates data presentation related to the
figures provided in Section N is inadequate, then additional data and/or data
presentation may be requested. Technical direction related to data presentation in
Section N that should be considered includes :
• The direction for data presentation in site assessment deliverables outlined in
Comment 23 from the November 2014 Review of Groundwater Assessment Work
Plan letters sent to Duke Energy.
Strike out the caveats that read "(subjectively as supportive of conveying findings
while affording depiction clarity)" from proposed text revisions. Direction
provided in Sections H. Soil Sampling Results and I. Groundwater Sampling
Results, respectively, gives specific instruction related to presentation of both soil
and groundwater analytical results detected above PQLs along with those results
above numeric regulatory limits. This approach is suggested in order to allow the
Page 12 of 15

CSA GUIDELINE ADJUSTMENTS DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
Division Regional offices to have sufficient information in a format that promotes
an effective review of the CSA documents. In addition, the Division Regional
Offices may request additional information in support of the CSA to aid in their
review.
• Map groundwater analytical results related to detection monitoring constituents
and inorganic parameters as identified in the USEPA April 2015 Final Ruling 40
CFR Parts 257 and 261, including boron, calcium, chloride, conductivity, pH,
sulfate, and total dissolved solids.
Map groundwater analytical results related to assessment monitoring constituents
as identified in the USEPA April 2015 Final Ruling 40 CFR Parts 257 and 261,
including aluminum, antimony, arsenic, barium, beryllium, cadmium, chromium,
copper, iron, lead, manganese, mercury, molybdenum, selenium, sulfate, sulfide,
and thallium. In addition, map the distribution of vanadium as an assessment
monitoring constituent.
O. Tables
• List all water supply wells, public or private, including irrigation wells and unused
wells, (omit those that have been properly abandoned in accordance with 15A NCAC
2C .0100) within a minimum of 1500 feet of the known extent of contamination For-
depth,each Nye!!, inelude the %reall nu-m-h-ear- (may use the tax map numbeF), Nye!] Awnevand
user- names, add-resses and telephone numbeFs, use of the well, Nvell
contamination;casing depth, Nvell screen interval and distance 49M the SOUFGe of
List the na nn es a nd ad-d-resses of pro moo,-ty ewneFs and e ntsyAt-h;n .
ce tiguous to the area containing C0Ht_ArAin_At_jA_14 -and all pFoper-ty owners
occupants within OF COntigUOUS tO the area Nvher-e the contamination is expected t&
migr-ate; 2,640 feet (one-half mile) from the established ash basin compliance
boundaries. For each well, include that information obtained during and since the
formerly noted Receptor Surveys.
• List the results for groundwater samples collected including sample location; date of
sampling; sample collection procedures (briefly/concisely as "bailer", "pump", etc.);
sample identifications; sample analyses; and sample analytical results (4s-t
demarcate (bold or otherwise) any contaminant detected above the method
detection limit in bold); and,
• List for each monitoring well, the monitoring well identification number, date water levels
were obtained, elevations of the water levels, the land surface, top of the well casing,
screened interval and bottom of the well.
Page 13 of 15

CSA GUIDELINE ADJUSTMENTS DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
NCDENR Division of Water Resources Position:
The Division does not intend to change the CSA Guidelines. Proposed changes in tables in Section
0 will be considered during the Division's review of the CSA reports. If the Division's review of a
CSA report indicates tables provided in Section 0 is inadequate, then revised tables may be
requested. Documentation of specific water supply well receptor information is expected to be
presented in a certain format to facilitate review and as indicated below:
Direction outlined in Comments 22 and 23, respectively, from the November 2014
Review of Groundwater Assessment Work Plan letters sent to Duke Energy for data
presentation in site assessment deliverables will be followed.
Highlight groundwater analytical results that exceed numeric regulatory values in some
manner that distinguishes those results from those below the limits. Note the numeric
regulatory value for a constituent in the table.
P. Appendices
• Boring logs and lithological descriptions;
• Well construction records;
• Standard procedures used at site for sampling, field equipment decontamination,
field screening, etc.;
• Laboratory reports and chain -of -custody documents;
• Copies of any permits or certificates obtained, permit number, permitting agency,
and
• Modeling data and results-,
• Slug/pumping test data; and
Certification fOr-M f9F GSA.
• The CSA Reports will be sealed and signed by a groundwater -experienced
Professional Engineer or Professional Geologist registered in North Carolina.
NOTE. Modeling data and results will be included in the Corrective Action Plans per NCDENR
DWR Conditional Approval of Revised Groundwater Assessment Work Plan letters.
NCDENR Division of Water Resources Position:
The Division accepts the proposed change in Section P to not include groundwater modeling
results and related data in the CSA Reports; instead, providing information related to
groundwater modeling in the Corrective Action Plans. The Division does require relevant
information provided in the Certification Form for the CSA Reports and does not accept the
proposed change for the CSA Guidelines.
Page 14 of 15

CSA GUIDELINE ADJUSTMENTS DWR Review June 2015
Tracked Changes Version, May 14, 2015
Reviewers & Users: See Document End Note
Document End Note:
This Microsoft Word file was generated from a PDF version of the August 12, 2014 Guidelines for
Comprehensive Site Assessment attached to NCDENR's August 14, 2015 Notice of Regulatory Requirements
letter. Generation comprised saving the PDF file as a Microsoft Word file using PDF Converter Assistant
within PDF Converter Enterprise 8.2, with post -conversion manual formatting. Any
discrepancy/disparity between the original PDF file and this Word file are unintentional.
Page 15 of 15

Clarification of Attachment 1 Groundwater Assessment Plan Conditional Letters of Approval Items Related to Speciation - May 22, 2015 e-mail
Duke Energy GAP Attachment Clarification Request Background:
Division of Water Resources Position
"Comment 4 of "Site Assessment: Data Requirements and Sampling Strategy" found in Attachment 1 of the GWAP
Since speciation of groundwater and surface water samples is a critical component of both the site assessments and corrective
Conditional Approval Letters states the following:
action, the Division expects a geochemical site conceptual site model (CSM) developed as a subsection in the Comprehensive
"Speciations for groundwater and surface water samples should include Fe, Mn, and any COPCs whose speciation state
Site Assessment (CSA) Reports. The geochemical CSM should provide a summary of the geochemical interactions between the
may affect toxicity or mobility (e.g. As, Cr, Se, or others if applicable). This speciation will apply for groundwater
solution and solid phases along the groundwater flowpath that impact the mobility of metal constituents. At a minimum, the
samples collected at wells located along proposed flowpath transects and in wells where these constituents exceed 2L
geochemical CSM will describe the adsorption/desorption and mineral precipitation/dissolution processes that are believed to
groundwater standards as well as for surface water samples collected within ash impoundments."
impact dissolved concentrations along the aquifer flowpaths away from the ash basin sources. The model descriptions should
After conversations with risk assessors and other technical leads with our consulting agencies, Duke Energy plans the
include the data upon which the conceptual model is based and any calculations (such as mineral saturation indices) that are
following as it relates to speciation sampling for the groundwater assessments:"
made to develop the site -specific model.
Metal speciation analyses cover a broad aspect of metals' geochemistry, including solution complexation with other dissolved
species and specific association with aquifer solids, such as a metal adsorbed onto HFO or precipitated as a sulfate mineral. A
comprehensive speciation analysis that requires a relatively complete groundwater analysis is expected that includes use of an
ion speciation computer code (such as PHREEQC) capable of calculating solution complexes, surface complexation onto HFO,
and mineral saturation indices. This type of speciation calculation is necessary for the development of a geochemical SCM and
understanding metal mobility in an aquifer.
Duke Energy Proposal
Division of Water Resources Position
For the sampling to be reported in the CSA (Round 1 of Samples)
The Division agrees with the overall approach presented for Round 1 of groundwater sampling since it is consistent with the
• At wells located along proposed flow -path transects and at surface water sample locations within the ash basins:
direction provided in Attachment 1 of the GAP Conditional Approval Letters. However as stated in the GAP Conditional Letters
o Collect samples and perform speciation for the following constituents and oxidation states: Fe(II, III), Mn(Il,lll),
of Approval, the Division reserves the right to request additional data to complete the CSA if a determination is made that
As(III,V), Cr(III,VI), Se (-II,IV,VI).
there is insufficient data to evaluate site conditions, including speciation of groundwater samples.
• At compliance wells where 2L exceedances have been measured (and are not related to turbidity):
Clarification of the Division's expectations with respect to the specific proposed direction for CSA Round 1 groundwater
o Perform speciation for the constituent with the measured exceedance if the constituent has a speciation state(s) that
sampling is provided below:
may affect toxicity or mobility.
• Existing background wells that have historically had 2L exceedances of speciation constituents and all newly installed
First bullet: Add Mn (IV) to the speciation list for wells along the flow -path transects.
background wells
o Collect samples and perform speciation for the following constituents and oxidation states: Fe(II, III), Mn(II,III),
Second bullet: The Division acknowledges that turbidity is problematic with respect to obtaining representative groundwater
As(III,V), Cr(III,VI), Se (-II,IV,VI).
samples for analysis at some wells at the coal ash facilities, particularly when the wells are completed in coal ash. However, the
Division expects that an intent to comply with the requirements of 15A NCAC 02C .0108 (p) is made:
"Each non -water supply well shall be developed such that the level of turbidity or settleable solids does not preclude accurate
chemical analyses of any fluid samples collected or adversely affect the operation of any pumps or pumping equipment."
The rules do not specify a minimum filter pack or levels of turbidity or settable solids applicable to monitoring wells; however,
proper well development must be conducted for each well such that there is no interference with subsequent sample analysis.
Any well that does not provide a water quality sample that meets the requirements of the well construction code may need to
be replaced.
Third bullet: Add Mn (IV) to the speciation list for background wells.

Duke Energy Proposal
Division of Water Resources Position
For the sampling to be reported in the Supplement to the CSA (Round 2 of Samples)
The Division agrees with the overall approach presented for Round 2 of groundwater sampling since it is consistent with the
• Any well where 2L exceedances were measured in the sampling reported in the CSA:
direction provided in Attachment 1 of the GAP Conditional Approval Letters. However as stated in the GAP Conditional Letters
o Collect samples and perform speciation for the following constituents and oxidation states: Fe(II, III), Mn(II,III),
of Approval, the Division reserves the right to request additional data to complete the CSA if a determination is made that
As(III,V), Cr(III,VI), Se (II,IV,VI) or for constituents with the measured exceedances from Round 1 if the constituent has a
there is insufficient data to evaluate site conditions, including speciation of groundwater samples.
speciation state(s) that may affect toxicity or mobility.
Clarification of the Division's expectations with respect to the specific proposed direction for CSA Round 2 groundwater
• Existing background wells that have historically had 2L exceedances of speciation constituents and all newly installed
sampling is provided below:
background wells
o Collect samples and perform speciation for constituents with the measured exceedances from Round 1 if the
First bullet: Sample wells and surface water locations situated on groundwater flow -paths as well as wells that exhibited
constituent has a speciation state(s) that may affect toxicity or mobility.
exceedances of 2L reported in the CSA. Add Mn (IV) to the speciation list for wells sampled. In addition, plan to sample a
subset of existing compliance and new site assessment wells two (2) additional times during 2015 as part of an anticipated
corrective action measure to support EPA tiered site analysis. The timeframe for these suggested additional groundwater
sample collection events should be such that the samples collected are not auto -correlated.
Second bullet: Add Mn (IV) to the speciation list for background wells. Plan to sample the existing and newly installed
background wells two (2) additional times during 2015 as part of an anticipated corrective action measure to support EPA
tiered site analysis and statistical analysis. The timeframe for these suggested additional groundwater sample collection events
should be such that the samples collected are not auto -correlated.

Revised Groundwater Assessment Work Plan

Marshall Steam Station Ash Basin
Proposed Groundwater
Assessment Work Plan
(Rev. 1)
NPDES Permit NC0004987
December 30, 2014

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
Table of Contents
Table of Contents
Tableof Contents.........................................................................................................................i
ExecutiveSummary..............................................................................................................ES-1
1.0 Introduction.......................................................................................................................... 1
2.0 Site History........................................................................................................................... 4
2.1 Plant Description...................................................................................................... 4
2.2 Ash Basin Description............................................................................................... 4
2.3 Regulatory Requirements......................................................................................... 5
3.0 Receptor Information............................................................................................................ 7
4.0 Regional Geology and Hydrogeology................................................................................... 8
5.0 Initial Conceptual Site Model...............................................................................................10
5.1 Physical Site Characteristics....................................................................................10
5.1.1 Ash Basin.....................................................................................................11
5.1.2 Dry Ash Landfill............................................................................................11
5.1.3 FGD Residue Landfill...................................................................................12
5.1.4 Industrial Landfill #1.....................................................................................12
5.1.5 Demolition Landfill........................................................................................12
5.1.6 Asbestos Landfill..........................................................................................13
5.1.7 Structural Fill................................................................................................13
5.2 Source Characteristics.............................................................................................13
5.3 Hydrogeologic Site Characteristics..........................................................................15
6.0 Compliance Groundwater Monitoring..................................................................................18
7.0 Assessment Work Plan.......................................................................................................19
7.1 Subsurface Exploration............................................................................................20
7.1.1 Ash and Soil Borings....................................................................................20
7.1.2 Shallow Monitoring Wells.............................................................................23
7.1.3 Deep Monitoring Wells.................................................................................24
7.1.4 Bedrock Monitoring Wells.............................................................................25
7.1.5 Well Completion and Development..............................................................26
7.1.6 Hydrogeologic Evaluation Testing................................................................26
7.2 Groundwater Sampling and Analysis.......................................................................27
7.2.1 Existing Compliance and Voluntary Monitoring Wells...................................29
7.2.2 Speciation of Select Inorganics....................................................................29

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Buck Combined Cycle Station Ash Basin
Table of Contents
7.3 Surface Water, Sediment, and Seep Sampling........................................................29
7.3.1 Surface Water Samples...............................................................................29
7.3.2 Seep Samples..............................................................................................30
7.3.3 Sediment Samples.......................................................................................31
7.4 Field and Sampling Quality Assurance/Quality Control Procedures .........................31
7.4.1
Field Logbooks.............................................................................................31
7.4.2
Field Data Records......................................................................................32
7.4.3
Sample Identification....................................................................................32
7.4.4
Field Equipment Calibration.........................................................................32
7.4.5
Sample Custody Requirements....................................................................33
7.4.6
Quality Assurance and Quality Control Samples..........................................34
7.4.7
Decontamination Procedures.......................................................................35
7.5 Site Hydrogeologic Conceptual Model.....................................................................36
7.6 Site -Specific Background Concentrations................................................................36
7.7 Groundwater Fate and Transport Model..................................................................37
7.7.1
MODFLOW/MT3DMS Model........................................................................37
7.7.2 Development of Kd Terms............................................................................38
7.7.3 MODFLOW/MT3DMS Modeling Process.....................................................40
7.7.4 Hydrostratigraphic Layer Development........................................................41
7.7.5 Domain of Conceptual Groundwater Flow Model.........................................42
7.7.6 Boundary Conditions for Conceptual Groundwater Flow Model....................42
7.7.7 Groundwater Impacts to Surface Water.......................................................43
8.0 Risk Assessment.................................................................................................................45
8.1 Human Health Risk Assessment..............................................................................45
8.1.1 Site -Specific Risk -Based Remediation Standards........................................46
8.2 Ecological Risk Assessment....................................................................................47
9.0 CSA Report.........................................................................................................................50
10.0 Proposed Schedule...........................................................................................................52
11.0 References........................................................................................................................53
Appendix A — Notice of Regulatory Requirements Letter from John E. Skvarla, III, Secretary,
State of North Carolina, to Paul Newton, Duke Energy, dated August 13, 2014.
Appendix B — Review of Groundwater Assessment Work Plan Letter from S. Jay Zimmerman,
Chief, Water Quality Regional Operations Section, NCDENR, To Harry Sideris,
Duke Energy, dated November 4, 2014.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Buck Combined Cycle Station Ash Basin FYZ
Table of Contents
Figures
1. Site Location Map
2. Site Layout Map
3. Proposed Well and Sample Location Map
Tables
1. Groundwater Monitoring Requirements
2. Exceedances of 2L Standards
3. Environmental Exploration and Sampling Plan
4. Soil and Ash Parameters and Analytical Methods
5. Groundwater and Surface Water Parameters and Constituent Analytical Methods
6. Historical Groundwater Analytical Results (Compliance and Voluntary Monitoring Wells)
7. Historical Surface Water Analytical Results (Ash Basin, FGD Landfill, and Industrial Landfill)
8. Historical Ash Analytical Results (Ash Basin)
9. Historical Ash Leachate Analytical Results (Ash Basin)
10. Historical Landfill Leachate Analytical Results (FGD Residue Landfill)
11. Historical Landfill Leachate Analytical Results (Industrial Landfill #1)
12. August 2014 Seep Sample Analytical Results

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
Executive Summary
Executive Summary
Duke Energy Carolinas, LLC (Duke Energy) owns and operates Marshall Steam Station (MSS)
which is located on Lake Norman in Catawba County near the town of Terrell, North Carolina
(see Figure 1). MSS began operation in 1965 as a coal-fired generating station and currently
operates four coal-fired units. The coal ash residue from MSS's coal combustion process has
historically been disposed in the station's ash basin located to the north of the station and
adjacent to Lake Norman. The discharge from the ash basin is permitted by the North Carolina
Department of Environment and Natural Resources (NCDENR) Division of Water Resources
(DWR) under the National Pollutant Discharge Elimination System (NPDES) Permit
NC0004987.
Duke Energy has performed voluntary groundwater monitoring around the ash basin from
November 2007 until February 2010. The voluntary groundwater monitoring wells were
sampled two times each year and the analytical results were submitted to DWR. Groundwater
monitoring as required by the NPDES permit began in February 2011. The system of
compliance groundwater monitoring wells required for the NPDES permit is sampled three times
a year and the analytical results are submitted to the DWR. The compliance groundwater
monitoring is performed in addition to the normal NPDES monitoring of the discharge flows from
the ash basin.
It is Duke Energy's intention that the assessment will collect additional data to validate and
expand the knowledge of the groundwater system at the ash basin. The proposed assessment
plan will provide the basis for a data -driven approach to additional actions related to
groundwater conditions if required by the results of the assessment and for closure.
On August 13, 2014, NCDENR issued a Notice of Regulatory Requirements (NORR) letter to
Duke Energy pursuant to Title 15A North Carolina Administrative Code Chapter (15A NCAC)
02L.0106. The NORR stipulates that for each coal -fueled plant owned, Duke Energy will
conduct a comprehensive site assessment (CSA) that includes a Groundwater Assessment
Work Plan (Work Plan) and a receptor survey. In accordance with the requirements of the
NORR, HDR completed a receptor survey to identify all receptors within a 0.5-mile radius (2,640
feet) of the MSS ash basin compliance boundary. This receptor survey also addressed the
requirements of the General Assembly of North Carolina Session 2013 Senate Bill 729 Ratified
Bill (SB 729). Similar requirements to perform a groundwater assessment are found in SB 729,
which revised North Carolina General Statute 130A-309.209(a).
In accordance with the NORR, Duke Energy submitted a Groundwater Assessment Work Plan
(GAWP) to the NCDENR on September 25, 2014. Subsequent to their review, the NCDENR
provided comments to the GAWP in a letter dated November 4, 2014. The letter included
general comments that pertained to each of the work plans prepared for Duke Energy's 14 coal
ash sites in North Carolina as well as comments specific to the MSS work plan and site. This
Revised GWAP has been prepared to address the general and site -specific comments made by
NCDENR in the November 4, 2014 letter.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
Executive Summary
Soil and groundwater sampling will be conducted to provide information pertaining to the
horizontal and vertical extent of potential soil and groundwater contamination. This will be
performed by sampling select existing wells, installing and sampling approximately 35 nested
monitoring well pairs (shallow and deep), 4 additional shallow monitoring wells, 1 additional
deep monitoring well, and 5 bedrock monitoring wells, and collecting soil and ash samples. One
observation well will be installed between two outer portions of the western extent of the ash
basin to characterize groundwater flow direction. This work will provide additional information on
the chemical and physical characteristics of site soils and ash as well as the geological and
hydrogeological features of the site that influence groundwater flow and direction and potential
transport of constituents from the ash basin, dry ash landfills, and structural fill. Samples of ash
basin water will be collected and used to evaluate potential impacts to groundwater and surface
water. One surface water sample and sediment sample will be collected from the surface water
located east of the ash basin. In addition, one previously identified potential seep sample
location will be evaluated for sample collection.
The information obtained through implementation of this Work Plan will be utilized to prepare a
CSA report in accordance with the requirements of the NORR. If it is determined that additional
investigations are required during the review of existing data or data developed from this
assessment, Duke Energy and HDR will notify the NCDENR regional office prior to initiating
additional sampling or investigations.
HDR will also perform an assessment of risks to human health and safety and to the
environment. This assessment will include the preparation of a conceptual site model illustrating
potential pathways from the source to possible receptors.
ES-2

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
1.0 Introduction
1.0 Introduction
Duke Energy Carolinas, LLC (Duke Energy) owns and operates Marshall Steam Station (MSS)
which is located on Lake Norman in Catawba County near the town of Terrell, North Carolina
(see Figure 1). MSS began operation in 1965 as a coal-fired generating station and currently
operates four coal-fired units. The coal ash residue from MSS's coal combustion process has
historically been disposed in the station's ash basin located to the north of the station and
adjacent to Lake Norman. The discharge from the ash basin is permitted by the North Carolina
Department of Environment and Natural Resources (NCDENR) Division of Water Resources
(DWR) under the National Pollutant Discharge Elimination System (NPDES) Permit
NC0004987.
Duke Energy has performed voluntary groundwater monitoring around the ash basin from
November 2007 until February 2010. The voluntary groundwater monitoring wells were
sampled two times each year and the analytical results were submitted to DWR. Groundwater
monitoring as required by the NPDES permit began in February 2011. The system of
compliance groundwater monitoring wells required for the NPDES permit is sampled three times
a year and the analytical results are submitted to the DWR. The compliance groundwater
monitoring is performed in addition to the normal NPDES monitoring of the discharge flows from
the ash basin.
It is Duke Energy's intention that the assessment will collect additional data to validate and
expand the knowledge of the groundwater system at the ash basin. The proposed assessment
plan will provide the basis for a data -driven approach to additional actions related to
groundwater conditions if required by the results of the assessment and for closure.
On August 13, 2014, NCDENR issued a Notice of Regulatory Requirements (NORR) letter to
Duke Energy pursuant to Title 15A North Carolina Administrative Code (15A NCAC) Chapter
02L.0106. The NORR stipulates that for each coal -fueled plant owned, Duke Energy will
conduct a comprehensive site assessment (CSA) that includes a Groundwater Assessment
Work Plan (Work Plan) and a receptor survey. In accordance with the requirements of the
NORR, HDR has completed a receptor survey to identify all receptors within a 0.5-mile radius
(2,640 feet) of the MSS ash basin compliance boundary. The NORR letter is included as
Appendix A.
The Coal Ash Management Act 2014 — General Assembly of North Carolina Senate Bill 729
Ratified Bill (Session 2013) (SB 729) revised North Carolina General Statute 130A-309.209(a)
to require the following:
(a) Groundwater Assessment of Coal Combustion Residuals Surface Impoundments. —
The owner of a coal combustion residuals surface impoundment shall conduct
groundwater monitoring and assessment as provided in this subsection. The
requirements for groundwater monitoring and assessment set out in this subsection
are in addition to any other groundwater monitoring and assessment requirements
applicable to the owners of coal combustion residuals surface impoundments.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin
1.0 Introduction
(1) No later than December 31, 2014, the owner of a coal combustion residuals
surface impoundment shall submit a proposed Groundwater Assessment Plan
for the impoundment to the Department for its review and approval. The
Groundwater Assessment Plan shall, at a minimum, provide for all of the
following:
a. A description of all receptors and significant exposure pathways.
b. An assessment of the horizontal and vertical extent of soil and groundwater
contamination for all contaminants confirmed to be present in groundwater in
exceedance of groundwater quality standards.
c. A description of all significant factors affecting movement and transport of
contaminants.
d. A description of the geological and hydrogeological features influencing the
chemical and physical character of the contaminants.
e. A schedule for continued groundwater monitoring.
f. Any other information related to groundwater assessment required by the
Department.
(2) The Department shall approve the Groundwater Assessment Plan if it determines
that the Plan complies with the requirements of this subsection and will be
sufficient to protect public health, safety, and welfare; the environment; and natural
resources.
(3) No later than 10 days from approval of the Groundwater Assessment Plan, the
owner shall begin implementation of the Plan.
(4) No later than 180 days from approval of the Groundwater Assessment Plan, the
owner shall submit a Groundwater Assessment Report to the Department. The
Report shall describe all exceedances of groundwater quality standards associated
with the impoundment.
This work plan addresses the requirements of 130A-309.209(a)(1) (a) through (f) and the
requirements of the NORR.
On behalf of Duke Energy, HDR submitted to NCDENR a proposed Work Plan for the MSS site
dated September 25, 2014. Subsequently, NCDENR issued a comment letter dated November
4, 2014, containing both general comments applicable to all 14 of Duke Energy ash basin
facilities and site -specific comments for the MSS. In response to these comments, HDR has
prepared this revised Work Plan for performing the groundwater assessment as prescribed in
the NORR. If it is determined that additional investigations are required during the review of
existing data or data developed from this assessment, Duke Energy and HDR will notify the
NCDENR regional office prior to initiating additional sampling or investigations.
HDR will also perform an assessment of risks to human health and safety and to the
environment. This assessment will include the preparation of a conceptual site model illustrating
potential pathways from the source to possible receptors.
The purpose of the work plan contains a description of the activities proposed to meet the
requirements of 15A NCAC 02L .0106(g). This rule requires:
2

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
1.0 Introduction
(g) The site assessment conducted pursuant to the requirements of Paragraph (c) of this
Rule, shall include:
(1) The source and cause of contamination;
(2) Any imminent hazards to public health and safety and actions taken to mitigate them
in accordance with Paragraph (f) of this Rule;
(3) All receptors and significant exposure pathways;
(4) The horizontal and vertical extent of soil and groundwater contamination and all
significant factors affecting contaminant transport; and
(5) Geological and hydrogeological features influencing the movement, chemical, and
physical character of the contaminants.
The work proposed in this plan will provide the information sufficient to satisfy the requirements
of the rule. However, uncertainties may exist due to the following factors:
The natural variations and the complex nature of the geological and hydrogeological
characteristics involved with understanding the movement, chemical, and physical
character of the contaminants
• The size of the site
• The time frame mandated by the Coal Ash Management Act (CAMA). Site assessments
are most effectively performed in a multi -phase approach where data obtained in a
particular phase of the investigation can be reviewed and used to refine the subsequent
phases of investigation. The mandated 180-day time frame will prevent this approach
from being utilized.
The 180-day time frame will limit the number of sampling events that can be performed after
well installation and prior to report production. Effectively, this time frame will likely reduce the
number of sampling events within the proposed wells to a single sampling event.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
2.0 Site History
2.0 Site History
2.1 Plant Description
MSS is a four -unit, coal-fired electric generating plant with a capacity of 2,090 megawatts
located in Catawba County, North Carolina, near the community of Terrell. The site is located
north of NC Hwy 150, east of Sherrills Ford Road, and south of Island Point Road, and the
surrounding area generally consists of residential properties, undeveloped land, and Lake
Norman (Figure 1).
The ash basin is situated between the MSS to the south, primarily residences to the west,
residences and undeveloped land to the north, and undeveloped land and Lake Norman to the
east (Figure 2). A topographical divide is located along Sherrills Ford Road to the west and
along Island Ford Road to the north. The topography at the site generally slopes downward from
that divide toward Lake Norman.
Duke Energy operates the Catawba-Wateree Project (Federal Energy Regulatory Commission
[FERC] Project No. 2232). Lake Norman is part of the Catawba-Wateree project and provides
cooling water for the station. Duke Energy has performed a review of property ownership of the
FERC project boundary property within the ash basin compliance boundary (described in
Section 2.3). The review indicated that Duke Energy owns all of the property within the project
boundary, the FERC boundary (Lake Norman) and the ash basin compliance boundary. The
Duke Energy property boundary and the ash basin compliance boundary are shown on Figures
2 and 3.
2.2 Ash Basin Description
The ash basin system consists of a single cell impounded by an earthen dike located on the
southeast end of the ash basin. The ash basin system was constructed in 1965 and is located
approximately 2,000 feet northeast of the power plant. The ash basin waste boundary, which is
shown on Figures 2 and 3, is approximately 382 acres in area.
The ash basin is operated as an integral part of the station's wastewater treatment system and
receives inflows from the ash removal system, coal pile runoff, landfill leachate, flue gas
desulfurization (FGD) wastewater, the station yard drain sump, stormwater flows, and station
wastewater. Due to variability in station operations and weather, inflows to the ash basin are
highly variable. Inflows from the station to the ash basin are discharged into the northwest
portion of the ash basin.
The discharge from the ash basin is through a concrete discharge tower located in the eastern
portion of the ash basin. The concrete discharge tower drains through a 30-inch-diameter
slip -lined corrugated metal pipe which discharges into Lake Norman. The ash basin pond
elevation is controlled by the use of concrete stoplogs in the discharge tower.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
2.0 Site History
Note that there are six permitted landfill areas and one structural fill area located adjacent to the
ash basin. Two ash landfills (Permit No. 1804) are located adjacent to the east and northeast
portions of the ash basin. The demolition landfill (Permit No. 1804), asbestos landfill (Permit No.
1804), and industrial landfill (Permit No. 1812) are located adjacent to the northern portion of the
ash basin. The FGD landfill (Permit No. 1809) is located southwest of the ash basin. The
structural fill area is located adjacent to and partially on top of the western most portion of the
ash basin. The approximate boundary of these landfill/structural fill areas are shown on Figures
2 and 3. Existing groundwater monitoring wells associated with the ash landfills and the FGD
landfill are shown on Figures 2 and 3.
2.3 Regulatory Requirements
The NPDES program regulates wastewater discharges to surface waters to ensure that surface
water quality standards are maintained. MSS operates under NPDES Permit NC0004987 which
authorizes discharge of cooling water and intake screen backwash (Outfall 001); treated
wastewater (consisting of metal cleaning wastes, coal pile runoff, ash transport water, domestic
wastewater, low volume wastes, and FGD wet scrubber wastewater) (Outfall 002); yard sump
overflows (Outfalls 002A and 002B); and non -contact cooling water from the induced draft fan
control house (Outfall 003) to the Catawba River (Lake Norman) in accordance with effluent
limitations, monitoring requirements, and other conditions set forth in the permit.
The NPDES permitting program requires that permits be renewed every 5 years. The most
recent NPDES permit renewal at MSS became effective on March 1, 2011, and expires April 30,
2015.
In addition to surface water monitoring, the NPDES permit requires groundwater monitoring.
Groundwater monitoring has been performed in accordance with the permit conditions
beginning in February 2011. NPDES Permit Condition A (11), Version 1. 1, dated June 15, 2011,
lists the groundwater monitoring wells to be sampled, the parameters and constituents to be
measured and analyzed, and the requirements for sampling frequency and reporting results.
These requirements are provided in Table 1.
The compliance boundary for groundwater quality at the MSS ash basin site is defined in
accordance with Title 15A NCAC 02L .0107(a) as being established at either 500 feet from the
waste boundary or at the property boundary, whichever is closer to the waste. The location of
the ash basin compliance monitoring wells, the ash basin waste boundary, and the compliance
boundary are shown on Figures 2 and 3.
The locations for the compliance groundwater monitoring wells were approved by the NCDENR
DWR Aquifer Protection Section (APS). All compliance monitoring wells included in Table 1 are
sampled three times per year (in February, June, and October). Analytical results are submitted
to DWR before the last day of the month following the date of sampling for all compliance
monitoring wells.
The compliance groundwater monitoring system for the MSS ash basin consists of the following
monitoring wells: MW-4, MW-41D, MW-10S, MW-10D, MW-11 S, MW-11 D, MW-12S, MW-12D,

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
2.0 Site History
MW-13S, MW-13D, MW-14S, and MW-14D (shown on Figures 2 and 3). With the exception of
monitoring wells MW-4 and MW-4D, all the compliance monitoring wells were installed in 2010
Monitoring well MW-4 was installed by Duke Energy in 1989 as part of the Marshall Dry Ash
Landfill (Permit No. 1804) groundwater monitoring network. Monitoring well MW-4D was
installed by Duke Energy in 2006 as part of a voluntary monitoring system. Based on the
locations of monitoring wells MW-4 and MW-4D relative to the ash basin, they were
incorporated into the ash basin compliance monitoring network.
One or more groundwater quality standards (2L Standards) have been exceeded in
groundwater samples collected at monitoring wells MW-4, MW-4D, MW-10S, MW-10D,
MW-11 S, MW-11 D, MW-12S, MW-12D, MW-13S, MW-13D, MW-14S, and MW-14D.
Exceedances have occurred for boron, iron, manganese, pH, sulfate, and/or total dissolved
solids (TDS). Table 2 presents exceedances measured from February 2011 through June 2014
Monitoring wells MW-4, MW-10S, MW-11 S, MW-12S, MW-13S, and MW-14S were installed
with 10-foot to 15-foot well screens placed above auger refusal to monitor the shallow aquifer
within the saprolite layer. (Duke Power Company, 1989; S&ME, 2006.) These wells were
installed to total depths ranging from 18 feet below ground surface (bgs) at MW-13S to 52 feet
bgs at MW-11 S.
Monitoring wells MW-4D1, MW-10D, MW-11 D, MW-12D, MW-13D, and MW-14D were installed
with 5-foot well screens placed in the fractured rock transition zone. These wells were installed
to total depths ranging from 46.5 feet bgs at MW-13D to 95 feet bgs at MW-12D.
Note that monitoring wells MW-6S, MW-6D, MW-7S, MW-7D, MW-8S, MW-8D, MW-9S, and
MW-9D were installed by Duke Energy in 2006 as part of a voluntary monitoring system. No
groundwater samples are currently collected from these wells under the compliance monitoring
program. The voluntary wells are shown on Figures 2 and 3.
' S&ME, Inc., Ash Basin Monitoring Well Installation, Duke Power -Marshall Steam Station, S&ME Project
No. 1356-06-834, December 4, 2006.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin
3.0 Receptor Information
3.0 Receptor Information
The August 13, 2014, NORR states:
No later than October 14th, 2014 as authorized pursuant to 15A NCAC 02L
.0106(g), the DWR is requesting that Duke perform a receptor survey at each of
the subject facilities and submitted to the DWR. The receptor survey is required
by 15A NCAC 02L .0106(g) and shall include identification of all receptors within
a radius of 2,640 feet (one-half mile) from the established compliance boundary
identified in the respective National Pollutant Discharge Elimination System
(NPDES) permits. Receptors shall include, but shall not be limited to, public and
private water supply wells (including irrigation wells and unused or abandoned
wells) and surface water features within one-half mile of the facility compliance
boundary. For those facilities for which Duke has already submitted a receptor
survey, please update your submittals to ensure they meet the requirements
stated in this letter and referenced attachments and submit them with the others.
If they do not meet these requirements, you must modify and resubmit the plans.
The results of the receptor survey shall be presented on a sufficiently scaled
map. The map shall show the coal ash facility location, the facility property
boundary, the waste and compliance boundaries, and all monitoring wells listed
in the respective NPDES permits. Any identified water supply wells shall be
located on the map and shall have the well owner's name and location address
listed on a separate table that can be matched to its location on the map.
In accordance with the requirements of the NORR, HDR completed and submitted the receptor
survey to NCDENR (HDR 2014A) in September 2014. HDR subsequently submitted to
NCDENR a supplement to the receptor survey (HDR 201413) in November 2014. The
supplementary information was obtained from responses to water supply well survey
questionnaires mailed to property owners within a 0.5-mile radius of the MSS ash basin
compliance boundary requesting information on the presence of water supply wells and well
usage.
The receptor survey includes a map showing the coal ash facility location, the facility property
boundary, the waste and compliance boundaries, and all monitoring wells listed in the NPDES
permit. The identified water supply wells are located on the map and the well owner's name and
location address are listed on a separate table that can be matched to its location on the map.
During completion of the CSA, HDR will update the receptor information as necessary in
general accordance with the CSA receptor survey requirements.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin
4.0 Regional Geology and Hydrogeology
4.0 Regional Geology and Hydrogeology
North Carolina is divided into distinct regions by portions of three physiographic provinces: the
Atlantic Coastal Plain, Piedmont, and Blue Ridge (Fenneman 1938). The MSS site is located in
the Charlotte terrane within the Piedmont province. The Piedmont province is bounded to the
east and southeast by the Atlantic Coastal Plain and to the west by the escarpment of the Blue
Ridge Mountains, covering a distance of 150 to 225 miles (LeGrand 2004).
The topography of the Piedmont region is characterized by low, rounded hills and long, rolling,
northeast -southwest trending ridges (Heath 1984). Stream valley to ridge relief in most areas
ranges from 75 to 200 feet. Along the Coastal Plain boundary, the Piedmont region rises from
an elevation of 300 feet above mean sea level to the base of the Blue Ridge Mountains at an
elevation of 1,500 feet (LeGrand 2004).
The Charlotte terrane consists primarily of igneous and metamorphic bedrock. The fractured
bedrock is overlain by a mantle of unconsolidated material known as regolith. The regolith
includes residual soil and saprolite zones and, where present, alluvium. Saprolite, the product of
chemical weathering of the underlying bedrock, is typically composed of clay and coarser
granular material and reflects the texture and structure of the rock from which it was formed.
The weathering products of granitic rocks are quartz -rich and sandy textured. Rocks poor in
quartz and rich in feldspar and ferro-magnesium minerals form a more clayey saprolite.
The groundwater system in the Piedmont Province, in most cases, is comprised of two
interconnected layers or mediums: 1) residual soil/saprolite and weathered fractured rock
(regolith) overlying, and 2) fractured crystalline bedrock (Heath 1980; Harned and Daniel 1992).
The regolith layer is a thoroughly weathered and structureless residual soil that occurs near the
ground surface with the degree of weathering decreasing with depth. The residual soil grades
into saprolite, a coarser -grained material that retains the structure of the parent bedrock.
Beneath the saprolite, partially weathered/fractured bedrock occurs with depth until sound
bedrock is encountered. This mantle of residual soil, saprolite, and weathered/fractured rock is a
hydrogeologic unit that covers and crosses various types of rock (LeGrand 1988). This layer
serves as the principal storage reservoir and provides an intergranular medium through which
the recharge and discharge of water from the underlying fractured rock occurs. Within the
fractured crystalline bedrock layer, the fractures control both the hydraulic conductivity and
storage capacity of the rock mass. A transition zone at the base of the regolith has been
interpreted to be present in many areas of the Piedmont. The zone consists of partially
weathered/fractured bedrock and lesser amounts of saprolite that grades into bedrock and has
been described as "being the most permeable part of the system, even slightly more permeable
than the soil zone" (Harned and Daniel 1992). The zone thins and thickens within short
distances and its boundaries may be difficult to distinguish. It has been suggested that the zone
may serve as a conduit of rapid flow and transmission of contaminated water (Harned and
Daniel 1992)
The igneous and metamorphic bedrock in the Piedmont consist of interlocking crystals and
primary porosity is very low, generally less than 3 percent. Secondary porosity of crystalline

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
4.0 Regional Geology and Hydrogeology
bedrock due to weathering and fractures ranges from 1 to 10 percent (Freeze and Cherry, 1979)
but, porosity values of from 1 to 3 percent are more typical (Daniel and Sharpless 1983). Daniel
(1990) reported that the porosity of the regolith ranges from 35 to 55 percent near land surface
but decreases with depth as the degree of weathering decreases.
LeGrand's (1988, 1989) conceptual model of the groundwater setting in the Piedmont
incorporates the above two -medium system into an entity that is useful for the description of
groundwater conditions. That entity is the surface drainage basin that contains a perennial
stream (LeGrand 1988). Each basin is similar to adjacent basins and the conditions are
generally repetitive from basin to basin. Within a basin, movement of groundwater is generally
restricted to the area extending from the drainage divides to a perennial stream (Slope -Aquifer
System; LeGrand 1988, 1989). Rarely does groundwater move beneath a perennial stream to
another more distant stream or across drainage divides (LeGrand 1989). The crests of the water
table undulations represent natural groundwater divides within a slope -aquifer system and may
limit the area of influence of wells or contaminant plumes located within their boundaries. The
concave topographic areas between the topographic divides may be considered as flow
compartments that are open-ended down slope.
Therefore, in most cases in the Piedmont, the groundwater system is a two -medium system
(LeGrand 1988) restricted to the local drainage basin. The groundwater occurs in a system
composed of two interconnected layers: residual soil/saprolite and weathered rock overlying
fractured crystalline rock separated by the transition zone. Typically, the residual soil/saprolite is
partially saturated and the water table fluctuates within it. Water movement is generally through
the weathered/fractured and fractured bedrock. The near -surface fractured crystalline rocks can
form extensive aquifers. The character of such aquifers results from the combined effects of the
rock type, fracture system, topography, and weathering. Topography exerts an influence on
both weathering and the opening of fractures, while the weathering of the crystalline rock
modifies both transmissive and storage characteristics.
Groundwater flow paths in the Piedmont are almost invariably restricted to the zone underlying
the topographic slope extending from a topographic divide to an adjacent stream. Under natural
conditions, the general direction of groundwater flow can be approximated from the surface
topography (LeGrand 2004).
Groundwater recharge in the Piedmont is derived entirely from infiltration of local precipitation.
Groundwater recharge occurs in areas of higher topography (i.e., hilltops) and groundwater
discharge occurs in lowland areas bordering surface water bodies, marshes, and floodplains
(LeGrand 2004). Average annual precipitation in the Piedmont ranges from 42 inches to 46
inches. Mean annual recharge in the Piedmont ranges from 4.0 inches to 9.7 inches per year
(Daniel 2001).
9

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
5.0 Initial Conceptual Site Model
5.0 Initial Conceptual Site Model
The following Initial Conceptual Site Model (ICSM) has been developed for the MSS site using
available regional data and site -specific data (e.g., boring logs, well construction records, etc.).
Although the groundwater flow system at the site is not fully understood and heterogeneities
exist, the available data indicates that the LeGrand Slope -Aquifer hydrogeologic conceptual
model for sites within the Piedmont, as described in Section 4.0, is a reasonable preliminary
representation of site conditions. The ICSM served as the foundation for the development of
proposed field activities and data collection presented in Section 7.0. The ICSM will be refined
as needed as additional site -specific information is obtained during the site assessment
process.
The ICSM serves as the basis for understanding the hydrogeologic characteristics of the site as
well as the characteristics of the ash sources and will serve as the basis for the Site Conceptual
Model (SCM) discussed in Section 7.5.
In general, the ICSM identified the need for the following additional information concerning the
site and ash:
• Delineation of the extent of possible soil and groundwater contamination
• Additional information concerning the direction and velocity of groundwater flow
• Information on the constituents and concentrations found in the site ash
• Properties of site materials influencing fate and transport of constituents found in ash
• Information on possible impacts to seeps and surface water from the constituents found
in the ash
The assessment work plan found in Section 7.0 was developed in order to collect and to
perform the analyses to provide this information.
5.1 Physical Site Characteristics
The ash basin was constructed in 1965 by building an earthen dike at the confluence where
Holdsclaw Creek historically entered Lake Norman. The earthen dike was constructed to
impound water and ash sluiced to the basin. In general, the ash basin is located in a historical
depression formed from Holdsclaw Creek and small tributaries that fed the creek.
Topography at the MSS site ranges from an approximate high elevation of 900 feet near the
intersection of Sherrills Ford Road and Island Point Road northwest of the site to an
approximate low elevation of 760 feet at the interface with Lake Norman on the southeastern
extent of the site. Topography generally slopes from a northwest to southeast direction with an
elevation loss of approximately 140 feet over an approximate distance of 1.8 miles. Surface
water drainage generally follows site topography and flows from the northwest to the southeast
across the site. Several unnamed drainage features are located on the north/northeast portion
of the site and drain southeast to Lake Norman. The full pond elevation for the MSS ash basin is
approximately 790 feet. The normal pond elevation of Lake Norman is approximately 760 feet.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
5.0 Initial Conceptual Site Model
In addition to the ash basin, several solid waste management units are located topographically
upgradient, adjacent to, and on top of portions of the ash basin as listed below. A structural fill
constructed of fly ash under the structural fill rules found in 15A NCAC 13B .1700 is also located
on portions of the ash basin. Additional information pertaining to each solid waste management
unit is provided below. Locations of site features are shown on Figures 2 and 3.
5.1.1 Ash Basin
Coal ash residue from the coal combustion process has historically been disposed in the MSS
ash basin. The ash basin is operated as an integral part of the station's wastewater treatment
system and consists of a single cell impounded by an earthen dike located on the southeast end
of the ash basin. The basin has a dendritic shape consisting of coves of deposited ash, dikes
which impound ash in portions of the basin, and four main ponded water areas. The ash basin
waste boundary, which is shown on Figures 2 and 3, is approximately 382 acres in area.
All coal ash from MSS was disposed of in the ash basin from approximately 1965 until 1984. Fly
ash precipitated from flue gas and bottom ash collected in the bottom of the boilers were sluiced
to the ash basin using conveyance water withdrawn from the Catawba River (Lake Norman).
Since 1984, fly ash has mainly been disposed of in the on -site dry ash landfills (described
below) and bottom ash has continued to be sluiced to the ash basin. No FGD residue is placed
in the ash basin. The contact stormwater and leachate from the FGD landfill and discharges
from the FGD wastewater treatment system are discharged to the ash basin. The FGD residue
produced by the air treatment system at MSS is primarily gypsum (CaSO4.H2O). The bottom
ash is sluiced to concrete pits where the water is allowed to decant and then flow to the basin.
The bottom ash is then excavated from the pit and sold for off -site beneficial reuse or used for
roads at the ash basin facility. During operations, the sluice water/ash slurry (and other flows) is
discharged into the northwest portion of the ash basin.
The other inflows to the ash basin include flows from coal pile runoff, landfill leachate, FGD
wastewater, the station yard drain sump, stormwater flows, and station wastewater. Due to
variability in station operations and weather, inflows to the ash basin are highly variable. Inflows
from the station to the ash basin are discharged into the northwest portion of the ash basin.
The discharge from the ash basin is permitted by the NCDENR DWR under NPDES Permit
NC0004987. Discharge occurs through a concrete discharge tower located in the eastern
portion of the ash basin. The concrete discharge tower drains through a 30-inch-diameter
slip -lined corrugated metal pipe which discharges into Lake Norman. The ash basin pond
elevation is controlled by the use of concrete stoplogs in the discharge tower.
5.1.2 Dry Ash Landfill
Two ash landfill units, referred to as the Marshall Dry Ash Landfill (NCDENR Division of Solid
Waste Permit No. 1804-INDUS), are located adjacent to the east (Phase 1) and northeast
(Phase 11) portions of the ash basin. Phase I contains approximately 280,000 tons of fly ash that
was placed from September 1984 through March 1986. Placement of ash in the Phase 11 areas
began around March 1986 and was completed in 1999. The approximate boundaries of Phase I

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
5.0 Initial Conceptual Site Model
and II are shown on Figures 2 and 3. The landfill units were constructed prior to the requirement
for lining industrial landfills and were closed with a soil cover system.
5.1.3 FGD Residue Landfill
The FGD residue landfill (NCDENR Division of Solid Waste Permit No. 1809-INDUS) is located
to the west of the ash basin. In general, the topography of the landfill site slopes from the west-
northwest to the east-southeast towards the Marshall ash basin. The landfill is currently in
operation and is permitted to receive FGD residue (gypsum), clarifier sludge, fly ash, bottom
ash, C&D waste, asbestos waste, mill rejects (pyrites), waste limestone material, land clearing
and inert debris, boiler slag, ball mill rejects, sand blast material, and coal waste. The landfill is
constructed with an engineered liner system and contact stormwater and Ieachate are collected
in a lined cell and then piped to the ash basin.
Leachate sampling is performed as a condition of the permit to operate the FGD landfill and
Ieachate sample results are provided in Table 10. Note that the conditions present in the landfill
that generate the Ieachate concentrations are not identical to those in the ash basin.
5.1.4 Industrial Landfill #1
The Industrial Landfill #1 (NCDENR Permit No. 1812-INDUS) is located adjacent to the north
portion of the ash basin. The landfill is currently in operation and is constructed with a Ieachate
collection and removal system and a three -component liner system where the components
consist of a primary geomembrane, secondary geomembrane (with a leak detection system
between them), and soil liner. The landfill is permitted to receive the following types of waste
generated at MSS: fly ash, bottom ash, FGD residue (gypsum), FGD clarifier sludge, asbestos
material, land clearing and inert debris, coal mill rejects, waste limestone material, boiler slag,
construction and demolition waste, sand blast material, ball mill rejects, coal waste, and pyrites.
The landfill was constructed over portions of residual material and over portions of inactive ash
basin. The subgrade for portions of this landfill were constructed of fly ash under the structural
fill rules found in 15A NCAC 13B .1700. Contact stormwater and Ieachate are collected in a
lined cell and then piped to the ash basin.
Leachate sampling is performed as a condition of the permit to operate the Industrial Landfill #1
and Ieachate sample results are provided in Table 11. Note that the conditions present in the
landfill that generate the Ieachate concentrations are not identical to those in the ash basin.
5.1.5 Demolition Landfill
The demolition landfill (NCDENR Permit No. 1804-INDUS) is located adjacent to the north
portion of the ash basin. The landfill received construction and demolition waste from MSS
starting in September 1984. The landfill was closed in 2008.
12

