NC0003425_Roxboro GW Assessment Work Plan_20140901

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GROUNDWATER ASSESSMENT
WORK PLAN
FOR
ROXBORO STEAM ELECTRIC PLANT
1700 DUNNAWAY ROAD
SEMORA, NORTH CAROLINA 27343
NPDES PERMIT ##NC0003425
N 36.484825/W-79.072315
PREPARED FOR
DUKE ENERGY PROGRESSi, INC.
410 S. WILMINGTON STREET/NC14
RALEIGHl NORTH CAROLINA 27601
DUKE
ENERGY.
PROGRESS
SUBMITTED: SEPTEMBER 2014
PREPARED BY
SYNTERRA
148 RIVER STREET
GREENVILLE0, SOUTH CAROLINA �-
(864) 421- 9999 so "44
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Pro a eologist
W. othy Webp, NC PG 1328
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INNOVATE 148 River Street, Suite 220 Greenville, SC 29601 [phone] Fax [phone] www.synterracorp.com

Groundwater Assessment Work Plan September 2014
Roxboro Steam Electric Plant SynTerra
TABLE OF CONTENTS
SECTION PAGE
Executive Summary
1.0
Introduction.....................................................................................................................1
2.0
Site History and Source Characterization.................................................................. 3
2.1
Plant Description........................................................................................................ 3
2.2
Ash Management Areas............................................................................................ 3
2.3
Groundwater Monitoring System........................................................................... 4
3.0
Receptor Information..................................................................................................... 6
4.0
Regional Geology and Hydrogeology........................................................................ 8
5.0
Site Geology and Hydrogeology................................................................................10
6.0
Groundwater Monitoring Results.............................................................................11
6.1
Groundwater Analytical Results...........................................................................11
6.2
Preliminary Statistical Evaluation Results...........................................................11
7.0
Assessment Work Plan.................................................................................................13
7.1
Anticipated Ash Basin Boring Locations..............................................................
13
7.2
Anticipated Soil Boring Locations.........................................................................
14
7.2.1 Inside Ash Basins...............................................................................................
14
7.2.2 Outside Ash Basins............................................................................................14
7.3
Anticipated Sediment and Surface Water Locations..........................................14
7.4
Anticipated Groundwater Monitoring Wells and Piezometers ........................15
7.4.1 General Construction, Development, Aquifer Testing .................................
15
7.4.2 Background Wells..............................................................................................
16
7.4.3 Ash Basins Area.................................................................................................
17
7.4.4 Downgradient Assessment Areas...................................................................
17
7.4.5 Groundwater Sampling....................................................................................18
7.5
Influence of Pumping Wells on Groundwater System.......................................18
7.6
Site Conceptual Model............................................................................................18
7.7
Development of Groundwater Computer Model...............................................18
8.0
Implementation Schedule and Report Submittal ...................................................
20
9.0
References.......................................................................................................................22
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Groundwater Assessment Work Plan September 2014
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List of Figures
Figure 1 — Site Location Map
Figure 2 — Site Layout
Figure 3 — Geology Map
Figure 4 — Anticipated Sample Locations
List of Tables
Table 1 — Summary of Concentration Ranges for Constituents Detected Greater than
21, Standards
Table 2 — Groundwater Assessment Parameter List
Table 3 — Assessment Sampling Plan
List of Appendices
Appendix A — NCDENR Letter of August 13, 2014
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Groundwater Assessment Work Plan September 2014
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EXECUTIVE SUMMARY
Duke Energy Progress, Inc. (Duke Energy) owns and operates the Roxboro Steam
Electric Plant (Roxboro Plant) located near Semora, in Person County, North Carolina.
The Roxboro Plant began operations in the 1960s and continued to add capacity
through the 1980s. Currently, the Plant operates four coal-fired units. Coal combustion
residues (CCR) have historically been managed at the Plant's on -site ash basins: the
semi -active East Ash Basin (operated from the mid-1960s to present) and the active
West Ash Basin (operated from the early 1970s to present).
Wastewater discharges from the ash basins is permitted by the North Carolina
Department of Environment and Natural Resources (NCDENR) Division of Water
Resources (DWR) under National Pollution Discharge Elimination System (NPDES)
Permit NC0003425.
In a letter dated August 13, 2014, the DWR requested that Duke Energy prepare a
Groundwater Assessment Plan to identify the source and cause of contamination, any
imminent hazards to public health and safety, all receptors and significant exposure
pathways for the site. In addition, the plan should be designed to determine the
horizontal and vertical extent of soil and groundwater contamination and all significant
factors affecting contaminant transport and the geological and hydrogeological features
influencing the movement, chemical, and physical character of the contaminants.
The following assessment plan anticipates:
• Implementation of a receptor survey to identify public and private water supply
wells (including irrigation wells and unused or abandoned wells), surface water
features, and wellhead protection areas (if present) within a 0.5 mile radius of the
Roxboro Plant compliance boundary;
• Installation of borings within the ash basins for chemical and geotechnical analysis
of residuals and in -place soils;
• Installation of background soil borings;
• Installation of monitoring wells and piezometers;
• Collection and analysis of groundwater samples from existing site wells and newly
installed monitoring wells;
• Statistical evaluation of groundwater analytical data; and
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• Development of a groundwater model to evaluate the long term fate and transport
of constituents of concern in groundwater associated with the ash management
units.
The information obtained through this Work Plan will be utilized to prepare a
Comprehensive Site Assessment (CSA) report in accordance with the Notice of
Regulatory Requirements (NORR). In addition to the components listed above, a
human health and ecological risk assessment will be conducted. This assessment will
include the preparation of a conceptual site model illustrating potential pathways from
the source to possible receptors.
During the CSA process if additional investigations are required NCDENR, will be
notified.
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Groundwater Assessment Work Plan
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1.0 INTRODUCTION
Duke Energy Progress, Inc. (Duke Energy) owns and operates the Roxboro Steam
Electric Plant (Roxboro Plant) located near Semora, in Person County, North Carolina
(Figure 1). The Roxboro Plant began operations in the 1960s and continued to add
capacity through the 1980s. Currently, the Plant operates four coal-fired units.
Coal combustion residues (CCR) have historically been managed at the Plant's on -site
ash basins: the semi -active East Ash Basin (operated from the mid-1960s to present)
and the active West Ash Basin (operated from the early 1970s to present; Figure 2). An
unlined landfill was constructed on top of the semi -active East Ash Basin in the late
1980s for the placement of dry fly ash (DFA). A lined landfill was constructed over the
unlined landfill around 2004. The discharges from the ash basins are permitted by the
North Carolina Department of Environment and Natural Resources (NCDENR)
Division of Water Resources (DWR) under the National Pollution Discharge
Elimination System (NPDES).
Groundwater monitoring has been performed in accordance with the conditions of
NPDES Permit #NC0003425. The current groundwater compliance monitoring plan for
the Roxboro Plant includes the sampling of eight (8) wells. These eight wells include
one background well and seven (7) downgradient wells.
In addition to the eight wells monitored as part of the NPDES permit, the Roxboro Plant
samples six monitoring wells and collects landfill leachate samples from four locations
associated with the lined DFA landfill in accordance with a permit issued by
NCDENR's Solid Waste Section.
The compliance boundary for the Plant is defined in accordance with NCAC Title 15A
Chapter 02L.0107(a) as being established at either 500 feet from the waste boundary or
at the property boundary.
In a Notice of Regulatory Requirement (NORR) letter dated August 13, 2014, the DWR
of the NCDENR requested that Duke Energy prepare a Groundwater Assessment Plan
to conduct a Comprehensive Site Assessment (CSA) in accordance with 15A NCAC 02L
.0106(g) to address groundwater constituents that have been detected at elevated levels
greater than the 21, Standard at the compliance boundary. A summary of these
constituents is provided in Table 1 and a copy of the DWR letter is provided in
Appendix A.
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SynTerra has prepared this Groundwater Assessment Work Plan on behalf of Duke
Energy to fulfill the DWR letter request and to satisfy the requirements of NC Senate
Bill 729 as ratified August 2014.
Specifically, this document describes the plans to meet the requirements of 15A NCAC
02L .0106(g) including;
• Identify the source and cause of contamination;
• Identify any imminent hazards to public health and safety and actions taken to
mitigate them in accordance to 15A NCAC 02L .0106(f);
• Identify receptors and significant exposure pathways;
• Determine the horizontal and vertical extent of soil and groundwater
contamination and significant factors affecting contaminant transport; and
• Determine geological and hydrogeological features influencing the movement,
chemical, and physical character of the contaminants.
The information obtained through this Work Plan will be utilized to prepare a CSA
report in accordance with the requirements of the NORR. In addition to the
components listed above, a human health and ecological risk assessment will be
conducted. This assessment will include the preparation of a conceptual site model
illustrating potential pathways from the source to possible receptors.
During the CSA process if additional investigations are required, NCDENR will be
notified.
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2.0 SITE HISTORY AND SOURCE CHARACTERIZATION
2.1 Plant Description
Duke Energy Progress, Inc. owns and operates the Roxboro Plant located in north -
central North Carolina near Semora, North Carolina. A large part of the Plant area
encompasses Hyco Lake. The Roxboro Plant is located in Person County along the east
bank of Hyco Lake north of Roxboro, NC and west of McGhees Mill Road. The site
location is shown on Figure 1.
The Roxboro Plant began operations in the 1960s and continued to add capacity
through the 1980s. The Roxboro Plant uses coal-fired units to produce steam. Ash
generated from coal combustion has been stored on -site in ash basins.
The Plant is located on Dunnaway Road, approximately 10 miles northwest of the city
of Roxboro, North Carolina. The Plant is situated on the south side of Hyco Lake, a lake
formed from the impoundment of the Hyco River. The Plant property is roughly
bounded by Hyco Lake to the north and west, NC Highway 57 (Semora Road) to the
south and west, and State Highway 1336 (McGhees Mill Road) to the east. The overall
topography of the Plant generally slopes toward the north (Hyco Lake).
2.2 Ash Management Areas
Ash generated from coal combustion has been stored in on -site ash basins and lined
landfill. Ash has been sluiced to the ash basins or conveyed in its dry form to the lined
landfill. Two ash basins areas have been used at the Roxboro Plant and are referenced
using the date of construction and relative location: the 1966 semi -active East Ash Basin
and the 1973 active West Ash Basin. The East Ash Basin is located southeast of the
plant, and the West Ash Basin is located south of the plant. An unlined landfill was
constructed on the East Ash Basin in the late 1980s. A lined landfill was subsequently
constructed over the unlined landfill around 2004.
The ash basins are impounded by earthen dams. Surface water runoff from the East
Ash basin and the lined landfill are routed into the West Ash Basin to allow settling. A
500-foot compliance boundary encircles both ash basins. The ash basins are indicated
on Figure 2.
Currently, the East Ash Basin and lined landfill are covered with vegetation where the
landfill is not active (grasses and shrubs). The West Ash Basin has some grass cover
and ponded water, mostly along the southern and eastern edges of the basin.
Wastewater discharges from the facility are permitted by the North Carolina
Department of Environment and Natural Resources (NCDENR) Division of Water
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Resources (DWR) under National Pollution Discharge Elimination System (NPDES)
Permit NC0003425.
2.3 Groundwater Monitoring System
The current groundwater compliance monitoring program for the Roxboro Plant
includes the sampling of eight wells surrounding the compliance boundary. These
eight wells include one background well and seven downgradient wells. The locations
of the monitoring wells, the waste boundary, and the compliance boundary are shown
on Figure 2.
In addition to the eight wells monitored as part of the NPDES permit, the Roxboro Plant
samples six monitoring wells and collects landfill leachate samples from four locations
associated with the active lined landfill in accordance with a permit issued by
NCDENR's solid waste section. The locations of landfill monitoring points are shown
on Figure 2.
The compliance monitoring network includes one background monitoring well, BG-1,
plus seven monitoring wells located in side -gradient and downgradient positions along
the compliance boundary.
The monitoring network at the lined landfill includes six monitoring wells located in
side gradient and down gradient positions as permitted by NCDENR's solid waste
section. Semi-annual groundwater monitoring is conducted for the landfill monitoring
wells. Groundwater analytical results from these monitoring events will be reviewed
and included in the assessment.
Wells CW-3D and CW-4D were installed in the upper bedrock and were paired with
shallow wells CW-3 and CW-4, which were installed above the bedrock, to monitor the
vertical hydraulic gradient in the area and aquifer conditions within the shallow
bedrock. The remainder of the compliance boundary wells were installed in the
saprolite or residuum, above bedrock.
In accordance with the current NPDES permit, the ash basins compliance monitoring
wells are sampled three times per year in April, July, and November. The analytical
results for the compliance monitoring program are compared to the 21, Standards or
site -specific background concentrations. A summary of the NPDES monitoring
requirements is provided below.
It is proposed that monitoring for aluminum be discontinued. Aluminum is a very
common, naturally -occurring element in soil and rocks of the area. A preliminary
statistical evaluation indicates that aluminum concentrations in downgradient
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compliance monitoring wells are not statistically significant increases (SSIs) over the
