Loading...
HomeMy WebLinkAboutRBSS Assessment Work Plan_Final_092514 Riverbend Steam Station Ash Basin Proposed Groundwater Assessment Work Plan NPDES Permit NC0004961 September 25, 2014 Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin TABLE OF CONTENTS i Table of Contents Page Table of Contents ......................................................................................................................... i Executive Summary .............................................................................................................. ES-1 1.0 Introduction ..................................................................................................................... 1 2.0 Site History ...................................................................................................................... 2 2.1 Plant Description .......................................................................................................... 2 2.2 Ash Basin Description .................................................................................................. 2 2.3 Regulatory Requirements ............................................................................................ 3 3.0 Receptor Information ....................................................................................................... 5 4.0 Regional Geology and Hydrogeology .............................................................................. 6 5.0 Site Geology and Hydrogeology ...................................................................................... 7 6.0 Groundwater Monitoring Results ..................................................................................... 8 7.0 Assessment Work Plan ................................................................................................... 9 7.1 Ash and Soil Sampling Plan ......................................................................................... 9 7.2 Groundwater Sampling Plan .......................................................................................11 7.3 Surface Water Sampling Plan .....................................................................................14 7.4 Site Hydrogeologic Conceptual Model ........................................................................14 7.5 Site-Specific Background Concentrations ...................................................................14 7.6 Groundwater Model ....................................................................................................14 8.0 Proposed Schedule ........................................................................................................16 9.0 References .....................................................................................................................17 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. Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin TABLE OF CONTENTS ii List of Figures 1. Site Location Map 2. Site Layout Map 3. Proposed Well and Sample Locations List of Tables 1. Groundwater Monitoring Requirements 2. Monitoring Well Locations 3. Exceedances of 2L Standards June 15, 2011 – June 3, 2014 4. Proposed Additional Exploration and Sampling Plan 5. Soil and Ash Parameters and Analytical Methods 6. Groundwater, Surface Water, and Seep Parameters and Analytical Methods Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin EXECUTIVE SUMMARY ES-1 Executive Summary Duke Energy Carolinas, LLC (Duke Energy), owns and formerly operated the Riverbend Steam Station (RBSS), located near Mt. Holly, in Gaston County, North Carolina (see Figure 1). The coal ash residue from RBSS’s coal combustion process was historically disposed of in the station’s ash basin located adjacent to the station and Mountain Island Lake. 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 NC0004961. 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 is in the process of completing a receptor survey to identify all receptors within a 0.5-mile radius (2,640 feet) of the RBSS ash basin compliance boundary. This receptor survey will also address the requirements of the General Assembly of North Carolina Session 2013 Senate Bill 729 Ratified Bill (SB 729). Soil and groundwater sampling will be performed to provide information pertaining to the horizontal and vertical extent of potential soil and groundwater contamination. This will be performed by sampling existing wells, installing and sampling approximately 26 nested monitoring well pairs (shallow and deep) and three shallow (only) wells, and collecting soil and ash samples. In addition, two observation wells will be installed to characterize groundwater flow in the region between the ash basin and the background monitoring wells. This work will provide 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 transport of constituents from the ash basin and ash storage areas. Samples of ash basin water will be collected and used to evaluate potential impacts to groundwater and surface water. In addition, seep samples will be collected from locations identified in May 2014 (as part of Duke Energy’s NPDES permit renewal application) to evaluate potential impacts to surface water. The information obtained through implementation of this W ork 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 or 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. Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin INTRODUCTION 1 1.0 Introduction Duke Energy Carolinas, LLC (Duke Energy), owns and formerly operated the Riverbend Steam Station (RBSS), located near Mt. Holly, in Gaston County, North Carolina (see Figure 1). The steam station generated electricity by burning coal. The coal ash residue from RBSS’s coal combustion process was historically disposed of in the station’s ash basin located adjacent to the station and Mountain Island Lake. The discharge from the ash basin is permitted by the North Carolina Department of Environment and Natural Resources (NCDENR) Division of Water Resources (DW R) under the National Pollutant Discharge Elimination System (NPDES) Permit NC0004961. 