3620_DukeAllenSSLF_ECMP Rev2_FID2049747_20250523

(> DUKE
ENEnNr'**%I%.7.
May 23, 2025
North Carolina Department of Environmental Quality (NCDEQ)
Division of Waste Management (DWM)
Solid Waste Section (the Section)
2090 U.S. 70 Highway
Swannanoa, NC 28778-8211
Attn: Ms. Sarah Moutos
Re: Environmental Controls Monitoring Plan (ECMP) Revision 2
Reference: South Starter Landfill (SSLF) Permit No. 3620-INDUS
Allen Steam Station
Gaston County
Dear Ms. Moutos,
525 S. Tryon Street
DEC-36A
Charlotte, NC 28202
An updated Environmental Control Monitoring Plan (ECMP; Revision 2) for the South Starter Landfill
(SSLF) (3620-INDUS), located in Gaston County, North Carolina, is enclosed for review and approval. This
ECMP is proposed to supersede the previously approved ECMP Revision 1 dated March 26, 2021.
ECMP Revision 2 has been updated primarily to incorporate the following items:
• Construction drain sampling locations (ALN-SSLF-CD1A and ALN-SSLF-CD1B);
• Revised leachate force main alignment; and
• Revised constituents and analytical methods in accordance with harmonized list approved by
the Section in a letter dated March 20, 2023.
Other minor revisions to this ECMP include updated aerial photography, and water level contours and
well locations on Drawing 3.
Please contact me at Courtney. [e-mail] or [phone] if you have any questions
or need additional information regarding this submittal.
Respectfully,
,I I
Courtney W. Murphy, P.G.
Environmental Services
Page 1 of 2

Enclosure (1): Environmental Controls Monitoring Plan, Allen Steam Station, South Starter Landfill
(3620-INDUS), Revision 2, (SynTerra, May 23, 2025)
Cc: Jordan Russ — NCDEQ
Sherri Stanley— NCDEQ
Elizabeth Werner - NCDEQ
Ed Sullivan — Duke Energy
Tyler Hardin — Duke Energy
Kim Witt — Duke Energy
Preston McCloud — Duke Energy
Ben Dawkins — Duke Energy
Sheila Westcott — Duke Energy
Dee O'Brien — Duke Energy
Chris Suttell — SynTerra
Page 2 of 2

Environmental Controls Monitoring Plan
Allen Steam Station
South Starter Landfill
(3620-INDUS)
Gaston County, North Carolina
PREPARED FOR:
Duke Energy Carolinas, LLC
f' DUKE
ENERGY
PREPARED BY:
SynTerra Corporation
148 River Street, Suite 220
Greenville, South Carolina 29601
Revision 2
May 23, 2025
rcl
Brooke Patton
Project Scientist
Project Manager

South Starter Landfill (3620-INDUS)
Environmental Controls Monitoring Plan
Revision 2, May 23, 2025
Revision History
Revision
Company
Date of Revision
DescriptionRevision
0
Duke Energy
11/09/2020
Initial Release
Incorporated additional NCDEQ DWM comments.
Relocated surface water sample location closer to
landfill.
1
Duke Energy
03/26/2021
Updated leachate force main piping and added
NPDES Outfall 006 to Drawing 2.
Revised constituents and analytical methods in
Table 1 in order to make comparisons to 02B
standards.
Revised constituents and analytical methods in
Table 1 in accordance with the harmonized
constituent list approved by NCDEQ DWM on March
20, 2023.
Revised depiction and description of leachate force
2
Duke Energy
05/23/2025
main piping, construction drain, construction drain
discharge pipes, and construction drain sampling
locations (ALN-SSLF-CD 1 A and ALN-SSLF-CD1B)
into the text and Drawing 2, as appropriate.
Newly installed monitoring wells CCR-28S through
CCR-32S were added to Drawing 3.