background well data set for the most recent sampling event. Further, aluminum is not
consistently monitored across the entirety of Duke Energy facilities, and there is no 2L
Standard for aluminum.
NPDES Groundwater Monitoring Requirements
Well
Nomenclature
Parameter Description
Frequency
Monitoring
Aluminum
Chloride
Mercury
TDS
Wells CW-1,
Antimony
Chromium
Nickel
Thallium
CW-2, CW-2D,
Arsenic
Copper
Nitrate
Zinc
April, July,
CW-3, CW-3D,
Barium
Iron
pH
November
CW-4, CW-5,
Boron
Lead
Selenium
BG-1
Cadmium
Manganese
Sulfate
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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, SynTerra is in the process of
completing a receptor survey for the Roxboro Plant to identify all receptors within a 0.5-
mile radius (2,640 feet) of the Roxboro Plant ash basin compliance boundary. The
compliance boundary for groundwater quality, in relation to the ash basin, is defined in
accordance with 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
receptors include 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
Roxboro Plant ash basin compliance boundary.
The survey consists of a review of publicly available data from NCDENR Department
of Environmental Health (DEH), NC OneMap GeoSpatial Portal, DWR Source Water
Assessment Program (SWAP) online database, county GIS, Environmental Data
Resources, Inc. (EDR) Records Review, the USGS National Hydrography Dataset
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(NHD), as well as a vehicular survey along public roads located within 0.5 mile radius
of the compliance boundary.
Additional receptor information will be collected as part of the anticipated assessment
to comply with the CSA guidelines (NCDENR, August 2014).
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4.0 REGIONAL GEOLOGY AND HYDROGEOLOGY
The Roxboro Plant is situated in the eastern Piedmont Region of north -central North
Carolina. The Piedmont is characterized by well-rounded hills and rolling ridges cut by
small streams and drainages. Elevations in the area of the Roxboro Plant range between
410 feet above mean sea level (msl) during full pool at Hyco Lake to 570 feet msl near
the Dunnaway Road and McGhees Mill Road intersection southeast of the Plant.
Geologically, the Plant is located near the contact of two regional geologic zones: the
Inner Piedmont zone and the Carolina zone. Both zones are generally comprised of
igneous and metamorphosed igneous and sedimentary rocks of Paleozoic age. In
general, the rocks are highly fractured and folded and have been subjected to long
periods of physical and chemical weathering. The origination, genesis, and
characteristics of the rocks of the region have been the focus of detailed study by
researchers for many years. These investigations have resulted in a number of
interpretations and periodic refinements to the overall geological model of the region.
Rocks of the region, except where exposed in road cuts, stream channels, and steep
hillsides, are covered with unconsolidated material formed from the in -situ chemical
and physical breakdown of the bedrock. This unconsolidated material is referred to as
saprolite or residuum. Direct observations at the Roxboro Plant confirm the presence of
residuum, developed above the bedrock, which is generally 10 to 30 feet thick. The
residuum extends from the ground surface (soil zones) downward, transitioning
through a zone comprised of unconsolidated silt and sand, downward through a
transition zone of partially weathered rock in a silt/sand matrix, down to the contact
with competent bedrock.
The Geologic Map of North Carolina (1985) places the rocks of the Plant area in the
Charlotte Terrane: a belt of metamorphic rock trending generally southwest to
northeast characterized by strongly foliated felsic mica gneiss and schist and
metamorphosed intrusive rocks (Figure 3). The rocks of the area near the Plant are
described as biotite gneiss and schist with abundant potassic feldspar and garnet, and
interlayered and gradational with calc-silicate rock, silliminite-mica schist and
amphibolite. The gneiss contains small masses of granite rock. The felsic mica gneiss of
the Charlotte Terrane is described as being interlayered with biotite and hornblende
schist. Later mapping generally confirms these observations and places the Roxboro
Plant near the contact between the Inner Piedmont zone, characterized by the presence
of biotite gneiss and schist, and the Charlotte Belt (or Charlotte Terrane), characterized
by felsic mica gneiss (USGS, 2007).
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Other researchers have conducted detailed investigations of the area and have provided
additional description of the geology in detailed tectonic, structural, and litho-
stratigraphic terms (Wilkins, Shell and Hibbard, 1995; Hibbard, et. al., 2002). One of the
most important interpretations concerning the geologic nature of the region is the
discovery and description of the Hyco shear zone, a tectonic boundary comprised of a
ductile shear zone that sharply separates contrasting rocks of the Charlotte (Milton) and
Carolina Terranes in north -central North Carolina and southern Virginia (Hibbard, et.
al., 1998). The Hyco shear zone was mapped as directly underlying Hyco Lake.
Groundwater within the area exists under unconfined, or water table, conditions within
the residuum and/or saprolite zone and in fractures and joints of the underlying
bedrock. The water table and bedrock aquifers are interconnected. The residuum acts
as a reservoir for supplying groundwater to the fractures and joints in the bedrock.
Shallow groundwater generally flows from local recharge zones in topographically high
areas, such as ridges, toward groundwater discharge zones, such as stream valleys.
Ridge and topographic high areas serve as groundwater recharge zones, and
groundwater flow patterns in recharge areas tend to develop a somewhat radial pattern
from the center of the recharge area outward toward the discharge areas and are
expected to mimic surface topography.
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5.0 SITE GEOLOGY AND HYDROGEOLOGY
Field activities at the Roxboro Plant document the bedrock of the northwestern portion
of the compliance boundary as mafic granitic gneiss and the remainder of the site as
felsic gneiss and hornblende gneiss. Based on available well logs, subsurface lithology
beneath the Plant area is comprised of tan to olive brown sandy silt and fine to coarse
sands grading into partially weathered rock and then competent bedrock.
Groundwater beneath the Plant area occurs within the residuum/partially weathered
rock or competent bedrock at depths ranging from three to 20 feet below land surface
(bls) along the downgradient compliance boundary and greater than 35 feet bls
upgradient of the ash basin. Routine water level measurements and corresponding
elevations from the compliance monitoring well network indicate that groundwater
generally flows from upland areas along the south, west, and eastern boundaries
towards the north and Hyco Lake. Groundwater generally flows from the south to the
north along the western portion of the property and from the southeast to the northwest
across the remainder of the property. The approximate groundwater gradient along the
western portion of the property for July 2014 data was 85.04 feet (vertical change) over
530 feet (horizontal distance) or 16 feet/100 feet as measured from upgradient
background well BG-1 to downgradient well CW-2. The approximate groundwater
gradient along the northern compliance boundary for July 2014 was slightly less at 76.64
feet (vertical change) over 570 feet (horizontal distance) or 13.4 feet over 100 feet as
measured from well CW-1 to downgradient well CW-2. Groundwater elevation data
collected from the two well pairs indicate the vertical gradient tends to be upward or
neutral between the transition zone and upper bedrock near surface water bodies.
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6.0 GROUNDWATER MONITORING RESULTS
6.1 Groundwater Analytical Results
July 2014 was the twelfth compliance monitoring event conducted in accordance with
the NPDES Permit. The routine analytical data indicates that chromium, iron,
manganese, sulfate, total dissolved solids (TDS), and pH have been elevated relative to
the 21, Standard. The concentration ranges for the constituents which have elevated
values greater than the 21, Standard are provided in Table 1.
• Chromium tends to be detected greater than the 21, Standard in background well
BG-1 and compliance boundary wells CW-1, CW-21), and CW-4.
• Iron tends to be detected greater than the 21, Standard in background well BG-1
and compliance boundary wells CW-1, CW-2, CW-21), CW-3, CW-31), and CW-4.
• Manganese tends to be detected greater than the 2L Standard in compliance
boundary wells CW-1, CW-2, and CW-31).
• Sulfate tends to be detected greater than the 21, Standard in compliance boundary
well CW-5.
• TDS tends to be detected greater than the 2L Standard in compliance boundary
wells CW-2, CW-3, CW-4, and CW-5.
• In general, the groundwater pH tends to be slightly below 6.5 Standard Units (SU),
which is below the lower end of the 2L Standard range, at background and
compliance wells for the ash basins.
6.2 Preliminary Statistical Evaluation Results
As a preliminary evaluation tool, statistical analysis was conducted on the groundwater
analytical data collected between November 2010 and July 2014. The statistical analysis
was conducted in accordance with US EPA, Statistical Training Course for Ground Water
Monitoring Data Analysis, EPA530-R-93-003, 1992 and US EPA's Statistical Analysis of
Groundwater Monitoring Data at RCRA Facilities; Unified Guidance EPA 530/R-09-007,
March 2009.
An inter -well prediction interval statistical analysis was utilized to evaluate the
groundwater data. The inter -well prediction interval statistical evaluation involves
comparing background well data to the results for the most recent sample date from
compliance boundary wells.
Monitoring well BG-1 is the upgradient background well and monitoring wells CW-1,
CW-2, CW-21), CW-3, CW-31), CW-4, and CW-5 are considered downgradient
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compliance boundary wells. Statistical analysis was performed on the inorganic
constituents with detectable concentrations for the most recent routine sampling event
(July 2014).
The statistical analysis indicated statistically significant increases (SSIs) over
background concentrations for the following:
• CW-1 sulfate and TDS (however, the concentrations of both constituents are
consistently much less than the 21, Standard);
• CW-2 barium, sulfate, and TDS (however, barium and sulfate concentrations are
consistently much less than the 2L Standard and TDS has occasionally been
detected at elevated concentrations greater than the 21, Standard);
• CW-2D barium, sulfate, and TDS (however, the concentrations of each of the three
constituents are consistently much less than the 21, Standard);
• CW-3 barium, chloride, sulfate, and TDS (however, only TDS concentrations have
been consistently detected at concentrations greater than the 21, Standard);
• CW-3D chloride, manganese, sulfate, and TDS (manganese has consistently been
detected at concentrations greater than the 2L Standard while chloride, sulfate and
TDS are consistently much less than the 21, Standard);
• CW-4 barium, chloride, and sulfate (however, the concentrations of each of three
constituents are consistently much less than the 2L Standard);
• CW-5 boron, chloride, sulfate, and TDS (however, only sulfate and TDS
concentrations have been consistently detected at concentrations greater than the
2L Standard).
A more robust statistical analysis will be completed as part of the CSA using data from
additional wells.
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Roxboro Steam Electric Plant SynTerra
7.0 ASSESSMENT WORK PLAN
The scope of work discussed in this plan is designed to meet the requirements of 15A
NCAC 02L .0106(g) and to;
• Identify the source and cause of contamination;
• Identify any imminent hazards to public health and safety and actions taken to
mitigate them in accordance to 15A NCAC 02L .0106(f);
• Identify all receptors and significant exposure pathways;
• Determine the horizontal and vertical extent of soil and groundwater
contamination and all significant factors affecting contaminant transport; and
• Determine geological and hydrogeological features influencing the movement,
chemical, and physical character of the contaminants.
The following sections generally describe anticipated assessment activities to fill data
gaps associated with the source, vertical and horizontal extent, in soil and groundwater,
for the constituents that have exceeded the 21, Standards. The assessment may be
iterative with possible additional assessment activities prior to the preparation of the
CSA. Groundwater samples collected will generally be analyzed for the constituents
listed in Table 2. The following activities are anticipated at this time.
7.1 Anticipated Ash Basin Boring Locations
Five borings are anticipated within the West Ash Basin to determine the thickness of
ash as well as to determine the current residual saturation. The anticipated boring
locations are shown on Figure 4.
The borings may be conducted using Direct Push Technology (DPT) or Roto-Sonic
drilling (or similar methods), to provide continuous soil cores through ash and into the
underlying native soil. Drilling will be extended to approximately 20 feet below the
bottom of the ash (or to refusal) to allow for characterization of the underlying native
soil.
Ash samples will be collected for laboratory analysis of total and SPLP metals. To
characterize the variation in ash composition, two samples, a shallow and a deep, are
anticipated at each location, if the ash thickness is less than 20 feet. If the thickness is
greater than 20 feet, three samples (shallow, intermediate, and deep), may be collected.
Page 13
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Groundwater Assessment Work Plan
Roxboro Steam Electric Plant
aber2014
SynTerra
A summary of the boring details is provided in Table 3. The depths at which the
samples are collected will be noted on sample IDs.
7.2 Anticipated Soil Boring Locations
7.2.1 Inside Ash Basins
As discussed above, continuous soil sample drilling techniques may be used to
conduct borings within the West Ash Basin. These borings are anticipated to
extend to a depth of approximately 20 feet below the ash (or to refusal) to
characterize the native material below the ash basin. No soil borings are
anticipated within the East Ash Basin based on available data from previous
investigations.
Soil samples are anticipated to be collected at each of the boring locations
immediately below the ash and at the bottom of the borings to provide
information on the vertical distribution of metals beneath the basin. The soil
samples will be analyzed for total metals, SPLP metals, and geotechnical
parameters. A summary of the anticipated boring details is provided in Table 3.
Following soil sample collection, the borings will be abandoned by filling with a
bentonite-grout mixture or will be converted to a piezometer to measure
groundwater fluctuations beneath the West Ash Basin.
7.2.2 Outside Ash Basins
Soil samples are anticipated to be collected during installation of monitoring well
pairs for metals analysis at all wells to further assess concentrations across the
site. Geotechnical parameters pertinent to developing the computer model will
be collected from AW-1, AW-2, AW-3, AW-5, and AW-6. Soil samples are
anticipated at each of the boring locations immediately above the water table and
within the transition zone. The soil samples will be analyzed for total metals,
SPLP metals, and geotechnical parameters. A summary of the anticipated boring
details is provided in Table 3.
7.3 Anticipated Sediment and Surface Water Locations
Surface water and sediment samples are not anticipated at this time. Data associated
with recent seep sampling will be used to infer preferential pathways and migration
from groundwater to surface water in various areas of the plant. Seep data analysis
may be used to guide the collection of additional sediment or surface water data in the
future.
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Plans \ Roxboro \ Roxboro GW Assessment Work Plan.docx