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 is in the process of completing a receptor survey to identify all receptors within a 0.5-mile radius (2,640 feet) of the RBSS ash basin compliance boundary. The NORR letter is included as Appendix A. On behalf of Duke Energy, HDR has prepared this proposed 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 or 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. Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin SITE HISTORY 2 2.0 Site History 2.1 Plant Description RBSS is a former coal-fired electricity generating facility which had a capacity of 454 megawatts located in Gaston County, North Carolina, near the town of Mt. Holly. As of April 1, 2013, all of the coal-fired units have been retired. The site is located between the south bank of the Catawba River on Mountain Island Lake and the north side of Horseshoe Bend Beach Road. The surrounding area generally consists of residential properties, undeveloped land, and Mountain Island Lake. Horseshoe Bend Beach Road runs generally west to east and is located along a local topographic divide. The topography at the site generally slopes downward from that divide to Mountain Island Lake. The seven-unit station began commercial operation in 1929 with two units and then expanded to seven by 1954. During its final years of operation, RBSS was considered a cycling station and was brought online to supplement energy supply when electricity demand was at its highest. 2.2 Ash Basin Description The ash basin system consists of a Primary Cell and a Secondary Cell, separated by an intermediate dike. The ash basin at RBSS originally consisted of a single-cell basin commissioned in 1957 and was expanded in 1979. The single basin was divided by constructing a divider dike to form two separate cells in 1986. The ash basin is located approximately 2,400 feet to the northeast of the power plant, adjacent to Mountain Island Lake, as shown on Figure 2. The Primary Cell is impounded by an earthen embankment dike, referred to as Dam #1 (Primary), located on the west side of the Primary Cell. The Secondary Cell is impounded by an earthen embankment dike, referred to as Dam #2 (Secondary), located along the northeast side of the Secondary Cell. The toe areas for both dikes are in close proximity to Mountain Island Lake. The surface area of the Primary Cell is approximately 41 acres with an approximate maximum pond elevation of 724 feet. The surface area of the Secondary Cell is approximately 28 acres with an approximate maximum pond elevation of 714 feet. The full pond elevation of Mountain Island Lake is approximately 646.8 feet. The ash basin system was an integral part of the station’s wastewater treatment system which predominantly received inflows from the ash removal system, station yard drain sump, and stormwater flows. During station operations, inflows to the ash basin were highly variable due to the cyclical nature of station operations. The inflows from the ash removal system and the station yard drain sump are discharged through sluice lines into the Primary Cell. The discharge from the Primary Cell to the Secondary Cell is through a concrete discharge tower located near the divider dike. Although the station is retired, wastewater effluent from other non-ash-related station discharges to the ash basin is discharged from the Secondary Cell, through a concrete discharge tower, to Mountain Island Lake. The concrete discharge tower drains through a 30- Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin SITE HISTORY 3 inch-diameter corrugated metal pipe (CMP) into a concrete-lined channel that discharges to Mountain Island Lake. The ash basin pond elevation is controlled by the use of concrete stop logs. 2.3 Regulatory Requirements The NPDES program regulates wastewater discharges to surface waters to ensure that surface water quality standards are maintained. RBSS is permitted to discharge wastewater under NPDES Permit NC0004961, which authorizes discharge of cooling water (Outfall 001), ash basin discharge (Outfall 002), and yard sump overflow (Outfall 002A) to the Catawba River 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 five years. The most recent NPDES permit renewal for RBSS became effective on March 1, 2011, and expires February 28, 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 December 2010. 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 RBSS 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 Figure 2. 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 the DWR before the last day of the month following the date of sampling for all compliance monitoring wells except MW -9, MW-10, and MW -13. The compliance groundwater monitoring system for the ash basin consists of the following monitoring wells: MW -7SR, MW -7D, MW -8S, MW-8I, MW-8D, MW-9, MW-10, MW-11SR, MW- 11DR, MW -13, MW -14, MW -15 (shown on Figures 2 and 3). All the compliance wells were installed in 2010. One or more groundwater quality standards (2L Standards) have been exceeded in groundwater samples collected at monitoring wells MW -7SR, MW -7D, MW-8S, MW -8I, MW -8D, MW -9, MW -10, MW -11SR, MW -11DR, MW -13, MW-14, and MW -15. Exceedances have occurred for pH, iron, and manganese. Note an exceedance of the interim maximum allowable concentration (IMAC) groundwater quality standard for antimony has been measured at MW - 7D. Table 3 presents exceedances measured from December 2010 through June 2014. Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin SITE HISTORY 4 Monitoring wells MW -9, MW -10, and MW-13 are located inside of the compliance boundary as it was not possible to access the compliance boundary at these three locations. Therefore, these monitoring wells are installed inside of the 500-foot compliance boundary. These monitoring wells are also sampled three times per year, and compliance with 2L Standards is determined by using predictive calculations or a groundwater model to demonstrate compliance. For these three monitoring wells, Duke Energy previously used a groundwater model to predict the concentrations at the compliance boundary. Monitoring wells MW -7SR and MW -7D are considered to represent background water quality. Monitoring wells MW -8S, MW -8I, and MW-8D are located to the south of an ash storage area and to the north of Horseshoe Bend Beach Road. Monitoring well MW -9 is located to the north of a cinder storage area. MW -10 is located downgradient of the Primary Cell. Monitoring wells MW -11SR and MW -11DR are located northwest of the dike dividing the Primary Cell and the Secondary Cell. Monitoring wells MW -13, MW-14, and MW -15 are located downgradient of the Secondary Cell. With the exception of monitoring wells MW -9, MW-10, and MW-13, the ash basin compliance monitoring wells were installed at or near the compliance boundary. Note that monitoring wells MW -1S, MW-1D, MW -2S, MW-2D, MW-3S, MW-3D, MW -4S, MW- 4D, MW -5S, MW -5D, MW -6S, and MW -6D were installed by Duke Energy in 2006 as part of a voluntary monitoring system. Samples are currently being collected from monitoring wells MW -4S, MW -4D, MW -5S, and MW -5D as part of groundwater assessment efforts. No samples are currently being collected from the other voluntary wells. The voluntary wells are shown on Figure 3. Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin RECEPTOR INFORMATION 5 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 is in the process of completing a receptor survey for RBSS to identify all receptors within a 0.5-mile radius (2,640 feet) of the ash basin compliance boundary to be submitted to NCDENR no later than October 1, 2014. This receptor survey will also address the requirements of the General Assembly of North Carolina Session 2013 Senate Bill 729 Ratified Bill (SB 729). The receptors include, but are not limited to, public and private water supply wells (including irrigation wells and unused or abandoned wells) and surface water features within a 0.5-mile radius of the RBSS ash basin compliance boundary. The compliance boundary for groundwater quality, in relation to the ash basin, 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 source. The receptor survey will include 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 will be located on the map and the well owner's name and location address 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. If necessary, an updated receptor survey will be submitted with the CSA report. Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin REGIONAL GEOLOGY AND HYDROGEOLOGY 6 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). RBSS 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). Piedmont bedrock primarily consists of igneous and metamorphic bedrock. The fractured bedrock is overlain by a mantle of unconsolidated material known as regolith. The regolith includes, where present, the soil zone, a zone of weathered, decomposed bedrock known as saprolite, and where present, alluvium. Saprolite, the product of chemical and mechanical weathering of the underlying bedrock, is typically composed of clay and coarser granular material up to boulder size and may reflect the texture of the rock from which it was formed. The weathering product of granitic rocks may be quartz-rich and sandy-textured, whereas rocks poor in quartz and rich in feldspar and other soluble minerals form a more clayey saprolite. The regolith serves as the principal storage reservoir for the underlying bedrock (LeGrand 2004). A transition zone may occur at the base of the regolith between the soil-saprolite and the unweathered bedrock. This transition zone of partially weathered rock is a zone of relatively high permeability compared to the overlying soil-saprolite and the underlying bedrock (LeGrand 2004). RBSS is located in the Charlotte terrane of the Carolina Zone (Pippin and others, 2008), or in the older belt terminology, the Charlotte Belt of the Piedmont physiographic province (Piedmont) (North Carolina Geological Survey, 1985). The Charlotte terrane is characterized by mostly felsic to mafic plutonic rocks which intrude a suite of mainly metaigneous rocks and minor metasedimentary rocks (Pippin and others, 2008). Based on the location of the site on the Geologic Map of the Charlotte 1º x 2º Quadrangle, North and South Carolina, the underlying bedrock at the site is composed of metamorphosed quartz diorite and tonalite (mqd). The mqd unit is described as gray, usually medium- to coarse- grained, generally foliated rock composed dominantly of plagioclase, quartz biotite, hornblende, and epidote. Biotite, hornblende, and epidote are commonly associated in clots replacing original mafic phenocrysts; clots may be smeared out, thus defining foliation (Goldsmith and others 1988). 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. LeGrand describes this as the local slope aquifer system. 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). Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin SITE GEOLOGY AND HYDROGEOLOGY 7 5.0 Site Geology and Hydrogeology Based on a review of soil boring and monitoring well installation logs provided by Duke Energy, subsurface stratigraphy consists of the following material types: fill, ash, alluvium, residuum, saprolite, partially weathered rock (PWR), and bedrock. In general, residuum, saprolite and PWR were encountered on most areas of the site. Alluvium was encountered in borings advanced along the northeastern extent of the Secondary Cell, within close proximity to Mountain Island Lake. Bedrock was encountered sporadically across the site ranging in depth from 34 feet on the northern extent of the site to greater than 200 feet on the southern extent of the site near Horseshoe Bend Beach Road. 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 ash storage area.  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 basins and ash and cinder storage areas.  Alluvium – Alluvium is unconsolidated soil and sediment that has been eroded and redeposited by streams and rivers. Alluvium may consist of a variety of materials ranging from silts and clays to sands and gravels. Alluvium was encountered in three boring locations at the base of the northern embankment of the Secondary Cell, proximal to Mountain Island Lake. Alluvium in these borings was described as yellowish red to reddish yellow silty clay to clayey sand with well rounded quartz pebbles.  