1812_DukeMarshall_ECMP_Rev5_FID1989376_20241107

Environmental Controls Monitoring Plan
Marshall Steam Station
Industrial Landfill No. 1
(1812-INDUS)
Catawba County, Terrell, North Carolina
PREPARED FOR:
Duke Energy Carolinas, LLC
DUKE
ENERGY
PREPARED BY:
SynTerra Corporation
148 River Street, Suite 220
Greenville, South Carolina 29601
Revision 5
November 6, 2024
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SEAL 056667
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Thomas Colton, NC PE 056667
Project Manager
Caroline Cothran
Staff Scientist

Industrial Landfill No. 1 1812-INDUS Revision 5, November 6, 2024
Environmental Controls Monitoring Plan
Revision History
CompanyRevision
Revision
..
0
SynTerra
10/8/2020
Original submittal to NCDEQ DWM
1
SynTerra
11/23/2020
Revision to incorporate NCDEQ DWM
comments
Revision to incorporate landfill underdrain
2
SynTerra
12/17/2021
sample location (MSS-LF-UD1), due to Phase 2
design modifications, and leachate basin leak
detection monitoring location (MSS -LB -LDS)
Revision to incorporate Phase 3 sample
locations (MSS-LF-LCS7, MSS-LF-LDS7, and
3
SynTerra
7/19/2022
MSS-LF-UD2), due to Phase 3 design
modifications, and leachate basin leak detection
monitoring location (MSS-LB-LDS2)
Revision to incorporate temporary flows from
Structural Fill stability feature dewatering
4
SynTerra
9/5/2024
system to the Leachate Basin and addition of
inline caustic treatment to provide pH treatment
to leachate prior to discharge into the Leachate
Basin.
Revision to perform the following:
1. Incorporate Phase 4 sample locations
(MSS-LF-LCS8, MSS-LF-LDS8)
2. Remove leachate basin leachate
5
SynTerra
11/6/2024
collection monitoring location (MSS-LF-
LCSC2) due to access constraints.
3. Update parameter list and sample
methods per updated parameter and
constituent list, approved by NCDEQ on
March 20, 2023
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Industrial Landfill No. 1 1812-INDUS Revision 5, November 6, 2024
Environmental Controls Monitoring Plan
Table of Contents
1.0
Introduction................................................................................................................................. 1
1.1
Site Description.................................................................................................................................
1
1.2
Site Geology and Hydrogeology.......................................................................................................
2
2.0
Monitoring Network.....................................................................................................................
3
2.1
Engineered Base Liner System Leak Detection Monitoring.............................................................
3
2.1.1 Engineered Base Liner System Leak Detection — Monitoring (NCGS 130A 295.4(b) and NCAC
15A13B .0602(e)(6))...................................................................................................................
3
2.1.2 Engineered Base Liner System Leak Detection - Reporting.......................................................4
2.2
Water Quality....................................................................................................................................
5
2.2.1 Water Quality Monitoring.............................................................................................................
5
2.2.1.1 Surface Water— Monitoring (NCAC 15A 13B.0602)..........................................................
5
2.2.1.2 Underdrain Outlet — Monitoring...........................................................................................
5
2.2.2 Water Quality Reporting...............................................................................................................
5
2.2.2.1 Surface Water — Reporting..................................................................................................
5
2.2.2.2 Underdrain Outlet — Reporting.............................................................................................
6
2.3
Leachate............................................................................................................................................7
2.3.1 Leachate - Monitoring..................................................................................................................
7
2.3.2 Leachate - Reporting...................................................................................................................
7
3.0
Sampling and Analysis................................................................................................................
8
3.1
Water Quality....................................................................................................................................
8
3.1.1 Surface Water— Sampling and Analysis.....................................................................................
8
3.1.2 Underdrain Outlet— Sampling and Analysis................................................................................
8
3.2
Leachate — Sampling and Analysis...................................................................................................
8
3.3
Field Collection Procedures..............................................................................................................
8
3.4
Analytical Procedures.......................................................................................................................
8
3.5
Quality Assurance and Quality Control Program..............................................................................
9
3.6
Validation of Field Data Package....................................................................................................
10
3.7
Validation of Laboratory Data.........................................................................................................
10
4.0
Environmental Controls Monitoring Reporting...........................................................................
10
4.1
Environmental Controls Monitoring Report Submittal....................................................................