Groundwater Assessment Work Plan
Roxboro Steam Electric Plant
aber2014
SynTerra
7.4 Anticipated Groundwater Monitoring Wells and Piezometers
A number of monitoring wells and piezometers are present at the site. These existing
wells will be supplemented with additional wells to complete the CSA.
7.4.1 General Construction, Development, Aquifer Testing
Monitoring wells and piezometers will be constructed by North Carolina -
licensed well drillers. Drilling equipment will be decontaminated prior to use at
each location using a high pressure steam cleaner.
Monitoring wells will be constructed of 2-inch ID, National Sanitation
Foundation (NSF) grade polyvinyl chloride (PVC) (ASTM 2012a,b) schedule 40
flush -joint threaded casing and 0.010-inch machine -slotted pre -packed screens
appropriately sized sand for a gravel pack around the screen. Piezometers will
be constructed of 1-inch ID, NSF Schedule 40 PVC flush -joint threaded casing
and pre -packed screens.
At each monitoring well location specified on Figure 4 with a "S" qualifier (ex.
AW-1S) a Type II well will be constructed. Each well will have a 10 foot screen
set approximately 5 feet below the water table.
Should the Roto-Sonic drilling technique not be technically feasible at deeper
bedrock wells the construction of Type III wells may be necessary. In these
instances, a cased Type III 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 2-feet into competent rock. Note that location specific
subsurface geology will dictate actual casing depths on a per -well basis. Air
rotary drilling (or other appropriate drilling method) will be used to advance the
borehole a minimum of 15 - 20 feet into competent bedrock with the intent of
setting a 10-foot well screen at least 10 feet below the bottom of the casing.
The deeper of the paired wells will be installed first. The monitoring well will be
constructed in accordance with 15A NCAC 02C (Well Construction Standards).
The monitoring wells will be completed with either steel above ground
protective casings with locking caps or steel flush -mount manholes with locking
expansion caps, and well tags. The protective covers will be secured and
completed in a concrete collar and 2-foot square concrete pad.
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Plans \ Roxboro \ Roxboro GW Assessment Work Plan.docx

