9210_DukeShearonHarris_AssessmentWorkPlan_DIN26954_20161028

S&ME, Inc. | 8646 W Market St, Ste 105 | Greensboro, NC 27409 | p 336.288.7180 | f 336.288.8980 | www.smeinc.com
October 27, 2016
NCDEQ-DWM, Solid Waste Section
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
Attention:Ms. Elizabeth Werner
Reference:Assessment Work Plan
Harris Nuclear Plant Closed Landfill (Permit No. 92-10)
New Hill, North Carolina
S&ME Project No. 7126-16-045
Dear Ms. Werner:
On behalf of Duke Energy Progress, LLC (Duke Energy), S&ME, Inc. (S&ME) prepared this Work Plan for
conducting assessment activities at the closed landfill located at Shearon Harris Nuclear Plant, in New Hill,
North Carolina. For ease of review, essential project background information has been summarized. This
Work Plan provides an outline of noteworthy tasks to be completed as part of this assessment and
tentative schedule for implementation of the plan. This Work Plan is consistent with information
presented and discussed during our October 13, 2016 meeting with John Toepfer with Duke Energy.
Background
The closed landfill is located at the Duke Energy, Shearon Harris Nuclear Plant in New Hill North Carolina
(see Figure 1). In accordance with the Closure of the Harris Nuclear Plant, Unlined Industrial Landfill Unit;
New Hill, North Carolina; FACILITY PERMIT #: 92-10, letter from the NCDEQ dated May 25, 2005; this
unlined industrial landfill was closed and covered under NCDEQ Solid Waste Permit No. 92-10. The
NCDEQ letter dated May 25, 2005, addressing the closure of this unlined Industrial landfill referenced Rule
0.510. As a 0.500 landfill the compliance boundary would be established 500 feet from the waste
boundary, or at the property line; whichever is closer to the waste boundary. The review boundary would
be established halfway between the waste boundary and compliance boundary.Figure 2 depicts the
approximate location of landfill waste boundary, review boundary, and compliance boundary. The landfill
cells were reportedly trench style units.Figure 3 depicts the two landfill cells (Cells 1 and 3) known to
contain waste, the third cell (Cell 2) was not used for waste disposal.
Currently, monitoring wells MW-1, MW-2, MW-3, MW-6, and MW-7 comprise the groundwater
monitoring network for the closed landfill. As part of post-closure monitoring, these wells are sampled on
a semi-annual basis and the collected groundwater samples analyzed for Appendix I VOCs, 8-RCRA
Metals, and sulfate. Analytical results are compared with the 15A North Carolina Administrative Code
(NCAC) 2L .0200 groundwater quality standards (2L Standard) or the NCDEQ Interim Maximum Allowable
Concentrations (IMACs) when no 2L Standard is published.
Assessment Work Plan
Harris Nuclear Plant Closed Landfill (Permit No. 92-10)
New Hill, North Carolina
S&ME Project No. 7126-16-045
October 27, 2016 2
For at least the past two post-closure monitoring events, analytical results of the monitoring well
groundwater samples have indicated that one or more volatile organic compounds (VOCs) have been
detected at monitoring wells MW-1 and MW-7 at concentrations greater than the corresponding 2L
Standard. Both of these monitoring wells (MW-1 and MW-7) are located less than 100 feet from the
landfill limits of waste and each well is substantially within the 500 foot compliance boundary. Monitoring
well MW-2, located near the review boundary has also had detections of VOCs with one VOC exceeding a
2L standard for the last two monitoring events.
At monitoring well MW-7, some of the detected VOCs have exhibited apparent trends of rising
concentrations over time. In contrast VOCs detected at monitoring well MW-1 have exhibited trends of
declining or stable concentrations over time.
Based on the detection of VOCs at monitoring wells MW-1 and MW-7 with concentrations greater than
the corresponding 2L Standards, this Work Plan was developed to outline the actions to be undertaken to
initiate an assessment of groundwater quality down-gradient of these wells.