Residuum – Residuum is the in-place weathered soil that consists of white, orange, tan, brown, gray or black sandy clay to clayey sand. This unit was encountered in various thicknesses across the site.  Saprolite – Saprolite is soil developed by in-place weathering of rock similar to the bedrock that consists of brown, tan, or green silty sand with trace mica. The primary distinction from residuum is that saprolite typically retains some structure (e.g., mineral banding) from the parent rock. This unit was found in most areas across the site and was described as white, orange, red, brown or black crumbly extremely weathered rock with relict rock structure.  Partially Weathered Rock (PWR) – PWR occurs between the saprolite and bedrock and contains saprolite and rock remnants. This unit was described as white to brownish yellow to greenish gray with quartz and potassium feldspar fragments.  Bedrock – Bedrock was encountered in three deep borings completed around the northern extent of the Secondary Cell and the western extent of the Primary Cell. Depth to top of bedrock ranged from 34 feet to 51 feet below ground surface (bgs). Bedrock was described as granite, quartzite and gneiss. Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin GROUNDWATER MONITORING RESULTS 8 6.0 Groundwater Monitoring Results From December 2010 through June 2014, the compliance groundwater monitoring wells at RBSS have been sampled a total of 12 times. During this period, these monitoring wells were sampled in:  December 2010  February 2011  June 2011  October 2011  February 2012  June 2012  October 2012  February 2013  June 2013  October 2013  February 2014  June 2014 Note that compliance monitoring wells MW -11DR, MW -11SR, and MW-15 were first sampled in February 2011. With the exception of iron, manganese, antimony, and pH, the results for all monitored parameters and constituents were less than the 2L Standards for all sampling events. Table 3 lists the range of exceedances for iron, manganese, antimony, and pH for the sampling events listed above. HDR previously completed an initial groundwater assessment of the 2L Standard exceedances in the compliance monitoring wells at RBSS through the February 2013 sampling event (Groundwater Assessment, Duke Energy Carolinas, LLC, Riverbend Steam Station Ash Basin, NPDES Permit NC0004961, May 31, 2013). The results and recommendations from this assessment report will be used during the groundwater assessment required by the NORR. Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin ASSESSMENT WORK PLAN 9 7.0 Assessment Work Plan Soil and groundwater sampling will be performed to provide information pertaining to the horizontal and vertical extent of potential soil and groundwater contamination. Based on readily available site background information and dependent upon accessibility, HDR anticipates collecting soil and/or ash samples during installation of approximately 26 nested monitoring well pairs (shallow and deep) and 3 shallow (only) wells. Groundwater samples will be collected from the proposed monitoring wells. The proposed well locations are listed in Table 4 and shown on Figure 3. HDR may also resample select existing monitoring wells to supplement groundwater quality data. In addition, two observation wells will be installed to characterize groundwater flow in the region between the ash basin and background monitoring wells. 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 and ash storage areas. Samples of ash basin water will also be collected and used to evaluate potential impacts to groundwater and surface water. If conditions allow for representative sampling, water samples will be collected from seep sample locations (S-1 through S-12) identified in May 2014 (as part of Duke Energy’s NPDES permit renewal application) to evaluate potential impacts to surface water. A summary of the proposed exploration plan, including estimated sample quantities and depths of soil borings and monitoring wells, is presented in Table 4. 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 Ash and Soil Sampling Plan 7.1.1 Boring and Sampling Methods Prior to drilling each boring, all downhole equipment and tools will be cleaned by washing with high-pressure hot water. A designated remote cleaning area will be established in the field. Water for cleaning will be obtained from a tap or hydrant (to be designated) at RBSS, or supplied by the drilling contractor from an off-site source. Cleaning water will not require collection, treatment, or disposal. Borings will be advanced using hollow stem auger or roller cone drilling techniques to facilitate collection of downhole data. Standard Penetration Testing (SPT) (ASTM D 1586) and split- spoon sampling will be performed at 2.5-foot to 5-foot increments using an 18-inch split-spoon sampler. The sampler will be decontaminated with a non-phosphate detergent wash between sampling depths. Ash and soil samples will be collected by the Project Scientist/Engineer. Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin ASSESSMENT WORK PLAN 10 Borings will be logged by the Project Scientist/Engineer and ash/soil samples will be observed, visually classified, and photographed in the field for origin, consistency/relative density, color, and soil type in accordance with the Unified Soil Classification System (ASTM D2487/D2488). Samples will be identified with a unique boring number and approximate collection depth (e.g., AB-1 (20’-25’)). Sample containers will be provided by HDR’s contracted laboratory prior to commencement of the on-site investigation. Samples will be delivered to the analytical laboratory in time to extract the samples within their specified hold times (to be provided by the laboratory). HDR will provide the name, phone number, and email address of the laboratory project manager to facilitate sample analysis coordination. Laboratory constituents and methods for analysis of environmental ash and soil samples are presented in Table 5. Boring locations will be surveyed for horizontal and vertical control upon completion of the field exploration program. 