Loading...
HomeMy WebLinkAbout8505_DukeBelewsCreek_FGD_AdditionalGWAssessmentPhase1_DIN27858_20170531Belews Creek Steam Station 3195 Pine Hall Road Belews Creek, NC 27009 336-445-0610 336-669-2994 May 31, 2017 North Carolina Department of Environmental Quality Division of Waste Management Solid Waste Section 1646 Mail Service Center Raleigh, North Carolina 28778 Attn: Ms. Elizabeth Werner Re: Additional Assessment of Groundwater Exceedances Belews Creek Steam Station Flue Gas Desulfurization Residue Landfill Permit No. 8505 Belews Creek Steam Station Stokes County Belews Creek, North Carolina 27009 Dear Ms. Werner, Attached you will find the Belews Creek Flue Gas Desulfurization Residue Landfill Additional Assessment of Groundwater Exceedances. The assessment report is being submitted as part of the ongoing assessment initiated in response to your letter dated November 9, 2011 to Mr. Ed Sullivan, P.E. (Duke Energy). Duke Energy is committed to excellent environmental stewardship and cooperation with the Division regarding the operation, maintenance, safety, and integrity of all of its facilities. We look forward to continuing to work with you regarding environmental concerns. If there are any questions regarding this request, please contact me at (336) 445-0610. Respectfully submitted, Melonie Martin Environmental Services Additional Assessment of Groundwater Exceedances – Phase I Belews Creek Steam Station Flue Gas Desulfurization Residue Landfill Permit No. 8505 Site Name and Location Belews Creek Steam Station 3195 Pine Hall Road Belews Creek, NC 27009 Groundwater Incident No.Not Assigned NPDES Permit No.NC0024406 Date of Report May 31, 2017 Permittee and Current Property Owner Duke Energy Carolinas, LLC 526 South Church St. Charlotte, NC 28202-1803 704.382.3853 Consultant Information HDR Engineering, Inc. of the Carolinas 440 South Church St, Suite 900 Charlotte, NC 28202 704.338.6700 Latitude and Longitude of Facility 36° 28’ 14” N, 80° 06’ 03” W Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 ii Contents Page Section 1 – Background ............................................................................................................. 1 1.1 2011 Requirement for Groundwater Assessment......................................................... 1 1.2 Monitoring Well BC-25 Assessment............................................................................. 2 1.3 Supplemental Groundwater Assessment ..................................................................... 3 1.4 Additional Groundwater Assessment Work Plan.......................................................... 4 Section 2 – Site Description and Groundwater Monitoring Program........................................... 7 2.1 Site and Flue-gas Desulfurization Residue Landfill Description.................................... 7 2.2 Site Geology and Hydrogeology................................................................................... 8 2.3 Description of Monitoring System................................................................................. 9 2.4 Site Groundwater Flow ................................................................................................ 9 2.5 Groundwater Quality Monitoring..................................................................................10 Section 3 – Additional Assessment...........................................................................................11 3.1 Task 1 – Review Existing Data...................................................................................11 3.1.1 Analytical Results from Semi-Annual Sampling Events........................................11 3.1.2 Landfill Construction and Liner Information ..........................................................15 3.2 Well Inspection, Cleaning, and Redevelopment ..........................................................15 3.3 Collect and Analyze Soil and Surface Water Samples ................................................16 3.4 Water Level Monitoring in BC-25 ................................................................................18 3.5.1 Groundwater Analytical Results...........................................................................19 3.5.2 Refined Groundwater Flow ..................................................................................20 Section 4 – Conclusions and Recommendations ......................................................................21 4.1 Conclusions................................................................................................................21 4.2 Recommendations......................................................................................................22 Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 iii FIGURES 1. Site Location Map 2. Site Layout 3. Generalized Groundwater Surface Contours – November 2016 4. BC-20, BC-21, BC-25, BC-26, BC-32 Sulfate Concentrations 5. BC-25 Sulfate and TDS Concentrations 6. BC-20, BC-21, BC-25, BC-26, BC-32 TDS Concentrations 7. BC-20, BC-21, BC-25, BC-26, BC-32 Selenium Concentrations 8. SW-1 Sulfate and TDS Concentrations 9. Soil Sampling Locations 10. BC-25 Groundwater Elevations and Conductivity 11. BC-28 Groundwater Elevations and Conductivity 12. BC-25 Groundwater Elevations and Precipitation 13. BC-28 Groundwater Elevations and Precipitation 14. BC-20, BC-21, BC-25, BC-26, BC-27, BC-29, and BC-7 Groundwater Elevations 15. BC-20 Sulfate Concentrations and Groundwater Elevations 16. BC-21 Sulfate Concentrations and Groundwater Elevations 17. BC-25 Sulfate Concentrations and Groundwater Elevations 18. Additional Assessment Well Locations 19. Sulfate Isoconcentration Contour Map 20. Generalized Groundwater Surface Contours – March 2017 TABLES 1. Selected Sulfate Analytical Results for Monitoring Wells BC-20, BC-21, BC-25, BC-26, and BC-32 2. Groundwater Analytical Results Background Monitoring Wells 3. Selected TDS Analytical Results for Monitoring Wells BC-20, BC-21, BC-25, BC-26, and BC-32 4. Selected Selenium Analytical Results for Monitoring Wells BC-20, BC-21, BC-25, BC- 26, and BC-32 5. Summary of Soil Analytical Results 6. Summary of Groundwater Analytical Results APPENDICES A Well Inspection Forms and Redevelopment Logs Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 1 – Background 1 Section 1 – Background The Belews Creek Steam Station (BCSS) Flue Gas Desulfurization (FGD) Residue Landfill (FGD Residue Landfill), Permit No. 8505, is located at the Belews Creek Steam Station in Stokes County, North Carolina (Figure 1), and is owned and operated by Duke Energy Carolinas, LLC (Duke Energy). Exceedances of groundwater quality standards, as found in Title 15A North Carolina Administrative Code (NCAC) Subchapter 2L .0202 Groundwater Quality Standards (2L Standards), were reported in samples collected from groundwater monitoring well BC-25 and other monitoring wells sampled during the May 16, 2011, groundwater monitoring event. As described below, an initial assessment and a supplemental assessment, as documented in reports dated October 5, 2012, and June 4, 2014, respectively, were performed to evaluate if the source of exceedances was related to naturally occurring conditions or to impacts from the BCSS FGD Residue Landfill. The results of evaluations completed in 2012 and 2014 did not conclusively identify the source of exceedances in groundwater monitoring wells located north and northwest of the FGD Residue Landfill. Thus, Duke Energy proposed a phased approach to additional assessment activities to further evaluate whether the FGD Residue Landfill is the source of exceedances. The initial phase, Phase I, proposed to review existing data and to collect field data from landfill monitoring wells and other recently installed wells in the vicinity of the FGD Residue Landfill. The results from Phase I would be used to identify if any additional field efforts (e.g., installation of additional groundwater monitoring wells) are required in Phase II to determine if the FGD Residue Landfill is the source of exceedances. The phased assessment was proposed and documented in the Proposed Work Plan for Additional Assessment of Groundwater Exceedances (work plan) and was submitted to the North Carolina Department of Environmental Quality (NCDEQ)1 Division of Waste Management (DWM) in August 2016. The work plan was approved by the NCDEQ DWM in correspondence dated September 7, 2016. The results of Phase I activities are summarized herein. 1.1 2011 Requirement for Groundwater Assessment In a letter dated November 9, 2011,2 to Mr. Ed Sullivan, P.E., of Duke Energy, the North Carolina Department of Environment and Natural Resources (NCDENR) DWM stated that exceedances of groundwater standards established in Title 15A North Carolina Administrative Code (NCAC) Subchapter 2L .0202 Groundwater Quality Standards (2L Standards) were reported in samples collected from groundwater monitoring well BC-25 during the May 16, 2011, sampling event.3 1 Prior to September 18, 2015, the NCDEQ was referred to as the North Carolina Department of Environment and Natural Resources (NCDENR). Both naming conventions are used in this report, as appropriate.2 North Carolina Department of Environment and Natural Resources. Division of Waste Management. November 9, 2011, Monitoring Well BC-25 Assessment. Duke Energy – Belews Creek FGD Landfill. DOC ID 15487.3 The NCDENR letter references the monitoring event as occurring on May 6, 2011. The actual date for the sampling event was May 16, 2011. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 1 – Background 2 The NCDENR letter stated that iron was reported at a concentration greater than the respective 2L Standard in the groundwater sample collected from BC-25 during this event. Monitoring well BC-25 is located beyond the compliance boundary. NCDENR also stated that industrial landfills are required to comply with the 2L Standards at the compliance boundary in accordance with 15A NCAC 13B .0503 (2)(d)(iv). The NCDENR letter also stated that iron and manganese were reported at concentrations above their respective 2L Standards in groundwater monitoring wells BC-20, BC-21, BC-23A, BC-26, BC-27, BC-29, and BC-31. These groundwater monitoring wells are located at or beyond the review boundary (Figure 2). NCDENR stated that based on these exceedances, Duke Energy must submit a groundwater assessment work plan to the DWM. The assessment work plan, dated February 9, 2012, was prepared by Altamont Environmental Inc. (Altamont) on behalf of Duke Energy and was approved by the DWM on March 23, 2012 (DOC ID 16351). 1.2 Monitoring Well BC-25 Assessment Monitoring well BC-25 is located outside of the compliance boundary and was installed as part of the initial permitting site investigation to obtain groundwater elevations and was subsequently incorporated into the groundwater sampling program. It was installed on February 21, 2006, which was more than a year prior to the pre-placement sampling at the BCSS FGD Residue Landfill. HDR prepared and submitted an assessment4 to NCDENR on behalf of Duke Energy for groundwater exceedances at groundwater monitoring wells BC-20, BC-21, BC-23A, BC-25, BC-26, BC-27, BC-29, and BC-31 and at surface water sample location SW-1. The assessment report concluded: x The source of iron exceedances reported in monitoring wells BC-20, BC-21, BC-23A, BC-26, BC-27, BC-29, and BC-31 appeared to be related to turbidity introduced from naturally occurring sources; x The source of manganese exceedances reported in monitoring well BC-27 appeared to be related to turbidity introduced from naturally occurring sources; x The manganese results at monitoring well BC-21 did not appear to be related to turbidity; and x The iron and manganese exceedances at surface water sampling location SW-1 appeared to be from naturally occurring sources and not related to impacts from the FGD Residue Landfill. The report included an assessment of 2L Standard exceedances for iron, sulfate, and TDS at monitoring well BC-25. The iron exceedances were determined to be attributed to turbidity in the groundwater samples and naturally occurring conditions. The assessment report concluded that the source of the sulfate in monitoring well BC-25 appeared to be from the FGD Residue Landfill. 4 HDR Engineering, Inc. of the Carolinas report Groundwater Assessment, Belews Creek Steam Station, FGD Residue Landfill, Permit No. 8505, dated October 5, 2012. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 1 – Background 3 HDR recommended installing an additional monitoring well at the review boundary between monitoring well BC-25 and the FGD Residue Landfill to further delineate the sulfate and TDS concentrations in this area and improve the understanding of groundwater flow near monitoring well BC-25. HDR further recommended that monitoring well BC-21 be re-sampled when the new monitoring well is sampled. In a letter dated November 28, 2012, to Mr. Ed Sullivan, P.E., of Duke Energy, the NCDENR DWM approved the recommendations presented in HDR’s groundwater assessment report dated October 5, 2012.5 1.3 Supplemental Groundwater Assessment A supplemental groundwater assessment at the FGD Residue Landfill was performed as stated in the recommendations in the groundwater assessment report dated October 5, 2012. The supplemental assessment report6 dated June 4, 2014, included a description of the additional monitoring well (BC-32) installed at the review boundary between monitoring well BC-25 and the FGD Residue Landfill to further delineate the sulfate and TDS concentrations in this area and improve the understanding of groundwater flow near monitoring well BC-25. HDR reviewed the operations of the FGD Residue Landfill, the groundwater flow in the FGD Residue Landfill area, and the analytical results for groundwater monitoring wells, and evaluated the following as the possible sources of the exceedances for sulfate and TDS in monitoring wells BC-20, BC-21, BC-25, and BC-32 and for selenium in monitoring well BC-21: x Leachate leakage through the engineered liner system and x Gypsum deposited onto the ground surface infiltrating into groundwater. If the source of the sulfate and TDS in monitoring wells BC-20, BC-21, and BC-25 and the source of the selenium in monitoring well BC-21 was caused by leakage in the liner system as a result of the failure of the geo-synthetic clay liner (GCL) to seal a defect or damage to the geomembrane, it was reasonable to expect that: 1. The concentration of sulfate, TDS, and selenium in newly installed monitoring well BC-32 would be greater than the concentrations observed in monitoring well BC-25. 