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HomeMy WebLinkAbout1119_DukeAsheville_DraftWQMP_Update_WordDoc_20230728Water Quality Monitoring Plan Asheville Steam Electric Plant CCR Landfill (Permit No.1119-INDUS) Buncombe County, North Carolina PREPARED FOR: Duke Energy Progress, LLC PREPARED BY: SynTerra Corporation 148 River Street, Suite 220 Greenville, SC 29601 Revision B July 28, 2023 Revision History Revision Company Date of Revision Description of Revision  A Duke Energy April 2021 Initial Submission  B SynTerra July 2023 Updated the list of constituents to be analyzed for surface water samples, provided updates to applicable surface water standards and screening criteria, updated Table 1 and Table 3 titles, added total well depth and depth to groundwater in feet below ground surface to Table 2.             Table of Contents 1.0 Introduction 1 1.1 Site Description 1 1.2 Site Geology and Hydrogeology 1 2.0 Monitoring System 2 2.1 Groundwater Monitoring (NCAC 15A 13B .0601) 2 2.1.1 Groundwater – Well Construction and Decommissioning 3 2.2 Surface Water Monitoring (NCAC 15A 13B .0602) 3 2.3 Engineered Drain Outlet Monitoring 4 2.4 Leachate Monitoring 4 3.0 Sampling and Analysis 4 3.1 Groundwater – Sampling and Analysis 4 3.1.1 Establishment of Background 4 3.2 Surface Water – Sampling and Analysis 4 3.3 Engineered Drain Outlet - Sampling and Analysis 5 3.4 Leachate – Sampling and Analysis 5 3.5 Field Collection Procedures 6 3.6 Analytical Procedures 6 4.0 Reporting 6 4.1 Well Abandonment Record Submittal 6 4.2 Well Construction Record Submittal 6 4.3 Monitoring Well Installation Report 6 4.4 Water Quality Monitoring Report 7 5.0 References 8 Appendices Appendix I – Drawings Appendix II – Tables Appendix III – Boring Logs and Well Construction Records Appendix IV – Duke Energy Sampling Procedures Attachment 1 Duke Energy Groundwater and Sampling Collection Procedure Attachment 2 Duke Energy Landfill Sample Collection Guidelines Attachment 3 Duke Energy Laboratory Analysis Plan Appendix V – NCDEQ Well Abandonment and Well Construction Forms (GW-1 and GW-30) Appendix VI – NCDEQ Environmental Monitoring Report Form Introduction This document provides the Water Quality Monitoring Plan (WQMP) for the Duke Energy Progress, LLC (Duke Energy) Asheville Stream Electric Plant (Asheville, Plant, or Site), Coal Combustion Residual (CCR) Landfill and is intended to satisfy the requirements of Title 15A of the North Carolina Administrative Code (NCAC) 13B .0504(1)(g)(iv). The purpose of this document is to establish procedures for monitoring groundwater in the uppermost aquifer, surface water in the vicinity of the landfill, and leachate during operational and post-closure periods. The WQMP is designed to provide information to the North Carolina Department of Environmental Quality (NCDEQ) - Solid Waste Section (SWS) and the landfill owner and operations personnel to evaluate potential effects on groundwater and surface water quality. The pertinent geologic and hydrogeologic characteristics of the Site, as described in the Site Study Report Volume II – Hydrogeologic Report (April 2019), prepared by Geosyntec Consultants, Inc. are summarized herein. Site Description The 12.5-acre landfill is generally bounded by a former railroad spur to the south, the former coal-fired power plant area and Lake Julian to the east, undeveloped land to the north, and Interstate I-26, wetlands, and the French Broad River to the west (Appendix I, Drawing 1). The landfill received a Permit to Operate on April 1, 2021. Leachate is conveyed from the landfill to a leachate tank for short-term storage. Leachate from the tank is discharged to the Buncombe County Metropolitan Sewerage District (MSD) where it comingles with other wastewater for treatment. The waste material placed throughout the life of the landfill consists of CCR, predominantly formerly ponded fly ash and bottom ash. The landfill no longer receives waste; closure was substantially complete in April 2023. Site Geology and Hydrogeology Asheville is within the Blue Ridge physiographic province, where soil overlying the bedrock has formed from the in-place weathering of bedrock. The groundwater system at the Site is grouped into three flow zones to distinguish the interconnected groundwater system: surficial zone (primarily