Groundwater Assessment Work Plan
Roxboro Steam Electric Plant
aber2014
SynTerra
Additional piezometers are not planned at this time, however, after a thorough
review of available data is completed, one or more piezometers may be
completed to address data gaps, if identified. Piezometers may be installed in a
similar manner, but with 1-inch ID, NSF Schedule 40 PVC flush -joint threaded
casing and pre -packed screens. A pelletized bentonite seal will be placed above
the filter pack and the remainder of the annular space will be filled with a neat
cement grout from the top of the upper bentonite seal to near ground surface.
The piezometers will be completed with either steel above ground protective
casings with locking caps or steel flush -mount manholes with locking expansion
caps, and well tags. The protective covers will be secured and completed in a
concrete collar and 1-foot square concrete pad.
Following installation, the monitoring wells will be developed in order to
remove drill fluids, clay, silt, sand, and other fines which may have been
introduced into the formation or sand pack during drilling and well installation,
and to establish communication of the well with the aquifer. Well development
will be performed using a portable submersible pump, which will be repeatedly
moved up and down the well screen interval until the water obtained is
relatively clear. Development will be continued by sustained pumping until
monitoring parameters (e.g., conductivity, pH, temperature) are generally
stabilized; estimated quantities of drilling fluids, if used, are removed; and,
turbidity decreases to acceptable levels.
After the wells have been developed, hydraulic conductivity tests (rising head
slug tests) will be conducted on each of the wells. The slug tests will be
performed in general accordance with ASTM D4044-96 Standard Test Method
(Field Procedure) for Instantaneous Change in Head (Slug) Tests for Determining
Hydraulic Properties of Aquifers and NCDENR Performance and Analysis of
Aquifer Slug Tests and Pumping Test Policy, dated May 31, 2007.
The data obtained during the slug tests will be reduced and analyzed using
AQTESOLVTM for Windows, version 4.5, software to determine the hydraulic
conductivity of the soils in the vicinity of wells.
7.4.2 Background Wells
Existing background well BG-1 is positioned to provide representative data for
comparison with background groundwater conditions. Additional background
well data will be useful to broaden the range of potential background
groundwater concentrations. Therefore, two additional background well pairs
BW-2S/BW-2D and BW-3S/BW-3D, along with one bedrock well (13W-11)),
Page 16
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Plans \ Roxboro \ Roxboro GW Assessment Work Plan.docx