7.1.2 Proposed Soil and Ash Sampling Locations and Depths HDR anticipates collection of soil and ash samples for laboratory analysis at eight locations within the Primary and Secondary Cells and on the impoundment and divider berms (designated as AB-1 through AB-8), three locations within the dry ash storage area (designated as AS-2, AS-4, and AS-6), and two locations within the cinder storage area (designated as C-11 and C- 12). The borings located within the ash basin, dry ash storage area, and cinder storage area (i.e., within the waste boundary) will extend approximately 20 feet below the ash/native soil interface, or to auger refusal, whichever is encountered first. In addition, HDR anticipates collection of soil samples at six background locations (designated as BG-series wells). Soil samples will not be collected for laboratory analysis during installation of monitoring wells located outside the waste boundary (designated as GWA-series wells). Proposed boring locations are shown on Figure 3. CONSTITUENT SAMPLING AND ANALYSES In general, ash is expected to be encountered in AB-series, AS-series, and C-series borings. Ash samples will be collected from shallow and deeper vertical intervals to evaluate variations in type (e.g., fly ash or bottom ash) and chemical profile of the ash. In general, shallow ash samples will be collected from the 4-foot to 5-foot intervals and deeper ash samples will be collected from the 1-foot to 2-foot intervals overlying the ash/native soil interface. The depth of deeper ash samples is expected to vary based on ash thickness at each specific boring location. Ash samples will be analyzed by HDR’s subcontract laboratory for total and leachable inorganic compounds as presented in Table 5. Soil samples will be collected immediately below the ash/native soil interface and from the terminus of each boring to characterize soil quality beneath the ash management areas. Soil samples will be analyzed by HDR’s subcontract laboratory for total inorganics using the same constituents’ list proposed for the ash samples. Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin ASSESSMENT WORK PLAN 11 INDEX PROPERTY SAMPLING AND ANALYSES Physical characteristics of ash and soil will be tested both in the field and in the laboratory to provide data for use in groundwater modeling. The location and depth of the index property samples will be based on site-specific geology and decided upon in the field. Based on HDR’s current understanding of site-specific geology, five hydrostratigraphic units are present on-site. In general, a minimum of five in-situ permeability tests, either falling or constant head tests, will be performed in each of the hydrostratigraphic units. In addition, a minimum of five packer tests will be performed in bedrock. Laboratory testing of soil and ash collected from SPT samples will include tests for grain size (with hydrometer), specific gravity, and porosity (calculation). 7.2 Groundwater Sampling Plan Groundwater samples will be collected from the proposed wells shown on Figure 3. Groundwater quality data may be supplemented through evaluation of historical data or re- sampling of select existing monitoring wells. The purpose and anticipated construction details of the proposed monitoring wells are as follows:  AB-series Wells – One shallow well screened across the water table (15-foot well screen) and one deep well with screen installed in the transition zone (5-foot well screen in weathered rock below auger refusal) will be installed at each location. The AB-series well locations were selected to provide water quality data in and beneath the ash basin.  AS-series Wells – One shallow well screened across the water table (15-foot well screen) and one deep well with screen installed in the transition zone (5-foot well screen in weathered rock below auger refusal) will be installed at each location. The AS-series well locations were selected to provide water quality data in and beneath the dry ash storage area.  C-series Wells – One shallow well screened across the water table (15-foot well screen) and one deep well with screen installed in the transition zone (5-foot well screen in weathered rock below auger refusal) will be installed at each location. The C-series well locations were selected to provide water quality data in and beneath the cinder storage area.  GWA-series Wells – One shallow well screened across the water table (15-foot well screen) and one deep well with screen installed in the transition zone (5-foot well screen in weathered rock below auger refusal) will be installed at each location. The GWA- series well locations were selected to provide water quality data beyond the waste boundary for use in groundwater modeling (i.e., to evaluate the horizontal and vertical extent of potentially impacted groundwater around the waste boundary).  OB-series wells – The observation wells (OB-1 and OB-2) will be installed with 20-foot screens (across the water table) and will be used for measuring water levels only (no water quality samples). The OB’s will be installed between the ash basin and the current site background monitoring well pair MW -7SR/D. The purpose of these OB’s is to characterize groundwater flow in the region between the ash basin and the background monitoring wells MW -7SR/D. In addition, monitoring well GWA-7S will be utilized as an Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin ASSESSMENT WORK PLAN 12 observation well in conjunction with OB-1 and OB-2 in order to characterize groundwater flow. Note that monitoring well GWA-7S will be installed to replace the proposed observation well OB-3, which was included in Duke Energy’s NPDES permit renewal application dated May 15, 2014.  BG-series wells – Three nested well pairs (shallow and deep) and three shallow wells will be installed as described below.  