Geology / Hydrogeology
According to the North Carolina Geologic Map, 1985, the subject site is located in an area underlain by
rock that is part of the Newark Super Group. The Newark Super Group is one of a series of sedimentary
rift valley structures worldwide resulting from movements in the continental plates during the Triassic
period. The Newark Super Group is located in the Eastern Piedmont area of North America, approximately
parallel to the coastline and extending roughly from Pennsylvania to northern Florida. The Newark Group
is divided into several separate basins, including the Culpepper, Richmond, Dan River and Deep River
Basins of Virginia and North Carolina. The subject site is located within the Deep River Basin.
The underlying rock present in the vicinity of the site can be classified as sedimentary rocks of the
Chatham Group, which can consist of shales, sandstones, and coarse conglomerates in a fine-grained
matrix. These sedimentary units are reported to dip gently eastward. Intrusive diabase dikes and sills are
known to locally cross-cut these sedimentary deposits.
From a hydrogeologic stand point, these deposits are generally very tight with bedrock permeability
primarily available in faults, joints, and fractures. Often the tight nature of these deposits makes
determining if and where groundwater is present in the overlying residual aquifer challenging.
Landfill monitoring wells MW-1, MW-2, and MW-3 were drilled in 1986. The well construction records for
these monitoring wells contains sparse geologic information and lack details of when or if bedrock was
encountered. Therefore, the aquifer unit monitored by these wells is not clear. Monitoring wells MW-6
and MW-7 were installed during 2003, and each well was reported as screened within a portion of a
bedrock aquifer. Well construction records describe the bedrock as a conglomerate.
Groundwater level data report that monitoring wells MW-6 and MW-7 exhibit artesian conditions,
representative of the intersected portions of the bedrock aquifer. Artesian conditions were not observed
at monitoring well MW-1, MW-2, and MW-3. Development of relevant groundwater elevation contours
for the landfill area has not been practical with the existing monitoring well network since:
Assessment Work Plan
Harris Nuclear Plant Closed Landfill (Permit No. 92-10)
New Hill, North Carolina
S&ME Project No. 7126-16-045
October 27, 2016 3
♦The long-axis of the landfill unit parallels the axis of a local topographic ridge. Using topography
as a guide to estimate groundwater flow directions, some degree of radial groundwater flow is
expected within the shallow groundwater aquifer underlying the landfill. Considering the
locations of monitoring wells MW-1, MW-2, and MW-3 relative to the axis of the ridge,
groundwater elevation data for these points were not contoured.
♦Three of the five monitoring wells may be screened within the shallow unconfined aquifer,
whereas two (MW-6 and MW-7) are known to be screened in the bedrock aquifer. It is often
inappropriate to mix disparate aquifer water level data sets in the preparation of groundwater
elevation contours.
Figure 2 presents the groundwater elevations observed during April 2016. Using topography as a guide
to estimate shallow unconfined aquifer flow directions,Figure 2 was prepared and depicts groundwater
flow direction arrows to illustrate estimated shallow groundwater flow in the vicinity of the closed landfill
unit. Considering the above stated limitations to the preparation of groundwater elevation contours,
groundwater flow rate calculations have not been prepared for this Facility.
Site Conceptual Model Development
Recognizing the inherent challenges imposed by site geology, potential data gaps were assess during the
development of a site conceptual model for the pending assessment. The lack of information regarding
probable locations for bedrock fractures and diabase dikes or sills in the study area were identified as
fundamental data gaps. To address these data gaps, THG Geophysics, Ltd. was contracted to perform
geophysical surveys to image possible bedrock fractures and mafic-rich dikes in the immediate area of the
closed landfill.
A Very Low Frequency (VLF) survey and Electrical Imaging (EI) survey were completed during September
2016 to image possible fractures in bedrock. A magnetometer survey was conducted to survey the landfill
area for the potential presence of mafic-rich
1 dikes or sills, referred to hereafter as diabase. Fractures are
anticipated to act as conduits, providing significant control over the migration of groundwater in the
bedrock aquifer. Diabase dikes often act as local barriers to groundwater flow. Based on our experience,
the margins of diabase dikes can be fractured.