saprolite), transition zone (between surficial and bedrock), and bedrock (competent rock). Groundwater is usually first encountered in the surficial flow zone; however, the surficial zone and transition zone thin to the west and northwest in the area of the landfill resulting in groundwater encountered only within the bedrock zone. Groundwater enters the system from upgradient, headwaters east of the landfill, and generally flows downward to the west toward an unnamed stream, and to the northwest toward a wetland area and several unnamed streams, which converge into Powell Creek. The wetland area and streams act as groundwater discharge zones downgradient of the landfill which are classified as Class C under Title 15A, NCAC, Subchapter 02B, Surface Water and Standards (02B standards). Flow from those surface water features eventually reaches the French Broad River, which is classified as Class B surface waters under 02B standards. Monitoring System Performance of the landfill-engineered base liner system and engineered cover are evaluated for control of releases to the environment based on water quality of groundwater and surface water downgradient of the landfill. Leachate is sampled from the leachate collection system to primarily provide analytical data to assist in evaluating potential water quality exceedances to determine if the landfill performance is a contributor of constituents in the environment. Sample locations and descriptions are presented in Appendix II, Table 1. Groundwater Monitoring (NCAC 15A 13B .0601) The groundwater monitoring network is designed to yield groundwater samples representative of aquifer conditions underlying the landfill area to monitor groundwater quality in the uppermost aquifer. The groundwater monitoring network consists of water quality wells upgradient of the landfill to determine background concentrations, water quality wells downgradient of the landfill to monitor performance of the landfill-engineered base liner system, and water-level-only wells to assist with refinement of groundwater flow. The groundwater monitoring network is shown in Appendix I, Drawing 2. Drawings 3A and 3B of Appendix I identify the water quality wells in the surficial, transition, and bedrock flow zones and depict the groundwater flow direction for each flow zone. Upgradient (background) water quality wells screened in: Surficial flow zone: ASV-CB-9 ASV-CB9-SL ASV- LMW-1S Bedrock flow zone: ASV-CB-9BR ASV-LMW-1B Downgradient water quality wells screened in: Transition flow zone: ASV-LMW-2T Bedrock flow zone: ASV-LMW-2B ASV-LMW-3B ASV-LMW-4B Water-level-only wells screened in: Transition flow zone: ASV-CB-8 ASV-MW-13D Bedrock flow zone: ASV-CB-8BR ASV-MW-13BR Monitoring well construction details are included in Appendix II, Table 2. Boring logs and well construction records are provided in Appendix III. Groundwater – Well Construction and Decommissioning M onitoring wells are constructed in accordance with NCAC 02C .0108 and guidance provided by NCDEQ (NCDEQ, 2023). A typical monitoring well construction detail is provided on Drawing 4 of Appendix I. Constructed monitoring wells are located by a North Carolina Professional Land Surveyor to within +0.1 foot on the horizontal plane and +0.01 foot vertically in reference to existing survey points and developed in accordance with NCAC 02C .0108 (q). Dedicated stainless steel bladder pumps are installed to help reduce agitation during sampling, resulting in lower sample turbidity and minimizing the risk of cross-contamination from well to well. Pump intakes are generally set within the center of each well screen. If a monitoring well no longer provides a sample representative of the quality of groundwater passing the relevant point of compliance, the SWS will be notified. The Owner or Owner’s Representative will re-evaluate the groundwater monitoring network, and provide recommendations to the SWS for modifying, rehabilitating, decommissioning, or installing replacement or additional monitoring wells, as appropriate. Surface Water Monitoring (NCAC 15A 13B .0602) The surface water monitoring network is designed to monitor the quality of jurisdictional waters. Surface water is monitored at three locations downgradient of the landfill to monitor performance of the landfill-engineered base liner system and closure