10
5.0
References................................................................................................................................11
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Environmental Controls Monitoring Plan
List of Tables
Table 1 Summary of Solid Waste Constituents and Analytical Methods
List of Drawings
Drawing 1 Site Location Map
Drawing 2 Monitoring Locations
Drawing 3 Direct Measurement Potentiometric Surface
List of Appendices
Appendix I — Landfill Sample Collection Guidelines
Appendix II — NCDEQ Environmental Monitoring Report Form
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Industrial Landfill No. 1 1812-INDUS Revision 5, November 6, 2024
Environmental Controls Monitoring Plan
1.0 Introduction
This Environmental Controls Monitoring Plan (Plan) for the Duke Energy Marshall Steam Station
(Marshall/Plant/Site) establishes locations and procedures for monitoring early detection of solid waste
or leachate potentially released to the environment from the Industrial Landfill No. 1 — Phase 1 through
Phase 4 (landfill/ILF) and leachate impoundment (leachate basin).
The landfill is situated partially within an area that was formerly used for the storage or disposal of coal
combustion residuals (CCR).
The landfill is designed and constructed in accordance with North Carolina General Statute (NCGS)
130A 295.4 for Combustion Products Landfills. This Plan is intended to satisfy the requirements of a
groundwater monitoring plan required by North Carolina Administrative Code Title 15A Subchapter 13B
(NCAC 15A 13B) .0504 (c)(8)(D)) in accordance with NCGS 130A 295.4(c) which states in part
"compliance with performance of the landfill to prevent releases of waste to the environment may be
determined based on leakage rate rather than monitoring well data". Additionally, groundwater
monitoring, required by the US Environmental Protection Agency (USEPA) Title 40 Code of Federal
Regulations Part 257 Subpart D (CCR Rule), is in accordance with 40 CFR §257.91(d) which states
"the owner or operator of multiple CCR units may install a multiunit groundwater monitoring system
instead of separate groundwater monitoring systems for each CCR unit". The landfill is part of a
multiunit system with the ash basin.
The leachate basin is designed and constructed in accordance with NCAC 15A 13B .1680. Per NCAC 15A
13B .1680(e)(6), this Plan is intended to satisfy the requirements of a groundwater monitoring system
"consistent with or equivalent to" the requirements for the landfill unit per NCAC 15A 13B .1631(e).
Prior to completion of landfill closure, this Plan will be evaluated and North Carolina Department of
Environmental Quality (NCDEQ) Division of Waste Management (DWM) will be consulted to determine
if this Plan should be revised for post closure monitoring of landfill performance.
1.1 Site Description
The approximate 91.3-acre landfill (Phases 1, 2, 3, and 4) is located north of the Marshall
power block and generally bounded by the property line to the north, vacant land and closed
asbestos and debris landfill areas (1804-INDUS) to the east, and CCR Structural Fill CCB0031
(previously known as the PV Structural Fill), the MAR-145 industrial stormwater pond, and
historic ash basin to the south and west (Drawing 1). The DWM issued the initial ILF Permit to
Operate on March 7, 2011. Phase 1 is constructed over the CCR Structural Fill CCB0072
(Landfill Phase I Subgrade). Phase 2 of the landfill is immediately south of Phase 1. Phase 3
of the landfill is immediately south of Cell 6 of Phase 2. Phase 4 is immediately west of Phase
3 and south of Phase 1. Phase 1, Phase 2, Phase 3, Phase 4, and Structural Fill CCB0072 are
situated adjacent to and partially over an upstream area of the historic ash basin waste
boundary.
The leachate basin is located south of the ILF bounded by the historic ash basin on the north,
east, and south and the CCR Structural Fill CCB0031 on the west (Drawing 2). The leachate
of Phases 1 and 2 is conveyed from the landfill to the leachate basin via a force main piping
network; leachate from Phase 3 and 4 is conveyed to the leachate basin directly via a force
main. The leachate basin discharges to the Lined Retention Basin (LRB) where it is comingled
with other Marshall wastewater for treatment (Drawing 2). The LRB discharges through a
permitted National Pollutant Discharge Elimination System (NPDES) outfall.
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Industrial Landfill No. 1 1812-INDUS Revision 5, November 6, 2024
Environmental Controls Monitoring Plan
Operational flows from the Structural Fill (CCB0031) stability feature dewatering systems will
be temporarily routed to the leachate basin. These flows are anticipated to start in the third
quarter of 2024. In addition, an inline caustic treatment and static mixer to the leachate basin
is proposed and anticipated to be installed in the fourth quarter of 2024 to provide additional
pH treatment prior to discharge into the leachate basin.