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South Starter Landfill (3620-INDUS)
Environmental Controls Monitoring Plan
Revision 2, May 23, 2025
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.................................................................................. 3
2.1.1 Engineered Base Liner System Leak Detection — Monitoring (NCGS 130A 295.4(b) and
NCAC 15A 13B .0602(e)(6))........................................................................................................... 3
2.1,2 Engineered Base Liner System Leak Detection — Reporting.......................................................... 4
2.2 Water Quality........................................................................................................................................ 4
2.2.1 Water Quality Monitoring................................................................................................................. 4
2.2.2 Water Quality Reporting.................................................................................................................. 5
2.3 Leachate.............................................................................................................................................7
2.3.1 Leachate — Monitoring..................................................................................................................... 7
2.3.2 Leachate — Reporting...................................................................................................................... 7
3.0 Sampling and Analysis................................................................................................................ 7
3.1 Water Quality........................................................................................................................................ 7
3.1.1 Surface Water Sampling and Analysis......................................................................................... 7
3.1.2 Construction Drain 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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South Starter Landfill (3620-INDUS) Revision 2, May 23, 2025
Environmental Controls Monitoring Plan
List of Tables
Table 1 Summary of Constituents and Analytical Methods
List of Drawings
Drawing 1 Site Location Map
Drawing 2 Monitoring Locations
Drawing 3 Direct Measurement Potentiometric Surface Uppermost Aquifer — February 2025
List of Appendices
Appendix I — Sample Collection Guidelines
Appendix II — NCDEQ Environmental Monitoring Report Form
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South Starter Landfill (3620-INDUS) Revision 2, May 23, 2025
Environmental Controls Monitoring Plan
1.0 Introduction
This Environmental Controls Monitoring Plan (ECMP) for the Duke Energy Allen Steam Station (Allen,
Station, or Site) establishes locations and procedures for monitoring early detection of solid waste or
leachate potentially released from the South Starter Landfill (SSLF or landfill).
The landfill is situated partially within the Active Ash Basin (AAB) 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(1)(g)(iv) [proposed .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 U.S. Environmental Protection Agency (USEPA)
Title 40 Code of Federal Regulations (CFR) Part 257 Subpart D (CCR Rule), is in accordance with 40
CFR § 257.91(d), which states "the owner of 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 that also includes the AAB, Retired Ash Basin (RAB), and
RAB Ash Landfill.
This SSLF ECMP is intended to satisfy the requirements of a groundwater monitoring system required
by NCAC 15A 13B .1680(e)(6), which states in part that "an alternative monitoring system approved by
the Division" can be used to satisfy the monitoring requirements.
Prior to completion of landfill closure, this ECMP will be evaluated and the North Carolina Department
of Environmental Quality (NCDEQ) Division of Waste Management (DWM) will be consulted to
determine whether this ECMP should be revised for post -closure monitoring of landfill performance.
1.1 Site Description
Allen was a coal-fired electricity -generating facility owned and operated by Duke Energy. The
Station and supporting facilities (approximately 1,000 acres) are on the west bank of the
Catawba River (Lake Wylie). The Site setting, topography, and nearby surface water features
are depicted on Drawing 1. Allen began operation as a coal-fired electricity -generating station
in 1957. The Station retired three of its five units in 2021. The remaining two units at Allen
were retired by the end of 2024. The Station is now fully retired, and Station decommissioning
activities are underway.
The approximately 22-acre landfill is located partially within the southeastern portion of the
AAB and the area between the AAB and the southern extent of the Allen property
(Drawing 1). The SSLF is bound by the AAB to the north, upland areas to the south and west,
and lowland areas and the Catawba River (Lake Wylie) to the east (Drawing 2).
Leachate is conveyed from the landfill to the Leachate Basin via a force main piping network.
The approximately 3-acre Leachate Basin is located within the northwestern portion of the
AAB and bounded by the RAB to the north, AAB to the east and south, and upland areas to
the west (Drawing 2). The Leachate Basin is designed and constructed in accordance with
NCAC 15A 13B .1680. The Leachate Basin ties into an existing 36-inch wastewater force main
where it is comingled with Plant wastewater and subsequently sent to the Lined Retention
Basin (LRB) for treatment. Flows from the LRB are discharged to the Catawba River (Lake
Wylie) through Outfall 006 in accordance with National Pollutant Discharge Elimination Permit
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South Starter Landfill (3620-INDUS)
Environmental Controls Monitoring Plan
Revision 2, May 23, 2025
(NPDES) Permit NC0004979 (Drawing 2). The landfill and Leachate Basin engineered base
liner are designed with a leak detection system (LDS) for monitoring the integrity of the liner
system.
The RAB received CCR via sluice lines from 1957 until 1973. In 1973, the AAB was
constructed and placed into operation. The AAB, which partially underlies the landfill, received
CCR via sluice lines beginning in 1973. In 2008, the facility converted from a wet fly ash
handling system to a dry fly ash handling system. Since 2008, fly ash has been disposed of in
the on -Site RAB Ash Landfill. The AAB ceased receipt of fly ash in 2008 and ceased receipt of
bottom ash in 2019. Sluicing of bottom ash to the AAB continued until early 2019 when the
facility converted to a dry bottom ash collection system. CCR is no longer generated at the
Site since the Station was retired in 2024.