system. There are no upgradient surface water monitoring locations. The surface water monitoring network is shown in Appendix I, Drawing 2. Details about the surface water monitoring network downgradient of the landfill include: ASV-LF-SW1 is located west of the landfill in an unnamed tributary that flows to the French Broad River, which is classified as Class B surface waters. The stream is a groundwater discharge zone approximately 100 feet side-gradient of the landfill. The location is monitored for water quality in conjunction with groundwater to monitor the performance of the landfill liner and closure systems. ASV-LF-SW2 is located northwest of the landfill in Powell Creek, which is classified as a Class C surface water. The stream is a groundwater discharge zone approximately 300 feet downgradient of the landfill. The location is monitored for water quality in conjunction with groundwater to monitor the performance of the landfill liner and closure systems. ASV-LF-SW3 is located north of the landfill in Powell Creek, upgradient of sampling location ASV-LF-SW2. The stream is a groundwater discharge zone approximately 120 feet downgradient of the landfill. The location is monitored for water quality in conjunction with groundwater to monitor the performance of the landfill liner and closure systems. Engineered Drain Outlet Monitoring The mechanically stabilized earthen (MSE) berm is constructed with an engineered drain in the northwest area of the landfill to capture groundwater seepage from beneath the landfill-engineered base liner. The engineered drain outlet sample location ASV-DP-4 is shown in Appendix I, Drawing 2. Leachate Monitoring One leachate sample location, ASV-LCS-1, representing leachate from the entire landfill, is collected from an in-line sampling port along the force main conveying leachate from the landfill to the Leachate Storage Tank (Drawing 2). Sampling and Analysis Groundwater, surface water, engineered drain outlet, and leachate will be sampled and analyzed on a semiannual basis during the life of the facility and the post-closure care period. Groundwater – Sampling and Analysis Groundwater samples are collected in accordance with NCAC 13B .0601 and guidance provided by NCDEQ (NCDEQ, 2023). Field collection procedures, labeling, chain-of-custody (COC) documentation, and laboratory receipt are included in the Duke Energy Groundwater and Sampling Collection Procedure provided as Attachment 1 of Appendix IV. Constituents for analysis and respective analytical methods are listed in Table 3 of Appendix II. Groundwater samples will be compared to appropriate North Carolina Regulatory Standards (02L). In addition, required field parameters, including but not limited to, pH, conductivity, dissolved oxygen (DO), oxidation reduction potential (ORP), temperature, and turbidity will be measured during each sampling event. Establishment of Background Eight independent groundwater samples were collected from each monitoring well prior to receipt of waste material, as specified in the Solid Waste Permit to Construct. Pre-disposal samples collected from wells were analyzed for the constituents listed in Table 3 in Appendix II. The intent of pre-disposal sampling is to collect pre-waste data to compare to post-waste analytical results more accurately. This groundwater data was submitted to the SWS in the Groundwater Monitoring Report – Baseline Sampling Events #1 through #4 (SynTerra, 2021a). Surface Water – Sampling and Analysis Surface water samples are only collected at each location if flowing water is observed during the sampling event. Samples are obtained using the grab sample method. Field collection procedures, labeling, COC documentation, and laboratory receipt are included in the Duke Energy Landfill Sample Collection Guidelines provided as Attachment 2 of Appendix IV. Constituents for analysis and respective analytical methods are listed in Table 3 of Appendix II. Surface water analytical results are screened to applicable Classifications and Water Quality Standards Applicable to Surface Waters and Wetlands of North Carolina as defined in 15A NCAC 02B, in-stream target values (ISTV), and the U.S. Environmental Protection Agency (USEPA) National Recommended Water Quality Criteria (NRWQC) for Aquatic Life and Human Health (Appendix II, Table 3). Duke Energy provides comparisons against ISTV with the qualification that an exceedance of the published value is not necessarily a violation of the water quality standard for toxicity. As stated by the USEPA, NRWQC standards do not constitute regulations, nor do they impose a legally binding requirement. Therefore, comparisons with those criteria are for information purposes only.   