The landfill and leachate basin engineered base liners include a leak detection system (LDS)
that monitors the integrity of the primary flexible membrane liner. A network of drainage
features manage stormwater from the landfill and adjacent area, which is routed to a permitted
outfall. No stormwater from the landfill area flows off the Site property or enters a surface
water prior to passing through a permitted outfall.
The historic ash basin, which partially underlies the landfill and is adjacent to the leachate
basin, received CCR via sluice lines beginning in 1965 until early 2019. In 1984, Marshall
converted from wet to dry fly ash handling. In 2019 bottom ash was converted from wet to dry
handling and all ash sluicing ceased. Duke Energy is authorized to discharge wastewater from
the ash basin to Lake Norman (Outfall 002) in accordance with NPDES Permit NC0004987.
Groundwater from beneath and in the vicinity of the ash basin and leachate basin is sampled
and analyzed according to the NCDEQ approved monitoring plan which meets the
requirements of the Coal Ash Management Act (CAMA).
The landfill and ash basin are monitored together, as a multiunit in accordance with the
requirements of 40 CFR 257.91(d). CCR Rule groundwater monitoring networks are certified
by a qualified professional engineer in accordance with 40 CFR 257.91(f) and subject to
additional modifications if wells are abandoned due to construction or ash basin closure
activities. Groundwater is sampled and analyzed semi-annually according to the requirements
of 40 CFR 257.93.
The CAMA and CCR Rule groundwater monitoring programs include routine monitoring and
reporting.
The majority of waste intended for placement throughout the life of the landfill consists of CCR,
predominantly fly ash and bottom ash. The approved waste stream can be found in the
Operations Plan.
1.2 Site Geology and Hydrogeology
The groundwater system in the natural materials (shallow/deep/bedrock) at Marshall is
consistent with the regolith-fractured rock system and is characterized as an unconfined,
interconnected aquifer system indicative of the Piedmont Physiographic Province in which the
site is contained. The groundwater system at the site is divided into the following three layers
to distinguish the interconnected groundwater system: the shallow flow zone, deep (transition
zone) flow zone, and the bedrock (competent bedrock) flow zone.
The ash basin, landfill, leachate basin, closed historic landfills, and CCR Structural Fills are
contained within a former perennial stream valley (flow compartment) (Drawing 1).
Groundwater within the flow compartment is a flow -through system. Groundwater enters the
system from the upgradient end near the landfill and flows laterally through the middle regions
and downward near the dam, or downgradient end. Groundwater divides are located west and
north of the landfill, concurrent with topographic ridges along Sherrills Ford Road to the west
and Island Point Road to the north. The topographically controlled flow direction provides
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Industrial Landfill No. 1 1812-INDUS Revision 5, November 6, 2024
Environmental Controls Monitoring Plan
natural hydraulic control of constituent migration from the ash basin and adjacent sources
within the flow compartment.
A recent potentiometric surface of the uppermost aquifer created by water level values from
direct measurements obtained from the CAMA and CCR Rule monitoring networks for the
area that includes the landfill, ash basin, leachate basin, closed historic landfills, and CCR
Structural Fills is provided as Drawing 3. The primary flow path of the groundwater remains
generally northwest to southeast within the flow compartment. This recent potentiometric
surface should not be used to estimate future groundwater conditions since ash basin closure
by excavation has the potential to alter groundwater elevations and flow.
2.0 Monitoring Network
Performance of the landfill and leachate basin engineered liner systems will be evaluated for control of
releases to the environment based on the flow rate within the engineered base liner LDS (described
below). Groundwater downgradient of the landfill and leachate basin is monitored in accordance with
CAMA and the CCR Rule groundwater monitoring programs and therefore not addressed in this Plan.
2.1 Engineered Base Liner System Leak Detection Monitoring
2.1.1 Engineered Base Liner System Leak Detection — Monitoring (NCGS 130A
295.4(b) and NCAC 15A 13B .0602(e)(6))
Leak detection system monitoring is conducted on a routine basis as defined in the
Operations Plan. A LDS is incorporated into the design of the landfill and leachate
basin engineered base liner systems to monitor performance and to prevent a release to
the environment. LDS monitoring occurs in the vicinity of each landfill sump and leachate
basin sump, identified as MSS-LF-LDS1 through MSS-LF-LDS8 and MSS -LB -LDS on
Drawing 2.