The ash basins have contributed CCR-related constituents to groundwater at the Site.
Because the SSLF is situated partially over an area of known effects from historical ash basin
operations, potential influence from the SSLF is indistinguishable from existing CCR effects in
groundwater.
Groundwater from beneath and in the vicinity of the ash basins is sampled and analyzed
according to the NCDEQ-approved monitoring plan, which meets the requirements of the Coal
Ash Management Act of 2014 (CAMA).
Groundwater associated with the SSLF and CCR Multiunit 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 because of
construction or ash basin closure activities. Groundwater is sampled and analyzed
semiannually 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 (AECOM, 2025).
1.2 Site Geology and Hydrogeology
The groundwater system in the natural materials at Allen 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, the deep (transition zone) flow
zone, and the bedrock flow zone.
The ash basins, distribution of residual solids (DORS) fills, RAB Ash Landfill, North Starter
Landfill (NSLF), SSLF, and Leachate Basin are contained within former perennial stream
valleys (flow compartment) (Drawing 1). Groundwater within the flow compartment is a flow -
through system. Groundwater enters the system from the upgradient end west of the AAB and
flows laterally through the central portion of the system and downward near the dam, or
downgradient end. A groundwater divide is located primarily west of the Site and roughly
follows topography along South Point Road and topographic highs north of the RAB along
Plant Allen Road to the Discharge Canal, and south of the AAB near Reese Wilson Road. The
topographically controlled flow direction provides natural hydraulic control of constituent
migration from the ash basins and adjacent sources within the flow compartment.
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South Starter Landfill (3620-INDUS)
Environmental Controls Monitoring Plan
Revision 2, May 23, 2025
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 SSLF as well as the Leachate Basin, NSLF, AAB, RAB, and RAB Ash
Landfill is provided as Drawing 3. The primary flow path of the groundwater remains generally
west to east within the flow compartment. This recent potentiometric surface should not be
used to estimate future groundwater conditions because ash basin closure by excavation has
the potential to alter groundwater elevation and flow.
2.0 Monitoring Network
Performance of the SSLF 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) and surface
water monitoring. Groundwater downgradient of the SSLF is monitored in accordance with CAMA and
the CCR Rule groundwater monitoring programs and therefore is not addressed in this ECMP. Leachate
is sampled from the leachate collection system to provide analytical data to assist in evaluating
concentrations against water quality criteria or Response Action Plan requirements and determine
whether the SSLF performance is a contributor of constituents in the environment. Performance of the
NSLF and Leachate Basin is monitored in accordance with the current ECMP for the NSLF.
2.1 Engineered Base Liner System Leak Detection
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 (AECOM, 2025). An LDS is incorporated into the design of the SSLF
engineered base liner systems to monitor performance to prevent a release to the
environment. LDS monitoring occurs in the vicinity of the landfill sump identified as ALN-
SSLF-LDS1 on Drawing 2.
The landfill, in accordance with NCGS § 130A 295.4(b), is 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.
The landfill is designed for leachate to flow to one sump. Details and calculations for the
engineered base liner systems are included in the Engineering and Facility Plan
(AECOM, 2021). 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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South Starter Landfill (3620-INDUS)
Environmental Controls Monitoring Plan
Revision 2, May 23, 2025
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
(AECOM, 2021) 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 SSLF are provided below, as defined in the Operations Plan (AECOM, 2025):
IRLR (gal/acre/day) ALR (gal/acre/day)
Landfill Phases 316 421
A Response Action Plan for the landfill is included in Section 2.4.3 of the Operations
Plan (AECOM, 2025), and the list of required actions if the IRLR or ALR is exceeded is
provided in Section 2.4.4 of the Operations Plan 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 the amount of liquid in the leak detection layer is greater than 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 the
NCDEQ DWM in the semiannual landfill Environmental Controls Monitoring Report.
Information provided in the report will include:
• 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
semiannual reporting time frame (through the month when sampling defined in
this ECMP occurs)
• If leakage rates greater than the IRLR and/or ALR are identified in the reporting
time frame, a summary of actions in accordance with the Response Action Plan
will be provided. The summary will generally include:
o The date of NCDEQ DWM notification
o Cause of leakage rate greater than IRLR or ALR (if known or summary of
evaluation efforts to date)
o Corrective action implemented or planned (if applicable)
2.2 Water Quality
2.2.1 Water Quality Monitoring
2.2.1.1 Surface Water - Monitoring (NCAC 15A 13B .0602)
Surface water samples are collected and analyzed on a semiannual basis from
the sample location designated as ALN-SSLF-SW1. The surface water sample
location is shown on Drawing 2.