Groundwater Assessment Work Plan
Roxboro Steam Electric Plant
aber2014
SynTerra
installed adjacent to transition background well BG-1 are anticipated at the
locations shown on Figure 4. BW-1D will be installed adjacent to existing
background well BG-1, but will be installed as a deep well, since BG-1 is installed
within the transition zone. BW-2S/D will be installed southeast of the West Ash
Basin between the end of Daisy Thompson Road and Sargents Creek. BW-3S/3D
will be installed southeast of the East Ash Basin to the east of the unnamed pond.
A summary of the boring details is provided in Table 3.
7.4.3 Ash Basins Area
A number of piezometer and groundwater monitoring wells are present in and
around both ash basin areas. Further, the semi -active east ash basin is partially
covered by a liner and a landfill. Therefore, no permanent piezometers or
monitoring wells are proposed for installation inside the ash basin areas.
7.4.4 Downgradient Assessment Areas
A preliminary review of site data and existing monitoring well locations indicate
that horizontal and vertical coverage around the compliance boundary is mostly
adequate to complete a CSA of the Roxboro Plant with the following exceptions.
At the western corner of the West Ash Basin, a well pair will be installed across
the Sargents Creek canal to monitor groundwater conditions in the deeper
portion of the surficial aquifer at this location. A deep monitoring well will also
be installed adjacent to compliance boundary well CW-4 to monitor groundwater
conditions in the deeper portion of the surficial aquifer at this location.
Two additional well pairs (AW-7S/D and AW8S/D) will be installed to the west
of the active ash basin between the basin and Hyco Lake to refine the flow
regime and provide additional geochemical data in this area.
To the north of the West Ash Basin an additional well pair (AW-6S/D) is
anticipated to refine groundwater flow north of the basin and provide additional
groundwater chemistry data north of CW-5. Wells AW-2S/D and AW-5S/D are
anticipated to be located between the West Ash Basin and the East Ash Basin to
refine groundwater flow between the basins and provide additional
groundwater geochemical data in this area. An additional well pair (AW-3S/D)
is anticipated to be located near the northeast corner of the gypsum pad. This
pair will further refine groundwater flow and provide additional groundwater
geochemistry area between the East Ash Basin and canal to the north.
The approximate locations of the additional monitoring wells are shown on
Figure 4. A summary of the boring details is provided in Table 3.
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Plans \ Roxboro \ Roxboro GW Assessment Work Plan.docx