2. The concentrations of sulfate and TDS in monitoring wells BC-20, BC-21, and BC-25 and the concentration of selenium in monitoring well BC-21 would continue to increase or remain elevated. It was concluded in the supplemental assessment report that although it was not possible to eliminate leakage through the liner system as a cause, HDR did not consider leakage through the liner system to be the likely source of the exceedances because: 5 North Carolina Department of Environment and Natural Resources, Division of Waste Management. November 28, 2012, Groundwater Assessment Report Response. Duke Energy – Belews Creek FGD Landfill, DOC ID 17761.6 North Carolina Department of Environment and Natural Resources, Division of Waste Management. June 4, 2014, Supplemental Groundwater Assessment. Duke Energy – Belews Creek FGD Landfill. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 1 – Background 4 x The sulfate and TDS concentrations had decreased since May 2013 in monitoring wells BC-20, BC-21, and BC-25, and since August 2013 in monitoring well BC-21. x The sulfate concentrations measured in monitoring well BC-32 were less than those measured in monitoring well BC-25. x The selenium concentrations decreased in monitoring well BC-21 and in BC-25. The additional assessment report concluded that increases in precipitation runoff received by non-contact stormwater basins SB-6 and SB-7, due to the progress of filling Cell 1, may have caused deposited FGD residue to be subjected to increased infiltration into the groundwater at these basins. Based on the correlation between groundwater level and increase in sulfate, TDS, and selenium concentrations observed in the monitoring wells located in close proximity to the sediment basins, it appears that an increase in surface runoff and infiltration of gypsum into the groundwater in this area may be the source of exceedances of sulfate, TDS, and selenium in these wells. As part of the supplemental assessment report, HDR recommended: 1. Concentrations of sulfate in BC-32 are in excess of the 2L Standard. Monitoring well BC-32 was installed at the review boundary and should continue to be sampled as part of the groundwater monitoring program for the FGD Residue Landfill. 2. Although decreasing, concentrations of sulfate and TDS in BC-25 are in excess of the respective 2L Standards. If the concentrations of sulfate and TDS decrease to below the 2L Standard in monitoring wells BC-25 and BC-32 and remain below the 2L Standard for a minimum of two sampling events, HDR recommends that groundwater monitoring be discontinued in monitoring well BC-25 and that monitoring well BC-32 be incorporated into the groundwater monitoring program for the FGD Residue Landfill as BC-32 is located at the review boundary and BC-25 is outside of the compliance boundary. Monitoring well BC-25 would be abandoned at that time. 3. If the concentrations of sulfate and TDS remain above the 2L Standards in monitoring wells BC-25 and BC-32 for the next three sampling events, conduct an additional assessment to identify the source of the exceedances. 1.4 Additional Groundwater Assessment Work Plan The Phase I Proposed Additional Groundwater Assessment Work Plan (work plan) to address the recommendations presented in the June 4, 2014, supplemental groundwater assessment report was submitted in August 2016 and approved by the NCDEQ DWM on September 7, 2016.7 The work plan scope included reviewing existing data and collecting field data to evaluate if the BCSS FGD Residue Landfill is the source of the sulfate and TDS exceedances of the 2L Standards in monitoring wells BC-25 and BC-32. The work plan was later amended to use previously installed groundwater monitoring wells in close proximity to the proposed well 7 North Carolina Department of Environmental Quality, Division of Waste Management. September 7, 2016, Approval of Work Plan, Additional Assessment of Groundwater Exceedances. Duke Energy Carolinas – Belews Creek Steam Station FGD Landfill, DOC ID 26714. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 1 – Background 5 locations (FGDLA-1S/D and FGDLA-2S/D) as indicated in the original work plan. 8 NCDEQ DWM approved the amendment to the work plan in a February 24, 2017, letter to Duke Energy. 9 The assessment work plan included the following: x An evaluation of the 2L Standard exceedances of sulfate and TDS in monitoring wells BC-20, BC-21, BC-25, and BC-32. During the August 19, 2013, sampling event, a 2L Standard exceedance for selenium was reported in monitoring well BC-21. An assessment of the selenium exceedance in monitoring well BC-21 was included in the June 4, 2014, supplemental groundwater assessment report. x During the May 2015 and November 2015 sampling events, selenium was reported in monitoring well BC-25 at concentrations greater than the 2L Standard. An assessment of selenium at this monitoring well will also be included in this additional groundwater assessment report. x Sulfate and TDS concentrations reported at seep sampling location SW-1 have been generally increasing over the period of monitoring. A preliminary review of the May 2016 sampling results indicate a 2L Standard exceedance of sulfate at this location. An assessment of sulfate and TDS at SW-1 will also be included in this additional groundwater assessment report. x The groundwater assessment will be performed in two phases. The initial phase, Phase I, will be used to review existing data and to collect field data that will be used to evaluate if the BCSS FGD Residue Landfill is the source of the exceedances. The results from Phase I will be used to identify if any additional field efforts (e.g., installation of additional groundwater monitoring wells) are required in Phase II to determine if the FGD Residue Landfill is the source of exceedances. The Phase I work plan tasks identified to conduct the additional groundwater assessment include the following: x Task 1 – Review Existing Data x Task 2 – Well Inspection, Cleaning, and Redevelopment x Task 3 – Collect and Analyze Soil and Surface Water Samples x Task 4 – Install Water Level and Conductance Logger in BC-25 x Task 5 – Installation of Assessment Groundwater Monitoring Wells x Task 6 – Phase I Assessment Report 8 Duke Energy. February 23, 2017, Amendment to FGD Residue Landfill Proposed Work Plan, Additional Assessment of Groundwater Exceedances. Permit No.: 8505-INDUS-, Belews Creek FGD Residue Landfill, Belews Creek Steam Station.9 North Carolina Department of Environmental Quality, Division of Waste Management. February 24, 2017, Concurrence to Amendment to FGD Residue Landfill Proposed Work Plan, Additional Assessment of Groundwater Exceedances. Duke Energy Carolinas – Belews Creek Steam Station FGD Landfill, DOC ID 27448. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 1 – Background 6 The results of these tasks are presented in Section 3 of this Phase I Additional Assessment of Groundwater Exceedances – Phase I Report (Task 6). Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 2 – Site Description and Groundwater Monitoring Program 7 Section 2 – Site Description and Groundwater Monitoring Program 2.1 Site and Flue-gas Desulfurization Residue Landfill Description The FGD Residue Landfill is located at Duke Energy’s Belews Creek Steam Station. Belews Creek Steam Station is a two-unit, coal-fired generating facility located on Belews Lake in Stokes County, North Carolina. The FGD Residue Landfill is permitted under the NCDEQ Solid Waste Permit No. 8505 to receive coal combustion products, FGD residue (gypsum), wastewater treatment clarifier sludge, waste limestone material, sand blast material, and waste coal produced at the Belews Creek Steam Station. However, the FGD Residual Landfill typically receives only gypsum. Other waste streams are disposed in the Craig Road Ash Landfill (Permit #8504). The FGD Residue Landfill is located south of the Belews Creek power plant on a peninsula of land in Belews Lake. The FGD Residue Landfill and nearby surrounding area are depicted on Figure 1. The location of the FGD Residue Landfill is on the northwestern facing side of a ridge running the length of the peninsula. A gravel road, located near monitoring wells BC-28 and BC-23A, runs generally along the crest of this ridge. Craig Road is located to the southwest of the FGD Residue Landfill. A gypsum stack-out yard and limestone storage yard are located to the north of the FGD Residue Landfill. A surface water drainage feature is located to the south of the FGD Residue Landfill, draining from the topographic high east of the landfill to the west towards Craig Road. In general, the original site topography slopes from the ridge to the north and to the west. Two sets of high-voltage transmission lines running roughly east to west are located immediately adjacent to and along the northern side of the FGD Residue Landfill. The FGD Residue Landfill consists of four cells contained in an area of approximately 24 acres as shown on Figure 2. The landfill has an engineered liner system consisting of a leachate collection system, underlain by a high-density polyethylene (HDPE) geomembrane liner, underlain by a GCL. A stormwater basin is located on the western edge of the FGD Residue Landfill and occupies an area of approximately 2.4 acres. The stormwater basin is used to manage leachate and contact stormwater collected from the FGD Residue Landfill. The stormwater basin is constructed with a concrete bottom surface, underlain by an HDPE geomembrane liner, which is underlain by a GCL placed above the prepared soil foundation. The FGD Residue Landfill first accepted waste in April 2008. Initial waste placement began in Cell 1. Waste placement has progressed across the four cells of the landfill. As described in the Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 2 – Site Description and Groundwater Monitoring Program 8 operations plan, a 12-inch-thick interim soil cover layer is placed as a dust control measure where final waste grades are achieved.10 2.2 Site Geology and Hydrogeology In 2005, S&ME, Inc. (S&ME) prepared a site suitability study for the BCSS FGD Residue Landfill.11 In 2015, HDR prepared a comprehensive site assessment (CSA) of the BCSS site.12 The 2005 and 2015 studies serve as the background for the discussion of the site geology and hydrogeology. The BCSS site is located in the Milton terrane. Rock units mapped in the vicinity of the site include alluvium, terrace deposits, sedimentary rocks of the Dan River Basin, a diabase dike, and felsic gneisses and schists with interlayered hornblende gneiss and schist. The alluvium consists of unconsolidated sand, silt, and clay with occasional subhedral to well- rounded pebbles and cobles. The terrace deposits consist of unconsolidated sand, silt, and clay with pebbles and cobles of quartz. In places, the terrace deposits are comprised of large angular quartz fragments in a red matrix of sand, silt, and clay. The diabase occurs in a long, relatively thin dike. The rocks of the Milton terrane in the area include interlayered augen gneiss, quartz-feldspar gneiss, flaser gneiss, “button” mica schist, and with interlayers of hornblende gneiss and schist. Based on the 2005 site suitability study, the bedrock in the vicinity of the FGD Residue Landfill generally consists of schist and gneiss. The soils that overlie the bedrock in the area have generally formed from the in-place weathering of the parent bedrock. These soils are termed residuum (residual soils) and saprolite. Based on the CSA site investigation, the groundwater system in the natural materials (alluvium, soil, soil/saprolite, and bedrock) at the BCSS site is consistent with the regolith-fractured rock system and is generally an unconfined, connected aquifer system without confining layers. The groundwater system at the BCSS site is divided into three layers referred to in this report as the shallow, deep (TZ), and bedrock flow layers, so as to distinguish flow layers within the connected aquifer system. Groundwater flow and transport at the BCSS site are assumed to follow the local slope aquifer system. Under natural conditions, the general direction of groundwater flow can be approximated from the surface topography. Topographic divides are located to the south and east of the ash basin approximately along Pine Hall Road. A topographic divide exists to the west of the ash basin along Middleton Loop Road. Another topographic divide exists north of the ash basin along a ridgeline that extends from the east dike abutment toward the northeast. These topographic divides generally function as groundwater divides although groundwater flow across topographic divides may be possible based on driving head conditions from the ash basin and the existence of preferential flow paths within the shallow and/or deep flow layers. The predominant direction of groundwater flows north and northwest toward the Dan River. 10 Belews Creek Steam Station FGD Residue Landfill Operations Plan, prepared by Joyce Engineering, May 23, 2012, JEI Project: 845.1202.11 Task 01, DIN 16987.11 Geologic and Hydrogeologic Siting Report FGD Scrubber Residue Disposal Site Belews Creek Steam Station, Belews Creek, North Carolina, S&ME Project No. 1054-04-955, September 28, 2005.12 Comprehensive Site Assessment Report, Belews Creek Steam Station Ash Basin, Belews Creek, North Carolina, HDR Engineering, Inc. of the Carolinas, September 9, 2015. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 2 – Site Description and Groundwater Monitoring Program 9 2.3 Description of Monitoring System According to the Water Quality Monitoring Plan (WQMP),13 the groundwater monitoring system at the FGD Residue Landfill consists of the following sampling locations: Monitoring Wells: BC-7 BC-26 BC-20 BC-27 BC-21 BC-28 BC-22 BC-29 BC-23A BC-30 BC-25 BC-31 Surface Water Sample Location:SW-1 Leachate Sample:Leachate The groundwater, surface water, and leachate sample locations are shown on Figure 2. According to the WQMP, monitoring wells BC-23A and BC-28 represent background groundwater quality conditions. Monitoring well BC-7 is used for water level measurements only. Other BCSS FGD Residue Landfill monitoring wells are used to monitor groundwater quality in the residual soil/saprolite layer and to measure groundwater levels. Sampling location SW-1 is an area of wetness (AOW) located east of monitoring well BC-28. Periodically, water emanates from the ground just above this sampling location. Therefore, analytical results from sampling location SW-1 are compared to 2L Standards. This surface water feature drains to Belews Lake. The FGD Residue Landfill leachate is sampled at a location within the stormwater basin as shown on Figure 2. 2.4 Site Groundwater Flow As previously described, the FGD Residue Landfill is located on the northwestern side of a ridge running the length of a peninsula between the West Belews Creek arm and the East Belews Creek arm of Belews Lake. A gravel road, located near monitoring wells BC-28 and BC-23A, runs generally along the crest of this ridge. Craig Road is located to the southwest of the FGD Residue Landfill. The approximate ground elevation at monitoring well BC-28 is 815.6 feet and the approximate ground elevation at monitoring well BC-23A is 861.3 feet. The gypsum stack-out yard and limestone storage yard are located north of the FGD Residue Landfill and monitoring wells BC-25, BC-20, and BC-21. The approximate ground elevation at monitoring well BC-25 is 746 feet. A surface water drainage feature is located south of the FGD Residue Landfill and drains to the west towards Craig Road. In general, the original site 13 Water Quality Monitoring Plan FGD Scrubber Residue Landfill Belews Creek Steam Station, S&ME Project 1054-04-955, December 07, 2007. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 2 – Site Description and Groundwater Monitoring Program 10 topography slopes from the ridge near monitoring wells BC-28 and BC-23A towards the north and the west. The elevation of Belews Lake ranges from approximately 722 feet to 725 feet. The predominant groundwater discharge area in the region of the FGD Residue Landfill is expected to be Belews Lake to the northwest of the landfill. Generalized groundwater surface contours from the November 2016 sampling event are shown on Figure 3. Groundwater flow in the area of interest to this assessment is discussed in greater detail in Section 5.1.2. 2.5 Groundwater Quality Monitoring In accordance with the WQMP, groundwater monitoring is performed semi-annually in May and November. Sampling results are due to NCDEQ DWM within 120 days of sampling. The initial groundwater sampling event at the FGD Residue Landfill was performed on November 5, 2007, prior to initial waste placement in April 2008. All 12 monitoring wells were installed prior to the initial sampling event. Surface water sample location SW-1 was first sampled in November 2010. The most recent groundwater monitoring event was conducted on May 3, 2017.14 14 These results will be presented in a subsequent semiannual groundwater monitoring report due to NCDEQ in November 2017. The most recent semiannual groundwater monitoring report to have been submitted to NCDEQ was for the November 2016 monitoring event titled Semiannual Groundwater Monitoring Report, Belews Creek Steam Station, FGD Residue Landfill, Permit No.8505, November 2016 Sampling Event, January 25, 2017, prepared by HDR Engineering, Inc. of the Carolinas. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 3 – Additional Assessment 11 Section 3 – Additional Assessment Additional assessment activities identified in the work plan were addressed and the activity descriptions and findings are discussed in the following section. 3.1 Task 1 – Review Existing Data 3.1.1 Analytical Results from Semi-Annual Sampling Events Since the completion and submittal of HDR’s June 4, 2014, Supplemental Groundwater Assessment Report, the monitoring network at the FGD Residue Landfill has been sampled during the following six semi-annual events: x May 2014 x November 2014 x May 2015 x November 2015 x May 2016 x November 2016 A sub-set of the monitoring network was also sampled as part of this additional assessment. Monitoring wells BC-20, BC-21, BC-23A, BC-25, BC-28, and BC-32 were sampled on March 8, 2017. The analytical results from the six semi-annual sampling events listed above were presented in the following reports prepared by HDR: x Semiannual Groundwater Monitoring Report, Belews Creek Steam Station, FGD Residue Landfill, May 2014 Sampling Event, dated July 29, 2014. x Semiannual Groundwater Monitoring Report, Belews Creek Steam Station, FGD Residue Landfill, November 2014 Sampling Event, dated February 3, 2015. x Semiannual Groundwater Monitoring Report, Belews Creek Steam Station, FGD Residue Landfill, May 2015 Sampling Event, dated July 17, 2015. x Semiannual Groundwater Monitoring Report, Belews Creek Steam Station, FGD Residue Landfill, November 2015 Sampling Event, dated February 2, 2016. x Semiannual Groundwater Monitoring Report, Belews Creek Steam Station, FGD Residue Landfill, May 2016 Sampling Event, dated August 2, 2016. x Semiannual Groundwater Monitoring Report, Belews Creek Steam Station, FGD Residue Landfill, November 2016 Sampling Event, dated January 25, 2017. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 3 –Additional Assessment 12 Groundwater Quality Exceedances - Sulfate The initial sulfate exceedance in the FGD Residue Landfill monitoring network was measured in monitoring well BC-25 during the November 7, 2011, sampling event. The sulfate results from November 2011 through March 2017 for monitoring wells BC-20, BC-21, BC-25, BC-26, and BC-32 are presented in Table 1. These wells are located at or beyond the review boundary. Exceedances of the sulfate 2L Standard have been measured in monitoring wells BC-20, BC-21, BC-25, and BC-32. Sulfate concentrations in monitoring well BC-26 have consistently been reported below the 2L Standard.Figure 4 depicts the sulfate concentrations for monitoring wells BC-20, BC-21, BC-25, BC-26, and BC-32 over the period of monitoring at the FGD Residue Landfill. Review of these data indicates the following trends and observations: x Concentrations in monitoring well BC-25 have decreased since the May 2015 sampling event. x Concentrations in monitoring well BC-32 have been greater than the 2L Standard and have continually increased since the installation sampling event in August 2013, with the exception of a decrease in concentration from the November 2016 to the March 2017 sampling event. x Concentrations measured in monitoring wells BC-20 and BC-21 have been greater than the 2L Standard since the May 2014 sampling event, with the exception of the November 2014 sampling event at BC-20 when sulfate was reported below the 2L Standard. x Background concentrations have ranged from 184 to 630 micrograms per liter (μg/L) in monitoring well BC-23A and from <100 to 466 μg/L in monitoring well BC-28, with the exception of the period from May 2008 to November 2011 when the laboratory method reporting limit (MRL) for sulfate was reported to be 5,000 μg/L. Background monitoring well results are presented on Table 2. x Monitoring well BC-32 is located between the FGD Residue Landfill and monitoring well BC-25. The sulfate concentrations measured in monitoring well BC-32 have been greater than the 2L Standard during each sampling event and have increased during each event since the well was installed and sampled during the August 2013 sampling event until the November 2016 sampling event. The sulfate concentration decreased from the November 2016 to the March 2017 sampling event. The concentrations reported in MW-32 were less than the sulfate concentrations measured in monitoring well BC-25 during each sampling event, with the exception of the recent March 2017 event. Considering groundwater flow direction, if the FGD Residue Landfill was the source of sulfate in groundwater, concentrations in well BC-32 should be higher than those measured in well BC-25; however, sulfate concentrations have consistently been higher in BC-25 than BC-32. Groundwater Quality Exceedances – Total Dissolved Solids Total dissolved solids (TDS) is defined by the United States Environmental Protection Agency (USEPA) as consisting of calcium, chlorides, nitrate, phosphorous, iron, sulfur, and other ion Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 3 –Additional Assessment 13 particles that will pass through a filter with pores of 2 microns in size (http://water.epa.gov/type/rsl/monitoring/vms58.cfm). The trend of TDS results from monitoring wells at the FGD Residue Landfill are similar to trends observed for sulfate. The correlation between sulfate and TDS concentrations in monitoring well BC-25 is shown on Figure 5. The initial TDS exceedance in the FGD Residue Landfill monitoring network was measured in monitoring well BC-25 during the November 7, 2011, sampling event. The TDS results from November 2011 through March 2017 for monitoring wells BC-20, BC-21, BC-25, BC-26, and BC-32 are presented in Table 3. Review of these data indicates the following trends and observations: x TDS concentrations measured in the background monitoring wells have ranged from 44,000 to 138,000 μg/L in monitoring well BC-23A and from 36,000 to 81,000 μg/L in monitoring well BC-28. Background monitoring well results are presented in Table 2. x Exceedances of the 2L Standard have been measured in monitoring wells BC-20, BC-21, BC-25, and BC-32. TDS concentrations in monitoring wells BC-20, BC-21, BC-25, BC-26, and BC-32 over the period of monitoring at the landfill are shown on Figure 6. x TDS concentrations in monitoring well BC-25 have decreased since the November 2015 sampling event, with an increase during the March 2017 sampling event. x TDS concentrations in monitoring well BC-32 have been greater than the 2L Standard and generally increased from the installation sampling event in August 2013 until the May 2016 sampling where they began to decrease. x TDS concentrations measured in monitoring wells BC-20 and BC-21 have been greater than the 2L Standard since the May 2014 sampling event, with the exception of the November 2014 sampling event at BC-20 which was less than the 2L Standard. x Monitoring well BC-32 is located between the FGD Residue Landfill and monitoring well BC-25. TDS concentrations measured in monitoring well BC-32 have been greater than the 2L Standard during every sampling event and have generally increased since the well was first installed and sampled during the August 2013 sampling event until the May 2016 sampling where they began to decrease. The concentrations reported in MW-32 were less than the TDS concentrations measured in monitoring well BC-25 during these sampling events with the exception of the November 2016 sampling event in which the results were generally the same with BC-32 (1,330,000 ug/L) being a slightly greater concentration than BC-25 (1,320,000 ug/L). If the source of TDS measured in these monitoring wells was the landfill, it would be expected that the concentrations measured in monitoring well BC-32 would be consistently greater than those measured in monitoring well BC-25; however, TDS concentrations have consistently been higher in BC-25 than BC-32. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 3 –Additional Assessment 14 Groundwater Quality Exceedances – Selenium Concentrations of selenium that exceeded the 2L Standard were measured in monitoring well BC-21 during the August 2013 sampling event and in monitoring well BC-25 during the May and November 2015 sampling events. These exceedances constitute the only 2L Standard exceedances for selenium in the monitoring network over the period of monitoring. The selenium concentration in monitoring well BC-21 returned to a concentration less than the 2L Standard during the subsequent November 2013 sampling event. The selenium concentration in BC-25 has been decreasing since the November 2015 exceedance and has been less than the 2L Standard during the last two sampling events. The selenium results from November 2011 through March 2017 for monitoring wells BC-20, BC-21, BC-25, BC-26, and BC-32 are presented in Table 4 and are shown on Figure 7. Review of these data indicates the following trends and observations: x Selenium has not been measured at a concentration that attains or exceeds the laboratory reporting limit in background monitoring wells BC-23A and BC-28 over the period of monitoring. Background monitoring well results are presented in Table 2. Monitoring well BC-32 is located between the FGD Residue Landfill and monitoring well BC-25. Selenium concentrations measured in monitoring well BC-32 have been less than the 2L Standard during every sampling event and less than the selenium concentrations measured in monitoring well BC-25 during every sampling event. If the source of selenium measured in these monitoring wells was the landfill, concentrations measured in monitoring well BC-32 should be consistently greater than those measured in monitoring well BC-25; however, selenium concentrations have consistently been higher in BC-25 than BC-32. Surface Water Quality Exceedances – Sulfate and TDS Sulfate and TDS concentrations reported at AOW sampling location SW-1 have generally increased from the November 2010 through the May 2016 sampling event. The concentration reported during the May 2016 sampling event constituted the first 2L Standard exceedance of sulfate reported during the monitoring period. The sulfate and TDS results reported in the sample collected during the November 2016 sampling event decreased to levels similar to the November 2010 and May 2011 results. Sulfate and TDS results at SW-1 over the period of monitoring are presented on Figure 8. Monitoring wells BC-31 and BC-28 are the closest landfill monitoring wells to AOW sample location SW-1. Sulfate concentrations over the period of monitoring in these monitoring wells have ranged from 271 to 2,712 ug/L. Based on the generalized groundwater surface contours, groundwater at these monitoring wells is flowing to the west and northwest across the landfill, and not from the landfill towards SW-1. Historical aerial deposition from the gypsum stack-out area may have contributed to the concentrations of sulfate and/or TDS reported in the samples collected from SW-1. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 3 –Additional Assessment 15 Enhanced dust control measures at the gypsum stack-out pad were implemented in October 2015 to minimize fugitive dust emissions. Control of fugitive dust at the gypsum stack-out area will reduce the aerial deposition of gypsum in the surrounding area. If fugitive dust was the cause of the historical increases in concentrations reported at SW-1, the concentrations of sulfate and TDS should continue to decrease or remain stable at the SW-1 sample location. 3.1.2 Landfill Construction and Liner Information The FGD Residue Landfill consists of four cells contained in an area of approximately 24 acres as shown on Figure 2. The FGD Residue Landfill first accepted waste in April 2008. Initial waste placement began in Cell 1. As of June 30, 2013, approximately 1,078,464 tons of waste had been placed in the landfill. Waste placement has progressed across the four cells of the landfill. As described in the operations plan, a 12-inch-thick interim soil cover layer is placed as a dust control measure where final waste grades are achieved. The landfill has an engineered liner system consisting of a leachate collection system, underlain by a HDPE geomembrane liner, underlain by a GCL. A stormwater basin is located on the western edge of the FGD Residue Landfill and occupies an area of approximately 2.4 acres. The stormwater basin is used to manage leachate and contact stormwater collected from the FGD Residue Landfill. The stormwater basin is constructed with a concrete bottom surface, underlain by an HDPE geomembrane liner, which is underlain by a GCL placed above the prepared soil foundation. If the source of the sulfate and TDS in monitoring wells BC-20, BC-21, BC-25, and BC-32, and the source of the selenium in monitoring wells BC-21 and BC-25 was caused by leakage in the liner system as a result of the failure of the GCL to seal a defect or damage to the geomembrane, it was reasonable to expect that: 1. The concentration of sulfate, TDS, and selenium in monitoring well BC-32 would be greater than the concentrations observed in monitoring well BC-25. 2. The concentrations of sulfate and TDS in monitoring wells BC-20, BC-21, BC-25, and BC-32, and the concentration of selenium in monitoring wells BC-21 and BC-25 would continue to increase or remain elevated. However, the data reviewed in this assessment does not indicate that either line of evidence is occurring at the FGD Residue Landfill. 3.2 Well Inspection, Cleaning, and Redevelopment The BCSS FGD Residue Landfill compliance monitoring well sampling records were reviewed to identify wells with historically high (>10 NTU) turbidity measurements. Historically high turbidity was identified in monitoring wells BC-23A, BC-25, and BC-30; these wells were scheduled for redevelopment to potentially remove fine-grained particles from the well and sand pack. Monitoring wells BC-20, BC-21, and BC-32 were also identified for redevelopment due to historical groundwater quality standard exceedances. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 3 –Additional Assessment 16 On November 9, 10, and 11, 2016, SynTerra personnel completed inspections of the compliance wells at the BCSS FGD Residue Landfill and found the surface completions in satisfactory condition. The dedicated pumps were removed from monitoring wells BC-20, BC-21, BC-23A, BC-25, BC-30, and BC-32 prior to their redevelopment. The pumps were inspected and cleaned with deionized water. Well inspection forms are presented in Appendix A. The six monitoring wells scheduled for redevelopment were evacuated of between 10 and 20 well volumes. Only well BC-21 exhibited a reduction in turbidity readings during redevelopment. The five remaining monitoring wells (BC-20, BC-23A, BC-25, BC-30, and BC-32) continued to yield turbid water (>10 NTU and brown coloration) with suspended sediment after a minimum of 10 well volumes purged. The observations suggest that sediment infiltration may be occurring via the formation into the well screen as no evidence of surficial sediment intrusion was observed around the well surface completions. Well redevelopment logs are in included in Appendix A. Neoprene slip caps (2-inch diameter) were installed on the well heads after inspection and redevelopment. Monitoring well BC-22 contained a wider pump cap preventing the installation of a 2-inch neoprene cap on this well. All of the groundwater monitoring wells that were redeveloped (BC-20, BC-21, BC-23A, BC-25, BC-30, and BC-32) were sampled for analysis in March 2017 with the exception of monitoring well BC-30. The turbidity readings reported in the five monitoring wells that were redeveloped were all less than 10 NTU. 3.3 Collect and Analyze Soil and Surface Water Samples Monitoring wells BC-25, BC-32, BC-21, and BC-20 are located between the BCSS FGD Residue Landfill and the gypsum stack-out area as shown on Figure 2. Soil samples were collected from locations between these areas to evaluate possible surficial sources for the exceedances reported in the monitoring wells. The approximate locations of the soil samples are depicted on Figure 9. Background soil samples were also collected at similar depths from a location east of the FGD Residue Landfill (FGDBGSB-1). Sample locations include the sediment basins north of the landfill, the drainage feature adjacent to BC-25, and other areas as shown on Figure 9. The soil samples were collected using a hand auger at five approximate depth intervals: ground surface, 1 foot below ground surface (bgs), 2 feet bgs, 3 feet bgs, and at hand auger refusal (or 5 feet bgs, whichever is encountered first). Soil samples were analyzed for the following constituents using the methods identified in the work plan: boron, chloride, fluoride, iron, manganese, selenium, and sulfate. All of the proposed surface water sample locations were dry at the time of sampling; therefore, soil samples were collected from the designated surface water sample locations. Hand auger refusal was encountered prior to reaching 5 feet bgs at 14 of the 19 sample locations. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 3 –Additional Assessment 17 The depths of the soil samples and the results of the analyses are presented in Table 5. Results of soil sample collection and analysis are as follows: x Five soil samples were collected from the background soil sample location (FGDBGSB-1) from depths ranging from the ground surface (0 to 0.5 foot bgs) to approximately 5 feet bgs. Selenium concentrations in the background soil samples ranged from 0.717 milligrams per kilogram (mg/kg) in the 0 to 0.5-foot bgs sample to 1.24 mg/kg in the 5-foot sample. The NCDEQ protection of groundwater preliminary soil remediation goal (PSRG) for selenium is 2.1 mg/kg. Selenium was reported in all of the soil samples collected at concentrations greater than the laboratory reporting limit and several concentrations reported were greater than the protection of groundwater PSRG. x Sulfate concentrations in the background soil samples ranged from less than the laboratory reporting limit (1.67 mg/kg) in the sample collected from 3 feet bgs to 42.6 mg/kg in the sample collected from 0 to 0.5-foot bgs. There is no established protection of groundwater PSRG for sulfate. The sulfate concentrations reported in the soil samples tend to decrease in concentration with greater depths. The results of analysis of soil samples collected from the 4-foot or 5-foot bgs range were consistent with results reported for background samples. Aerial deposition due to historical housekeeping/operations at the gypsum stack-out area may have contributed to the concentrations of sulfate and/or selenium reported in the soil samples collected near the ground surface in this portion of the site. The selenium and sulfate reported in the soil may be contributing to concentrations of these constituents in groundwater. Duke Energy instituted a dust management plan at the FGD Residue Landfill in January 2013. Additionally, in April 2012, a tire/truck washing system was installed to minimize dusting. The wash system was installed to wash the tires and underneath the trucks prior to the trucks leaving the gypsum stack-out area. A similar washing system is employed for vehicles leaving the FGD Residue Landfill. Dust control measures at the gypsum stack-out pad have been updated and implemented since October 2015 in order to minimize fugitive dust. The maintenance and housekeeping activities implemented at the gypsum stack-out area since October 2015 include: x Asphalt paving and sealing of the area under the radial stacker; x Installation of curbing along the non-ditched portion of the pad road perimeter; x Cleaning and flushing of the subsurface drainage system; x Extension of the vertical spray guards at the wheel wash; x Sealing of perimeter road and ditchline cracks; x Concrete paving of some perimeter exposed areas; x Affixing the pad liner to the interior of the perimeter road; Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 3 –Additional Assessment 18 x Addition of a dedicated water truck for road cleaning and dust control; and x No loading in the scale area. The reduction of fugitive dust at the gypsum stack-out area will reduce the aerial deposition of gypsum in the surrounding area and reduce gypsum on the ground surface being introduced to groundwater during rain (flushing) events. 3.4 Water Level Monitoring in BC-25 A data logger, capable of measuring and recording water levels, temperature, and conductivity was installed in well BC-25 to assist in evaluating possible impacts from surface water. The logged data was reviewed for changes that may be attributed to infiltration of surface water. For comparison to background conditions, a second logger was installed to monitor the same parameters in BC-28, the site background well. The dataloggers were installed on November 30, 2016, and downloaded approximately every 2 weeks over the period of monitoring to assure that they were functioning properly. The dataloggers were removed from the monitoring wells on February 2, 2017. Graphs of groundwater elevations and conductivity readings from the dataloggers placed in monitoring wells BC-25 and BC-28 are presented on Figures 10 and 11, respectively. Comparing the water levels and conductivity readings in these wells yields no direct correlation. However, the conductivity readings in BC-25 are greater than those reported in BC-28. Also, the variability of both groundwater elevations and conductivity readings in BC-25 are greater than those reported in BC-28 which maintained relatively constant water level and conductivity readings over the logging period. The location of sediment basin SB-6 located adjacent to BC-25 may be having an effect on the greater variability in groundwater elevations compared to BC-28 which is not located near a sediment basin. Rainfall data over the logging period were obtained from United States Geologic Survey (USGS) rainfall gauge 02069000 located on the Dan River at Pine Hall, North Carolina. Precipitation and groundwater elevation graphs for monitoring wells BC-25 and BC-28 are presented on Figures 12 and 13, respectively. Monitoring well BC-25 (located near the sediment basins) shows a greater fluctuation in groundwater elevation compared to rainfall amounts than does BC-28 for the same rainfall events. The groundwater elevations in monitoring wells BC-20, BC-21, BC-25, BC-26, BC-27, BC-29, and BC-7 over the period of monitoring are shown on Figure 14. A greater fluctuation in water level elevations in the monitoring wells located near the sediment basins (monitoring wells BC-20, BC-21, and BC-25) can be seen on Figure 14 compared to the wells located away from the sediment basins over the period of monitoring. Sulfate concentrations and water level elevations in monitoring wells BC-20, BC-21, and BC-25 are shown on Figures 15,16, and 17,respectively. These figures generally show that increases in sulfate concentrations measured during sampling event coincide with increased water level elevations measured in each of these wells over the period of monitoring. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 3 –Additional Assessment 19 The selenium concentrations in monitoring wells BC-20, BC-21, BC-25, BC-26, and BC-32 are depicted on Figure 7.Review of Figure 7 indicates the selenium exceedance of 23.7 μg/L measured in monitoring well BC-21 during the August 2013 sampling event followed by a decrease to 2.69 μg/L in the following sampling event in November 2013. Monitoring well BC-25 shows a similar increase in selenium concentrations followed by decreases in concentrations during the following sampling event. The increases and subsequent decreases in selenium concentrations correspond to increases and subsequent decreases in the groundwater elevations as shown on Figure 14. 3.5 Installation of Assessment Groundwater Monitoring Wells Two pairs of nested groundwater monitoring wells were proposed for installation along the northern side of the FGD Residue Landfill in the work plan. Each location was proposed to consist of a shallow “S” and a deep “D” monitoring well (FGDLA-1S/D and FGDLA-2S/D). The proposed location of these monitoring wells was between the existing landfill monitoring wells with reported exceedances and the landfill limit of waste. Duke Energy later submitted an amendment to the work plan to utilize previously installed groundwater monitoring wells at the landfill to obtain the necessary data instead of installing the proposed wells. The amendment was approved by NCDEQ in a letter dated February 24, 2017. The monitoring wells utilized for analysis are BC-20, BC-21, BC-23A, BC-25, BC-28, BC-32, CCR-FGD-3S, CCR-FGD-3D, CCR-FGD4S, CCR-FGD-4D, CCR-FGD-5S, and CCR-FGD-5D (Figure 18). Shallow “BC” and “S” monitoring wells are defined as wells set to bracket the water table surface at the time of installation. Deep “D” monitoring wells are defined as wells that are screened within the partially weathered/fractured bedrock transition zone at the base of the regolith. Monitoring wells CCR-FGD-3S, CCR-FGD-3D, CCR-FGD-4S, CCR-FGD-4D, CCR-FGD-5S, and CCR-FGD-5D are located between existing landfill monitoring wells with reported exceedances and the landfill limit of waste. The monitoring wells were sampled on March 8, 2017, and analyzed for the following constituents by the methods identified in the work plan: arsenic, barium, boron, cadmium, chloride, chromium, copper, fluoride, iron, lead, manganese, mercury, nickel, nitrate as nitrogen, selenium, silver, sulfate, TDS, and zinc. A summary of the analytical results from the March 2017 sampling event are presented in Table 6. 