Surface water samples are analyzed for the surface water constituents
summarized in Table 1.
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South Starter Landfill (3620-INDUS) Revision 2, May 23, 2025
Environmental Controls Monitoring Plan
Surface Water Upgradient of Facility
No surface water streams are upgradient of the landfill. An intermittent stream
originates immediately downgradient of the SSLF disposal area, as delineated by
McKim & Creed in 2017. To determine background concentrations and assist in
evaluating potential surface water concentrations greater than water quality
criteria downgradient of the facility, historical surface water data from the same
stream will be used. The historical concentrations will be compared to present
day concentrations to determine whether the landfill and/or operation is a
contributor to constituents in surface water.
Surface Water Downgradient of Facility
Surface water is sampled at one location (ALN-SSLF-SW1) down and side -
gradient of the landfill within the feature currently shown as an intermittent stream
south of the SSLF (Drawing 2). The permitting process has been initiated for an
Individual Permit (IP) from the U.S. Army Corp of Engineers, and an IP will be
obtained prior to SSLF construction to allow jurisdiction intermittent stream
impacts in the vicinity of the SSLF. The SSLF surface water sample, ALN-SSLF-
SW1, will be collected in the portion of the stream to be covered in the future IP,
prior to flow entering jurisdictional waters.
2.2.1.2 Construction Drain Outlet — Monitoring
One construction drain outlet water sample will be collected and analyzed on a
semiannual basis at one of two sampling locations shown on Drawing 2 and
described below.
Sample location ALN-SSLF-CD1A is at the terminus of a discharge pipe leading
to the East Sediment Basin. ALN-SSLF-CD1A will be the temporary sample
location for the construction drain until conveyance piping is completed from the
wet well structure to the on -Site wastewater treatment system (WWTS). At the
time of this ECMP revision (Revision 2), flows to East Sediment Basin are
pumped to the AAB where they are then routed to the on -Site WWTS.
Sample location ALN-SSLF-CD1 B will be at a wet well structure adjacent to the
SSLF. This location will be used after construction drain discharge to the East
Sediment Basin is terminated (anticipated to occur in late 2025). At that time, the
discharge pipe from the SSLF construction drain will no longer convey flow to the
East Sediment Basin, and therefore, future construction drain discharge samples
will be collected from ALN-SSLF-CD1 B.
Construction drain water samples will be analyzed for the surface water
constituents summarized in Table 1.
2.2.2 Water Quality Reporting
2.2.2.1 Surface Water — Reporting
Surface water analytical results will be compared to respective Classifications
and Water Quality Standards Applicable to Surface Waters and Wetlands of
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South Starter Landfill (3620-INDUS)
Environmental Controls Monitoring Plan
Revision 2, May 23, 2025
North Carolina as defined in 15A NCAC 02B .0200 (02B standards) for
parameters summarized in Table 1.
Surface water results will be provided to the NCDEQ DWM in the semiannual
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 Results reported in micrograms per liter (fag/L), except for field
parameters
o Laboratory method detection limits
o Comparison to appropriate 02B standards with concentrations
greater than 02B standards shown in bold
2.2.2.2 Construction Drain Outlet — Reporting
Construction drain outlet analytical results will not be compared to water quality
standards for flow that:
• Outlets inside the boundary of a NPDES-permitted wastewater unit
• Passes through an NPDES-permitted outfall before entering surface
water.
Construction drain outlet samples ALN-SSLF-CD1A and ALN-SSLF-CD1B are
within an NPDES-permitted wastewater unit and pass through an NPDES-
permitted outfall downstream; therefore, sample results from the construction
drain outlet will not be compared to water quality standards.
Construction drain outlet analytical results will be provided to NCDEQ DWM in
the semiannual 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 fag/L, except for
field parameters
o Laboratory method detection limits, and if applicable:
■ Appropriate 02B standards
■ Concentrations greater than 02B standards shown in bold
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South Starter Landfill (3620-INDUS)
Environmental Controls Monitoring Plan
Revision 2, May 23, 2025
2.3 Leachate
2.3.1 Leachate — Monitoring
Discrete leachate samples will be collected and analyzed on a semiannual basis from a
sump within the SSLF, ALN-SSLF-LCS1, located in the vicinity of the corresponding
sump header. Leachate from the SSLF is routed via a force main to the Leachate Basin,
as shown on Drawing 2. A comprehensive leachate sample from the Leachate Basin is
collected and analyzed on a semiannual basis in accordance with the current NCDEQ-
approved North Starter Landfill ECMP. Leachate sample locations are shown on
Drawing 2.