The landfill, in accordance with NCGS 130A 295.4(b), and leachate basin in accordance
with NCAC 15A 13B .1680(e)(2) are constructed with a base liner system that includes a
primary and secondary geomembrane liner. The primary and secondary liners are
separated by a geocomposite drainage layer to create a leak detection layer. The
geocomposite provides enough capacity to convey liquid that enters the leak detection
layer to a sump area (lowest elevation in an area of the liner system) where it is
collected for removal by mechanical pumping. Removal of liquid from the leak detection
layer in addition to the combination of a geosynthetic clay liner (GCL) and compacted
soil liner beneath the secondary liner reduces the potential for liquid to enter the
environment. The quantity of liquid removed from the leak detection layer is measured
and recorded.
Details and calculations for the engineered base liner systems are included in the
Engineering and Facility Plan. The presence of liquid in a leak detection layer is typical
and anticipated from but not limited to:
• water remaining in the geonet or sump from initial construction;
• condensed liquid accumulated after installation of the overlying primary
geomembrane, and;
• flow through defects in the primary geomembrane.
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Industrial Landfill No. 1 1812-INDUS Revision 5, November 6, 2024
Environmental Controls Monitoring Plan
Design of the liner LDS includes defining the rate at which water entering the leak
detection layer is not typical under normal operations. The Engineering and Facility
Plan includes the method used to define an Initial Response Leakage Rate (IRLR) and
Action Leakage Rate (ALR) for the leak detection layer. The ALR represents the
maximum sustained flow rate that would be expected in the leak detection layer under
normal conditions. The IRLR is generally a fraction of the ALR and represents the initial
threshold where action would be required. The IRLR and ALR monitoring rates for the
landfill and leachate basin are provided below as defined in the Operations Plan.
IRLR
(gal/acre/day)
ALR
(gal/acre/day)
Phase 1 Cells 1-4
316
421
Phase 2 Cells 5-6
316
421
Phase 3 Cell 7
316
421
Phase 4 Cell 8
316
421
Leachate Basin
316
421
Note: Cells 1-4 and 5-6 are grouped for reporting purposes but all individual cells have
the same IRLR and ALR, which are based on a per acre basis.
A Response Action Plan for the landfill and leachate basin is included in the Operations
Plan Section 2.4.3 and the list of required actions if the IRLR or ALR is exceeded are
provided in the Operations Plan Section 2.4.4 to comply with NCGS 130A 295.4(c).
The purpose of the Response Action Plan and list of actions is to define the necessary
steps in the event liquid in the leak detection layer exceeds the IRLR and/or ALR. Leak
detection layer flow rates are monitored, recorded, and compared to the defined IRLR
and ALR.
2.1.2 Engineered Base Liner System Leak Detection - Reporting
Average monthly flow rates with comparison to leakage rates will be provided to DWM in
the semi-annual landfill Environmental Controls Monitoring Report. Information provided
in the report will consist of:
• a summary of average monthly flows from each LDS sump (Drawing 2), with
comparison to the IRLR and ALR, will be provided in tabular form for the semi-annual
reporting timeframe (through the month when sampling defined in this Plan occurs)
and;
• if exceedances of the IRLR and/or ALR are identified in the reporting timeframe, a
summary of actions in accordance with the Response Action Plan will be provided.
The summary will generally include:
o date of DWM notification
o cause of exceedance (if known or summary of evaluation efforts to date)
o corrective action implemented or planned (if applicable)
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2.2 Water Quality
2.2.1 Water Quality Monitoring
2. 2.1.1 Surface Water — Monitoring (NCAC 15A 13B . 0602)
Surface water quality monitoring is not required for Phases 1-4 of the landfill.
Surface water (non -contact stormwater) will be directed via channels around the
perimeter of the landfill to a NPDES wastewater unit or permitted Stormwater Outfall.
This Plan will be reviewed if the path of stormwater leaving the landfill area will be
altered or permit status for receiving unit(s) will change. DWM will be consulted to
determine if surface water quality monitoring requirements should be revised for
monitoring of stormwater leaving the landfill area.
2.2.1.2 Underdrain Outlet — Monitoring
Underdrain outlet water samples are collected and analyzed on a semi-annual basis
from sample locations designated as MSS-LF-UD1 and MSS-LF-UD2. MSS-LF-UD1 is
associated with the Phase 2 underdrain located in the upper southwest corner of Phase
2. MSS-LF-UD2 is associated with the Phase 3 and Phase 4 underdrain with an
underdrain outlet sample location in the southern extent of Phase 3. The underdrain
outlet sample locations are shown on Drawing 2.
Underdrain outlet water samples are analyzed for the constituents summarized on
Table 1.
2.2.2 Water Quality Reporting
2.2.2.1 Surface Water — Reporting
Surface water reporting is currently not required for the landfill (see Section 2.2.1). This
Plan will be revised to include the following general language in this section, as
applicable, if surface water monitoring becomes required in Section 2.2.1:
Surface water analytical results would be 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 would
be for information purposes only.