3.5.1 Groundwater Analytical Results Monitoring wells CCR-FGD-5S and CCR-FGD-5D are located near the limit of waste, between monitoring well BC-32 and the landfill (Figure 18). The selenium, sulfate, and TDS results reported in CCR-FGD-5S and CCR-FGD-5D were all less than the 2L Standards and less than the concentrations reported in BC-32. Sulfate and TDS exceedances were reported in BC-32 during the March 2017 sampling event. If the source of selenium, sulfate, and TDS measured in these monitoring wells was the landfill, it would be expected that the concentrations measured in monitoring wells CCR-FGD-5S and CCR-FGD-5D would be greater than those measured in Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 3 –Additional Assessment 20 monitoring well BC-32. The following observations were made upon review of the March 2017 laboratory data: x Monitoring wells CCR-FGD-4S and CCR-FGD-4D are located near the limit of waste between monitoring well BC-20 and the landfill (Figure 18). The selenium, sulfate, and TDS results reported in CCR-FGD-4S were less than the 2L Standards and less than the concentrations reported in BC-20. Sulfate and TDS exceedances were reported in CCR-FGD-4D and BC-20 during the March 2017 sampling event; however, the concentrations reported in CCR-FGD-4D were less than those reported in BC-20. If the source of selenium, sulfate, and TDS measured in these monitoring wells was the landfill, it would be expected that the concentrations measured in monitoring wells CCR-FGD-4S and CCR-FGD-4D would be greater than those measured in monitoring well BC-20. x Monitoring wells CCR-FGD-3S and CCR-FGD-3D are located near the limit of waste between monitoring wells BC-20 and BC-21 and the landfill (Figure 18). Selenium, sulfate, and TDS results reported in CCR-FGD-3S and CCR-FGD-3D were less than the 2L Standards and less than the concentrations reported in BC-20 and BC-21. Sulfate and TDS exceedances were reported in monitoring wells BC-20 and BC-21 during the March 2017 sampling event. If the source of selenium, sulfate, and TDS measured in these monitoring wells was the landfill, it would be expected that the concentrations measured in monitoring wells CCR-FGD-3S and CCR-FGD-3D would be greater than those measured in monitoring wells BC-20 and BC-21. A sulfate isoconcentration map is presented as Figure 19. 3.5.2 Refined Groundwater Flow On March 6, 2017, depth to groundwater was gauged in wells BC-7, BC-20, BC-21, BC-22, BC-23A, BC-25, BC-26, BC-27, BC-28, BC-29, BC-31, BC-32, CCR-FGD-2S, CCR-FGD-2D, CCR-FGD-3S, CCR-FGD-3D, CCR-FGD-4S, CCR-FGD-4D, CCR-FGD-5S, CCR-FGD-5D, CCR-FGD-6S, CCR-FGD-6D, CCR-FGD-7S, and CCR-FGD-7D. Inferred groundwater contours for the March 6, 2017, gauging event are presented on Figure 20. Groundwater flow in the northwest portion of the landfill is to the west and northwest toward Belews Lake. This is consistent with the November 2016 inferred groundwater flow contours presented on Figure 3 and with historical groundwater data at the landfill. If the source of exceedances was the landfill, it would be expected that the monitoring wells closer to the landfill (CCR-FGD-3S/D, CCR-FGD-4S/D, and CCR-FGD-5S/D) would have greater concentrations reported than monitoring wells further from the landfill (BC-20, BC-21, BC-25, and BC-32). Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 4 – Conclusions and Recommendations 21 Section 4 – Conclusions and Recommendations 4.1 Conclusions The following conclusions have been developed from the information presented in this additional assessment report: x Based on the selenium, sulfate, and TDS results reported during the March 2017 well inspection and redevelopment sampling event, gypsum directly entering the monitoring wells at the well heads from aerial deposition is not a significant contributor to the exceedances reported in monitoring wells BC-20, BC-21, BC-25, or BC-32. x Aerial deposition due to the historical gypsum stack-out area and landfill operations may have contributed to the concentrations of sulfate and/or selenium reported in the near surface soil samples in this portion of the site. The selenium and sulfate reported in the soil may be contributing to concentrations of these constituents reported in groundwater. x Comparing the datalogger results of water levels and conductivity readings in wells BC-25 and BC28, there is not a direct correlation between water levels and conductivity readings. However, the conductivity readings in BC-25 are greater than those reported in BC-28. Also, the variability of both groundwater elevations and conductivity readings in BC-25 are greater than those reported in BC-28, which maintained relatively constant water level and conductivity readings over the period the dataloggers were installed. The proximity of sediment basin SB-6 adjacent to BC-25 may influence the greater variability in groundwater elevations compared to BC-28 which is not located near a sediment basin. x Concentrations of selenium, sulfate, and TDS were less in monitoring wells closer to the landfill (e.g., BC-32) than in wells farther from the landfill (e.g., BC-25). If the source of the exceedances were the landfill, it would be expected that the concentrations measured in the monitoring wells closer to the landfill would be greater than those measured in monitoring wells further from the landfill. x The following maintenance and housekeeping activities were implemented in October 2015 to minimize fugitive dust at the gypsum stack-out area: o Asphalt paving and sealing of the area under the radial stacker o Installation of curbing along the non-ditched portion of the pad road perimeter o Cleaning and flushing of the subsurface drainage system o Extension of the vertical spray guards at the wheel wash o Sealing of perimeter road and ditchline cracks o Concrete paving of some perimeter exposed areas o Affixing the pad liner to the interior of the perimeter road o Addition of a dedicated water truck for road cleaning and dust control o No loading in the scale area Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Section 4 –Conclusions and Recommendations 22 If fugitive dust was the cause of the historical increases in concentrations reported at SW-1, the concentrations of sulfate and TDS should continue to decrease or remain stable at the SW-1 sample location. 4.2 Recommendations Aerial deposition from historical operations at the landfill and gypsum stack-out area may have contributed to the concentrations of sulfate and/or selenium reported in near-surface soil samples in this portion of the site. The selenium and sulfate reported in the soil may be contributing to concentrations of these constituents in groundwater. Maintenance and housekeeping activities (as previously mentioned) at the gypsum stack-out area were updated in October 2015. These activities included engineering controls, maintenance and dust control measures. If fugitive dust and aerial deposition of selenium and sulfate represent a source for groundwater and surface water exceedances, implementation and maintenance of the dust control system should result in a reduction of constituent concentrations in groundwater and surface water over time. A reduction in sulfate concentration in sample SW-1 was observed from the May 2016 to March 2017 sampling event. It is recommended that monitoring of groundwater and surface water continue for four semi-annual sampling events to evaluate if constituent concentrations continue to decline. If constituent concentrations increase at a given sample location in three consecutive events, additional assessment may be warranted. Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Figures #UJ$CUKP ^,>E&/>> WZD/dEK͘ ϴϱϬϯ &'>E&/>>WZD/dEK͘ ϴϱϬϱ %TCKI4QCF Z/'ZK>E&/>>WZD/dEK͘ ϴϱϬϰ 'CUV$GNGYU %TGGM#TO $GNGYU.CMG 9GUV$GNGYU %TGGM#TO $GNGYU.CMG $GNGYU%TGGM5VGCO5VCVKQP .CPFHKNN$QWPFCT[ 5%#.' (''6   0QVGU 5QWTEG75)56QRQITCRJKE/CRÄ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o v - 0 7 N o v - 0 8 N o v - 0 9 N o v - 1 0 N o v - 1 1 N o v - 1 2 N o v - 1 3 N o v - 1 4 N o v - 1 5 N o v - 1 6 ug / L Fi g u r e 4 - B e l e w s C r e e k F G D R e s i d u e L a n d f i l l BC - 2 0 , B C - 2 1 , B C - 2 5 , B C - 2 6 , B C - 3 2 Su l f a t e C o n c e n t r a t i o n s NC A C 1 5 A - 2 L BC - 2 0 BC - 2 1 BC - 2 5 BC - 2 6 BC - 3 2 2L S t a n d a r d f o r S u l f a t e = 2 5 0 , 0 0 0 μ g/ L μ g/ L 74 0 0 0 11 0 0 0 0 14 2 0 0 0 12 4 0 0 0 14 4 0 0 0 24 7 0 0 0 39 1 0 0 0 62 3 0 0 0 71 9 0 0 0 65 9 0 0 0 66 8 0 0 0 14 8 0 0 0 0 14 1 0 0 0 0 10 3 0 0 0 0 14 0 0 0 0 0 12 8 0 0 0 0 17 4 0 0 0 0 18 1 0 0 0 0 15 6 0 0 0 0 13 2 0 0 0 0 13 5 0 0 0 0 14 3 2 0 22 7 0 0 20 6 0 0 20 0 0 0 26 2 0 0 10 9 0 0 0 21 4 0 0 0 35 3 0 0 0 42 8 0 0 0 36 9 0 0 0 39 4 0 0 0 93 0 0 0 0 85 8 0 0 0 65 7 0 0 0 91 7 0 0 0 85 3 0 0 0 11 9 0 0 0 0 11 5 0 0 0 0 99 9 0 0 0 96 7 0 0 0 88 7 0 0 0 0 20 0 0 0 0 40 0 0 0 0 60 0 0 0 0 80 0 0 0 0 10 0 0 0 0 0 12 0 0 0 0 0 14 0 0 0 0 0 16 0 0 0 0 0 18 0 0 0 0 0 20 0 0 0 0 0 No v - 0 7 N o v - 0 8 N o v - 0 9 N o v - 1 0 N o v - 1 1 N o v - 1 2 N o v - 1 3 N o v - 1 4 N o v - 1 5 N o v - 1 6 ug / L Fi g u r e 5 - B e l e w s C r e e k F G D R e s i d u e L a n d f i l l BC - 2 5 Su l f a t e a n d T D S C o n c e n t r a t i o n s TD S , t o t a l ( μ g/ L ) NC A C 1 5 A - 2 L ( T D S ) SO 4 , t o t a l ( μ g/ L ) NC A C 1 5 A - 2 L ( S O 4 ) 2L S t a n d a r d f o r T D S = 5 0 0 , 0 0 0 μ g/ L 2L S t a n d a r d f o r S u l f a t e = 2 5 0 , 0 0 0 μ g/ L μ g/ L 0 20 0 0 0 0 40 0 0 0 0 60 0 0 0 0 80 0 0 0 0 10 0 0 0 0 0 12 0 0 0 0 0 14 0 0 0 0 0 16 0 0 0 0 0 18 0 0 0 0 0 20 0 0 0 0 0 No v - 0 7 N o v - 0 8 N o v - 0 9 N o v - 1 0 N o v - 1 1 N o v - 1 2 N o v - 1 3 N o v - 1 4 N o v - 1 5 N o v - 1 6 ug / L Fi g u r e 6 - B e l e w s C r e e k F G D R e s i d u e L a n d f i l l BC - 2 0 , B C - 2 1 , B C - 2 5 , B C - 2 6 , B C - 3 2 TD S C o n c e n t r a t i o n s NC A C 1 5 A - 2 L BC - 2 0 BC - 2 1 BC - 2 5 BC - 2 6 BC - 3 2 2L S t a n d a r d f o r T D S = 5 0 0 , 0 0 0 μ g/ L μ g/ L 0510152025 No v - 0 7 N o v - 0 8 N o v - 0 9 N o v - 1 0 N o v - 1 1 N o v - 1 2 N o v - 1 3 N o v - 1 4 N o v - 1 5 N o v - 1 6 ug / L Fi g u r e 7 - B e l e w s C r e e k F G D R e s i d u e L a n d f i l l BC - 2 0 , B C - 2 1 , B C - 2 5 , B C - 2 6 , B C - 3 2 Se l e n i u m C o n c e n t r a t i o n s NC A C 1 5 A - 2 L BC - 2 0 BC - 2 1 BC - 2 5 BC - 2 6 BC - 3 2 2L S t a n d a r d f o r S e l e n i u m = 2 0 μ g/ L μ g/ L Re s u l t s n o t n o t d e t e c t e d a t c o n c e n t r a t i o n s wh i c h a t t a i n o r e x c e e d t h e l a b o r a t o r y me t h o d r e p o r t i n g l i m i t h a v e b e e n s e t e q u a l to z e r o f o r v i s u a l i z a t i o n p u r p o s e s . 0 50 , 0 0 0 10 0 , 0 0 0 15 0 , 0 0 0 20 0 , 0 0 0 25 0 , 0 0 0 30 0 , 0 0 0 35 0 , 0 0 0 40 0 , 0 0 0 45 0 , 0 0 0 50 0 , 0 0 0 No v - 1 0 A p r - 1 2 A u g - 1 3 J a n - 1 5 M a y - 1 6 μ g/ L Fi g u r e 8 - B e l e w s C r e e k F G D R e s i d u e L a n d f i l l SW - 1 Su l f a t e a n d T D S C o n c e n t r a t i o n s SO 4 , t o t ( μ g/ L ) NC A C 1 5 A - 2 L ( S O 4 ) TD S ( μ g/ L ) NC A C 1 5 A - 2 L ( T D S ) 2L S t a n d a r d f o r S u l f a t e = 2 5 0 , 0 0 0 μ g/ L 2L S t a n d a r d f o r T D S = 5 0 0 , 0 0 0 μ g/ L 10 0 0 12 0 0 14 0 0 16 0 0 18 0 0 20 0 0 22 0 0 72 8 . 0 72 8 . 5 72 9 . 0 72 9 . 5 73 0 . 0 73 0 . 5 73 1 . 0 11 / 2 9 1 2 / 9 1 2 / 1 9 1 2 / 2 9 1 / 8 1 / 1 8 1 / 2 8 C o n d u c t i v i t y ( μ S ) G r o u n d w a t e r E l e v a t i o n ( f t ) Fi g u r e 1 0 - B e l e w s C r e e k F G D R e s i d u e L a n d f i l l BC - 2 5 G r o u n d w a t e r E l e v a t i o n s a n d C o n d u c t i v i t y Gr o u n d w a t e r E l e v a t i o n Co n d u c t i v i t y 010203040506070809010 0 76 7 . 0 76 7 . 5 76 8 . 0 76 8 . 5 76 9 . 0 76 9 . 5 77 0 . 0 11 / 2 6 1 2 / 6 1 2 / 1 6 1 2 / 2 6 1 / 5 1 / 1 5 1 / 2 5 2 / 4 2 / 1 4 C o n d u c t i v i t y ( μ S ) G r o u n d w a t e r E l e v a t i o n ( f t ) Fi g u r e 1 1 - B e l e w s C r e e k F G D R e s i d u e L a n d f i l l BC - 2 8 G r o u n d w a t e r E l e v a t i o n s a n d C o n d u c t i v i t y Gr o u n d w a t e r E l e v a t i o n Co n d u c t i v i t y 00. 0 5 0. 1 0. 1 5 0. 2 0. 2 5 0. 3 0. 3 5 0. 4 0. 4 5 0. 5 72 8 . 0 72 8 . 5 72 9 . 0 72 9 . 5 73 0 . 0 73 0 . 5 73 1 . 0 11 / 2 9 1 2 / 9 1 2 / 1 9 1 2 / 2 9 1 / 8 1 / 1 8 1 / 2 8 P r e c i p i t a t i o n ( i n ) G r o u n d w a t e r E l e v a t i o n ( f t ) Fi g u r e 1 2 - B e l e w s C r e e k F G D R e s i d u e L a n d f i l l BC - 2 5 G r o u n d w a t e r E l e v a t i o n s a n d P r e c i p i t a t i o n Gr o u n d w a t e r E l e v a t i o n Pr e c i p i t a t i o n 00. 0 5 0. 1 0. 1 5 0. 2 0. 2 5 0. 3 0. 3 5 0. 4 0. 4 5 0. 5 76 7 . 0 76 7 . 5 76 8 . 0 76 8 . 5 76 9 . 0 76 9 . 5 77 0 . 