Leachate will be analyzed for the constituents summarized in Table 1.
2.3.2 Leachate — Reporting
Leachate analytical results will not be compared to water quality standards.
Leachate analytical results for the SSLF will be provided to the NCDEQ DWM in the
semiannual 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 figure that includes leachate sampling locations
• A table of analytical results and field parameters that will include:
o Analytical results reported in units applicable to the method detection
limits or regulatory standards, and laboratory method detection limits.
o If a leachate sample is unable to be obtained from the sampling locations
defined in Section 2.3 of this ECMP, that location will have a note
indicating the reason a sample was unable to be obtained.
Results of the comprehensive leachate sample collected from the Leachate Basin are
included with the NSLF ECMP reporting.
3.0 Sampling and Analysis
Surface water, construction drain outlet flow, and leachate 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 samples will be collected semiannually from one location (ALN-SSLF-
SW1). The surface water sampling location is defined in Section 2.2 of this ECMP.
Constituents to be analyzed along with their respective analytical methods are listed in
Table 1.
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South Starter Landfill (3620-INDUS) Revision 2, May 23, 2025
Environmental Controls Monitoring Plan
3.1.2 Construction Drain Outlet — Sampling and Analysis
One construction drain outlet water sample will be collected and analyzed on a
semiannual basis at one of two sampling locations shown on Drawing 2, as described in
Section 2.2.1.2. Constituents to be analyzed along with their respective analytical
methods are listed in Table 1.
3.2 Leachate — Sampling and Analysis
Landfill leachate samples will be collected semiannually from the sump sampling port (ALN-
SSLF-LCS1). The leachate sampling location is defined in Section 2.3 of this ECMP.
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 ECMP 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 USEPA and North Carolina certification requirements may be
used for analyses with approval by Duke Energy.
The analytical procedures used for this ECMP are listed in Table 1. The laboratory must report
detections of constituents (as revised in the October 27, 2006, NCDEQ Division memorandum
and February 23, 2007, addendum).
The laboratory certificates of analysis 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 holding times and quality control (QC) criteria were met and that
samples were received intact and properly preserved, with a brief discussion of
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 the
statements are true to the best of the reviewer's knowledge, and that the data meet the
data quality objectives as described in this ECMP (except as noted). One narrative is
required for each sample group.
• Original Chain -of -Custody Form.
• Analytes for which the samples were analyzed.
• Dilution factors with a narrative of the sample results, including the reasons for the
dilution (if any).
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South Starter Landfill (3620-INDUS)
Environmental Controls Monitoring Plan
Revision 2, May 23, 2025
• Blank data: If organic analyses are required, the laboratory will report the results of
method blanks, reagent blanks, trip blanks, field blanks, and other blanks associated
with the sample group. For inorganic analyses, the laboratory will provide the results of
preparation or initial calibration blanks associated with the sample group.
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 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.
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 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.
Page 9 of 11

South Starter Landfill (3620-INDUS) Revision 2, May 23, 2025
Environmental Controls Monitoring Plan
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
• 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 semiannual report of monitoring results for the landfill base liner LDS, water quality, and
leachate will be submitted to the NCDEQ DWM within 120 days following the date of sampling.
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 ECMP
• Engineered base liner leak detection system monitoring results for the landfill
• Sampling and analysis data, including:
o Monitoring data sheets
o Field calibration forms
o COC records
o Laboratory QA data
o Data validation checklists.
• An electronic data deliverable (EDD) spreadsheet in required NCDEQ DWM format for
analysis data
Page 10 of 11

South Starter Landfill (3620-INDUS)
Environmental Controls Monitoring Plan
Revision 2, May 23, 2025
5.0 References
The references cited below were used in the preparation of this ECMP and may or may not be
referenced within the text.
AECOM. (2021). Engineering and Facility Plan, Revision 1 — Duke Energy Carolinas, LLC.,
Allen Steam Station — South Starter Landfill, Permit No. 3620-INDUS. March 26, 2021.
AECOM. (2025). Operations Plan, Revision 1 — Duke Energy Carolinas, LLC., Allen Steam
Station — South Starter Landfill, Permit No. 3620-INDUS. May 16, 2025.
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.
North Carolina Department of Environment, Health, and Natural Resources. (1995). N.C.
Water Quality Monitoring Guidance Document for Solid Waste Facilities.