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
5.0 Initial Conceptual Site Model
5.1.6 Asbestos Landfill
The asbestos landfill (NCDENR Permit No. 1804-INDUS) is located adjacent to the north portion
of the ash basin. The landfill received asbestos waste from MSS and other Duke Energy
facilities staring in December 1987. The landfill was closed in 2008.
5.1.7 Structural Fill
A structural fill constructed of fly ash under the structural fill rules found in 15A NCAC 13B .1700
is located adjacent to and on top of the northwest portion of the ash basin. Placement of dry ash
in the structural fill area began in October 2000. The structural fill was completed in February
2013.
5.2 Source Characteristics
The ash in the ash basin consists of fly ash and bottom ash produced form the combustion of
coal. The physical and chemical properties of coal ash are determined by reactions that occur
during the combustion of the coal and subsequent cooling of the flue gas. In general, coal is
dried, pulverized, and conveyed to the burner area of a boiler for combustion. Material that
forms larger particles of ash and falls to the bottom of the boiler is referred to as bottom ash.
Smaller particles of ash, fly ash, are carried upward in the flue gas and are captured by an air
pollution control device. Approximately 70 percent to 80 percent of the ash produced during coal
combustion is fly ash (EPRI 1993). Typically 65 percent to 90 percent of fly ash has particle
sizes that are less than 0.010 millimeter (mm). Bottom ash particle diameters can vary from
approximately 38 mm to 0.05 mm.
The chemical composition of coal ash is determined based on many factors including the source
of the coal, the type of boiler where the combustion occurs (the thermodynamics of the boiler),
and air pollution control technologies employed. The major elemental composition of fly ash
(approximately 90 percent by weight) is composed of mineral oxides of silicon, aluminum, iron,
and calcium. Minor constituents such as magnesium, potassium, titanium, and sulfur comprise
approximately 8 percent of the mineral component, while trace constituents such as arsenic,
cadmium, lead, mercury, and selenium make up less than approximately 1 percent of the total
composition (EPRI 2009). Other trace constituents in coal ash (fly ash and bottom ash) consist
of antimony, barium, beryllium, boron, chromium, copper, lead, mercury, molybdenum, nickel,
selenium, strontium, thallium, uranium, vanadium, and zinc (EPRI 2009).
In addition to these constituents, coal ash leachate contains chloride, fluoride, sulfate, and
sulfide. In the U.S. Environmental Protection Agency's (EPA's) Proposed Rules Disposal of
Coal Combustion Residuals From Electric Utilities, Federal Register / Vol. 75, No. 118 /
Monday, June 21, 2010, 35206, EPA proposed that the following constituents be used as
indicators of groundwater contamination in the detection monitoring program for coal
combustion residual landfills and surface impoundments: boron, chloride, conductivity, fluoride,
pH, sulfate, sulfide, and total dissolved solids (TDS). In selecting the parameters for detection
monitoring, EPA selected constituents that are present in coal combustion residual that would
13

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
5.0 Initial Conceptual Site Model
move rapidly through the subsurface, thereby providing an early indication that contaminants
were migrating from the landfill or ash basin.
In the 1998 Report to Congress, Wastes from the Combustion of Fossil Fuels (USEPA 1998),
EPA presented waste characterization data for coal combustion product (CCP) wastes in
impoundments and in landfills. The constituents listed were: arsenic, barium, beryllium, boron,
cadmium, chromium, cobalt, copper, lead, manganese, nickel, selenium, silver, thallium,
strontium, vanadium, and zinc. In this report, the EPA reviewed radionuclide concentrations in
coal and ash and ultimately eliminated radionuclides from further consideration due to the low
risks associated with the radionuclides.
The geochemical factors controlling the reactions associated with leaching of ash and the
movement and transport of the constituents leached from ash is complicated. The mechanisms
that affect movement and transport vary by constituent but, in general, are mineral equilibrium,
solubility, and adsorption onto inorganic soil particles. Due to the complexity associated with
understanding or identifying the specific mechanism controlling these processes, HDR believes
that the effect of these processes are best considered by determination of site -specific soil -
water distribution coefficient, Kd, values as described in Section 7.7.
The oxidation -reductions and precipitation -dissolution reactions that occur in a complex
environment such as an ash basin are poorly understood. In addition to the variability that might
be seen in the mineralogical composition of the ash, based on different coal types, different age
of ash in the basin, etc., it would be anticipated that the chemical environment of the ash basin
would vary over time and over distance and depth, increasing the difficulty of making specific
predictions related to concentrations of specific constituents. Duke Energy has performed
limited leaching analysis on fly ash and bottom ash. Available data is presented in Table 9.
Due to the complex nature of the geochemical environment and process in the ash basin, HDR
believes that the most useful representation of the potential impacts to groundwater will be
obtained from the sampling and analyses of ash in the basin, in the ash landfills, and from
porewater and groundwater samples proposed in Section 7.0 of this work plan.
Understanding the factors controlling mobility, retention, and transport of the constituents that
may leach from ash are also complicated by the complex nature of the geochemical
environment of the ash basin combined with the complex geochemical processes occurring in
the soils beneath the ash basin along the groundwater flow paths. Mobility, retention, and
transport of the constituents can vary by each individual constituent. As these processes are
complex and highly dependent on the mineral composition of the soils, it will not be possible to
determine with absolute clarity the specific mechanism that controls the mobility and retention of
the constituents; however, the effect of these processes will be represented by the
determination of the site -specific soil -water distribution coefficient, Kd, values as described in
Section 7.7. As described in that section, samples will be collected to develop Kd terms for the
various materials encountered at the site. These Kd terms are then to be used as part of the
groundwater modeling, if required to predict concentrations of constituents at the compliance
boundary.
14

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
5.0 Initial Conceptual Site Model
The site residual soils were formed by in -place weathering of meta -quartz diorite, mica schist,
and biotite gneiss. Iron (Fe) and manganese (Mn) present in groundwater at a number of the
on -site monitoring wells are constituents of the bedrock, primarily in ferro-magnesium minerals.
Manganese substitutes for iron and magnesium in a number of minerals and is enriched in
mafic and ultramafic lithologies relative to felsic lithologies (1,000 parts per million [ppm] in
basalt and 400 ppm in granite; Krauskopf 1972). In the Piedmont, manganese oxides occur as
thin coatings along bedrock fractures (as well as iron oxides) and as thin coatings along relict
discontinuities in saprolite. Manganese ranges from 20 to 3,000 ppm in residual soils (Krauskopf
1972).
In a study in Orange County, North Carolina, Cunningham and Daniel (2001) reported
manganese in 94% and iron in 80% of the drinking water wells tested. Iron exceeded North
Carolina drinking water standards in 6% of the wells and for manganese in 24% of the wells
(Cunningham and Daniel 2001). In more recent study, Gillispie (2014) found that approximately
50% of wells in North Carolina have manganese concentrations exceeding the state standard of
0.05 mg/L (Gillispie 2014). The manganese detected in water wells at ten NC Division of Water
Resources groundwater research stations studied by Gillispie (2014) is naturally derived and
concentrations are spatially variable ranging from less than 0.01 to greater than 2 mg/L.
Approximately 50 percent of wells in North Carolina have manganese concentrations exceeding
the state standard of 0.05 mg/L (Gillispie 2014). The manganese detected in water wells at ten
NC Division of Water Resources groundwater research stations studied by Gillispie (2014) is
naturally derived and concentrations are spatially variable ranging from less than 0.01 to greater
than 2 mg/L.
5.3 Hydrogeologic Site Characteristics
Based on a review of soil boring and monitoring well installation logs (ash basin voluntary and
compliance wells) provided by Duke Energy, subsurface stratigraphy consists of the following
material types: fill, ash, alluvium, residual soil, saprolite, partially weathered/fractured rock
(PWR), and bedrock. In general, saprolite, PWR, and bedrock were encountered on most areas
of the site. Bedrock was encountered across the site ranging in depth below ground surface
from 36 feet on the northwest extent of the site to 94 feet along the western extent of the site
and to approximately 85 feet on the southeastern extent of the site near Lake Norman. The
general stratigraphic units, in sequence from the ground surface down to boring termination, are
defined as follows:
• Fill — Fill material generally consisted of re -worked silts and clays that were borrowed
from one area of the site and re -distributed to other areas. Fill was used in the
construction of dikes and presumably as cover for the landfill and structural fill areas.
• Ash — Although previous exploration activities, for which Duke Energy provided boring
logs, did not evaluate ash management areas of the site, ash is expected to be present
within the ash basin, ash landfill areas, and the structural fill area.
• Alluvium — Alluvium was not encountered in the boring information provided to HDR.
However, alluvium is expected to be present beneath the southeastern portion of the ash
15

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
5.0 Initial Conceptual Site Model
basin where streams likely existed and flowed toward the Catawba River prior to
construction of the ash basin. Alluvium is unconsolidated soil and sediment that has
been eroded and re -deposited by streams and rivers.
• Residual Soil- The soil that develops in -place and generally consists of white, yellow,
red, brown, gray, or olive sandy clay to silty sand. This unit was encountered in various
thicknesses across the site. The residual soil horizon grades into saprolite at depth.
• Saprolite - Saprolite develops by the in -place chemical weathering of igneous and
metamorphic rocks. Saprolite is characterized by the preservation of structures that
were present in the unweathered parent bedrock. This unit was found in areas across
the site and was described as white, brown, orange, yellow, red, gray, or greenish -brown
silty sand, course to fine sand, and sandy silt with manganese staining, some quartz
rock fragments, and trace mica.
• Partially Weathered Rock (PWR) - PWR occurs between the saprolite and bedrock
and contains saprolite and rock remnants. This unit was described as white, black, gray,
and green medium to very fine sand and sandy silty clay with some rock fragments and
manganese staining.
• Bedrock - Bedrock was encountered in borings completed around the western,
northern, and southeastern extents of the ash basin. Depth to top of bedrock ranged
from 36 feet to 94 feet below ground surface. Bedrock was described as biotite gneiss,
quartz-sericite schist, and granite.
Hydraulic conductivity in these hydrostratigraphic units can vary, but is generally thought to fall
within the ranges provided in the table below where Kh refers to hydraulic conductivity in the
horizontal direction and Kv refers to hydraulic conductivity in the vertical direction:
Hydrostratigraphic Unit Range of k Values (cm/sec)
Fill (Kh)`
Ash (Kh)''3
Ash (Kv)4
Alluvium (Kh)''3
Residual Soil/Saprolite (Kh)''3
Partially Weathered/ Fractured Rock —
TZ (Kh)''3
Bedrock (Kh)''3
1.0E-06 to 1.0E-04
1.0E-06 to 1.0 E-04
2.8E-05 to 1.17E-04
1.31 E-06 to 2.72E-03
9.67E-07 to 1.79E-02
1.92E-06 to 3.3E-02
1.78E-07 to 9.89E-03
Notes:
1. Data from in -situ permeability tests at ash basins located within the Carolina Piedmont.
2. Estimates for F (fill) based on data that indicates the 'k' for fill is about an order of magnitude lower than
the in -situ material used for the fill (after compaction).
3. Hydraulic Conductivity Database - HDR (unpublished data).
4. Hydraulic Conductivity data from site -specific laboratory testing of Shelby tube samples from Buck Steam
Station (HDR, 2014C)
As the site is located in the Piedmont, it is anticipated that the groundwater flow will be primarily
in the saprolite and the transition zone material with flow also occurring in the fractured or
weathered zones in bedrock. The sampling and testing proposed in Section 7 will provide
additional information on the transport characteristics of the materials at the site.
16

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
5.0 Initial Conceptual Site Model
Groundwater flow and transport at the MSS site are assumed to follow the local slope aquifer
system as described by LeGrand (2004). Under natural conditions the general direction of
groundwater flow can be approximated from the surface topography. A topographic divide is
located approximately along Sherrills Ford Road, to the west of the ash basin. A topographic
divide is located approximately along Island Ford Road, to the north of the ash basin. These
topographic divides likely also function as groundwater divides. Lake Norman is located to the
southeast of the ash basin. The predominant direction of groundwater flow from the ash basin is
likely in a southeasterly direction, generally towards Lake Norman.
Groundwater recharge in the Piedmont is derived entirely from infiltration of local precipitation.
Groundwater recharge occurs in areas of higher topography (i.e., hilltops) and groundwater
discharge occurs in lowland areas bordering surface water bodies, marshes, and floodplains
(LeGrand 2004). At the MSS site, groundwater recharge is expected to occur on the western
and northern portions of the site where topography is higher. Groundwater is expected to
discharge into tributary drainage features or into Lake Norman.
Following completion of the groundwater assessment work, a site conceptual model will be
developed as described in Section 7.5.
17

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
6.0 Compliance Groundwater Monitoring
6.0 Compliance Groundwater Monitoring
As described in Section 2.3, groundwater monitoring is required as a condition of the NPDES
permit. From February 2011 through June 2014, the compliance groundwater monitoring wells
at MSS have been sampled a total of 11 times. During this period, these monitoring wells were
sampled in:
• February 2011
• June 2011
• October 2011
• February 2012
• June 2012
• October 2012
• February 2013
• June 2013
• October 2013
• February 2014
• June 2014
With the exception of boron, iron, manganese, pH, sulfate, and TDS, the results for all
monitored parameters and constituents were less than the 2L Standards. Table 2 lists the range
of exceedances for boron, iron, manganese, pH, sulfate, and TDS for the period of February
2011 through June 2014.
All available groundwater quality data for compliance and voluntary monitoring wells (as
mentioned above and shown on Figure 2) are summarized in Table 6. Historical analytical data
for surface water samples, ash samples, ash Ieachate samples, industrial landfill Ieachate
samples, and FGD residue landfill Ieachate samples were provided by Duke Energy. Surface
water quality data for samples collected from the ash basin is provided in Table 7. Analytical
results for totals analyses on ash samples collected from the ash basin is provided in Table 8.
Ash Ieachate quality data for samples collected from the ash basin is provided in Table 9.
Leachate quality data for samples collected from the FGD residue landfill Ieachate management
system is provided in Table 10. Leachate quality data for samples collected from the Industrial
Landfill #1 Ieachate management system is provided in Table 11. In addition, seep analytical
results from the August 2014 seep sampling (as part of Duke Energy's NPDES permit renewal
application) are provided in Table 12.
Compliance groundwater monitoring will continue as scheduled in accordance with the
requirements of the NPDES permit.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
7.0 Assessment Work Plan
Soil and aqueous media sampling will be performed to provide information pertaining to the
horizontal and vertical extent of potential soil and groundwater contamination and to determine
physical properties of the ash and soil. Based on readily available site background information
and dependent upon accessibility, HDR anticipates collecting the following samples as part of
the subsurface exploration plan:
• Ash and soil samples from borings within and beneath the ash basin, ash landfills, and
structural fill
• Soil samples from borings located outside the ash basin, ash landfills, and structural fill
waste boundaries
• Groundwater samples from proposed monitoring wells
• Groundwater samples from select existing compliance and/or voluntary monitoring wells
• Surface water samples from water bodies located within the ash basin waste boundary
• Surface water and sediment samples from surface water location (SW-6) potentially
impacted by the ash basin due to proximity to and downgradient location from the basin
• One potential seep sample from seep location S-2 identified as part of Duke Energy's
NPDES permit renewal application (from August 2014)
In addition, hydrogeologic evaluation testing will be conducted during and following monitoring
well installation activities as described in Section 7.1.6. Existing groundwater quality data from
ash basin compliance and voluntary monitoring wells and on -site landfill monitoring wells will be
used to supplement data obtained from this assessment work. In addition, existing landfill
leachate data will be used in the evaluation of data obtained from this assessment work.
A summary of the proposed exploration plan including estimated sample quantities and
estimated depths of soil borings and monitoring wells is presented in Table 3. The proposed
well and boring locations are shown on Figure 3.
Groundwater samples collected from existing ash basin compliance monitoring wells MW-11 D,
MW-12D, and MW-13S are located at or close to the western Duke Energy property boundary
and have shown exceedances of the 2L Standard for iron. Upon approval of the work plan, HDR
proposes to perform an evaluation of these exceedances with respect to turbidity and to
naturally occurring background conditions. If that evaluation finds the exceedances are caused
by turbidity, the well(s) will be redeveloped and replaced, if required, as described in Section
7.2.1. If that evaluation finds that the exceedances are not caused by turbidity or naturally
occurring conditions, then additional monitoring wells will be installed to delineate the extent of
the exceedances. The proposed potential locations would not be located on Duke Energy
property and would require permission from adjacent property owners. The proposed potential
locations of these wells are shown on Figure 3. The installation depths of the well screens will
be determined based on site conditions and the depth of the compliance wells with the
exceedance.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin
7.0 Assessment Work Plan
If it is determined that additional investigations are required during the review of existing data or
data developed from this assessment, Duke Energy and HDR will notify the NCDENR regional
office prior to initiating additional sampling or investigations.
7.1 Subsurface Exploration
Characterization of subsurface materials will be conducted through the completion of soil
borings and borings performed for installation of monitoring wells as shown on Figure 3.
Installation details for soil borings and monitoring wells, as well as estimated sample quantities
and depths, are described below and presented in Table 3.
For nested monitoring wells, the deep monitoring well boring will be utilized for characterization
of subsurface materials and collection of samples for laboratory analysis. Shallow, deep, and
bedrock monitoring well borings will be logged in the field as described below.
At the conclusion of well installation activities, well construction details including casing depth,
total well depth, and well screen length, slot size, and placement within specific
hydrostratigraphic units will be presented in tabular form for inclusion into the final CSA Report.
Well completion records will be submitted to NCDENR within 30 days of completion.
Duke Energy acknowledges that subsurface geophysics may be useful for evaluation of
subsurface conditions in areas of the site that have not been significantly reworked by
construction or ash management activities, but less useful in basins and fills. Subsequent to
evaluation of field data obtained during the proposed investigation activities, Duke Energy will
evaluate the need for and potential usefulness of subsurface geophysics in select areas of the
site. If it is determined that subsurface investigation is warranted, Duke Energy and HDR will
notify the NCDENR regional office prior to initiating additional investigations.
7.1.1 Ash and Soil Borings
Characterization of ash and underlying soil will be accomplished through the completion and
sampling of borings advanced at 21 monitoring well locations within the ash basin and on the
ash basin dike (designated as AB-1 through A13-21), 4 monitoring well locations within and
immediately adjacent to the ash landfill areas (designated as AL-1 through AL-4), and 15 soil
boring locations in the ash basin and structural fill area (designated as SB-1 through SB-15). In
addition, 12 soil borings (designated as GWA-1 through GWA-9 and BG-1 through BG-3) will be
completed outside of ash management areas to provide additional soil quality data.
Note that Duke Energy will notify the Division of Waste Management (DWM) prior to installing
proposed borings/monitoring wells located adjacent to and within the permitted Dry Ash Landfill
(designated as AL-1 S/D, AL-2S/D, AL-3S/D, and AL-4D) and within the Structural Fill
(designated as S13-2 through S13-9 and AB-20S/D).
Field data collected during boring advancement will be used to evaluate:
• Presence or absence of ash
• Areal extent and depth/thickness of ash
20

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
• Groundwater flow and transport characteristics if groundwater is encountered
Borings will be advanced using hollow stem auger or roller cone drilling techniques to facilitate
collection of down -hole data. Standard Penetration Testing (SPT) (ASTM D 1586) and
split -spoon sampling will be performed at 5-foot increments using an 18-inch split -spoon
sampler. Soil borings located within the ash basin and structural fill that will not be used for
installation of monitoring wells (SIB-1 through SIB-1 5) will extend approximately 20 feet below the
ash/native soil interface or to refusal, whichever is encountered first. Note that continuous coring
will be performed from auger refusal to a depth of at least 50 feet into competent bedrock for
bedrock monitoring well borings (designated as BR soil boring/groundwater monitoring well
locations on Figure 3).
Borings will be logged and ash/soil samples will be photographed, described, and visually
classified in the field for origin, consistency/relative density, color, and soil type in accordance
with the Unified Soil Classification System (ASTM D2487/D2488).
BORINGS WITHIN ASH BASIN, ASH LANDILL, AND STRUCTURAL FILL AREAS
In areas where ash is known or suspected to be present (i.e., AB-, AL-, and S-borings), solid
phase samples will be collected for laboratory analysis from the following intervals in each
boring:
• Shallow Ash — approximately 3 feet to 5 feet bgs
• Deeper Ash — approximately 2 feet above the ash/soil interface
• Upper Soil — approximately 2 feet below the ash/soil interface
• Deeper Soil — approximately 8 feet to 10 feet below the ash/soil interface
If ash is observed to be greater than 30 feet thick, a third ash sample will be collected from the
approximate mid -point depth between the shallow and deeper samples. The ash samples will
be used to evaluate geochemical variations in ash located in the ash basin, ash landfill, or
structural fill. The upper and deeper soil samples will be used to delineate the vertical extent of
potential soil impacts beneath the ash basin, ash landfill, and structural fill.
Ash and soil samples will be analyzed for total inorganic compounds as presented in Table 4.
Select ash samples will be analyzed for leachable inorganic compounds using the Synthetic
Precipitation Leaching Procedure (SPLP) to evaluate the potential for leaching of constituents
from ash into underlying soil. The ash SPLP analytical results will be compared to Class GA
Standards as found in 15A NCAC 02L .0202 Groundwater Quality Standards, last amended on
April 1, 2013 (2L Standards).
Ash is located at varying depths beneath the ponded water areas within the ash basin. Due to
safety concerns, borings will not be completed where ponded water is present within the ash
basin. Safety concerns may also prevent access to proposed boring locations on ash areas
where saturated ash presents stability issues.
21

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
BORINGS OUTSIDE ASH BASIN, ASH LANDILL, AND STRUCTURAL FILL AREAS
Borings located outside the ash basin, ash landfill, and structural fill are designated as GWA
and BG borings.
The GWA soil samples will be used to provide additional characterization of soil conditions
outside the ash basin, ash landfill, and structural fill. Solid phase samples will be collected for
laboratory analysis from the following intervals in each boring:
• Approximately 2 feet to 3 feet above the water table
• Approximately 2 feet to 3 feet below the water table
• Within the saturated upper transition zone material (if not already included in the two
sample intervals above)
• From a primary, open, stained fracture within fresh bedrock if existent (bedrock core
locations only)
The boring locations designated as BG borings will be used to evaluate site -specific background
soil quality. Solid phase samples will be collected for laboratory analysis from the following
intervals in each boring:
• At approximately 10-foot intervals until reaching the water table (i.e., 0 feet to 2 feet, 10
feet to 12 feet, 20 feet to 22 feet, and so forth)
• Approximately 2 feet to 3 feet above the water table
• Approximately 2 feet to 3 feet below the water table
• Within the saturated upper transition zone material (if not already included in the two
sample intervals above)
• From a primary, open, stained fracture within fresh bedrock if existent (bedrock core
locations only)
The laboratory analyses performed on the GWA and BG samples will depend on the nature and
quantity of material collected.
One or more of the above listed sampling intervals may be combined if field conditions indicate
they are in close proximity to each other (i.e., one sample will be obtained that will be applicable
to more than one interval).
INDEX PROPERTY SAMPLING AND ANALYSES
In addition, physical properties of ash and soil will be tested in the laboratory to provide data for
use in groundwater modeling. Split -spoon samples will be collected at selected locations with
the number of samples collected from the material types as follows:
• Fill — 5 samples
• Ash — 5 samples
• Alluvium — 5 samples
• Soil/Saprolite — 5 samples
• Soil/Saprolite (immediately above refusal) — 5 samples
Select split -spoon samples will be tested for:
22

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
Natural Moisture Content Determination in accordance with ASTM D-2216
• Grain size with hydrometer determination in accordance with ASTM Standard D-422
The select split -spoon samples are anticipated to be collected from the following boring
locations:
• Fill — AB-1 S/D (two samples) and AB-2S/D (three samples)
• Ash — AB-4S/D, AB-6S/D, AB- 12S/D, AB-15S/D, AB-20S/D, and AL-2S/D
• Alluvium (if present) — AB-1 S/D, AB-2S/D, and SB-1
• Soil/Saprolite (two locations each as stated above) — AB-2S/D, AB-6S/D, AB-12S/D,
GWA-3 S/D, and GWA-6S/D
The depth intervals of the select split -spoon samples will be determined in the field by the Lead
Geologist/Engineer.
In addition to split -spoon sampling, a minimum of five thin -walled undisturbed tubes ("Shelby"
tubes) in fill, ash, and soil/saprolite layers will be collected from the above -referenced boring
locations. Sample depths will be determined in the field based on conditions encountered during
borehole advancement. The Shelby tubes will be transported to a soil testing laboratory and
each tube will be tested for the following:
• Natural Moisture Content Determination in accordance with ASTM D-2216
• Grain size with hydrometer determination in accordance with ASTM Standard D-422
• Hydraulic Conductivity Determination in accordance with ASTM Standard D-5084
• Specific Gravity of Soils in accordance with ASTM Standard D-854
The results of the laboratory soil and ash property determination will be used to determine
additional soil properties such as porosity, transmissivity, and specific storativity. The results
from these tests will be used in the groundwater fate and transport modeling. The specific
borings where these samples are collected from will be determined based on field conditions
with consideration given to their location relative to use in the groundwater model.
7.1.2 Shallow Monitoring Wells
SHALLOW MONITORING WELLS IN REGOLITH
Groundwater quality and flow characteristics within the regolith aquifer will be evaluated through
the installation, sampling, and testing of 35 shallow monitoring wells at the locations specified
on Figure 3 with an "S" qualifier in the well name (e.g., AB-1 S). Shallow monitoring wells are
defined as wells that are screened wholly within the regolith zone or ash and set to bracket the
water table surface at the time of installation.
Shallow monitoring wells will be installed using hollow stem auger or roller cone drilling
techniques. At each monitoring well location, a shallow well will be constructed with a 2-inch-
diameter, Schedule 40 polyvinyl chloride (PVC) screen and casing. Each of these wells will
have a 10-foot to 15-foot pre -packed well screen having manufactured 0.010-inch slots.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
In the event that the regolith zone is found to be relatively thick at a particular well location and
that more than one discreet flow zone is observed during drilling (e.g., presence of confining
unit), a second shallow monitoring well will be installed to provide groundwater flow and quality
data for upper and lower flow zones. In these instances, the wells installed into the lower flow
zones will be designated with an "SL" identifier to differentiate between the upper and lower
shallow wells located in the regolith zone.
In addition, one observation well, OW-1(WLO), will be installed to characterize groundwater flow
direction at the location shown on Figure 3. The observation well will be installed with the same
methods and to the same specifications as shallow monitoring wells.
SHALLOW MONITORING WELLS IN DAMS
Groundwater quality and flow characteristics of the phreatic surface within the ash basin dam
not founded on ash will be evaluated through the installation, sampling, and testing of 2 shallow
monitoring wells at the locations specified on Figure 3 with an "S" qualifier in the well name
(AB-1S and A13-2S). Wells will be installed with 10-foot to15-foot screens set to bracket the
phreatic surface at the time of installation.
Shallow monitoring wells will be installed using hollow stem auger or roller cone drilling
techniques. At each monitoring well location, a shallow well will be constructed with a 2-inch-
diameter, Schedule 40 PVC screen and casing. Each of these wells will have a 10-foot to
15-foot pre -packed well screen having manufactured 0.010-inch slots.
SHALLOW MONITORING WELLS IN ASH BASIN POREWATER
The water quality and flow characteristics within the ash basin porewater will be evaluated
through the installation, sampling, and testing of 4 porewater wells at the locations specified on
Figure 3. Wells designated as "S" will be installed with 10-foot to 15-foot screens with the well
screen set to bracket the water table surface at the time of installation. Wells designated as "SL
will be installed with the bottom of the well screen set above the ash-regolith interface and will
be installed with 10-foot screens.
These wells will be installed using hollow stem auger or roller cone drilling techniques. The wells
will be constructed with 2-inch-diameter, Schedule 40 PVC screen and casing. These wells will
be installed with pre -packed well screens having manufactured 0.010-inch slots
7.1.3 Deep Monitoring Wells
Groundwater quality and flow characteristics within the transition zone (if present) will be
evaluated through the installation, sampling, and testing of 36 deep monitoring wells at the
locations specified on Figure 3 with a "D" qualifier in the well name (e.g., AB-1 D). Deep
monitoring wells are defined as wells that are screened within the partially weathered/fractured
bedrock transition zone at the base of the regolith.
Deep monitoring wells will be installed using hollow stem augers and rock coring drilling
techniques. At each deep monitoring well location, a double -cased well will be constructed with
a 6-inch-diameter PVC outer casing and a 2-inch-diameter PVC inner casing and well screen.
The purpose of installing cased wells at the site is to prevent possible cross -contamination of

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
flow zones within the shallow and deeper portions of the unconfined aquifer during well
installation. Outer well casings (6-inch casing) will be advanced to auger refusal and set
approximately 1 foot into PWR (if present). Note that location -specific subsurface geology will
dictate actual casing depths on a per -well basis. The annulus between the borehole and casing
will be grouted to the surface using the tremie grout method. After the grout has been allowed to
cure for a period of 24 hours, the borehole will be extended via coring approximately 10 feet to
15 feet into transition zone rock using an HQ core barrel. A 2-inch-diameter well with a 5-foot
pre -packed well screen will be set at least 2 feet below the bottom of the outer casing.
If the PWR thickness is determined to be greater than 30 feet thick at a nested well location,
additional wells in the transition zone will be considered based on site -specific conditions.
Rock cores will be logged in accordance with the Field Guide for Rock Core Logging and
Fracture Analysis by Midwest GeoSciences Group. Percent recovery and rock quality
designation (RQD) will be calculated in the field. The cores will be photographed and retained.
7.1.4 Bedrock Monitoring Wells
Groundwater quality and flow within fractured bedrock beneath the site will be evaluated
through the installation, sampling, and testing of 5 bedrock monitoring wells at the locations
specified on Figure 3 with a "BR" qualifier in the name (e.g., GWA-1 BR). Bedrock monitoring
wells are defined as wells that are screened across water -bearing fractures wholly within fresh,
competent bedrock.
At these locations, continuous coring will be performed from auger refusal to a depth of at least
50 feet into competent bedrock. Packer testing will be performed on select fractures observed in
the rock cores. See Section 7.1.6 for details regarding packer test implementation.
Water source(s) to be used in rock coring and packer testing will be sampled for all constituents
included in Table 5 before use.
Rock cores will be logged in accordance with the Field Guide for Rock Core Logging and
Fracture Analysis by Midwest GeoSciences Group. Percent recovery and RQD will be
calculated in the field. The cores will be photographed and retained.
At each of these locations, a double -cased well will be constructed with a 6-inch-diameter PVC
outer casing and a 2-inch-diameter PVC inner casing and well screen. Outer well casings will be
advanced through the transition zone and set approximately 1 foot into competent bedrock. The
annulus between the borehole and casing will be grouted to the surface using the tremie grout
method. After the grout has been allowed to cure for a period of 24 hours, the borehole will be
extended via coring approximately 50 feet into competent bedrock using an HQ core barrel. A
2-inch-diameter well with a 5-foot pre -packed well screen will be set at depth across an
interpreted water -bearing fracture or fracture zone based on the results of packer testing. Note
that location -specific subsurface geology will dictate actual casing depths and screen placement
on a per -well basis.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
7.1.5 Well Completion and Development
WELL COMPLETION DETAILS
As described above, pre -packed screens will be installed around the monitoring well screens to
reduce turbidity during sample collection. The pre -packed screens will consist of environmental
grade sand contained within a stainless steel wire mesh cylinder. The sand gradation in the pre -
packed screen will be made in advance anticipating a wide range of site conditions; however,
HDR believes that the sand will typically be 20/40 mesh silica sand. The Geologist/Engineer
involved with the specific installation will evaluate field conditions and determine if changes are
required. A minimum one foot to two foot thick bentonite seal hydrated with potable water will be
placed above the pre -packed screen. Cement grout will be placed in the annular space between
the PVC casing and the borehole above the bentonite seal and extending to the ground surface.
Each well will be finished at the ground surface with a 2-foot square concrete well pad and new
4-inch or 8-inch steel above -grade lockable covers. Following completion, all wells will be locked
with a keyed pad lock.
WELL DEVELOPMENT
All newly installed monitoring wells will be developed to create an effective filter pack around the
well screen and to remove fine particles within the well from the formation near the borehole.
Based on site -specific conditions per 15A NCAC 02C .0108(p), appropriate measures (e.g.,
agitation, surging, pumping, etc.) will be utilized to stress the formation around the screen and
the filter pack so that mobile fines, silts, and clays are pulled into the well and removed.
Water quality parameters (specific conductance, pH, temperature, oxidation reduction potential
[ORP], and turbidity) will be measured and recorded during development and should stabilize
before development is considered complete. Development will continue until development water
is visually clear (< 10 Nephelometric Turbidity Units [NTU] Turbidity) and sediment free.
If a well cannot be developed to produce low turbidity (< 10 NTU) groundwater samples,
NCDENR will be notified and supplied with the well completion and development measures that
have been employed to make a determination if the turbidity is an artifact of the geologic
materials in which the well is screened.
Following development, sounding the bottom of the well with a water level meter should indicate
a "hard" (sediment -free) bottom. Development records will be prepared under the direction of
the Project Scientist/Engineer and will include development method(s), water volume removed,
and field measurements of temperature, pH, conductivity, and turbidity.
7.1.6 Hydrogeologic Evaluation Testing
In order to better characterize hydrogeologic conditions at the site, falling and constant head
tests, packers tests, and slug tests will be performed as described below. Data obtained from
these tests will be used in groundwater modeling. In addition, historical soil boring data at the
site will be utilized as appropriate to better characterize hydrogeologic conditions and will be
used for groundwater modeling. All water meters, pressure gages, and pressure transducers
will be calibrated per specifications for testing.
26

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
FALLING/CONSTANT HEAD TESTS
A minimum of five in -situ borehole horizontal permeability tests, either falling or constant head
tests, will be performed just below refusal in the upper bedrock (transition zone if present). In
each of the hydrostratigraphic units above refusal; ash, fill, alluvium, and soil/saprolite (if
present), a minimum of ten falling or constant head tests (five for vertical permeability and five
for horizontal permeability) will be performed. The tests will be at locations based on
site -specific conditions at the time of assessment work. The U.S. Bureau of Reclamation (1995)
test method and calculation procedures as described in Chapter 10 of their Ground Water
Manual (2nd Edition) will be used.
PACKER TESTS
A minimum of five packer tests using a double packer system will be performed in deep
well/transition zone borings at locations based on site -specific conditions as well as a minimum
of one packer test in each soil/rock core well boring as described in Section 7.1.4 after
completion of the holes. Packer tests will utilize a double packer system and the interval (5 or 10
feet based on field conditions) to be tested will be based on observation of the rock core and will
be selected by the Lead Geologist/Engineer. The U.S. Bureau of Reclamation (1995) test
method and calculation procedures as described in Chapter 10 of their Ground Water Manual
(2nd Edition) will be used.
SLUG TESTS
Hydraulic conductivity (slug) tests will be completed in all installed monitoring wells under the
direction of the Lead Geologist/Engineer. Slug tests will be performed to meet the requirements
of the NCDENR Memorandum titled "Performance and Analysis of Aquifer Slug Tests and
Pumping Tests Policy" dated May 31, 2007. Water level change during the slug tests will be
recorded by a data logger. The slug test will be performed for no less than 10 minutes or until
such time as the water level in the test well recovers 95 percent of its original pre -test level,
whichever occurs first. Slug tests will be terminated after 2 hours even if the 95 percent pre -test
level is not achieved. Slug test field data will be analyzed using the Aqtesolv (or similar)
software using the Bouwer and Rice method.
7.2 Groundwater Sampling and Analysis
Subsequent to monitoring well installation and development, each newly installed well will be
sampled using low -flow sampling techniques in accordance with USEPA Region 1 Low Stress
(low flow) Purging and Sampling Procedure for the Collection of Groundwater Samples from
Monitoring Wells (revised January 19, 2010). The purposes of the proposed monitoring wells
are as follows:
AB -series Wells —The AB -series well locations were selected to provide water quality
data in and beneath the active ash basin
AL -series Wells — The AL -series well locations were selected to provide water quality
data beneath and adjacent to the ash landfill areas located along the east/northeast
extents of the ash basin (i.e., to evaluate potentially impacted groundwater beneath the
ash landfills and adjacent to the ash basin)
27

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
GWA-series Wells — The GWA-series well locations were selected to provide water
quality data beyond the ash basin waste boundary for use in groundwater modeling (i.e.,
to evaluate the horizontal and vertical extent of potentially impacted groundwater outside
the ash basin waste boundary)
OB-series wells — OB-1 will be installed for measuring water levels only (no water quality
samples) between two outer portions of the western extent of the ash basin. The
purpose of OB-1 is to characterize groundwater flow in this area.
BG-series Wells — These wells will be used to provide information on background water
quality and soil conditions. The background well locations were selected to provide
additional physical separation from possible influence of the ash basin on groundwater.
These wells will also be useful in the statistical analysis to determine the site -specific
background water quality concentrations (SSBCs).
During low -flow purging and sampling, groundwater is pumped into a flow -through chamber at
flow rates that minimize or stabilize water level drawdown within the well. Indicator parameters
are measured over time (usually at 5-minute intervals). When parameters have stabilized within
±0.2 pH units and ±10 percent for temperature, conductivity, and dissolved oxygen (DO), and
±10 millivolts (mV) for ORP over three consecutive readings, representative groundwater has
been achieved for sampling. Turbidity levels of 10 NTU or less will be targeted prior to sample
collection. Purging will be discontinued and groundwater samples will be obtained if turbidity
levels of 10 NTU or less are not obtained after 2 hours of continuous purging. Groundwater
samples will be analyzed by a North Carolina certified laboratory for the constituents included in
Table 11. Select constituents will be analyzed for total and dissolved concentrations.
In 2014, the Electric Power Research Institute published the results of a critical review that
presented the current state -of -knowledge concerning radioactive elements in CCPs and the
potential radiological impacts associated with management and disposal. The review found:
Despite the enrichment of radionuclides from coal to ash, this critical review did not
locate any published studies that suggested typical CCPs posed any significant
radiological risks above background in the disposal scenarios considered, and when
used in concrete products. These conclusions are consistent with previous
assessments. The USGS (1997) concluded that "Radioactive elements in coal and fly
ash should not be sources of alarm. The vast majority of coal and the majority of fly ash
are not significantly enriched in radioactive elements, or in associated radioactivity,
compared to common soils or rocks."A year later, the U. S. EPA (1998) concluded that
the risks of exposure to radionuclide emissions from electric utilities are "substantially
lower than the risks due to exposure to background radiation."
Duke Energy proposes to sample voluntary monitoring wells MW-6S and MW-7S and the
proposed background wells BG-1 S/D for total combined radium (Ra-226 and Ra-228) and will
consult with the DWR regional office to determine if additional wells are to be sampled.
Groundwater sample results will be compared to Class GA Standards as found in 15A NCAC
02L .0202 Groundwater Quality Standards, last amended on April 1, 2013 (2L Standards).
28

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
Redox conditions are not likely to be strong enough to produce methane at the site; therefore,
methane was not included in the constituent list (Table 5).
7.2.1 Existing Compliance and Voluntary Monitoring Wells
Groundwater samples will be collected from selected existing voluntary and/or compliance
monitoring wells. Prior to collecting groundwater samples from the existing voluntary and/or
compliance monitoring wells, the historical turbidity values at each of the wells will be evaluated
For wells where turbidity levels have historically been greater than 10 NTUs, these wells will be
re -developed, as described above, prior to collecting groundwater samples. If redevelopment
does not result in reduced turbidity, the well(s) will be replaced. The DWR regional office will be
contacted prior to replacing a compliance monitoring well.
7.2.2 Speciation of Select Inorganics
In addition to total analytes, speciation of select inorganics will be conducted for select sample
locations to characterize the aqueous chemistry and geochemistry in locations and depths of
concern. Speciation of iron (Fe(II), Fe(III)) and manganese (Mn(II), Mn(IV)) will be conducted in
pore water samples collected from upper and lower elevations of ash within the basin and in
groundwater samples collected from wells outside and downgradient of the ash basin.
Specifically, Duke Energy proposes to speciate iron and manganese in pore water and
groundwater samples collected from proposed wells AB-4S/SL/D, AB-12S/SL/D and AB-
15S/SL/D, in groundwater samples collected from compliance wells MW-4, MW-4D, MW-10S,
MW-10D, MW-12S, MW-12D, MW-14S and MW-14D, and in groundwater samples collected
from proposed wells AB-1 S/D and BG-1 S/D. Laboratory analyses will be performed in
accordance with the methods provided in Table 5.
7.3 Surface Water, Sediment, and Seep Sampling
7.3.1 Surface Water Samples
WITHIN ASH BASIN
Surface water samples will be collected from the ash basin at the approximate open water
locations shown on Figure 3 (SW-1 through SW-5). At each location, two water samples will be
collected —one sample close to the surface (i.e., 0 foot to 1 foot from surface) and one sample
at the approximate middle depth of the water body. Prior to sampling, the depth to ash will be
measured by slowly lowering a measuring stick or tape until the ash surface is encountered,
being careful to avoid suspending the ash. The depth to ash will be noted, and a sample thief
will be slowly lowered to the desired depth to collect the sample. The sample thief and sample
will be retrieved and the sample will be transferred to the appropriate sample containers
provided by the laboratory. The middle depth sample will vary based on the water level in the
water body. In areas where the water body is less than 5 feet deep, one water sample will be
collected from the location at the approximate middle depth of the water body. Ash basin
surface water samples will be analyzed for the same constituents as groundwater samples
(Table 5). Select constituents will be analyzed for total and dissolved concentrations.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
Ash is located beneath the water in the ash basin at the proposed locations for surface water
samples SW-1 and SW-2. The water body where surface water sample SW-3 is proposed is
used for the plant's ash handling system and the water level fluctuates daily. Surface water
samples SW-4 and SW-5 are proposed in water bodies that contain mainly pyrites beneath the
water. It is expected that some ash is located beneath the ponded water where SW-3, SW-4,
and SW-5 are proposed.
OUTSIDE ASH BASIN
One water sample will be collected from the surface water located southeast of the ash basin
(SW-6) shown on Figure 3. This surface water sample will be analyzed for the same
constituents as groundwater samples (Table 5). Select constituents will be analyzed for total
and dissolved concentrations.
A water sample was previously collected from the proposed location SW-6 in September 2014
as part of Duke Energy's NPDES permit renewal application package. The sample location was
referred to as S-1 for the September 2014 sampling event. The analytical results indicated
exceedances of 2B Standards for several constituents: iron, manganese, sulfate, and TDS.
Duke Energy collects surface water samples from Lake Norman from upstream and
downstream locations for their existing NPDES permit requirements. If water sample analytical
results indicate potential for impacts to Lake Norman, then surface water quality data collected
in Lake Norman will be reviewed.
Analytical results for surface water samples collected from outside the ash basin will be
compared to 15A NCAC 213 .0200 Classifications and Water Quality Standards Applicable to
Surface Waters and Wetlands of North Carolina (21B Standards), from the DWR, and EPA
Criteria Table, last amended on May 15, 2013
7.3.2 Seep Samples
A potential seep sample location was previously identified east of the ash basin dam (S-2) as
shown on Figure 3. During the July and August 2014 seep sampling event performed as part of
Duke Energy's NPDES permit renewal application, there was no flow and, therefore, the
potential seep sampling location was not sampled. If there is seep flow that will allow for proper
sample collection at the time of this assessment work, a seep sample will be collected from the
S-2 location. If collected, the seep sample will be analyzed for the constituents listed in Table 5.
Select constituents will be analyzed for total and dissolved concentrations.
In March 2014, DENR conducted seep sampling at the site. HDR does not currently have the
analytical results from this sampling event; however, once data is received, HDR will review the
data and determine if changes to the proposed seep locations are needed.
Analytical results from the potential seep sampling will be reviewed to determine if similar
speciation analyses as described in Section 7.2.3 are to be performed for the potential seep
location.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
After analytical results for seep samples are reviewed, a determination will be made concerning
collection of additional off -site seep samples. If it is determined that additional off site seep
samples are to be collected, the DWR regional office will be contacted.
7.3.3 Sediment Samples
Due to the exceedances of 2B Standards at surface water sample location SW-6 (referred to as
S-1 for September 2014 sampling event), one sediment sample will be collected from the bed
surface of the surface water at this location. The streambed sediment sample will be analyzed
for total inorganics using the same constituents list proposed for the soil and ash samples
(Table 4).
In addition, a sediment sample will be collected in conjunction with seep sample S-2 if seep flow
allows for a proper seep sample to be collected. If collected, the sediment sample will be
analyzed for total inorganics using the same constituents list proposed for the soil and ash
samples (Table 4)
Due to safety concerns, sediment samples will not be collected at this time where open water or
ponded water is present within the ash basin.
7.4 Field and Sampling Quality Assurance/Quality Control
Procedures
Documentation of field activities will be completed using a combination of logbooks, field data
records (FDRs), sample tracking systems, and sample custody records. Site and field logbooks
are completed to provide a general record of activities and events that occur during each field
task. FDRs have been designated for each exploration and sample collection task to provide a
complete record of data obtained during the activity.
7.4.1 Field Logbooks
The field logbooks provide a daily hand written account of field activities. Logbooks are
hardcover books that are permanently bound. All entries are made in indelible ink, and
corrections are made with a single line with the author initials and date. Each page of the
logbook will be dated and initialed by the person completing the log. Partially completed pages
will have a line drawn through the unused portion at the end of each day with the author's
initials. The following information is generally entered into the field logbooks:
• The date and time of each entry. The daily log generally begins with the Pre -Job Safety
Brief.
• A summary of important tasks or subtasks completed during the day
• A description of field test completed in association with the daily task
• A description of samples collected including documentation of any quality control
samples that were prepared (rinse blanks, duplicates, matrix spike, split samples, etc.)
• Documentation of equipment maintenance and calibration activities
• Documentation of equipment decontamination activities

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
• Descriptions of deviations from the work plan
7.4.2 Field Data Records
Sample FDRs contain sample collection and/or exploration details. A FDR is completed each
time a field sample is collected. The goal of the FDR is to document exploration and sample
collection methods, materials, dates and times, and sample locations and identifiers. Field
measurements and observations associated with a given exploration or sample collection task
are recorded on the FDRs. FDRs are maintained throughout the field program in files that
become a permanent record of field program activities.
7.4.3 Sample Identification
In order to ensure that each number for every field sample collected is unique, samples will be
identified by the sample location and depth interval, if applicable (e.g., AB-1 S (5-6). Samples
will be numbered in accordance with the proposed sample IDs shown on Figure 3.
7.4.4 Field Equipment Calibration
Field sampling equipment (e.g., water quality meter) will be properly maintained and calibrated
prior to and during continued use to ensure that measurements are accurate within the
limitations of the equipment. Personnel will follow the manufacturers' instructions to determine if
the instruments are functioning within their established operation ranges. The calibration data
will be recorded on a FDR.
To be acceptable, a field test must be bracketed between acceptable calibration results.
• The first check may be an initial calibration, but the second check must be a continuing
verification check
• Each field instrument must be calibrated prior to use
• Verify the calibration at no more than 24-hour intervals during use and at the end of the
use if the instrument will not be used the next day or time periods greater than 24 hours
• Initial calibration and verification checks must meet the acceptance criteria
recommended by each instrument manufacturer
• If an initial calibration or verification check fails to meet the acceptance criteria,
immediately recalibrate the instrument or remove it from service
• If a calibration check fails to meet the acceptance criteria and it is not possible to
reanalyze the samples, the following actions must be taken:
- Report results between the last acceptable calibration check and the failed
calibration check as estimated (qualified with a "J")
- Include a narrative of the problem
- Shorten the time period between verification checks or repair/replace the instrument
• If historically generated data demonstrate that a specific instrument remains stable for
extended periods of time, the interval between initial calibration and calibration checks
may be increased
32

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
Acceptable field data must be bracketed by acceptable checks. Data that are not
bracketed by acceptable checks must be qualified.
Base the selected time interval on the shortest interval that the instrument maintains
stability
If an extended time interval is used and the instrument consistently fails to meet the
final calibration check, then the instrument may require maintenance to repair the
problem or the time period is too long and must be shortened
• For continuous monitoring equipment, acceptable field data must be bracketed by
acceptable checks or the data must be qualified
Sampling or field measurement instrument determined to be malfunctioning will be repaired or
will be replaced with a new piece of equipment.
7.4.5 Sample Custody Requirements
A program of sample custody will be followed during sample handling activities in both field and
laboratory operations. This program is designed to ensure that each sample is accounted for at
all times. The appropriate sampling and laboratory personnel will complete sample FDRs, chain -
of -custody records, and laboratory receipt sheets.
The primary objective of sample custody procedures is to obtain an accurate written record that
can trace the handling of all samples during the sample collection process, through analysis,
until final disposition.
FIELD SAMPLE CUSTODY
Sample custody for samples collected during each sampling event will be maintained by the
personnel collecting the samples. Each sampler is responsible for documenting each sample
transfer, maintaining sample custody until the samples are shipped off -site, and sample
shipment. The sample custody protocol followed by the sampling personnel involves:
• Documenting procedures and amounts of reagents or supplies (e.g., filters) which
become an integral part of the sample from sample preparation and preservation
• Recording sample locations, sample bottle identification, and specific sample acquisition
measures on appropriate forms
• Using sample labels to document all information necessary for effective sample tracking
• Completing sample FDR forms to establish sample custody in the field before sample
shipment
Prepared labels are normally developed for each sample prior to sample collection. At a
minimum, each label will contain:
• Sample location and depth (if applicable)
• Date and time collected
• Sampler identification
• Analyses requested and applicable preservative
33