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Industrial Landfill No. 1 1812-INDUS Revision 5, November 6, 2024
Environmental Controls Monitoring Plan
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
(fag/L). Duke Energy will use the analytical method USEPA 245.1/SW 7470A for
mercury analysis, which has a reporting limit of 0.050 fag/L and is greater than the
02B criteria of 0.012 tag/L.
Surface water results would be provided to DWM in the semi-annual landfill
Environmental Controls Monitoring Report. Information provided in the report would
consist of:
• a copy of the laboratory report(s);
• a copy of the sampling log(s);
• a table of analytical results and field parameters that will include:
■ results reported in micrograms per liter (ug/L), except for field parameters;
■ laboratory method detection limits, and;
■ comparison to appropriate 02B Standards with exceedances shown in bold.
2.2.2.2 Underdrain Outlet — Reporting
Underdrain outlet analytical results will not be compared to any water quality standards
for flow that:
• outlets inside the boundary of a NPDES permitted wastewater unit and/or;
• passes through a NPDES permitted outfall before entering surface water.
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Industrial Landfill No. 1 1812-INDUS Revision 5, November 6, 2024
Environmental Controls Monitoring Plan
Underdrain outlet samples MSS-LF-UD1 and MSS-LF-UD2 are within the NPDES
permitted wastewater unit and passes through a NPDES permitted outfall downstream;
therefore, sample results from the underdrain outlet will not be compared to water quality
standards.
Underdrain outlet analytical results will be provided to DWM in the semi-annual landfill
Environmental Controls Monitoring Report. Information provided in the report will consist
of:
• a copy of the laboratory report(s);
• a copy of the sampling log(s);
• a table of analytical results and field parameters that will include:
o analytical results reported in micrograms per liter (pg/L), except as noted (for field
parameters), and;
o laboratory method detection limits.
• monitoring data documents, including, field sampling logs, field calibration forms,
COC records, laboratory reports, and data validation checklists.
2.3 Leachate
2.3.1 Leachate - Monitoring
Discrete leachate samples will be collected and analyzed on a semi-annual basis from
each landfill cell sump, MSS-LF-LCS1 through MSS-LF-LCS8, located in the vicinity of
each corresponding sump header.
One comprehensive leachate sample will also be collected and analyzed on a semi-
annual basis from the Leachate Basin. MSS-LF-LCSC1 is located inline from the
forcemain that runs from the Leachate Basin to the Lined Retention Basin (LRB) and is
representative of the Leachate Basin and contains the leachate contribution of each of
the cells.
Leachate sample locations are shown on Drawing 2.
Leachate will be analyzed for the constituents summarized on Table 1.
2.3.2 Leachate - Reporting
Leachate analytical results will not be compared to any water quality standards.
Leachate analytical results will be provided to DWM in the semi-annual landfill
Environmental Controls Monitoring Report. Information pertaining to leachate monitoring
provided in the report will consist of:
• a figure that includes relevant facility features and leachate sample locations
sampled as a part of this Plan;
• an Electronic Data Deliverable (EDD) spreadsheet in required DWM format for
leachate analysis data;
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Industrial Landfill No. 1 1812-INDUS Revision 5, November 6, 2024
Environmental Controls Monitoring Plan
• a table of analytical results and field parameters that will include:
o analytical results reported in units applicable to the method detection limits;
o laboratory method detection limits, and;
• monitoring data documents, including, field sampling logs, field calibration forms,
COC records, laboratory reports, and data validation checklists.
3.0 Sampling and Analysis
Leachate and underdrain samples will be collected and analyzed as described in this section.
3.1 Water Quality
3.1.1 Surface Water— Sampling and Analysis
Surface water sampling and analysis is currently not required for the landfill (see
Section 2.2.1).
This Section will be revised if surface water monitoring becomes required as defined in
Section 2.2.1.
3.1.2 Underdrain Outlet — Sampling and Analysis
Underdrain outlet samples will be collected semi-annually from MSS-LF-UD1 and
MSS-LF-UD2. The underdrain outlet sampling locations are defined in Section 2.2 of
this Plan. Constituents to be analyzed along with their respective analytical methods are
listed in Table 1.
3.2 Leachate — Sampling and Analysis
On a semi-annual basis, discrete leachate samples will be collected from each sump sampling
port (MSS-LF-LCS1 through MSS-LF-LCS8) and one comprehensive leachate samples
(MSS-LF-LCSC1 ) will be collected from the leachate basin. The leachate sampling locations
are defined in Section 2.3 of this Plan. Constituents to be analyzed along with their respective
analytical methods are listed in Table 1.