BG-25S/D – One shallow well screened across the water table (15-foot well screen) and one deep well with screen installed in the transition zone (5-foot well screen in partially weathered rock below auger refusal). This location was selected to approximate the conditions of MW -13 (well screened in region with similar hydrogeologic conditions- close to river/lake) with respect to redox conditions and will be used to evaluate the groundwater exceedances measured in MW -13. This location will also provide additional physical separation from possible influence of the ash basin on groundwater.  BG-51S/D – One shallow well screened across the water table (15- to 20-foot well screen) and one deep well with screen installed in the transition zone (5-foot well screen in partially weathered rock below auger refusal). This location was selected to provide additional physical separation from possible influence of the ash basin on groundwater. The well pair will be located approximately mid-way between proposed background well pair location, BG-25S/D, and proposed background well pair location, BG-21S/D. These wells will also be useful in the statistical analysis to determine the site-specific background water quality concentrations (SSBCs) and in characterizing shallow and deep groundwater flow in the region between the BG-25 S/D and BG-21S/D background well pairs.  BG-21S/D – One shallow well screened across the water table (15-foot to 20-foot well screen) and one deep well with screen installed in the transition zone (5-foot well screen in partially weathered rock below auger refusal). This location was selected to provide additional physical separation from possible influence of the ash basin on groundwater. This well pair will be located approximately 1,600 feet southeast of the ash basin and east of the existing background well pair location, MW-7SR/D. These wells will also be useful in the statistical analysis to determine the SSBCs.  BG-55S, -81S, and -85S – Three shallow wells screened across the water table (15-foot to 20-foot well screens). These locations were selected to facilitate evaluation of local groundwater flow conditions in the vicinity of MW -8. More specifically, data obtained from these wells will be used to evaluate potential hydraulic mounding from the ash basins. 7.2.1 Well Installation and Development SHALLOW MONITORING WELLS At each monitoring well location specified on Figure 3 with an “S” qualifier in the well name (e.g., MW -5S), a shallow well will be constructed with a 2-inch-diameter, schedule 40 PVC screen and casing. Each of these wells will have a 15-foot well screen (0.010-slot) set to bracket the water table at the time of installation. Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin ASSESSMENT WORK PLAN 13 DEEP MONITORING WELLS At each monitoring well location specified on Figure 3 with a “D” qualifier in the well name (e.g., MW -5D), a double-cased deep 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 restrict vertical mixing 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 partially weathered rock (PWR). Note that location- specific subsurface geology will dictate actual casing depths on a per-well basis. Air rotary drilling will be used to advance the borehole a minimum of 10 feet into PWR or bedrock with the intent of setting a 5-foot well screen at least 10 feet below the bottom of the outer casing. All newly installed monitoring wells will be developed using appropriate measures (e.g., agitation, surging, pumping, etc.). Water quality parameters (specific conductance, pH, temperature 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 (target < 50 Nephelometric Turbidity Units (NTU) Turbidity) and sediment free. 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. 7.2.2 Hydrogeologic Evaluation Hydraulic conductivity (slug) tests will be completed in select monitoring wells under the direction of the Project Scientist/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. In addition, approximately 5 to 10 packer tests will be conducted during installation of the Type III wells to facilitate permeability testing of the upper five feet of rock. 7.2.3 Groundwater Sampling Subsequent to monitoring well installation and development, each newly installed well will be sampled using low-flow sampling techniques. 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 oxidation reduction potential (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. Groundwater samples will be analyzed by a North Carolina certified laboratory for the constituents included in Table 6. Select constituents may be analyzed for total and dissolved concentrations. Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin ASSESSMENT WORK PLAN 14 7.3 Surface Water Sampling Plan 7.3.1 Ash Basin Surface Water Samples Surface water samples will be collected from the ash basin at one open water location near the discharge tower. Samples will be collected approximately 3 feet below the surface and at a depth of approximately 15 feet. Ash basin surface water samples will be analyzed for the same constituents as groundwater samples (Table 6). Select constituents may be analyzed for total and dissolved concentrations. 7.3.2 Seep Samples Water samples will be collected from the seep sample locations shown on Figure 3. The seep samples will be collected for laboratory analysis of the constituents listed in Table 6. Select constituents may be analyzed for total and dissolved concentrations. Duke Energy collects surface water samples from Mountain Island Lake from upstream and downstream locations for existing RBSS NPDES permit requirements. If seep analytical results indicate potential for impacts to Mountain Island Lake, then surface water quality data collected in Mountain Island Lake will be reviewed. 7.4 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 a site hydrogeologic conceptual model (SCM). The NCDENR document, “Hydrogeologic Investigation and Reporting Policy Memorandum,” dated May 31, 2007 (Reference 6), will be used as general guidance. In general, the SCM will utilize site information to characterize the geologic and hydrogeologic characteristics of the area of interest, and, where appropriate, lead directly to the proper construction of a groundwater flow and transport model. 