Additional information regarding surface water standards and screening criteria are outlined below: Several 02B standards and ISTV require sampling methods specific to acute or chronic concentrations and are not applicable to the grab sample method; however acute standards are considered more applicable to grab sampling and are included for screening purposes only. Hardness-dependent standards require sampling methods specific to acute or chronic concentrations and are not applicable to the grab sample method. Duke Energy will use a standard hardness of 25 milligrams per liter (mg/L) for screening purposes only; however, if the in-stream hardness values for a given sampling event are substantially less than or greater than 25 mg/L, the minimum in-stream hardness value will be used to calculate the hardness-dependent standard to more accurately screen analytical results. The 02B surface water standards for chromium are based upon speciation for dissolved trivalent and hexavalent chromium. Duke energy will sample for total and dissolved total chromium. Results will be screened to the dissolved trivalent 02B standard; this standard is also a hardness dependent, acute standard and will be based on 25 mg/L hardness and used for screening purposes only. The 02B surface water standard for mercury represents a total concentration and is not for acute, chronic, or hardness-dependent concentrations. The mercury 02B standard for Class B, C, and water supply waters is 0.012 micrograms per liter (µg/L). Duke Energy will use the analytical method USEPA 245.1/SW 7470A for mercury analysis, which has a reporting limit of 0.050 µg/L and is greater than the 02B criteria of 0.012 µg/L. Engineered Drain Outlet - Sampling and Analysis An engineered drain outlet sample is only collected if flowing water is observed during the sampling event. Samples are obtained using the grab sample method. Field collection procedures, labeling, COC documentation, and laboratory receipt are included in the Duke Energy Landfill Sample Collection Guidelines provided as Attachment 2 of Appendix IV. Analytical results from the engineered drain outlet are compared to applicable 02B surface water standards. Constituents for analysis and respective analytical methods are listed in Table 3 of Appendix II. Leachate – Sampling and Analysis A leachate sample is collected from an inline sample port. Field collection procedures, labeling, COC documentation, and laboratory receipt are included in the Duke Energy Landfill Sample Collection Guidelines provided as Attachment 2 of Appendix IV. Constituents for analysis and respective analytical methods are listed in Table 3 of Appendix II. Field Collection Procedures Duke Energy Groundwater Sampling Collection Procedure 3175.6 is provided as Attachment 1 of Appendix IV and shall be followed when collecting groundwater samples on-Site. The Duke Energy Landfill Sample Collection Guideline is provided as Attachment 2 of Appendix IV and shall be followed when collecting surface water, engineered drain flow, and leachate samples on Site. Analytical Procedures Duke Energy Laboratory Analysis Plan, including quality assurance and quality control, is provided as Attachment 3 of Appendix IV and shall be followed for analysis of water quality samples. Reporting Well Abandonment Record Submittal A certified record of well abandonment (form GW-30) is submitted to the NCDEQ Division of Water Resources within a period of 30 days after well abandonment in accordance with NCAC 02C .0114. A copy of the NCDEQ GW-30 Well Abandonment Record form has been included in Appendix V. Well Construction Record Submittal A certified record of well construction (form GW-1) is submitted to the NCDEQ Division of Water Resources within a period of 30 days after well completion in accordance with NCAC 02C .0114. A copy of the NCDEQ GW-1 Well Construction Record form has been included in Appendix V. Monitoring Well