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
A manually prepared chain -of -custody record will be initiated at the time of sample collection.
The chain -of -custody record documents:
• Sample handling procedures including sample location, sample number, and number of
containers corresponding to each sample number
• The requested analysis and applicable preservative
• The dates and times of sample collection
• The names of the sampler(s) and the person shipping the samples (if applicable)
• The date and time that samples were delivered for shipping (if applicable)
• Shipping information (e.g., FedEx Air Bill)
• The names of those responsible for receiving the samples at the laboratory
Chain -of -custody records will be prepared by the individual field samplers.
SAMPLE CONTAINER PACKING
Sample containers will be packed in plastic coolers for shipment or pick up by the laboratory.
Bottles will be packed tightly to reduce movement of bottles during transport. Ice will be placed
in the cooler along with the chain -of -custody record in a separate, resealable, air tight, plastic
bag. A temperature blank provided by the laboratory will also be placed in each cooler prior to
shipment if required for the type of samples collected and analyses requested.
7.4.6 Quality Assurance and Quality Control Samples
The following Quality Assurance/Quality Control samples will be collected during the proposed
field activities:
• Equipment rinse blanks (one per day)
• Field Duplicates (one per 20 samples per sample medium)
Equipment rinse blanks will be collected from non -dedicated equipment used between wells and
from drilling equipment between soil samples. The field equipment is cleaned following
documented cleaning procedures. An aliquot of the final control rinse water is passed over the
cleaned equipment directly into a sample container and submitted for analysis. The equipment
rinse blanks enable evaluation of bias (systematic errors) that could occur due to
decontamination.
A field duplicate is a replicate sample prepared at the sampling locations from equal portions of
all sample aliquots combined to make the sample. Both the field duplicate and the sample are
collected at the same time, in the same container type, preserved in the same way, and
analyzed by the same laboratory as a measure of sampling and analytical precision.
Field QA/QC samples will be analyzed for the same constituents as proposed for the soil and
groundwater samples, as identified on Tables 4 and 5, respectively.
34

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
7.4.7 Decontamination Procedures
DECONTAMINATION PAD
A decontamination pad will be constructed for field cleaning of drilling equipment. The
decontamination pad will meet the following requirements:
• The pad will be constructed in an area believed to be free of surface contamination
• The pad will be lined with a water -impermeable material with no seams within the pad.
The material should be easily replaced (disposable) or repairable.
• If possible, the pad will be constructed on a level, paved surface to facilitate the removal
of decontamination water. This may be accomplished by either constructing the pad with
one corner lower than the rest, or by creating a lined sump or pit in one corner.
• Sawhorses or racks constructed to hold field equipment while being cleaned will be high
enough above ground to prevent equipment from being contacted by splashback during
decontamination
Decontamination water will be allowed to percolate into the ground adjacent to the
decontamination pad. Containment and disposal of decontamination water is not required.
At the completion of field activities, the decontamination pad will be removed and any sump or
pit will be backfilled with appropriate material.
DECONTAMINATION OF FIELD SAMPLING EQUIPMENT
Field sampling equipment will be decontaminated between sample locations using potable
water and phosphate and borax -free detergent solution and a brush, if necessary, to remove
particulate matter and surface films. Equipment will then be rinsed thoroughly with tap water to
remove detergent solution prior to use at the next sample location.
DECONTAMINATION OF DRILLING EQUIPMENT
Any downhole drilling equipment will be steam cleaned between boreholes. The following
procedure will be used for field cleaning augers, drill stems, rods, tools, and associated
downhole equipment.
• Hollow -stem augers, bits, drilling rods, split -spoon samplers and other downhole
equipment will be placed on racks or sawhorses at least 2 feet above the floor of the
temporary decontamination pad. Soil, mud, and other material will be removed by hand,
brushes, and potable water. The equipment will be steam cleaned using a
high-pressure, high -temperature steam cleaner.
• Downhole equipment will be rinsed thoroughly with potable water after steam cleaning
The clean equipment will then be removed from the decontamination pad and either placed on
the drill rig, if mobilizing immediately to the next boring, or placed on and covered with clean,
unused plastic sheeting if not used immediately.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
7.5 Site Hydrogeologic Conceptual Model
The data obtained during the proposed assessment will be supplemented by available reports
and data on site geotechnical, geologic, and hydrologic conditions to develop an SCM. The
scope of these efforts will depend upon site conditions and existing geologic information for the
site.
The SCM is a conceptual interpretation of the processes and characteristics of a site with
respect to the groundwater flow and other hydrologic processes at the site and will be a
refinement of the ICSM described in Section 5.0.
The NCDENR document "Hydrogeologic Investigation and Reporting Policy Memorandum"
dated May 31, 2007, will be used as general guidance. In general, components of the SCM will
consist of developing and describing the following aspects of the site: geologic/soil framework,
hydrologic framework, and the hydraulic properties of site materials. More specifically, the SCM
will describe how these aspects of the site affect the groundwater flow at the site. In addition to
these site aspects, the SCM will:
• Describe the site and regional geology
• Present longitudinal and transverse cross -sections showing the hydrostratigraphic layers
• Develop the hydrostratigraphic layer properties required for the groundwater model
• Present a groundwater contour map showing the potentiometric surface of the shallow
aquifer
• Present information on horizontal and vertical groundwater gradients
The SCM will serve as the basis for developing understanding the hydrogeologic characteristics
of the site and for developing a groundwater flow and transport model.
The historic site groundwater elevations and ash basin water elevations will be used to develop
a historic estimated seasonal high groundwater contour map for the site.
A fracture trace analysis will be performed for the site as well as on-site/near-site geologic
mapping to better understand site geology and to confirm and support the SCM.
7.6 Site -Specific Background Concentrations
Statistical analysis will be performed using methods outlined in the Resource Conservation and
Recovery Act (RCRA) Unified Guidance (USEPA, 2009, EPA 530/R-09-007) to develop SSBCs.
The SSBCs will be determined to assess whether or not exceedances can be attributed to
naturally occurring background concentrations or attributed to potential contamination.
Specifically, the relationship between exceedances and turbidity will be explored to determine
whether or not there is a possible correlation due to naturally occurring conditions and/or well
construction. Alternative background boring locations will be proposed to NCDENR if the
background wells shown on Figure 3 are found to not represent background conditions.
36

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
7.7 Groundwater Fate and Transport Model
A three-dimensional groundwater fate and transport model will be developed for the ash basin
site. The objective of the model process will be to:
Predict concentrations of the Constituents of Potential Concern (COPC) at the facility's
compliance boundary or other locations of interest over time
• Estimate the groundwater flow and loading to surface water discharge areas
• Support the development of the CSA report and the corrective action plan, if required
The model and model report will be developed in general accordance with the guidelines found
in the memorandum Groundwater Modeling Policy, NCDENR DWQ, May 31, 2007 (DENR
modeling guidelines).
The groundwater model will be developed from the SCM, from existing wells and boring
information provided by Duke Energy, and from information developed from the site
investigation. The model will also be supplemented with additional information developed by
HDR from other Piedmont sites as applicable. The SCM is a conceptual interpretation of the
processes and characteristics of a site with respect to the groundwater flow and other
hydrologic processes at the site. Development of the SCM is discussed in Section 7.5.
Although the site is anticipated in general to conform to the LeGrand conceptual groundwater
model, due to the configuration of the ash basin, the additional possible sources (structural fill
and ash landfills), and the boundary conditions present at the site, HDR believes that a three-
dimensional groundwater model would be more appropriate than performing two-dimensional
modeling. The modeling process, the development of the model hydrostratigraphic layers, the
model extent (or domain), and the proposed model boundary conditions are presented below.
7.7.1 MODFLOW/MT3DMS Model
The groundwater modeling will be performed under the direction of Dr. William Langley, PE,
Department of Civil and Environmental Engineering, University of North Carolina Charlotte
(UNCC). Groundwater flow and constituent fate and transport will be modeled using Visual
MODFLOW 2011.1 (flow engine USGS MODFLOW 2005 from SWS) and MT3DMS.
Duke Energy, HDR, and UNCC considered the appropriateness of using MODFLOW and
MT3DMS as compared to the use of MODFLOW coupled with a geochemical reaction code
such as PHREEQC. The decision to use MODFLOW and MT3DMS was based on the intensive
data requirements of PHREEQC, the complexity of developing an appropriate geochemical
model given the heterogeneous nature of Piedmont geology, and the general acceptance of
MODLFOW and MT3DMS. However, batch PHREEQC simulations may be used to estimate
sensitivity of the proposed sorption constants used with MODFLOW/MT3DMS, as described
below, if geochemistry varies significantly across the site.
Additional factors that were considered in the decision to use MT3DMS as compared to a
reaction -based code utilizing geochemical modeling were as follows:

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
Modeling the complete geochemical fate and transport of trace, minor, or major
constituents would require simultaneous modeling of the following in addition to
groundwater flow:
• All major, minor, and trace constituents (in their respective species forms) in
aqueous, equilibrium (solid), and complexed phases
• Solution pH, oxidation/reduction potential, alkalinity, dissolved oxygen, and
temperature
• Reactions including oxidation/reduction, complexation, precipitation/dissolution, and
ion exchange
2. Transient versus steady-state reaction kinetics may need to be considered. In general,
equilibrium phases for trace constituents cannot be identified by mineralogical analysis.
In this case, speciation geochemical modeling is required to identify postulated solid
phases by their respective saturation indices.
3. If geochemical conditions across the site are not widely variable, an approach that
considers each modeled COPC as a single species in the dissolved and complexed, or
sorbed, phases is justified. The ratio of these two phases is prescribed by the sorption
coefficient Kd which has dimensions of volume (L3) per unit mass (M). The variation in
geochemical conditions can be considered, if needed, by examining pH,
oxidation/reduction potential, alkalinity, and dissolved oxygen, perhaps combined with
geochemical modeling, to justify the Kd approach utilized by MT3DMS. Geochemical
modeling using PHREEQC (Parkhurst et al. 2013) running in the batch mode can be
used to indicate the extent to which a COPC is subject to solubility constraints, a
variable Kd, or other processes.
The groundwater model will be developed in general accordance with the guidelines found in
the Groundwater Modeling Policy, NCDENR DWQ, May 31, 2007, and based on discussions
previously conducted concerning groundwater modeling between Duke Energy, HDR, UNCC,
and NCDENR.
7.7.2 Development of Kd Terms
It is critical to determine the ability of the site soils to attenuate, adsorb, or through other
processes reduce the concentrations of COPCs that may impact groundwater. To determine the
capacity of the site soils to attenuate a COPC, the site -specific Kd terms will be developed by
UNCC utilizing soil samples collected during the site investigation. These Kd terms quantify the
equilibrium relationship between chemical constituents in the dissolved and sorbed phases.
For soils at the site, sorption is most likely the reversible, exchange -site type associated with
hydrous oxides of iron on weathered soil surfaces (NCDENR DWQ 2012). Experiments to
quantify sorption can be conducted using batch or column procedures (Daniels and Das 2014).
A batch sorption procedure generally consists of combining soil samples and solutions across a
range of soil -to -solution ratios, followed by shaking until chemical equilibrium is achieved. Initial
and final concentrations of chemicals in the solution determine the adsorbed amount of
38

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
chemical and provide data for developing plots of sorbed versus dissolved chemical and the
resultant Kd term. If the plot, or isotherm, is linear, the single -valued Kd is considered linear as
well. Depending on the chemical constituent and soil characteristics, non -linear isotherms may
also result (EPRI 2004).
The column sorption procedure consists of passing a solution of known chemical concentration
through a cylindrical column packed with the soil sample. Batch and column methods for
estimating sorption were considered in development of the Kd terms. UNCC recommends an
adaption of the column method (Daniels and Das 2014) to develop Kd estimates that are more
conservative and representative of in -situ conditions, especially with regard to soil -to -liquid
ratios.
Soil samples with measured dry density and maximum particle size will be placed in lab -scale
columns configured to operate in the up -flow mode. A solution with measured COPC
concentrations will be pumped through each column as effluent samples are collected at regular
intervals over time. When constituent breakthroughs are verified, a "clean" solution (no COPCs)
will be pumped through the columns and effluent samples will be collected as well. Samples will
be analyzed by inductively coupled plasma -mass spectroscopy (ICP-MS) and ion
chromatography (IC) in the Civil & Environmental Engineering laboratories at the EPIC Building,
UNC Charlotte. COPCs measured in the column effluent as a function of cumulative pore
volumes displaced will be analyzed using CXTFIT (Tang et al. 2010) to select the
appropriate adsorption model and associated parameters of the partition coefficient Kd, either
linear, Freundlich, or Langmuir. This allows use of a nonlinear partition coefficient in the event
that the linear partition coefficient is not suitable for the modeled input concentration range.
It is noted that some COPCs may have indeterminate Kd values by the column method due to
solubility constraints and background conditions. In this case, batch sorption tests will be
conducted in accordance with U.S. Environmental Protection Agency (EPA) Technical Resource
Document EPA/530/SW-87/006-F, Batch -type Procedures for Estimating Soil Adsorption of
Chemicals. COPC-specific solutions will be used to prepare a range of soil -to -solution ratios.
After mixing, supernatant samples will be drawn and analyzed as described above. Plots of
sorbed versus dissolved COPC mass will be used to develop Kd terms. Batch tests will be
performed in triplicate.
When applied in the fate and transport modeling performed by MT3DMS, the Kds will determine
the extent to which COPC transport in groundwater flow is attenuated by sorption. In effect,
simulated COPC concentrations will be reduced, as will their rate of movement in advection in
groundwater.
Ten (10) soil core samples will be selected from representative material at the site for column
tests to be performed in triplicate. Additionally, batch Kd tests, if performed, will be executed in
triplicate.
These Kd terms will apply to the selected soil core samples and background geochemistry of
the test solution including pH and oxidation-reduction potential. In order to make these results
transferable to other soils and geochemical conditions at the site, UNCC recommends that the

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
core samples with derived Kds and 20 to 25 additional core samples be analyzed for hydrous
ferrous oxides (HFO) content, which is considered to the primary determinant of COPC sorption
capacity of soils at the site. In the groundwater modeling study, the correlation between derived
Kds and HFO content can be used to estimate Kd at other site locations where HFO and
background water geochemistry, especially pH and oxidation-reduction potential, are known. If
significant differences in water geochemistry are observed, batch geochemical modeling can be
used to refine the Kd estimate as described in Section 7.1.1. UNCC recommends that core
samples for Kd and HFO tests be taken from locations that are in the path of groundwater
flowing from the ash impoundments.
Determination of which COPCs will have Kd terms developed will be determined after review of
the analyses on the site ash and review of the site groundwater analyses results. The COPCs
selected will be considered simultaneously in each test. Competitive sorption is taken into
account implicitly in the lab -measured sorption terms as COPCs are combined into a single test
solution. Significant competition sorption is not anticipated given that COPCs in groundwater,
where present, will be at trace levels.
7.7.3 MODFLOW/MT3DMS Modeling Process
The MODFLOW groundwater model will be developed using the hydrostratigraphic layer
geometry and properties of the site as described in this section. After the geometry and
properties of the model layers are input, the model will be calibrated to existing water levels
observed in the monitoring wells and ash basin. Infiltration into the areas outside of the ash
basin will be estimated based on available information. Infiltration within the basin will be
estimated based on available water balance information and pond elevation data provided by
Duke Energy.
The MT3MS portion of the model will utilize the Kd terms and the input concentrations of
constituents found in the ash. The leaching characteristics of ash are complex and expected to
vary with time and as changes occur in the geochemical environment of the ash basin. Due to
factors such as quantity of a particular constituent found in ash, mineral complex, solubility, and
geochemical conditions, the rate of leaching and leached concentrations of constituents will vary
with time and respect to each other. The experience that UNCC brings to this process through
their years of working with leaching and characterization of ash, particularly with Duke Energy
ash, will be of particular value.
Since the ash within the basin has been placed over a number of years, the analytical results
from an ash sample collected during the groundwater assessment is unlikely to represent the
current concentrations that are present in the hydrologic pathway between the ash basin and a
particular groundwater monitoring well or other downgradient location.
As a result of these factors and due to the time period involved in groundwater flow,
• concentrations may vary spatially over time, and
• peak concentrations may not yet have arrived at compliance wells.
40

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
The selection of the initial concentrations and the predictions of the concentrations for
constituents with respect to time will be developed with consideration of the following:
• Site specific analytical results from leach tests (SPLP) and from total digestion of ash
samples taken at varying locations and depths within the ash basin. Note that the total
digestion concentrations, if used, would be considered an upper bound to concentrations
and that the actual concentrations would be lower that the results from the total
digestion.
• Analytical results from appropriate groundwater monitoring wells or surface water
sample locations outside of the ash basin
• Analytical results from monitoring wells installed in the ash basin pore water
(screened -in ash)
• Published or other data on sequential leaching tests performed on similar ash
The information above will be used with constituent concentrations measured at the compliance
boundary to calibrate the fate and transport model and to develop a representation of the
concentration with respect to time for a particular constituent. The starting time of the model will
correspond to the date that the ash basin was placed in service. The resulting model, which will
be consistent with the calibration targets mentioned above, can then be used to predict
concentrations over space and time.
The model calibration process will consist of varying hydraulic conductivity and retardation
within and between hydrostratigraphic units in a manner that is consistent with measured values
of hydraulic conductivity, sorption terms, groundwater levels, and COPC concentrations.
A sensitivity analysis will be performed for the fate and transport analyses.
The model report will contain the information required by Section II of the NCDENR modeling
guidelines, as applicable.
7.7.4 Hydrostratigraphic Layer Development
The three-dimensional configuration of the groundwater model hydrostratigraphic layers for a
site will be developed using the Initial Site Conceptual Model (Section 5.0) and from pre-existing
data and data obtained during the site investigation process. The thickness and extent for the
various layers will be represented by a three-dimensional surface model for each
hydrostratigraphic layer. For most sites the hydrostratigraphic layers will include ash, fills (both
for dikes/dam and/or ash landfills/structural fills), soil/saprolite, transition zone (where present),
and bedrock (Section 5.3).
The boring data from the site investigation and from existing boring data, as available and
provided by Duke Energy, will be entered into the RockWorks16TM program. This program,
along with site -specific and regional knowledge of Piedmont hydrogeology, will be used to
interpret and develop the layer thickness and extent across areas of the site where boring data
is not available. The material layers will be categorized based on physical and material
properties such as standard penetration blow count for soil/saprolite, and percent recovery and
41

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
RQD for the transition zone and bedrock. The material properties required for the model such as
total porosity, effective porosity, and specific storage for ash, fill, alluvium, and soil/saprolite will
be developed from laboratory testing (grain size analysis as described in Section 7.1.1) and
published data. Hydraulic conductivity (horizontal and vertical) of all layers will be developed
utilizing existing site data, in -situ permeability testing (falling head, constant head, and packer
testing where appropriate), slug tests in completed monitoring wells, laboratory testing of
undisturbed samples (ash, fill, soil/saprolite), and from an extensive database of Piedmont soil
and rock properties developed by HDR (Sections 7.1.1 and 7.1.6). The effective porosity
(primarily fracture porosity) and specific storage of the transition zone and bedrock will be
estimated from published data.
7.7.5 Domain of Conceptual Groundwater Flow Model
The MSS ash basin model domain encompasses the area where groundwater flow will be
simulated to estimate the impacts of coal ash stored at the site. By necessity, the conceptual
model domain extends beyond the ash storage area proper to physical or artificial hydraulic
boundaries such that groundwater flow through the area is accurately simulated. Physical
hydraulic boundary types include specified head, head dependent flux, no -flow, and recharge at
ground or water surface. Artificial boundaries, which are developed based on information from
the site investigation, may include the specified head and no -flow types. In plan, the Marshall
model domain is bounded approximately by the northwestern shore of Lake Norman to the
southeast, the unnamed tributary and drainage feature to the east between Lake Norman and
the drainage divide approximately defined by Island Point Road, the drainage divide
approximately defined by Island Point Road to the north, the drainage divide approximately
defined by Sherrills Ford Road to the west, and the drainage divide approximated by the railroad
tracks, sidings, and yard to the south. The lower limit of the model domain coincides with the
maximum depth of water yielding fractures in bedrock. The upper limit coincides with the upper
surface of soil, fill, ash, landfilled materials, or ash basin surface water, where present. The
basis for selecting these boundaries is described in the following section.
7.7.6 Boundary Conditions for Conceptual Groundwater Flow Model
The northwestern shore of Lake Norman is considered to be a specified head type where the
head is the average annual river stage for steady-state simulations, or the stage observed
simultaneously with groundwater level measurements at the site. Lake Norman is considered to
be the ultimate discharge boundary for all groundwater flowing through the model domain. The
proposed site investigation of lake sediment properties and hydraulic head differentials between
near -shore piezometer/monitoring well water elevations and lake stage may indicate a head
dependent flux type boundary is more appropriate.
The unnamed tributary and its upper drainage feature to the east between Lake Norman and
the drainage divide approximately defined by Island Point Road is considered to be a
combination of a physical and artificial, specified head boundary types. Where surface water
flow in the tributary is perennial, the boundary is a physical constant head type, unless the
proposed site investigation of near -stream sediment properties and hydraulic head differentials
between near -stream piezometer/monitoring well water elevations and stream stage indicate a
42

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
head dependent flux type boundary is more appropriate. The upper drainage feature is a
constant head type where the head distribution will be an interpolation of measured heads from
the nearest piezometers and monitoring wells.
The drainage divide approximately defined by Island Point Road to the north, Sherrills Ford to
the west, and the railroad tracks, sidings, and yard to the south are considered to be no -flow
type boundaries.
The upper boundary across the site is the recharge type, where recharge is dependent on
regional precipitation estimates and land cover type, either soil, fill, ash, or landfilled materials.
Given that the hydrostratigraphic zones across the site are hydraulically connected, these
boundaries are considered to be applicable to local (shallow) and regional (deep) groundwater
flow.
7.7.7 Groundwater Impacts to Surface Water
If the groundwater modeling predicts exceedances of the 2L Standards at or beyond the
compliance boundary where the plume containing the exceedances would intercept surface
waters, the groundwater model results will be coupled with modeling of surface waters to predict
contaminant concentrations in the surface waters. This work would be performed by HDR in
conjunction with UNCC.
Model output from the fate and transport modeling (i.e. groundwater volume flux and
concentrations of constituents with exceedances of the 2L Standards) will be used as input for
surface water modeling in the adjacent water bodies (i.e., streams or reservoirs). The level of
surface water modeling will be determined based on the potential for water quality impacts in
the adjacent water body. That is, if the available mixing and dilution of the groundwater plume
in the water body is sufficient that surface water quality standards are expected to be attained
within a short distance a simple modeling approach will be used. If potential water quality
impacts are expected to be such that the simple model approach is not sufficient, or if the water
body type requires a more complex analysis, then a more detailed modeling approach will be
used. A brief description of the simple and detailed modeling approaches is presented below.
Simple Modeling Approach — This approach will include the effects of upstream flow on
dilution of the groundwater plume within allowable mixing zone limitations along with
analytical solutions to the lateral spreading and mixing of the groundwater plume in the
adjacent water body. This approach will be similar to that presented in EPA's Technical
Support Document for Water Quality based Toxics Control (EPA/505/2-90-001) for
ambient induced mixing that considers lateral dispersion coefficient, upstream flow and
shear velocity. The results from this analysis will provide information constituent
concentration as a function of the spatial distance from the groundwater input to the
adjacent water body.
Detailed Modeling Approach — This approach will involve the use of a water quality
model that is capable of representing a multi -dimensional analysis of groundwater plume
mixing and dilution in the adjacent water body. This method involves segmenting the
water body into model segments (lateral, longitudinal and/or vertical) for calculating the

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
7.0 Assessment Work Plan
resulting constituent concentrations spatially in the water body either in a steady-state or
time -variable mode. The potential water quality models that could be used for this
approach include: QUAL2K; CE-QUAL-W2; EFDC/WASP; ECOMSED/RCA; or other
applicable models.
In either approach, the model output from the groundwater model will be coupled with the
surface water model to determine the resulting constituent concentrations in the adjacent water
body spatially from the point of input. These surface water modeling results can be used for
comparison to applicable surface water quality standards to complete determine compliance.
The development of the model inputs would require additional data for flow and chemical
characterization of the surface water that would potentially be impacted. The specific type of
data required (i.e., flow, chemical characterization, etc.) and the locations where this data would
be collected would depend on the surface water body and the modeling approach selected. If
modeling groundwater impacts to surface water is required, HDR and Duke Energy will consult
with the DWR regional office to present those specific data requirements and modeling
approach.
44

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
8.0 Risk Assessment
8.0 Risk Assessment
To support the groundwater assessment and inform corrective action decisions, potential risks
to human health and the environment will be assessed in accordance with applicable federal
and state guidance. Initially, screening level human health and ecological risk assessments will
be conducted that include development of conceptual site models (CSM) to serve as the
foundation for evaluating potential risks to human and ecological receptors at the site.
Consistent with standard risk assessment practice, separate CSMs will be developed for the
human health and ecological risk evaluations.
The purpose of the CSM is to identify potentially complete exposure pathways to environmental
media associated with the site and to specify the types of exposure scenarios relevant to
include in the risk analysis. The first step in constructing a CSM is to characterize the site and
surrounding area. Source areas and potential transport mechanisms are then identified,
followed by determination of potential receptors and routes of exposure. Potential exposure
pathways are determined to be complete when they contain the following aspects: 1) a
constituent source, 2) a mechanism of constituent release and transport from the source area to
an environmental medium, and 3) a feasible route of potential exposure at the point of contact
(e.g., ingestion, dermal contact, and inhalation). Completed exposure pathways identified in the
CSM are then evaluated in the risk assessment. Incomplete pathways are characterized by
some gaps in the links between site sources and exposure. Based on this lack of potential
exposure, incomplete pathways are not included in the estimation or characterization of
potential risks since no exposure can occur via these pathways.
Preliminary COPCs for inclusion in the screening level risk assessments will be identified based
on the preliminary evaluations performed at the site in conjunction with recommendations from
NCDENR regarding coal ash constituents. Both screening level risk assessments will compare
maximum constituent concentrations to appropriate risk -based screening values as a
preliminary step in evaluating potential for risks to receptors. Based on results of the screening
level risk assessments, a refinement of COPCs will be conducted and more definitive risk
characterization will be performed as part of the corrective action process if needed.
8.1 Human Health Risk Assessment
As noted above, the initial human health risk assessment (HHRA) will include the preparation of
a CSM illustrating potential exposure pathways from the source area to possible receptors. The
information gathered in the CSM will be used in conjunction with analytical data collected as
part of the CSA. Although groundwater appears to be the primary exposure pathway for human
receptors, a screening level evaluation will be performed to determine if other potential
exposure routes exist.
The HHRA for the site will include an initial comparison of constituent concentrations in various
media to risk -based screening levels. The data will be screened against the following criteria:
45

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
8.0 Risk Assessment
• Soil analytical results will be compared to USEPA residential and industrial soil Regional
Screening Levels (RSLs) (USEPA, November 2014 or latest update)
• Groundwater results will be compared to USEPA tap water RSLs (USEPA, October
2014) and NCDENR Title 15A, Subchapter 2L Standards (NCDENR 2006)
• Surface water analytical results will be compared to USEPA national recommended
water quality criteria and North Carolina surface water standards (USEPA 2006;
NCDENR 2007)
• The surface water classification as it pertains to drinking water supply, aquatic life,
high/exceptional quality designations and other requirements for other activities (e.g.,
landfill permits, NPDES wastewater discharges) shall be noted
• Sediment results will be compared to USEPA residential soil RSLs (USEPA, November
2014 or latest update)
• The soil, sediment, and ground water data will also be compared to available
background soil, sediment, and ground water data from previous monitoring and
investigations
The results of this comparison will be presented in a table along with recommendations for
further evaluation.
8.1.1 Site -Specific Risk -Based Remediation Standards
If deemed necessary based on the results of the initial comparison to standards, site- and
media -specific risk -based remediation standards will be calculated in accordance with the
Eligibility Requirements and Procedures for Risk -Based Remediation of Industrial Sites
Pursuant to N.C.G.S. 130A-310.65 to 310.77, North Carolina Department of Environment and
Natural Resources, Division of Waste Management, 29 July 2011.
These calculations will include an evaluation of the following based on site -specific activities and
conditions:
• Remediation methods and technologies resulting in emissions of air pollutants are to
comply with applicable air quality standards adopted by the Environmental Management
Commission (Commission).
• Site -specific remediation standards for surface waters are to be the water quality
standards adopted by the Commission
• The current and probable future use of groundwater shall be identified and protected.
Site -specific sources of contaminants and potential receptors are to be identified,
protected, controlled, or eliminated whether on or off the site of the contaminant source.
• Natural environmental conditions affecting the fate and transport of contaminants (e.g.,
natural attenuation) shall be determined by appropriate scientific methods
• Permits for facilities subject to the programs or requirements of G.S. 130A-310.67(a)
shall include conditions to avoid exceedances of applicable groundwater standards
pursuant to Article 21 of Chapter 143 of the General Statutes; permitted facilities shall be
designed to avoid exceedances of the North Carolina ground or surface water standards

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
8.0 Risk Assessment
• Soil shall be remediated to levels that no longer constitute a continuing source of
groundwater contamination in excess of the site -specific groundwater remediation
standards approved for the site
• The potential for human inhalation of contaminants from the outdoor air and other site -
specific indoor air exposure pathways shall be considered during remediation, if
applicable
• The site -specific remediation standard shall protect against human exposure to
contamination through the consumption of contaminated fish or wildlife and through the
ingestion of contaminants in surface water or groundwater supplies
• For known or suspected carcinogens, site -specific remediation standards shall be
established at levels not to exceed an excess lifetime cancer risk of one in a million. The
site -specific remediation standard may depart from this level based on the criteria set out
in 40 Code of Federal Regulations § 300.430(e)(9) (July 1, 2003). The cumulative
excess lifetime cancer risk to an exposed individual shall not be greater than 1 in 10,000
based on the sum of carcinogenic risk posed by each contaminant present.
• For systemic toxicants (non -carcinogens), site -specific remediation standards shall be
set at levels to which the human population, including sensitive subgroups, may be
exposed without any adverse health effect during a lifetime or part of a lifetime. Site -
specific remediation standards for systemic toxicants shall incorporate an adequate
margin of safety and shall take into account cases where two or more systemic toxicants
affect the same organ or organ system.
• A comparison will also be made between the concentrations detected in ground water
and the constituent specific primary drinking water standards, as well as the
concentrations in impacted vs. background levels to determine if there are other
considerations that will need to be addressed in risk management decision making.
The site -specific remediation standards for each medium shall be adequate to avoid
foreseeable adverse effects to other media or the environment that are inconsistent with the
state's risk -based approach.
8.2 Ecological Risk Assessment
The screening level ecological risk assessment (SLERA) for the site will begin with a description
of the ecological setting and development of the ecological CSM specific to the ecological
communities and receptors that may potentially be at risk. This scope is equivalent to Step 1:
preliminary problem formulation and ecological effects evaluation (USEPA 1998).
The screening level evaluation will include compilation of a list of potential ecological receptors
(e.g., plants, benthic invertebrates, fish, birds, etc.). Additionally, an evaluation of sensitive
ecological populations will be performed. Preliminary information on listed rare animal species
at or near the site will be compiled from the North Carolina Natural Heritage Program database
and U.S. Fish and Wildlife Service (USFWS) county list to evaluate the potential for presence of
rare or endangered animal and plant species. Rare natural communities will also be evaluated
and identified if near the site.
47

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
8.0 Risk Assessment
Appropriate state and federal natural resource trustees and their representatives (e.g., USFWS)
will be contacted to determine the potential presence (or lack thereof) of sensitive species or
their critical habitat at the time the screening is performed. If it is determined a sensitive species
or critical habitat is present or potentially present, a survey of the appropriate area will be
conducted. If it is found that sensitive species are utilizing the site, or may in the future, a finding
concerning the likelihood of effects due to site -related contaminants or activities should be
developed and presented to the trustee agency.
The preliminary ecological risk screening will also include, as the basis for the CSM, a
description of the known fate and transport mechanisms for site -related constituents and
potentially complete pathways from assumed source to receptor. An ecological checklist will be
completed for the site as required by Guidelines for Performing Screening Level Ecological Risk
Assessment within North Carolina (NCDENR 2003).
Following completion of Step 1, the screening level exposure estimate and risk calculations
(Step 2), will be performed in accordance with the Guidelines for Performing Screening Level
Ecological Risk Assessment within North Carolina (NCDENR 2003). Step 2 estimates the level
of a constituent a plant or animal is exposed to at the site and compares the maximum
constituent concentrations to Ecological Screening Values (ESVs).
Maximum detected concentrations or the maximum detection limit for non -detected constituents
of potential concern (those metals or other chemicals present in site media that may result in
risk to ecological receptors) will be compared to applicable ecological screening values intended
to be protective of ecological receptors (including those sensitive species and communities
noted above, where available) to derive a hazard quotient (HQ). An HQ greater than 1 indicates
potential ecological impacts cannot be ruled out.
Ecological screening values will be taken from the following and other appropriate sources:
• USEPA Ecological Soil Screening Levels
• USEPA Region 4 Recommended Ecological Screening Values
• USEPA National Recommended Water Quality Criteria and North Carolina Standards
The state's SLERA guidance (NCDENR 2003) requires that constituents be identified as a
Step 2 COPC as follows:
• Category 1 — Contaminants with a maximum detection exceeding the ESV
• Category 2 — Undetected contaminants with a laboratory sample quantitation limit
exceeding the ESV
• Category 3 — Detected contaminants with no ESV
• Category 4 — Undetected contaminants with no ESV
Exceedances of the ESVs indicate the potential need for further evaluation of ecological risks at
the site. The frequency, magnitude, pattern, and basis of any exceedances should also be
considered.
48

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin
8.0 Risk Assessment
The process ultimately identifies a Scientific -Management Decision Point (SMDP) to determine
if ecological threats are absent and no further assessment is needed; if further assessment
should be performed to determine whether risks exist; or if there is the possibility of adverse
ecological effects; and therefore, a determination made on whether a more detailed ecological
risk and/or habitat assessment is needed, and if so, the scope of the assessment(s).
49

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
9.0 CSA Report
9.0 CSA Report
The CSA report will be developed in the format required by the NORR, which includes the
following components:
• Executive Summary
• Site History and Source Characterization
• Receptor Information
• Regional Geology and Hydrogeology
• Site Geology and Hydrogeology
• Soil Sampling Results
• Groundwater Sampling Results
• Hydrogeological Investigation
• Groundwater Modeling results
• Risk Assessment
• Discussion
• Conclusions and Recommendations
• Figures
• Tables
• Appendices
The CSA report will provide the results of one iterative assessment phase. No off -site
assessment or access agreements are anticipated to be utilized during this task other than for
the possible additional off -site wells discussed in Section 6.0.
The CSA will be prepared to include the items contained in the Guidelines for Comprehensive
Site Assessment (guidelines) included as attachment to the NORR, as applicable. HDR will
provide the applicable figures, tables, and appendices as listed in the guidelines.
As part of CSA deliverables, a minimum the following tables, graphs, and maps will be provided:
• Box (whisker) plots for locations sampled on four or more events showing the quartiles
of the data along with minimum and maximum. Plots will be aligned with multiple
locations on one chart. Similar charts will be provided for each constituent of concern
(COC).
• Stacked time -series plots will be provided for each COC. Multiple wells/locations will be
stacked using the same x-axis to discern seasonal trends. Turbidity, dissolved oxygen,
ORP, or other constituents will be shown on the plots where appropriate to demonstrate
influence.
• Piper and/or stiff diagrams showing selected monitoring wells and surface water
locations as separate symbols
• Correlation charts where applicable
• Orthophoto potentiometric maps for shallow, deep, and bedrock wells

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin
9.0 CSA Report
• Orthophoto potentiometric difference maps showing the difference in vertical heads
between selected flow zones
• Orthophoto iso-concentration maps for selected COCs and flow zones
• Orthophoto map showing the relationship between groundwater and surface water
samples for selected COCs
• Geologic cross -sections
• Photographs of select split -spoon samples and cores at each boring location
• Others as appropriate
Recommendations will be provided in the CSA report for a sampling plan to be performed after
completion of this groundwater assessment. The sampling plan will describe the recommended
sampling frequency, constituent and parameter list, and proposed sampling locations including
monitoring wells, seeps, and surface water locations as required.
51

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
10.0 Proposed Schedule
10.0 Proposed Schedule
Duke Energy will submit the CSA Report within 180 days of NCDENR approval of this Work
Plan. The anticipated schedule for implementation of field work, evaluation of data, and
preparation of the Work Plan is presented in the table below.
Activity
Field Exploration Program
Receive Laboratory Data
Evaluate Lab/Field Data, Develop SCM
Prepare and Submit CSA
Start Date
Duration to
Complete
10 days following Work Plan approval
75 days
14 days following end of Exploration
15 days
Program
5 days following receipt of Lab Data
30 days
10 days following Work Plan approval
170 days
In addition, the following permits and approvals from NCDENR will potentially be required to
commence field work:
If site land disturbance equal to or greater than 1 acre is required for access and clearing
associated with drilling work, an erosion and sedimentation control permit must be
approved by the NCDENR Division of Energy, Mineral and Land Resources, Land
Quality Section.
Installation of monitoring wells and/or soil borings on the dams and/or dikes at the ash
basin site must be approved by the NCDENR Division of Energy, Mineral and Land
Resources, Dam Safety Section prior to drilling. Location and well construction details
will be submitted following approval of the proposed locations.
52

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
11.0 References
11.0 References
1. Daniel, C.C., III and Sharpless, N.B. 1983. Ground -water supply potential and
procedures for well -site selection upper Cape Fear basin, Cape Fear basin study, 1981-
1983: North Carolina Department of Natural Resources and Community Development
and U.S. Water Resources Council in cooperation with the U.S. Geological Survey, 73 p.
2. Daniels, John L. and Das, Gautam P. 2014. Practical Leachability and Sorption
Considerations for Ash Management, Geo-Congress 2014 Technical Papers: Geo-
characterization and Modeling for Sustainability. Wentworth Institute of technology,
Boston, MA.
3. Cunningham, W. L. and C. C. Daniels, III. 2001. Investigation of ground -water availability
and quality in Orange County, North Carolina: U. S. Geological Survey, Water -
Resources Investigations Report 00-4286, 59p.
4. Duke Power Company. 1989. Marshall Steam Station, Dry Ash Landfill, Monitoring Well
Drill Records, July 1989.
5. Electric Power Research Institute (EPRI). 2014. Assessment of Radioactive Elements in
Coal Combustion Products, 2014 Technical Report 3002003774, Final Report August
2014.
6. EPRI. 2009. Electric Power Research Institute, Technical Update - Coal Combustion
Products - Environmental Issues - Coal Ash: Characteristics, Management and
Environmental Issues, EPRI 1019022. September 2009.
7. EPRI. 2004. Electric Power Research Institute, Chemical Attenuation Coefficients for
Arsenic Species Using Soil Samples Collected from Selected Power Plant Sites:
Laboratory Studies, Product ID:1005505, December 2004.
8. EPRI. 1993. Electric Power Research Institute, Physical and Hydraulic Properties of Fly
Ash and Other By -Products from Coal Combustion, EPRI TR-101999. February 1993.
9. Fenneman, Nevin Melancthon. 1938. Physiography of eastern United States. McGraw-
Hill.
10. Freeze, R. A., J. A. and Cherry. 1979. Ground Water, Englewood Cliffs, NJ, Prentice -
Hall.
11. Gillispie, EC., Austin, R., Abraham, J., Wang, S., Bolich, R., Bradley, P., Amoozegar, A.,
Duckworth, O., Hesterberg, D., and Polizzotto, ML. 2014. Sources and variability of
manganese in well water of the North Carolina Piedmont. Water Resources Research
Institute of the University of North Carolina System Annual 2014 Conference, Raleigh,
NC, March 2014. Poster Presentation.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
11.0 References
12. Harned, D. A. and Daniel, C. C., III. 1992. The transition zone between bedrock and
regolith: Conduit for contamination?, p. 336-348, in Daniel, C. C., III, White, R. K., and
Stone, P. A., eds., Groundwater in the Piedmont: Proceedings of a Conference on
Ground Water in the Piedmont of the Eastern United States, October 16-18, 1989,
Clemson University, 693p.
13. HDR. 2014A. Marshall Steam Station Ash Basin Drinking Water Supply Well and
Receptor Survey, NPDES Permit NC0004987.
14. HDR. 2014B. Marshall Steam Station Ash Basin Supplement to Drinking Water Supply
Well and Receptor Survey.
15. Heath, R.C. 1980. Basic elements of groundwater hydrology with reference to conditions
in North Carolina: U.S. Geo-logical Survey Open -File Report 80-44, 86 p.
16. Heath, R.C. 1984. Ground -water regions of the United States. U.S. Geological Survey
Water -Supply Paper 2242, 78 p.
17. Krauskopf, K.B. 1972. Geochemistry of micronutrients: in Micronutrients in Agriculture,
J.J. Mortvedt, F.R. Cox, L.M. Shuman, and R.M. Walsh, eds., Soil Science Society of
America, Madison, Wisconsin, p. 7-36.
18. LeGrand, H.E. 1988. Region 21, Piedmont and Blue Ridge. In Hydrogeology, The
Geology of North America, vol. 0-2, ed. W.B. Back, J.S. Rosenshein, and P.R. Seaber,
201-207. Geological Society of America. Boulder CO: Geological Society of America.
19. LeGrand, H.E. 1989. A conceptual model of ground water settings in the Piedmont
region. In Ground Water in the Piedmont, ed. C.C. Daniel III, R.K. White, and P.A.
Stone, 693. Proceedings of a Conference on Ground Water in the Piedmont of the
Eastern United States, Clemson University, Clemson, South Carolina. Charlotte, NC:
U.S. Geological Survey.
20. LeGrand, Harry E. 2004. A Master Conceptual Model for Hydrogeological Site
Characterization in the Piedmont and Mountain Region of North Carolina, A Guidance
Manual, North Carolina Department of Environment and Natural Resources Division of
Water Quality, Groundwater Section.
21. NCDENR. 2003. Division of Waste Management - Guidelines for Performing Screening
Level Ecological Risk Assessments within North Carolina.
22. NCDENR. 2007. Memorandum "Performance and Analysis of Aquifer Slug Tests and
Pumping Tests Policy" dated May 31, 2007.
23. NCDENR. 2007. Document "Hydrogeologic Investigation and Reporting Policy
Memorandum" dated May 31, 2007.
24. NCDENR DWQ NCDENR Division of Water Quality. 2013. Evaluating Metals in
Groundwater at DWQ Permitted Facilities: A Technical Assistance Document for DWQ
Staff. July 2013.

Duke Energy Carolinas, LLC I Proposed Groundwater Assessment Work Plan
Marshall Steam Station Ash Basin FN
11.0 References
25. Parkhurst, D.L., and Appelo, C.A.J., 2013, Description of input and examples for
PHREEQC version 3-A computer program for speciation, batch -reaction, one-
dimensional transport, and inverse geochemical calculations: U.S. Geological Survey
Techniques and Methods, book 6, chap. A43, 497 p.
26. S&ME, Inc. 2006. Ash Basin Monitoring Well Installation, Duke Power -Marshall Steam
Station, S&ME Project No. 1356-06-834, December 4, 2006.
27. Tang, G., Mayes, M. A., Parker, J. C., & Jardine, P. M. (2010). CXTFIT/Excel-A modular
adaptable code for parameter estimation, sensitivity analysis and uncertainty analysis for
laboratory or field tracer experiments. Computers & Geosciences, 36(9), 1200-1209.
28. USEPA. 1987. Batch -type procedures for estimating soil adsorption of chemicals
Technical Resource Document 530/SW-87/006-F.
29. USEPA. 1997. Ecological Risk Assessment Guidance for Superfund: Process for
Designing and Conducting Ecological Risk Assessments.
30. USEPA. 2001. Region 4 Ecological Risk Assessment Bulletins -Supplement to RAGS.
31. USEPA. 1998. Guidelines for Ecological Risk Assessment.
32. US FWS. 2009. Range -wide Indiana Bat Protection and Enhancement Plan Guidelines,
at http://www.fws.gov/frankfort/pdf/inbatpepguidelines.pdf.
33. US Geological Survey (USGS). 1961. Akio Ogata and R.B. Banks Professional Paper
411-A. A Solution of Differential Equation of Longitudinal Dispersion in Porous Media.
34. US Geological Survey (USGS). 1997. Radioactive elements in coal and fly ash:
abundance, forms, and environmental significance. U.S. Geological Survey Fact Sheet
FS-163-97.
35. USEPA. 1998. Study of Hazardous Air Pollutant Emissions from Electric Utility Steam
Generating Units -Final Report to Congress. Volume 1. Office of Air Quality, Planning
and Standards. Research Triangle Park, NC 27711, EPA-453/R-98-004a.
36. USEPA. 1998. Report to Congress Wastes from the Combustion of Fossil Fuels, Volume
2 Methods, Findings, and Recommendations.