Groundwater Assessment Work Plan
Roxboro Steam Electric Plant
aber2014
SynTerra
7.4.5 Groundwater Sampling
It is anticipated that groundwater samples will be collected using a low -flow
sampling technique consistent with compliance monitoring well sampling
protocol. The groundwater samples will be analyzed for the parameters listed in
Table 2. Total and dissolved metals analysis will be conducted. A summary of
the anticipated groundwater samples is included in Table 3.
During groundwater sampling activities, water level measurements will be made
at the existing site monitoring wells, observation wells, and piezometers, along
with the new wells. The data will be used to generate water table and
potentiometric maps of the upper and lower portions of the surficial aquifer
zones, as well as to determine the degree of residual saturation beneath the ash
basins.
7.5 Influence of Pumping Wells on Groundwater System
No pumping or production wells have been reported onsite. Potentially, one
production well exists at a neighboring industry within 0.25 mile of the East Ash Basin.
This well is located across the canal from the Plant and is not expected to substantially
influence the groundwater flow system near the ash basins. Preliminary information
indicates 57 potential private water supply wells may be located within a 0.5 mile
radius of the compliance boundary. The wells are located upgradient from the ash
basins. It is anticipated that due to the distance from the ash basins and likely limited
withdrawal rates, the use of the off -site wells should not substantially affect the
groundwater flow system near the ash basins. Additional information on the potential
off -site water supply wells will also be collected as part of the assessment.
7.6 Site Conceptual Model
Existing and new hydrogeological data will be used to develop a Site Conceptual Model
(SCM). The SCM will be developed in accordance with "Evaluating Metals in
Groundwater at DWR Permitted Facilities" (July 2012) and the May 31, 2007 NCDENR
Memorandum entitled Hydrogeologic Investigation and Reporting Policy. The SCM will
define the groundwater flow systems at the site, horizontally and vertically, and
provide a better understanding of the fate and transport of constituents of concern in
groundwater. This information will be used to develop a groundwater computer
model. Figure 4 shows the proposed locations for Geologic Cross Sections anticipated
for the SCM.
7.7 Development of Groundwater Computer Model
Data from existing and new monitoring wells will be used to develop a groundwater
computer model of the system. The groundwater modeling will be conducted in
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Plans \ Roxboro \ Roxboro GW Assessment Work Plan.docx

Groundwater Assessment Work Plan September 2014
Roxboro Steam Electric Plant SynTerra
accordance with the requirements of the May 31, 2007 NCDENR Memorandum entitled
Groundwater Modeling Policy.
At this time, it is anticipated that a numerical groundwater flow model will be
developed using the MODFLOW finite difference model that was developed by the
USGS and is one of the most widely accepted and widely used groundwater flow
models. The MODFLOW model will be created as a multi -layer flow model to better
determine the vertical flow component of the aquifer system which will allow for more
accurate fate and transport modeling. Once the model is created, it will be calibrated to
site conditions by modifying model inputs, such as hydraulic conductivity, within
established limits based on actual site data, until a reasonable match between the model
and actual site conditions is accomplished.
After the MODFLOW model is calibrated, the modeled flow data will be imported into
MT3D or RT3D and a fate and transport model will be created. MT3D and RT3D are
three-dimensional numerical solute fate and transport model, which will be used to
predict the short and long-term movement of the constituents of interest in
groundwater at the site and under the various predictive scenarios discussed above.
Due to the data requirements of the computer modeling, the computer model will be
completed after the majority of the groundwater assessment activities. The results of
the groundwater modeling are anticipated as an appendix to the CSA Report.
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Plans \ Roxboro \ Roxboro GW Assessment Work Plan.docx

Groundwater Assessment Work Plan
aber2014
Roxboro Steam Electric Plant SynTerra
8.0 IMPLEMENTATION SCHEDULE AND REPORT SUBMITTAL
Implementation will take place immediately following approval of this Groundwater
Assessment Plan by DWR. The anticipated schedule of activities and project
completion following plan approval is provided below.
• 10 days to begin field activities upon approval of plan
(Including, but not limited to, notification of public utility locate services,
road access clearing, container requests from laboratories for the soil and
groundwater samples, assemble information on existing site wells and
piezometers in addition to compliance boundary well information)
• 60 days to complete field activities
• Complete drilling activities
• Conduct slug tests
• Survey soil borings, wells, and other assessment locations
• Collect groundwater and other assessment samples
• Collect site -wide water levels
• Setup groundwater computer model
• 30 days after completion of field activities receive analytical data
• 60 days after receipt of analytical data evaluate results, conduct statistical
evaluation, prepare summary tables, develop CSM, and calibrate computer
model.
• 20 days to complete Assessment Report, per NC Senate Bill 729, August 2014.
• 90 days (up to 180 days) to complete computer modeling and Corrective Action
Plan, per NC Senate Bill 729, August 2014.
• Conduct additional work as may be required to complete the CSA.
• 90 days to complete CSA preparation, review, and submittal, in accordance with
NCDENR guidance (August 2014).
Page 20
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Plans \ Roxboro \ Roxboro GW Assessment Work Plan.docx

Groundwater Assessment Work Plan September 2014
Roxboro Steam Electric Plant SynTerra
Project Assumptions Include:
• No more than one iterative assessment step will be required;
• DEP will make a diligent effort to collect all receptor information in accordance
with NCDENR guidance (August 2014); however, it is anticipated that all such
information may not be available;
• If off -site water supply wells sampling is deemed necessary, NCDENR staff may
be requested to assist with access;
• No special permitting is anticipated; and
• Data may not reflect all seasonal or extreme hydrologic conditions.
• During the CSA process if additional investigations are required NCDENR, will
be notified.
• In addition to the components listed above, a human health and ecological risk
assessment will be conducted.
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Plans \ Roxboro \ Roxboro GW Assessment Work Plan.docx