The locations of survey imaged fractures and probable diabase features are depicted on Figure 3. The
solid lines shown indicative of facture and diabase features are based on interpretations of the direction
and interconnection of imaged features detected, between data collection transects. This figure was used
to examine potential spatial correlations between the imaged fractures and diabase features relative to
the waste disposal unit and the known distribution of dissolved phase groundwater contaminants. As
depicted in Figure 3, the geophysical surveys imaged two fracture zones striking generally north – south
and dipping toward the west and one vertical fracture zone striking generally east - west. These features
appear underlie portion of the landfill. Indications of a diabase feature striking generally north - south
were detected immediately east of the landfill.
1 A magnetometer can measure properties of bedrock that are consistent with those of mafic-rich rocks;
however, it cannot determine actual rock compositions. Given that diabase rocks, a mafic-rich rock, have
been mapped in the area by others, the term diabase is utilized herein for simplicity of discussion.
Assessment Work Plan
Harris Nuclear Plant Closed Landfill (Permit No. 92-10)
New Hill, North Carolina
S&ME Project No. 7126-16-045
October 27, 2016 4
Our conceptual site model for the landfill assumes that water which percolates downward from the land
surface, interacts with landfill contents in the waste management units, then continues to migrate
downward into the underlying groundwater aquifer. Due to the tight nature of the surround geologic
formations, groundwater flow and dissolved phase contaminant migration are largely controlled by
fractures and the diabase features. Thus groundwater migrating downward beneath the landfill may
intersect the east – west striking fracture and based upon head pressures, migrate east or west along this
fracture as a preferential flow path. When groundwater migrating along the east – west fracture intersects
one of the imaged north – south striking fractures, these may also become preferential flow paths, with
flow controlled by head pressures. It is possible that the diabase feature east of the landfill may inhibit
further eastward migration of groundwater, and if present, fractures on the margins of the diabase may
be preferred flow paths to the north or south. The hypothetical function of the diabase as a local barrier
to groundwater flow, may in part explain the observed absence of VOCs in the groundwater at monitoring
well MW-6.
Based on the known site background information and our initial Site Conceptual Model, the following
Work Plan elements are proposed to assess the VOC detections at monitoring wells MW-6 and MW-7.
Assessment Work Plan
Task 1: Soil Borings and Monitoring Well Installations
Hollow-stem auger soil borings will be completed adjacent to existing monitoring wells MW-1 and MW-2.
These borings will extend to the depth of auger refusal, and the bore-hole left open for approximately 24-
hours to monitor for presence of shallow water table. Each boring will be abandoned after water level
data collection is complete. An Environmental Staff Professional will be on-site to observe drilling and
classify the soils. The information gathered will fill some of the subsurface geologic conditions data gaps
that currently exist for these monitoring wells.
Two new monitoring wells will be installed at locations approximated on Figure 3. Monitoring well MW-8
will target the down-dip extension of the nearby north - south striking fracture zone. Monitoring well
MW-9 will target the possible fractures along the margin of the imaged diabase. The monitoring wells will
be constructed in accordance with the Solid Waste Sections requirement and the requirements specified
under NCAC 2C. The following summarizes basic tasks associated with the installation of the new
monitoring wells:
♦The proposed wells will be Type II PVC monitoring wells designed to monitor the uppermost
prevalent aquifer. Two-inch diameter Schedule 40 PVC casing and screens will be installed in the
hollow-stem auger borings / rock-core borings. Pre-packed screens will be utilized during well
construction. A bentonite seal will be installed above the well screen and the annulus space
between the borehole wall and the well casing grouted up to the ground surface. Each
monitoring well will be completed at the surface by enclosing the casing within a protective cover
installed to a height approximately three feet above ground surface, and encased within a 2-foot
by 2-foot concrete pad installed at the ground surface.
♦An Environmental Staff Professional will be on-site to observe drilling, classify the soils, and
determine site-specific well construction details based on observed subsurface conditions.