Mini iron

NOTES:
1. PARCEL DATA FOR THE SITE WAS OBTAINED FROM DUKE ENERGY REAL ESTATE AND IS APPROXIMATE.
2. WASTE BOUNDARY AND ASH STORAGE AREA BOUNDARY ARE APPROXIMATE. 500
3. AS -BUILT MONITORING WELL LOCATIONS PROVIDED BY DUKE ENERGY.
4. COMPLIANCE SHALLOW MONITORING WELLS (S) ARE SCREENED ACROSS THE SURFICIAL WATER TABLE.
5. COMPLIANCE DEEP MONITORING WELLS (D) ARE SCREENED IN THE TRANSITION ZONE BETWEEN COMPETENT BEDROCK AND THE REGOLITH.
6. TOPOGRAPHY DATA FOR THE SITE WAS OBTAINED FROM INC DOT GEOGRAPHIC INFORMATION SYSTEM (GIS) WEB SITE (DATED 2007).
7. AERIAL PHOTOGRAPHY WAS OBTAINED FROM WSP DATED APRIL 2014.
8. THE COMPLIANCE BOUNDARY IS ESTABLISHED ACCORDING TO THE DEFINITION FOUND IN 15A NCAC 02L .0107 (a)
SCALE (FEET)
0 500' 1.000'
l" = [, 000' F)
LEGEND:
DUKE ENERGY PROPERTY BOUNDARY
ASH BASIN WASTE BOUNDARY
LANDFILL/STRUCTURAL FILL BOUNDARY
ASH BASIN COMPLIANCE BOUNDARY
_ ASH BASIN COMPLIANCE BOUNDARY COINCIDENT
�. WITH DUKE PROPERTY BOUNDARY
STREAM
TOPOGRAPHIC CONTOUR (4-FT INTERVAL)
1L EXISTING ASH BASIN COMPLIANCE
�J GROUNDWATER MONITORING WELL
EXISTING ASH BASIN VOLUNTARY
GROUNDWATER MONITORING WELL
SITE LAYOUT MAP
DUKE ENERGY CAROLINAS, LLC
MARSHALL STEAM STATION ASH BASIN
NPDES PERMIT NO. NC0004987
CATAWBA COUNTY, NORTH CAROLINA
DATE
12/30/2014
FIGURE
2

NOTES:
1. PARCEL DATA FOR THE SITE WAS OBTAINED FROM DUKE ENERGY REAL ESTATE AND IS APPROXIMATE.
2. WASTE BOUNDARY AND ASH STORAGE AREA BOUNDARY ARE APPROXIMATE.
3. AS -BUILT MONITORING WELL LOCATIONS PROVIDED BY DUKE ENERGY.
4. COMPLIANCE SHALLOW MONITORING WELLS (S) ARE SCREENED ACROSS THE SURFICIAL WATER TABLE.
5. COMPLIANCE DEEP MONITORING WELLS (D) ARE SCREENED IN THE TRANSITION ZONE BETWEEN COMPETENT BEDROCK AND THE REGOLITH.
6. TOPOGRAPHY DATA FOR THE SITE WAS OBTAINED FROM NC DOT GEOGRAPHIC INFORMATION SYSTEM (GIS) WEB SITE (DATED 2007).
7. AERIAL PHOTOGRAPHY WAS OBTAINED FROM WSP DATED APRIL 2014.
8. THE COMPLIANCE BOUNDARY IS ESTABLISHED ACCORDING TO THE DEFINITION FOUND IN 15A NCAC 02L .0107 (a).
9. PROPOSED SOIL BORING AND WELL LOCATIONS ARE APPROXIMATE AND MAY BE ADJUSTED BASED ON FIELD CONDITIONS.
10. WLO = WATER LEVEL ONLY
11. PROPOSED SURFACE WATER SAMPLE LOCATION SW-6 INCLUDES COLLECTION OF A SURFACE WATER AND SEDIMENT SAMPLE.
12. PROPOSED POTENTIAL MONITORING WELL LOCATIONS ARE APPROXIMATE AND MAY BE ADJUSTED BASED ON ACCESSIBILITY AND FIELD CONDITIONS.
SCALE (FEET)
250' 0 250' 500'
l" = 500'
LEGEND:
\I
DUKE ENERGY PROPERTY BOUNDARY
ASH BASIN WASTE BOUNDARY
LANDFILL/STRUCTURAL FILL BOUNDARY
LANDFILL COMPLIANCE BOUNDARY
ASH BASIN COMPLIANCE BOUNDARY
ASH BASIN COMPLIANCE BOUNDARY COINCIDENT
WITH DUKE PROPERTY BOUNDARY
STREAM
TOPOGRAPHIC CONTOUR (4-FT INTERVAL)*
EXISTING ASH BASIN COMPLIANCE
GROUNDWATER MONITORING WELL
lq� EXISTING ASH BASIN VOLUNTARY
GROUNDWATER MONITORING WELL
EXISTING LANDFILL GROUNDWATER MONITORING
WELL (ASH LANDFILLS AND FGD RESIDUE LANDFILL)
PROPOSED SOIL BORING/GROUNDWATER
MONITORING WELL LOCATION
PROPOSED POTENTIAL BORING/GROUNDWATER
MONITORING WELL LOCATION
PROPOSED SOIL BORING LOCATION
4&1 PROPOSED OBSERVATION WELL (SEE NOTE 10)
PROPOSED WELL AND SAMPLE LOCATIONS
DUKE ENERGY CAROLINAS, LLC
MARSHALL STEAM STATION ASH BASIN
NPDES PERMIT NO. NC0004987
CATAWBA COUNTY, NORTH CAROB NA
PROPOSED SURFACE WATER SAMPLE LOCATION
(SEE NOTE 11)
POTENTIAL SEEP AND SEDIMENT SAMPLE LOCATION
(PREVIOUSLY IDENTIFIED SEEP)
DATE
12/30/2014
FIGURE
3

Table 1. Groundwater Monitoring Requirements
Well Nomenclature
Antimony
Monitoring Wells: MW-4, MW-413,
Arsenic
MW-10S, MW-101), MW-11S, MW-
Barium
11D, MW-12S, MW-12D, MW-13S,
Boron
MW-13D, MW-14S, MW-14D
Cadmium
Chloride
Constituents and Parameters
Chromium Nickel Thallium
Copper Nitrate Water Level
Iron pH Zinc
Lead Selenium
Manganese Sulfate
Mercury TDS
rrequency
February,
June,
October
Tables - Page 1

Table 2. Exceedances of 2L Standards February 2011—June 2014
Parameter
Units
2L Standard
Boron
pg/L
700
Iron
pg/L
300
Manganese
pg/L
50
pH
SU
6.5 - 8.5
Sulfate
mg/L
250
Total Dissolved
Solids
mg/L
500
Well ID
Range of Exceedances
MW-4
No
No
No
Exceedances
5.5 — 6.0
No
Exceedances
No
Exceedances
Exceedances
Exceedances
MW-41)
No
376
No
Exceedances
5 9 — 6 2
No
Exceedances
No
Exceedances
Exceedances
MW-10S
No
373 — 616
65
5.1 — 5.7
No
Exceedances
No
Exceedances
Exceedances
MW-10D
No
371 — 406
59 — 97
6.2 — 6.4
No
Exceedances
No
Exceedances
Exceedances
MW-11 S
No
324 — 467
No
Exceedances
5.9 — 6.4
No
Exceedances
No
Exceedances
Exceedances
MW-11 D
No
325 — 839
No
Exceedances
No Exceedances
No
Exceedances
No
Exceedances
Exceedances
MW-12S
No
No
54 — 127
4.9 — 5.7
No
Exceedances
No
Exceedances
Exceedances
Exceedances
MW-12D
No
305 — 970
No
Exceedances
5.9 — 6.4
No
Exceedances
No
Exceedances
Exceedances
MW-13S
No
324 — 1,470
54
5.8 — 6.3
No
Exceedances
No
Exceedances
Exceedances
MW-13D
No
No
No
Exceedances
5.9 — 6.4
No
Exceedances
No
Exceedances
Exceedances
Exceedances
MW-14S
3,190 — 4,530
322 — 1,270
66 — 192
5.2 — 5.5
280 — 400
570 — 650
MW-14D
2,750 — 3,660
No
51 — 73
5.3 — 5.6
270 — 310
510 — 540
Exce dances
Tables - Page 2

Table 3. Environmental Exploration and Sampling Plan
MARSHALL STEAM STATION
Exploration
Area
Soil Borings
Shallow
Monitoring Wells
Deep
Monitoring Wells
Bedrock Monitoring
Wells
Surface Water/Seep
Estimated
Estimated
Screen
Estimated
Estimated
Screen
Estimated
Estimated
Screen
Quantity of
Quantity of
Boring Us
Quantity
Boring Depth
Well IDs
Quantity
Well Depth
Length
Well IDs
Quantity
Casing Depth
Well Depth
Length
Well IDs
Quantity
Casing Depth
Well Depth
Length
Locations
Samples
(ft bgs)
(ft bgs)
(ft)
(ft bgs)
(ft bgs)
(ft)
(ft bgs)
(ft bgs)
(ft)
AB -IS through
Ash Basin
AB-1 through
AB-21S,
AB-5BR,
and
AB-21,
36
40-90
AB-4SL,
25
15-50
10-15
AB-1Dthrough
21
25-75
40-90
5
AB-9BR
2
50-100
100-150
5
5
10
Structural
SB-1 through
AB-10SL,
AB-21D
Fill
SB-15
AB-12SL, and
AB-15SL
Ash Landfill
AL-1 through
4
65 115
AL-1S, AL-2S,
3
40 80
15
AL-1Dthrough
4
50-100
65-115
5
N/A
N/A
N/A
N/A
N/A
N/A
N/A
AL-4
AL-3S
AL-4D
Beyond
GWA-1 S
GWA-1 D
GWA-1BR,
1 Stream
2
Waste
N/A
N/A
N/A
through
8
20-50
15
through
8
30-80
45-95
5
GWA-9BR
2
50-100
100-150
5
1 Potential
(potentially
Boundary
GWA-8S
GWA-8D
Seep
4)
Background
BG-1, BG-2,
3
55-105
BG-1S, BG-2S,
3
30-50
15
BG-1D, BG-2D,
3
40-90
55-105
5
BG-2BR
1
60-110
110-160
5
N/A
N/A
and BG-3
and BG-3S
and BG-3D
Notes:
1. Estimated boring and well depths based on data available at the time of work plan preparation and subject to change based on site -specific conditions in the field.
2. Laboratory analyses of soil, ash, groundwater, and surface water samples will be performed in accordance with the constituents and methods identified in Tables 4 and 5.
3. Additionally, soils will be tested in the laboratory to determine grain size (with hydrometer), specific gravity, and permeability.
4. During drilling operations, downhole testing will be conducted to determine in -situ soil properties such as horizontal and vertical hydraulic conductivity.
5. Actual number of field and laboratory tests will be determined in field by Field Engineer or Geologist in accordance with project specifications.
6. Proposed stream surface water and seep sample locations include both water and sediment samples.
Tables - Page 3

Table 4. Soil and Ash Parameters and Analytical Methods
INORGANIC COMPOUNDS
UNITS
METHOD
Antimony
mg/kg
EPA 6020A
Arsenic
mg/kg
EPA 6020A
Barium
mg/kg
EPA 6010C
Boron
mg/kg
EPA 6010C
Cadmium
mg/kg
EPA 6020A
Chloride
mg/kg
EPA 9056A
Chromium
mg/kg
EPA 6010C
Copper
mg/kg
EPA 6010C
Iron
mg/kg
EPA 6010C
Lead
mg/kg
EPA 6020A
Manganese
mg/kg
EPA 6010C
Mercury
mg/kg
EPA Method 7470A/7471 B
Nickel
mg/kg
EPA 6010C
pH
SU
EPA 9045D
Selenium
mg/kg
EPA 6020A
Thallium (low level) (SPLP Extract only)
mg/kg
EPA 6020A
Zinc
mg/kg
EPA 6010C
Notes:
1. Soil samples to be analyzed for Total Inorganics using USEPA Methods 6010/6020
and pH using USEPA Method 9045, as noted above.
2. Ash samples to be analyzed for Total Inorganics using USEPA Methods 6010/6020
and pH using USEPA Method 9045; select ash samples will also be analyzed for
leaching potential using SPLP Extraction Method 1312 in conjunction with USEPA
Methods 6010/6020. SPLP results to be reported in units of mg/L for comparison to 2L
Standards.
Tables - Page 4

Table 5. Groundwater and Surface Water Parameters and Constituent Analytical Methods
PARAMETER
RL
UNITS
METHOD
FIELD PARAMETERS
pH
NA
SU
Field Water Quality Meter
Specific Conductance
NA
mmho/cm
Field Water Quality Meter
Temperature
NA
°C
Field Water Quality Meter
Dissolved Oxygen
NA
mg/L
Field Water Quality Meter
Oxidation Reduction Potential
NA
mV
Field Water Quality Meter
Turbidity
NA
NTU
Field Water Quality Meter
Ferrous Iron
NA
mg/L
Field Test Kit
INORGANICS
Aluminum
5
pg/L
EPA 200.7 or 6010C
Antimony
1
pg/L
EPA 200.8 or 6020A
Arsenic
1
pg/L
EPA 200.8 or 6020A
Barium
5
pg/L
EPA 200.7 or 6010C
Beryllium
1
pg/L
EPA 200.8 or 6020A
Boron
50
pg/L
EPA 200.7 or 6010C
Cadmium
1
pg/L
EPA 200.8 or 6020A
Chromium
1
pg/L
EPA 200.7 or 6010C
Cobalt
1
pg/L
EPA 200.8 or 6020A
Copper
0.005
mg/L
EPA 200.7 or 6010C
Iron
10
pg/L
EPA 200.7 or 6010C
Lead
1
pg/L
EPA 200.8 or 6020A
Manganese
5
pg/L
EPA 200.7 or 6010C
Mercury (low level)
0.012
pg/L
EPA 245.7 or 1631
Molybdenum
5
pg/L
EPA 200.7 or 6010C
Nickel
5
pg/L
EPA 200.7 or 6010C
Total Combined Radium (Ra-226 and Ra-228) 4
5
pCi/L
EPA 903.0
Selenium
1
pg/L
EPA 200.8 or 6020A
Strontium
5
pg/L
EPA 200.7 or 6010C
Thallium (low level)
0.2
pg/L
EPA 200.8 or 6020A
Vanadium (low level)
0.3
mg/L
EPA 200.8 or 6020A
Zinc
5
pg/L
EPA 200.7 or 6010C
ANIONS/CATIONS
Alkalinity (as CaCO3)
20
mg/L
SM 2320B
Bicarbonate
20
mg/L
SM 2320
Calcium
0.01
mg/L
EPA 200.7
Carbonate
20
mg/L
SM 2320
Chloride
0.1
mg/L
EPA 300.0 or 9056A
Magnesium
0.005
mg/L
EPA 200.7
Nitrate as Nitrogen
0.023
mg-N/L
EPA 300.0 or 9056A
Potassium
0.1
mg/L
EPA 200.7
Sodium
0.05
mg/L
EPA 200.7
Sulfate
0.1
mg/L
EPA 300.0 or 9056A
Sulfide (as 1-12S) 5
0.05
mg/L
SM4500S-D
Total Dissolved Solids
25
mg/L
SM 2540C
Total Organic Carbon
0.1
mg/L
SM 5310
Total Suspended Solids
2
mg/L
SM 2450D
ADDITIONAL GROUNDWATER CONSTITUENTS
Iron speciation Fe(II), Fe(III)
Vendor Specific
pg/L
IC-ICP-CRC-MS
Manganese Speciation (Mn (ll), Mn(IV))
Vendor Specific
pg/L
IC-ICP-CRC-MS
Notes:
1. Select constituents will be analyzed for total and
dissolved concentrations.
2. RL is the laboratory analytical method reporting
limit.
3. NA indicates not applicable.
4. Voluntary monitoring wells MW-6S and MW-7S and proposed background wells
BG-1 S/D will be sampled for
total combined radium.
5. Sulfide (as 1-12S) will be analyzed for groundwater samples only.
6. All EPA methods and RLs are at or below the respective 2L or 2B Standard for constituents with standards
Tables - Page 5

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Well Name
Well Type
M-16
Boring/Temporary
M-6
Boring/Temporary
MW-10D
Compliance
MW-10D
Compliance
MW-10D
Compliance
MW-10D
Compliance
MW-10D
Compliance
MW-10D
Compliance
MW-10D
Compliance
MW-10D
Compliance
MW-10D
Compliance
MW-10D
Compliance
MW-10D
Compliance
MW-10S
Compliance
MW-10S
Compliance
MW-10S
Compliance
MW-10S
Compliance
MW-10S
Compliance
MW-10S
Compliance
MW-10S
Compliance
MW-10S
Compliance
MW-10S
Compliance
MW-10S
Compliance
MW-10S
Compliance
MW-11D
Compliance
MW-11D
Compliance
MW-11D
Compliance
MW-11D
Compliance
MW-11D
Compliance
MW-11 D
Compliance
MW-11D
Compliance
MW-11D
Compliance
MW-11D
Compliance
MW-11D
Compliance
MW-11D
Compliance
MW-11S
Compliance
MW-11S
Compliance
MW-11S
Compliance
MW-11S
Compliance
MW-11S
Compliance
MW-11S
Compliance
MW-11S
Compliance
MW-11S
Compliance
MW-11S
Compliance
MW-11S
Compliance
MW-11S
Compliance
Analytical Parameter Depth to Water Temp. DO Cond. pH ORP Turbidity Alkalinity Aluminum Antimony" Arsenic Barium
Units Feet C mg/L umhos/cm SU my NTU mg/L CaCO3 pg/L pg/L pg/L pg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard NA NA NA NA 6.5 - 8.5 NA NA NE NE 1 10 700
Hydrostratigraphic Unit
Residuum
Surface Water
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Analytical Method
Field Measurements
Sample Collection Date
2320B4d N/A 200.8
200.8
200.7
Total Dissolved Total Dissolved Total Dissolved Total
10/5/2011
31.39
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
10/5/2011
20.14
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
2/7/2011
16.01
14.25
N/A
68
6.68
N/A
6.59
N/A
N/A
N/A
<1
N/A
<1
N/A
19
6/1/2011
14.66
16.06
N/A
70
6.18
N/A
2.66
N/A
N/A
N/A
<1
N/A
<1
N/A
22
10/5/2011
17.58
15.25
N/A
64
6.48
N/A
2.21
N/A
N/A
N/A
<1
N/A
<1
N/A
21
2/8/2012
16.48
15.04
5.44
62
6.54
350
1.62
N/A
N/A
N/A
<1
N/A
<1
N/A
19
6/6/2012
14.56
15.36
5.74
60
6.34
352
3.28
N/A
N/A
N/A
<1
N/A
<1
N/A
20
10/4/2012
16.94
15.58
5.51
59
6.34
389
0.83
N/A
N/A
N/A
<1
N/A
<1
N/A
19
2/7/2013
15.18
14.6
3.93
59
6.33
367
5.14
23
N/A
N/A
<1
N/A
<1
N/A
19
6/5/2013
14.26
15.74
2.68
58
6.32
374
6.79
21
N/A
<1
<1
<1
<1
18
20
10/1/2013
15.26
16.36
2.85
57
6.36
337
4.52
19
N/A
N/A
<1
N/A
<1
N/A
20
2/6/2014
16.1
14.37
4.75
58
6.3
354
8.59
19
N/A
N/A
<1
N/A
<1
N/A
22
6/4/2014
14.22
15.83
5.23
60
6.25
341
7.36
19
N/A
N/A
<1
N/A
<1
N/A
20
2/7/2011
16.1
14.01
N/A
18
5.66
N/A
12.5
N/A
N/A
N/A
<1
N/A
<1
N/A
42
6/1/2011
14.94
15.63
N/A
20
5.28
N/A
23.8
N/A
N/A
N/A
<1
N/A
<1
N/A
57
10/5/2011
19.1
15.03
N/A
18
5.44
N/A
12.8
N/A
N/A
N/A
<1
N/A
<1
N/A
48
2/8/2012
16.59
14.56
7.48
19
5.56
407
6.72
N/A
N/A
N/A
<1
N/A
<1
N/A
42
6/6/2012
14.85
14.98
8.6
17
5.18
413
11.6
N/A
N/A
N/A
<1
N/A
<1
N/A
47
10/4/2012
17.21
15.63
8.59
16
5.36
470
9.01
N/A
N/A
N/A
<1
N/A
<1
N/A
43
2/7/2013
15.23
14.06
6.58
17
5.1
423
6.52
6.7
N/A
N/A
<1
N/A
<1
N/A
42
6/5/2013
14.45
15.69
6.83
15
5.23
417
5.77
4.1
N/A
<1
<1
<1
<1
40
43
10/1/2013
15.63
16.76
7.92
17
5.21
385
9.12
<0.1
N/A
N/A
<1
N/A
<1
N/A
43
2/6/2014
16.24
14.31
5.29
17
5.14
415
8.3
<0.1
N/A
N/A
<1
N/A
<1
N/A
46
6/4/2014
14.57
15.79
7.27
17
5.14
376
16.8
<5
N/A
N/A
<1
N/A
<1
N/A
46
2/7/2011
44.31
14.65
N/A
81
7.51
N/A
35
N/A
N/A
N/A
<1
N/A
<1
N/A
67
6/1/2011
44.33
17.74
N/A
88
6.89
N/A
33.3
N/A
N/A
N/A
<1
N/A
<1
N/A
69
10/5/2011
44.99
15.89
N/A
70
6.98
N/A
12.2
N/A
N/A
N/A
<1
N/A
<1
N/A
63
2/8/2012
44.92
14.24
5
71
7.1
323
8.89
N/A
N/A
N/A
<1
N/A
<1
N/A
56
6/6/2012
44.58
16.03
5.24
70
6.95
353
14.1
N/A
N/A
N/A
<1
N/A
<1
N/A
57
10/4/2012
45.24
16.24
5.63
60
6.9
390
10.1
N/A
N/A
N/A
<1
N/A
<1
N/A
55
2/6/2013
45.53
15.6
6.51
59
6.86
342
7.54
24
N/A
N/A
<1
N/A
<1
N/A
50
6/5/2013
44.69
16.21
6.01
53
6.65
361
6.98
20
N/A
<1
<1
<1
<1
56
62
10/1/2013
44.01
16.6
5.81
55
6.74
340
4.63
19
N/A
N/A
<1
N/A
<1
N/A
61
2/6/2014
44.18
14.17
6.69
53
6.61
327
8.41
20
N/A
N/A
<1
N/A
<1
N/A
66
6/4/2014
43.12
17.03
6.69
53
6.69
347
6.47
20
N/A
N/A
<1
N/A
<1
N/A
62
2/7/2011
44.8
14.77
N/A
34
6.38
N/A
15.3
N/A
N/A
N/A
<1
N/A
<1
N/A
25
6/1/2011
44.87
16.49
N/A
37
6.11
N/A
22
N/A
N/A
N/A
<1
N/A
<1
N/A
34
10/5/2011
45.43
15.92
N/A
37
6.28
N/A
18.3
N/A
N/A
N/A
<1
N/A
<1
N/A
29
2/8/2012
45.41
13.98
7.37
37
6.29
366
12.6
N/A
N/A
N/A
<1
N/A
<1
N/A
28
6/6/2012
45.01
16.97
6.74
37
6.03
388
11.7
N/A
N/A
N/A
<1
N/A
<1
N/A
29
10/4/2012
45.63
16.31
6.98
37
6.09
419
13.8
N/A
N/A
N/A
<1
N/A
<1
N/A
32
2/6/2013
45.96
15.51
7.42
37
6.06
379
9.51
12
N/A
N/A
<1
N/A
<1
N/A
28
6/5/2013
45.12
16.49
7.31
38
5.94
392
5.37
11
N/A
<1
<1
<1
<1
28
29
10/1/2013
44.33
16.88
7.09
40
6.08
366
5.76
10
N/A
N/A
<1
N/A
<1
N/A
30
2/6/2014
44.51
13.71
7.56
40
5.99
364
8.43
11
N/A
N/A
<1
N/A
<1
N/A
34
6/4/2014
43.51
17.08
7.87
42
5.95
378
6.24
9.9
N/A
N/A
<1
N/A
<1
N/A
33
Tables - Page 6

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Analytical Parameter Depth to Water Temp. DO Cond. pH ORP Turbidity Alkalinity
Units Feet C mg/L umhos/cm SU my NTU mg/L CaCO3
Well Name
MW-12D
MW-12D
MW-12D
MW-12D
MW-12D
MW-12D
MW-12D
MW-12D
MW-12D
MW-12D
MW-12D
MW-12S
MW-12S
MW-12S
MW-12S
MW-12S
MW-12S
MW-12S
MW-12S
MW-12S
MW-12S
MW-12S
MW-13D
MW-13D
MW-13D
MW-13D
MW-13D
MW-13D
MW-13D
MW-13D
MW-13D
MW-13D
MW-13D
MW-13S
MW-13S
MW-13S
MW-13S
MW-13S
MW-13S
MW-13S
MW-13S
MW-13S
MW-13S
MW-13S
MW-14D
MW-14D
Well Type
Compliance
Compliance
Compliance
Compliance
Compliance
(Compliance
Compliance
Compliance
(Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
(Compliance
Compliance
Compliance
(Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
(Compliance
Compliance
Compliance
(Compliance
Compliance
(Compliance
Compliance
(Compliance
Compliance
15A NCAC 02L .0202(g) Groundwater Quality Standard NA NA NA NA 6.5 - 8.5 NA NA NE
Hydrostratigraphic Unit
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
;esiduum
:esiduum
;esiduum
:esiduum
;esiduum
:esiduum
;esiduum
:esiduum
;esiduum
:esiduum
;esiduum
edrock
edrock
,edrock
,edrock
,edrock
,edrock
,edrock
edrock
edrock
edrock
edrock
;esiduum
:esiduum
;esiduum
:esiduum
;esiduum
:esiduum
;esiduum
;esiduum
;esiduum
:esiduum
;esiduum
edrock
edrock
Analytical Method
Sample Collection Date
2/7/2011
6/1 /2011
10/5/2011
2/8/2012
6/6/2012
10/4/2012
2/6/2013
6/5/2013
10/1 /2013
2/6/2014
6/4/2014
2/7/2011
6/1 /2011
10/5/2011
2/8/2012
6/6/2012
10/4/2012
2/6/2013
6/5/2013
10/1 /2013
2/6/2014
6/4/2014
2/7/2011
6/1 /2011
10/5/2011
2/8/2012
6/6/2012
10/4/2012
2/6/2013
6/5/2013
1011 /2013
2/6/2014
6/4/2014
2/7/2011
6/1 /2011
10/5/2011
2/8/2012
6/6/2012
10/4/2012
2/6/2013
6/5/2013
10/1 /2013
2/6/2014
6/4/2014
2/7/2011
6/1 /2011
14.16
13.31
16.1
12.98
13.09
16.44
14.59
12.55
13.45
11.07
10.66
11.52
11.41
15.31
10.16
11.57
15.97
12.26
10.78
12.66
8.74
9.72
3.32
3.43
4.62
3.84
3.88
4.85
4.25
3.61
3.66
2.85
2.33
5.45
5.59
6.61
5.9
5.95
6.82
6.31
5.78
5.88
5.17
4.75
37.67
37.86
14.58
15.91
15.55
14.78
15.21
15.41
15.14
15.34
15.42
14.88
15.44
13.61
16.03
15.44
13.8
14.74
15.74
13.54
15.96
15.86
13.04
15.27
14.57
15.74
15.02
14.66
15.14
15.52
14.3
15.35
16.04
14.06
15.21
13.47
14.88
16.26
12.49
14.76
16.94
12.87
15.7
16.32
11.48
15.08
14.22
16.27
Field I
N/A
N/A
N/A
3.08
3.13
3.04
3.25
3.99
2.76
3.2
3.09
N/A
N/A
N/A
7.1
7.77
3.46
7.59
7.9
7.87
7.59
3.39
N/A
N/A
N/A
5.38
5.39
3.48
3.29
5.22
5.21
3.17
3.19
N/A
N/A
N/A
3.74
3.63
6.6
3.74
3.82
5.41
7.46
7.1
N/A
N/A
dleasurements
72.1
71.4
71.7
68
68
67
66
65
67
65
65
20.8
19.1
23.9
23
17
23
18
16
21
17
16
88.7
90.5
89.3
90
88
90
89
89
91
90
91
84
96.6
86.5
87
84
87
85
85
88
85
87
683.7
674.3
2320B4d
5.89
N/A
11
N/A
6.26
N/A
13.8
N/A
6.37
N/A
12.2
N/A
6.35
377
9.8
N/A
6.34
388
6.81
N/A
6.26
379
9.8
N/A
6.25
363
9.6
23
6.02
387
8.17
20
6.24
352
8.93
20
6.2
345
8.17
20
6.14
394
8.55
19
5.19
N/A
6.89
N/A
5.26
N/A
3.3
N/A
5.66
N/A
5.99
N/A
5.21
443
1.65
N/A
5.07
457
1.92
N/A
5.69
416
3.35
N/A
5.35
427
4.04
5.8
4.89
438
2.19
1.5
5.49
398
3.45
2
4.96
444
2.05
<0.1
5.11
432
2.36
<5
6.16
N/A
2.66
N/A
6.17
N/A
1.32
N/A
6.19
N/A
4.6
N/A
6.39
382
1.03
N/A
6.33
395
0.44
N/A
6.34
392
0.6
N/A
6.35
366
1.59
32
5.86
393
0.92
30
6.22
364
1.16
29
6.24
345
1.89
30
6.11
378
1.59
29
6.14
N/A
61.8
N/A
6.18
N/A
17.8
N/A
5.83
N/A
27.7
N/A
6.27
380
7.91
N/A
6.26
394
7.69
N/A
6.14
386
23.9
N/A
6.32
375
22.9
30
5.76
396
19.1
28
6.07
370
26.7
28
6.26
344
16.7
29
6.01
371
4.78
28
5.31
N/A
2.95
N/A
5.56
N/A
2.91
N/A
Aluminum
pg/L
NE '
N/A
Total
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Antimony*
pg/L
1
Arsenic
pg/L
10
200.8
200.7
Dissolved
Total
Dissolved
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
<1
<1
<1
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
<1
<1
<1
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
<1
<1
<1
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
<1
<1
<1
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
<1
N/A
I
Total
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
Barium
pg/L
700
200.7
Dissolved
N/A
N/A
N/A
N/A
N/A
N/A
N/A
21
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
52
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
45
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
38
N/A
N/A
N/A
N/A
N/A
Total
26
30
28
29
27
34
27
27
28
27
25
56
37
45
54
42
41
36
52
41
73
22
42
46
45
43
46
43
44
47
46
49
45
46
43
43
39
46
49
44
51
48
47
41
42
43
Tables - Page 7

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Analytical Parameter Depth to Water Temp. DO Cond. pH ORP Turbidity Alkalinity
Units Feet C mg/L umhos/cm SU my NTU mg/L CaCO3
Well Name
MW-14D
MW-14D
MW-14D
MW-14D
MW-14D
MW-14D
MW-14D
MW-14D
MW-14D
MW-14S
MW-14S
MW-14S
MW-14S
MW-14S
MW-14S
MW-14S
MW-14S
MW-14S
MW-14S
MW-14S
MW-4
MW-4
MW-4
MW-4
MW-4
MW-4
MW-4
MW-4
MW-4
MW-4
MW-4
MW-4
MW-4
MW-4
MW-4
MW-4
MW-4
MW-4D
MW-4D
MW-4D
MW-4D
MW-4D
MW-4D
MW-4D
MW-4D
MW-4D
Well Type
Compliance
Compliance
Compliance
Compliance
(Compliance
Compliance
Compliance
Compliance
(Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
(Compliance
Compliance
(Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
(Compliance
Compliance
(Compliance
Compliance
(Compliance
Compliance
15A NCAC 02L .0202(g) Groundwater Quality Standard NA NA NA NA 6.5 - 8.5 NA NA NE
Hydrostratigraphic Unit
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Analytical Method
Sample Collection Date
10/5/2011
2/8/2012
6/6/2012
10/4/2012
2/7/2013
6/5/2013
10/1 /2013
2/6/2014
6/4/2014
2/7/2011
6/1 /2011
10/5/2011
2/8/2012
6/6/2012
10/4/2012
2/7/2013
6/5/2013
10/1 /2013
2/6/2014
6/4/2014
11 /8/2007
2/12/2008
8/28/2008
2/16/2009
8/10/2009
2/8/2010
2/7/2011
6/1 /2011
10/5/2011
2/8/2012
6/6/2012
10/4/2012
2/6/2013
6/5/2013
10/1 /2013
2/6/2014
6/4/2014
11 /8/2007
2/12/2008
8/28/2008
2/16/2009
8/10/2009
2/8/2010
2/7/2011
6/1 /2011
10/5/2011
38.71
38.16
38.15
38.77
38.31
37.91
38.08
37.66
36.76
37.17
37.32
38.18
37.67
37.61
38.23
37.82
37.38
37.51
37.1
36.17
N/A
N/A
N/A
N/A
N/A
N/A
38.76
38.41
39.34
38.77
38.42
38.48
38.81
37.72
37.08
37.2
36.3
N/A
N/A
N/A
N/A
N/A
N/A
38.8
38.39
39.38
15.81
14.95
15.29
15.56
14.75
15.76
16.03
14.48
15.8
14.49
16.34
15.77
14.7
15.26
15.93
13.86
15.96
16.72
12.21
16.1
14.16
14.26
16.69
13.59
17.28
13.24
13.27
16.95
15.21
14.94
16.77
16.08
16.21
16.57
17.04
14.3
16.21
14.59
14.52
15.91
14.52
16.23
14.21
13.94
16.68
15.17
Field I
N/A
D.71
1.09
D.63
D.71
181
3.72
D.74
D.71
N/A
N/A
N/A
2.35
3.29
2.67
3.22
3.89
3.66
4.54
4.2
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
5.81
3.89
7.13
9.12
3.38
7.88
8.3
3.08
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
dleasurements
646.6
634
619
621
611
594
597
578
597
815.7
792.9
760.8
741
724
748
744
735
743
723
749
43.2
48.2
59.2
41.3
47.3
47.2
44
48
49.1
45
44
49
46
46
45
46
46
75.2
78.5
76.5
69.3
75.7
78.8
73
77
76
232064d
5.58
N/A
6.57
N/A
5.49
394
1.82
N/A
5.54
415
1.2
N/A
5.51
350
1.51
N/A
5.55
408
1.67
28
5.48
411
1.07
26
5.5
350
1.29
25
5.49
383
2.73
26
5.46
381
5.18
24
5.15
N/A
8.39
N/A
5.36
N/A
2.74
N/A
5.43
N/A
9.98
N/A
5.34
414
3.39
N/A
5.38
424
2.96
N/A
5.35
383
9.86
N/A
5.48
415
7.73
19
5.4
427
6.47
18
5.43
329
20.3
17
5.43
401
5.21
19
5.38
395
13.6
16
5.65
N/A
6.71
19
5.86
N/A
14.4
22
5.79
N/A
2.93
21
6
N/A
4.33
24
5.64
N/A
6.92
20
6.25
N/A
3.59
19
6.03
N/A
7.45
N/A
5.82
N/A
11.6
N/A
5.86
N/A
5.32
N/A
5.52
410
1.57
N/A
5.73
396
3.83
N/A
5.63
416
4.38
N/A
5.89
389
7.6
21
5.84
394
5.92
20
5.86
376
5.16
13
5.65
385
2.54
15
5.53
379
12.5
11
5.88
N/A
7.47
36
6.1
N/A
3.92
37
5.92
N/A
2.86
36
6.07
N/A
2.48
37
5.96
N/A
5.86
35
6.46
N/A
3.22
33
6.22
N/A
4.85
N/A
6.07
N/A
0.74
N/A
6.16
N/A
0.74
N/A
Aluminum
pg/L
NE '
N/A
Total
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Antimony* Arsenic Barium
pg/L pg/L pg/L
10
200.8
Dissolved
200.8
Total
Dissolved
Total
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
<1
<1
<1
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
<1
<1
<1
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
<1
<1
<1
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
700
200.7
Dissolved
N/A
N/A
N/A
N/A
N/A
37
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
21
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
46
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Total
41
38
39
38
36
38
37
37
36
28
25
24
24
24
28
23
31
33
28
26
49
51
50
47
53
46.7
48
55
53
49
50
46
45
48
46
48
48
43
44
44
41
42
39.5
43
43
43
Tables - Page 8

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Analytical Parameter Depth to Water Temp. DO Cond. pH ORP Turbidity Alkalinity
Units Feet C mg/L umhos/cm SU my NTU mg/L CaCO3
Well Name
MW-4D
MW-4D
MW-4D
MW-4D
MW-4D
MW-4D
MW-4D
MW-4D
MW-6D
MW-6D
MW-6D
MW-6D
MW-6D
MW-6D
MW-6S
MW-6S
MW-6S
MW-6S
MW-6S
MW-6S
MW-6S
MW-6S
MW-7D
MW-7D
MW-7D
MW-7D
MW-7D
MW-7D
MW-7S
MW-7S
MW-7S
MW-7S
MW-7S
MW-7S
MW-7S
MW-7S
MW-7S
MW-8D
MW-8D
MW-8D
MW-8D
MW-8D
MW-8D
MW-8S
MW-8S
MW-8S
Well Type
Compliance
Compliance
(Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
(Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
(Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
15A NCAC 02L .0202(g) Groundwater Quality Standard NA NA NA NA 6.5 - 8.5 NA NA NE
Hydrostratigraphic Unit
edrock
edrock
edrock
,edrock
edrock
edrock
,edrock
edrock
,edrock
edrock
edrock
edrock
edrock
edrock
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
edrock
edrock
,edrock
edrock
edrock
edrock
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
edrock
edrock
edrock
,edrock
edrock
edrock
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
Analytical Method
Sample Collection Date
2/8/2012
6/6/2012
10/4/2012
2/6/2013
6/5/2013
1011 /2013
2/6/2014
6/4/2014
11 /8/2007
2/12/2008
8/28/2008
2/16/2009
8/10/2009
2/8/2010
11 /8/2007
8/28/2008
2/16/2009
8/10/2009
2/8/2010
2/7/2011
6/1 /2011
10/5/2011
11 /8/2007
2/12/2008
8/28/2008
2/16/2009
8/10/2009
2/8/2010
11 /8/2007
2/12/2008
8/28/2008
2/16/2009
8/10/2009
2/8/2010
2/7/2011
6/1 /2011
10/5/2011
11 /8/2007
2/12/2008
8/28/2008
2/16/2009
8/10/2009
2/8/2010
11 /8/2007
2/12/2008
8/28/2008
38.65
38.31
38.33
38.67
37.55
36.98
37.06
36.11
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
23.37
22.58
23.71
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
14.14
13.31
14.8
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
14.85
15.87
15.87
15.67
15.87
15.93
15.35
16
17.09
15.97
17.25
15.23
17.91
16.33
18.78
18.75
13.52
18.62
15.27
N/A
N/A
N/A
15.41
14.68
17.01
14.53
17.66
15.21
17.04
14.35
20.79
14.9
20.3
14.18
N/A
N/A
N/A
16.11
15.13
16.9
17.15
17.73
15.52
16.83
16.1
17.27
Field 1
5.04
5.92
5.98
5.99
5.75
5.47
5.66
5.54
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
dleasurements
76
74
75
75
77
77
76
79
115
113
113.2
115
116
116
136.3
180.5
535
778
802
N/A
N/A
N/A
473.2
466
461.7
456
454
457
202.1
541
1160
1922
1333
1550
N/A
N/A
N/A
517.8
510
519
502
517
520
592
381
875
2320B4d
6.09
378
7.48
N/A
6.01
383
1.08
N/A
6.08
411
0.7
N/A
6.02
387
1.85
35
5.98
391
0.59
34
6.08
369
1.03
31
6.03
375
2.15
32
5.88
386
5.63
30
6.18
N/A
17.8
44
6.15
N/A
10.4
44
6.06
N/A
23.4
44
6.15
N/A
10A
43
6.04
N/A
5.66
42
6.42
N/A
4.36
41
4.68
N/A
891
N/A
4.38
N/A
2.82
<5
4.02
N/A
8.25
<5
3.94
N/A
4.81
<5
4.42
N/A
30.4
<5
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
7.32
N/A
0.2
104
7.3
N/A
1.13
110
7.37
N/A
2.23
100
7.37
N/A
0.21
110
7.36
N/A
1
97
7.6
N/A
1.29
96
4.86
N/A
2.5
<5
4.4
N/A
2.4
<5
4.22
N/A
10
<5
4.1
N/A
8.87
<5
4.2
N/A
17
<5
4.45
N/A
10.7
<5
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
6.77
N/A
57
144
6.78
N/A
46.4
150
6.67
N/A
12.2
140
6.75
N/A
5.97
150
6.75
N/A
7.34
140
6.95
N/A
5.53
140
6.33
N/A
11
251
6.25
N/A
5.08
150
6.34
N/A
1.84
300
Aluminum
pg/L
NE '
N/A
Total
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Antimony* Arsenic Barium
pg/L pg/L pg/L
10
200.8
Dissolved
200.8
Total
Dissolved
Total
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
<1
<1
<1
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
<1
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
1.9
N/A
N/A
N/A
1.8
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
6
N/A
N/A
N/A
5.3
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
N/A
N/A
N/A
<2
700
200.7
Dissolved
N/A
N/A
N/A
N/A
43
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Total
46
43
41
41
43
42
42
42
58
62
64
62
63
57.2
N/A
202
580
665
1240
N/A
N/A
N/A
50
53
53
51
52
50.6
65
169
641
417
448
318
N/A
N/A
N/A
42
35
25
22
22
31
145
109
180
Tables - Page 9

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Well Name
Well Type
MW-8S
Voluntary
MW-8S
Voluntary
MW-8S
Voluntary
MW-8S
Voluntary
MW-8S
Voluntary
MW-8S
Voluntary
MW-9D
Voluntary
MW-9D
Voluntary
MW-9D
Voluntary
MW-9D
Voluntary
MW-9D
Voluntary
MW-9D
Voluntary
MW-9S
Voluntary
MW-9S
Voluntary
MW-9S
Voluntary
MW-9S
Voluntary
MW-9S
Voluntary
MW-9S
Voluntary
MW-9S
Voluntary
MW-9S
Voluntary
MW-9S
Voluntary
Analytical Parameter
Depth to Water
Temp.
DO Cond.
Units
Feet
C
mg/L umhos/cm
15A NCAC 02L .0202(g) Groundwater Quality Standard
NA
NA
NA NA
Hydrostratigraphic Unit
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
edrock
edrock
,edrock
edrock
edrock
edrock
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
Analytical Method
Sample Collection Date
2/16/2009
8/10/2009
2/8/2010
2/7/2011
6/1/2011
10/5/2011
11 /8/2007
2/12/2008
8/28/2008
2/16/2009
8/10/2009
2/8/2010
11 /8/2007
2/12/2008
8/28/2008
2/16/2009
8/10/2009
2/8/2010
2/7/2011
6/1 /2011
10/5/2011
N/A
N/A
N/A
17.79
16.27
18.99
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
19.05
17.18
19.64
16.9
17.65
15.64
N/A
N/A
N/A
16.04
15.28
16.48
16.1
17.62
15.1
16.87
15.64
17.14
15.88
19
14.67
N/A
N/A
N/A
Field I
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Measurements
985
947
927
N/A
N/A
N/A
294.3
310.2
315.2
322
332
346
526.4
502.8
504.1
509
514
509
N/A
N/A
N/A
pH ORP
SU my
6.5 - 8.5 NA
6.53 N/A
6.54 N/A
6.79 N/A
N/A N/A
N/A N/A
N/A N/A
5.62 N/A
5.78 N/A
5.73 N/A
5.75 N/A
5.79 N/A
5.99 N/A
6.65 N/A
6.77 N/A
6.74 N/A
6.77 N/A
6.75 N/A
6.99 N/A
N/A N/A
N/A N/A
N/A N/A
Turbidity
Alkalinity
Aluminum
NTU
mg/L CaCO3
pg/L
NA
NE
NE
2320B4d
N/A
Total
21.7
460
N/A
7.5
<5
N/A
10.8
440
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
6.91
38.5
N/A
5.04
39
N/A
2.23
38
N/A
1.99
39
N/A
1.64
37
N/A
1.97
37
N/A
8.74
207
N/A
5.76
200
N/A
3.88
200
N/A
1.32
210
N/A
2.31
200
N/A
2.05
200
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Antimony*
pg/L
1
Arsenic
pg/L
10
Barium
pg/L
700
200.8 200.8 200.7
Dissolved
Total
Dissolved
Total
Dissolved
Total
N/A
N/A
N/A
<2
N/A
243
N/A
N/A
N/A
<1
N/A
232
N/A
N/A
N/A
<1
N/A
154
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<2
N/A
74
N/A
N/A
N/A
<2
N/A
81
N/A
N/A
N/A
<2
N/A
82
N/A
N/A
N/A
<2
N/A
84
N/A
N/A
N/A
<1
N/A
87
N/A
N/A
N/A
<1
N/A
87.1
N/A
N/A
N/A
<2
N/A
197
N/A
N/A
N/A
<2
N/A
203
N/A
N/A
N/A
<2
N/A
217
N/A
N/A
N/A
<2
N/A
266
N/A
N/A
N/A
<1
N/A
247
N/A
N/A
N/A
<1
N/A
225
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Tables - Page 10

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Well Name
4-16
4-6
4W-10D
4W-10D
4W-10D
4W-10D
4W-10D
4W-10D
4W-10D
4W-10D
4W-10D
4W-10D
4W-10D
4W-10S
4W-10S
4W-10S
4W-10S
4W-10S
4W-10S
4W-10S
4W-10S
4W-10S
4W-10S
4W-10S
4W-11D
4W-11D
4W-11D
4W-11D
4W-11D
4W-11D
4W-11D
4W-11D
4W-11D
4W-11D
4W-11D
4W-11S
4W-11S
4W-11S
4W-11S
4W-11S
4W-11S
4W-11S
4W-11 S
4W-11S
4W-11S
4W-11S
Well Type
Boring/Temporary
Boring/Temporary
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Analytical Parameter
Beryllium*
Boron
Cadmium
Calcium
Chloride
Chromium
Cobalt*
Copper
Fluoride
Units
pg/L
pg/L
pg/L
mg/L
mg/L
pg/L
pg/L
mg/L
mg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard
4
700
2
NE
250
10
1
1
2
Analytical Method 200.7 200.8 200.7 300 200.7 200.8 200.7
Hydrostratigraphic Unit Sample Collection Date Total Dissolved Total Dissolved Total Dissolved Total Total Dissolved Total Dissolved Total Dissolved Total F, tot (mg/L)
Residuum
Surface Water
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
10/5/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
10/5/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
2/7/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
1.5
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/1/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
1.6
N/A
<5
N/A
N/A
N/A
<0.005
N/A
10/5/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
1.5
N/A
<5
N/A
N/A
N/A
<0.005
N/A
2/8/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
1.5
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/6/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
1.4
N/A
<5
N/A
N/A
N/A
<0.005
N/A
10/4/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
1.4
N/A
<5
N/A
N/A
N/A
<0.005
N/A
2/7/2013
N/A
N/A
<50
N/A
<1
N/A
3.88
1.4
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/5/2013
N/A
<50
<50
<1
<1
4.08
3.88
1.4
<5
<5
N/A
N/A
<0.005
<0.005
N/A
10/1/2013
N/A
N/A
<50
N/A
<1
N/A
4.02
1.3
N/A
<5
N/A
N/A
N/A
<0.005
N/A
2/6/2014
N/A
N/A
<50
N/A
<1
N/A
4.27
1.5
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/4/2014
N/A
N/A
<50
N/A
<1
N/A
3.99
1.4
N/A
<5
N/A
N/A
N/A
<0.005
N/A
2/7/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
0.99
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/1/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
1
N/A
<5
N/A
N/A
N/A
<0.005
N/A
10/5/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
0.91
N/A
<5
N/A
N/A
N/A
<0.005
N/A
2/8/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
0.97
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/6/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
1
N/A
<5
N/A
N/A
N/A
<0.005
N/A
10/4/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
1
N/A
<5
N/A
N/A
N/A
<0.005
N/A
2/7/2013
N/A
N/A
<50
N/A
<1
N/A
0.341
1.1
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/5/2013
N/A
<50
<50
<1
<1
0.386
0.389
1.1
<5
<5
N/A
N/A
<0.005
<0.005
N/A
10/1/2013
N/A
N/A
<50
N/A
<1
N/A
0.19
0.93
N/A
<5
N/A
N/A
N/A
<0.005
N/A
2/6/2014
N/A
N/A
<50
N/A
<1
N/A
0.332
1.2
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/4/2014
N/A
N/A
<50
N/A
<1
N/A
0.28
1.1
N/A
<5
N/A
N/A
N/A
<0.005
N/A
2/7/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
2.3
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/1/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
2.2
N/A
<5
N/A
N/A
N/A
<0.005
N/A
10/5/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
2.2
N/A
5
N/A
N/A
N/A
<0.005
N/A
2/8/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
2.2
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/6/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
2.1
N/A
<5
N/A
N/A
N/A
<0.005
N/A
10/4/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
2.1
N/A
<5
N/A
N/A
N/A
<0.005
N/A
2/6/2013
N/A
N/A
<50
N/A
<1
N/A
3.08
2.1
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/5/2013
N/A
<50
<50
<1
<1
3.29
3.24
2.1
6
7
N/A
N/A
<0.005
<0.005
N/A
10/1/2013
N/A
N/A
<50
N/A
<1
N/A
3.27
2
N/A
7
N/A
N/A
N/A
<0.005
N/A
2/6/2014
N/A
N/A
<50
N/A
<1
N/A
3.47
2.2
N/A
6
N/A
N/A
N/A
<0.005
N/A
6/4/2014
N/A
N/A
<50
N/A
<1
N/A
3.26
2
N/A
7
N/A
N/A
N/A
<0.005
N/A
2/7/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
2.8
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/1/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
2.7
N/A
<5
N/A
N/A
N/A
<0.005
N/A
10/5/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
2.6
N/A
<5
N/A
N/A
N/A
<0.005
N/A
2/8/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
2.6
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/6/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
2.5
N/A
<5
N/A
N/A
N/A
<0.005
N/A
10/4/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
2.5
N/A
<5
N/A
N/A
N/A
<0.005
N/A
2/6/2013
N/A
N/A
<50
N/A
<1
N/A
1.51
2.6
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/5/2013
N/A
<50
<50
<1
<1
1.59
1.62
2.5
<5
<5
N/A
N/A
<0.005
<0.005
N/A
10/1/2013
N/A
N/A
<50
N/A
<1
N/A
1.68
2.5
N/A
<5
N/A
N/A
N/A
<0.005
N/A
2/6/2014
N/A
N/A
<50
N/A
<1
N/A
1.75
2.7
N/A
<5
N/A
N/A
N/A
<0.005
N/A
6/4/2014
N/A
N/A
<50
N/A
<1
N/A
1.71
2.6
N/A
<5
N/A
N/A
N/A
<0.005
N/A
Tables - Page 11

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Analytical Parameter Beryllium* Boron Cadmium Calcium
Units pg/L pg/L pg/L mg/L
Chloride Chromium
mg/L pg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard 4 700 2 NE 250
Analytical Method
200.7
Total
200.8
Dissolved
200.7
300
Total
Well Name
Well Type
Hydrostratigraphic Unit
Sample Collection Date
Total
Dissolved
Total
Dissolved
Total
MW-12D
Compliance
Transition (PWR)
2/7/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
1.1
MW-12D
Compliance
Transition (PWR)
6/1/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
1.1
MW-12D
Compliance
Transition (PWR)
10/5/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
1.1
MW-12D
Compliance
Transition (PWR)
2/8/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
1.1
MW-12D
Compliance
Transition (PWR)
6/6/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
1.1
MW-12D
Compliance
Transition (PWR)
10/4/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
1.1
MW-12D
Compliance
Transition (PWR)
2/6/2013
N/A
N/A
<50
N/A
<1
N/A
3.85
1.1
MW-12D
Compliance
Transition (PWR)
6/5/2013
N/A
<50
<50
<1
<1
3.77
3.9
1.1
MW-12D
Compliance
Transition (PWR)
10/1/2013
N/A
N/A
<50
N/A
<1
N/A
3.92
1
MW-12D
Compliance
Transition (PWR)
2/6/2014
N/A
N/A
<50
N/A
<1
N/A
4.07
1.2
MW-12D
Compliance
Transition (PWR)
6/4/2014
N/A
N/A
<50
N/A
<1
N/A
3.78
1.1
MW-12S
Compliance
Residuum
2/7/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
1.5
MW-12S
Compliance
Residuum
6/1/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
1.4
MW-12S
Compliance
Residuum
10/5/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
1.1
MW-12S
Compliance
Residuum
2/8/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
1.7
MW-12S
Compliance
Residuum
6/6/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
1.5
MW-12S
Compliance
Residuum
10/4/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
1.2
MW-12S
Compliance
Residuum
2/6/2013
N/A
N/A
<50
N/A
<1
N/A
0.3
1.5
MW-12S
Compliance
Residuum
6/5/2013
N/A
<50
<50
<1
<1
0.229
0.237
1.6
MW-12S
Compliance
Residuum
10/1/2013
N/A
N/A
<50
N/A
<1
N/A
0.425
1.2
MW-12S
Compliance
Residuum
2/6/2014
N/A
N/A
<50
N/A
<1
N/A
0.412
1.9
MW-12S
Compliance
Residuum
6/4/2014
N/A
N/A
<50
N/A
<1
N/A
0.078
1.3
MW-13D
Compliance
Bedrock
2/7/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
4.8
MW-13D
Compliance
Bedrock
6/1/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
4.9
MW-13D
Compliance
Bedrock
10/5/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
5
MW-13D
Compliance
Bedrock
2/8/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
4.9
MW-13D
Compliance
Bedrock
6/6/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
4.6
MW-13D
Compliance
Bedrock
10/4/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
4.3
MW-13D
Compliance
Bedrock
2/6/2013
N/A
N/A
<50
N/A
<1
N/A
6.48
4.7
MW-13D
Compliance
Bedrock
6/5/2013
N/A
<50
<50
<1
<1
6.77
6.92
4.6
MW-13D
Compliance
Bedrock
10/1/2013
N/A
N/A
<50
N/A
<1
N/A
6.98
4.6
MW-13D
Compliance
Bedrock
2/6/2014
N/A
N/A
<50
N/A
<1
N/A
7.19
5
MW-13D
Compliance
Bedrock
6/4/2014
N/A
N/A
<50
N/A
<1
N/A
6.86
4.6
MW-13S
Compliance
Residuum
2/7/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
4.6
MW-13S
Compliance
Residuum
6/1/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
4.7
MW-13S
Compliance
Residuum
10/5/2011
N/A
N/A
<50
N/A
<1
N/A
N/A
4.8
MW-13S
Compliance
Residuum
2/8/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
4.8
MW-13S
Compliance
Residuum
6/6/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
4.3
MW-13S
Compliance
Residuum
10/4/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
4.8
MW-13S
Compliance
Residuum
2/6/2013
N/A
N/A
<50
N/A
<1
N/A
6.3
4.5
MW-13S
Compliance
Residuum
6/5/2013
N/A
<50
<50
<1
<1
6.37
6.66
4.3
MW-13S
Compliance
Residuum
10/1/2013
N/A
N/A
<50
N/A
<1
N/A
6.57
4.3
MW-13S
Compliance
Residuum
2/6/2014
N/A
N/A
<50
N/A
<1
N/A
6.74
4.7
MW-13S
Compliance
Residuum
6/4/2014
N/A
N/A
<50
N/A
<1
N/A
6.57
4.3
MW-14D
Compliance
Bedrock
2/7/2011
N/A
N/A
3600
N/A
<1
N/A
N/A
3.3
MW-14D
Compliance
Bedrock
6/1/2011
N/A
N/A
3660
N/A
<1
N/A
N/A
3.4
Cobalt* Copper Fluoride
pg/L mg/L mg/L
10
200.7
1
1
2
200.8
200.7
Dissolved
Dissolved
Total
F, tot (mg/L)
Dissolved
Total
Total
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
<5
<5
N/A
N/A
<0.005
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
<5
<5
N/A
N/A
<0.005
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
<5
<5
N/A
N/A
<0.005
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
<5
<5
N/A
N/A
<0.005
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
Tables - Page 12