7.5 Site-Specific Background Concentrations Statistical analysis will be performed to determine the SSBCs to assess whether or not the 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. 7.6 Groundwater Model Groundwater flow and chemical constituent fate and transport at the site will be modeled in three dimensions using the MODFLOW -2005 groundwater flow numeric engine and the MT3D transport model with linear isotherm sorption to predict chemical constituent concentrations over time at the compliance boundary. The groundwater model layers will be developed based on hydrogeologic properties and other data obtained during the site investigation and the site hydrogeologic conceptual model. The model will include the effects of recharge from precipitation. Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin ASSESSMENT WORK PLAN 15 Site soil samples will be collected and used to develop site-specific distribution coefficient, Kd, terms using batch methods (“US EPA Batch-type procedures for estimating soil adsorption of chemicals Technical Resource Document 530/SW-87/006-F”). The selection of the initial concentrations and the predictions of the concentrations for constituents with respect to time are to be developed with consideration of the following data:  Site-specific analytical results from leach tests and from total digestion of ash samples taken at varying locations and depths within the ash basin and ash storage piles (if present),  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), and  Published or other data on sequential leaching tests performed on similar ash. The groundwater modeling will be conducted in general with the requirements of the May 31, 2007, NCDENR Memorandum titled, “Groundwater Modeling Policy.” The groundwater model and the report on the results of the groundwater modeling will be prepared by Dr. William Langley, P.E., Department of Civil and Environmental Engineering, University of North Carolina at Charlotte. Dr. Langley will perform the work under contract with HDR, and the groundwater model report will be included as an attachment to the CSA. The groundwater model will be used, as required, to evaluate options for potential corrective action in the subsequent phase of work. Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin PROPOSED SCHEDULE 16 8.0 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 Start Date Duration to Complete Field Exploration Program 10 days following Work Plan approval 75 days Receive Laboratory Data 14 days following end of Exploration Program 15 days Evaluate Lab/Field Data, Develop SCM 5 days following receipt of Lab Data 30 days Prepare and Submit CSA 10 days following Work Plan approval 170 days Duke Energy Carolinas, LLC | Proposed Groundwater Assessment Work Plan Riverbend Steam Station Ash Basin REFERENCES 17 9.0 References 1. Fenneman, Nevin Melancthon. “Physiography of eastern United States.” McGraw-Hill. 1938. 2. Goldsmith, R., Milton, D. J. and Horton, J. W., Jr. 1988. Geologic map of the Charlotte 1o x 2o quadrangle, North Carolina and South Carolina: United States Geological Survey, Miscellaneous Investigations Series, Map I-1251-E, scale 1:250,000. 3. Groundwater Assessment, Duke Energy Carolinas, LLC, Riverbend Steam Station Ash Basin, NPDES Permit NC0004961, May 31, 2013. 4. 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. 5. NCDENR Memorandum “Performance and Analysis of Aquifer Slug Tests and Pumping Tests Policy,” May 31, 2007. 6. NCDENR document, “Hydrogeologic Investigation and Reporting Policy Memorandum”, dated May 31, 2007. 7. North Carolina Geological Survey, 1985, Geologic map of North Carolina: North Carolina Geological Survey, General Geologic Map, scale 1:500000. 8. Pippin, C.G., Chapman, M.J., Huffman, B.A., Heller, M.J., and Schelgel, M.E., 2008, Hydrogeologic setting, ground-water flow, and ground-water quality at the Langtree Peninsula research station, Iredell County, North Carolina, 2000–2005: U.S. Geological Survey Scientific Investigations Report 2008–5055, 89 p. (available online at http://pubs.water.usgs.gov/sir2008–5055). 9. US EPA Batch-type procedures for estimating soil adsorption of chemicals TechnicalResource Document 530/SW -87/006-F. Figures DRAFT - A s a � t i LEGEND: DUKE ENERGY PROPERTY BOUNDARY _ - ASH BASIN COMPLIANCE BOUNDARY jy- - ASH BASIN COMPLIANCE BOUNDARY COINCIDENT _ - - - WITH DUKE ENERGY PROPERTY BOUNDARY sY' ASH BASIN WASTE BOUNDARY ASH OR CINDER STORAGE AREA BOUNDARY :A ;...— — — — — — — — — — — TOPOGRAPHIC CONTOUR (4 FOOT) ',y�'•'i . ,-�,',� � � � A - � • 0 • J` ASH BASIN COMPLIANCE GROUNDWATER • a !fe . J MONITORING WELL LOCATION "� /' c•.p •f•i. ,-�'��' STREAM ' lam• �?' 9y t . - P a PIN 19 .lf Is �z FBI • � ff ` a., �, '�'�.. f •1 "_'`r�l rtd£7 �•�. ��. y � -' � � �+ ,fir..' a �. f'C -. 1 .'1r,k�c e,�,•��iep'�. � � _ • �`• � �-I �'. -a fir. s .� c. t �`" r•� 't—,' r' .� � 7y. ,..f,t - '�• ,,� - - -.S �' � fix NOTES: 1. PARCEL DATA FOR THE SITE WAS OBTAINED FROM DUKE ENERGY REAL ESTATE AND IS APPROXIMATE. SCALE (FEET) SITE LAYOUT MAP DATE 2. ASH STORAGE BOUNDARY AND CINDER STORAGE BOUNDARY ARE APPROXIMATE. 0 S00' E,99' 3. AS -BUILT MONITORING WELL LOCATIONS PROVIDED BY DUKE ENERGY. /" = 600' ®_ _ DUKE ENERGY CAROLI NAS, LLC 9/25/2014 4. SHALLOW MONITORING WELLS (S) - WELL SCREEN INSTALLED ACROSS THE SURFICIAL WATER TABLE. ® RIVERBEND STEAM STATION FIGURE 5. DEEP MONITORING WELLS (D) - WELL SCREEN INSTALLED 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. N PD ES PERMIT I\I O. I\I C 0004961 7. ORTHOPHOTOGRAPHY WAS OBTAINED FROM WSP (DATED APRIL 2014). — 2 8. THE COMPLIANCE BOUNDARY IS ESTABLISHED ACCORDING TO THE DEFINITION FOUND IN 15A NCAC 02L.0107 (a). GASTON COUNTY, NORTH CAROLINA ev— ASH STORAG TV v °.� n r.. e•• ' X PIN BG-81S WA-4S/D Al 3G-8SS '44, F/ c- le NOTES: 1. PARCEL DATA FOR THE SITE WAS OBTAINED FROM DUKE ENERGY REAL ESTATE AND IS APPROXIMATE. SCALE (FEET) 2. ASH STORAGE BOUNDARY AND CINDER STORAGE BOUNDARY ARE APPROXIMATE. 0 100' 600 3. AS -BUILT MONITORING WELL LOCATIONS PROVIDED BY DUKE ENERGY. 