3.3 Field Collection Procedures
Sampling will be conducted at the locations defined in this Plan and in general conformance
with procedures provided in Appendix I.
3.4 Analytical Procedures
The main analytical laboratory used in this program is the Duke Energy Central Laboratory
Services: NC Wastewater (#248) Certification.
Vendor laboratories that meet EPA and NC certification requirements may be used for
analyses with approval by Duke Energy.
The analytical procedures used for this Plan are listed in Table 1. The laboratory must report
any detection of any constituent (as revised in the October 27, 2006, NCDEQ DWM
memorandum and February 23, 2007, addendum).
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Industrial Landfill No. 1 1812-INDUS Revision 5, November 6, 2024
Environmental Controls Monitoring Plan
The laboratory certificates -of -analyses will, at a minimum, include:
Narrative: The narrative will include a brief description of the sample group (number and
type of samples, field and associated lab sample identification numbers, preparation and
analytical methods used). The data reviewer will also include a statement that all holding
times and Quality Control (QC) criteria were met, samples were received intact and
properly preserved, with a brief discussion of any deviations potentially affecting data
usability. This includes but is not limited to: test method deviation(s), holding time
violations, out -of -control incidents occurring during the processing of QC or field samples
and corrective actions taken, and repeated analyses and reasons for the reanalysis
(including, for example, contamination, failing surrogate recoveries, matrix effects, or
dilutions). The narrative will be signed by the laboratory director or authorized laboratory
representative, signifying that all statements are true to the best of the reviewer's
knowledge, and that the data meet the data quality objectives as described in this Plan
(except as noted). One narrative is required for each sample group.
• Original Chain -of -Custody Form;
• The laboratory will list all analytes for which the samples were analyzed;
• Dilution factors with a narrative of the sample results, including the reasons for the dilution
(if any);
• Blank Data: If organic analyses is required, the laboratory will report the results of any
method blanks, reagent blanks, trip blanks, field blanks, and any other blanks associated
with the sample group. For inorganic analyses, the laboratory will provide the results of
any preparation or initial calibration blanks associated with the sample group, and;
• QC Summary: The laboratory will provide summary forms detailing laboratory QC sample
results, which include individual recoveries and relative percent differences (if appropriate)
for the following Quality Assurance (QA)/QC criteria: surrogates, matrix spike (MS)
analyses, matrix spike duplicate (MSD) analyses, laboratory control samples, and sample
duplicate analyses. QC control limits will also be reported; if any QC limits are exceeded, a
flag or footnote will be placed to indicate the affected samples.
Additional QA data and/or other pertinent data may be reported as requested.
3.5 Quality Assurance and Quality Control Program
Duke Energy laboratory QC checks used by vendor laboratories are described in each
laboratory's generic Quality Assurance Plan and procedures manual. Using the Duke Energy
laboratory QC checks, the vendor laboratories demonstrate the ability to produce acceptable
results using the methods specified.
QC checks used by the Duke Energy laboratory for sampling procedures and laboratory
analyses are conducted for each sampling event. These QC checks consist of the preparation
and submittal of field blanks, trip (travel) blanks, and/or field replicates for analysis of each of
the parameters at frequencies described in the laboratory(s) procedures manuals.
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Industrial Landfill No. 1 1812-INDUS Revision 5, November 6, 2024
Environmental Controls Monitoring Plan
The field QC blanks and replicates that may be included as QC checks are described below.
The specific type and number of blanks used as listed below may vary depending on the
sampling event and will be determined by the Duke Energy field sampling personnel:
Field Blanks: A field blank consists of a sample container filled in the field with organic -
free, deionized, or distilled water prepared and preserved in the same manner as the
samples. The field blank is transported to the laboratory with the samples and analyzed
along with the field samples for the constituents of interest to check for contamination
imparted to the samples by the sample container, preservative, or other exogenous
sources. Field blanks are typically utilized for each sampling event. The field blanks are
typically analyzed for major anions and cations and metals.
• Trip Blanks: If any samples are being analyzed for volatile organic compounds, a trip
blank is required. A trip blank is a sample container filled with organic -free water in the
laboratory that travels unopened with the sample bottles. The trip blank is returned to the
laboratory with the field samples and analyzed along with the field samples for parameters
of interest.
Field Replicates: A field replicate is a duplicate sample prepared at the sampling
locations from equal portions of the sample aliquots combined to make the sample. Both
the field replicate and the sample are collected at the same time, in the same container
type, preserved in the same way, and analyzed by the same laboratory as a measure of
sampling and analytical precision.