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Analytical Parameter Beryllium* Boron Cadmium Calcium
Units pg/L pg/L pg/L mg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard 4 700
Analytical Method
200.7
2
200.8
Well Name Well Type Hydrostratigraphic Unit Sample Collection Date Total Dissolved Total Dissolved Total
AW-14D
Compliance
Bedrock
10/5/2011
N/A
N/A
3520
N/A
<1
4W-14D
Compliance
Bedrock
2/8/2012
N/A
N/A
3300
N/A
<1
AW-14D
Compliance
Bedrock
6/6/2012
N/A
N/A
3320
N/A
<1
4W-14D
Compliance
Bedrock
10/4/2012
N/A
N/A
3220
N/A
<1
4W-14D
Compliance
Bedrock
2/7/2013
N/A
N/A
2960
N/A
<1
4W-14D
Compliance
Bedrock
6/5/2013
N/A
3040
3060
<1
<1
4W-14D
Compliance
Bedrock
10/1/2013
N/A
N/A
2970
N/A
<1
4W-14D
Compliance
Bedrock
2/6/2014
N/A
N/A
2910
N/A
<1
4W-14D
Compliance
Bedrock
6/4/2014
N/A
N/A
2750
N/A
<1
4W-14S
Compliance
Residuum
2/7/2011
N/A
N/A
4440
N/A
<1
4W-14S
Compliance
Residuum
6/1/2011
N/A
N/A
4530
N/A
<1
4W-14S
Compliance
Residuum
10/5/2011
N/A
N/A
4160
N/A
<1
4W-14S
Compliance
Residuum
2/8/2012
N/A
N/A
4010
N/A
<1
4W-14S
Compliance
Residuum
6/6/2012
N/A
N/A
3930
N/A
<1
4W-14S
Compliance
Residuum
10/4/2012
N/A
N/A
3820
N/A
<1
4W-14S
Compliance
Residuum
2/7/2013
N/A
N/A
3640
N/A
<1
4W-14S
Compliance
Residuum
6/5/2013
N/A
3900
3800
<1
<1
4W-14S
Compliance
Residuum
10/1/2013
N/A
N/A
3750
N/A
<1
4W-14S
Compliance
Residuum
2/6/2014
N/A
N/A
3660
N/A
<1
4W-14S
Compliance
Residuum
6/4/2014
N/A
N/A
3190
N/A
<1
4W-4
Compliance
Residuum
11/8/2007
N/A
N/A
<100
N/A
<0.5
4W-4
Compliance
Residuum
2/12/2008
N/A
N/A
<100
N/A
<0.5
4W-4
Compliance
Residuum
8/28/2008
N/A
N/A
<100
N/A
<0.5
4W-4
Compliance
Residuum
2/16/2009
N/A
N/A
<100
N/A
<0.5
4W-4
Compliance
Residuum
8/10/2009
N/A
N/A
<100
N/A
<1
4W-4
Compliance
Residuum
2/8/2010
N/A
N/A
<50
N/A
<1
4W-4
Compliance
Residuum
2/7/2011
N/A
N/A
<50
N/A
<1
4W-4
Compliance
Residuum
6/1/2011
N/A
N/A
<50
N/A
<1
4W-4
Compliance
Residuum
10/5/2011
N/A
N/A
<50
N/A
<1
4W-4
Compliance
Residuum
2/8/2012
N/A
N/A
<50
N/A
<1
4W-4
Compliance
Residuum
6/6/2012
N/A
N/A
<50
N/A
<1
4W-4
Compliance
Residuum
10/4/2012
N/A
N/A
<50
N/A
<1
4W-4
Compliance
Residuum
2/6/2013
N/A
N/A
<50
N/A
<1
4W-4
Compliance
Residuum
6/5/2013
N/A
<50
<50
<1
<1
4W-4
Compliance
Residuum
10/1/2013
N/A
N/A
<50
N/A
<1
4W-4
Compliance
Residuum
2/6/2014
N/A
N/A
<50
N/A
<1
4W-4
Compliance
Residuum
6/4/2014
N/A
N/A
<50
N/A
<1
4W-4D
Compliance
Bedrock
11/8/2007
N/A
N/A
<100
N/A
<0.5
4W-4D
Compliance
Bedrock
2/12/2008
N/A
N/A
<100
N/A
<0.5
4W-4D
Compliance
Bedrock
8/28/2008
N/A
N/A
<100
N/A
<0.5
4W-4D
Compliance
Bedrock
2/16/2009
N/A
N/A
<100
N/A
<0.5
4W-4D
Compliance
Bedrock
8/10/2009
N/A
N/A
<100
N/A
<1
4W-4D
Compliance
Bedrock
2/8/2010
N/A
N/A
<50
N/A
<1
AW-4D
Compliance
Bedrock
2/7/2011
N/A
N/A
<50
N/A
<1
4W-4D
Compliance
Bedrock
6/1/2011
N/A
N/A
<50
N/A
<1
4W-4D
Compliance
Bedrock
10/5/2011
N/A
N/A
<50
N/A
<1
Chloride Chromium
mg/L pg/L
NE 250
10
Cobalt* Copper Fluoride
pg/L mg/L mg/L
1
1
3
200.7 300 200.7 200.8 200.7
Dissolved Total Total Dissolved Total Dissolved Total Dissolved Total F, tot (mg/L)
N/A
N/A
3.1
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
3.4
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
3.2
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
2.7
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
61.8
4
N/A
<5
N/A
N/A
N/A
<0.005
N/A
62.1
62.6
5.2
<5
<5
N/A
N/A
<0.005
<0.005
N/A
N/A
62.1
7.9
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
62.2
12
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
62
16
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
4.8
N/A
<5
N/A
N/A
N/A
0.014
N/A
N/A
N/A
5.1
N/A
<5
N/A
N/A
N/A
0.015
N/A
N/A
N/A
4.7
N/A
<5
N/A
N/A
N/A
0.016
N/A
N/A
N/A
5.1
N/A
<5
N/A
N/A
N/A
0.008
N/A
N/A
N/A
4.6
N/A
<5
N/A
N/A
N/A
0.009
N/A
N/A
N/A
4.7
N/A
<5
N/A
N/A
N/A
0.01
N/A
N/A
73.7
6
N/A
<5
N/A
N/A
N/A
0.008
N/A
78.2
76.5
8.8
<5
<5
N/A
N/A
<0.005
0.005
N/A
N/A
77.2
17
N/A
<5
N/A
N/A
N/A
0.006
N/A
N/A
79.8
29
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
76.5
44
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
3.74
1.92
N/A
1.47
N/A
N/A
N/A
<0.002
<0.1
N/A
3.81
1.9
N/A
1.36
N/A
N/A
N/A
<0.002
0.1
N/A
3.92
1.8
N/A
1.32
N/A
N/A
N/A
<0.002
<0.1
N/A
3.46
2
N/A
1.39
N/A
N/A
N/A
<0.002
0.15
N/A
4.05
1.6
N/A
1.3
N/A
N/A
N/A
<0.001
<1
N/A
3.65
1.9
N/A
1.6
N/A
N/A
N/A
<0.001
0.12
N/A
N/A
1.8
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
1.9
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
1.7
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
1.8
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
1.8
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
1.6
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
3.46
1.8
N/A
<5
N/A
N/A
N/A
<0.005
N/A
3.53
3.51
1.9
<5
<5
N/A
N/A
<0.005
<0.005
N/A
N/A
3.44
1.8
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
3.6
2
N/A
<5
N/A
N/A
N/A
0.005
N/A
N/A
3.42
2
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
5.814
1.4
N/A
<1
N/A
N/A
N/A
<0.002
<0.1
N/A
5.89
1.5
N/A
<1
N/A
N/A
N/A
<0.002
0.11
N/A
5.84
1.4
N/A
<1
N/A
N/A
N/A
<0.002
<0.1
N/A
5.54
1.6
N/A
<1
N/A
N/A
N/A
<0.002
<1
N/A
5.79
1.3
N/A
<1
N/A
N/A
N/A
<0.001
<1
N/A
5.32
1.6
N/A
<1
N/A
N/A
N/A
<0.001
0.15
N/A
N/A
1.5
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
1.6
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
1.3
N/A
<5
N/A
N/A
N/A
<0.005
N/A
Tables - Page 13

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Analytical Parameter Beryllium* Boron Cadmium Calcium
Units pg/L pg/L pg/L mg/L
Chloride Chromium
mg/L pg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard 4 700 2 NE 250
Analytical Method
200.7
Total
200.8
Dissolved
200.7
300
Total
Well Name
Well Type
Hydrostratigraphic Unit
Sample Collection Date
Total
Dissolved
Total
Dissolved
Total
MW-41D
Compliance
Bedrock
2/8/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
1.5
MW-4D
Compliance
Bedrock
6/6/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
1.5
MW-4D
Compliance
Bedrock
10/4/2012
N/A
N/A
<50
N/A
<1
N/A
N/A
1.3
MW-4D
Compliance
Bedrock
2/6/2013
N/A
N/A
<50
N/A
<1
N/A
5.55
1.4
MW-4D
Compliance
Bedrock
6/5/2013
N/A
<50
<50
<1
<1
5.9
5.9
1.4
MW-4D
Compliance
Bedrock
10/1/2013
N/A
N/A
<50
N/A
<1
N/A
5.84
1.4
MW-4D
Compliance
Bedrock
2/6/2014
N/A
N/A
<50
N/A
<1
N/A
5.69
1.6
MW-4D
Compliance
Bedrock
6/4/2014
N/A
N/A
<50
N/A
<1
N/A
5.85
1.5
MW-6 D
Voluntary
Bedrock
11/8/2007
N/A
N/A
<100
N/A
<0.5
N/A
8.892
3.89
MW-61D
Voluntary
Bedrock
2/12/2008
N/A
N/A
<100
N/A
<0.5
N/A
9.05
3.9
MW-6D
Voluntary
Bedrock
8/28/2008
N/A
N/A
<100
N/A
<0.5
N/A
9.17
4
MW-6D
Voluntary
Bedrock
2/16/2009
N/A
N/A
<100
N/A
<0.5
N/A
8.67
3.6
MW-6D
Voluntary
Bedrock
8/10/2009
N/A
N/A
<100
N/A
<1
N/A
9.19
4
MW-6D
Voluntary
Bedrock
2/8/2010
N/A
N/A
<50
N/A
<1
N/A
8.59
4.4
MW-6S
Voluntary
Transition (Saprolite)
11/8/2007
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
MW-6S
Voluntary
Transition (Saprolite)
8/28/2008
N/A
N/A
182
N/A
<0.5
N/A
0.135
24
MW-6S
Voluntary
Transition (Saprolite)
2/16/2009
N/A
N/A
223
N/A
0.669
N/A
0.202
140
MW-6S
Voluntary
Transition (Saprolite)
8/10/2009
N/A
N/A
349
N/A
1.9
N/A
0.376
210
MW-6S
Voluntary
Transition (Saprolite)
2/8/2010
N/A
N/A
788
N/A
1.9
N/A
0.685
220
MW-6S
Voluntary
Transition (Saprolite)
2/7/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
MW-6S
Voluntary
Transition (Saprolite)
6/1/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
MW-6S
Voluntary
Transition (Saprolite)
10/5/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
MW-7 D
Voluntary
Bedrock
11/8/2007
N/A
N/A
<100
N/A
<0.5
N/A
71.589
4.5
MW-7D
Voluntary
Bedrock
2/12/2008
N/A
N/A
<100
N/A
<0.5
N/A
72.4
4.6
MW-7 D
Voluntary
Bedrock
8/28/2008
N/A
N/A
<100
N/A
<0.5
N/A
70.9
4.8
MW-7 D
Voluntary
Bedrock
2/16/2009
N/A
N/A
<100
N/A
<0.5
N/A
72.6
4.2
MW-7 D
Voluntary
Bedrock
8/10/2009
N/A
N/A
<100
N/A
<1
N/A
70.2
4.4
MW-7D
Voluntary
Bedrock
2/8/2010
N/A
N/A
<50
N/A
<1
N/A
66.5
5
MW-7S
Voluntary
Transition (Saprolite)
11/8/2007
N/A
N/A
249
N/A
<0.5
N/A
13.165
17.88
MW-7S
Voluntary
Transition (Saprolite)
2/12/2008
N/A
N/A
224
N/A
0.83
N/A
46.6
120
MW-7S
Voluntary
Transition (Saprolite)
8/28/2008
N/A
N/A
503
N/A
1.37
N/A
109
310
MW-7S
Voluntary
Transition (Saprolite)
2/16/2009
N/A
N/A
2230
N/A
0.904
N/A
212
520
MW-7S
Voluntary
Transition (Saprolite)
8/10/2009
N/A
N/A
6460
N/A
<1
N/A
136
360
MW-7S
Voluntary
Transition (Saprolite)
2/8/2010
N/A
N/A
4970
N/A
<1
N/A
156
390
MW-7S
Voluntary
Transition (Saprolite)
2/7/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
MW-7S
Voluntary
Transition (Saprolite)
6/1/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
MW-7S
Voluntary
Transition (Saprolite)
10/5/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
MW-8D
Voluntary
Bedrock
11/8/2007
N/A
N/A
203
N/A
<0.5
N/A
88.513
5.15
MW-8D
Voluntary
Bedrock
2/12/2008
N/A
N/A
190
N/A
<0.5
N/A
88.2
5.1
MW-8 D
Voluntary
Bedrock
8/28/2008
N/A
N/A
198
N/A
<0.5
N/A
88
5.3
MW-8D
Voluntary
Bedrock
2/16/2009
N/A
N/A
208
N/A
<0.5
N/A
90.4
4.5
MW-8 D
Voluntary
Bedrock
8/10/2009
N/A
N/A
192
N/A
<1
N/A
89.3
4.8
MW-8 D
Voluntary
Bedrock
2/8/2010
N/A
N/A
200
N/A
<1
N/A
83.3
5.5
MW-8S
Voluntary
Transition (Saprolite)
11/8/2007
N/A
N/A
140
N/A
<0.5
N/A
56.513
5.66
MW-8S
Voluntary
Transition (Saprolite)
2/12/2008
N/A
N/A
<100
N/A
<0.5
N/A
33.3
<0.1
MW-8S
Voluntary
Transition (Saprolite)
8/28/2008
N/A
N/A
162
N/A
<0.5
N/A
85.8
1.3
Cobalt* Copper Fluoride
pg/L mg/L mg/L
10
200.7
1
1
2
200.8
200.7
Dissolved
Dissolved
Total
F, tot (mg/L)
Dissolved
Total
Total
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
<5
<5
N/A
N/A
<0.005
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<5
N/A
N/A
N/A
<0.005
N/A
N/A
<1
N/A
N/A
N/A
<0.002
<0.1
N/A
<1
N/A
N/A
N/A
0.002
0.1
N/A
<1
N/A
N/A
N/A
0.002
<0.1
N/A
<1
N/A
N/A
N/A
<0.002
<1
N/A
<1
N/A
N/A
N/A
<0.001
<0.1
N/A
<1
N/A
N/A
N/A
<0.001
0.15
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.011
0.28
N/A
<1
N/A
N/A
N/A
0.032
1.2
N/A
<1
N/A
N/A
N/A
0.046
1.1
N/A
5.4
N/A
N/A
N/A
0.051
1.6
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
<0.002
1.04
N/A
<1
N/A
N/A
N/A
<0.002
1.2
N/A
<1
N/A
N/A
N/A
<0.002
1.1
N/A
<1
N/A
N/A
N/A
<0.002
1.3
N/A
<1
N/A
N/A
N/A
<0.001
0.99
N/A
<1
N/A
N/A
N/A
<0.001
1.1
N/A
<1
N/A
N/A
N/A
<0.002
0.2
N/A
<1
N/A
N/A
N/A
<0.002
0.71
N/A
<1
N/A
N/A
N/A
<0.002
0.87
N/A
<1
N/A
N/A
N/A
0.003
1.9
N/A
<1
N/A
N/A
N/A
<0.001
1.1
N/A
<1
N/A
N/A
N/A
<0.001
1.2
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
2.6
N/A
N/A
N/A
0.005
0.7
N/A
1.55
N/A
N/A
N/A
0.005
0.88
N/A
<1
N/A
N/A
N/A
0.002
0.79
N/A
<1
N/A
N/A
N/A
<0.002
1
N/A
<1
N/A
N/A
N/A
<0.001
0.7
N/A
1.9
N/A
N/A
N/A
0.004
0.82
N/A
<1
N/A
N/A
N/A
<0.002
<0.1
N/A
<1
N/A
N/A
N/A
<0.002
0.11
N/A
<1
N/A
N/A
N/A
<0.002
0.11
Tables - Page 14

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Analytical Parameter Beryllium* Boron
Units pg/L pg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard 4 700
Analytical Method
200.7
Cadmium
Calcium
Chloride
Chromium
Cobalt*
Copper
Fluoride
pg/L
mg/L
mg/L
pg/L
pg/L
mg/L
mg/L
2 NE 250 10
200.8
Well Name Well Type Hydrostratigraphic Unit Sample Collection Date Total Dissolved Total Dissolved Total
1W-8S
Voluntary
Transition (Saprolite)
2/16/2009
N/A
N/A
237
N/A
<0.5
4W-8S
Voluntary
Transition (Saprolite)
8/10/2009
N/A
N/A
222
N/A
<1
AW-8S
Voluntary
Transition (Saprolite)
2/8/2010
N/A
N/A
241
N/A
<1
1W-8S
Voluntary
Transition (Saprolite)
2/7/2011
N/A
N/A
N/A
N/A
N/A
1W-8S
Voluntary
Transition (Saprolite)
6/1/2011
N/A
N/A
N/A
N/A
N/A
1W-8S
Voluntary
Transition (Saprolite)
10/5/2011
N/A
N/A
N/A
N/A
N/A
1W-9D
Voluntary
Bedrock
11/8/2007
N/A
N/A
386
N/A
<0.5
4W-9D
Voluntary
Bedrock
2/12/2008
N/A
N/A
378
N/A
<0.5
1W-9D
Voluntary
Bedrock
8/28/2008
N/A
N/A
374
N/A
<0.5
4W-9D
Voluntary
Bedrock
2/16/2009
N/A
N/A
382
N/A
<0.5
4W-9D
Voluntary
Bedrock
8/10/2009
N/A
N/A
385
N/A
<1
4W-9D
Voluntary
Bedrock
2/8/2010
N/A
N/A
389
N/A
<1
1W-9S
Voluntary
Transition (Saprolite)
11/8/2007
N/A
N/A
<100
N/A
<0.5
4W-9S
Voluntary
Transition (Saprolite)
2/12/2008
N/A
N/A
<100
N/A
<0.5
1W-9S
Voluntary
Transition (Saprolite)
8/28/2008
N/A
N/A
<100
N/A
<0.5
4W-9S
Voluntary
Transition (Saprolite)
2/16/2009
N/A
N/A
<100
N/A
<0.5
1W-9S
Voluntary
Transition (Saprolite)
8/10/2009
N/A
N/A
<100
N/A
<1
4W-9S
Voluntary
Transition (Saprolite)
2/8/2010
N/A
N/A
<50
N/A
<1
1W-9S
Voluntary
Transition (Saprolite)
2/7/2011
N/A
N/A
N/A
N/A
N/A
1W-9S
Voluntary
Transition (Saprolite)
6/1/2011
N/A
N/A
N/A
N/A
N/A
1W-9S
Voluntary
Transition (Saprolite)
10/5/2011
N/A
N/A
N/A
N/A
N/A
200.7
300
200.7
Dissolved
Total
Total
Dissolved
N/A
151
5.6
N/A
N/A
131
5.4
N/A
N/A
128
3.4
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
35.867
6.17
N/A
N/A
37.8
6.3
N/A
N/A
38.7
6.1
N/A
N/A
38.8
5
N/A
N/A
41
5.6
N/A
N/A
40.8
6.2
N/A
N/A
61.731
8.57
N/A
N/A
59.2
9.9
N/A
N/A
60.2
7.8
N/A
N/A
61.9
8.4
N/A
N/A
63
8.6
N/A
N/A
57.9
11
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1 2
200.8 200.7
Total Dissolved Total Dissolved Total F, tot (mg/L)
<1
N/A
N/A
N/A
<0.002
<1
<1
N/A
N/A
N/A
<0.001
0.17
<1
N/A
N/A
N/A
<0.001
0.32
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.003
<0.1
<1
N/A
N/A
N/A
0.003
0.12
<1
N/A
N/A
N/A
0.003
<0.1
<1
N/A
N/A
N/A
<0.002
<1
<1
N/A
N/A
N/A
0.002
<0.1
<1
N/A
N/A
N/A
0.002
0.16
<1
N/A
N/A
N/A
<0.002
0.16
<1
N/A
N/A
N/A
<0.002
0.11
<1
N/A
N/A
N/A
<0.002
0.14
<1
N/A
N/A
N/A
<0.002
<1
<1
N/A
N/A
N/A
<0.001
0.1
<1
N/A
N/A
N/A
<0.001
0.22
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Tables - Page 15

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Analytical Parameter Iron
Units Ng/L
Lead
Magnesium
Manganese
Mercury
Molydenum
Nickel
Nitrate as N
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
mg-N/L
15A NCAC 02L .0202(g) Groundwater Quality Standard 300 15 NE 50 1 NE 100 10
Analytical Method 200.7 200.8 200.7 200.8 245.1 200.8 200.7 300.0
Well Name Well Type Hydrostratigraphic Unit Sample Collection Date Dissolved Total Dissolved Total Dissolved Total Dissolved Total Dissolved Total Dissolved Total Dissolved Total Total
M-1
M-6
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
MW-
6 Boring/Temporary Residuum 10/5/2011 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Boring/Temporary Surface Water 10/5/2011 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
10D Compliance Bedrock 2/7/2011 N/A 186 N/A <1 N/A N/A N/A 97 N/A <0.05 N/A N/A N/A <5 0.29
10D Compliance Bedrock 6/1/2011 N/A 133 N/A <1 N/A N/A N/A 81 N/A <0.05 N/A N/A N/A <5 0.46
10D Compliance Bedrock 10/5/2011 N/A 91 N/A <1 N/A N/A N/A 59 N/A <0.05 N/A N/A N/A <5 0.39
10D Compliance Bedrock 2/8/2012 N/A 47 N/A <1 N/A N/A N/A 38 N/A <0.05 N/A N/A N/A <5 0.39
10D Compliance Bedrock 6/6/2012 N/A 142 N/A <1 N/A N/A N/A 30 N/A <0.05 N/A N/A N/A <5 0.36
10D Compliance Bedrock 10/412012 N/A 35 N/A <1 N/A N/A N/A 19 N/A <0.05 N/A N/A N/A <5 0.36
10D Compliance Bedrock 2/7/2013 N/A 151 N/A <1 N/A 0.724 N/A 11 N/A <0.05 N/A N/A N/A <5 0.37
10D Compliance Bedrock 6/5/2013 37 406 <1 <1 0.699 0.763 7 14 <0.05 <0.05 N/A N/A <5 <5 0.34
10D Compliance Bedrock 10/1/2013 N/A 234 N/A <1 N/A 0.74 N/A 9 N/A <0.05 N/A N/A N/A <5 0.33
10D Compliance Bedrock 2/6/2014 N/A 371 N/A <1 N/A 0.815 N/A 10 N/A <0.05 N/A N/A N/A <5 0.37
10D Compliance Bedrock 6/4/2014 N/A 137 N/A <1 N/A 0.71 N/A 7 N/A <0.05 N/A N/A N/A <5 0.35
10S Compliance Residuum 2/7/2011 N/A 105 N/A <1 N/A N/A N/A 49 N/A <0.05 N/A N/A N/A <5 <0.1
10S Compliance Residuum 6/1/2011 N/A 373 N/A <1 N/A N/A N/A 65 N/A <0.05 N/A N/A N/A <5 0.05
10S Compliance Residuum 10/5/2011 N/A 236 N/A <1 N/A N/A N/A 35 N/A <0.05 N/A N/A N/A <5 0.03
10S Compliance Residuum 2/8/2012 N/A 77 N/A <1 N/A N/A N/A 23 N/A <0.05 N/A N/A N/A <5 <0.02
10S Compliance Residuum 6/6/2012 N/A 193 N/A <1 N/A N/A N/A 25 N/A <0.05 N/A N/A N/A <5 <0.022
10S Compliance Residuum 10/4/2012 N/A 98 N/A <1 N/A N/A N/A 20 N/A <0.05 N/A N/A N/A <5 <0.022
10S Compliance Residuum 2/7/2013 N/A 65 N/A <1 N/A 1.06 N/A 16 N/A <0.05 N/A N/A N/A <5 <0.022
10S Compliance Residuum 6/5/2013 18 432 <1 <1 1.07 1.14 14 20 <0.05 <0.05 N/A N/A <5 <5 <0.022
10S Compliance Residuum 10/1/2013 N/A 443 N/A <1 N/A 1.09 N/A 18 N/A <0.05 N/A N/A N/A <5 0.03
10S Compliance Residuum 2/6/2014 N/A 450 N/A <1 N/A 1.17 N/A 22 N/A <0.05 N/A N/A N/A <5 <0.022
10S Compliance Residuum 6/4/2014 N/A 616 N/A <1 N/A 1.14 N/A 24 N/A <0.05 N/A N/A N/A <5 <0.022
11D Compliance Bedrock 2/7/2011 N/A 839 N/A <1 N/A N/A N/A 40 N/A <0.05 N/A N/A N/A <5 0.13
11D Compliance Bedrock 6/1/2011 N/A 368 N/A <1 N/A N/A N/A 14 N/A <0.05 N/A N/A N/A <5 0.27
11D Compliance Bedrock 10/5/2011 N/A 252 N/A <1 N/A N/A N/A 8 N/A <0.05 N/A N/A N/A <5 0.26
11D Compliance Bedrock 2/8/2012 N/A 160 N/A <1 N/A N/A N/A <5 N/A <0.05 N/A N/A N/A <5 0.25
11D Compliance Bedrock 6/6/2012 N/A 325 N/A <1 N/A N/A N/A 6 N/A <0.05 N/A N/A N/A <5 0.25
11D Compliance Bedrock 10/4/2012 N/A 178 N/A <1 N/A N/A N/A <5 N/A <0.05 N/A N/A N/A <5 0.24
11D Compliance Bedrock 2/6/2013 N/A 125 N/A <1 N/A 1.5 N/A <5 N/A <0.05 N/A N/A N/A <5 0.27
11D Compliance Bedrock 6/5/2013 18 341 <1 <1 1.6 1.64 <5 5 <0.05 <0.05 N/A N/A <5 <5 0.29
11D Compliance Bedrock 10/1/2013 N/A 220 N/A <1 N/A 1.64 N/A <5 N/A <0.05 N/A N/A N/A <5 0.27
11D Compliance Bedrock 2/6/2014 N/A 501 N/A <1 N/A 1.79 N/A 5 N/A <0.05 N/A N/A N/A <5 0.26
11D Compliance Bedrock 6/4/2014 N/A 287 N/A <1 N/A 1.63 N/A <5 N/A <0.05 N/A N/A N/A <5 0.26
11S Compliance Residuum 2/7/2011 N/A 199 N/A <1 N/A N/A N/A 26 N/A <0.05 N/A N/A N/A <5 0.46
11S Compliance Residuum 6/1/2011 N/A 467 N/A <1 N/A N/A N/A 18 N/A <0.05 N/A N/A N/A <5 0.64
11S Compliance Residuum 10/5/2011 N/A 176 N/A <1 N/A N/A N/A 6 N/A <0.05 N/A N/A N/A <5 0.5
11S Compliance Residuum 2/8/2012 N/A 137 N/A <1 N/A N/A N/A <5 N/A <0.05 N/A N/A N/A <5 0.5
11S Compliance Residuum 6/6/2012 N/A 123 N/A <1 N/A N/A N/A <5 N/A <0.05 N/A N/A N/A <5 0.49
11S Compliance Residuum 10/4/2012 N/A 324 N/A <1 N/A N/A N/A 9 N/A <0.05 N/A N/A N/A <5 0.49
11S Compliance Residuum 2/6/2013 N/A 70 N/A <1 N/A 0.86 N/A <5 N/A <0.05 N/A N/A N/A <5 0.53
11S Compliance Residuum 6/5/2013 18 117 <1 <1 0.867 0.888 <5 <5 <0.05 <0.05 N/A N/A <5 <5 0.54
11S Compliance Residuum 10/1/2013 N/A 114 N/A <1 N/A 0.928 N/A <5 N/A <0.05 N/A N/A N/A <5 0.52
11S Compliance Residuum 2/6/2014 N/A 202 N/A <1 N/A 1.01 N/A <5 N/A <0.05 N/A N/A N/A <5 0.56
11S Compliance Residuum 6/4/2014 N/A 92 N/A <1 N/A 0.976 N/A <5 N/A <0.05 N/A N/A N/A <5 0.54
Tables - Page 16
Tables - Page 16

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Analytical Parameter
Units
1W-12D
1W-12D
1W-12D
1W-12D
1W-12D
1W-12D
1W-12D
1W-12D
1W-12D
1W-12D
1W-12D
1W-12S
1W-12S
1W-12S
1W-12S
1W-12S
1W-12S
1W-12S
1W-12S
1W-12S
1W-12S
1W-12S
1W-13D
1W-13D
1W-13D
1W-13D
1W-13D
1W-13D
1W-13D
1W-13D
1W-13D
1W-13D
1W-13D
1W-13S
1W-13S
1W-13S
1W-13S
1W-13S
1W-13S
1W-13S
1W-13S
1W-13S
1W-13S
1W-13S
1W-14D
1W-14D
Well Type
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
Iron
pg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard 300
Analytical Method 200.7
Hydrostratigraphic Unit
Sample Collection Date
Dissolved
Total
Transition (PWR)
2/7/2011
N/A
305
Transition (PWR)
6/1/2011
N/A
652
Transition (PWR)
10/512011
N/A
421
Transition (PWR)
2/8/2012
N/A
624
Transition (PWR)
6/6/2012
N/A
535
Transition (PWR)
10/4/2012
N/A
970
Transition (PWR)
2/6/2013
N/A
553
Transition (PWR)
6/5/2013
18
538
Transition (PWR)
10/1/2013
N/A
712
Transition (PWR)
2/6/2014
N/A
503
Transition (PWR)
6/4/2014
N/A
478
Residuum
2/7/2011
N/A
25
Residuum
6/1/2011
N/A
12
Residuum
10/5/2011
N/A
15
Residuum
2/8/2012
N/A
15
Residuum
6/6/2012
N/A
11
Residuum
10/4/2012
N/A
12
Residuum
2/6/2013
N/A
16
Residuum
6/5/2013
<10
79
Residuum
10/1/2013
N/A
61
Residuum
2/6/2014
N/A
25
Residuum
6/4/2014
N/A
34
Bedrock
2/7/2011
N/A
24
Bedrock
6/1/2011
N/A
19
Bedrock
10/5/2011
N/A
17
Bedrock
2/8/2012
N/A
12
Bedrock
6/6/2012
N/A
12
Bedrock
10/4/2012
N/A
<10
Bedrock
2/6/2013
N/A
16
Bedrock
6/5/2013
<10
24
Bedrock
10/1/2013
N/A
25
Bedrock
2/6/2014
N/A
19
Bedrock
6/4/2014
N/A
18
Residuum
2/7/2011
N/A
1010
Residuum
6/1/2011
N/A
375
Residuum
10/5/2011
N/A
324
Residuum
2/8/2012
N/A
211
Residuum
6/6/2012
N/A
649
Residuum
10/412012
N/A
1060
Residuum
2/6/2013
N/A
421
Residuum
6/5/2013
13
1230
Residuum
10/1/2013
N/A
1470
Residuum
2/6/2014
N/A
787
Residuum
6/4/2014
N/A
221
Bedrock
2/7/2011
N/A
123
Bedrock
6/1/2011
N/A
159
Lead
pg/L
15
200.8
Dissolved
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
N/A
N/A
Magnesium Manganese Mercury Molydenum Nickel Nitrate as N
pg/L pg/L pg/L pg/L pg/L mg-N/L
NE
200.7
Total
Dissolved
Total
Dissoly
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
1.28
N/A
<1
1.08
1.23
7
<1
N/A
1.26
N/A
<1
N/A
1.28
N/A
<1
N/A
1.17
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
0.271
N/A
<1
0.271
0.276
20
<1
N/A
0.292
N/A
<1
N/A
0.446
N/A
<1
N/A
0.128
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
2.06
N/A
<1
2.09
2.15
<5
<1
N/A
2.17
N/A
<1
N/A
2.25
N/A
<1
N/A
2.11
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
2.04
N/A
<1
1.91
2.36
<5
<1
N/A
2.29
N/A
<1
N/A
2.24
N/A
<1
N/A
2.01
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
50
200.1
ed
Total
40
37
29
24
21
25
16
15
13
11
11
46
29
14
127
32
10
54
23
10
37
11
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
54
27
26
17
27
49
17
31
25
16
6
73
63
1 NE 100 10
245.1 200.8 200.7 300.0
Dissolved
Total
Dissolved
Total
Dissolved
Total
Total
N/A
<0.05
N/A
N/A
N/A
<5
<0.1
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
<0.02
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
<0.05
<0.05
N/A
N/A
<5
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
<0.1
N/A
<0.05
N/A
N/A
N/A
<5
0.03
N/A
<0.05
N/A
N/A
N/A
<5
0.04
N/A
<0.05
N/A
N/A
N/A
<5
<0.02
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
0.02
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
<0.05
<0.05
N/A
N/A
<5
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
1.6
N/A
<0.05
N/A
N/A
N/A
<5
2.2
N/A
<0.05
N/A
N/A
N/A
<5
1.8
N/A
<0.05
N/A
N/A
N/A
<5
1.7
N/A
<0.05
N/A
N/A
N/A
<5
1.5
N/A
<0.05
N/A
N/A
N/A
<5
1.5
N/A
<0.05
N/A
N/A
N/A
<5
1.6
<0.05
<0.05
N/A
N/A
<5
<5
1.6
N/A
<0.05
N/A
N/A
N/A
<5
1.5
N/A
<0.05
N/A
N/A
N/A
<5
1.7
N/A
<0.05
N/A
N/A
N/A
<5
1.6
N/A
<0.05
N/A
N/A
N/A
<5
1.5
N/A
<0.05
N/A
N/A
N/A
<5
2.1
N/A
<0.05
N/A
N/A
N/A
<5
1.5
N/A
<0.05
N/A
N/A
N/A
<5
1.6
N/A
<0.05
N/A
N/A
N/A
<5
1.4
N/A
<0.05
N/A
N/A
N/A
<5
1.3
N/A
<0.05
N/A
N/A
N/A
<5
1A
<0.05
<0.05
N/A
N/A
<5
<5
1.5
N/A
<0.05
N/A
N/A
N/A
<5
1.4
N/A
<0.05
N/A
N/A
N/A
<5
1.5
N/A
<0.05
N/A
N/A
N/A
<5
1.5
N/A
<0.05
N/A
N/A
N/A
28
0.14
N/A
<0.05
N/A
N/A
N/A
27
0.19
Tables - Page 17

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Analytical Parameter
Units
Well Name
1W-14D
1W-14D
1W-14D
1W-14D
1W-14D
1W-14D
1W-14D
1W-14D
1W-14D
1W-14S
1W-14S
1W-14S
1W-14S
1W-14S
1W-14S
1W-14S
1W-14S
1W-14S
1W-14S
1W-14S
1W-4
1W-4
1W-4
1W-4
1W-4
1W-4
1W-4
1W-4
1W-4
1W-4
1W-4
1W-4
1W-4
1W-4
1W-4
1W-4
1W-4
1W-4D
1W-4D
1W-4D
1W-4D
1W-4D
1W-4D
1W-4D
1W-4D
1W-4D
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
Iron
pg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard 300
Analytical Method 200.7
Hydrostratigraphic Unit
Sample Collection Date
Dissolved
Total
Bedrock
10/5/2011
N/A
98
Bedrock
2/8/2012
N/A
81
Bedrock
6/6/2012
N/A
93
Bedrock
10/412012
N/A
94
Bedrock
2/7/2013
N/A
63
Bedrock
6/5/2013
39
95
Bedrock
10/1/2013
N/A
113
Bedrock
2/6/2014
N/A
124
Bedrock
6/4/2014
N/A
85
Residuum
2/7/2011
N/A
411
Residuum
6/1/2011
N/A
142
Residuum
10/5/2011
N/A
244
Residuum
2/8/2012
N/A
213
Residuum
6/6/2012
N/A
202
Residuum
10/4/2012
N/A
463
Residuum
2/7/2013
N/A
322
Residuum
6/5/2013
13
1160
Residuum
10/1/2013
N/A
1270
Residuum
2/6/2014
N/A
583
Residuum
6/4/2014
N/A
393
Residuum
11/8/2007
N/A
300
Residuum
2/12/2008
N/A
87
Residuum
8/28/2008
N/A
38
Residuum
2/16/2009
N/A
67
Residuum
8/10/2009
N/A
66
Residuum
2/8/2010
N/A
60.7
Residuum
2/7/2011
N/A
128
Residuum
6/1/2011
N/A
160
Residuum
10/5/2011
N/A
109
Residuum
2/8/2012
N/A
70
Residuum
6/6/2012
N/A
180
Residuum
10/4/2012
N/A
38
Residuum
2/6/2013
N/A
77
Residuum
6/5/2013
<10
164
Residuum
10/1/2013
N/A
137
Residuum
2/6/2014
N/A
66
Residuum
6/4/2014
N/A
190
Bedrock
11/8/2007
N/A
253
Bedrock
2/12/2008
N/A
52
Bedrock
8/28/2008
N/A
98
Bedrock
2/16/2009
N/A
56
Bedrock
8/1012009
N/A
48
Bedrock
2/8/2010
N/A
40.1
Bedrock
2/7/2011
N/A
268
Bedrock
6/1/2011
N/A
21
Bedrock
10/5/2011
N/A
26
Lead
pg/L
15
200.8
Dissolved
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Magnesium Manganese Mercury Molydenum Nickel Nitrate as N
pg/L pg/L pg/L pg/L pg/L mg-N/L
NE
200.7
50
1
NE
100
10
200.8
245.1
200.8
200.7
300.0
Total
Dissolved
Total
Dissolved
Total
Dissolved
Total
Dissolved
Total
Dissolved
Total
Total
<1
N/A
N/A
N/A
57
N/A
<0.05
N/A
N/A
N/A
25
0.14
<1
N/A
N/A
N/A
53
N/A
<0.05
N/A
N/A
N/A
24
0.14
<1
N/A
N/A
N/A
51
N/A
<0.05
N/A
N/A
N/A
24
0.13
<1
N/A
N/A
N/A
54
N/A
<0.05
N/A
N/A
N/A
25
0.12
<1
N/A
17.4
N/A
46
N/A
<0.05
N/A
N/A
N/A
24
0.14
<1
17.3
17.3
44
44
<0.05
<0.05
N/A
N/A
23
23
0.14
<1
N/A
17.4
N/A
43
N/A
<0.05
N/A
N/A
N/A
21
0.14
<1
N/A
16.5
N/A
42
N/A
<0.05
N/A
N/A
N/A
23
0.13
<1
N/A
17.1
N/A
40
N/A
<0.05
N/A
N/A
N/A
26
0.1
<1
N/A
N/A
N/A
192
N/A
<0.05
N/A
N/A
N/A
66
0.23
<1
N/A
N/A
N/A
147
N/A
<0.05
N/A
N/A
N/A
66
0.29
<1
N/A
N/A
N/A
110
N/A
<0.05
N/A
N/A
N/A
63
0.2
<1
N/A
N/A
N/A
95
N/A
<0.05
N/A
N/A
N/A
58
0.2
<1
N/A
N/A
N/A
85
N/A
<0.05
N/A
N/A
N/A
59
0.18
<1
N/A
N/A
N/A
82
N/A
<0.05
N/A
N/A
N/A
63
0.17
<1
N/A
28.2
N/A
69
N/A
<0.05
N/A
N/A
N/A
59
0.21
<1
29.7
29.7
65
71
<0.05
<0.05
N/A
N/A
60
56
0.22
<1
N/A
29.8
N/A
66
N/A
<0.05
N/A
N/A
N/A
58
0.22
<1
N/A
31.1
N/A
67
N/A
<0.05
N/A
N/A
N/A
58
0.2
<1
N/A
29.2
N/A
77
N/A
<0.05
N/A
N/A
N/A
55
0.15
<2
N/A
0.841
N/A
10
N/A
<0.1
N/A
N/A
N/A
<2
0.12
<2
N/A
0.815
N/A
10
N/A
<0.2
N/A
N/A
N/A
<2
0.08
<2
N/A
0.82
N/A
<5
N/A
<0.05
N/A
N/A
N/A
<2
0.11
<2
N/A
0.732
N/A
<5
N/A
<0.05
N/A
N/A
N/A
<2
0.12
<1
N/A
0.828
N/A
<5
N/A
<0.05
N/A
N/A
N/A
<1
<0.23
<1
N/A
0.744
N/A
<5
N/A
<0.05
N/A
N/A
N/A
<1
0.09
<1
N/A
N/A
N/A
8
N/A
<0.05
N/A
N/A
N/A
<5
<0.1
<1
N/A
N/A
N/A
9
N/A
<0.05
N/A
N/A
N/A
<5
0.08
<1
N/A
N/A
N/A
5
N/A
<0.05
N/A
N/A
N/A
<5
0.18
<1
N/A
N/A
N/A
7
N/A
<0.05
N/A
N/A
N/A
<5
0.08
<1
N/A
N/A
N/A
11
N/A
<0.05
N/A
N/A
N/A
<5
0.07
<1
N/A
N/A
N/A
5
N/A
<0.05
N/A
N/A
N/A
<5
0.13
<1
N/A
0.718
N/A
<5
N/A
<0.05
N/A
N/A
N/A
<5
0.05
<1
0.698
0.728
<5
<5
<0.05
<0.05
N/A
N/A
<5
<5
0.05
<1
N/A
0.707
N/A
<5
N/A
<0.05
N/A
N/A
N/A
<5
0.04
<1
N/A
0.731
N/A
<5
N/A
<0.05
N/A
N/A
N/A
<5
0.03
<1
N/A
0.715
N/A
9
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
<2
N/A
1.395
N/A
37
N/A
<0.1
N/A
N/A
N/A
<2
0.02
<2
N/A
1.39
N/A
15
N/A
<0.2
N/A
N/A
N/A
<2
0.02
<2
N/A
1A
N/A
11
N/A
<0.05
N/A
N/A
N/A
<2
0.02
<2
N/A
1.29
N/A
6
N/A
<0.05
N/A
N/A
N/A
<2
<0.23
<1
N/A
1.32
N/A
6
N/A
<0.05
N/A
N/A
N/A
<1
<0.23
<1
N/A
1.26
N/A
<5
N/A
<0.05
N/A
N/A
N/A
<1
0.04
<1
N/A
N/A
N/A
38
N/A
<0.05
N/A
N/A
N/A
<5
<0.1
<1
N/A
N/A
N/A
<5
N/A
<0.05
N/A
N/A
N/A
<5
0.04
<1
N/A
N/A
N/A
<5
N/A
<0.05
N/A
N/A
N/A
<5
0.03
Tables - Page 18

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Analytical Parameter
Units
1W-4D
1W-4D
1W-4D
1W-4D
1W-4D
1W-4D
1W-4D
1W-4D
1W-6D
1W-6D
1W-6D
1W-6D
1W-6D
1W-6D
1W-6S
1W-6S
1W-6S
1W-6S
1W-6S
1W-6S
1W-6S
1W-6S
1W-7D
1W-7D
1W-7D
1W-7D
1W-7D
1W-7D
1W-7S
1W-7S
1W-7S
1W-7S
1W-7S
1W-7S
1W-7S
1W-7S
1W-7S
1W-8D
1W-8D
1W-8D
1W-8D
1W-8D
1W-8D
1W-8S
1W-8S
1W-8S
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
mpliance
Iron
pg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard 300
Analytical Method 200.7
Hydrostratigraphic Unit
Sample Collection Date
Dissolved
Total
Bedrock
2/8/2012
N/A
376
Bedrock
6/6/2012
N/A
88
Bedrock
10/4/2012
N/A
41
Bedrock
2/6/2013
N/A
17
Bedrock
6/5/2013
<10
18
Bedrock
10/1/2013
N/A
17
Bedrock
2/6/2014
N/A
16
Bedrock
6/4/2014
N/A
25
Bedrock
11/8/2007
N/A
211
Bedrock
2/12/2008
N/A
296
Bedrock
8/28/2008
N/A
482
Bedrock
2/16/2009
N/A
289
Bedrock
8/10/2009
N/A
227
Bedrock
2/8/2010
N/A
52.5
Transition (Saprolite)
11/8/2007
N/A
N/A
Transition (Saprolite)
8/28/2008
N/A
295
Transition (Saprolite)
2/16/2009
N/A
77
Transition (Saprolite)
8/10/2009
N/A
58
Transition (Saprolite)
2/8/2010
N/A
290
Transition (Saprolite)
2/7/2011
N/A
N/A
Transition (Saprolite)
6/1/2011
N/A
N/A
Transition (Saprolite)
10/5/2011
N/A
N/A
Bedrock
11/8/2007
N/A
500
Bedrock
2/12/2008
N/A
506
Bedrock
8/28/2008
N/A
516
Bedrock
2/16/2009
N/A
490
Bedrock
8/10/2009
N/A
492
Bedrock
2/8/2010
N/A
478
Transition (Saprolite)
11/8/2007
N/A
68
Transition (Saprolite)
2/12/2008
N/A
19
Transition (Saprolite)
8/28/2008
N/A
183
Transition (Saprolite)
2/16/2009
N/A
80
Transition (Saprolite)
8/10/2009
N/A
341
Transition (Saprolite)
2/8/2010
N/A
43.8
Transition (Saprolite)
2/7/2011
N/A
N/A
Transition (Saprolite)
6/1/2011
N/A
N/A
Transition (Saprolite)
10/5/2011
N/A
N/A
Bedrock
11/8/2007
N/A
3462
Bedrock
2/12/2008
N/A
2120
Bedrock
8/28/2008
N/A
1470
Bedrock
2/16/2009
N/A
1130
Bedrock
8/1012009
N/A
1130
Bedrock
2/8/2010
N/A
1860
Transition (Saprolite)
11/8/2007
N/A
7109
Transition (Saprolite)
2/12/2008
N/A
8720
Transition (Saprolite)
8/28/2008
N/A
1580
Lead
pg/L
15
200.8
Dissolved
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Magnesium Manganese Mercury Molydenum Nickel Nitrate as N
pg/L pg/L pg/L pg/L pg/L mg-N/L
NE
200.7
Total
Dissolved
Total
Dissoly
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
N/A
N/A
<1
N/A
1.28
N/A
<1
1.34
1.35
<5
<1
N/A
1.33
N/A
<1
N/A
1.3
N/A
<1
N/A
1.32
N/A
<2
N/A
3.228
N/A
<2
N/A
3.43
N/A
<2
N/A
3.59
N/A
<2
N/A
3.26
N/A
<1
N/A
3.39
N/A
<1
N/A
3.19
N/A
N/A
N/A
N/A
N/A
<2
N/A
9.17
N/A
<2
N/A
34
N/A
<1
N/A
54.6
N/A
1.3
N/A
62.6
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<2
N/A
6.131
N/A
<2
N/A
6.51
N/A
<2
N/A
6.48
N/A
<2
N/A
6.06
N/A
<1
N/A
6.15
N/A
<1
N/A
6.03
N/A
<2
N/A
2.563
N/A
<2
N/A
9.18
N/A
<2
N/A
25.2
N/A
<2
N/A
46.6
N/A
1.8
N/A
34.5
N/A
1
N/A
46.8
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
2.66
N/A
4.66
N/A
2.09
N/A
4.61
N/A
<2
N/A
4.51
N/A
<2
N/A
4.26
N/A
<1
N/A
4.36
N/A
1.8
N/A
4.46
N/A
<2
N/A
12.876
N/A
<2
N/A
8.39
N/A
<2
N/A
20.1
N/A
50
200.1
ed
Total
48
9
<5
<5
<5
<5
<5
<5
17
14
16
13
11
5.75
N/A
247
942
1630
1650
N/A
N/A
N/A
443
450
451
430
441
423
1586
5230
9440
10400
10200
12900
N/A
N/A
N/A
253
218
208
192
208
222
4632
3360
4910
1 NE 100 10
245.1 200.8 200.7 300.0
Dissolved
Total
Dissolved
Total
Dissolved
Total
Total
N/A
<0.05
N/A
N/A
N/A
<5
0.03
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
<0.05
<0.05
N/A
N/A
<5
<5
<0.023
N/A
<0.05
N/A
N/A
N/A
<5
0.03
N/A
<0.05
N/A
N/A
N/A
<5
0.03
N/A
<0.05
N/A
N/A
N/A
<5
<0.023
N/A
<0.1
N/A
N/A
N/A
<2
<0.02
N/A
<0.2
N/A
N/A
N/A
<2
<0.02
N/A
<0.05
N/A
N/A
N/A
<2
<0.02
N/A
<0.05
N/A
N/A
N/A
<2
<0.23
N/A
<0.05
N/A
N/A
N/A
<1
<0.02
N/A
<0.05
N/A
N/A
N/A
<1
<0.02
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<0.05
N/A
N/A
N/A
<2
0.02
N/A
<0.05
N/A
N/A
N/A
5.09
<0.23
N/A
<0.05
N/A
N/A
N/A
8.3
0.09
N/A
<0.05
N/A
N/A
N/A
9.4
0.03
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<0.1
N/A
N/A
N/A
<2
<0.02
N/A
<0.2
N/A
N/A
N/A
<2
<0.02
N/A
<0.05
N/A
N/A
N/A
<2
<0.02
N/A
<0.05
N/A
N/A
N/A
<2
<0.23
N/A
<0.05
N/A
N/A
N/A
<1
<0.02
N/A
<0.05
N/A
N/A
N/A
<1
<0.02
N/A
<0.1
N/A
N/A
N/A
<2
0.27
N/A
<0.2
N/A
N/A
N/A
<2
0.27
N/A
0.307
N/A
N/A
N/A
3.04
0.25
N/A
0.141
N/A
N/A
N/A
2.63
0.33
N/A
0.244
N/A
N/A
N/A
1.3
0.41
N/A
0.23
N/A
N/A
N/A
2.1
0.76
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<0.1
N/A
N/A
N/A
<2
<0.02
N/A
<0.2
N/A
N/A
N/A
<2
<0.02
N/A
<0.05
N/A
N/A
N/A
<2
<0.02
N/A
<0.05
N/A
N/A
N/A
<2
<0.23
N/A
<0.05
N/A
N/A
N/A
<1
<0.02
N/A
<0.05
N/A
N/A
N/A
1.4
<0.02
N/A
<0.1
N/A
N/A
N/A
<2
<0.02
N/A
<0.2
N/A
N/A
N/A
<2
<0.02
N/A
<0.05
N/A
N/A
N/A
<2
<0.02
Tables - Page 19