4. SHALLOW MONITORING WELLS (S) - WELL SCREEN INSTALLED ACROSS THE SURFICIAL WATER TABLE. /" = 600' 5. DEEP MONITORING WELLS (D) - WELL SCREEN INSTALLED 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. 7. ORTHOPHOTOGRAPHY 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 WELL LOCATIONS ARE APPROXIMATE AND MAY BE ADJUSTED DUE TO FIELD CONDITIONS. 10. SEEP SAMPLING LOCATIONS WERE OBTAINED BY HDR USING A TRIMBLE HANDHELD GPS UNIT ON APRIL 29, 2014. * INDICATES SEEP SAMPLING LOCATIONS WERE NOT RECORDED WITH GPS UNIT AND ARE APPROXIMATE. r... e... ..: LEGEND: �r is • DUKE ENERGY PROPERTY BOUNDARY ASH BASIN COMPLIANCE BOUNDARY - ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY ASH OR CINDER STORAGE AREA BOUNDARY t - - - . - TOPOGRAPHIC CONTOUR (4 FOOT) ASH BASIN COMPLIANCE GROUNDWATER - MONITORING WELL LOCATION ASH BASIN VOLUNTARY GROUNDWATER MONITORING WELL LOCATION IRSESHOE PROPOSED GROUNDWATER MONITORING WELL REND RAROAD LOCATION PROPOSED OBSERVATION WELL LOCATION • PROPOSED SURFACE WATER SAMPLE LOCATION • SEEP SAMPLE LOCATION ,•' .���������. STREAM PROPOSED WELL AND SAMPLE LOCATIONS DATE DUKE ENERGY CAROLINAS, LLC 9/25/2014 RIVERBEND STEAM STATION FIGURE NPDES PERMIT NO. NC0004961 3 GASTON COUNTY, NORTH CAROLINA Tables TABLE 1 – GROUNDWATER MONITORING REQUIREMENTS Well Nomenclature Constituents and Parameters Frequency Monitoring Wells: MW-7SR, MW-7D, MW-8S, MW-8I, MW- 8D, *MW-9, *MW-10, MW- 11SR, MW-11DR, *MW-13, MW-14, MW-15 Antimony Chromium Nickel Thallium February, June, October Arsenic Copper Nitrate Water Level Barium Iron pH Zinc Boron Lead Selenium Cadmium Manganese Sulfate Chloride Mercury TDS Note: Monitoring wells marked with * are located inside of the compliance boundary. TABLE 2 – MONITORING WELL LOCATIONS Monitoring Well Locations Monitoring Well At or Near the Compliance Boundary MW -7SR, MW -7D, MW -8S, MW -8I, MW -8D, MW -11SR, MW -11DR, MW -14, MW -15 Inside of the Compliance Boundary MW -9, MW -10, MW -13 TABLE 3 – EXCEEDANCES OF 2L STANDARDS DECEMBER 2010 – JUNE 2014 Parameter Iron Manganese pH Antimony Units µg/L µg/L SU µg/L 2L Standard 300 50 6.5 - 8.5 1 Well ID Range of Exceedances MW-7SR 445 – 790 67 – 413 5.0 – 5.4 No Exceedances MW-7D No Exceedances No Exceedances 5.5 – 5.8 1.04 MW-8S No Exceedances 68 – 144 4.3 – 5.2 No Exceedances MW-8I 436 – 976 52 – 290 5.7 – 6.4 No Exceedances MW-8D 777 – 4,160 82 – 671 6.3– 6.5 No Exceedances MW-9* 341 – 1,950 62 – 147 5.8 – 6.4 No Exceedances MW-10* 310 – 1,420 67 – 355 4.8 – 5.4 No Exceedances MW-11SR 486 59 - 384 5.6 – 6.1 No Exceedances MW-11DR No Exceedances 51 – 168 5.6 - 5.8 No Exceedances MW-13* 7,690– 37,700 8,070 – 11,200 5.8 – 6.4 No Exceedances MW-14 371 – 935 55 – 353 No Exceedances No Exceedances MW-15 399 52 – 86 5.1 – 5.3 No Exceedances Note: Monitoring wells marked with * are located inside of the compliance boundary. TABLE 4 – ENVIRONMENTAL EXPLORATION AND SAMPLING PLAN Exploration Area Soil Borings Shallow Monitoring Wells Deep Monitoring Wells Surface Water Boring IDs Quantity Estimated Boring Depth (ft bgs) Well IDs Quantity Estimated Well Depth (ft bgs) Screen Length (ft) Well IDs Quantity Estimated Casing Depth (ft bgs) Estimated Well Depth (ft bgs) Screen Length (ft) Quantity of Locations Quantity of Samples Ash Basin AB-1 through AB-8 8 75 AB-1S through AB-8S 8 30-50 15 AB-1D through AB-8D 8 40-60 55-75 5 2 4 Ash Storage / Cinder Storage AS-2, AS-4, AS-6, C-11, and C-12 5 80 AS-2S, AS-4S, AS-6S, C-11S, and C-12S 5 30-80 15 AS-2D, AS-4D, AS-6D, C-11D, and C-12D 5 40-90 55-105 5 N/A N/A Beyond Waste Boundary N/A 0 N/A GWA-1S through GWA-10S 10 15-45 10-15 GWA-1D through GWA-10D 10 25-125 40-140 5 N/A N/A Background BG-21, BG-25, BG-51, BG-55, BG-81, BG-85 6 30-100 BG-21S, BG- 25S, BG-51S, BG-55S, BG- 81S, BG-85S 6 20-60 15 BG-21D, BG-25D, BG-51D 3 30-125 45-140 5 N/A N/A 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 constitu ents 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, down hole 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 specifica tions. TABLE 5 – SOIL AND ASH PARAMETERS AND ANALYTICAL METHODS INORGANIC COMPOUNDS UNITS METHOD Antimony mg/kg EPA 6020 Arsenic mg/kg EPA 6020 Barium mg/kg EPA 6010 Boron mg/kg EPA 6010 Cadmium mg/kg EPA 6020 Chloride mg/kg SM4500-Cl-E Chromium mg/kg EPA 6010 Copper mg/kg EPA 6010 Iron mg/kg EPA 6010 Lead mg/kg EPA 6020 Manganese mg/kg EPA 6010 Mercury mg/kg EPA Method 7470A/7471 Nickel mg/kg EPA 6010 pH SU EPA 9045 Selenium mg/kg EPA 6020 Thallium (low level) mg/kg EPA 6020 Zinc mg/kg EPA 6010 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. TABLE 6 – GROUNDWATER, SURFACE WATER, AND SEEP PARAMETERS AND ANALYTICAL METHODS PARAMETER UNITS METHOD FIELD PARAMETERS pH SU Field Water Quality Meter Specific Conductance mmho/cm Field Water Quality Meter Temperature ºC Field Water Quality Meter Dissolved Oxygen mg/L Field Water Quality Meter Oxidation Reduction Potential mV Field Water Quality Meter NPDES CONSTITUENTS Antimony µg/L EPA 200.8 or 6020 Arsenic µg/L EPA 200.8 or 6020 Barium µg/L EPA 200.7 or 6010 Boron µg/L EPA 200.7 or 6010 Cadmium µg/L EPA 200.8 or 6020 Chloride mg/L EPA 300.0 Chromium µg/L EPA 200.7 or 6010 Copper mg/L EPA 200.7 or 6010 Iron µg/L EPA 200.7 or 6010 Lead µg/L EPA 200.8 or 6020 Manganese µg/L EPA 200.7 or 6010 Mercury µg/L EPA 245.1 Nickel µg/L EPA 200.7 or 6010 Nitrate as Nitrogen mg-N/L EPA 300.0 Selenium µg/L EPA 200.8 or 6020 Sulfate mg/L EPA 300.0 Thallium (low level) µg/L EPA 200.8 or 6020 Total Dissolved Solids mg/L EPA 160.1 or SM 2540C Zinc mg/L EPA 200.7 or 6010 ADDITIONAL GROUNDWATER CONSTITUENTS Alkalinity (as CaCO3) mg/L SM2320B Calcium mg/L EPA 200.7 Ferrous Iron mg/L SM4500-Fe Magnesium mg/L EPA 200.7 Potassium mg/L EPA 200.7 Sodium mg/L EPA 200.7 Sulfide mg/L SM4500S-F Total Organic Carbon mg/L SM5310 Notes: 1. Select constituents may be analyzed for total and dissolved concentrations. 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. 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: 919-807-64641 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 (919) 807-6351. 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 (919) 707-9083; • 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