North Carolina Department of Environment and Natural Resources. (2006). N.C. New
Guidelines for Electronic Submittal of Environmental Monitoring Data.
North Carolina Department 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 Department of Environmental Quality. (2020). Environmental Monitoring — Field
Measurements and Sampling Procedures. [online] Available at:
https://deg.nc.gov/about/divisions/waste-management/waste-management-
Dermitauidance/solid-waste-section/environmental-monitorina.
North Carolina Department of Environment and Natural Resources, Division of Waste
Management. (2014). Memorandum Regarding Groundwater, Surface Water, Soil,
Sediment, and Landfill Gas Electronic Document Submittal, dated November 5, 2014.
USEPA. (2017). Operating Procedure, Groundwater Sampling, US EPA Region IV Science
and Ecosystem Support Division, April 26, 2017.
Page 11 of 11

South Starter Landfill (3620-INDUS)
Environmental Controls Monitoring Plan
Revision 2, May 23, 2025
Table

TABLE 1
SUMMARY OF CONSTITUENTS AND ANALYTICAL METHODS
ENVIRONMENTAL CONTROLS MONITORING PLAN
SOUTH STARTER LANDFILLLL (3620-INDUS)
ALLEN STEAM STATION
DUKE ENERGY CAROLINAS, LLC, GASTON COUNTY, NORTH CAROLINA
Constituent
Analytical Method
In Situ Parameters
pH
Water Quality Meter
Temperature
Water Quality Meter
Specific Conductance
Water Quality Meter
Dissolved Oxygen
Water Quality Meter
Oxidation Reduction Potential
Water Quality Meter
Turbidity
Water Quality Meter
Laboratory Analyses
Antimony
EPA 200.8 / SW 6020B
Arsenic
EPA 200.8 / SW 6020B
Barium
EPA 200.7 / SW 6010D
Beryllium
EPA 200.8 / SW 6020B
Beryllium (dissolved)*
EPA 200.8 / SW 6020B
Boron
EPA 200.7 / SW 6010D
Cadmium
EPA 200.8 / SW 6020B
Cadmium (dissolved)*
EPA 200.8 / SW 6020B
Calcium
EPA 200.7 / SW 6010D
Chloride
EPA 300.0 / EPA 9056A
Chromium
EPA 200.8 / SW 6020B
Chromium (dissolved)*
EPA 200.8 / SW 6020B
Cobalt
EPA 200.8 / SW 6020B
Copper
EPA 200.8 / SW 6020B
Copper (dissolved)*
EPA 200.8 / SW 6020B
Fluoride
EPA 300.0 / EPA 9056A
Iron
EPA 200.7 / SW 6010D
Lead
EPA 200.8 / SW 6020B
Lead (dissolved)*
EPA 200.8 / SW 6020B
Lithium
EPA 200.7 / SW 6010D
Magnesium
EPA 200.7 / SW 6010D
Manganese
EPA 200.7 / SW 6010D
Mercury
EPA 245.1 / SW 7470A
Molybdenum
EPA 200.8 / SW 6020B
Nickel
EPA 200.8 / SW 6020B
Nickel (dissolved)*
EPA 200.8 / SW 6020B
Nitrate
EPA 300.0 / EPA 9056A
Selenium
EPA 200.8 / SW 6020B
Silver
EPA 200.8 or 6020A
Silver (dissolved)*
EPA 200.8 or 6020A
Sulfate
EPA 300.0 / EPA 9056A
Total Dissolved Solids (TDS)
SM 2540C / EPA 160.1 / ASTM D5907
Total Hardness*
EPA 200.7 / SW 6010D
Thallium
EPA 200.8 / SW 6020B
Vanadium
EPA 200.8 / SW 6020B
Zinc
EPA 200.7 / SW 6010D
Zinc (dissolved)*
EPA 200.7 / SW 6010D
Prepared by: LWD Checked by: SDG
Revised by: CJS
Notes:
* Analysis only applicable for samples collected from surface water and/or construction drain 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 Subchapter 02B.
Page 1 of 1

South Starter Landfill (3620-INDUS)
Environmental Controls Monitoring Plan
Revision 2, May 23, 2025
Drawings

Cy - N
FOY�51 DR I�2 - A9frrrti '
FAO Z
� : RES I
°pT • p
LINED RETENTION BASIN , y■ w1`r1e c = d!
y!
DUKE ENERGY CAROLINAS ' m
PROPERTY BOUNDARY w
GYPSUM PADt
■
L
"00,e.