Assessment Work Plan
Harris Nuclear Plant Closed Landfill (Permit No. 92-10)
New Hill, North Carolina
S&ME Project No. 7126-16-045
October 27, 2016 5
♦Depth to groundwater measurements will be determined a minimum 24-hours following well
completion.
♦Drilling equipment will be decontaminated prior to use at each location.
♦Each newly-installed monitoring well will be developed using an electric submersible pump to
remove visible clay, silt, and sand particles that may have been introduced into the formation or
filter pack during installation.
♦Subcontract a registered land surveyor to determine the coordinates for each new well and top of
casing elevations. The top of casing elevations and depth to groundwater measurements will be
used to calculate observed groundwater elevations.
♦A well construction record (Form GW-1) for each new well will be prepared and submitted to the
NCDEQ within 30-days of well completion.
Task 2: Groundwater Sampling and Analyses
Following well installation and development, groundwater samples will be obtained using low-flow
sampling methods consistent with those utilized at the landfill for routine site post-closure monitoring.
The collected groundwater samples will be analyzed for Appendix I VOCs, 8-RCRA Metals, and sulfate,
consistent with the suite of analyses used during post-closure care monitoring.
Task 3: Slug Testing
Rising or falling head slug tests will be performed on each the two new monitoring wells. The collected
data will be analyzed and used to provide estimate hydraulic conductivities for each well location.
Task 4: Reporting
A written report will be prepared to summarize the field methods employed and the results that were
obtained. Groundwater analytical results will be compared with the corresponding 2L Standard or NCDEQ
IMACs when applicable. The report will include borings logs, well construction records, and laboratory
analytical reports generated for this assessment.
Schedule
The attached Preliminary Project Implementation Schedule provides an estimate of the time frame needed
to complete the proposed activities. The drilling schedule considers some anticipated challenges to
developing access for drilling rigs and drill crew availability. We anticipate drilling to commence
sometime in November 2016.
Assessment Work Plan
Harris Nuclear Plant Closed Landfill (Permit No. 92-10)
New Hill, North Carolina
S&ME Project No. 7126-16-045
October 27, 2016 6
Closure
Please review the proposed assessment activities and provide us with your comments and/or approval to
proceed with the assessment outlined herein. Contact Edmund Henriques at [phone] if you have
any questions regarding this proposed work plan. We appreciate your assistance in this matter.
Sincerely,
S&ME, Inc.
John Whitehead Edmund Q.B. Henriques, L.G.
Senior Project Manager Senior Geologist
NC Geology License 1216
Attachments
Attachment I – Figures
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Attachment II – Preliminary Schedule
PRELIMINARY PROJECT IMPLEMENTATION SCHEDULE
HARRIS NUCLEAR PLANT, CLOSED LANDFILL ASSESSMENT
S&ME PROJECT NO. 7158-14-014
Tasks
Data Review & Project Planning
Meet with NCDEQ-SWS
########
Prepare Work Plan for Assessment Activities
Prepare and Submit Work Plan to NCDEQ-SWS
Obtain NCDEQ-SWS Approval
Geophysical Survey
Geophysical Survey Data Collection (THG+S&ME)
Data Review & proposed well site selection
Drilling
Drill site access development
Complete Soil Borings next to MW-1 and MW-2
Install 2 New Monitoring Wells
Develop New Monitoring Wells
Sample New Monitoring Wells
Slug Testing of New Wells
Monitoring Well Survey
Survey each new monitoring well
Assessment Report Preparation
Prepare Well Installation and Sampling Report
Submit Report to NCDEQ-SWS
August
2016
September
2016
October
2016
November
2016
December
2016
January
2017
February
2017
March
2017
April
2017
T:\Projects\2016\Energy\7126-16-045_Duke Energy_Shearon Harris Nuclear Plant_Landfill Assessment\Deliverables\Assessment Work Plan\SCHEDULE-DRAFT_HARRIS NUCLEAR PLANT LANDFILL ASSESSMENT.xlsx