0 11 / 2 6 1 2 / 6 1 2 / 1 6 1 2 / 2 6 1 / 5 1 / 1 5 1 / 2 5 2 / 4 2 / 1 4 P r e c i p i t a t i o n ( i n ) G r o u n d w a t e r E l e v a t i o n ( f t ) Fi g u r e 1 3 - B e l e w s C r e e k F G D R e s i d u e L a n d f i l l BC - 2 8 G r o u n d w a t e r E l e v a t i o n s a n d P r e c i p i t a t i o n Gr o u n d w a t e r E l e v a t i o n Pr e c i p i t a t i o n 72 5 73 0 73 5 74 0 74 5 75 0 No v - 0 7 N o v - 0 8 N o v - 0 9 N o v - 1 0 N o v - 1 1 N o v - 1 2 N o v - 1 3 N o v - 1 4 N o v - 1 5 N o v - 1 6 Fe e t Fi g u r e 1 4 - B e l e w s C r e e k F G D R e s i d u e L a n d f i l l BC - 2 0 , B C - 2 1 , B C - 2 5 , B C - 2 6 , B C - 2 7 , B C - 2 9 , a n d B C - 7 Gr o u n d w a t e r E l e v a t i o n s BC - 2 0 BC - 2 1 BC - 2 5 BC - 2 6 BC - 2 7 BC - 2 9 BC - 7 72 8 73 0 73 2 73 4 73 6 73 8 74 0 74 2 74 4 74 6 74 8 0 10 0 0 0 0 20 0 0 0 0 30 0 0 0 0 40 0 0 0 0 50 0 0 0 0 60 0 0 0 0 No v - 0 7 N o v - 0 8 N o v - 0 9 N o v - 1 0 N o v - 1 1 N o v - 1 2 N o v - 1 3 N o v - 1 4 N o v - 1 5 N o v - 1 6 Fe e t μ g/ L Fi g u r e 1 5 - B e l e w s C r e e k F G D R e s i d u e L a n d f i l l BC - 2 0 Su l f a t e C o n c e n t r a t i o n s a n d G r o u n d w a t e r E l e v a t i o n s NC A C 1 5 A - 2 L SO 4 , t o t a l ( μ g/ L ) Gr o u n d w a t e r E l e v a t i o n ( f e e t ) 2L S t a n d a r d f o r S u l f a t e = 2 5 0 , 0 0 0 μ g/ L 72 8 73 3 73 8 74 3 74 8 75 3 0 10 0 0 0 0 20 0 0 0 0 30 0 0 0 0 40 0 0 0 0 50 0 0 0 0 60 0 0 0 0 70 0 0 0 0 80 0 0 0 0 No v - 0 7 N o v - 0 8 N o v - 0 9 N o v - 1 0 N o v - 1 1 N o v - 1 2 N o v - 1 3 N o v - 1 4 N o v - 1 5 N o v - 1 6 Fe e t ug / L Fi g u r e 1 6 - B e l e w s C r e e k F G D R e s i d u e L a n d f i l l BC - 2 1 Su l f a t e C o n c e n t r a t i o n s a n d G r o u n d w a t e r E l e v a t i o n s NC A C 1 5 A - 2 L SO 4 , t o t a l ( μ g/ L ) Gr o u n d w a t e r E l e v a t i o n ( f e e t ) 2L S t a n d a r d f o r S u l f a t e = 2 5 0 , 0 0 0 μ g/ L μ g/ L 72 8 73 0 73 2 73 4 73 6 73 8 74 0 74 2 74 4 74 6 74 8 0 20 0 0 0 0 40 0 0 0 0 60 0 0 0 0 80 0 0 0 0 10 0 0 0 0 0 12 0 0 0 0 0 14 0 0 0 0 0 No v - 0 7 N o v - 0 8 N o v - 0 9 N o v - 1 0 N o v - 1 1 N o v - 1 2 N o v - 1 3 N o v - 1 4 N o v - 1 5 N o v - 1 6 Fe e t ug / L Fi g u r e 1 7 - B e l e w s C r e e k F G D R e s i d u e L a n d f i l l BC - 2 5 Su l f a t e C o n c e n t r a t i o n s a n d G r o u n d w a t e r E l e v a t i o n s NC A C 1 5 A - 2 L SO 4 , t o t a l ( μ g/ L ) Gr o u n d w a t e r E l e v a t i o n ( f e e t ) 2L S t a n d a r d f o r S u l f a t e = 2 5 0 , 0 0 0 μ g/ L μ g/ Duke Energy Carolinas, LLC |Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 Tables T T a b l e 1 S e l e c t e d S u l f a t e A n a l y t i c a l R e s u l t s f o r M o n i t o r i n g W e l l s B C -2 0 , B C -2 1 , B C -2 5 , B C -2 6 , a n d B C -3 2 D u k e E n e r g y C a r o l i n a s L L C /B e l e w s C r e e k S t e a m S t a t i o n F G D R e s i d u e L a n d f i l l , P e r m i t N o . 8 5 0 5 Pa g e 1 o f 1 BC - 2 0 34 , 0 8 0 10 4 , 0 0 0 7 1 , 2 0 0 4 7 5 , 0 0 0 2 7 1 , 0 0 0 1 6 8 , 0 0 0 5 5 4 , 0 0 0 2 2 6 , 0 0 0 5 0 6 , 0 0 0 4 9 2 , 0 0 0 5 4 0 , 0 0 0 5 3 7 , 0 0 0 5 7 1 , 0 0 0 μ g/ L BC - 2 1 85 , 4 0 0 18 5 , 0 0 0 9 1 , 5 0 0 4 8 7 , 0 0 0 4 9 6 , 0 0 0 1 7 3 , 0 0 0 5 6 9 , 0 0 0 3 5 5 , 0 0 0 7 0 1 , 0 0 0 4 5 3 , 0 0 0 4 9 8 , 0 0 0 3 6 4 , 0 0 0 4 2 6 , 0 0 0 μ g/ L BC - 2 5 35 3 , 0 0 0 42 8 , 0 0 0 3 9 4 , 0 0 0 9 3 0 , 0 0 0 8 5 8 , 0 0 0 6 5 7 , 0 0 0 9 1 7 , 0 0 0 8 5 3 , 0 0 0 1 , 1 9 0 , 0 0 0 1 , 1 5 0 , 0 0 0 9 9 9 , 0 0 0 9 6 7 , 0 0 0 8 8 7 , 0 0 0 μ g/ L BC - 2 6 19 , 7 6 0 20 , 2 0 0 1 6 , 5 0 0 1 7 , 3 0 0 N S 1 5 , 9 0 0 1 7 , 6 0 0 1 4 , 9 0 0 1 6 , 1 0 0 1 2 , 8 0 0 1 4 , 5 0 0 2 6 , 0 0 0 N S μ g/ L BC - 3 2 NS NS N S N S 4 9 0 , 0 0 0 5 1 7 , 0 0 0 7 0 7 , 0 0 0 7 1 7 , 0 0 0 7 5 3 , 0 0 0 8 5 4 , 0 0 0 9 4 9 , 0 0 0 9 5 4 , 0 0 0 9 1 6 , 0 0 0 μ g/ L No t e s : 1 . μ g/ L i n d i c a t e s m i c r o g r a m s p e r l i t e r . 2 . 1 5 A N C A C 2 L S t a n d a r d r e f e r s t o C l a s s G A S t a n d a r d s a s f o u n d i n 1 5 A N C A C 0 2 L . 0 2 0 2 G r o u n d w a t e r Q u a l i t y S t a n d a r d s , l a s t a m e n d e d o n A p r i l 1 , 2 0 1 3 . 3 . S h a d e d r e s u l t s i n d i c a t e v a l u e s t h a t a t t a i n o r e x c e e d t h e 1 5 A N C A C 2 L S t a n d a r d . 4 . N S i n d i c a t e s n o t s a m p l e d . 5 . C o n c e n t r a t i o n s b a s e d o n d a t a i n D u k e E n e r g y C a r o l i n a s , L L C a n a l y t i c a l r e s u l t s d a t a b a s e . We l l I D No v e m b e r 7 , 20 1 1 An a l y t i c a l Re s u l t s Ma y 8 , 20 1 2 An a l y t i c a l Re s u l t s Un i t s Au g u s t 1 9 , 20 1 3 An a l y t i c a l Re s u l t s Ma y 7 , 20 1 4 An a l y t i c a l Re s u l t s No v e m b e r 3 , 20 1 6 An a l y t i c a l Re s u l t s Ma y 4 , 20 1 6 An a l y t i c a l Re s u l t s No v e m b e r 4 , 20 1 5 An a l y t i c a l Re s u l t s Ma y 6 , 20 1 5 An a l y t i c a l Re s u l t s No v e m b e r 1 2 , 20 1 4 An a l y t i c a l Re s u l t s Ma r c h 8 , 20 1 7 An a l y t i c a l Re s u l t s 25 0 , 0 0 0 No v e m b e r 2 6 , 20 1 2 An a l y t i c a l Re s u l t s Ma y 1 4 , 20 1 3 An a l y t i c a l Re s u l t s No v e m b e r 2 5 - 2 6 , 20 1 3 An a l y t i c a l R e s u l t s 15 A N C A C 2 L St a n d a r d TTable 2 Groundwater Analytical Results Background Monitoring Wells Duke Energy Carolinas LLC/Belews Creek Steam Station FGD Residue Landfill, Permit No. 8505 Page 1 of 1 Analyte Unit CAS Number NCDEQ 2L Sample ID BC-23A BC-28 BC-23A BC-28 BC-23A BC-28 Maximum 630 466 138,000 81000 Minimum 184 <100 44,000 36000 Collection Date 11/6/2007 630 100 U 61,000 72,000 2 U 2 U 5/19/2008 5000 U 5000 U 74,000 68,000 10 U 10 U 11/5/2008 5000 U 5000 U 52,000 36,000 10 U 10 U 5/6/2009 5000 U 5000 U 138,000 70,000 10 U 10 U 11/17/2009 5000 U 5000 U 72,000 62,000 10 U 10 U 5/17/2010 5000 U 5000 U 56,000 64,000 10 U 10 U 11/29/2010 5000 U 5000 U 44,000 44,000 10 U 10 U 5/16/2011 302 311 67,000 51,000 1 U 1 U 11/7/2011 374.3 347.2 94,000 81,000 1 U 1 U 5/8/2012 405 377 52,000 61,000 1 U 1 U 11/26/2012 225 422 53,000 61,000 1 U 1 U 5/13/2013 329 442 51,000 65,000 1 U 1 U 11/26/2013 237 466 58,000 70,000 1 U 1 U 5/7/2014 196 363 65,000 70,000 1 U 1 U 11/12/2014 203 298 49,000 68,000 1 U 1 U 5/6/2015 189 299 57,000 63,000 1 U 1 U 11/4/2015 227 338 64,000 73,000 1 U 1 U 5/4/2016 273 398 51,000 70,000 1 U 1 U 11/3/2016 184 271 54,000 55,000 1 U 1 U Notes: 1. 2. 3. 4. 5. 10 U 1 U μg/L indicates micrograms per liter 15A NCAC 2L Standard refers to Class GA Standards as found in 15A NCAC 02L. 0202 Selenium μg/L 7782-49-2 20 TDS μg/L -- 500,000 Sulfate μg/L 14808-79-8 250,000 Groundwater Quality Standards, last amended on April 1, 2013 Concentrations based on data in Duke Energy Carolinas, LLC analytical results database U indicates the result was not detected at a concentration which attains or exceeds the laboratory method reporting limit (MRL). TDS indicates total dissolved solids. T T a b l e 3 S e l e c t e d T D S A n a l y t i c a l R e s u l t s f o r M o n i t o r i n g W e l l s B C -2 0 , B C -2 1 , B C -2 5 , B C -2 6 , a n d B C -3 2 D u k e E n e r g y C a r o l i n a s L L C /B e l e w s C r e e k S t e a m S t a t i o n F G D R e s i d u e L a n d f i l l , P e r m i t N o . 8 5 0 5 Pa g e 1 o f 1 BC - 2 0 16 8 , 0 0 0 24 6 , 0 0 0 2 1 4 , 0 0 0 7 7 2 , 0 0 0 4 8 5 , 0 0 0 3 2 3 , 0 0 0 8 3 8 , 0 0 0 3 8 6 , 0 0 0 7 3 0 , 0 0 0 7 8 0 , 0 0 0 8 2 5 , 0 0 0 8 1 2 , 0 0 0 8 5 6 , 0 0 0 μ g/ L BC - 2 1 26 1 , 0 0 0 39 1 , 0 0 0 2 2 4 , 0 0 0 8 0 0 , 0 0 0 8 2 9 , 0 0 0 3 3 0 , 0 0 0 8 5 0 , 0 0 0 5 7 9 , 0 0 0 7 0 1 , 0 0 0 7 1 9 , 0 0 0 7 7 5 , 0 0 0 5 4 4 , 0 0 0 6 9 6 , 0 0 0 μ g/ L BC - 2 5 62 3 , 0 0 0 71 9 , 0 0 0 6 6 8 , 0 0 0 1 , 4 8 0 , 0 0 0 1 , 4 1 0 , 0 0 0 1 , 0 3 0 , 0 0 0 1 , 4 0 0 , 0 0 0 1 , 2 8 0 , 0 0 0 1 , 7 4 0 , 0 0 0 1 , 8 1 0 , 0 0 0 1 , 5 6 0 , 0 0 0 1 , 3 2 0 , 0 0 0 1 , 3 5 0 , 0 0 0 μ g/ L BC - 2 6 91 , 0 0 0 80 , 0 0 0 7 8 , 0 0 0 9 5 , 0 0 0 N S 9 6 , 0 0 0 1 0 2 , 0 0 0 9 0 , 0 0 0 9 7 , 0 0 0 1 1 4 , 0 0 0 1 0 4 , 0 0 0 1 2 2 , 0 0 0 N S μ g/ L BC - 3 2 NS NS N S N S 7 8 9 , 0 0 0 7 9 4 , 0 0 0 1 , 1 1 0 , 0 0 0 1 , 1 0 0 , 0 0 0 1 , 1 2 0 , 0 0 0 1 , 2 7 0 , 0 0 0 1 , 3 8 0 , 0 0 0 1 , 3 3 0 , 0 0 0 1 , 2 5 0 , 0 0 0 μ g/ L No t e s : 1 . μ g/ L i n d i c a t e s m i c r o g r a m s p e r l i t e r . 2 . 1 5 A N C A C 2 L S t a n d a r d r e f e r s t o C l a s s G A S t a n d a r d s a s f o u n d i n 1 5 A N C A C 0 2 L . 02 0 2 G r o un d w a t e r Q u a l i t y S t a n d a r d s , l a s t a m e n d e d o n A p r i l 1 , 20 1 3 . 3 . S h a d e d r e s u l t s i n d i c a t e v a l u e s t h a t a t t a i n o r e x c e e d t h e 1 5 A N C A C 2 L S t a n d a r d . 4 . N S i n d i c a t e s n o t s a m p l e d . 5 . C o n c e n t r a t i o n s b a s e d o n d a t a i n D u k e E n e r g y C a r o l i n a s , L L C a n a l y t i c a l r e s u l t s d a t a b a s e . Au g u s t 1 9 , 20 1 3 An a l y t i c a l Re s u l t s No v e m b e r 3 , 20 1 6 An a l y t i c a l Re s u l t s Ma y 4 , 20 1 6 An a l y t i c a l Re s u l t s No v e m b e r 4 , 20 1 5 An a l y t i c a l Re s u l t s Ma y 6 , 20 1 5 An a l y t i c a l Re s u l t s No v e m b e r 1 2 , 20 1 4 An a l y t i c a l Re s u l t s Ma y 7 , 20 1 4 An a l y t i c a l Re s u l t s We l l I D No v e m b e r 7 , 20 1 1 An a l y t i c a l Re s u l t s Ma y 8 , 20 1 2 An a l y t i c a l Re s u l t s No v e m b e r 2 6 , 20 1 2 An a l y t i c a l Re s u l t s Ma y 1 4 , 20 1 3 An a l y t i c a l Re s u l t s Ma r c h 8 , 20 1 7 An a l y t i c a l Re s u l t s No v e m b e r 2 5 - 2 6 , 20 1 3 An a l y t i c a l R e s u l t s Un i t s 15 A N C A C 2L St a n d a r d 50 0 , 0 0 0 T T a b l e 4 S e l e c t e d S e l e n i u m A n a l y t i c a l R e s u l t s f o r M o n i t o r i n g W e l l s B C -2 0 , B C -2 1 , B C -2 5 , B C -2 6 , a n d B C -3 2 D u k e E n e r g y C a r o l i n a s L L C /B e l e w s C r e e k S t e a m S t a t i o n F G D R e s i d u e L a n d f i l l , P e r m i t N o . 8 5 0 5 Pa g e 1 o f 1 BC - 2 0 1 U 1 U 1 . 1 8 2 . 1 9 1 . 9 6 1 . 7 8 2 . 8 2 . 4 2 . 5 1 2 . 2 4 3 . 9 6 3 . 8 5 4 . 5 μ g/ L BC - 2 1 1 U 3. 3 2 . 5 5 1 . 3 6 2 3 . 7 2 . 6 9 1 . 6 1 1 . 8 1 3 . 4 2 1 . 7 7 0 . 8 6 4 J 0 . 9 6 8 J 1 9 . 1 μ g/ L BC - 2 5 1.9 2 3. 4 5 3 . 7 0 1 9 . 2 1 4 . 1 7 . 9 8 1 9 13 . 1 2 0 . 3 2 1 . 9 1 2 . 4 9 . 7 1 0 . 0 μ g/ L BC - 2 6 1 U 1 U 1 U 1 U N S 1 U 0 . 1 1 7 J 0 . 0 9 2 U 0 . 0 9 2 U 0 . 1 1 7 J 0 . 0 9 2 U 0 . 1 3 7 J N S μ g/ L BC - 3 2 NS NS N S N S 6 . 0 3 5 . 7 2 5 . 6 7 3 . 9 6 6 . 5 5 . 9 8 5 . 7 8 4 . 2 1 4 . 4 μ g/ L No t e s : 1 . μ g/ L i n d i c a t e s m i c r o g r a m s p e r l i t e r . 2 . 1 5 A N C A C 2 L S t a n d a r d r e f e r s t o C l a s s G A S t a n d a r d s a s f o u n d i n 1 5 A N C A C 0 2 L . 02 0 2 G r o un d w a t e r Q u a l i t y S t a n d a r d s , l a s t a m e n d e d o n A p r i l 1 , 20 1 3 . 3 . S h a d e d r e s u l t s i n d i c a t e v a l u e s t h a t a t t a i n o r e x c e e d t h e 1 5 A N C A C 2 L S t a n d a r d . 4 . N S i n d i c a t e s n o t s a m p l e d . 5 . C o n c e n t r a t i o n s b a s e d o n d a t a i n D u k e E n e r g y C a r o l i n a s , L L C a n a l y t i c a l r e s u l t s d a t a b a s e . 6 . U i n d i c a t e s t h e r e s u l t w a s n o t d e t e c t e d a t a c o n c e n t r a t i o n wh i c h a t t a i n s o r e x c e e d s t h e l a b o ra t o r y m e t h o d r e p o r t i n g l i m i t ( MR L ) . 7 . J i n d i c a t e s a n l a b o r a t o r y e s t i m a t e d c o n c e n t r a t i o n w h i c h e q u a l o r a r e g r e a t e r t h a n t h e m e t h o d d e t e c t i o n l i m i t b u t a r e l e s s t ha n t h e l a b o r a t o r y ' s M R L . No v e m b e r 2 5 - 2 6 , 20 1 3 An a l y t i c a l R e s u l t s Un i t s 15 A NC A C 2 L St a n d a r d 20 Ma r c h 8 , 20 1 7 An a l y t i c a l Re s u l t s We l l I D No v e m b e r 7 , 20 1 1 An a l y t i c a l Re s u l t s Ma y 8 , 20 1 2 An a l y t i c a l Re s u l t s No v e m b e r 2 6 , 20 1 2 An a l y t i c a l Re s u l t s Ma y 1 4 , 20 1 3 An a l y t i c a l Re s u l t s Au g u s t 1 9 , 20 1 3 An a l y t i c a l Re s u l t s No v e m b e r 3 , 20 1 6 An a l y t i c a l Re s u l t s Ma y 4 , 20 1 6 An a l y t i c a l Re s u l t s No v e m b e r 4 , 20 1 5 An a l y t i c a l Re s u l t s Ma y 6 , 20 1 5 An a l y t i c a l Re s u l t s No v e m b e r 1 2 , 20 1 4 A n a l y t i c a l Re s u l t s Ma y 7 , 20 1 4 An a l y t i c a l Re s u l t s Table 5: Summary of Soil Analytical Results Duke Energy Carolinas LLC/Belews Creek Steam Station FGD Residue Landfill, Permit No. 8505 Page 1 of 1 Boron Chloride Fluoride Iron Manganese Selenium Sulfate mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg 7440-42-8 16887-00-6 16984-48-8 7439-89-6 7439-96-5 7782-49-2 14808-79-8 46,000 NS 9,400 100,000 5,200 1,160 NS 45 NS NS 150 65 2.1 NS Sample ID Collection Date FGDSB-1 (0-0.5)11/9/2016 1.04 U 3.10 5.45 23,600 313 2.20 714 FGDSB-1 (1)11/9/2016 1.90 1.98 1.74 26,600 411 1.17 1,310 FGDSB-1 (2)11/9/2016 1.09 U 1.60 0.450 11,500 221 1.74 150 FGDSB-1 (3)11/9/2016 1.20 U 5.10 0.419 U 8,250 281 1.94 392 FGDSB-1 (5)11/9/2016 1.19 U 5.86 0.405 U 5,500 146 0.479 334 FGDSB-2 (0-0.5)11/9/2016 1.03 U 2.38 4.59 20,900 333 3.58 4,510 FGDSB-2 (1)11/9/2016 1.07 U 3.20 2.20 34,400 161 3.23 2,970 FGDSB-2 (2)11/9/2016 1.13 U 7.51 0.889 70,500 590 7.23 940 FGDSB-3 (0-0.5)11/9/2016 1.09 U 3.82 3.69 22,300 393 1.87 6,260 FGDSB-3 (1)11/9/2016 1.04 U 2.56 0.627 20,300 632 1.95 2,440 FGDSB-4 (0-0.5)11/9/2016 1.10 U 4.49 8.52 27,300 173 5.90 14,400 FGDSB-5 (0-0.5)11/9/2016 1.34 U 9.04 7.75 40,700 376 5.52 18,100 FGDSB-5 (1)11/9/2016 1.11 U 4.65 1.15 15,300 576 2.37 1,990 FGDSB-5 (2)11/9/2016 1.03 U 5.13 0.365 U 20,700 287 1.86 800 FGDSB-5 (3)11/9/2016 1.05 U 2.08 0.516 11,900 273 2.89 756 FGDSB-6 (0-0.5)11/9/2016 1.14 U 3.56 0.385 U 22,400 390 2.62 338 FGDSB-6 (1)11/9/2016 1.11 U 1.71 0.368 U 12,500 329 1.86 107 FGDSB-7 (0-0.5)11/10/2016 1.49 2.23 3.10 24,500 350 2.05 379 FGDSB-7 (1)11/10/2016 1.12 1.49 3.07 15,700 350 2.54 44.5 FGDSB-8 (0-0.5)11/10/2016 1.17 U 2.55 7.28 25,400 410 3.58 8,610 FGDSB-8 (1)11/10/2016 1.11 U 1.68 0.630 29,500 543 1.84 100 FGDSB-8 (2)11/10/2016 1.12 U 2.63 0.385 U 26,000 907 2.30 174 FGDSB-8 (3)11/10/2016 1.10 U 1.90 0.377 U 22,300 239 2.00 114 FGDSB-9 (0-0.5)11/10/2016 1.20 U 1.87 1.47 21,200 337 2.96 93.6 FGDSB-9 (1)11/10/2016 1.13 U 1.87 0.550 9,690 62.9 0.977 22.7 FGDSB-9 (2)11/10/2016 1.20 U 2.77 0.403 U 9,520 51.3 2.53 37.6 FGDSB-9 (3)11/10/2016 1.19 U 1.92 0.394 U 11,300 110 2.98 44.5 FGDSB-9 (5)11/10/2016 1.19 U 2.24 0.399 U 11,200 56.2 1.58 34.8 FGDSB-10 (0-0.5)11/10/2016 1.08 U 2.43 1.76 21,100 343 1.31 45.6 FGDSB-11 (0-0.5)11/10/2016 1.08 U 9.54 0.460 20,400 201 2.08 3,460 FGDSB-11 (1)11/10/2016 1.08 U 6.51 0.359 U 28,900 366 2.28 858 FGDSB-11 (2)11/10/2016 1.14 U 5.52 0.380 U 22,100 482 2.67 100 FGDSB-11 (3)11/10/2016 1.23 U 12.2 0.414 U 37,600 177 1.03 18.0 FGDSB-11 (4)11/10/2016 1.16 U 3.86 0.389 U 38,800 592 1.48 92.6 FGDSB-12 (0-0.5)11/10/2016 1.06 U 32.7 0.485 21,100 172 2.78 3,410 FGDSB-13 (0-0.5)11/10/2016 1.13 U 5.83 2.44 26,100 534 1.71 54.0 FGDSB-13 (1)11/10/2016 1.11 U 4.84 1.16 27,200 505 1.62 119 FGDSB-13 (2)11/10/2016 1.06 U 2.26 4.15 26,400 458 1.43 259 FGDSB-14 (0-0.5)11/9/2016 1.26 U 2.17 6.23 18,600 558 9.35 17,400 FGDSB-15 (0-0.5)11/9/2016 1.05 U 1.67 3.79 22,300 319 6.35 13,100 FGDSB-15 (1)11/9/2016 1.14 U 2.66 10.1 15,200 208 9.65 15,700 FGDSB-15 (2)11/9/2016 2.16 1.60 8.94 23,000 398 5.00 13,200 FGDSB-16 (0-0.5)11/10/2016 1.57 2.37 5.32 39,500 477 7.12 7,010 FGDSB-16 (1)11/10/2016 1.08 U 1.62 1.89 7,610 96.6 2.37 133 FGDSB-16 (2)11/10/2016 1.00 U 1.38 3.03 7,180 125 0.859 53.6 FGDSB-16 (3)11/10/2016 1.08 U 0.774 U 2.97 10,700 136 2.85 105 FGDSB-16 (5)11/10/2016 1.08 U 2.40 0.367 U 8,350 126 1.02 102 FGDSB-17 (0-0.5)11/9/2016 1.26 U 4.32 5.67 30,700 435 3.43 6,910 FGDSB-17 (1)11/9/2016 1.01 U 2.14 0.994 18,700 165 1.34 231 FGDSB-18 (0-0.5)11/10/2016 1.21 U 3.10 1.59 27,300 388 2.20 122 FGDSB-18 (1)11/10/2016 1.04 U 1.61 0.961 8,690 123 1.37 52.2 FGDBGSB-1 (0-0.5)11/10/2016 0.984 U 3.15 0.699 21,600 335 0.717 42.6 FGDBGSB-1 (1)11/10/2016 1.08 U 2.91 0.360 U 22,700 512 1.00 33.3 FGDBGSB-1 (2)11/10/2016 1.25 U 12.5 0.426 U 51,800 102 0.966 8.76 FGDBGSB-1 (3)11/10/2016 1.23 U 17.3 0.427 U 38,600 89.4 0.974 1.67 U FGDBGSB-1 (5)11/10/2016 1.23 U 16.3 0.429 U 34,200 92.0 1.24 2.67 Notes: 1. 