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Analytical Parameter Iron
Units pg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard 300
Analytical Method 200.7
Well Name Well Type Hydrostratigraphic Unit Sample Collection Date Dissolved Total
1W-8S
Voluntary
Transition (Saprolite)
2/16/2009
N/A
156C
1W-8S
Voluntary
Transition (Saprolite)
8/10/2009
N/A
256C
1W-8S
Voluntary
Transition (Saprolite)
2/8/2010
N/A
493
1W-8S
Voluntary
Transition (Saprolite)
2/7/2011
N/A
N/A
1W-8S
Voluntary
Transition (Saprolite)
6/1/2011
N/A
N/A
1W-8S
Voluntary
Transition (Saprolite)
10/5/2011
N/A
N/A
1W-9D
Voluntary
Bedrock
11/8/2007
N/A
395
1W-9D
Voluntary
Bedrock
2/1212008
N/A
221
1W-9D
Voluntary
Bedrock
8/28/2008
N/A
184
1W-9D
Voluntary
Bedrock
2/16/2009
N/A
135
1W-9D
Voluntary
Bedrock
8/10/2009
N/A
86
1W-9D
Voluntary
Bedrock
2/8/2010
N/A
67.6
1W-9S
Voluntary
Transition (Saprolite)
11/8/2007
N/A
160
1W-9S
Voluntary
Transition (Saprolite)
2/12/2008
N/A
35
1W-9S
Voluntary
Transition (Saprolite)
8/28/2008
N/A
63
1W-9S
Voluntary
Transition (Saprolite)
2/16/2009
N/A
384C
1W-9S
Voluntary
Transition (Saprolite)
8/10/2009
N/A
24
1W-9S
Voluntary
Transition (Saprolite)
2/8/2010
N/A
17
1W-9S
Voluntary
Transition (Saprolite)
2/7/2011
N/A
N/A
1W-9S
Voluntary
Transition (Saprolite)
6/1/2011
N/A
N/A
1W-9S
Voluntary
Transition (Saprolite)
10/5/2011
N/A
N/A
Lead Magnesium Manganese Mercury Molydenum Nickel Nitrate as N
pg/L pg/L pg/L pg/L pg/L pg/L mg-N/L
15
NE
50
1
NE
100
200.8
200.7
200.8
245.1
200.8
200.7
Dissolved
Total
Dissolved
Total
Dissolved
Total
Dissolved
Total
Dissolved
Total
Dissolved
Totai
N/A
<2
N/A
28.7
N/A
5750
N/A
<0.05
N/A
N/A
N/A
2.34
N/A
<1
N/A
28.5
N/A
7720
N/A
<0.05
N/A
N/A
N/A
2.5
N/A
<1
N/A
28.4
N/A
1160
N/A
<0.05
N/A
N/A
N/A
<1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<2
N/A
5.006
N/A
308
N/A
<0.1
N/A
N/A
N/A
3.9
N/A
<2
N/A
5.66
N/A
323
N/A
<0.2
N/A
N/A
N/A
3.77
N/A
<2
N/A
5.89
N/A
337
N/A
<0.05
N/A
N/A
N/A
3.51
N/A
<2
N/A
5.68
N/A
350
N/A
<0.05
N/A
N/A
N/A
3.46
N/A
<1
N/A
6.09
N/A
387
N/A
<0.05
N/A
N/A
N/A
3.2
N/A
<1
N/A
6.2
N/A
412
N/A
<0.05
N/A
N/A
N/A
3.9
N/A
<2
N/A
12.826
N/A
1851
N/A
<0.1
N/A
N/A
N/A
<2
N/A
<2
N/A
13.1
N/A
295
N/A
<0.2
N/A
N/A
N/A
<2
N/A
<2
N/A
13.7
N/A
62
N/A
<0.05
N/A
N/A
N/A
<2
N/A
<2
N/A
12.8
N/A
666
N/A
<0.05
N/A
N/A
N/A
<2
N/A
<1
N/A
13.8
N/A
39
N/A
<0.05
N/A
N/A
N/A
<1
N/A
<1
N/A
13.2
N/A
6.54
N/A
<0.05
N/A
N/A
N/A
<1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
10
300.0
<0.23
<0.02
0.21
N/A
N/A
N/A
<0.02
<0.02
0.02
<0.23
<0.02
<0.02
<0.02
<0.02
0.05
<0.23
0.05
0.19
N/A
N/A
N/A
Tables - Page 20

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Analytical Parameter
Units
15A NCAC 02L .0202(g) Groundwater Quality Standard
Well Name
4-16
4-6
4W-10D
4W-10D
4W-10D
4W-10D
4W-10D
4W-10D
4W-10D
4W-10D
4W-10D
4W-10D
4W-10D
4W-10S
4W-10S
4W-10S
11W-10S
4W-10S
4W-10S
4W-10S
4W-10S
4W-10S
4W-10S
4W-10S
4W-11D
4W-11D
4W-11D
4W-11D
4W-11D
4W-11D
4W-11D
4W-11D
4W-11D
4W-11D
4W-11D
4W-11S
4W-11S
/lW-11S
/lW-11S
4W-11S
4W-11S
4W-11S
4W-11S
4W-11S
4W-11S
4W-11S
Well Type
Boring/Temporary
Boring/Temporary
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Potassium
Selenium
Sodium
Strontium
Sulfate
TDS
Thallium*
TOC
TOX
mg/L
pg/L
mg/L
mg/L
mg/L
mg/L
pg/L
mg/L
pg/L
NE
20
NE
NE
250
500
0.2
NIA
NE i
Analytical Method 200.7
200.8
200.7
N/A
Hydrostratigraphic Unit Sample Collection Date Dissolved Total Dissolved Total Dissolved Total Total
Residuum
Surface Water
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
300.0 2540C 200.8 5310B N/A
Total Total Dissolved Total Total Total
10/5/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
10/5/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
2/7/2011
N/A
N/A
N/A
<1
N/A
N/A
N/A
5.4
80
N/A
<0.2
N/A
6/1/2011
N/A
N/A
N/A
<1
N/A
N/A
N/A
5.6
72
N/A
<0.2
N/A
10/5/2011
N/A
N/A
N/A
<1
N/A
N/A
N/A
3.9
89
N/A
<0.2
N/A
2/8/2012
N/A
N/A
N/A
<1
N/A
N/A
N/A
3.3
83
N/A
<0.2
N/A
6/6/2012
N/A
N/A
N/A
<1
N/A
N/A
N/A
3
77
N/A
<0.2
N/A
10/4/2012
N/A
N/A
N/A
<1
N/A
N/A
N/A
2.8
71
N/A
<0.2
N/A
2/7/2013
N/A
1.32
N/A
<1
N/A
6.51
N/A
3.2
74
N/A
<0.2
N/A
6/5/2013
1.36
1.41
<1
<1
6.41
6.07
N/A
3.1
81
<0.2
<0.2
N/A
10/1/2013
N/A
1.39
N/A
<1
N/A
6.36
N/A
3
82
N/A
<0.2
N/A
2/6/2014
N/A
1.51
N/A
<1
N/A
6.86
N/A
2.8
68
N/A
<0.2
N/A
6/4/2014
N/A
1.36
N/A
<1
N/A
6.6
N/A
2.9
79
N/A
<0.2
N/A
2/7/2011
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.16
21
N/A
<0.2
N/A
6/1/2011
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.17
<10
N/A
<0.2
N/A
10/5/2011
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.14
25
N/A
<0.2
N/A
2/8/2012
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.13
35
N/A
<0.2
N/A
6/6/2012
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.13
<25
N/A
<0.2
N/A
10/4/2012
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.14
17
N/A
<0.2
N/A
2/7/2013
N/A
0.95
N/A
<1
N/A
0.714
N/A
0.15
14
N/A
<0.2
N/A
6/5/2013
0.93
1.02
<1
<1
0.727
0.748
N/A
0.12
<25
<0.2
<0.2
N/A
10/1/2013
N/A
1.02
N/A
<1
N/A
0.631
N/A
0.11
<25
N/A
<0.2
N/A
2/6/2014
N/A
0.977
N/A
<1
N/A
0.743
N/A
0.14
<25
N/A
<0.2
N/A
6/4/2014
N/A
0.998
N/A
<1
N/A
0.688
N/A
0.11
<25
N/A
<0.2
N/A
2/7/2011
N/A
N/A
N/A
<1
N/A
N/A
N/A
6
92
N/A
<0.2
N/A
6/1/2011
N/A
N/A
N/A
<1
N/A
N/A
N/A
7.9
64
N/A
<0.2
N/A
10/5/2011
N/A
N/A
N/A
<1
N/A
N/A
N/A
6.9
98
N/A
<0.2
N/A
2/8/2012
N/A
N/A
N/A
<1
N/A
N/A
N/A
7.5
95
N/A
<0.2
N/A
6/6/2012
N/A
N/A
N/A
<1
N/A
N/A
N/A
4.9
80
N/A
<0.2
N/A
10/4/2012
N/A
N/A
N/A
<1
N/A
N/A
N/A
3.3
77
N/A
<0.2
N/A
2/6/2013
N/A
2.07
N/A
<1
N/A
6.32
N/A
2.7
73
N/A
<0.2
N/A
6/5/2013
2.38
2.44
<1
<1
4.5
4.26
N/A
1.1
73
<0.2
<0.2
N/A
10/1/2013
N/A
2.5
N/A
<1
N/A
4.09
N/A
0.88
73
N/A
<0.2
N/A
2/6/2014
N/A
2.47
N/A
<1
N/A
4.68
N/A
1.7
69
N/A
<0.2
N/A
6/4/2014
N/A
2.33
N/A
<1
N/A
4.35
N/A
1.3
75
N/A
<0.2
N/A
2/7/2011
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.41
47
N/A
<0.2
N/A
6/1/2011
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.44
29
N/A
<0.2
N/A
10/5/2011
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.47
62
N/A
<0.2
N/A
2/8/2012
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.43
52
N/A
<0.2
N/A
6/6/2012
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.39
49
N/A
<0.2
N/A
10/4/2012
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.4
53
N/A
<0.2
N/A
2/6/2013
N/A
0.927
N/A
<1
N/A
4.21
N/A
0.41
47
N/A
<0.2
N/A
6/5/2013
0.971
0.992
<1
<1
4.37
4.43
N/A
0.43
47
<0.2
<0.2
N/A
10/1/2013
N/A
0.998
N/A
<1
N/A
4.43
N/A
0.38
48
N/A
<0.2
N/A
2/6/2014
N/A
1.04
N/A
<1
N/A
4.7
N/A
0.39
44
N/A
<0.2
N/A
6/4/2014
N/A
1.01
N/A
<1
N/A
4.67
N/A
0.37
46
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
TSS Zinc
mg/L mg/L
NE 1
N/A 200.7
Total Dissolved Total
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<0.00!
N/A
N/A
0.006
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
8
<0.005
0.008
N/A
N/A
<0.00!
N/A
N/A
0.006
N/A
N/A
<0.00!
N/A
N/A
0.006
N/A
N/A
0.01
N/A
N/A
0.008
N/A
N/A
0.009
N/A
N/A
0.01
N/A
N/A
0.008
N/A
N/A
0.008
8
0.007
0.01
N/A
N/A
0.006
N/A
N/A
0.01
N/A
N/A
0.011
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
12
<0.005
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
0.012
<5
<0.005
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
N/A
N/A
<0.00!
Tables - Page 21

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Well Name
AW-12D
4W-12D
4W-12D
4W-12D
4W-12D
4W-12D
4W-12D
4W-12D
4W-12D
4W-12D
4W-12D
4W-12S
4W-12S
4W-12S
4W-12S
4W-12S
4W-12S
4W-12S
4W-12S
4W-12S
4W-12S
4W-12S
4W-13D
4W-13D
4W-13D
4W-13D
4W-13D
4W-13D
4W-13D
4W-13D
4W-13D
4W-13D
4W-13D
4W-13S
4W-13S
4W-13S
4W-13S
4W-13S
4W-13S
4W-13S
4W-13S
4W-13S
4W-13S
4W-13S
4W-14D
4W-14D
Well Type
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
(Compliance
Compliance
(Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
(Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
(Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
(Compliance
Compliance
Compliance
(Compliance
(Compliance
Compliance
Compliance
Compliance
Compliance
Analytical Parameter
Potassium
Selenium
Sodium
Strontium
Sulfate
TDS
Thallium"
TOC
TOX
TSS
Units
mg/L
pg/L
mg/L
mg/L
mg/L
mg/L
Ng/L
mg/L
pg/L
mg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard
NE
20
NE
NE
250
500
0.2
NIA
NE
NE
Hydrostratigraphic Unit
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
ransition (PWR)
;esiduum
:esiduum
;esiduum
:esiduum
lesiduum
;esiduum
;esiduum
;esiduum
;esiduum
;esiduum
;esiduum
edrock
edrock
,edrock
edrock
,edrock
edrock
edrock
edrock
edrock
edrock
edrock
;esiduum
;esiduum
;esiduum
:esiduum
;esiduum
:esiduum
;esiduum
:esiduum
;esiduum
:esiduum
;esiduum
edrock
edrock
Analytical Method
Sample Collection Date
2/7/2011
6/1 /2011
10/5/2011
2/8/2012
6/6/2012
10/4/2012
2/6/2013
6/5/2013
10/1 /2013
2/6/2014
6/4/2014
2/7/2011
6/1 /2011
10/5/2011
2/8/2012
6/6/2012
10/4/2012
2/6/2013
6/5/2013
10/1 /2013
2/6/2014
6/4/2014
2/7/2011
6/1 /2011
10/5/2011
2/8/2012
6/6/2012
10/4/2012
2/6/2013
6/5/2013
10/1 /2013
2/6/2014
6/4/2014
2/7/2011
6/1 /2011
10/5/2011
2/8/2012
6/6/2012
10/4/2012
2/6/2013
6/5/2013
10/1 /2013
2/6/2014
6/4/2014
2/7/2011
6/1 /2011
200.7
Dissolved
N/A
N/A
N/A
N/A
N/A
N/A
N/A
2.37
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
0.74
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1.85
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1.67
N/A
N/A
N/A
N/A
N/A
200.8 200.7 N/A 300.0 2540C 200.8 5310B N/A N/A
Total Dissolved Total Dissolved Total Total Total Total Dissolved Total Total Total Total
N/A
N/A
<1
N/A
N/A
N/A
7.7
82
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
8.2
70
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
8.4
100
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
7.4
95
N/A
<0.2
N/A
N/A
N/A
NIA
N/A
<1
N/A
N/A
N/A
6.5
81
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
7.4
85
N/A
<0.2
N/A
N/A
N/A
2.53
N/A
<1
N/A
6.25
N/A
7.5
85
N/A
<0.2
N/A
N/A
N/A
2.59
<1
<1
6.35
6.58
N/A
7
85
<0.2
<0.2
N/A
N/A
6
2.64
N/A
<1
N/A
6.47
N/A
7
82
N/A
<0.2
N/A
N/A
N/A
2.65
N/A
<1
N/A
6.71
N/A
7.6
75
N/A
<0.2
N/A
N/A
N/A
2.45
N/A
<1
N/A
6.27
N/A
7.6
82
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.97
24
NIA
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
1
<10
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
1.2
44
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.94
25
N/A
0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.83
<25
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
1.1
30
N/A
<0.2
N/A
N/A
N/A
1.02
N/A
<1
N/A
2.08
N/A
0.75
21
N/A
<0.2
N/A
N/A
N/A
0.807
N/A
<1
1.7
1.75
N/A
0.76
<25
<0.2
<0.2
N/A
N/A
<5.26
1.38
N/A
<1
N/A
2.47
N/A
0.84
32
N/A
<0.2
N/A
N/A
N/A
0.968
N/A
<1
N/A
1.41
N/A
0.33
<25
N/A
<0.2
N/A
N/A
N/A
1.23
N/A
<1
N/A
2.24
N/A
0.74
25
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.55
88
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.58
79
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.61
100
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.57
100
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.54
85
N/A
<0.2
N/A
N/A
N/A
NIA
N/A
<1
N/A
N/A
N/A
0.56
90
N/A
<0.2
N/A
N/A
N/A
1.79
N/A
<1
N/A
6.97
N/A
0.56
88
N/A
<0.2
N/A
N/A
N/A
1.91
<1
<1
7.18
7.35
N/A
0.58
95
<0.2
<0.2
N/A
N/A
<5
1.89
N/A
<1
N/A
7.32
N/A
0.53
88
N/A
<0.2
N/A
N/A
N/A
1.99
N/A
<1
N/A
7.74
N/A
0.58
79
N/A
<0.2
N/A
N/A
N/A
1.82
N/A
<1
N/A
7.2
N/A
0.55
95
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.66
95
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.54
63
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.57
100
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.55
97
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.49
84
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.5
99
N/A
<0.2
N/A
N/A
N/A
1.85
N/A
<1
N/A
6.9
N/A
0.48
96
N/A
<0.2
N/A
N/A
N/A
2.17
<1
<1
7.1
7.24
N/A
0.52
96
<0.2
<0.2
N/A
N/A
28
2.11
N/A
<1
N/A
7.1
N/A
0.46
89
N/A
<0.2
N/A
N/A
N/A
2.02
N/A
<1
N/A
7.41
N/A
0.5
80
N/A
<0.2
N/A
N/A
N/A
1.73
N/A
<1
N/A
6.98
N/A
0.47
91
NIA
<0.2
N/A
N/A
N/A
N/A
N/A
6.76
N/A
N/A
N/A
310
540
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
6.26
N/A
N/A
N/A
310
510
N/A
<0.2
N/A
N/A
N/A
Zinc
mg/L
1
200.7
Dissolved
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
N/A
N/A
Total
<0.005
<0.005
<0.005
<0.005
<0.005
0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
0.007
<0.005
<0.005
<0.005
<0.005
<0.005
0.008
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
0.009
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
0.006
<0.005
0.005
<0.005
<0.005
0.006
Tables - Page 22

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Well Name
AW-14D
4W-14D
AW-14D
4W-14D
4W-14D
4W-14D
4W-14D
4W-14D
4W-14D
4W-14S
4W-14S
4W-14S
4W-14S
4W-14S
4W-14S
4W-14S
4W-14S
4W-14S
4W-14S
4W-14S
-4
-4
-4
-4
-4
-4D
-4D
-4D
-4D
-4D
-4D
-4D
-4D
-4D
Well Type
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Analytical Parameter
Potassium
Selenium
Sodium
Strontium
Sulfate
TDS
Thallium"
TOC
TOX
TSS
Units
mg/L
pg/L
mg/L
mg/L
mg/L
mg/L
Ng/L
mg/L
pg/L
mg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard
NE
20
NE
NE
250
500
0.2
NIA
NE
NE
Hydrostratigraphic Unit
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Residuum
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Analvtical Method
Sample Collection Date
10/5/2011
2/8/2012
6/6/2012
10/4/2012
2/7/2013
6/5/2013
10/1 /2013
2/6/2014
6/4/2014
2/7/2011
6/1 /2011
10/5/2011
2/8/2012
6/6/2012
10/4/2012
2/7/2013
6/5/2013
10/1 /2013
2/6/2014
6/4/2014
11 /8/2007
2/12/2008
8/28/2008
2/16/2009
8/10/2009
2/8/2010
2/7/2011
6/1 /2011
10/5/2011
2/8/2012
6/6/2012
10/4/2012
2/6/2013
6/5/2013
10/1 /2013
2/6/2014
6/4/2014
11 /8/2007
2/12/2008
8/28/2008
2/16/2009
8/10/2009
2/8/2010
2/7/2011
6/1 /2011
10/5/2011
200.7 200.8 200.7 N/A 300.0 2540C 200.8 5310B N/A N/A
Dissolved
Total
Dissolved
Total
Dissolved
Total
Total
Total
Total
Dissolved
Total
Total
Total
Total
N/A
N/A
N/A
6.26
N/A
N/A
N/A
290
510
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
N/A
7.1
N/A
N/A
N/A
310
510
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
N/A
6.21
N/A
N/A
N/A
280
494
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
N/A
6.26
N/A
N/A
N/A
270
490
N/A
<0.2
N/A
N/A
N/A
N/A
4.81
N/A
5.65
N/A
28.5
N/A
270
480
N/A
<0.2
N/A
N/A
N/A
4.98
5.05
4.21
4.33
29.3
29.5
N/A
250
470
<0.2
<0.2
N/A
N/A
<5
N/A
5
N/A
4.33
N/A
29.1
N/A
240
460
N/A
<0.2
N/A
N/A
N/A
N/A
5.09
N/A
4.29
N/A
29.7
N/A
240
450
N/A
<0.2
N/A
N/A
N/A
N/A
4.87
N/A
4.35
N/A
28.9
N/A
230
450
N/A
<0.2
N/A
N/A
N/A
N/A
NIA
N/A
7.7
N/A
N/A
N/A
400
650
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
N/A
6.89
N/A
N/A
N/A
400
620
N/A
<0.2
N/A
N/A
N/A
N/A
NIA
N/A
7.13
N/A
N/A
N/A
370
610
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
N/A
7.82
N/A
N/A
N/A
360
580
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
N/A
7.18
N/A
N/A
N/A
350
573
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
N/A
6.9
N/A
N/A
N/A
350
590
N/A
<0.2
N/A
N/A
N/A
N/A
5.42
N/A
7.69
N/A
27.7
N/A
350
580
N/A
<0.2
N/A
N/A
N/A
5.52
5.53
6.95
6.62
28.1
27
N/A
340
600
<0.2
<0.2
N/A
N/A
10
N/A
5.71
N/A
6.4
N/A
27.2
NIA
310
580
NIA
<0.2
N/A
N/A
N/A
N/A
5.61
N/A
6.2
NIA
27.3
N/A
310
570
N/A
<0.2
N/A
N/A
N/A
N/A
5.16
N/A
6.25
N/A
25.2
N/A
280
580
N/A
<0.2
N/A
N/A
N/A
N/A
2.09
N/A
<2
N/A
3.607
N/A
0.13
37
N/A
N/A
0.13
<1000
N/A
N/A
2.1
N/A
<2
NIA
3.88
N/A
0.11
10
N/A
NIA
0.2
<1000
NIA
N/A
2.08
N/A
<2
N/A
3.86
N/A
0.11
48
N/A
N/A
0.178
<20
N/A
N/A
1.98
N/A
<2
NIA
3.56
N/A
0.15
24
N/A
N/A
0.143
30
N/A
N/A
2.05
N/A
<1
N/A
3.95
N/A
0.1
52
N/A
N/A
0.56
<20
N/A
N/A
1.93
N/A
<1
N/A
3.54
N/A
0.14
<20
N/A
N/A
0.227
<50
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.14
54
N/A
<0.2
N/A
N/A
N/A
N/A
NIA
N/A
<1
N/A
N/A
N/A
0.16
46
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.25
63
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.2
63
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.16
55
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
0.2
46
N/A
<0.2
N/A
N/A
N/A
N/A
1.92
N/A
<1
N/A
3.82
N/A
0.12
48
N/A
<0.2
N/A
N/A
N/A
1.99
2.01
<1
<1
3.96
3.94
N/A
0.23
46
<0.2
<0.2
N/A
N/A
<5.26
N/A
1.99
N/A
<1
N/A
3.91
N/A
0.13
55
N/A
<0.2
N/A
N/A
N/A
N/A
2.05
N/A
<1
N/A
4.23
N/A
0.13
43
N/A
<0.2
N/A
N/A
N/A
N/A
1.99
N/A
<1
N/A
4.01
N/A
0.11
46
N/A
<0.2
N/A
N/A
N/A
N/A
2.32
N/A
<2
N/A
7.074
N/A
1.19
69
N/A
N/A
0.15
<1000
N/A
N/A
2.31
N/A
<2
NIA
7.54
NIA
1
41
NIA
N/A
0.14
<1000
N/A
N/A
2.25
N/A
<2
N/A
7.32
N/A
0.98
72
N/A
N/A
0.148
<20
N/A
N/A
2.14
N/A
<2
N/A
7.2
N/A
1.4
72
N/A
N/A
0.138
40
N/A
N/A
2.16
N/A
<1
N/A
7.41
N/A
1
78
N/A
N/A
0.16
<20
N/A
N/A
2.05
N/A
<1
N/A
6.89
N/A
1.2
42
N/A
N/A
0.141
<50
N/A
N/A
NIA
N/A
<1
N/A
N/A
N/A
1.2
82
NIA
<0.2
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
1.3
58
N/A
<0.2
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
1.2
88
N/A
<0.2
N/A
N/A
N/A
Zinc
mg/L
1
200.7
Dissolved
N/A
N/A
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
0.01
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Total
0.005
<0.005
<0.005
<0.005
0.005
0.005
<0.005
0.006
<0.005
0.011
0.013
0.012
0.011
0.012
0.013
0.011
0.012
0.01
0.015
0.011
<0.005
<0.005
<0
<0.005
<0.005
0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Tables - Page 23

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Well Name
AW-4D
4W-4D
4W-4D
4W-4D
4W-4D
4W-4D
4W-4D
4W-4D
4W-6D
4W-6D
4W-6D
4W-6D
4W-6D
4W-6D
4W-6S
4W-6S
4W-6S
4W-6S
4W-6S
4W-6S
4W-6S
4W-6S
4W-7D
4W-7D
4W-7D
4W-7D
4W-7D
4W-7D
4W-7S
4W-7S
4W-7S
4W-7S
4W-7S
4W-7S
4W-7S
4W-7S
4W-7S
4W-8D
4W-8D
4W-8D
4W-8D
4W-8D
4W-8D
4W-8S
4W-8S
4W-8S
Well Type
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
Compliance
(Voluntary
Voluntary
(Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
(Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
(Voluntary
Voluntary
(Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
(Voluntary
Voluntary
(Voluntary
Voluntary
Voluntary
Voluntary
(Voluntary
Voluntary
(Voluntary
Voluntary
(Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Voluntary
Analytical Parameter
Potassium
Selenium
Sodium
Strontium
Sulfate
TDS
Thallium"
TOC
TOX
Units
mg/L
pg/L
mg/L
mg/L
mg/L
mg/L
Ng/L
mg/L
pg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard
NE
20
NE
NE
250
500
0.2
NIA
NE
Hydrostratigraphic Unit
edrock
edrock
edrock
edrock
edrock
edrock
edrock
edrock
edrock
edrock
edrock
edrock
edrock
edrock
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
edrock
edrock
,edrock
edrock
,edrock
edrock
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
edrock
edrock
edrock
,edrock
edrock
edrock
ransition (Saprolite)
ransition (Saprolite)
ransition (Saprolite)
Analytical Method
Sample Collection Date
2/8/2012
6/6/2012
10/4/2012
2/6/2013
6/5/2013
10/1 /2013
2/6/2014
6/4/2014
11 /8/2007
2/12/2008
8/28/2008
2/16/2009
8/10/2009
2/8/2010
11 /8/2007
8/28/2008
2/16/2009
8/10/2009
2/8/2010
2/7/2011
6/1 /2011
10/5/2011
11 /8/2007
2/12/2008
8/28/2008
2/16/2009
8/10/2009
2/8/2010
11 /8/2007
2/12/2008
8/28/2008
2/16/2009
8/10/2009
2/8/2010
2/7/2011
6/1 /2011
10/5/2011
11 /8/2007
2/12/2008
8/28/2008
2/16/2009
8/10/2009
2/8/2010
11 /8/2007
2/12/2008
8/28/2008
200.7
Dissolved
N/A
N/A
N/A
N/A
2.24
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
200.8 200.7 N/A 300.0 2540C 200.8 5310B N/A
Total Dissolved Total Dissolved Total Total Total Total Dissolved Total Total Total
N/A
N/A
<1
N/A
N/A
N/A
1.4
95
N/A
<0.2
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
1.3
73
N/A
<0.2
N/A
N/A
N/A
N/A
<1
N/A
N/A
N/A
1.2
76
N/A
<0.2
N/A
N/A
2.1
N/A
<1
N/A
7.23
N/A
1.3
84
N/A
<0.2
N/A
N/A
2.23
<1
<1
7.66
7.66
N/A
1.4
83
<0.2
<0.2
N/A
N/A
2.19
N/A
<1
N/A
7.52
N/A
1.3
85
N/A
<0.2
N/A
N/A
2.17
N/A
<1
N/A
7.48
N/A
1.4
73
N/A
<0.2
N/A
N/A
2.21
N/A
<1
N/A
7.66
N/A
1.4
83
N/A
<0.2
N/A
N/A
2.32
N/A
<2
N/A
7.471
N/A
8.54
97
N/A
N/A
0.16
<1000
2.48
N/A
<2
N/A
8.05
N/A
8
45
N/A
N/A
0.18
<1000
2.49
N/A
<2
N/A
8.01
N/A
8.5
86
N/A
N/A
0.228
<20
2.44
N/A
<2
N/A
7.75
N/A
7.7
64
N/A
N/A
0.206
30
2.43
N/A
<1
N/A
8.13
N/A
9.3
110
N/A
N/A
0.201
30
2.35
N/A
<1
N/A
7.71
N/A
9.4
74
N/A
N/A
0.324
<50
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
4.07
N/A
<2
N/A
12.9
N/A
30
110
N/A
N/A
0.803
30
7.57
N/A
2.7
N/A
25.7
N/A
16
202
N/A
N/A
0.457
90
8.84
N/A
1.5
N/A
24.3
N/A
14
366
N/A
N/A
0.501
90
10.5
N/A
1.1
N/A
21.1
N/A
12
364
N/A
N/A
0.787
<50
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
3.15
N/A
<2
N/A
9.93
N/A
134.13
350
N/A
N/A
0.24
<1000
3.32
N/A
<2
N/A
11.1
N/A
120
300
N/A
N/A
0.19
<1000
3.27
N/A
<2
N/A
10.8
N/A
110
350
N/A
N/A
0.271
20
3.2
N/A
<2
N/A
10.6
N/A
120
312
N/A
N/A
0.275
40
3.18
N/A
<1
N/A
10.8
N/A
120
342
N/A
N/A
0.26
50
3.16
N/A
<1
N/A
10.4
N/A
120
308
N/A
N/A
0.244
<50
3
N/A
<2
N/A
12.21
N/A
52.19
106
N/A
N/A
0.15
<1000
4.66
N/A
2.93
N/A
20.7
N/A
38
240
N/A
N/A
<0.1
<1000
8.33
N/A
4.09
N/A
24.5
N/A
18
1160
N/A
N/A
0.234
40
6.62
N/A
10.6
N/A
21.3
N/A
37
926
N/A
N/A
0.235
100
6.66
N/A
2.5
N/A
15.9
N/A
77
1080
N/A
N/A
0.329
160
5.65
N/A
1.9
N/A
12.3
N/A
130
1030
N/A
N/A
0.291
<50
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
3.46
N/A
<2
N/A
8.578
N/A
122.32
366
N/A
N/A
0.29
<1000
3.32
N/A
<2
N/A
9.68
N/A
120
330
N/A
N/A
0.26
<1000
3
N/A
<2
N/A
9.69
N/A
110
358
N/A
N/A
0.383
<20
2.91
N/A
<2
N/A
9.59
N/A
110
356
N/A
N/A
0.291
10
2.89
N/A
<1
N/A
9.81
N/A
130
380
N/A
N/A
0.38
70
2.93
N/A
<1
N/A
9.58
N/A
120
358
N/A
N/A
0.358
<50
3.27
N/A
<2
N/A
10.475
N/A
20.69
278
N/A
N/A
1.75
<1000
2.92
N/A
<2
N/A
8.9
N/A
8.6
140
N/A
N/A
1.18
<1000
5.34
N/A
3.94
N/A
15.8
N/A
36
376
N/A
N/A
2.95
<20
TSS
mg/L
NE
N/A
Total
N/A
N/A
N/A
N/A
<5
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Zinc
mg/L
1
200.7
Dissolved
N/A
N/A
N/A
N/A
<0.005
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Total
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
0.007
0.007
0.008
0.007
0.005
0.006
N/A
0.036
0.114
0.172
0.201
N/A
N/A
N/A
<0.005
<0.005
<0
<0.005
<0.005
<0.005
0.009
0.021
0.054
0.06
0.044
0.043
N/A
N/A
N/A
0.015
0.007
<0
<0.005
<0.005
0.009
<0.005
<0.005
<0
Tables - Page 24

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Analytical Parameter
Potassium
Selenium
Sodium
Strontium
Sulfate
TDS
Thallium"
TOC
TOX
TSS
Zinc
Units
mg/L
pg/L
mg/L
mg/L
mg/L
mg/L
Ng/L
mg/L
pg/L
mg/L
mg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard
NE
20
NE
NE
250
500
0.2
N/A
NE
NE
1
Analytical Method
200.7
200.8
200.7
N/A
300.0
2540C
200.8
5310B
N/A
N/A
200.7
Well Name
Well Type
Hydrostratigraphic Unit
Sample Collection Date
Dissolved
Total
Dissolved
Total
Dissolved
Total
Total
Total
Total
Dissolved
Total
Total
Total
Total
Dissolved
Total
MW-8S
Voluntary
Transition (Saprolite)
2/16/2009
N/A
6.87
N/A
2.96
N/A
17.5
N/A
67
500
N/A
N/A
3.9
60
N/A
N/A
<0.00!
MW-8S
Voluntary
Transition (Saprolite)
8/10/2009
N/A
7.27
N/A
1.3
N/A
18.5
N/A
81
536
N/A
N/A
3.92
70
N/A
N/A
<0.00!
MW-8S
Voluntary
Transition (Saprolite)
2/8/2010
N/A
9.63
N/A
6.5
N/A
20.7
N/A
78
550
N/A
N/A
3.65
<50
N/A
N/A
<0.00!
MW-8S
Voluntary
Transition (Saprolite)
2/7/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
MW-8S
Voluntary
Transition (Saprolite)
6/1/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
MW-8S
Voluntary
Transition (Saprolite)
10/5/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
MW-9D
Voluntary
Bedrock
11/8/2007
N/A
2.77
N/A
<2
N/A
9.026
N/A
96.75
217
N/A
N/A
0.28
<1000
N/A
N/A
0.008
MW-9D
Voluntary
Bedrock
2/12/2008
N/A
3.02
N/A
<2
N/A
10.5
N/A
100
180
N/A
N/A
0.33
<1000
N/A
N/A
<0.00!
MW-9D
Voluntary
Bedrock
8/28/2008
N/A
2.98
N/A
<2
N/A
10.5
N/A
94
216
N/A
N/A
0.376
<20
N/A
N/A
<0
MW-91D
Voluntary
Bedrock
2/16/2009
N/A
2.94
N/A
<2
N/A
10.4
N/A
100
220
N/A
N/A
0.3
50
N/A
N/A
<0.00!
MW-9D
Voluntary
Bedrock
8/10/2009
N/A
3.01
N/A
<1
N/A
10.8
N/A
110
236
N/A
N/A
0.295
110
N/A
N/A
<0.00!
MW-9D
Voluntary
Bedrock
2/8/2010
N/A
2.99
N/A
<1
N/A
10.6
N/A
120
260
N/A
N/A
0.303
<50
N/A
N/A
<0.00!
MW-9S
Voluntary
Transition (Saprolite)
11/8/2007
N/A
4.64
N/A
<2
N/A
23.58
N/A
66.01
327
N/A
N/A
1.9
<1000
N/A
N/A
<0.00!
MW-9S
Voluntary
Transition (Saprolite)
2/12/2008
N/A
5.03
N/A
<2
N/A
26.4
N/A
54
280
N/A
N/A
2.13
<1000
N/A
N/A
<0.001
MW-9S
Voluntary
Transition (Saprolite)
8/28/2008
N/A
5.29
N/A
<2
N/A
24
N/A
52
290
N/A
N/A
1.94
<20
N/A
N/A
<0
MW-9S
Voluntary
Transition (Saprolite)
2/16/2009
N/A
4.92
N/A
<2
N/A
22.8
N/A
55
290
N/A
N/A
1.88
60
N/A
N/A
<0.00!
MW-9S
Voluntary
Transition (Saprolite)
8/10/2009
N/A
4.82
N/A
<1
N/A
22.7
N/A
57
318
N/A
N/A
1.56
70
N/A
N/A
<0.00!
MW-9S
Voluntary
Transition (Saprolite)
2/8/2010
N/A
4.84
N/A
<1
N/A
22.8
N/A
52
312
N/A
N/A
1.33
<50
N/A
N/A
<0.00!
MW-9S
Voluntary
Transition (Saprolite)
2/7/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
MW-9S
Voluntary
Transition (Saprolite)
6/1/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
MW-9S
Voluntary
Transition (Saprolite)
10/5/2011
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Tables - Page 25

Table 6. Historical groundwater analytical results (compliance and voluntary wells)
Notes:
1. Depth to Water measured from the top of well casing.
2. Analytical parameter abbreviations:
Temp. = Temperature
DO = Dissolved oxygen
Cond. = Specific conductivity
ORP = Oxidation reduction potential
TDS = Total dissolved solids
TSS = Total suspended solids
TOC = Total organic carbon
3. Units:
'C = Degrees Celsius
SU = Standard Units
my = millivolts
NTU = Nephelometric Turbidity Unit
mg/L = milligrams per liter
pg/L = micrograms per liter
pmhos/cm = micromhos per centimeter
CaCO3 = calcium carbonate
HCO3 = bicarbonate
C032- = carbonate
4. N/A = Not applicable
5. NE = Not established
6. " Interim Maximum Allowable Concentration (IMAC) standards
7. Highlighted values indicate values that exceed the 15A NCAC 2L Standard
8. Analytical results with "<" preceding the result indicates that the parameter
was not detected at a concentration which attains or exceeds the laboratory reporting limit.
Tables - Page 26

Table 7. Historical surface water analytical results (ash basin, FGD landfill, and industrial landfill
Analytical Parameter Temp.
DO Cond. pH ORP Turbidity
Alkalinity
Alkalinity Alkalinity Aluminum Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Units C
mg/L pmhos/cm SU my NTU
mg/L CaCO3
mg/L HCO3 mg/L C032- Ng/L
Ng/L
N9/L
pg/L
N9/L
Ng/L
15A NCAC 02B .0200 Surface Water Quality Standard NA
NA NA 6.0 - 9.0 NA NA
NE
NE NE 87 5.6
10
1000
6.5
NE
2
Analytical Method
2320134d
200.8
200.8
200.7
200.7
200.8
Sample Collection
Field Measurements
Sample Name Sample Location
Total Dissolved Total
Dissolved Total
Dissolved Total
Total
Dissolved Total
Dissolved Total
Date
Tower-0.3m
Ash Basin
7/10/2013
29.48
N/A
824
6.86
N/A
11.5
23
N/A
N/A
N/A
N/A
<1
N/A
8.65
N/A
73
N/A
N/A
4480
N/A
<1
Tower-0.3m
Ash Basin
10/1/2013
22.98
6.43
1156
7.15
275
9.57
35
N/A
N/A
N/A
N/A
<1
N/A
8.71
N/A
53
N/A
N/A
6470
N/A
<1
Tower-0.3m
Ash Basin
2/6/2014
7.78
10.25
1091
6.71
338
8.85
20
N/A
N/A
N/A
N/A
<1
N/A
4.53
N/A
71
N/A
N/A
6600
N/A
<1
Tower-0.3m
Ash Basin
6/4/2014
25.83
6.55
1126
6.81
261
19.2
24
N/A
N/A
N/A
N/A
<1
N/A
8.79
N/A
73
N/A
N/A
5710
N/A
<1
Cl-LEACHATE
FGD Landfill
3/13/2012
N/A
N/A
N/A
N/A
N/A
N/A
<100
N/A
N/A
N/A
N/A
N/A
5.78
6.67
23
23
N/A
24900
24900
<2
<2
Cl-LEACHATE
FGD Landfill
9/17/2012
18.81
N/A
4969
5.56
N/A
10.6
46900
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
29.1
N/A
N/A
27100
N/A
<1
Cl-LEACHATE
FGD Landfill
3/18/2013
14.25
5.69
4326
4.64
404
35.4
1350
N/A
N/A
N/A
N/A
N/A
N/A
<10
N/A
24
N/A
N/A
21800
N/A
<10
Cl-LEACHATE
FGD Landfill
9/11/2013
20.08
6.43
4650
5.34
313
33.6
20100
N/A
N/A
N/A
N/A
N/A
N/A
<10
N/A
24.7
N/A
N/A
23100
N/A
<10
Cl-LEACHATE
FGD Landfill
3/31/2014
14.76
6.05
3189
4.32
492
6.52
<20000
N/A
N/A
N/A
N/A
N/A
N/A
<10
N/A
30.6
N/A
N/A
12000
N/A
<10
Cl-LEACHATE
FGD Landfill
9/24/2014
16.2
8.72
4901
3.16
567
30.5
<5000
N/A
N/A
N/A
N/A
N/A
N/A
<10
N/A
22.8
N/A
N/A
22000
N/A
<10
MS-ILF1-C1
Industrial LF
8/8/2011
24.02
N/A
251.8
7.06
N/A
2.7
106700
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
74.59
N/A
N/A
<50
N/A
<1
MS-ILF1-Cl
Industrial LF
2/9/2012
15.41
N/A
429
5.48
N/A
0.82
6072
N/A
N/A
N/A
N/A
N/A
N/A
4.1
N/A
103
N/A
N/A
224
N/A
<1
MS-ILF1-C1
Industrial LF
8/27/2012
19.77
N/A
2138
4.57
N/A
0.95
6000
N/A
N/A
N/A
N/A
N/A
N/A
29.67
N/A
73.89
N/A
N/A
13100
N/A
<10
MS-ILF1-Cl
Industrial LF
2/12/2013
16.22
6060
2016
4.65
482
1.62
317
N/A
N/A
N/A
N/A
N/A
N/A
21.6
N/A
58.1
N/A
N/A
14200
N/A
<10
MS-ILF1-C1
Industrial LF
8/6/2013
19.84
3980
2174
4.54
486
2.81
<100
N/A
N/A
N/A
N/A
N/A
N/A
40.3
N/A
59.1
N/A
N/A
18700
N/A
<10
MS-ILF1-Cl
Industrial LF
2/24/2014
18.07
0
2431
4.2
467
15.8
<100
N/A
N/A
N/A
N/A
N/A
N/A
98.3
N/A
70.4
N/A
N/A
26400
N/A
<10
MS-ILF1-Cl
Industrial LF
8/6/2014
17.29
1710
1600
4.36
466
2.02
<5000000
N/A
N/A
N/A
N/A
N/A
N/A
15.2
N/A
44.9
N/A
N/A
9810
N/A
<10
MS-ILF1-C2
Industrial LF
8/8/2011
23.98
N/A
198.1
6.84
N/A
3.41
69560
N/A
N/A
N/A
N/A
N/A
N/A
<1
N/A
48.13
N/A
N/A
<50
N/A
<1
MS-ILF1-C2
Industrial LF
2/9/2012
15.5
N/A
872
4.27
N/A
1.98
1645
N/A
N/A
N/A
N/A
N/A
N/A
28.8
N/A
91.6
N/A
N/A
5971
N/A
<1
MS-ILF1-C2
Industrial LF
8/27/2012
19.83
N/A
2361
4.45
N/A
0.96
4850
N/A
N/A
N/A
N/A
N/A
N/A
39.25
N/A
63.95
N/A
N/A
21900
N/A
<10
MS-ILF1-C2
Industrial LF
2/12/2013
15.41
7310
1943
4.37
490
1.48
<100
N/A
N/A
N/A
N/A
N/A
N/A
27.9
N/A
49.5
N/A
N/A
9590
N/A
<10
MS-ILF1-C2
Industrial LF
8/6/2013
19.48
4940
2254
4.27
493
2.59
<100
N/A
N/A
N/A
N/A
N/A
N/A
40.6
N/A
66.9
N/A
N/A
16100
N/A
<10
MS-ILF1-C2
Industrial LF
2/24/2014
17.85
6380
1686
4.18
463
1.61
<100
N/A
N/A
N/A
N/A
N/A
N/A
83.2
N/A
74.4
N/A
N/A
15900
N/A
<10
MS-ILF1-C2
Industrial LF
8/6/2014
17.2
4500
2177
3.94
494
2.07
<5000000
N/A
N/A
N/A
N/A
N/A
N/A
23.8
N/A
46.4
N/A
N/A
8360
N/A
<10
Tables - Page 27

Table 7. Historical surface water analytical results (ash basin, FGD landfill, and industrial landfill
Analytical Parameter
Calcium
Chloride
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Molydenum
Units
mg/L
mg/L
Ng/L
Ng/L
mg/L
pg/L
pg/L
pg/L
Ng/L
pg/L
pg/L
15A NCAC 02B .0200 Surface Water Quality Standard
NE
230
20
3
3
1000
25
NE
200
0.012
160
Analytical Method
200.7
300
200.7
200.8
200.7
200.7
200.8
200.7
200.8
245.1
200.8
Sample Collection
Sample Name Sample Location
Dissolved Total
Total
Dissolved Total
Dissolved Total
Dissolved Total
Dissolved Total
Dissolved Total
Dissolved Total
Dissolved Total
Dissolved Total
Dissolved Total
Date
Tower-0.3m
Ash Basin
7/10/2013
N/A
85.3
150
N/A
<5
N/A
N/A
N/A
<0.005
N/A
428
N/A
<1
N/A
37.8
N/A
382
N/A
<0.05
N/A
N/A
Tower-0.3m
Ash Basin
10/1/2013
N/A
107
230
N/A
<5
N/A
N/A
N/A
<0.005
N/A
284
N/A
<1
N/A
57.7
N/A
867
N/A
<0.05
N/A
N/A
Tower-0.3m
Ash Basin
2/6/2014
N/A
106
240
N/A
<5
N/A
N/A
N/A
<0.005
N/A
627
N/A
<1
N/A
56.1
N/A
888
N/A
<0.05
N/A
N/A
Tower-0.3m
Ash Basin
6/4/2014
N/A
112
240
N/A
<5
N/A
N/A
N/A
<0.005
N/A
302
N/A
<1
N/A
56
N/A
689
N/A
<0.05
N/A
N/A
Cl-LEACHATE
FGD Landfill
3/13/2012
660000
661000
780000
16.7
18.2
N/A
N/A
61
60
284000
269000
<2
<2
260000
261000
8160
8330
N/A
<0.05
N/A
N/A
Cl-LEACHATE
FGD Landfill
9/17/2012
N/A
725000
737000
N/A
<1
N/A
N/A
N/A
<5
N/A
331000
N/A
<1
N/A
261000
N/A
4490
N/A
<0.05
N/A
N/A
Cl-LEACHATE
FGD Landfill
3/18/2013
N/A
572000
574000
N/A
<10
N/A
N/A
N/A
26.6
N/A
273000
N/A
19.1
N/A
209000
N/A
5880
N/A
<0.05
N/A
N/A
Cl-LEACHATE
FGD Landfill
9/11/2013
N/A
660000
552000
N/A
<10
N/A
N/A
N/A
<5
N/A
293000
N/A
<10
N/A
241000
N/A
4940
N/A
<0.05
N/A
N/A
Cl-LEACHATE
FGD Landfill
3/31/2014
N/A
479000
294000
N/A
<10
N/A
N/A
N/A
10
N/A
150000
N/A
<10
N/A
155000
N/A
4550
N/A
<0.05
N/A
N/A
Cl-LEACHATE
FGD Landfill
9/24/2014
N/A
660000
526000
N/A
<10
N/A
N/A
N/A
<5
N/A
331000
N/A
<10
N/A
260000
N/A
7450
N/A
<0.05
N/A
N/A
MS-ILF1-C1
Industrial LF
8/8/2011
N/A
40520
2213
N/A
<5
N/A
N/A
N/A
<5
N/A
<10
N/A
<1
N/A
2162
N/A
8.97
N/A
<0.05
N/A
N/A
MS-ILF1-Cl
Industrial LF
2/9/2012
N/A
50830
6739
N/A
<5
N/A
N/A
N/A
<5
N/A
<10
N/A
<1
N/A
13620
N/A
2206
N/A
<0.05
N/A
N/A
MS-ILF1-Cl
Industrial LF
8/27/2012
N/A
353000
13300
N/A
<5
N/A
N/A
N/A
27.19
N/A
42.73
N/A
<10
N/A
54500
N/A
14400
N/A
<0.05
N/A
N/A
MS-ILF1-Cl
Industrial LF
2/12/2013
N/A
282000
10800
N/A
<5
N/A
N/A
N/A
64
N/A
30.1
N/A
<10
N/A
52900
N/A
13400
N/A
<0.05
N/A
N/A
MS-ILF1-Cl
Industrial LF
8/6/2013
N/A
334000
11300
N/A
<5
N/A
N/A
N/A
32.7
N/A
39.2
N/A
<10
N/A
52700
N/A
14500
N/A
<0.05
N/A
N/A
MS-ILF1-Cl
Industrial LF
2/24/2014
N/A
254000
18600
N/A
<5
N/A
N/A
N/A
5.25
N/A
30.3
N/A
<10
N/A
67600
N/A
24000
N/A
<0.05
N/A
N/A
MS-ILF1-Cl
Industrial LF
8/6/2014
N/A
234000
6140
N/A
<5
N/A
N/A
N/A
44.3
N/A
31.1
N/A
<10
N/A
26500
N/A
6880
N/A
<0.05
N/A
N/A
MS-ILF1-C2
Industrial LF
8/8/2011
N/A
28340
3545
N/A
<5
N/A
N/A
N/A
<5
N/A
16.18
N/A
<1
N/A
1939
N/A
<5
N/A
<0.05
N/A
N/A
MS-ILF1-C2
Industrial LF
2/9/2012
N/A
87690
11580
N/A
<5
N/A
N/A
N/A
25.7
N/A
<10
N/A
<1
N/A
27390
N/A
3487
N/A
<0.05
N/A
N/A
MS-ILF1-C2
Industrial LF
8/27/2012
N/A
324000
17900
N/A
<5
N/A
N/A
N/A
25.47
N/A
16.51
N/A
<10
N/A
74800
N/A
13800
N/A
<0.05
N/A
N/A
MS-ILF1-C2
Industrial LF
2/12/2013
N/A
249000
11800
N/A
<5
N/A
N/A
N/A
66
N/A
40
N/A
<10
N/A
47800
N/A
12400
N/A
<0.05
N/A
N/A
MS-ILF1-C2
Industrial LF
8/6/2013
N/A
332000
12800
N/A
<5
N/A
N/A
N/A
116
N/A
102
N/A
<10
N/A
59000
N/A
10900
N/A
<0.05
N/A
N/A
MS-ILF1-C2
Industrial LF
2/24/2014
N/A
170000
17800
N/A
<5
N/A
N/A
N/A
14.4
N/A
21.1
N/A
<10
N/A
56200
N/A
14700
N/A
<0.05
N/A
N/A
MS-ILF1-C2
Industrial LF
8/6/2014
N/A
360000
9330
N/A
<5
N/A
N/A
N/A
148
N/A
86.6
N/A
<10
N/A
29500
N/A
7810
N/A
<0.05
N/A
N/A
Tables - Page 28