Groundwater Assessment Work Plan
aber2014
Roxboro Steam Electric Plant SynTerra
9.0 REFERENCES
ASTM D4044-96 Standard Test Method (Field Procedure) for Instantaneous Change in Head
(Slug) Tests for Determining Hydraulic Properties of Aquifers
Hibbard, James P., Glenn S. Shell, Phillip J. Bradley, Scott D. Samson, and Greg L.
Wortman, February 1998, The Hyco shear zone in North Carolina and southern
Virginia: Implications for the Piedmont Zone -Carolina Zone boundary in the southern
Appalachians. American Journal of Science, V. 298, p. 85 —107.
Hibbard, James P., Edward F. Stoddard, Donald T. Secor, and Allen J. Dennis, 2002, The
Carolina Zone: overview of Neoproterozoic to Early Paleozoic peri-Gondwanan terranes
along the eastern Flank of the southern Appalachians: Earth Science Reviews, v. 57.
NCDENR Document, "Hydrogeologic Investigation and Reporting Policy
Memorandum", dated May 31, 2007.
NCDENR Document, "Groundwater Modeling Policy Memorandum", dated May 31,
2007.
NCDENR Document, "Performance and Analysis of Aquifer Slug Tests and Pumping
Test Policy", dated May 31, 2007.
North Carolina Geological Survey, 1985, Geologic map of North Carolina: North Carolina
Geological Survey, General Geologic Map, scale 1:500000.
USGS, December 2007, Preliminary integrated geologic map databases for the United States:
Alabama, Florida, Georgia, Mississippi, North Carolina, and South Carolina. United
States Geological Survey Open -File Report 2005-1323, Version 1.1.
Wilkins, James K., Glenn S. Shell, and James P. Hibbard, 1995, Geologic contrasts across
the central Piedmont Suture in north -central North Carolina. South Carolina Geology,
V. 37, p. 25 — 32.
Page 22
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Plans \ Roxboro \ Roxboro GW Assessment Work Plan.docx

FIGURES

-E
PROPERTY BC
SOURCE:
OU CE:
USGS TOPOGRAPHIC MAP OBTAINED FROM THE NRCS GEOSPATIAL DATA GATEWAY AT httpY1datagateway.nres.usda.gov/
ROXBORO POWER PLANT
PERSON COUNTY FIGURE 1
SITE LOCATION MAP
DUKE ENERGY PROGRESS
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GREENSBGR°' TerraRSTEAM ELECTRIC PLANT
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Vn__TTEVILLE SEMORA, NORTH CAROLINA
OLIVE HILL, NC QUADRANGLE
148 RIVER STREET, SUITE 220 WILMGTON DRAWN BY S ARLEDGE DATE 2014-09-25
GREENVILLE, SOUTH CAROLINA 1�� GRAPHIC SCALE
ONE 864-421-9999 PH PROJECT KATHY WEBB CONTOUR INTERVAL 1000 0 1000 2000
T FIG
1 (USGS SITE LOCATION) MAP DATE 1994
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LEGEND - UNIT NAME
CZbg BIOTITE GNEISS AND SCHIST (INNER PIEDMONT)
CZfg FELSIC MICA GNEISS (CHARLOTTEAND MILTON BELTS)
CZg METAMORPHOSED GRANITIC ROCK I EASTERN SLATE BELT)
PzZg METAMORPHOSED QUARTZ DIORITE (EASTERN SLATE BELT)
GEOLOGY SOURCE NOTE:
GEOLOGY SHAPEFILES OBTAINED FROM THE USGS Preliminary integrated geologic map databases forthe United
States -Alabama, Flonda, Georgia, Mississippi, North Carolina, and South Carolina, DATED 2007 AT
httpYIpubs.usgs.gov/of2005113231
DISCLAIMER
The information on this map was denied from digital databases at the INC Department of Transportation Website. Care was
taken in the creation ofthis map. SYNTERRA cannot accept any responsibility fore—, omissions, orpositional accuracy.
There are no warranties, expressed orimplied, including the warranty of merchantability orfitness fora particular purpose,
accompanying this product. However, notification of anyerrom will be appreciated.
GRAPHIC SCALE
1 1500 0 1500 3000
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IN FEET
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PROJECT MANAGER KATHYWEBB
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GEOLOGY MAP
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ROXBORO STEAM ELECTRIC PLANT
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SEMORA, NORTH CAROLINA

TABLES

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TABLE 2
ASSESSMENT PARAMETER LIST
ROXBORO STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS, INC., ROXBORO, NORTH CAROLINA
PARAMETER
UNITS
FIELD EQUIPMENT/
LAB METHOD
Field Parameters
pH
SU
YSI Professional Plus or YSI 556 MPS
Specific Conductivity
µS/cm
YSI Professional Plus or YSI 556 MPS
Temperature
Co
YSI Professional Plus or YSI 556 MPS
ORP
my
YSI Professional Plus or YSI 556 MPS
Dissolved Oxygen
mg/L
YSI Professional Plus or YSI 556 MPS
ITurbidity
I NTU
Hach 2100
Lab Parameters
- Inorganics (Total
& Dissolved)
Antimony
µg/L
EPA 200.8
Arsenic
µg/L
EPA 200.8
Barium
mg/L
EPA 200.7
Boron
mg/L
EPA 200.7
Cadmium
µg/L
EPA 200.8
Chromium
µg/L
EPA 200.8
Copper
mg/L
EPA 200.7
Iron
mg/L
EPA 200.7
Lead
µg/L
EPA 200.8
Manganese
mg/L
EPA 200.7
Mercury
µg/L
EPA 245.1
Molydbenum
µg/L
EPA 200.8
Nickel
µg/L
EPA 200.8
Selenium
µg/L
EPA 200.8
Thallium (low level)
µg/L
EPA 200.8
Zinc
m L
EPA 200.7
Lab
Parameters - Anions/Cations
Nitrate as Nitrogen
mg-N/L
EPA 300.0
Ferrous Iron
mg/L
(Field Test Kit)
Sulfate
mg/L
EPA 300.0
Sulfide
mg/L
SM 4500 Sd
Methane
mg/L
RSK 175
Chloride
mg/L
EPA 300.0
Calcium
mg/L
EPA 200.7
Magnesium
mg/L
EPA 200.7
Sodium
mg/L
EPA 200.7
Potassium
mg/L
EPA 200.7
Bromide
mg/L
EPA 300.1
Total Organic Carbon
mg/I
EPA 5310
Alkalinity (as CaCO3)
mg/L
SM 2320B
Total Dissolved Solids
m /L
SM 2540C
Notes:
SU - Standard Units
µS/cm - microsiemens per centimeter
Co - degrees Celsius
my - millivolts
Prepared by: RBI Checked by: JAW
mg/L - milligrams per liter
NTU - Nephelometric Turbidity Units
µg/L - micrograms per liter
mg-N/L - milligrams nitrate (as nitrogen) per liter
Page 1of1
P:\Duke Energy Progress.1026\ALL NC SITES\DENR Letter Deliverables\GW Assessment Plans\Roxboro\Tables\Table 2
Assessment Parameter List Roxboro.xlsx