2. 3. 4. 5. mg/kg indicates milligram per kilogram NS indicates no standard U indicates the results were not detected at concentrations which equal the laboratory's method detection limit (MDL) A bolded and shaded result indicates an exceedance of the Protection of Groundwater Preliminary Soil Remediation Goal (PSRG) The number(s) in parenthesis in the sample ID represent the approximate depth below ground surface (bgs) the sample was collected Analyte Unit CAS Number Industrial Health PSRG Protection of Groundwater PSRG Duke Energy Carolinas, LLC | Additional Assessment of Groundwater Exceedances Belews Creek Steam Station FGD Landfill, Permit No. 8505 A Appendix A Well Inspection Forms and Redevelopment Logs WELL INSPECTION FORM P:\Duke Energy Progress.1026\20. BELEWS CREEK\03. FGD Landfill additional assessment\Field Work\inspection forms\BC-20.docx Page 1 Plant: BELEWS CREEK Address: 3195 PINE HALL RD BELEWS CREEK, NC 27009 County: FORSYTH State: NC Today’s Date: 11/10/2016 Field Personnel: BDW, WJW Weather: ☒ Sunny ☐ Overcast ☐ Rain Approx. Temp: 60 WELL ID: BC-20 Redevelopment Recommended? ☒ Yes (as instructed) ☐ No Inspection Photos Measured DTW: 18.21FT Measured TD: 24.49 FT Condition of Protective Casing: RUSTED, BUT GOOD Bolts in place w/ gaskets? ☐ Yes ☐ No ☒ Stick Up Condition of Concrete Pad? GOOD Condition of PVC casing/riser and cap (water tightness)? GOOD – DEDICATED PUMP CAP (NO SEAL). Pictures Taken? ☒ Yes ☐ No General Observations (vegetation, hardness of well bottom, etc): - GRASS MOWED AROUND WELL - TAGGED SOFT BOTTOM, SEDIMENT ON END OF WL TAPE - SOME BUILD UP IN BOTTOM OF WELL Other comments (bollards, locks, well tag, miscellaneous debris, sediment buildup): - BOLLARDS IN PLACE, WELL IS LOCKED, TAG OK - PORTONS OF INTERIOR OF TUBING W/ DEDICATED PUMP HAS A GREENISH/YELLOW FILM (ALMOST NEON) - SCREEN: 14.22’ - 24.22’ (4’ OF OPEN SCREEN ABOVE WATER TABLE) - SEE DEVELOPMENT LOG FOR FUTHER DETAILS WELL INSPECTION FORM P:\Duke Energy Progress.1026\20. BELEWS CREEK\.03 FGD Landfill additional assessment\Field Work\inspection forms\BC-21.docxP:\Duke Energy Progress.1026\20. BELEWS CREEK\03. FGD Landfill additional assessment\Field Work\inspection forms\BC-21.docx Page 1 Plant: BELEWS CREEK Address: 3195 PINE HALL RD BELEWS CREEK, NC 27009 County: FORSYTH State: NC Today’s Date: 11/10/2016 Field Personnel: BDW, WJW Weather: ☒ Sunny ☐ Overcast ☐ Rain Approx. Temp: 65 WELL ID: BC-21 Redevelopment Recommended? ☒ Yes (as instructed) ☐ No Inspection Photo Measured DTW: 13.36 Measured TD: 16.99 Condition of Protective Casing: RUSTED, BUT GOOD Bolts in place w/ gaskets? ☐ Yes ☐ No ☒ Stick Up Condition of Concrete Pad? GOOD Condition of PVC casing/riser and cap (water tightness)? GOOD – DEDICATED PUMP CAP (NO SEAL). PINK SPRAY PAINT IN TOP OF PVC RISER. Pictures Taken? ☒ Yes ☐ No General Observations (vegetation, hardness of well bottom, etc): - GRASS MOWED AROUND WELL - SOFT TAG IN BOTTOM OF WELL CAP - HARD TAG ON LIP OF BOTTOM SCREEN Other comments (bollards, locks, well tag, miscellaneous debris, sediment buildup): - SCREENED: 6.77’ - 16.77’; ABOUT 7’ OF OPEN SCREEN ABOVE WATER TABLE - BOLLARDS IN PLACE, WELL IS LOCKED, TAG OK - WELL VOLUME = 0.6 GALLONS (SEE DEVELOPMENT LOG FOR DETAILS) - SEDIMENT-RICH WATER BUT BEGAN TO CLEAR UP AFTER 10-15 WELL VOLUMES - SEE DEVELOPMENT LOG FOR FURTHER DETAILS WELL INSPECTION FORM P:\Duke Energy Progress.1026\20. BELEWS CREEK\.03 FGD Landfill additional assessment\Field Work\inspection forms\BC-22.docx Page 1 Plant: BELEWS CREEK Address: 3195 PINE HALL RD BELEWS CREEK, NC 27009 County: FORSYTH State: NC Today’s Date: 11/10/2016 Field Personnel: BDW, WJW Weather: ☒ Sunny ☐ Overcast ☐ Rain Approx. Temp: 65 WELL ID: BC-22 Redevelopment Recommended? ☐ Yes ☒ No Inspection Photos Measured DTW: 5.39’ Measured TD: 13.00’ Condition of Protective Casing: GOOD – 6” X 6” STEEL CASING Bolts in place w/ gaskets? ☐ Yes ☐ No ☒ Stick Up Condition of Concrete Pad? GOOD Condition of PVC casing/riser and cap (water tightness)? GOOD – DEDICATED PUMP CAP (NO SEAL). Pictures Taken? ☒ Yes ☐ No General Observations (vegetation, hardness of well bottom, etc): - GRASS MOWED AROUND WELL. - REMOVED MINOR DEBRIS FROM WELL PAD. Other comments (bollards, locks, well tag, miscellaneous debris, sediment buildup): - SCREEN: 3’ - 13’ = APPROX. 2’ OF OPEN SCREEN ABOVE WATER TABLE - NO BOLLARDS, LOCK OK, TAG OK - DEDICATED PUMP CAP LARGER THAN 2” RISER, NOT ABLE TO INSTALL NEOPRENE SEAL CAP - DID NOT PULL DEDICATED PUMP, NO TURBIDITY ISSUES INDICATED IN DATA TABLE PROVIDED BY HDR WELL INSPECTION FORM P:\Duke Energy Progress.1026\20. BELEWS CREEK\.03 FGD Landfill additional assessment\Field Work\inspection forms\BC-23A.docx Page 1 Plant: BELEWS CREEK Address: 3195 PINE HALL RD BELEWS CREEK, NC 27009 County: FORSYTH State: NC Today’s Date: 11/11/2016 Field Personnel: BDW, WJW Weather: ☒ Sunny ☐ Overcast ☐ Rain Approx. Temp: 55 WELL ID: BC-23A Redevelopment Recommended? ☒ Yes (as instructed) ☐ No Inspection Photos Measured DTW: 78.58 FT Measured TD: 101.42 FT Condition of Protective Casing: RUSTED, BUT GOOD Bolts in place w/ gaskets? ☐ Yes ☐ No ☒ Stick Up Condition of Concrete Pad? GOOD – ROUND (NOT SQUARE) Condition of PVC casing/riser and cap (water tightness)? GOOD – DEDICATED PUMP CAP (NO SEAL). Pictures Taken? ☒ Yes ☐ No General Observations (vegetation, hardness of well bottom, etc): - GRASS AROUND WELL IS MOWED - STICK UP IS 2’ - SOFT TAG ON BOTTOM - SEDIMENT BUILT UP ON TOP OF DEDICATED PUMP (CLEANED BEFORE REINSTALLATION) - AN EXTREMELY HIGH SEDIMENT LOAD OBSERVED DURING RE-DEVELOPMENT Other comments (bollards, locks, well tag, miscellaneous debris, sediment buildup): - SCREEN 76.21’ – 101.21’; APPROX. 2’ OF OPEN SCREEN ABOVE WATER TABLE - NO BOLLARDS, LOCK OK, TAG OK - INTERIOR SECTION OF DEDICATED TUBING APPEARS YELLOW/GREEN (SLIGHTLY NEON); SIMILAR TO COLOR OBSERVED IN BC-20 - SEE DEVELOPMENT LOG FOR FURTHER DETAILS WELL INSPECTION FORM P:\Duke Energy Progress.1026\20. BELEWS CREEK\03. FGD Landfill additional assessment\Field Work\inspection forms\BC-25.docx Page 1 Plant: BELEWS CREEK Address: 3195 PINE HALL RD BELEWS CREEK, NC 27009 County: FORSYTH State: NC Today’s Date: 11/09/2016 Field Personnel: BDW, WJW Weather: ☐ Sunny ☒ Overcast ☐ Rain Approx. Temp: 75 WELL ID: BC-25 Redevelopment Recommended? ☒ Yes (as instructed) ☐ No Inspection Photos Measured DTW: 17.59 FT Measured TD: 25.73 FT Condition of Protective Casing: RUSTED, BUT GOOD Bolts in place w/ gaskets? ☐ Yes ☐ No ☒ Stick Up Condition of Concrete Pad? SLIGHTLY UNDERCUT ON OPPOSITE SIDE OF ROAD Condition of PVC casing/riser and cap (water tightness)? GOOD, DEDICATED PUMP CAP (NO SEAL). Pictures Taken? ☒ Yes ☐ No General Observations (vegetation, hardness of well bottom, etc): - TAGGED HARD BOTTOM - GRASS MOWED AROUND AREA - WELL CONSTRUCTION TABLE INCORRECT – TOTAL DEPTH Other comments (bollards, locks, well tag, miscellaneous debris, sediment buildup): - BOLLARDS IN PLACE, LOCK GOOD, TAG OK - SCREENED 8.15’ - 23.15’; APPROX. 10’ OF OPEN SCREEN ABOVE WATER TABLE - SEE DEVELOPMENT LOG FOR FURTHER DETAILS WELL INSPECTION FORM P:\Duke Energy Progress.1026\20. BELEWS CREEK\.03 FGD Landfill additional assessment\Field Work\inspection forms\BC-26.docx Page 1 Plant: BELEWS CREEK Address: 3195 PINE HALL RD BELEWS CREEK, NC 27009 County: FORSYTH State: NC Today’s Date: 11/10/2016 Field Personnel: BDW, WJW Weather: ☒ Sunny ☐ Overcast ☐ Rain Approx. Temp: 70 WELL ID: BC-26 Redevelopment Recommended? ☐ Yes ☒ No Inspection Photo Measured DTW: 17.58’ Measured TD: 23.26’ Condition of Protective Casing: LATCH ON LID NEARLY BROKEN, NEEDS REPLACED. OTHER CASING INTACT. Bolts in place w/ gaskets? ☐ Yes ☐ No ☒ Stick Up Condition of Concrete Pad? GOOD – SLIGHTLY COVERED W/ DEBRIS UPON ARRIVAL Condition of PVC casing/riser and cap (water tightness)? GOOD – DEDICATED PUMP CAP (NO SEAL). Pictures Taken? ☒ Yes ☐ No General Observations (vegetation, hardness of well bottom, etc): - BRUSHED DEBRIS OFF WELL PAD, PAD IN GOOD CONDITION Other comments (bollards, locks, well tag, miscellaneous debris, sediment buildup): - SCREENED 8.26’ -23.26’; APPROX. 10’ OF SCREEN ABOVE WATER TABLE - NO BOLLARDS, LOCK OK, TAG OK - CUT SMALL PIECE OF TUBING OFF PUMP CAP IN ORDER TO INSTALL NEOPRENE SLIP CAP - DID NOT REMOVE DEDICATED PUMP, NO TURBIDITY ISSUES INDICATED IN DATA TABLE PROVIDED BY HDR WELL INSPECTION FORM P:\Duke Energy Progress.1026\20. BELEWS CREEK\.03 FGD Landfill additional assessment\Field Work\inspection forms\BC-27.docx Page 1 Plant: BELEWS CREEK Address: 3195 PINE HALL RD BELEWS CREEK, NC 27009 County: FORSYTH State: NC Today’s Date: 11/10/2016 Field Personnel: BDW, WJW Weather: ☒ Sunny ☐ Overcast ☐ Rain Approx. Temp: 65 WELL ID: BC-27 Redevelopment Recommended? ☐ Yes ☒ No Inspection Photos Measured DTW: Below Pump Measured TD: 34.95 Condition of Protective Casing: RUSTED, BUT GOOD Bolts in place w/ gaskets? ☐ Yes ☐ No ☒ Stick Up Condition of Concrete Pad? GOOD Condition of PVC casing/riser and cap (water tightness)? GOOD – DEDICATED PUMP CAP (NO SEAL). Pictures Taken? ☒ Yes ☐ No General Observations (vegetation, hardness of well bottom, etc): - VERY CLOSE TO ACTIVE PAVED HAUL ROAD - NO DEBRIS/SEDIMENT BUILT UP AROUND WELL - GRASS MOWED AROUND WELL Other comments (bollards, locks, well tag, miscellaneous debris, sediment buildup): - BOLLARDS IN PLACE, LOCK IS GOOD, WELL TAG OK - INSTALLED NEOPRENE SLIP CAP - DID NOT PULL DEDICATED PUMP, NO TURBIDITY ISSUES INDICATED IN DATA TABLE PROVIDED BY HDR - SCREENED 19.95’ – 34.95’. WELL INSPECTION FORM P:\Duke Energy Progress.1026\20. BELEWS CREEK\.03 FGD Landfill additional assessment\Field Work\inspection forms\BC-28.docx Page 1 Plant: BELEWS CREEK Address: 3195 PINE HALL RD BELEWS CREEK, NC 27009 County: FORSYTH State: NC Today’s Date: 11/10/2016 Field Personnel: BDW, WJW Weather: ☒ Sunny ☐ Overcast ☐ Rain Approx. Temp: 65 WELL ID: BC-28 Redevelopment Recommended? ☐ Yes ☒ No Inspection Photos Measured DTW: 49.16’ Measured TD: 60.20’ Condition of Protective Casing: RUSTED, BUT GOOD Bolts in place w/ gaskets? ☐ Yes ☐ No ☒ Stick Up Condition of Concrete Pad? GOOD – PREVIOUSLY REPAIRED Condition of PVC casing/riser and cap (water tightness)? GOOD – DEDICATED PUMP CAP (NO SEAL). Pictures Taken? ☒ Yes ☐ No General Observations (vegetation, hardness of well bottom, etc): - GRASS IS MOWED AROUND WELL - STICK UP IS 2’ ABOVE GROUND Other comments (bollards, locks, well tag, miscellaneous debris, sediment buildup): - SCREENED 45.20’ - 60.20’; APPROX. 4’ OF OPEN SCREEN ABOVE WATER TABLE - NO BOLLARDS, LOCK OK, TAG OK - LID OF PROTECTIVE CASING NOT ATTACHED, HINGE IS EXTREMELY RUSTED - RECOMMEND REPLACEMENT OF PROTECTIVE CASING OR PROTECTIVE CASING LID - DID NOT PULL DEDICATED PUMP, NO TURBIDITY ISSUES INDICATED IN DATA TABLE PROVIDED BY HDR WELL INSPECTION FORM P:\Duke Energy Progress.1026\20. BELEWS CREEK\03. FGD Landfill additional assessment\Field Work\inspection forms\BC-29.docx\BC-29.docx Page 1 Plant: BELEWS CREEK Address: 3195 PINE HALL RD BELEWS CREEK, NC 27009 County: FORSYTH State: NC Today’s Date: 11/10/2016 Field Personnel: BDW, WJW Weather: ☒ Sunny ☐ Overcast ☐ Rain Approx. Temp: 65 WELL ID: BC-29 Redevelopment Recommended? ☐ Yes ☒ No Inspection Photos Measured DTW: BELOW PUMP Measured TD: 22.30 Condition of Protective Casing: GOOD; ROUND (NOT SQUARE) Bolts in place w/ gaskets? ☐ Yes ☐ No ☒ Stick Up Condition of Concrete Pad? GOOD (CIRCULAR) Condition of PVC casing/riser and cap (water tightness)? GOOD, DEDICATED PUMP CAP (NO SEAL). Pictures Taken? ☒ Yes ☐ No General Observations (vegetation, hardness of well bottom, etc): - ABOUT 4.5’ - 5’ OF STICK UP AND PROTECTIVE CASING. - NOT MOWED ON UPGRADIENT SIDE OF WELL HEAD (NO IMPACTS EXPECTED). Other comments (bollards, locks, well tag, miscellaneous debris, sediment buildup): - SCREENED 7.30’ – 22.30’; MAJORITY OF SCREEN ABOVE WATER TABLE - NO BOLLARDS, LOCK OK, TAG OK - INSTALLED NEOPRENE SLIP CAP (CUT TUBING ~1/4'’ IN ORDER TO INSTALL SECURELY OVER PUMP CAP) - DID NOT PULL DEDICATED PUMP, NO TURBIDITY ISSUES INDICATED IN DATA TABLE PROVIDED BY HDR WELL INSPECTION FORM P:\Duke Energy Progress.1026\20. BELEWS CREEK\03. FGD Landfill additional assessment\Field Work\inspection forms\BC-30.docx Page 1 Plant: BELEWS CREEK Address: 3195 PINE HALL RD BELEWS CREEK, NC 27009 County: FORSYTH State: NC Today’s Date: 11/11/2016 Field Personnel: BDW, WJW Weather: ☒ Sunny ☐ Overcast ☐ Rain Approx. Temp: 65 WELL ID: BC-30 Redevelopment Recommended? ☒ Yes (as instructed) ☐ No Inspection Photo Measured DTW: 27.97 FT Measured TD: 34.35 FT Condition of Protective Casing: RUSTED, BUT GOOD Bolts in place w/ gaskets? ☐ Yes ☐ No ☒ Stick Up Condition of Concrete Pad? GOOD Condition of PVC casing/riser and cap (water tightness)? GOOD – DEDICATED PUMP CAP (NO SEAL). Pictures Taken? ☒ Yes ☐ No General Observations (vegetation, hardness of well bottom, etc): - VEGETATION IS MOWED AROUND WELL - YELLOW/GREENISH FILM ON INTERIOR OF DEDICATED TUBING IN WELL, THROUGHOUT ENTIRE LENGTH - SLIGHTLY SOFT TAG ON BOTTOM Other comments (bollards, locks, well tag, miscellaneous debris, sediment buildup): - NO BOLLARDS, LOCK OK, TAG OK - SCREENED 19.10’ – 34.10’; APPROX. 