Table 7. Historical surface water analytical results (ash basin, FGD landfill, and industrial landfill
Analytical Parameter
Nickel
Nitrate as N
Potassium
Selenium
Sodium
Strontium
Sulfate
TDS
Thallium
TOC
TOX
TSS
Zinc
Units
Ng/L
mg -NIL
mg/L
pg/L
mg/L
mg/L
mg/L
mg/L
Ng/L
mg/L
ug/L
mg/L
mg/L
15A NCAC 02B .0200 Surface Water Quality Standard
25
10
NE
5
NE
14
NE
500
0.24
N/A
NE
20
50
Analytical Method
200.7
300.0
200.7
200.8
200.7
300.0
2540C
200.8
5310E
200.7
Sample Name Sample Location Sample Collection
Date
Dissolved Total
Total
Dissolved Total
Dissolved Total
Dissolved Total
Total
Total
Total
Dissolved Total
Total
Total
Total
Dissolved Total
Tower-0.3m
Ash Basin
7/10/2013
N/A
<5
<0.023
N/A
4.17
N/A
2.64
N/A
6.83
N/A
130
610
N/A
0.21
N/A
N/A
N/A
N/A
0.009
Tower-0.3m
Ash Basin
10/1/2013
N/A
<5
2
N/A
4.71
N/A
2.26
N/A
7.44
N/A
130
770
N/A
<0.2
N/A
N/A
N/A
N/A
<0.005
Tower-0.3m
Ash Basin
2/6/2014
N/A
8
1.6
N/A
4.91
N/A
2.63
N/A
7.96
N/A
130
720
N/A
0.44
N/A
N/A
N/A
N/A
0.016
Tower-0.3m
Ash Basin
6/4/2014
N/A
<5
0.91
N/A
3.62
N/A
2.98
N/A
8.63
N/A
120
810
N/A
<0.2
N/A
N/A
N/A
N/A
<0.005
Cl-LEACHATE
FGD Landfill
3/13/2012
272
277
4900
18900
19300
163
169
14500
14700
N/A
2500000
4680000
N/A
N/A
N/A
N/A
N/A
534
554
Cl-LEACHATE
FGD Landfill
9/17/2012
N/A
122
5420
N/A
25800
N/A
223
N/A
14400
N/A
2260000
4700000
N/A
N/A
N/A
N/A
N/A
N/A
167
Cl-LEACHATE
FGD Landfill
3/18/2013
N/A
156
4480
N/A
20400
N/A
272
N/A
14500
N/A
2210000
4250000
N/A
N/A
N/A
N/A
N/A
N/A
278
Cl-LEACHATE
FGD Landfill
9/11/2013
N/A
123
4440
N/A
24300
N/A
459
N/A
16000
N/A
2280000
4310000
N/A
N/A
N/A
N/A
N/A
N/A
224
Cl-LEACHATE
FGD Landfill
3/31/2014
N/A
133
1480
N/A
15000
N/A
178
N/A
11700
N/A
1820000
3200000
N/A
N/A
N/A
N/A
N/A
N/A
258
Cl-LEACHATE
FGD Landfill
9/24/2014
N/A
177
2010
N/A
24200
N/A
210
N/A
19400
N/A
2900000
5120000
N/A
N/A
N/A
N/A
N/A
N/A
379
MS-ILF1-C1
Industrial LF
8/8/2011
N/A
<5
1277
N/A
8628
N/A
<1
N/A
939
N/A
6983
130000
N/A
N/A
N/A
N/A
N/A
N/A
<5
MS-ILF1-C1
Industrial LF
2/9/2012
N/A
58.4
2013
N/A
5160
N/A
5.31
N/A
5462
N/A
181500
314000
N/A
N/A
N/A
N/A
N/A
N/A
8.96
MS-ILF1-C1
Industrial LF
8/27/2012
N/A
344
5020
N/A
56300
N/A
170
N/A
60100
N/A
1290000
2120000
N/A
N/A
N/A
N/A
N/A
N/A
407
MS-ILF1-C1
Industrial LF
2/12/2013
N/A
216
6210
N/A
47400
N/A
144
N/A
61200
N/A
1190000
1820000
N/A
N/A
N/A
N/A
N/A
N/A
392
MS-ILF1-C1
Industrial LF
8/6/2013
N/A
167
6240
N/A
57300
N/A
234
N/A
82600
N/A
1390000
2070000
N/A
N/A
N/A
N/A
N/A
N/A
265
MS-ILF1-C1
Industrial LF
2/24/2014
N/A
156
10600
N/A
76900
N/A
83.8
N/A
127000
N/A
1450000
2080000
N/A
N/A
N/A
N/A
N/A
N/A
280
MS-ILF1-C1
Industrial LF
8/6/2014
N/A
273
2250
N/A
<40000
N/A
83.6
N/A
43700
N/A
925000
1340000
N/A
N/A
N/A
N/A
N/A
N/A
448
MS-ILF1-C2
Industrial LF
8/8/2011
N/A
<5
2505
N/A
7319
N/A
1.16
N/A
2498
N/A
8868
93000
N/A
N/A
N/A
N/A
N/A
N/A
<5
MS-ILF1-C2
Industrial LF
2/9/2012
N/A
118
5246
N/A
15710
N/A
25.1
N/A
30390
N/A
398100
683000
N/A
N/A
N/A
N/A
N/A
N/A
81.5
MS-ILF1-C2
Industrial LF
8/27/2012
N/A
263
6690
N/A
79400
N/A
229
N/A
97000
N/A
1410000
2310000
N/A
N/A
N/A
N/A
N/A
N/A
257
MS-ILF1-C2
Industrial LF
2/12/2013
N/A
298
6800
N/A
36600
N/A
164
N/A
49100
N/A
1190000
1660000
N/A
N/A
N/A
N/A
N/A
N/A
364
MS-ILF1-C2
Industrial LF
8/6/2013
N/A
305
12200
N/A
47400
N/A
247
N/A
66000
N/A
1440000
2100000
N/A
N/A
N/A
N/A
N/A
N/A
400
MS-ILF1-C2
Industrial LF
2/24/2014
N/A
163
12800
N/A
31700
N/A
66.9
N/A
76300
N/A
1020000
1380000
N/A
N/A
N/A
N/A
N/A
N/A
228
MS-ILF1-C2
Industrial LF
8/6/2014
N/A
410
2870
N/A
<40000
N/A
55.2
N/A
37000
N/A
1420000
2100000
N/A
N/A
N/A
N/A
N/A
N/A
627
Tables - Page 29

Table 7. Historical surface water analytical results (ash basin, FGD landfill, and industrial landfill
Notes:
1. Analytical parameter abbreviations:
Temp. = Temperature
DO = Dissolved oxygen
Cond. = Specific conductivity
ORP = Oxidation reduction potential
TDS = Total dissolved solids
TSS = Total suspended solids
TOC = Total organic carbon
2. Units:
°C = Degrees Celsius
SU = Standard Units
my = millivolts
NTU = Nephelometric Turbidity Unit
mg/L = milligrams per liter
pg/L = micrograms per liter
pmhos/cm = micromhos per centimeter
CaCO3 = calcium carbonate
HCO3 = bicarbonate
C032- = carbonate
3. N/A = Not applicable
4. NE = Not established
5. Highlighted values indicate values that exceed the 15A NCAC 2B Standard
6. Analytical results with "<" preceding the result indicates that the parameter
was not detected at a concentration which attains or exceeds the laboratory reporting limit.
Tables - Page 30

Table 8. Historical ash analytical results (ash basin)
Analytical Parameter pH % Solids
Units SU %
IHSB Protection of Groundwater PSRG
Site Name
FlyAsh_1700
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
IHSB Industrial Health -Based PSRG
Analytical Method
Sample Collection Date
9/24/2010
10/30/2006
11 /30/2006
1 /29/2007
2/28/2007
3/28/2007
1 /15/2009
2/12/2009
3/12/2009
4/9/2009
4/30/2009
5/12/2009
6/4/2009
7/6/2009
8/7/2009
9/3/2009
10/1 /2009
11 /5/2009
12/4/2009
1 /7/2010
2/4/2010
3/4/2010
4/1 /2010
5/6/2010
6/3/2010
7/9/2010
8/6/2010
9/2/2010
10/7/2010
11 /4/2010
12/7/2010
1 /5/2011
2/3/2011
3/2/2011
4/7/2011
5/5/2011
6/2/2011
7/7/2011
8/4/2011
9/1 /2011
10/6/2011
11 /4/2011
11 /30/2011
Field Mee
9
6.9
7.38
6.88
5.88
6.92
6.55
6.23
8.31
3.98
8.3
7
7.3
6.72
7.36
7.28
6.38
8.24
6.98
6.88
8.01
7.58
7.13
7.86
6.87
7.21
7.28
7.44
7.3
7.4
7.6
7.2
6.7
7.2
7.2
6.5
7.7
8.5
7.9
7.6
8.4
8.7
8.7
surement -
76.4
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
74
78
64
82.1
70.6
78.9
87.1
56.4
74.8
61
88.5
71.6
58.2
69.8
74.7
72.6
69.5
86.8
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
100000
0.9
58
5800
63
45
3
NE
3.8
0.9
700
150
270
NE
82
24
380000
400
40000
160
NE
5.6
60
8200
100000
800
200.8
200.8
200.7
200.7
200.8
200.7
200.7
200.8
200.7
200.7
200.8
N/A
N/A
42.1
244
N/A
77.3
<0.992
4350
25.4
N/A
33.4
N/A
17.4
N/A
N/A
0.74
58
N/A
2.6
0.022
740
3.3
N/A
6.2
N/A
0.58
N/A
N/A
2
67
N/A
5.3
0.1
210
1.9
N/A
3.8
N/A
0.42
N/A
N/A
1.3
100
N/A
<120
0.087
400
3.1
N/A
5.8
N/A
0.75
N/A
N/A
1.1
69
N/A
<110
0.12
410
3.2
N/A
6.6
N/A
0.68
N/A
N/A
1.4
110
N/A
4.4
0.043
290
2.9
N/A
6.6
N/A
0.67
N/A
N/A
2.9
1070
N/A
101
0.06
12440
354
N/A
98
N/A
14
N/A
N/A
<0.53
22
N/A
<27
<0.27
560
2.3
N/A
6
N/A
0.34
N/A
N/A
<0.58
37
N/A
<29
<0.29
680
2.2
N/A
5.2
N/A
<0.29
N/A
N/A
42
310
N/A
76
<0.76
3700
52
N/A
47
N/A
28
N/A
N/A
<5.62
17.9
N/A
<5.62
<1.69
436
<2.25
N/A
3.59
N/A
<5.06
N/A
N/A
<6.02
26.3
N/A
<6.02
<1.81
620
2.43
N/A
5.11
N/A
<5.42
N/A
N/A
<1.2
24.1
N/A
<12
<1.2
587
3.39
N/A
4.28
N/A
<1.2
N/A
N/A
<1.33
14.7
N/A
3.45
0.041
502
1.77
N/A
3.33
N/A
<2
N/A
N/A
<6.67
40.2
N/A
8.53
<2
667
2.93
N/A
4.6
N/A
<6
N/A
N/A
<1.33
30.1
N/A
5.75
<0.333
873
3.58
N/A
6.43
N/A
<2
N/A
N/A
<1.3
18.7
N/A
4.67
<0.333
360
1.33
N/A
4.6
N/A
100
N/A
N/A
<1.33
18.2
N/A
7.53
0.653
1230
5.53
N/A
6.87
N/A
<2
N/A
N/A
2.87
13.7
N/A
4.8
0.693
553
3.7
N/A
9.47
N/A
37.3
N/A
N/A
<1.33
12.1
N/A
<3.33
<0.333
253
1.01
N/A
3
N/A
<2
N/A
N/A
<1.33
19.9
N/A
5.67
0.065
1140
3.07
N/A
6.93
N/A
<2
N/A
N/A
<1.33
15.3
N/A
6
<0.333
807
1.87
N/A
4.47
N/A
<2
N/A
N/A
<1.33
4.33
N/A
3.47
<0.333
262
1.07
N/A
3.33
N/A
7
N/A
N/A
<1.33
11.3
N/A
4.97
<0.333
471
1.17
N/A
2.91
N/A
<2
N/A
N/A
<1.33
9.93
N/A
4.47
<0.333
344
1.17
N/A
3.25
N/A
<2
N/A
N/A
<1.33
37.9
N/A
3.38
<0.333
371
1.13
N/A
4.27
N/A
<2
N/A
N/A
<1.33
15.5
N/A
4.52
<0.333
504
1.36
N/A
3.15
N/A
<2
N/A
N/A
<1.33
62.4
N/A
7.33
0.641
987
1.92
N/A
10
N/A
<2
N/A
N/A
<1.21
21.6
N/A
<12.1
<1.21
398
2.85
N/A
5.82
N/A
<1.21
N/A
N/A
<1.33333
13.3
N/A
3.71
<0.333333
409
0.984
N/A
3.94
N/A
<2
N/A
N/A
<1.33
35.4
N/A
8.04
0.442
967
3.33
N/A
12.5
N/A
<2
N/A
N/A
<1.3
4.6
N/A
<3.3
<0.33
239
0.94
N/A
3.21
N/A
<2
N/A
N/A
<1.3
10.5
N/A
<3.3
<0.33
327
1.01
N/A
2.56
N/A
<2
N/A
N/A
<1
6.77
N/A
<3
<0.3
141
0.679
N/A
1.12
N/A
<2
N/A
N/A
<1.33
12.4
N/A
<3.33
<0.333
94
0.608
N/A
2.52
N/A
<2
N/A
N/A
<1.33
18.6
N/A
<3.33
<0.333
333
3.53
N/A
4.05
N/A
<2
N/A
N/A
<1.3
12.8
N/A
<3.3
<0.33
324
1.83
N/A
2.56
N/A
<2
N/A
N/A
<1.3
26.2
N/A
<3.3
<0.33
577
1.89
N/A
3.54
N/A
<2
N/A
N/A
11.8
23.1
N/A
<3.3
<0.33
581
3.82
N/A
8.28
N/A
9.65
N/A
N/A
<1.3
22.5
N/A
<3.3
<0.33
411
2.57
N/A
4.64
N/A
<2
N/A
N/A
<13.3
18.5
N/A
<33.3
<3.33
549
<3.33
N/A
4.77
4280
<20
N/A
N/A
1.83
47.9
N/A
8.67
0.378
1930
5.01
N/A
7.53
N/A
<2
N/A
N/A
<1.3
17.5
N/A
5.43
<0.33
1030
2.71
N/A
4.82
N/A
<2
Tables - Page 31

Table 8. Historical ash analytical results (ash basin)
Analytical Parameter pH
% Solids Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Units SU
% mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
IHSB Protection of Groundwater PSRG
100000
0.9
58
5800
63
45
3
NE
3.8
0.9
700
150
270
IHSB Industrial Health -Based PSRG
NE
82
24
380000
400
40000
160
NE
5.6
60
8200
100000
800
Site Name
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Analytical
Sample Collection Date
1 /4/2012
2/3/2012
3/1 /2012
4/5/2012
5/3/2012
6/7/2012
7/5/2012
8/3/2012
9111 /2012
10/4/2012
11/112012
12/11/2012
1 /4/2013
2/13/2013
3/8/2013
4/8/2013
5/9/2013
6/5/2013
7/17/2013
8/12/2013
9/9/2013
Field Measurement
8.5
83.4
N/A
200.8
N/A
200.8
<1.33
200.7
14.8
N/A
200.7
200.8
<0.333
200.7
200.7
2.2
200.8
200.7
200.7
200.8
<3.33
616
N/A
3.47
N/A
<2
7.5
86.3
N/A
N/A
<1.33
16.3
N/A
6.96
<0.333
784
3.58
N/A
3.91
N/A
<2
7.3
N/A
N/A
N/A
<1.33
43.2
N/A
<3.33
0.697
415
2.09
N/A
11.9
N/A
<2
6.6
85
N/A
N/A
<13.3
49.7
N/A
<33.3
<3.33
656
3.37
N/A
5.29
N/A
<20
7.2
81.8
N/A
N/A
<1.33
40.9
N/A
3.76
<0.333
887
3.08
N/A
5.22
N/A
<2
7
N/A
N/A
N/A
1.8
27.7
N/A
8.36
0.551
719
6.77
N/A
6.64
N/A
<2
10.8
N/A
N/A
N/A
<13.3
35.5
N/A
<33.3
<3.33
888
3.8
N/A
5.83
N/A
<20
7.2
N/A
N/A
N/A
<6.67
24.5
N/A
<16.7
<1.67
566
2.52
N/A
8.46
N/A
<10
6.2
N/A
N/A
N/A
2.18
43.3
N/A
6.92
0.59
1550
5.43
N/A
7
N/A
<2
7.4
N/A
N/A
N/A
<13.3
29
N/A
<33.3
<3.33
1180
3.8
N/A
4.66
N/A
<20
8.2
N/A
N/A
N/A
<6.66667
25.3
N/A
<16.6667
<1.66667
1000
3.88
N/A
4.1
N/A
<10
6.8
N/A
N/A
N/A
<13.3
35.1
N/A
<33.3
<3.33
627
<3.33
N/A
<3.33
N/A
<20
7.3
N/A
N/A
N/A
<13.3
43.1
N/A
<33.3
<3.33
808
<3.33
N/A
<3.33
N/A
<20
7
N/A
N/A
N/A
18.1
81
N/A
<33.3
<3.33
973
11.9
N/A
17.8
N/A
<20
9.8
N/A
N/A
N/A
<13.3
45.2
N/A
<33.3
<3.33
623
3.38
N/A
13.8
N/A
<20
5.3
N/A
N/A
N/A
<13.3333
53.9
N/A
<33.3333
<3.33333
774
4.83
N/A
11.4
N/A
<20
2.8
N/A
N/A
N/A
<13.3
159
N/A
<33.3
<3.33
848
19.7
N/A
15.3
N/A
<20
6.1
N/A
N/A
N/A
<13.3333
74.7
N/A
<33.3333
<3.33333
2820
7.29
N/A
6.96
N/A
<20
6
N/A
N/A
N/A
<13.3333
75.5
N/A
<33.3333
<3.33333
2330
11.6
N/A
10.1
N/A
<20
6.9
N/A
N/A
N/A
<13.3333
121
N/A
<33.3333
<3.33333
2330
14.1
N/A
14.8
N/A
<20
7.25
N/A
N/A
N/A
16.9
138
N/A
<33.3333
<3.33333
767
11.3
N/A
20.1
N/A
<20
Tables - Page 32

Table 8. Historical ash analytical results (ash basin)
Analytical Parameter
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Phosphorus
Potassium
Selenium
Silver
Sodium
Strontium
Thallium
Zinc
Units
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
IHSB Protection of Groundwater PSRG
NE
65
1
NE
130
NE
NE
2.1
3.4
NE
NE
0.28
1200
IHSB Industrial Health -Based PSRG
NE
4600
3.1
1000
4000
4
NE
1000
1000
NE
100000
2
62000
Analytical Method
200.7
200.8
245.1
200.8
200.7
200.7
200.8
200.7
200.8
200.7
Site Name
Sample Collection Date
FlyAsh_1700
9/24/2010
692
29.2
0.52
8.89
31.2
379
1520
18.9
<0.992
325
N/A
N/A
33.4
Reuse Comp (M)
10/30/2006
150
23
0.009
N/A
5.1
40
260
N/A
0.034
44
N/A
N/A
3
Reuse Comp (M)
11/30/2006
68
12
0.009
N/A
3.2
25
120
N/A
<0.28
20
N/A
N/A
1.8
Reuse Comp (M)
1/29/2007
130
16
<0.032
N/A
6.4
41
270
N/A
<1.2
49
N/A
N/A
4.4
Reuse Comp (M)
2/28/2007
120
13
<0.03
N/A
7.2
4.6
210
N/A
<1.1
45
N/A
N/A
4.3
Reuse Comp (M)
3/28/2007
110
9.3
<0.031
N/A
4.1
36
230
0.65
<0.39
40
N/A
N/A
2.6
Reuse Comp (M)
1/15/2009
5070
210
<0.01
N/A
221
802
16420
0.3
0.14
2330
N/A
N/A
42
Reuse Comp (M)
2/12/2009
87
9.6
<0.022
N/A
5.2
17
140
1.4
<0.27
37
N/A
N/A
2.7
Reuse Comp (M)
3/12/2009
92
11
<0.024
N/A
5.3
52
130
1.1
<0.29
34
N/A
N/A
<2.9
Reuse Comp (M)
4/9/2009
950
39
0.11
N/A
29
400
2500
15
<0.76
370
N/A
N/A
58
Reuse Comp (M)
4/30/2009
75.3
6.35
<0.022
0.423
4.89
40.6
100
<0.15
<0.424
53.5
N/A
N/A
3.98
Reuse Comp (M)
5/12/2009
92.8
13.1
0.099
0.803
5.48
74.1
72.9
0.209
<0.301
27.2
N/A
N/A
3.15
Reuse Comp (M)
6/4/2009
140
10.4
<0.12
<3.61
9.69
41
140
<2.4
<1.2
<240
N/A
N/A
<12
Reuse Comp (M)
7/6/2009
79.3
26.4
<0.122
<0.667
3.73
56.2
66.3
<0.667
<0.333
32.9
N/A
N/A
1.89
Reuse Comp (M)
8/7/2009
98
14.9
<0.143
<0.667
4.2
61.4
92.3
<0.667
<0.333
39.3
N/A
N/A
2.53
Reuse Comp (M)
9/3/2009
109
19.3
<0.122
2.22
5.24
63.3
98.6
<2
<0.333
39.1
N/A
N/A
2.92
Reuse Comp (M)
10/1/2009
63
5.27
<0.112
1.33
3.07
30.7
72.7
<2
<0.333
33.5
N/A
N/A
1.93
Reuse Comp (M)
11/5/2009
139
27.8
0.175
1.62
6.2
95.3
106
<2
<0.333
51.7
N/A
N/A
3.67
Reuse Comp (M)
12/4/2009
83.3
17.9
<0.119
2.95
6.44
32.9
101
2.93
<0.333
36.6
N/A
N/A
8.27
Reuse Comp (M)
1/7/2010
48.2
7.93
<0.126
1.69
3.45
14.1
49.6
<2
<0.333
28.3
N/A
N/A
1.47
Reuse Comp (M)
2/4/2010
109
15.6
<0.114
0.853
8.02
88.7
92
<2
<0.333
41.7
N/A
N/A
2.87
Reuse Comp (M)
3/4/2010
94
6
<0.134
0.4
4
72.3
97.3
<2
<0.333
44.7
N/A
N/A
2.33
Reuse Comp (M)
4/1/2010
33.4
3.6
<0.131
0.8
<0.333
19.3
36
<2
<0.333
21.4
N/A
N/A
0.867
Reuse Comp (M)
5/6/2010
75.3
4.68
<0.117
0.673
3.57
37.1
61.5
<2
<0.333
33.067
N/A
N/A
1.67
Reuse Comp (M)
6/3/2010
56.8
5.87
<0.117
1.17
4.29
16.2
74.7
<2
<0.333
39.9
N/A
N/A
1.81
Reuse Comp (M)
7/9/2010
48.8
3.38
<0.117
<0.333
7.33
33.1
49.3
<2
<0.333
29.7
N/A
N/A
1.69
Reuse Comp (M)
8/6/2010
58.7
11.4
<0.134
1.27
3.25
42.5
52.6
<2
<0.333
35.9
N/A
N/A
1.45
Reuse Comp (M)
9/2/2010
129
22.7
<0.161
1.01
7.53
157
142
<2
<0.333
52.7
N/A
N/A
2.6
Reuse Comp (M)
10/7/2010
141
7.75
<0.12
<3.62
6.76
48.1
180
<2.41
<1.21
<241
N/A
N/A
<12.1
Reuse Comp (M)
11/4/2010
41.4
4.78
<0.14
0.589
3.32
42.3
41.1
<2
<0.333333
28.5
N/A
N/A
2.02
Reuse Comp (M)
12/7/2010
132
10.5
0.12
0.968
6.4
90.3
119
<2
<0.333
52.3
N/A
N/A
4.54
Reuse Comp (M)
1/5/2011
44.2
11
<0.11
<0.33
7.34
9.99
50.7
<2
<0.33
26.4
N/A
N/A
1.31
Reuse Comp (M)
2/3/2011
57
5.62
<0.17
0.468
2.83
26.2
52.9
<2
<0.33
26.9
N/A
N/A
1.33
Reuse Comp (M)
3/2/2011
25.5
2.14
<0.13
<0.3
1.52
10.1
22.3
<2
<0.3
16.6
N/A
N/A
0.764
Reuse Comp (M)
4/7/2011
36.2
1.73
<0.16
0.88
3.52
8.27
36.6
<2
<0.33
22.3
N/A
N/A
1.58
Reuse Comp (M)
5/5/2011
66.3
8.91
0.19
0.446
4.58
25.4
75.1
<2
<0.333
37.3
N/A
N/A
1.97
Reuse Comp (M)
6/2/2011
48.5
4.25
<0.13
0.525
3.76
21.1
51.7
<2
<0.33
25.3
N/A
N/A
1.12
Reuse Comp (M)
7/7/2011
74.9
7.24
<0.17
0.369
4.21
39.7
73.9
<2
<0.33
33
N/A
N/A
1.96
Reuse Comp (M)
8/4/2011
94.7
24.9
0.14
1.5
9.38
48.2
83.5
<2
<0.33
33.6
N/A
N/A
7.74
Reuse Comp (M)
9/1/2011
79.5
11.9
<0.13
0.713
4.45
31.2
88.9
<2
<0.33
30.1
N/A
N/A
1.8
Reuse Comp (M)
10/6/2011
93.3
10.7
<0.13
<0.05
3.67
407
74.3
<20
<3.33
34
N/A
N/A
<3.33
Reuse Comp (M)
11/4/2011
291
18.5
<0.14
0.643
6.16
95.3
254
<2
<0.33
71.7
N/A
N/A
3.94
Reuse Comp (M)
11/30/2011
138
12.9
<0.12
0.633
6.09
38.9
69.5
<2
<0.33
32.5
N/A
N/A
2.03
Tables - Page 33

Table 8. Historical ash analytical results (ash basin)
Analytical Parameter
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Phosphorus
Potassium
Selenium
Silver
Sodium
Strontium
Thallium
Zinc
Units
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
IHSB Protection of Groundwater PSRG
NE
65
1
NE
130
NE
NE
2.1
3.4
NE
NE
0.28
1200
IHSB Industrial Health -Based PSRG
NE
4600
3.1
1000
4000
4
NE
1000
1000
NE
100000
2
62000
Site Name
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Reuse Comp (M)
Analytical Method 200.7 200.8 24
Sample Collection Date
1 /4/2012
85.6
13.2
<0.12
2/3/2012
120
10.3
<0.11
3/1/2012
108
19.2
0.13
4/5/2012
142
14.2
<0.12
5/3/2012
144
8.5
<0.12
6/7/2012
161
13
<0.13
7/5/2012
177
12.8
<0.125
8/3/2012
107
7.71
<0.12
9/11/2012
240
17.2
<0.113
10/4/2012
178
12.2
<0.12
11/1/2012
160
10.3
<0.109
12/11/2012
98.1
6.69
<0.121
1 /4/2013
115
7.5
<0.114
2/13/2013
259
62.7
<0.123
3/8/2013
156
6.5
<0.116
4/8/2013
203
9.02
<0.115
5/9/2013
310
137
<0.126
6/5/2013
345
23.7
<0.138
7/17/2013
328
39.3
<0.112
8/12/2013
1020
97.9
<0.12
9/9/2013
316
56.2
<0.122
200.8 200.7 200.7 200.8 200.7 200.8
0.358
4.25
29.9
77.8
<2
<0.333
30.2
N/A
N/A
0.687
5.63
43.6
151
<2
<0.333
52.3
N/A
N/A
1.53
11.7
61.7
140
<2
<0.333
37.1
N/A
N/A
<3.33
6.31
1020
247
<20
<3.33
39
N/A
N/A
0.489
6.94
55.3
162
<2
<0.333
38
N/A
N/A
0.901
9.91
64.6
199
<2
<0.333
45.1
N/A
N/A
<3.33
9.79
1090
297
<20
<3.33
51.1
N/A
N/A
<1.67
5.49
42.4
124
<10
<1.67
27.7
N/A
N/A
0.823
10.1
101
299
<2
<0.333
84.3
N/A
N/A
<3.33
6.32
713
180
<20
<3.33
65
N/A
N/A
<1.66667
6
318
167
<10
<1.66667
45.8
N/A
N/A
<3.33
4.72
44.7
104
<20
<3.33
48
N/A
N/A
<3.33
3.9
586
105
<20
<3.33
<33.3
N/A
N/A
<3.33
16
1680
410
<20
<3.33
95
N/A
N/A
<3.33
9.02
91.3
349
<20
<3.33
97.1
N/A
N/A
<3.33333
11.7
107
425
<20
<3.33333
98.5
N/A
N/A
<3.33
13.7
1010
396
<20
<3.33
62.5
N/A
N/A
<3.33333
11.1
134
365
<20
<3.33333
109
N/A
N/A
<3.33333
15.8
158
409
<20
<3.33333
125
N/A
N/A
<3.33333
16
2460
1100
<20
<3.33333
134
N/A
N/A
<3.33333
13.4
116
626
<20
<3.33333
100
N/A
N/A
1.37
2.5
13.1
<3.33
2.47
5.24
4.61
2.01
3.67
<3.33
2.52
<3.33
<3.33
12
7.44
7.48
15.4
6.34
9.03
13.1
12.6
Tables - Page 34

Table 8. Historical ash analytical results (ash basin)
Notes:
1. Units:
SU = Standard Units
mg/kg = milligrams per kilogram
2. Screening levels obtained from Inactive Hazardous Sites Branch (IHSB) Preliminary Soil
Remediation Goals (PSRG) Table dated January 2014
3. N/A = Not applicable
4. NE = Not established
5. Standard is for hexavalent chromium (Cr VI); Results shown are for total chromium
6. Sample depth interval in parentheses
7. Highlighted cells indicate concentrations that exceed the Protection of Groundwater PSRG from 01/2014
8. Bold values indicate concentrations that exceed the Indutrial Health -Based PSRG from 01/2014
Tables - Page 35

Table 9 - Historical Ash Leachate Analytical Results (Ash Basin)
Analytical Parameter pH
Aluminum Antimony
Arsenic
Barium Beryllium
Boron
Cadmium
Calcium
Chloride Chromium
Cobalt
Copper Fluorine
Iron
Lead
Magnesium
Units SU
mg/L mg/L
mg/L
mg/L mg/L
mg/L
mg/L
mg/L
mg/L mg/L
mg/L
mg/L mg/L
mg/L
mg/L
mg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard 6.5 - 8.5
NE 0.001*
0.01
0.7 0.004*
0.7
0.002
NE
250 0.01
0.001*
1 2
0.3
0.015
NE
Analytical Method
200.8
200.8
200.7
200.7
200.8
200.7
200.7
200.8
200.7
200.7
200.8
200.7
Site Name Protocol Sample Collection Date
FlyAsh
SPLP
9/24/2010
N/A
N/A
0.022
0.198
0.155
N/A
1.79
<0.001
69.7
<1
0.013
N/A
<0.01
0.18
<0.05
<0.005
1.83
FlyAsh
TCLP
9/24/2010
9
N/A
N/A
<0.1
0.32
N/A
N/A
<0.01
N/A
N/A
<0.05
N/A
N/A
N/A
N/A
<0.05
N/A
Reuse Comp
SPLP
10/7/2010
N/A
N/A
<0.01
<0.01
<0.01
N/A
<0.5
<0.001
1.01
1.19
<0.005
N/A
<0.01
<0.1
<0.05
<0.005
<1
Reuse Comp
TCLP
10/7/2010
7.3
N/A
N/A
<0.1
<0.1
N/A
N/A
<0.01
N/A
N/A
<0.05
N/A
N/A
N/A
N/A
<0.05
N/A
Reuse Comp
TCLP
10/6/2011
8.4
N/A
N/A
<0.01
<0.01
N/A
N/A
<0.001
N/A
N/A
<0.005
N/A
N/A
N/A
N/A
0.037
N/A
Tables - Page 36

Table 9 - Historical Ash Leachate Analytical Results (Ash Basin)
Analytical Parameter
Manganese
Mercury
Molydenum
Nickel
Nitrate as N Phosphorus Potassium
Selenium Silver
Sodium Strontium Sulfate
Thallium
Zinc
Units
mg/L
mg/L
mg/L
mg/L
mg/L mg/L mg/L
mg/L mg/L
mg/L mg/L mg/L
mg/L
mg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard
0.05
0.001
NE
0.1
10 NE NE
0.02 20
NE NE 250
0.0002*
1
Analytical Method
200.8
245.1
200.8
200.7
200.7
200.8
200.7
200.8
200.7
Site Name Protocol Sample Collection Date
FlyAsh
SPLP
9/24/2010
<0.15
<0.001
N/A
<0.01
<0.1
N/A
7.33
0.451
<0.005
N/A
N/A
N/A
N/A
<0.05
FlyAsh
TCLP
9/24/2010
N/A
<0.01
N/A
N/A
N/A
N/A
N/A
0.291
<0.05
N/A
N/A
N/A
N/A
N/A
Reuse Comp
SPLP
10/7/2010
<0.15
<0.05
N/A
<0.001
<0.1
N/A
<0.01
<1
<0.01
N/A
N/A
N/A
N/A
<0.005
Reuse Comp
TCLP
10/7/2010
N/A
<0.01
N/A
N/A
N/A
N/A
N/A
<0.1
<0.05
N/A
N/A
N/A
N/A
N/A
Reuse Comp
TCLP
10/6/2011
N/A
<0.01
N/A
N/A
N/A
N/A
N/A
<0.01
<0.005
N/A
N/A
N/A
N/A
N/A
Tables - Page 37

Table 9 - Historical Ash Leachate Analytical Results (Ash Basin)
Notes:
1. TDS = Total dissolved solids
SPLP = Synthetic Precipitation Leaching Procedure
TCLP = Toxicity Characteristic Leaching Procedure
2. Units:
mg/L = milligrams per liter
pg/L = micrograms per liter
3. " IMAC (interim maximum allowable concentration)
4. Sample depth interval in parentheses
5. Highlighted values indicate values that exceed the 15A NCAC 2L Standard
6. Analytical results with "<" preceding the result indicates that the parameter
was not detected at a concentration which attains or exceeds the laboratory reporting limit
Tables - Page 38

Table 10 - Historical Landfill Leachate Analytical Results (Industrial Landfill)
Site Name
MS-ILFI-Cl
MS-ILF1-Cl
MS-ILF1-Cl
MS-ILFI-Cl
MS-ILF1-Cl
MS-ILF1-Cl
MS-ILFI-Cl
MS-ILF1-C2
MS-ILF1-C2
MS-ILF1-C2
MS-ILF1-C2
MS-ILFI-C2
MS-ILF1-C2
MS-ILF1-C2
Analytical Parameter Temp Cond. DO pH ORP Turbid
Units C Nmhos/cm ug/L SU mV NTU
oundwater Quality Standard NE NE NE 6.5 - 8.5 NE NE
Alkalinity Aluminum Antimony* Arsenic Barium Beryllium* Boron Cadmium Calcium Chloride Chromium Cobalt*
ig/L CaCO3 Ng/L pg/L pg/L pg/L pg/L pg/L pg/L pg/L pg/L pg/L Ng/L
NE NE 1 10 700 4 700 2 NE 250000 10 1
Analytical Method
2320B4d
200.8
200.8
200.7
200.7
200.8
200.7
200.7
200.8
Field Measurements
Sample Collection Date
8/8/2011
24.02
251.8
N/A
7.06
N/A
2.7
106700
N/A
N/A
<1
74.59
N/A
<50
<1
40520
2213
<5
N/A
2/9/2012
15.41
429
N/A
5.48
N/A
0.82
6072
N/A
N/A
4.1
103
N/A
224
<1
50830
6739
<5
N/A
8/27/2012
19.77
2138
N/A
4.57
N/A
0.95
6000
N/A
N/A
29.67
73.89
N/A
13100
<10
353000
13300
<5
N/A
2/12/2013
16.22
2016
6060
4.65
482
1.62
317
N/A
N/A
21.6
58.1
N/A
14200
<10
282000
10800
<5
N/A
8/6/2013
19.84
2174
3980
4.54
486
2.81
<100
N/A
N/A
40.3
59.1
N/A
18700
<10
334000
11300
<5
N/A
2/24/2014
18.07
2431
0
4.2
467
15.8
<100
N/A
N/A
98.3
70.4
N/A
26400
<10
254000
18600
<5
N/A
8/6/2014
17.29
1600
1710
4.36
466
2.02
<5000000
N/A
N/A
15.2
44.9
N/A
9810
<10
234000
6140
<5
N/A
8/8/2011
23.98
198.1
N/A
6.84
N/A
3.41
69560
N/A
N/A
<1
48.13
N/A
<50
<1
28340
3545
<5
N/A
2/9/2012
15.5
872
N/A
4.27
N/A
1.98
1645
N/A
N/A
28.8
91.6
N/A
5971
<1
87690
11580
<5
N/A
8/27/2012
19.83
2361
N/A
4.45
N/A
0.96
4850
N/A
N/A
39.25
63.95
N/A
21900
<10
324000
17900
<5
N/A
2/12/2013
15.41
1943
7310
4.37
490
1.48
<100
N/A
N/A
27.9
49.5
N/A
9590
<10
249000
11800
<5
N/A
8/6/2013
19.48
2254
4940
4.27
493
2.59
<100
N/A
N/A
40.6
66.9
N/A
16100
<10
332000
12800
<5
N/A
2/24/2014
17.85
1686
6380
4.18
463
1.61
<100
N/A
N/A
83.2
74.4
N/A
15900
<10
170000
17800
<5
N/A
8/6/2014
17.2
2177
4500
3.94
494
2.07
<5000000
N/A
N/A
23.8
46.4
N/A
8360
<10
360000
9330
<5
N/A
Tables - Page 39

Table 10 - Historical Landfill Leachate Analytical Results (Industrial Landfill)
Analytical Parameter
Copper
Fluoride
Iron
Lead
Manganese
Mercury
Nickel
Nitrate an N
Selenium
Silver
Units
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard
1000
2000
300
15
50
1
100
10000
20
20
Analytical Method
200.7
200.7
200.8
200.8
245.1
200.7
200.8
Site Name
Sample Collection Date
MS-ILFI-Cl
8/8/2011
<5
117
<10
<1
8.97
<0.05
_
<5
1277
<1
<5
MS-ILF1-C1
2/9/2012
<5
503
<10
<1
2206
<0.05
58.4
2013
5.31
<5
MS-ILF1-C1
8/27/2012
27.19
1950
42.73
<10
14400
<0.05
344
5020
170
<5
MS-ILF1-C1
2/12/2013
64
1610
30.1
<10
13400
<0.05
216
6210
144
<5
MS-ILF1-C1
8/6/2013
32.7
2080
39.2
<10
14500
<0.05
167
6240
234
<5
MS-ILF1-C1
2/24/2014
5.25
2140
30.3
<10
24000
<0.05
156
10600
83.8
<5
MS-ILF1-C1
8/6/2014
44.3
2210
31.1
<10
6880
<0.05
273
2250
83.6
<5
MS-ILF1-C2
8/8/2011
<5
100
16.18
<1
<5
<0.05
<5
2505
1.16
<5
MS-ILF1-C2
2/9/2012
25.7
736
<10
<1
3487
<0.05
118
5246
25.1
<5
MS-ILF1-C2
8/27/2012
25.47
2080
16.51
<10
13800
<0.05
263
6690
229
<5
MS-ILF1-C2
2/12/2013
66
1750
40
<10
12400
<0.05
298
6800
164
<5
MS-ILF1-C2
8/6/2013
116
1880
102
<10
10900
<0.05
305
12200
247
<5
MS-ILF1-C2
2/24/2014
14.4
1810
21.1
<10
14700
<0.05
163
12800
66.9
<5
MS-ILF1-C2
8/6/2014
148
1990
86.6
<10
7810
<0.05
410
2870
55.2
<5
Sulfate Thallium* TDS Zinc
pg/L pg/L pg/L pg/L
250000 0.2 500000 1000
200.8 22.7
6983
N/A
130000
<5
181500
N/A
314000
8.96
1290000
N/A
2120000
407
1190000
N/A
1820000
392
1390000
N/A
2070000
265
1450000
N/A
2080000
280
925000
N/A
1340000
448
8868
N/A
93000
<5
398100
N/A
683000
81.5
1410000
N/A
2310000
257
1190000
N/A
1660000
364
1440000
N/A
2100000
400
1020000
N/A
1380000
228
1420000
N/A
2100000
627
Tables - Page 40

Table 10 - Historical Landfill Leachate Analytical Results (Industrial Landfill)
Notes:
1. TDS = Total dissolved solids
DO = Dissolved oxygen
Cond. = Specific conductivity
ORP = Oxidation reduction potential
TDS = Total dissolved solids
TSS = Total suspended solids
TOC = Total organic carbon
2. Units:
'C = Degrees Celsius
SU = Standard Units
my = millivolts
NTU = Nephelometric Turbidity Unit
pmhos/cm = micromhos per centimeter
mg/L = milligrams per liter
pg/L = micrograms per liter
3. ' IMAC (interim maximum allowable concentration)
4. Highlighted values indicate values that exceed the 15A NCAC 2L Standard
5. Analytical results with "<" preceding the result indicates that the parameter
was not detected at a concentration which attains or exceeds the laboratory reporting limit
Tables - Page 41

Table 11 - Historical Landfill Leachate Analytical Results (FGD Landfill)
Analytical Parameter Temp.
DO Cond. pH ORP Turbidity Alkalinity Aluminum
Antimony*
Arsenic
Barium Beryllium*
Boron
Cadmium
Calcium
Units C
mg/L umhos/cm SU my NTU mg/L CaCO3 pg/L
pg/L
pg/L
pg/L pg/L
pg/L
pg/L
pg/L
15A NCAC 02L .0202(g) Groundwater Quality Standard NA
NA NA 6.5 - 8.5 NA NA NE NE
1
10
700 4
700
2
NE
Analytical Method
2320B4d
200.8
200.8
200.7
200.7
200.8
200.7
Well Name Sample Collection Date
Field Measurements
Total Total Dissolved Total Dissolved Total Dissolved Total Total Dissolved Total Dissolved Total Dissolved Total
MSFGDLF-C-1
3/13/2012
21.72
N/A
5417
3.28
N/A
21.1
<100
N/A
N/A
N/A
5.78
6.67
23
23
N/A
24900
24900
<2
<2
660000
661000
MSFGDLF-C-1
9/17/2012
18.81
N/A
4969
5.56
N/A
10.6
46900
N/A
N/A
N/A
N/A
<1
N/A
29.1
N/A
N/A
27100
N/A
<1
N/A
725000
MSFGDLF-C-1
3/18/2013
14.25
5690
4326
4.64
404
35.4
1350
N/A
N/A
N/A
N/A
<10
N/A
24
N/A
N/A
21800
N/A
<10
N/A
572000
MSFGDLF-C-1
3/31/2014
14.76
6050
3189
4.32
492
6.52
<20000
N/A
N/A
N/A
N/A
<10
N/A
30.6
N/A
N/A
12000
N/A
<10
N/A
479000
MSFGDLF-C-1
9/24/2014
16.2
8720
4901
3.16
567
30.5
<5000
N/A
N/A
N/A
N/A
<10
N/A
22.8
N/A
N/A
22000
N/A
<10
N/A
660000
Tables - Page 42

Table 11 - Historical Landfill Leachate Analytical Results (FGD Landfill)
Analytical Parameter
Chloride
Chromium
Cobalt*
Copper Fluoride
Iron
Lead
Magnesium
Manganese
Mercury
Molydenum
Units
Ng/L
Ng/L
Ng/L
Ng/L Ng/L
Ng/L
Ng/L
Ng/L
Ng/L
N9
N9
15A NCAC 02L .0202(g) Groundwater Quality Standard
250000
10
1
1000 2000
300
15
NE
50
1
NE
Analytical Method
300
200.7
200.8
200.7
200.7
200.8
200.7
200.8
245.1
200.8
Well Name Sample Collection Date Total Dissolved Total Dissolved Total Dissolved Total Total Dissolved Total Dissolved Total Dissolved Total Dissolved Total Dissolved Total Dissolved Total
MSFGDLF-C-1
3/13/2012
780000
16.7
18.2
N/A
N/A
61
60
2900
284000
269000
<2
<2
260000
261000
8160
8330
N/A
<0.05
N/A
N/A
MSFGDLF-C-1
9/17/2012
737000
N/A
<1
N/A
N/A
N/A
<5
<5000
N/A
331000
N/A
<1
N/A
261000
N/A
4490
N/A
<0.05
N/A
N/A
MSFGDLF-C-1
3/18/2013
574000
N/A
<10
N/A
N/A
N/A
26.6
5300
N/A
273000
N/A
19.1
N/A
209000
N/A
5880
N/A
<0.05
N/A
N/A
MSFGDLF-C-1
3/31/2014
294000
N/A
<10
N/A
N/A
N/A
10
3430
N/A
150000
N/A
<10
N/A
155000
N/A
4550
N/A
<0.05
N/A
N/A
MSFGDLF-C-1
9/24/2014
526000
N/A
<10
N/A
N/A
N/A
<5
4780
N/A
331000
N/A
<10
N/A
260000
N/A
7450
N/A
<0.05
N/A
N/A
Tables - Page 43

Table 11 - Historical Landfill Leachate Analytical Results (FGD Landfill)
Analytical Parameter
Nickel
Nitrate as N
Potassium
Selenium Silver
Sodium
Sulfate
TDS
Thallium*
TOC
TOX TSS
Zinc
Units
Ng/L
Ng-N/L
Ng/L
Ng/L Ng/L
Ng/L
Ng/L
Ng/L
ug/L
Ng/L
N9/L N9/L
N9
15A NCAC 02L .0202(g) Groundwater Quality Standard
100
10000
NE
20 20
NE
250000
500000
0.2
NE
NE NE
1000
Analytical Method
200.7
300.0
200.7
200.8
200.7
300.0
2540C
200.8
5310E
2450D
200.7
Well Name Sample Collection Date Dissolved Total Total Dissolved Total Dissolved Total Dissolved Total Dissolved Total Total Total Dissolved Total Total Total Total Dissolved Total
MSFGDLF-C-1
3/13/2012
272
277
4900
18900
19300
163
169
<5
<5
14500
14700
2500000
4680000
N/A
N/A
N/A
N/A
N/A
534
554
MSFGDLF-C-1
9/17/2012
N/A
122
5420
N/A
25800
N/A
223
N/A
<5
N/A
14400
2260000
4700000
N/A
N/A
N/A
N/A
N/A
N/A
167
MSFGDLF-C-1
3/18/2013
N/A
156
4480
N/A
20400
N/A
272
N/A
<5
N/A
14500
2210000
4250000
N/A
N/A
N/A
N/A
N/A
N/A
278
MSFGDLF-C-1
3/31/2014
N/A
133
1480
N/A
15000
N/A
178
N/A
<5
N/A
11700
1820000
3200000
N/A
N/A
N/A
N/A
N/A
N/A
258
MSFGDLF-C-1
9/24/2014
N/A
177
2010
N/A
24200
N/A
210
N/A
<5
N/A
19400
2900000
5120000
N/A
N/A
N/A
N/A
N/A
N/A
379
Tables - Page 44