COVE •' - �ALLEN STEAM STATION
■ �� � o11 Tp
DISCHARGE g'
CANAL ANT pLLfN a� f C :�
rr _ COAL PILE AREA
� Z
■ M ,
i �■ � c rr ■ 1
+�, ►-�. NORTH STARTER RETIRED ASH BASIN
LANDFILL
c�
j� 3619-INDUS Jr RETIRED ASH BASIN
+ L� ASH LANDFILL
•i = N 3612-INDUS
. �' w ■
RETIRED ASH BASIN V
WASTE BOUNDARY 111
■
o�ER ARHS LEACHATE RARM + �.. �.... ■
o 'P L BASIN
bac o �4� a • ACTIVE ASH BASIN
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SYawe �m a
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e 'po �eK
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NOTES:
1- BOUNDARIES ARE AP PROXI MATE-
' v
2. WATER FEATURES DEPICTED WITHIN WASTE BOUNDARIES OF THE ASH BASINS ON
THE USGS TOPOGRAPHIC MAP DO NOT REPRESENT CURRENT CONDITIONS. THE
CONDITIONS DEPICTED ARE SIMILAR TO THOSE SHOWN ON THE 1968AND 1973 USGS -
TOPOGRAPHIC MAPS OF THE AREA [(1968 WEST CHARLOTTE t124ODD) AND 1973 '
BELMONT [124000]]-
3- USGS TOPOGRAPHIC MAP OBTAINED FROM ESRI, LAST U P DATED APRI L 2024.
P'
�' DUKE DOCATI }G i
■fir �/ SITE LOCATION MAP
ENERG 1 ww5ro sa+ v ENVIRONMENTAL CONTROLS MONITORING PLAN REV IMN2
CAROLINA- SOUTH STARTER LANDFILL (362D-INDUS)
AS VN E ALLEN STEAM STATION
GASTON COUNTY, NORTH CAROLINA
L� CHARLOT L
GASTON DRAWN BY: 7-KING DATE 12/06/24724 0RApHIC SCALE
COUNTY REVISED BY: B. PATTON DATE: 0!"28/2025 py ❑ spy �❑❑❑
synTerm APC. SUrTELL DATE: 05/23/2025
APPROVED RY: C. SUTTELL DATE: 05/23/2025 [IH P£Cfl
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a
-
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'k.
0 CONSTRUCTION DRAIN OUTLET SAMPLING LOCATION
■ LEACHATE DETECTION SYSTEM MONITORING
D LEACHATE SAMPLING LOCATION
■ SURFACE WATER SAMPLING LOCATION
■'
❑ NPDES OUTFALL
❑ CONSTRUCTION DRAIN WET WELL
CONSTRUCTION DRAIN
LEACHATE FORCEMAIN
— - — • CURRENT TEMPORARY LEACHATE FORCEMAIN
'
LEACHATE BASIN
NORTH STARTER LANDFILL BOUNDARY
SOUTH STARTER LANDFILL BOUNDARY
p SITE FEATURES
.-
G ACTIVE ASH BASIN WASTE BOUNDARY
r- � RETIREDASH BASIN WASTE BOUNDARY
� RETIRED ASH BASIN ASH LANDFILL WASTE BOUNDARY
DORS FILLS BOUNDARIES
r
y DUKE ENERGY CAROLINAS PROPERTY BOUNDARY
�0 SURFACE WATER FLOW DIRECTION
•' �� I
0 STREAM (AMEC NRTR 2015)
WETLAND (AMEC NRTR 2015)
NOTES:
.. •
1. THE WATERS OF THE US HAVE NOT BEEN APPROVED BY THE US ARMY CORPS OF
ENGINEERS AT THE TIME OF THE MAP CREATION. THIS MAP IS A PRELIMINARY
JURISDICTIONAL DETERMINATION ONLY. THE WETLANDS AND STREAMS BOUNDARIES WERE
OBTAINED FROM AMEC FOSTER WHEELER ENVIRONMENTAL B INFRASTRUCTURE, INC.
NATURAL RESOURCE TECHNICAL REPORT FOR ALLEN STEAM STATION DATED MAY 29, 2015.
2. BOUNDARIES ARE APPROXIMATE.
JaES
3. PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY CAROLINAS.
4. AERIAL IMAGERY IS A COMBINATION OF DUKE ENERGY PROPELLER AERIAL PHOTOGRAPHY
F-Lp51
COLLECTED ON MAY 13. 2025 AND MAXAR IMAGERY FROM ESRt COLLECTED ON MAY 26. 2024.