9’ OF WELL SCREEN ABOVE WATER TABLE - CUT ~¼” OF TUBING OUT OF DEDICATED PUMP CAP IN ORDER TO INSTALL NEOPRENE SLIP CAP - SEE DEVELOPMENT LOG FOR FURTHER DETAILS WELL INSPECTION FORM P:\Duke Energy Progress.1026\20. BELEWS CREEK\.03 FGD Landfill additional assessment\Field Work\inspection forms\BC-31.docx Page 1 Plant: BELEWS CREEK Address: 3195 PINE HALL RD BELEWS CREEK, NC 27009 County: FORSYTH State: NC Today’s Date: 11/10/2016 Field Personnel: BDW, WJW Weather: ☒ Sunny ☐ Overcast ☐ Rain Approx. Temp: 65 WELL ID: BC-31 Redevelopment Recommended? ☐ Yes ☒ No Inspection Photos Measured DTW: 58.73’ Measured TD: 83.30’ Condition of Protective Casing: RUSTED, BUT GOOD Bolts in place w/ gaskets? ☐ Yes ☐ No ☒ Stick Up Condition of Concrete Pad? GOOD Condition of PVC casing/riser and cap (water tightness)? GOOD – DEDICATED PUMP CAP (NO SEAL). Pictures Taken? ☒ Yes ☐ No General Observations (vegetation, hardness of well bottom, etc): - AREA AROUND WELL MOWED NICELY - REMOVED MINOR DEBRIS FROM WELL PAD Other comments (bollards, locks, well tag, miscellaneous debris, sediment buildup): - SCREENED 63.30’ – 83.30’ - NO BOLLARDS, TAG OK, LOCK OK - CUT TUBING STICK UP (~1/4”) FROM DEDICATED PUMP CAP IN ORDER TO INSTALL NEOPRENE SLIP CAP - DID NOT PULL DEDICATED PUMP, NO TURBIDITY ISSUES INDICATED IN DATA TABLE PROVIDED BY HDR WELL INSPECTION FORM P:\Duke Energy Progress.1026\20. BELEWS CREEK\.03 FGD Landfill additional assessment\Field Work\inspection forms\BC-32.docx Page 1 Plant: BELEWS CREEK Address: 3195 Pine Hall Rd Belews Creek, NC 27009 County: FORSYTH State: NC Today’s Date: 11/09/2016 Field Personnel: BDW, WJW Weather: ☒ Sunny ☐ Overcast ☐ Rain Approx. Temp: 70 WELL ID: BC-32 Redevelopment Recommended? ☒ Yes (as instructed) ☐ No Inspection Photo Measured DTW: 17.96 Measured TD: 33.02 Condition of Protective Casing: GOOD Bolts in place w/ gaskets? ☐ Yes ☐ No ☒ Stick Up Condition of Concrete Pad? GOOD Condition of PVC casing/riser and cap (water tightness)? GOOD – DEDICATED PUMP CAP (NO SEAL). Pictures Taken? ☒ Yes ☐ No General Observations (vegetation, hardness of well bottom, etc): - GRASS MOWED AROUND PAD - HARD BOTTOM TAG Other comments (bollards, locks, well tag, miscellaneous debris, sediment buildup): - BOLLARDS IN PLACE, LOCK IS GOOD, TAG OK - WATER FROM DEVELOPMENT APPEARS TURBID POSSIBLY DUE TO FORMATION INFLUENCE IN THE SCREENED INTERVAL. - SCREENED 18.01’ – 33.01’ - INSTALLED NEOPRENE SEAL CAP - SEE WELL DEVELOPMENT LOG FOR FURTHER DETAILS MONITORING WELL DEVELOPMENT DUKE ENERGY CAROLINAS, LLC BELEWS CREEK STEAM STATION WELL DEVELOPMENT LOG P:\Duke Energy Progress.1026\20. BELEWS CREEK\.03 FGD Landfill additional assessment\Field Work\Development Logs\BC-20.docx FIELD PERSONNEL: BDW, WJW WEATHER: SUNNY OVERCAST RAIN TEMPERATURE (APPROX): 60 148 River Street, Suite 220 Greenville, South Carolina 29601 (864) 421-9999  (864) 421-9909 Fax www.synTerracorp.com NOTES: WATER LEVEL HAS SIGNFICANTLY DROPPED OVER TIME COMPARED TO HISTORICAL TABLE WELL ID: BC-20 START DEVELPOMENT TIME/DATE: 11-10-16/ 0830 MEASURING POINT: TOC END DEVELOPMENT TIME/DATE: 11-10-16/ 1635 WELL DIAMETER: 2 IN TOTAL VOL PURGED: 16.0 GAL WELL DEPTH: 24.49 (FT) WELL VOLUME: 1.02 GAL DEPTH TO WATER: 18.21 (FT) DEVELOPMENT METHOD: Grundfos Pump 12 Volt Pump Polyethylene Bailer TIME VOL TEMPERATURE DO CONDUCTANCE pH ORP* TURBIDITY* NOTES ( Celsius) (mg/L) (S/cm) (su) (mV) (NTU) 835 3 18 7.5 688 5.4 204 O.O.R. BROWN-FULL OF SEDIMENT; SURGED 940 5 18 8.54 712 5.4 240 O.O.R. BROWN-SEDIMENT 943 6 18 7.50 726 5.4 241 O.O.R. BROWN SWITCHED TO BAILER – SURGING – TAGGING HARD BOTTOM 955 7.5 SEDIMENT APPEARS TO BE ENTERING THROUGH SCREEN - BROWN 1342 10.5 19 7.36 949 5.4 147 299 CLOUDY W/ FINES CLOUDY WATER W/ FINES IN TOP HALF OF BAILER, SEDIMENT IN BOTTOM HALF OF BAILER – SEE PHOTO ON INSPECTION FORM 1610 13.0 19 6.26 965 5.4 187 499 STILL FEELS LIKE SEDIMENT BUILD-UP IN BOTTOM (SOFT) CONTINUED SURGING & BAILING BAILING SEEMS INEFFECTIVE, SEDIMENT CONTINUES TO INFILTRATE THE SCREEN 1635 16.0 COMMENTS: FIELD VEHICLE ACCESSIBLE YES NO Associated midday/end-of-day DO, conductivity, pH within range? (See calibration sheet for this sample date) YES NO. If NO, which parameter ____________. NOTE that reported data should be considered as flagged accordingly. * SynTerra is not NC-certified for these parameters. Data collected for information purposes only. O.O.R. = OUT OF RANGE. WELL TAG PROTECTIVE CASING LOCK CAP CONCRETE PAD GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE MONITORING WELL DEVELOPMENT DUKE ENERGY CAROLINAS, LLC BELEWS CREEK STEAM STATION WELL DEVELOPMENT LOG P:\Duke Energy Progress.1026\20. BELEWS CREEK\.03 FGD Landfill additional assessment\Field Work\Development Logs\BC-21.docx FIELD PERSONNEL: BDW, WJW WEATHER: SUNNY OVERCAST RAIN TEMPERATURE (APPROX): 148 River Street, Suite 220 Greenville, South Carolina 29601 (864) 421-9999  (864) 421-9909 Fax www.synTerracorp.com NOTES: WELL ID: BC-21 START DEVELPOMENT TIME/DATE: 11-10-16/ 1013 MEASURING POINT: TOC END DEVELOPMENT TIME/DATE: 11-10-16/ 1600 WELL DIAMETER: 2 IN TOTAL VOL PURGED: 11.0 GAL WELL DEPTH: 16.99 (FT) WELL VOLUME: 0.60 GAL DEPTH TO WATER: 13.36 (FT) DEVELOPMENT METHOD: Grundfos Pump 12 Volt Pump Polyethylene Bailer TIME VOL TEMPERATURE DO CONDUCTANCE pH ORP* TURBIDITY* NOTES ( Celsius) (mg/L) (S/cm) (su) (mV) (NTU) 1016 3 O.O.R. BROWN – SEDIMENT RICH 1045 5 O.O.R. BROWN 1205 6.5 20 6.33 747 5.3 193 94 CLOUDY FROM TOP OF BAILER (SEDIMENT IN BOTTOM) 1322 8.0 19 5.68 739 5.5 156 81.9 CLOUDY – CLEARER AT TOP OF BAILER (SEDIMENT AT BOTTOM) 1550 9 19 5.90 730 5.2 171 30.4 CLEAR W/ FINES TOP OF BAILER CLEAN, MINOR SEDIMENT AT BOTTOM - SEE PHOTO ON INSPECTION LOG 1600 11.0 COMMENTS: FIELD VEHICLE ACCESSIBLE YES NO Associated midday/end-of-day DO, conductivity, pH within range? (See calibration sheet for this sample date) YES NO. If NO, which parameter ____________. NOTE that reported data should be considered as flagged accordingly. * SynTerra is not NC-certified for these parameters. Data collected for information purposes only. O.O.R. = OUT OF RANGE. WELL TAG PROTECTIVE CASING LOCK CAP CONCRETE PAD GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE MONITORING WELL DEVELOPMENT DUKE ENERGY CAROLINAS, LLC BELEWS CREEK STEAM STATION WELL DEVELOPMENT LOG P:\Duke Energy Progress.1026\20. BELEWS CREEK\.03 FGD Landfill additional assessment\Field Work\Development Logs\BC23A-.docx FIELD PERSONNEL: BDW, WJW WEATHER: SUNNY OVERCAST RAIN TEMPERATURE (APPROX): 55 148 River Street, Suite 220 Greenville, South Carolina 29601 (864) 421-9999  (864) 421-9909 Fax www.synTerracorp.com NOTES: SEDIMENT ON TOP OF DEDICATED PUMP SOFT TAG AT WELL BOTTOM WELL ID: BC-23A START DEVELPOMENT TIME/DATE: 11-11-16/ 0826 MEASURING POINT: TOC END DEVELOPMENT TIME/DATE: 11-11-16/ 1300 WELL DIAMETER: 2 IN TOTAL VOL PURGED: 39 GAL WELL DEPTH: 101.42 (FT) WELL VOLUME: 3.7 GAL DEPTH TO WATER: 78.58 (FT) DEVELOPMENT METHOD: Grundfos Pump 12 Volt Pump Polyethylene Bailer TIME VOL TEMPERATURE DO CONDUCTANCE pH ORP* TURBIDITY* NOTES ( Celsius) (mg/L) (S/cm) (su) (mV) (NTU) 0830 2.5 COARSE BLACK PARTICULATES AT START OF FLOW. FLOW SEEMS REDUCED DUE TO SEDIMENT LOAD. BROWNISH-GRAY WATER- EXTREMELY THICK WITH SEDIMENT. FEELS LIKE LARGE ACCUMUALATION OF SEDIMENT IN BOTTOM OF WELL. 0851 6 16 6.68 115 6.1 12.9 O.O.R. TAN – W/ SEDIMENT 0900 8.5 BROWN - FULL OF SEDIMENT 0923 10.0 16 5.31 74 6.1 -3.3 O.O.R. BROWN – W/ HEAVY SEDIMENT 0934 14.0 16 7.31 53 5.9 42 O.O.R. LT. BROWN W/ SEDIMENT 1046 18.5 16 7.05 48 5.9 102 748 LT TAN W/ FINES 1104 22.0 18 6.50 47 5.9 75 O.O.R. LT TAN W/ FINES 1109 24.0 LT TAN W/ FINES 1202 29.0 19 8.28 135 5.8 79 O.O.R. LT TAN W/ FINES 1215 31.0 19 7.71 49 5.8 77 SWITCHED TO BAILER 1240 36 16 8.17 48 5.8 99 O.O.R. BROWN 1300 39 16 7.94 49 5.8 84 O.O.R. BROWN SEDIMENT APPEARS TO BE ENTERING THROUGH THE FORMATION, HARD TAG WITH BAILER AT WELL BOTTOM COMMENTS: FIELD VEHICLE ACCESSIBLE YES NO Associated midday/end-of-day DO, conductivity, pH within range? (See calibration sheet for this sample date) YES NO. If NO, which parameter ____________. NOTE that reported data should be considered as flagged accordingly. * SynTerra is not NC-certified for these parameters. Data collected for information purposes only. O.O.R. = OUT OF RANGE. WELL TAG PROTECTIVE CASING LOCK CAP CONCRETE PAD GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE MONITORING WELL DEVELOPMENT DUKE ENERGY CAROLINAS, LLC BELEWS CREEK STEAM STATION WELL DEVELOPMENT LOG P:\Duke Energy Progress.1026\20. BELEWS CREEK\.03 FGD Landfill additional assessment\Field Work\Development Logs\BC-25.docx FIELD PERSONNEL: BDW, WJW WEATHER: SUNNY OVERCAST RAIN TEMPERATURE (APPROX): 75 148 River Street, Suite 220 Greenville, South Carolina 29601 (864) 421-9999  (864) 421-9909 Fax www.synTerracorp.com NOTES: UPPER 10’ OF SCREEN IS DRY TOTAL DEPTH IN CONSTRUCTION TABLE INCORRECT WELL ID: BC-25 START DEVELPOMENT TIME/DATE: 11-9-16/ 1515 MEASURING POINT: TOC END DEVELOPMENT TIME/DATE: 11-9-16/ 1646 WELL DIAMETER: 2 IN TOTAL VOL PURGED: 27 GAL WELL DEPTH: 25.73 (FT) WELL VOLUME: 2.16 GAL DEPTH TO WATER: 17.59 (FT) DEVELOPMENT METHOD: Grundfos Pump 12 Volt Pump Polyethylene Bailer TIME VOL TEMPERATURE DO CONDUCTANCE pH ORP* TURBIDITY* NOTES ( Celsius) (mg/L) (S/cm) (su) (mV) (NTU) 1515 2.5 20 2.95 1533 5.2 182 O.O.R. BROWN 1519 5 19 3.25 1467 5.3 187 O.O.R. BROWN 1522 7.5 19 4.26 1162 5.3 193 O.O.R. BROWN – DRY PUMP OFF 1534 10 19 3.67 1317 5.3 189 126 CLOUDY W/FINES 1559 15 19 4.71 1174 5.3 188 O.O.R. SURGED 1602 17 DRY – PUMP OFF 1622 20 19 4.82 1248 5.3 191 66.7 CLOUDY W/ FINES 1625 22 19 5.55 1309 5.3 198 337 LT BROWN W/ SEDIMENT 1643 25 19 4.95 1429 5.3 214 26.6 TURBIDITY TAKEN AFTER TURNING PUMP ON, RISING QUICKLY 1645 27 19 5.70 1381 5.3 216 382 LT BROWN W/ FINES COMMENTS: FIELD VEHICLE ACCESSIBLE YES NO Associated midday/end-of-day DO, conductivity, pH within range? (See calibration sheet for this sample date) YES NO. If NO, which parameter ____________. NOTE that reported data should be considered as flagged accordingly. * SynTerra is not NC-certified for these parameters. Data collected for information purposes only. O.O.R. = OUT OF RANGE. WELL TAG PROTECTIVE CASING LOCK CAP CONCRETE PAD GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE MONITORING WELL DEVELOPMENT DUKE ENERGY CAROLINAS, LLC BELEWS CREEK STEAM STATION WELL DEVELOPMENT LOG P:\Duke Energy Progress.1026\20. BELEWS CREEK\.03 FGD Landfill additional assessment\Field Work\Development Logs\BC-30.docx FIELD PERSONNEL: BDW, WJW WEATHER: SUNNY OVERCAST RAIN TEMPERATURE (APPROX): 148 River Street, Suite 220 Greenville, South Carolina 29601 (864) 421-9999  (864) 421-9909 Fax www.synTerracorp.com NOTES: SOMEWHAT SOFT TAG INITIALLY HARD TAG AFTER 10 GALLONS WELL ID: BC-30 START DEVELPOMENT TIME/DATE: 11-11-16/ 0951 MEASURING POINT: TOC END DEVELOPMENT TIME/DATE: 11-11-16/ 1025 WELL DIAMETER: 2 IN TOTAL VOL PURGED: 10 GAL WELL DEPTH: 34.35 (FT) WELL VOLUME: 1.0 GAL DEPTH TO WATER: 27.97 (FT) DEVELOPMENT METHOD: Grundfos Pump 12 Volt Pump Polyethylene Bailer TIME VOL TEMPERATURE DO CONDUCTANCE pH ORP* TURBIDITY* NOTES ( Celsius) (mg/L) (S/cm) (su) (mV) (NTU) 1001 3.0 15 7.58 74 5.8 116 O.O.R. BROWN - SEDIMENT LOTS OF SEDIMENT, BLACK MATERIAL COMING OUT OF WELL IN BAILER. HARD TAG ON BOTTOM AFTER 5 GALLONS 1004 5 14 7.58 68.6 5.8 145 O.O.R. BROWN SEDIMENT 1019 9 14 7.55 66.8 5.8 169 O.O.R. BROWN SEDIMENT 1024 10 14 7.57 65.4 5.8 185 O.O.R. BROWN SEDIMENT HARD TAG W/ WATER LEVEL AT 10 GALLONS PURGED – SEDIMENT COMING IN FROM FORMATION COMMENTS: FIELD VEHICLE ACCESSIBLE YES NO Associated midday/end-of-day DO, conductivity, pH within range? (See calibration sheet for this sample date) YES NO. If NO, which parameter ____________. NOTE that reported data should be considered as flagged accordingly. * SynTerra is not NC-certified for these parameters. Data collected for information purposes only. O.O.R. = OUT OF RANGE. WELL TAG PROTECTIVE CASING LOCK CAP CONCRETE PAD GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE MONITORING WELL DEVELOPMENT DUKE ENERGY CAROLINAS, LLC BELEWS CREEK STEAM STATION WELL DEVELOPMENT LOG P:\Duke Energy Progress.1026\20. BELEWS CREEK\.03 FGD Landfill additional assessment\Field Work\Development Logs\BC-32.docx FIELD PERSONNEL: BDW, WJW WEATHER: SUNNY OVERCAST RAIN TEMPERATURE (APPROX): 70 148 River Street, Suite 220 Greenville, South Carolina 29601 (864) 421-9999  (864) 421-9909 Fax www.synTerracorp.com NOTES: SURFACE COMPLETION AND PUMP IN EXCELLENT CONDITION WELL ID: BC-32 START DEVELPOMENT TIME/DATE: 11-9-16/ 0949 MEASURING POINT: TOC END DEVELOPMENT TIME/DATE: 11-9-16/ 1440 WELL DIAMETER: 2 IN TOTAL VOL PURGED: 35 GAL WELL DEPTH: 33.02 (FT) WELL VOLUME: 3.33 GAL DEPTH TO WATER: 17.96 (FT) DEVELOPMENT METHOD: Grundfos Pump 12 Volt Pump Polyethylene Bailer TIME VOL TEMPERATURE DO CONDUCTANCE pH ORP* TURBIDITY* NOTES ( Celsius) (mg/L) (S/cm) (su) (mV) (NTU) 0952 5 18 5.07 1300 5.4 212 O.O.R. SURGED – LT BROWN SEDIMENT 0955 10 17 4.05 1460 5.4 220 O.O.R. LT BROWN – SEDIMENT 0958 12.5 17 7.20 1344 5.5 216 O.O.R. INTERMITTENT FLOW – PUMP OFF ALLOWED WELL TO RECHARGE 1207 15 18 8.22 1348 5.5 187 373 MILKY GREY 1210 20 17 8.61 1337 5.6 199 O.O.R. SURGED – TAN SEDIMENT 1213 23 17 5.71 1495 5.4 202 O.O.R. LT BROWN SEDIMENT 1430 25 17 8.24 1347 5.5 142 219 CLOUDY W/ FINES 1434 27.5 17 8.42 1328 5.5 157 347 MILKY 1437 30 17 8.42 1278 5.5 168 402 MILKY 1439 35 17 9.12 1377 5.5 172 O.O.R. TURBIDITY INCREASES AS WATER DRAWS DOWN TO BOTTOM OF SCREEN – ENTERING FROM FORMATION COMMENTS: FIELD VEHICLE ACCESSIBLE YES NO Associated midday/end-of-day DO, conductivity, pH within range? (See calibration sheet for this sample date) YES NO. If NO, which parameter ____________. NOTE that reported data should be considered as flagged accordingly. * SynTerra is not NC-certified for these parameters. Data collected for information purposes only. O.O.R. = OUT OF RANGE. WELL TAG PROTECTIVE CASING LOCK CAP CONCRETE PAD GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE GOOD BAD NONE