TABLE 3
ASSESSMENT SAMPLING PLAN
ROXBORO STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS, INC., SEMORA, NORTH CAROLINA
ASH
ESTIMATED
ESTIMATED
SAMPLE
MANAGEMENT
BORING /
BORING
NO.OF
SAMPLE
DEPTHS/INTERVALS/
LAB ANALYSIS
PURPOSE/NOTES
AREA
WELL ID
DEPTH
SAMPLES
MEDIA
TARGET ZONES
(ft bgs)
Ash
1-2'
Total metals + SPLP
Refine ash thickness, determine residual
Ash
Intermediate (if >20' thick)
Total metals + SPLP
saturation of ash, characterize ash
AB-1
40
4-5
Ash
Above ash/soil contact
Total metals + SPLP
chemistry and leachability, characterize
Soil
2' Below ash/soil contact
Total metals + Geotech
soil chemistry beneath ash, geologic
Soil
Bottom of boring
Total metals + Geotech
cross section, groundwater modeling
Ash
1-2'
Total metals + SPLP
Refine ash thickness, determine residual
Ash
Intermediate (if >20' thick)
Total metals + SPLP
saturation of ash, characterize ash
AB-2
40
4-5
Ash
Above ash/soil contact
Total metals + SPLP
chemistry and leachability, characterize
Soil
2' Below ash/soil contact
Total metals + Geotech
soil chemistry beneath ash, geologic
Soil
Bottom of boring
Total metals + Geotech
cross section, groundwater modeling
Ash
1-2'
Total metals + SPLP
Refine ash thickness, determine residual
Ash
Intermediate (if >20' thick)
Total metals + SPLP
saturation of ash, characterize ash
Ash Basin
AB-3
40
4-5
Ash
Above ash/soil contact
Total metals + SPLP
chemistry and leachability, characterize
Soil
2' Below ash/soil contact
Total metals + Geotech
soil chemistry beneath ash, geologic
Soil
Bottom of boring
Total metals + Geotech
cross section, groundwater modeling
Ash
1-2'
Total metals + SPLP
Refine ash thickness, determine residual
Ash
Intermediate (if >20' thick)
Total metals + SPLP
saturation of ash, characterize ash
AB-4
40
4-5
Ash
Above ash/soil contact
Total metals + SPLP
chemistry and leachability, characterize
Soil
2' Below ash/soil contact
Total metals + Geotech
soil chemistry beneath ash, geologic
Soil
Bottom of boring
Total metals + Geotech
cross section, groundwater modeling
Ash
1-2'
Total metals + SPLP
Refine ash thickness, determine residual
Ash
Intermediate (if >20' thick)
Total metals + SPLP
saturation of ash, characterize ash
AB-5
40
4-5
Ash
Above ash/soil contact
Total metals + SPLP
chemistry and leachability, characterize
Soil
2' Below ash/soil contact
Total metals + Geotech
soil chemistry beneath ash, geologic
Soil
Bottom of boring
Total metals + Geotech
cross section, groundwater modeling
Soil
Just above the water table
Total metals
Soil
Within transition zone
Total metals
Groundwater modeling, statistical
BW-1D
100
3
Water
Screened interval
Table 2 List
evaluation, and sentinel well
Table 2 List
Soil
Just above the water table
Total metals
BW-25/D
50
4
Soil
Within transition zone
Total metals
Groundwater modeling, statistical
100
Water
Screened interval
Table 2 List
evaluation, and sentinel well
Water
Screened interval
Table 2 List
Soil
Just above the water table
Total metals
BW-35/D
50
4
Soil
Within transition zone
Total metals
Groundwater modeling, statistical
100
Water
Screened interval
Table 2 List
evaluation, and sentinel well
Water
Screened interval
Table 2 List
Soil
Just above the water table
Total metals + Geotech
AW-1S/D
20
4
Soil
Within transition zone
Total metals+ Geotech
Groundwater modeling and horizontal
50
Water
Screened interval
Table 2 List
and vertical extent
Water
Screened interval
Table 2 List
Soil
Just above the water table
Total metals + Geotech
AW-25/D
20
4
Soil
Within transition zone
Total metals+ Geotech
Groundwater modeling and horizontal
50
Water
Screened interval
Table 2 List
and vertical extent
Water
Screened interval
Table 2 List
Soil
Just above the water table
Total metals + Geotech
New Monitoring
AW-35/D
20
4
Soil
Within transition zone
Total metals+ Geotech
Groundwater modeling and horizontal
Wells
50
Water
Screened interval
Table 2 List
and vertical extent
Water
Screened interval
Table 2 List
Soil
Just above the water table
Total metals
Soil
Within transition zone
Total metals
Groundwater modeling and horizontal
AW-4D
100
3
Water
Screened interval
Table 2 List
and vertical extent
Table 2 List
Soil
Just above the water table
Total metals + Geotech
AW-55/D
50
4
Soil
Within transition zone
Total metals+ Geotech
Groundwater modeling and horizontal
100
Water
Screened interval
Table 2 List
and vertical extent
Water
Screened interval
Table 2 List
Soil
Just above the water table
Total metals + Geotech
AW-65/D
50
4
Soil
Within transition zone
Total metals + Geotech
Groundwater modeling and horizontal
100
Water
Screened interval
Table 2 List
and vertical extent
Water
Screened interval
Table 2 List
Soil
Just above the water table
Total metals + Geotech
AW-75/D
50
4
Soil
Within transition zone
Total metals + Geotech
Groundwater modeling and horizontal
100
Water
Screened interval
Table 2 List
and vertical extent
Water
Screened interval
Table 2 List
Soil
Just above the water table
Total metals + Geotech
AW-85/D
20
4
Soil
Within transition zone
Total metals+ Geotech
Groundwater modeling and horizontal
50
Water
Screened interval
Table 2 List
and vertical extent
Water
Screened interval
Table 2 List
Existing
Existing
Monitoring Wells
Monitoring
TBD
Variable
TBD
Water
Well Screen Interval (variable)
Table 2 List
Wells
Prepared by: TDP Checked by: JAW
Notes:
Total Metals - As, B, Ba, Cd, Cr, Cu, Fe, Hg, Mn,Mo, Ni, Pb, Sb, Se, TI, and Zn.
SPLP (Synthetic Preciptation Leaching Procedure) Metals - As, B, Ba, Cd, Cr, Cu, Fe, Hg, Mn,Mo, Ni, Pb, Sb, Se, TI, and Zn.
Geotech - Geotechnical parameters include moisture content, particle size distribution, Atterberg limits, specific gravity, and permeability.
Table 2 List - Parameter list presented in Table 2 of this document.
ft bgs - Feet below ground surface.
TBD - To be determined.
P:\Duke Energy Pmgr—.1026\ALL NCSRES\DENR Letter Deliverable,\GWAss,—nt Plans\Rmcboro\Tables\Table 3-Assessment Sampling Plan R-bom.xl.. Pagel of 1

APPENDIX A
NCDENR LETTER of AUGUST 13, 2014

��
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: 91H07-64641Internet: www.ncdenr.gov
An Equal Opportunity t Affirmative Aclion 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 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.

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

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 presentifuture surrounding
land uses.
E. Receptor Information
Provide a site map showing labeled well locations within a
2

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 citylcounty 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,
rechargeldischarge, 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

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.
Le

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 . ncden r. org/web/wq/aps/cwp ro/policy).
N OTE: 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

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
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.
NDTE: 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".
■ 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

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)
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