3.6 Validation of Field Data Package
The field data package includes the field records and measurements developed by the
sampling team personnel. The field data package validation will be performed by Duke Energy
personnel. The procedure for validation consists of the following:
• a review of field data contained on the Monitoring Data Sheets for completeness;
• verification that equipment blanks, field blanks, and trip blanks (if required) were properly
prepared, identified, and analyzed;
• a check of the Field Sampling Calibration Form for equipment calibration and instrument
conditions, and;
• a review of the COC Record for proper completion, signatures of field personnel and the
laboratory sample custodian, dates and times, and for verification that the correct analyses
were specified.
3.7 Validation of Laboratory Data
The laboratory will perform a validation review of the submitted samples and analytical results
to confirm that the laboratory QA/QC requirements are acceptable.
4.0 Environmental Controls Monitoring Reporting
4.1 Environmental Controls Monitoring Report Submittal
A semi-annual report of monitoring results for the landfill and leachate base liner LDS and
leachate will be submitted to DWM within 120 days following the date of sampling.
Page 10 of 11

Industrial Landfill No. 1 1812-INDUS Revision 5, November 6, 2024
Environmental Controls Monitoring Plan
The report will include, at a minimum:
• a completed NCDEQ Environmental Monitoring Report Form (Appendix II);
• a figure that includes relevant facility features and monitoring locations sampled as a part
of this Plan;
• engineered base liner leak detection system monitoring results for the landfill and leachate
basin;
• an Electronic Data Deliverable (EDD) spreadsheet in required DWM format for leachate
analysis data;
• a table of analytical results and field parameters, and;
• Monitoring data documents, including field sampling logs, field calibration forms, Chain -of -
Custody (COC) records, laboratory reports, and data validation checklists.
5.0 References
The references cited below were used in the preparation of this Plan and may or may not be referenced
within the text.
LeGrand Sr., Harry E. 2004. A Master Conceptual Model for Hydrogeological Site
Characterization in the Piedmont and Mountain Region of North Carolina, a Guidance
Manual.
Operating Procedure, Groundwater Sampling, US EPA Region IV Science and Ecosystem
Support Division, April 26, 2017.
North Carolina Dept. of Environment and Natural Resources, Division of Waste Management
Memorandum Regarding Groundwater, Surface Water, Soil, Sediment, and Landfill Gas
Electronic Document Submittal, dated November 5, 2014.
North Carolina Dept. of Environment, Health, and Natural Resources. 1995. N.C. Water Quality
Monitoring Guidance Document for Solid Waste Facilities.
North Carolina Dept. of Environment and Natural Resources. 2006. N.C. New Guidelines for
Electronic Submittal of Environmental Monitoring Data.
North Carolina Dept. of Environment and Natural Resources. 2007. N.C. Addendum to October
27, 2006, North Carolina Solid Waste Section Memorandum Regarding New Guidelines
for Electronic Submittal of Environmental Monitoring Data.
North Carolina Dept. of Environmental Quality. 2020. Environmental Monitoring — Field
Measurements and Sampling Procedures. [online] Available at:
htti)s:Hdeg.nc.gov/about/divisions/waste-management/waste-management-i)ermit-
guidance/solid-waste-section/environmental-monitoring
S&ME. 2018. Operations Plan — Revision 6 Duke Energy Carolinas, LLC- Marshall Steam
Station Industrial Landfill No. 1— Phase 1 Permit No. 1812 Catawba County, Terrell,
North Carolina.
Page 11 of 11

Industrial Landfill No. 1 1812-INDUS Revision 5, November 6, 2024
Environmental Controls Monitoring Plan
Tables

TABLE 1
SUMMARY OF CONSTITUENTS AND ANALYTICAL METHODS
ENVIRONMENTAL CONTROLS MONITORING PLAN
INDUSTRIAL LANDFILL NO. 1 (1812-INDUS)
MARSHALL STEAM STATION
DUKE ENERGY CAROLINAS, LLC, TERRELL, NC
Constituent
Units
Analytical Methods
In Situ Parameters
Field pH
S.U.