Table 11- Historical Landfill Leachate Analytical Results (FGD Landfill)
Notes:
1. TDS = Total dissolved solids
DO = Dissolved oxygen
Cond. = Specific conductivity
ORP = Oxidation reduction potential
TDS = Total dissolved solids
TSS = Total suspended solids
TOC = Total organic carbon
2. Units:
'C = Degrees Celsius
SU = Standard Units
my = millivolts
NTU = Nephelometric Turbidity Unit
pmhos/cm = micromhos per centimeter
mg/L = milligrams per liter
pg/L = micrograms per liter
3. ' IMAC (interim maximum allowable concentration)
4. Highlighted values indicate values that exceed the 15A NCAC 2L Standard
5. Analytical results with "<" preceding the result indicates that the parameter
was not detected at a concentration which attains or exceeds the laboratory reporting limit
Tables - Page 45

Table 12 - August 2014 Seep Sample Analytical Results
Analytical Parameter Temp.
Cond.
pH
Aluminum
Antimony
Arsenic
Barium
Boron
Cadmium
Calcium
COD
Chloride
Chromium
Copper
Flow
Fluoride
Units T
pmhos/cm
SU
mg/L
Ng/L
Ng/L
mg/L
mg/L
pg/L
mg/L
mg/L
mg/L
pg/L
pg/L
MGD
mg/L
15A NCAC 02B .0200 Surface Water Quality Standard NE
NE
6.0 - 9.0
0.087
5.6
10
1
NE
2
NE
NE
NE
50
7
N/A
2
Site Name
EPA 200.7
EPA 200.8
EPA 200.8
EPA 200.7
EPA 200.7
EPA 200.8
EPA 200.7
HACH 8000
EPA 300.0
EPA 200.8
EPA 200.8
N/A
EPA 300.0
S-1 21.5
2700
6.55
0.278
<1
<1
0.098
<3.99
<1
63.3
<20
5.1
<1.47
1
0.0019 <0.5
S-2 N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
S-3 N/A
N/A
N/A
N/A
N/A
<1
N/A
N/A
<1
N/A
N/A
N/A
<1
2.46
N/A
N/A
S-4
N/A I N/A I N/A I N/A I N/A I <1 I N/A I N/A I <1
N/A I N/A I N/A I <1 1 5.06 1 N/A I N/A
Tables - Page 46

Table 12 - August 2014 Seep Sample Analytical Results
Analytical Parameter Hardness
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Oil and Grease
Selenium
Sulfate
TDS
Thallium
TSS
Zinc
Units mg/L (CaCO3)
mg/L
Ng/L
mg/L
mg/L
Ng/L
Ng/L
Ng/L
mg/L
Ng/L
mg/L
mg/L
Ng/L
mg/L
mg/L
15A NCAC 02B .0200 Surface Water Quality Standard 100
1
25
NE
0.2
0.012
160
25
see note 3
5
250
500
0.24
NE
50
Site Name EPA 200.7
EPA 200.7 EPA 200.8
EPA 200.7
EPA 200.7
EPA 245.1
EPA 200.8
EPA 200.8
EPA 1664B
EPA 200.8
EPA 300.0
SM2540C
EPA 200.8
SM2540D
EPA 200.7
S-1 291
4.41
<1
32.3
0.936
<0.05
<1
<1.93
<5
<4.58
290
530
<0.2
18
<0.005
S-2 N/A
N/A
N/A
N/A
1 I
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1
N/A
N/A
1
N/A
N/A
I
S-3 N/A
N/A
<1
N/A
N/A
<0.05
N/A
N/A
N/A
<1
N/A
40
N/A
N/A
<1
S-4
N/A I N/A I <1 1 N/A I N/A 1 <0.05 1 N/A
N/A I N/A I <1 1 N/A 1 60 1 N/A I N/A 1 2.23
Tables - Page 47

Table 12 - August 2014 Seep Sample Analytical Results
Notes:
1. Analytical parameter abbreviations:
Temp. = Temperature
Cond. = Specific conductivity
TDS = Total dissolved solids
TSS = Total suspended solids
2. Units:
°C = Degrees Celsius
SU = Standard Units
pmhos/cm = micromhos per centimeter
mg/L = milligrams per liter
pg/L = micrograms per liter
CaCO3 = calcium carbonate
3. Take the lowest LC50 available for the particular type of OG you have (or similar OG)
and multiply it by a safety factor of 0.01 to obtain the criteria
4. N/A = Not applicable
5. NE = Not established
6. Flow measurements at S1 was collected on September 4, 2014
7. Lake Norman Samples were collect on August 5, 2013
8. Seep S2 was not sampled due to absence of flow during this monitoring event
9. Highlighted values indicate values that exceed the 15A NCAC 2B Standard
10. Analytical results with "<" preceding the result indicates that the parameter
was not detected at a concentration which attains or exceeds the laboratory reporting limit
Tables - Page 48

A:4i'A&A
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
August 13, 2014
CERTIFIED MAIL 7004 2510 0000 3651 1168
RETURN RECEIPT REQUESTED
Paul Newton
Duke Energy
526 South Church Street
Charlotte, NC 28202
Subject: Notice of Regulatory Requirements
Title 15A North Carolina Administrative Code (NCAC) 02L .0106
14 Coal Ash Facilities in North Carolina
Dear Mr. Newton:
Chapter 143, North Carolina General Statutes, authorizes and directs the Environmental
Management Commission of the Department of Environment and Natural Resources to protect
and preserve the water and air resources of the State. The Division of Water Resources (DWR)
has the delegated authority to enforce adopted pollution control rules.
Rule 15A NCAC 02L .0103(d) states that no person shall conduct or cause to be conducted any
activity which causes the concentration of any substance to exceed that specified in 15A NCAC
02L .0202. As of the date of this letter, exceedances of the groundwater quality standards at 15A
NCAC 02L .0200 Classifications and Water Quality Standards Applicable to the Groundwaters
of North Carolina have been reported at each of the subject coal ash facilities owned and
operated by Duke Energy (herein referred to as Duke).
Groundwater Assessment Plans
No later than September, 26 2014 Duke Energy shall submit to the Division of Water Resources
plans establishing proposed site assessment activities and schedules for the implementation,
completion, and submission of a comprehensive site assessment (CSA) report for each of the
following facilities in accordance with 15A NCAC 02L .0106(g):
Asheville Steam Electric Generating Plant
Belews Creek Steam Station
Buck Steam Station
Cape Fear Steam Electric Generating Plant
Cliffside Steam Station
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Phone: [phone] Internet: www.ncdenr.gov
An Equal Opportunity 1 Affirmative Action Employer — Made in part by recycled paper
A-1

Mr. Paul Newton
August 12, 2014
Page 2 of 3
Dan River Combined Cycle Station
H.F. Lee Steam Electric Plant
Marshall Steam Station
Mayo Steam Electric Generating Plant
Plant Allen Steam Station
Riverbend Steam Station
Roxboro Steam Electric Generating Plant
L.V. Sutton Electric Plant
Weatherspoon Steam Electric Plant
The site assessment plans shall include a description of the activities proposed to be completed
by Duke that are necessary to meet the requirements of 15A NCAC 02L .0106(g) and to provide
information concerning the following:
(1) the source and cause of contamination;
(2) any imminent hazards to public health and safety and actions taken to mitigate
them in accordance to 15A NCAC 02L .0106(f);
(3) all receptors- and significant exposure pathways;
(4) the horizontal and vertical extent of soil and groundwater contamination and all
significant factors affecting contaminant transport; and
(5) geological and hydrogeological features influencing the movement, chemical, and
physical character of the contaminants.
For your convenience, we have attached guidelines detailing the information necessary for the
preparation of a CSA report. The DWR will review the plans and provide Duke with review
comments, either approving the plans or noting any deficiencies to be corrected, and a date by
which a corrected plan is to be submitted for further review and comment or approval. For those
facilities for which Duke has already submitted groundwater assessment plans, please update
your submittals to ensure they meet the requirements stated in this letter and referenced
attachments and submit them with the others.
Receptor Survey
No later than October 14'', 2104 as authorized pursuant to 15A NCAC 02L .0106(g), the DWR is
requesting that Duke perform a receptor survey at each of the subject facilities and submitted to
the DWR. The receptor survey is required by 15A NCAC 02L .0106(g) and shall include
identification of all receptors within a radius of 2,640 feet (one-half mile) from the established
compliance boundary identified in the respective National Pollutant Discharge Elimination
System (NPDES) permits. Receptors shall include, but shall not be limited to, public and private
water supply wells (including irrigation wells and unused or abandoned wells) and surface water
features within one-half mile of the facility compliance boundary. For those facilities for which
Duke has already submitted a receptor survey, please update your submittals to ensure they meet
the requirements stated in this letter and referenced attachments and submit them with the others.
If they do not meet these requirements, you must modify and resubmit the plans.
A-2

Mr. Paul Newton
August 12, 2014
Page 3 of 3
The results of the receptor survey shall be presented on a sufficiently scaled map. The map shall
show the coal ash facility location, the facility property boundary, the waste and compliance
boundaries, and all monitoring wells listed in the respective NPDES permits. Any identified
water supply wells shall be located on the map and shall have the well owner's name and
location address listed on a separate table that can be matched to its location on the map.
Failure to comply with the State's rules in the manner and time specified may result in the
assessment of civil penalties and/or the use of other enforcement mechanisms available to the
State.
We appreciate your attention and prompt response in this matter. If you have any questions,
please feel free to contact S. Jay Zimmerman, Water Quality Regional Operations Section Chief,
at [phone].
Sincerely,
hn E. Skvarla, III
Attachment enclosed
cc: Thomas A. Reeder, Director, Division of Water Resources
Regional Offices — WQROS
File Copy
A-3

August 12, 2014
GUIDELINES FOR COMPREHENSIVE SITE ASSESSMENT
This document provides guidelines for those involved in the investigation of
contaminated soil and/or groundwater, where the source of contamination is from:
■ Incidents caused by activities subject to permitting under G.S. 143-215.1
■ Incidents caused by activities subject to permitting under G.S. 87-88
■ Incidents arising from agricultural operations, including application of
agricultural chemicals, but not including unlawful discharges, spills or
disposal of such chemicals
Comprehensive Site Assessment (CSA)
NOTE: Regional Offices may request additional information in support of the CSA to aid
in their review and will not approve the CSA if any of the elements specified below have
not been included or have not been sufficiently addressed
Minimum Elements of the Comprehensive Site Assessment Report:
A. Title Page
• Site name, location and Groundwater Incident number (if
assigned) and Permit Number;
• Date of report;
• Responsible Party and/or permittee, including address and
phone number;
• Current property owner including address and phone
number;
• Consultanticontractor information including address and
phone number;
• Latitude and longitude of the facility; and
• Seal and signature of certifying P.E. or P.G., as appropriate.
B. Executive Summary
The Executive Summary should provide a brief overview of the pertinent
site information (i.e., provide sufficient information to acquaint the reader
with the who, what, when, where, why and how for site activities to date).
1. Source information:
Type of contaminants
2. Initial abatement/emergency response information.
1
A-4

August 12, 2014
3. Receptor information:
• Water supply wells;
• Public water supplies (wells, surface water intakes);
• Surface water bodies;
• Wellhead protection areas;
• Deep aquifers in the Coastal Plain physiographic region;
• Subsurface structures; and
• Land use.
4. Sampling/investigation results:
• Nature and extent of contamination;
• Maximum contaminant concentrations;
• Site hydrogeology.
5. Conclusions and recommendations.
C. Table of Contents
• First page number for each section listed.
• List of figures (all referenced by number and placed in a
single section following contents text).
• List of tables (all referenced by number and placed in a single
section following contents text).
• List of appendices.
D. Site History and Source Characterization
• Provide a history of property ownership and use. Indicate
dates of ownership, uses of the site, and potential sources of
contaminants.
• Discuss the source(s) of contamination, including primary
and secondary sources.
• For permitted activities, describe nature of activity, permitted
waste, application of all instances of
over-application/irrigation of wastes or water
• Summarize assessment activities and corrective actions
performed to date including emergency response, initial
abatement, primary and secondary source removal.
• Discuss geographical setting and present/future surrounding
land uses.
E. Receptor Information
Provide a site map showing labeled well locations within a
2
A-5

August 12, 2014
minimum of 1500 feet of the known extent of contamination.
Key to the table and maps described.
NOTE: As the known extent of contamination changes, the
receptor survey must be updated to reflect the change. This
applies throughout the Receptor Information section.
• In table format, list all water supply wells, public or private,
including irrigation wells and unused wells, (omit those that
have been properly abandoned in accordance with 15A
NCAC 2C .0100) within a minimum of 1500 feet of the known
extent of contamination. Note whether well users are also
served by a municipal water supply.
• For each well, include well number, well owner and user
names, addresses and telephone numbers, use of the well,
well depth, well casing depth, well screen interval, and
distance from source of contamination;
NOTE: It will often be necessary to conduct any or all of the
following in order to ensure reliability in a water supply well
survey.
o Call the city/county water department to inquire about
city water connections;
o Visit door-to-door (make sure that you introduce
yourself and state your purpose to residents prior to
examining their property) to obtain accurate
description of water usage, and if some residents are
not at home, ask surrounding neighbors who are
home about the water usage at those residences.
Even if a public water line is available, some
residents still use their well water and are not
connected to the public water system; and
o Search for water meters and well houses.
• Site map showing location of subsurface structures (e.g.,
sewers, utility lines, conduits, basements, septic tanks,
drain fields, etc.) within a minimum of 1,500 feet of the known
extent of contamination;
• Table of surrounding property owner addresses;
• Discuss the availability of public water supplies within a
minimum of 1,500 feet of the source area, including the
distance and location to the nearest public water lines and
the source(s) of the public water supply;
3
A-6

August 12, 2014
• Identify all surface water bodies (e.g., ditch, pond, stream,
lake, river) within a minimum of 1,500 feet of the source of
contamination;
Determine the location of any designated wellhead protection
areas as defined in 42 USC 300h-7(e) within a minimum of
1,500 feet of the source of contamination. Identify and
discuss the location of the water supply well(s) for which the
area was designated a wellhead protection area, and the
extent of the protected area. Include information about the
well owner, well -construction specifications (especially at
screened intervals), pumping rate and pumping schedule.
Information regarding designated wellhead protection areas
may be obtained by contacting the Public Water Supply
Section at [phone];
• Discuss the uses and activities (involving possible human
exposure to contamination) that could occur at the site and
adjacent properties. Examples of such activities and uses
include but are not limited to use of a property for an office,
manufacturing operation, residence, store, school, gardening
or farming activities, recreational activities, or undeveloped
land;
• Determine whether the contaminated area is located in an
area where there is recharge to an unconfined or
semi -confined deeper aquifer that is being used or may be
used as a source of drinking water. Based on a review of
scientific literature on the regional hydrogeology and well
construction records and lithological logs for deeper wells in
the area, identify and describe the deep aquifers underlying
the source of contamination. Include information on the depth
of the deep aquifer in relation to the surficial saturated zone,
the lithology and hydraulic conductivity of the strata between
the surficial aquifer and the deeper aquifer, and the
difference in groundwater head between the surficial aquifer
and the deeper aquifer. Discuss the local and regional usage
of the deep aquifer and the draw down from major pumping
influences. Also, specify the distance from the source of
contamination to major discharge areas such as streams and
rivers. Cite all sources and references used for this
discussion.
NOTE: This requirement (last bullet) only pertains to
A-7

August 12, 2014
contamination sources in the Coastal Plain physiographic region
as designated on a map entitled "Geology of North Carolina"
published by the Department in 1985. However,
recharge/discharge, hydraulic conductivity, lithology, head
difference, etc. is also important information at mountains
and piedmont sites.
F. Regional Geology and Hydrogeology
Provide a brief description of the regional geology and hydrogeology. Cite
all references.
G. Site Geology and Hydrogeology
• Describe the soil and geology encountered at the site. Use
the information obtained during assessment activities (e.g.,
lithological descriptions made during drilling, probe surveys,
etc.). This information should correspond to the geologic
cross sections required in N. below; and
• Based on the results of the groundwater investigation,
describe the site hydrogeology, including a discussion of
groundwater flow direction, hydraulic gradient, hydraulic
conductivity and groundwater velocity. Discuss the effects of
the geologic and hydrogeological characteristics on the
migration, retardation, and attenuation of contaminants.
H. Soil Sampling Results
Using figures and tables to the extent possible, describe all soil sampling
performed to date and provide the rationale for sample locations, number
of samples collected, etc. Include the following information:
• Location of soil samples;
• Date of sampling;
• Type of soil samples (from excavation, borehole, Geoprobe,
etc.);
• Soil sample collection procedures (split spoon, grab, hand
auger, etc.)
• Depth of soil samples below land surface;
• Soil sample identification
• Soil sample analyses;
• Soil sample analytical results (list any contaminant detected
above the method detection limit); and
5
A-8

August 12, 2014
• Identify any sample analytical results that exceed the
applicable cleanup levels.
NOTE: Information related to H. above should correspond to the
sampling location and sampling results maps required in N. below.
I . Groundwater Sampling Results
Using figures and tables to the extent possible describe the groundwater
sampling performed to date and provide the rationale for sample locations
(based on source and contaminant type), number of samples collected,
etc. Include the following information:
• Location of groundwater samples and monitoring wells;
• Date of sampling;
• Groundwater sample collection procedures (bailer, pump,
etc.);
• Groundwater sample identification and whether samples
were collected during initial abatement, CSA, etc.;
• Groundwater sample analyses;
• Groundwater sample analytical results (list any contaminant
detected above the method detection limit; and
• Identify all sample analytical results that exceed 15A NCAC
2L or interim standards.
NOTE: Information related to I. above should correspond to the
sampling location and sampling results maps required in N. below.
J. Hydrogeological Investigation
Describe the hydrogeological investigation performed including all
methods, procedures and calculations used to characterize site
hydrogeological conditions. The following information should be discussed
and should correspond to the maps and figures required below:
• Groundwater flow direction;
• Hydraulic gradient (horizontal and vertical);
• Hydraulic conductivity;
• Groundwater velocity;
Contaminant velocity;
• Slug test results; *
• Aquifer test results;
• Plume's physical and chemical characterization; and
• Fracture trace study if groundwater in bedrock is impacted.
6
A-9

August 12, 2014
* Check with the Regional Office prior to performing these tests
and study to see if necessary for the site.
K. Groundwater Modeling Results
Groundwater modeling or predictive calculations may be necessary at
some sites (source area proximate to surface water, source area located
within wellhead protection area or source area overlying semi -confined or
unconfined deeper Coastal Plain aquifer) to verify, based on site specific
hydrogeological conditions, whether groundwater contamination poses a
risk to receptors. For contamination shown to pose a risk to receptors,
groundwater modeling may be necessary to determine an appropriate
cleanup level for contaminated groundwater. Modeling should illustrate the
input data used to complete the model and will generally be required for
natural attenuation proposals (see Groundwater Modeling Policy at
hftr)://Portal.ncdenr.org/web/wci/aps/���-qwpro/Soricy).
NOTE: Input data for models should be derived from site specific
information with limited assumptions or estimates. All assumptions and
estimated values including biodegradation rates must be conservative
(predict reasonable worst -case scenarios) and must be well documented.
L. Discussion
Nature and extent of contamination, including primary and
secondary source areas, and impacted groundwater and
surface water resources;
• Maximum contaminant concentrations;
• Contaminant migration and potentially affected receptors
M. Conclusions and Recommendations
If corrective action will be necessary, provide a preliminary evaluation of
remediation alternatives appropriate for the site. Discuss the remediation
alternatives likely to be selected. Note that for impacts to groundwater
associated with permitted activities, corrective action pursuant to 15A
NCAC 2L .0106(k), (1) and (m) is not applicable, unless provided for
pursuant to 15A NCAC 2L .0106(c) and (e) or through a variance from the
Environmental Management Commission (EMC).
N. Figures
■ 71/2 minute USGS topographic quadrangle map showing an area
A-10

August 12, 2014
within a minimum of a 1,500-foot radius of the source of
contamination and depicting the site location, all water supply wells,
public water supplies, surface water intakes, surface water bodies,
designated well head protection areas, and areas of recharge to
deeper aquifers in the Coastal Plain that are or may be used as a
source for drinking water;
Site map locating source areas, site boundaries, buildings, all water
supply wells within a minimum of 1,500 feet, named
roads/easements/right-of-ways, subsurface utilities, product or
chemical storage areas, basements and adjacent properties, scale
and north arrow;
At least two geologic cross sections through the saturated and
unsaturated zones intersecting at or near right angles through the
contaminated area using a reasonable vertical exaggeration.
Indicate monitoring well/sample boring/sample locations and
analytical results for soil samples. Identify the depth to the water
table. Provide a site plan showing the locations of the cross
sections;
Site map(s) showing the results of all soil sampling conducted.
Indicate sampling identifications, sampling depths, locations and
analytical results;
■ Site map(s) showing the results of all groundwater sampling
conducted. Indicate sampling locations, monitoring well
identifications, sample identifications, and analytical results;
Separate groundwater contaminant iso-concentration contour maps
showing total volatile organic compound concentrations, total
semi -volatile organic compound concentrations and concentrations
for the most extensive contaminant. Maps should depict the
horizontal and vertical extent. Contour line for applicable 2L
standard should be shown in bold;
Site map(s) showing the elevation of groundwater in the monitoring
wells and the direction of groundwater flow. Contour the
groundwater elevations. Identify and locate the datum (arbitrary
A-11

August 12, 2014
100', USGS, NGVD) or benchmark. Indicate the dates that water
level measurements were made. There should be one map for each
series of water level measurements obtained;
■ Groundwater contaminant iso-concentration contour cross-section;
and
■ Site map(s) showing the monitoring wells.
NOTE: If possible, use a single base map to prepare site maps using a
map scale of 1 inch = 40 feet (or a smaller scale for large sites, if
necessary). Maps and figures should include conventional symbols,
notations, labeling, legends, scales, and north arrows and should
conform to generally accepted practices of map presentation such as
those enumerated in the US Geological Survey pamphlet, "Topographic
Maps".
O. Tables
List all water supply wells, public or private, including irrigation wells
and unused wells, (omit those that have been properly abandoned
in accordance with 15A NCAC 2C .0100) within a minimum of 1500
feet of the known extent of contamination For each well, include the
well number (may use the tax map number), well owner and user
names, addresses and telephone numbers, use of the well, well
depth, well casing depth, well screen interval and distance from the
source of contamination;
List the names and addresses of property owners and occupants
within or contiguous to the area containing contamination and all
property owners and occupants within or contiguous to the area
where the contamination is expected to migrate;
List the results for groundwater samples collected including sample
location; date of sampling; sample collection procedures (bailer,
pump, etc.); sample identifications; sample analyses; and sample
analytical results (list any contaminant detected above the method
detection limit in bold); and
■ List for each monitoring well, the monitoring well identification
r_10M

August 12, 2014
numbers, date water levels were obtained, elevations of the water
levels, the land surface, top of the well casing, screened interval
and bottom of the well.
P Appendices
• Boring logs and lithological descriptions;
• Well construction records;
• Standard procedures used at site for sampling, field equipment
decontamination, field screening, etc.;
• Laboratory reports and chain -of -custody documents;
• Copies of any permits or certificates obtained, permit number,
permitting agency, and
• Modeling data and results;
• Slug/pumping test data; and
• Certification form for CSA
10
A-13

August 12, 2014
DIVISION OF WATER RESOURCES
Certification for the Submittal of a Comprehensive Site Assessment
Responsible Party and/or Permittee:
Contact Person:
Address:
City: State: Zip Code:
Site Name:
Address:
City: State: Zip Code:
Groundwater Incident Number (applicable):
I, , a Professional Engineer/Professional Geologist
(circle one) for (firm or
company of employment) do hereby certify that the information indicated below is
enclosed as part of the required Comprehensive Site Assessment (CSA) and that
to the best of my knowledge the data, assessments, conclusions,
recommendations and other associated materials are correct, complete and
accurate.
(Each item must be initialed by the certifying licensed professional)
1. The source of the contamination has been identified. A list of all
potential
sources of the contamination are attached.
2. Imminent hazards to public health and safety have been identified.
3. Potential receptors and significant exposure pathways have been
identified.
4. Geological and hydrogeological features influencing the movement
of groundwater have been identified. The chemical and physical character of the
contaminants have been identified.
5. The CSA sufficiently characterizes the cause, significance and
extent of groundwater and soil contamination such that a Corrective Action Plan
can be developed. If any of the above statements have been altered or items not
initialed, provide a detailed explanation. Failure to initial any item or to provide
written justification for the lack thereof will result in immediate return of the CSA to
the responsible party.
(Please Affix Seal and Signature)
11
A-14

FYZ

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Pat McCrory
Governor
November 4, 2014
Mr. Harry Sideris
Senior Vice -President
Environment, Health, and Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, NC 28202
RE: Duke Energy Carolinas, LLC
Marshall Steam Station
NPDES Permit No. NCO004987 — Catawba County
Review of Groundwater Assessment Work Plan
Dear Mr. Sideris:
John E. Skvarla, III
Secretary
On September 26, 2014, the Division of Water Resources (Division) received the Groundwater
Assessment Work Plan (GAP) for the subject facility. The GAP was submitted in accordance
with the August 13, 2014, Notice of Regulatory Requirements (NORR) and G.S. 130A-
309.209(a)(1). After careful review, the Division has determined that the GAP is deficient in
detailing a strategy to achieve compliance with NCAC 15A 2L .0106(g), the NORR issued to
Duke, and (or) applicable general statutes. The plan as submitted fails to provide an adequate
level of detail regarding the planned assessment activities, which if left unchanged may lead to
an inadequate assessment of environmental conditions at the site. To assist you in drafting a
complete GAP, the Division offers you the following review comments which must be addressed
and incorporated into a revised groundwater assessment work plan. This review document is
separated into continents applicable to all previously submitted plans followed by comments
applicable to the referenced facility
General Comments Applicable to All Facilities
The Site Conceptual Model (SCM) section of the work plans does not provide sufficient
detail needed for the Division to adequately review the proposed data collection efforts.
The SCM section should include an "initial conceptual model" as described in
Groundwater Modeling Policy, May 31, 2007, page 6, paragraph 2, which states, "An
initial conceptual model should be developed from available regional and local studies
and information [existing site data], and initial site visits before significant site -specific
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Phone: [phone] Internet: www.ncdenr.00v
An Equal Opportunity l Affirmative Action Employer — Made in part by recycled paper
B-1

Duke Energy Carolinas, LLC - Marshall
November 4, 2414
Page 2 of 11
data collection efforts are undertaken. This step is necessary to assure that adequate
types and quantities of data are collected..." The initial conceptual model will be refined
or modified later in the process as a result of data collection. The refined or modified
model, the SCM, will then be used as the foundation upon which any numerical models
are developed for the site. Importantly, the initial conceptual model should identify data
gaps and provide the context and rationale for the types and amounts of data collection
proposed in the work plans.
Refer to the Modeling policy, the Hydrogeologie Investigation and Reporting Policy
(May 31, 2007), and other pertinent references such as ASTM E1689-95, for the elements
expected in the initial conceptual model. Ensure also that the nature, sources, and sinks
of site contaminants of concern, along with their mobility, retention, and transport
characteristics are addressed.
2. The numerical modeling description presented in the GAP is inadequate. The dram GAP
states that fate and transport modeling will be conducted using MODFLOW and MT31)
or RT3D, with very little supporting rationale or information identified to justify the use
of the chosen model or approach. Explaining the rationale for the chosen model type and
design (including the inputs that will be needed for the model) will help make site
assessment data collection more efficient and may highlight deficiencies in the initial
conceptual model.
To provide context and rationale for the chosen model(s) and proposed data collection
efforts, provide in the GAP, at a minimum, the following information:
a) the purpose of any proposed numerical modeling,
b) the question(s) the model will help answer,
c) basic information about the model (type, boundaries, layers, whether/how
site heterogeneities will be modeled, etc.),
d) a description of the partition coefficient (Kd), how, where, and at what
depths it will be derived, and how/whether it will adequately account for
the dominant mechanisms of contaminant retention,
e) whether stream flow measurements are needed for the model and, if so,
when, where, and how those would be measured,
f) model limitations, and
g) specific data gaps (types, general locations and depths, etc) that must be
filled in order to develop the model(s).
Refer to Groundwater Modeling Policy, May 31, 2007 for the elements expected in any
numerical model developed for the site.
B-2

Duke Energy Carolinas, LLC - Marshall
November 4, 2014
Page 3 of 11
3. The proposed borings, core, and well installation work are inadequate to understand,
characterize, and (or) model subsurface conditions at the sites. For piedmont and
mountain sites, the GAP shall propose field work necessary to evaluate and document the
following:
a) presence/absence,
b) areal extent and depth/thickness,
c) flow and transport properties, and
d) heterogeneity of the following groundwater flow zones: alluvial/fluvial,
fill/residuum/saprolite, weathered rock (transition zone), and fresh,
competent fractured bedrock. Specifically, continuous core shall be
collected from land surface to a depth of at least 50 feet into fresh,
competent bedrock at a sufficient number of locations inside and outside
of ash basins to understand the flow system in areas proposed for
modeling and (or) areas of contaminant concern. All cores shall be
described/logged, photographed, and retained.
Data previously obtained from existing voluntary and compliance well borings and wells
shall also be used to understand and characterize the multipart flow system. Data
collection should also be sufficient for the development of any proposed numerical
models.
Note: Drilling and caring methods shall be used to prevent potential cross
contamination of flow zones, as stipulated in 1 SA NCAC 02C, and, where
applicable, to maintain structural integrity of dam.
4. Rather than abandoning the cored locations, consideration should be given to converting
borings to either a well nest/cluster or a piezometer nest/cluster. Nested/clustered wells
shall be open to each of the dominant flow zones through the use of appropriately sized
screens and discreet screened intervals and shall be installed to measure groundwater
quality and properties that may affect contaminant mobility and transport. If the boring is
not of sufficient diameter to install all of the necessary nested wells/piezometers, the
remaining wells/piezometers should be installed in the immediate vicinity.
In addition to the logging described in comment 3 above, each core location shall include
the collection of a solid phase sample at the following intervals:
a) immediately above the water table,
b) immediately below the water table,
c) within the saturated upper transition zone material (if not already included
in a) or b) above), and
d) from a primary, open, stained fracture within fresh bedrock, if these zones
exist.
B-3

Duke Energy Carolinas, LLC - Marshall
November 4, 2014
Page 4 of 11
The sample(s) 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, organic carbon
content, organic carbonate content, cation exchange capacity, anion exchange
capacity, surface area, moisture content, particle size analysis, Atterberg limits,
specific gravity, porosity, permeability, and any other physical properties or
analyses that may be required to estimate a batch partition coefficient Kd or
otherwise serve as input to a chosen model.
In addition, total analytes (see comment #12), SPLP analytes (see comment #12), and
speciation of selected inorganics shall be conducted for selected sample locations in
sufficient quantity and distribution to characterize the solid and aqueous chemistry and
geochemistry in locations and depths of contaminant concern, and this work shall be
clearly defined in the GAP. Inorganic speciation typically will include Fe and Mn, along
with others that may shed light on contaminant toxicity, mobility, and (or) prevailing
geochemical conditions. Sulfide and methane shall also be collected at selected locations
to evaluate geochemical conditions. Water and bed sediment samples from seeps and
streams shall be treated and analyzed in a manner consistent with the description above.
If a given analysis is believed to be unnecessary at a given location or depth based on site
conditions or assessment objectives, provide a detailed rationale for its omission for the
Division's consideration. In general, the collection strategy for ash samples from cores
inside of ash basins as described in the GAP appear to be adequate, along with the
proposed total and SPLP analyses. The need for additional core locations, where
applicable, is provided in the site -specific comment section below. Note that the chosen
numerical model(s), extent of contamination, and size of site shall drive the number,
distribution, and type of solid phase sample collection and analyses needed to understand
the retention and mobility of constituents of concern.
5. Duke shall describe the batch partition coefficient Kd, the individual inorganics that will
be tested, and whether multi -metals will be co -tested. Duke shall identify the
approximate number, distribution, and depths/flow zones of solid phase samples used to
derive the Kd(s) across the site.
G. The term "deep" as it relates to a well is subjective. For consistency and to avoid
confusion as to whether a deep well is open to transition zone material or competent
bedrock, please refer in all descriptions to each well as alluvial/fluvial, saprolite,
transition zone, or bedrock. If one or more of these zones are relatively thick, contain
more than one discreet flow zone, and should be thought of as "upper" and "lower", that
qualifying designation is also appropriate (for example, upper transition zone and lower
transition zone if the two intervals represent discreet flow intervals).
7. Surface water and bed sediment sampling are limited or are not proposed in the GAP.
The Division expects base flow surface water and bed sediment sampling to be included
in the site assessment and the GAP. These data will provide information on surface water
B-4

Duke Energy Carolinas, LLC - MarshalI
November 4, 2014
Page 5 of 11
quality and will be useful in efforts to understand the interaction of ground and surface
water at the site. Sample locations and distribution shall be based on site specific
considerations, but seepage areas, key tributaries, and ash ponds should be given special
emphasis. Surface water data collected by the Division during the March 2014 sampling
event, and existing ground and surface water data collected by Duke should be used in
the sample design and site assessment.
S. It is expected that Duke conduct assessment work, including borings, wells, and surface
waterbed sediment sampling„ offsite (outside of property boundaries) as needed for
adherence to 15A NCAC 02L.0106 (g)(4) and (or) for the evaluation of background
conditions. The plans as submitted do not adequately account for offsite assessment
work or provide a justification that offsite work is not needed. Proposed offsite
assessment locations should be described in the GAP.
9. It is expected that as data from wells, borings, and water samples are derived and
evaluated, Duke will identify and sample additional locations as needed to complete the
horizontal and vertical extent of impacts associated with coal ash to subsurface soils,
saprolite, bedrock, and the ground and surface water resources. These activities and
anticipated locations shall be proposed in the GAP and included in the assessment.
10. Please note that wells identified as "background" are subject to periodic review based on
an increased understanding of site chemistry and hydrogeologic conditions. If a well
currently identified or otherwise labeled as background does not, in fact, represent
background conditions, it shall be excluded from further consideration as "background".
The need for additional or replacement background wells shall be considered during site
assessment and (or) as outlined in the site specific comment section below. However, 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 that are associated with groundwater
contamination (e.g., alluvium, fluvial deposits, saprolite, transition zone, and (or)
competent bedrock). Each of these wells must represent ambient background conditions
unaffected by site or offsite activities. Offsite well placement will, in some cases, be
expected depending on the position and proximity of waste, compliance, and property
boundaries. At least four independent sampling events generally are needed for a well to
be used in formal statistical testing.
11. Quality control samples shall be proposed in the GAP. These shall include but are not
limited to, descriptions of field calibration procedures, collection of replicate
measurements, use of field blanks, use of "blind" quality control samples, etc.
B-5

Duke Energy Carolinas, LLC - Marshall
November 4, 2014
Page 6 of 11
12. The analyte list for supply well sampling, compliance well sampling, and site assessment
sampling shall include, but is not limited to, the following:
Al, Sb, As, Ba, B, Be, Ca, Cd, Co, Cr, Cu, Fe, K, Pb, Mg, Mn, Mo, Hg, Na, Ni,
Se, Sr, TI, V, Zn, CI, SO4, total dissolved solids (TDS), alkalinity, bicarbonate,
carbonate, total 'suspended solids (TSS), turbidity, pH, temperature, specific
conductance (SC), dissolved oxygen (DO), oxidation reduction potential (ORP),
and water level (water level measurements in supply wells may be omitted if well
head hardware prevents ready access). In addition, total combined radium (Ra-
226 + Ra-228) shall be measured on at least one occasion in selected compliance
wells of highest concern at each facility. Note that .15A NCAC 02K 0804 requires
certification for field parameters.
The GAP shall include the sampling frequency for each sample type. Justification must
be provided for Division consideration for any sample types/locations in which a sample
frequency of one is proposed.
13. Duke shall list and provide a detailed description of each coal combustion residuals
(CCR) waste storage or disposal area (unit) at each facility. This description shall state
the following:
a) known or approximate quantities of CCR waste stored in the unit(s);
b) details of the operational history of the unit(s), including years of use, all
known waste types, methods of emplacement, rationale for formal or
informal closure, and methods of closure or abandonment;
c) whether the unit is already included in the facility's current NPDES
permit;
d) whether the unit was permitted and managed by an agency other than the
Division and pertinent details of that permit;
e) whether there are additional permitted or unpermitted waste storage areas
within CCR waste storage areas;
f) the location and distribution of any coal ash used as structural fill or other
construction (i.e. roadbeds, storage pads, berms, etc.) both on and offsite
(proximal to the site); and
g) whether the existing compliance boundary captures all the CCR waste
storage areas or if revisions need to be made.
Based on requirements specified in 15A NCAC 02L .0107 and a review of the
information discussed in a) to g) above, the Division will determine whether additional
units or areas need to be included in an existing or a new compliance boundary.
14. It is expected that the reporting limits associated with all analytical methods proposed in
the GAP be EPA approved and be at or below the state groundwater standards at 15A.
NCAC 2L or surface water standards at 15A NCAC 2B.
B-6

Duke Energy Carolinas, LLC - Marshall
November 4, 2014
Page 7 of 11
15. 15A NCAC 02C .0108(p) specifies that each non -water supply well be developed such
that the level of turbidity or settleable solids does not preclude accurate chemical
analyses of any fluid samples collected. The GAP shall acknowledge and state that well
construction design will be based on site specific conditions and shall be actively
modified in the field (alternate screen slot size, use of well sock, or others, for example)
'to accommodate the grain size of the formation, as needed to minimize turbidity or
address other unforeseen issues. Any deviations from originally proposed protocols shall
be fully documented and provided to the Division.
16. The GAP shall state that well development and purging protocols will be based on site
specific conditions and shall be actively modified in the field as needed to minimize
turbidity or address other unforeseen issues. In all cases, well development and purging
prior to sample collection shall be conducted to specific field standards which shall be
clearly stated in the GAP. Deviations from this protocol or from other proposed
development and purging protocols shall be fully documented and provided to the
Division. If the Division concludes that turbidity is impacting analytical results for any
reason, a replacement well will, in some cases, be required.
17. Duke shall contact adjacent property owners for site access as needed to complete the
assessment activities. If Duke is unable to obtain access from an owner, Duke shall
request liaison assistance from the Division in writing. This request shall include all
contact information, details of all prior discussions regarding access to the property for
purposes of conducting site assessment, and results of those discussions. Duke shall
provide the Division a copy of any formal access agreements proposed for use.
18. The statewide 1:500,000 geologic map is not a substitute for local, larger scale geologic
mapping and site scale geologic information where available. The GAP shall propose the
use of fracture trace analysis (where applicable) and onsite/near-site geologic mapping to
better understand site geology. The scope of these efforts shall depend upon site
conditions and existing geologic information.
19. If proposed, please provide a detailed rationale for the use of Rotosonic or similar drill
method and why it is appropriate for use in the site assessments. Please address any
potential issues (such as the consolidation of aquifer material in the vicinity of the well
screen) that could affect aquifer or groundwater analyses.
20. The purpose, methods, and numbers (including anticipated depths/flow zone(s) and,
where known, locations) of packer testing shall be clearly detailed in the GAP.
21. The use of statistics to help establish background concentrations of specific parameters
shall be based on site -specific data and shall follow the methods approved for use by the
Division. In most cases, the methods outlined in RCRA Unified Guidance (U.S. EPA,
2009, EPA 530/R-09-007) are considered to be appropriate for use at these sites.
Background wells deemed appropriate for use in statistical analyses must be approved by
the Division. Final background determinations are made by the Division Director based
on available data and information.
B-7

Duke Energy Carolinas, LLC - Marshall
November 4, 2014
Page 8of11
22. As part of the GAP, provide an oversized summary table of all existing compliance and
voluntary well data collected to date at the site. Please place all constituents, including
DO, SC, ORP, and turbidity, as headings across the top of the table, and all wells and
sample dates as rows along the left side of the table. Highlight in yellow those values
that exceed a 2L standard. Please also include on this table any surface water, ash, and
(or) ash leachate data relevant to the site. This table should be included in, the GAP and
also made available in electronic (Excel or similar) format.
23. As part of future site assessment reporting deliverables, provide at a minimum the
following tables, graphs, and maps:
a) box (whisker) plots, for locations sampled on four or more events (show
min, 25, 50, 75, max); align plots for multiple locations on one chart;
construct a similar chart for each constituent of concern (COC),
b) stacked time -series plots (for each COC, stack multiple wells/locations
using same x-axis to discern seasonal trends; construct similar chart for
each COC; consider also showing turbidity, DO, ORP, or other constituent
on plot to demonstrate influence,
c) piper and (or) stiff diagrams showing selected monitor wells, supply wells,
surface water locations, ash leachate as separate symbols,
d) correlation charts, where applicable,
e) orthophoto potentiometric maps for "like" flow zones (maps for bedrock
wells likely will be plotted on a different map than maps for transition
zone wells),
f) orthophoto potentiometric difference maps, showing the difference in
vertical heads between selected flow zones,
g) orthophoto iso-concentration maps for selected COCs and flow zones,
h) orthophoto map showing relationship between ground and surface water
samples for selected COC(s),
i) geologic cross sections,
j) photographed borings/core for each boring location, and
k) others as appropriate.
For summary statistics tables, avoid presenting "average" value(s) unless the
constituent(s) at the location in question is (are) normally distributed, in which case a
mean and standard deviation are acceptable. For non -normal data, use of the median
value is more appropriate. In either case, use of the maximum value is often misleading
if it is a formally -tested outlier or is associated with high turbidity; footnote maximum
values as appropriate.
24. With respect to the use of the terms "may" versus "will", the GAP shall use the term
"will" or clearly state, in detail, why the qualifying term "may" is used. In either case,
the Division reserves the right to request at any time additional work needed to meet site
assessment objectives. During the assessment, if Duke decides that additional work is
B-8

Duke Energy Carolinas, LLC - Marshall
November 4, 2014
Page 9 of 11
needed at a facility, the Division shall be contacted immediately with a description of the
proposed work and timeline.
25. Any assumptions or timelines stated in the GAP shall not be used as justification to
circumvent the mandatory deadlines established by legislative order, Governor's
Executive Action, or NQRR.
Additional Comments Specific to the Referenced Facilily
26. GAP Figures 2 and 3 depict the facility's southeastern property boundary on the eastern
shore line of Lake Dorman.. Does Duke Energy own Lake Norman and/or the lakebed?
Please refer to "All Facilities" Comment 13.
27. The GAP proposes to install borings AL- 1S/D, AL-2S/D, AL-3S/D, AL-41), and ©B-1
within or immediately adjacent to an on -site ash landfill permitted by the Division of
Waste Management (DWM) under permit number 1804. There are six DWM permitted
landfill areas located adjacent to ash basins at the site. A structural fill area is located
adjacent to and partially on top of the western most portion of the ash basin. The GAP
does not indicate that the structural fill area is a permitted disposal area no details are
provided as to what wastes may be buried within the structural fill area. While it is
expected that the GAP should detail plans to characterize the impacts of coal combustion
residual wastes throughout the site (including within, or adjacent to the ash basins), Duke
Energy should advise the DWM or any other applicable agencies of their plans to install
any borings/monitoring wells inside or immediately adjacent to waste management
structures that were permitted and/or are managed by those agencies. Please also refer to
"All Facilities" comment 13 and provide additional details regarding each coal
combustion residual waste storage or disposal area at the facility.
28. The GAP should include a discussion of whether ash is also present within the waters of
the Ash Basin in the areas where basin water sample locations SW-1 through SW-5 are
proposed. If ash is present with these ponds, the GAP should include a proposal for
characterization of the ash within these locations or an explanation as to why these
samples are not needed or are unable to be obtained.
29. The ash basin area is for the Marshall site is very large, encompassing over 380 acres.
The GAP has insufficient ash/soil boring locations to characterize the storage areas. In
many cases there are over 1000 feet between boring ash boring locations. Examples
include but are not limited to; at least one additional set of ash/soil characterization
borings could be proposed approximately 600 feet westisouthwest of AB-20S/D; one set
approximately 700 feet west/northwest of AB-2S/D; at least another boring set within the
area being characterized by AB-21 S/D; one boring set located between AB-12S/D and
AB-13S/D; one boring set located between AB-15S/D and AB-19S/D; one boring set
placed in the uncharacterized "tongue" of the ash basin adjacent to and west of AB-
17S/D; and one boring set located between SB-4 and SB-5. If coal combustion residuals
were included in the materials emplaced in the structural fill area, additional boring sets
should be proposed to more completely characterize this area.
B-9

Dube Energy Carolinas, LLC - Marshall
November 4, 2014
Page 10 of 11
30. The GAP proposed collecting native soil samples from immediately below the ash basins
and in the AB, AL and SB series borings. Additional soil samples are also proposed from
three "background" boring/monitoring well locations, however the GAP provides
insufficient details regarding from what depth intervals these soil samples will be
collected or how they will be utilized to characterize and/or model the site at all zones of
interest: The GAP should address this deficiency. - Additionally, the GAP does not
propose plans to collect soil samples from the GWA or MS series boring/monitoring well
locations because they will be located outside the waste boundary. Inclusion of soil
samples from the GWA and MS series borings will provide additional characterization of
soil solid phase conditions outside the waste storage area and should be detailed in the
GAP. In addition to soil samples, the GAP should include a sufficient number of borings
and cores to understand, characterize, and (or) model subsurface conditions (both solid
phase and groundwater) at the site at all depths of interest. The current GAP lacks
sufficient detail, proposes an insufficient number of soil samples and a complete lack of
bedrock core samples for characterization of the site's subsurface conditions. Please
refer to "All Facilities" comments 3 and 4.
31. Three "background" borings/monitoring wells (BG-1S/D, BG-2S/D, BG-3S/D) are
proposed in the GAP to assist in characterizing the site. The background monitoring well
location at BG-1 S/D may not be located hydraulically or sufficiently far enough away
from the influence of ash waste storage areas depending on the findings of the planned
assessment. Although the locations of this "background" monitoring well may provide
some useful information for the assessment efforts, depending on the findings of the
assessment, an additional off -site background location to replace BG-1S/D may have to
be proposed which will have a higher likelihood of clearly reflecting soil and
groundwater conditions beyond the influence of the ash waste storage areas. Please refer
to "All Facilities" comments 7 and 8. Proposed background monitoring well location
BG-2S/D may be located at a sufficient distance from the influence of the of the waste
storage areas however, review of the GAP noted that there is additional space within the
Duke Property boundary to the north which would allow for approximately 1000 more
feet of separation by shifting the locations of BG-2S/D and BG-3S/D to the
north/northeast.
32. Samples periodically collected from compliance monitoring wells MW-13S and MW-
12D have shown consistent exceedances of the 15A NCAC 2L (2L) groundwater quality
standards for iron. The GAP does not provide plans or discussion of assessment to the
west and southwest of these locations to delineate these exceedances. MW-11D has
intermittently shown exceedances for iron during previous periodic sampling events,
however, no proposals or discussion of additional off -site assessment to the southeast was
included in the GAP. Although there is a topographic divide along Sherrills Ford Rd, this
area is hydrologically complex and off -site assessment to the west is necessary to
characterize the geologic, geochemical and hydrogeologic zones which are and are not
under the influence of coal combustion residual wastes at the site. The GAP shall include
sufficient borings/monitoring well nests to characterize all zones of interest and this shall
include off site borings where necessary to delineate exceedances of the 2L standards.
Please refer to "All Facilities" comment 8 and 9.
B-10

Duke Energy Carolinas, LLC - Marshall
November 4, 2014
Page 11 of 11
33. The GAP includes ash basin surface water sampling at five locations (SW-1 through SW-
5) with a possible surface water sample (S-1) being collected near MW-14S/D. Large
Figure 3, which was submitted with the GAP, denotes a possible sample location
designated S-2 approximately 400 feet northeast of NPDES outfall 002 but it is not
referenced in the report or in the smaller version of Figure 3 included in the GAP. There
are no proposed seep samples in the GAP. Previous' groundwater samples collected from
MW-14S/D, adjacent to a cove of Lake Norman, have shown 2L exceedances of boron,
sulfate, TDS, iron and manganese. Previous samples collected from MW-10S/D,
immediately adjacent to Lake Norman, have also shown some 2L exceedances of iron
and manganese during previous periodic sampling. During a 3/10/14 site visit, DWR
staff identified two seepage or moist areas on the eastern side of the dike wall
approximately 400 feet northeast (discharge SW001) ofNPDES outfall 002 and 400 feet
southwest (discharge SW002) ofNPDES outfall 002. The GAP should include plans to
characterize these areas. No other surface waters or stream sediments sampling is
discussed in the GAP. Please refer to "All Facilities" comments 7, 8 and 9 and provide
plans for assessing the groundwater and surface water interactions at the site.
Your assessment plan must be submitted to the DWR Mooresville Regional Office and Central
Office for review within 30 days of the receipt of this letter. A revised plan must be submitted
that fully incorporates the responses to the above comments rather than a letter response
intended to supplement the previously submitted plans.
Please note that failure to conduct a complete assessment pursuant to the above referenced rule
and statute will be considered a violation, subject to potential enforcement actions by the
Division.
We appreciate your attention and prompt response in this matter. If you have questions, please
do not hesitate to call Bruce Parris at 704-663-1699.
Sincerely
e.
S aye- immerman, P.G., Chief
Water Quality Regional Operations Section
Cc: WQROS -- MRO
WQROS — Central Office
Don van der Vaart
HDR (Attn: William Miller) 440 South Church Street, Suite 1000, Charlotte, NC 28202
KNEE