Installation Report After completion of well installation-related field activities, a Groundwater Monitoring Well Installation Report (SynTerra, 2021b) was prepared and includes the following information regarding the sample network: Description of field activities Table summarizing monitoring well construction details Boring and well logs Well development notes Slug test data Soil laboratory data Effective porosity estimates Water Quality Monitoring Report A semiannual report of monitoring results will be submitted to the SWS within 120 days after the date of sampling. The report will include, at a minimum: Completed NCDEQ Environmental Monitoring Report Form (Appendix VI) A figure which includes relevant facility features and monitoring locations sampled as a part of this Plan A groundwater flow map with arrows indicating flow direction prepared from the current monitoring event Sampling and analysis data including: Monitoring data sheets Field calibration forms COC records Laboratory quality assurance (QA) data Data validation checklists Table of groundwater detections and exceedances for each monitoring location, which will provide: Analytical results reported in relevant screening value units, except for field parameters Laboratory method detection limits Appropriate North Carolina Regulatory Standards (02L) Appropriate USEPA Regulatory Standards exceedances shown in bold Field parameters Groundwater monitoring well construction table Table with calculated groundwater elevation and groundwater flow rates Table for surface water and engineered drain outlet monitoring locations which will provide: Analytical results reported in relevant screening value units, except for field parameters Laboratory method detection limits Screening values: Appropriate North Carolina Regulatory Standards (02B) Appropriate USEPA Regulatory Standards Field parameters Table for leachate monitoring location which will provide: Analytical results reported in relevant screening value units, except for field parameters. Analytical results are provided for information purposes only and not compared to groundwater (02L standards) or surface water (02B standards) quality standards. Laboratory method detection limits Field parameters An Electronic Data Deliverable (EDD) spreadsheet in the required Division format for analysis data The SWS will be notified if vendor lab analyses have not been completed within 120 days of the sampling event. Groundwater monitoring data sheets, field calibration forms, COC records, laboratory QA data, and data validation checklists shall be kept on file by Duke Energy and are available upon request. References The references cited below were used in the preparation of this WQMP and may or may not be referenced within the text. Geosyntec Consultants, Inc. (2019). Site Study Report, Volume II – Site Hydrogeologic Report. Asheville Steam Electric Plant. Project Number GC6709. April 2019. Geosyntec Consultants, Inc., (2019). Water Quality Monitoring Plan. CCR Landfill, Asheville Steam Electric Plant. Project Number GC6709. October 2019. NCDEQ. (2020). Environmental Data Submissions. North Carolina Department of Environmental Quality. 2020 Retrieved May 16, 2023, from https://edocs.deq.nc.gov/WasteManagement/DocView.aspx?id=1419626&dbid=0&repo=WasteManagement&searchid=ec6f4b82-3cb5-43e5-a214-ea22139492f4&cr=1 NCDEQ. (2023). Environmental Monitoring – Field Measurement and Sampling Procedures. North Carolina Department of Environmental Quality. Retrieved May 16, 2023, from https://www.deq.nc.gov/about/divisions/waste-management/solid-waste-section/compliance-and-monitoring/environmental-monitoring SynTerra. (2021a). Groundwater Monitoring Report – Baseline Sampling Events #1 through #4. CCR Landfill, Asheville Steam Electric Plant. April 2021. SynTerra. (2021b). Groundwater Monitoring Well Installation Report. CCR Landfill, Asheville Steam Electric Plant. April 2021. Appendices – Drawings  – Tables – Boring Logs and Well Construction Records – Duke Energy Sampling Procedures Attachment 1 - Duke Energy Groundwater and Sampling Collection Procedure Attachment 2 - Duke Energy Landfill Sample Collection Guidelines Attachment 3 - Duke Energy Laboratory Analysis Plan – NCDEQ Well Abandonment and Well Construction Forms (GW-1 and GW-30) – NCDEQ Environmental Monitoring Report Form