Multi -Parameter Water Quality Meter
Field Specific Conductance
µ0/cm
Multi -Parameter Water Quality Meter
Field Temperature
degrees Celsius
Multi -Parameter Water Quality Meter
Field Dissolved Oxygen
mg/L
Multi -Parameter Water Quality Meter
Field Oxidation Reduction Potential
mV
Multi -Parameter Water Quality Meter
Field Turbidity
NTU
Turbidimeter
Water Level
feet
Water Level Meter
Laboratory Analyses
Antimony
µg/L
EPA 200.8 / SW 6020B
Arsenic
µg/L
EPA 200.8 / SW 6020E
Barium
µg/L
EPA 200.7 / SW 6010D
Beryllium
µg/L
EPA 200.8 / SW 6020B
Beryllium (dissolved)*
µg/L
EPA 200.8 / SW 6020E
Boron
µg/L
EPA 200.7 / SW 6010D
Cadmium
µg/L
EPA 200.8 / SW 6020E
Cadmium (dissolved)*
µg/L
EPA 200.8 / SW 6020E
Calcium
mg/L
EPA 200.7 / SW 6010D
Chloride
mg/L
EPA 300.0 / EPA 9056A
Chromium
µg/L
EPA 200.8 / SW 6020E
Chromium (dissolved)*
µg/L
EPA 200.8 / SW 6020E
Cobalt
µg/L
EPA 200.8 / SW 6020E
Copper
µg/L
EPA 200.8 / SW 6020B
Copper (dissolved)*
µg/L
EPA 200.8 / SW 6020E
Fluoride
mg/L
EPA 300.0 / EPA 9056A
Iron
µg/L
EPA 200.7 / SW 6010D
Lead
µg/L
EPA 200.8 / SW 6020B
Lead (dissolved)*
µg/L
EPA 200.8 / SW 6020E
Lithium
µg/L
EPA 200.7 / SW 6010D
Magnesium
mg/L
EPA 200.7 / SW 6010D
Manganese
µg/L
EPA 200.7 / SW 6010D
Mercury
µg/L
EPA 245.1 / SW 7470A
Molybdenum
µg/L
EPA 200.8 / SW 6020B
Nickel
µg/L
EPA 200.8 / SW 6020E
Nickel (dissolved)*
µg/L
EPA 200.8 / SW 6020B
Nitrate
mg/L
EPA 300.0 / EPA 9056A
Selenium
µg/L
EPA 200.8 / SW 6020E
Selenium (dissolved)*
µg/L
EPA 200.8 / SW 6020E
Silver
µg/L
EPA 200.8 or SW 6020A
Silver (dissolved)*
µg/L
EPA 200.8 or SW 6020A
Page 1 of 2

TABLE 1
SUMMARY OF CONSTITUENTS AND ANALYTICAL METHODS
ENVIRONMENTAL CONTROLS MONITORING PLAN
INDUSTRIAL LANDFILL NO. 1 (1812-INDUS)
MARSHALL STEAM STATION
DUKE ENERGY CAROLINAS, LLC, TERRELL, NC
Constituent
Units
Analytical Methods
Laboratory Analyses (Continued)
Sulfate
mg/L
EPA 300.0 / EPA 9056A
Thallium
µg/L
EPA 200.8 / SW 6020E
Total Dissolved Solids
mg/L
SM 2540C / EPA 160.1 / ASTM D5907
Total Hardness
mg/L
Calculation (2.497 (calcium) + 4.118 (magnesium))
Vanadium
µg/L
EPA 200.8 / SW 6020E
Zinc
µg/L
EPA 200.7 / SW 6010D
Zinc (dissolved)*
µg/L
EPA 200.7 / SW 6010D
Prepared by: GTC Checked by: DAA
Note:
* Dissolved analysis only applicable for samples collected from surface water and/or underdrain outlets as it pertains to a receiving water body with
water quality standards applicable to Surface Waters and Wetlands of North Carolina as defined in Title 15A NCAC 02B.
Acronym List:
µg/L - micrograms per liter
µQ/cm - micro -ohms per centimeter
mg/L - milligrams per liter
my - millivolts
S.U. - standard units
NTU - nephelometric turbidity units
Page 2 of 2

Industrial Landfill No. 1 1812-INDUS Revision 5, November 6, 2024
Environmental Controls Monitoring Plan
Drawings

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2.2019 USGS TOPOGRAPHIC MAP, TROUTMAN &
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SEMIANNUAL REPORT
INDUSTRIAL LANDFILL NO. 1
MARSHALL STEAM STATION
TERRELL, NORTH CAROLINA
DRAWN BY C. WYATT DATE_ 09/09/2020
REVISED BY: T. KING DATE: 10/25/2024 1000 0 GRAPHIC SCALE 2000
CHECKED BY T COLTON DATE_ 10/25/2024
APPROVED BY COLTON DATE_ 10/25/2024 (IN FEET)
PROJECT MANAGER: T. COLTON

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