;c;,�psg
•
5. DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CARO LI NA STATE PLANE
• A-N-55LF-CI71A
COORDINATE SYSTEM FI PS 3200 1NAD83j.
=•I. �I . i F-LCSf
'-7
S. FOR CONSTRUCTION DRAIN DETAILS, SEE RESPECTIVE LANDFILL CONSTRUCTION QUALITY
_____--
ASSURANCE REPORTS BY WSP USA, INC.
7. DORS - DISTRIBUTION OF RESIDUAL SOLIDS
RLNSSLFSW 1
S. NPDES - NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
9. LEACHATE FORCE MAIN ALIGNMENT DEPICTS LEACHATE ROUTING FOR MULTIPLE ONS ITE
LANDFILLS.
A ! ,i CAROLIN a
r� synTena
GRAPHIC SCALE
500 0 500 1,0oo DRAWING 2
I IN MONITORING LOCATIONS
DRAWN BY: T.KING DATE:05/09/2025 ENVIRONMENTAL CONTROLS MONITORING PLAN REVISION 2
REVISEDBY:S. PATTON DATE-05/23/2025 SOUTH STARTER LANDFILL (3620-INDUS)
CHECKED BY: C. SUTTELL DATE-W23/2025 ALLEN STEAM STATION
APPROVED BY: C. SUTTELL DATE: 0 5/23/2025 GASTON COUNTY, NORTH CAROLINA
PROJECT MANAGER: C. SUTTELL

NOTES:
1. WATER LEVELS COLLECTED FEB RUARY 26, 2025.
2. NA - NOT ACCESSIBLE
3. DRY - I N D ICATES TH E W E LL WAS D RY.
4. DORS - DIVISION OF WATER RESOURCES DISTRIBUTION OF RES I DUAL SOLI DS
S. NATURAL RESOURCES TECHNICAL REPORT INRTRI PREPARED BY AMEC FOSTER WHEELER
INC., MAY 29, 2015.
5. BOU N DAIRIES ARE APPROXI MATE.
7. PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY CAROLINAS.
B. AERIAL IMAGERY 15 A COMBINATION OF DUKE ENERGY PROPELLER AERIAL PHOTOGRAPHY
GOL LECTED ON MAY 13, 2025 AND MAXAR IMAGERY FROM ES RI COLLECTED ON MAY 28, 2024.
9. DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE PLANE
COORDINATE SYSTEM FIPS 3200 (NAD83).
10. LEACHATE FORCEMAIN ALIGNMENT DEPICTS LEACHATE ROUTING FOR MULTIPLE ON -SITE
LANDFILLS.
f�. r
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614.99 CCR-27S "' 567.77
6�0 617.15 CCR-3S GWA-275 CP-5S
roor i s o CCR-2S DRY 586.21 ■ . - 569.72
f GWA�OS .
fiA g � 1R '. �_ 6� 615.78 - CCR�SA 575.84
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' 'ar• �• . AB�4S6 DRY CCR-7S CCR-95 ' 5fi8.76
i �►a+ 599Z5' CCR-66 561.16 570.72
590.30
GWA-1 fiS
605.49 0 4 ■ + AB3SS AB-4OSS AB-3355 CCR-8S
■ ` . T r 602.47 594.82 599.67 574.23
•: .:= . .. CCR-BG-1S o
" AB-325
622.95-
ti 579.73
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- ' * AB-31S
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AB 16 ' R
y 639.70 p'.,.•, s p - " t 35` CCR-16S
LEGEND Q 635.82 -_ r 568.38
MONITORING WELL IN SHALLOW F} FiI
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CCR-17S
i 573.27
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" . ■ r yuk �.
G
FLOW DIRECTION GWA-24SA 637.84r��i AB-225 AB-10S
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584.57 564.37
o `
y ELEVATION CONTOUR {10' "y �, AB-21SS a'' �•
INTERVAL 627.70
} ; .: A13-6A
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ELEVATION CONTOUR {10'
INTERVAL} 587.33
LEACHATE BASIN AB-12S �•, -=30 CCR-20S
638.57 '. '� 594.39 n
NORTH STARTER LANDFILL a * - * 2 6�0 sa° CCR-32S
BOUNDARY
567.73
SOUTH STARTER LANDFILL �^ �• a -' ; "a g yqo oa
BOUNDARY GWA-26op
it
S " T ' 1� • - - ho
'+ f 634.36 yekv
SITE FEATURE e1e - ■ f
`" .• CCR-31S
CONSTRUCTION DRAIN �{ - �. 56765
LEACHATE FORCEMAIN BIG-1S ' CCR-286 R ~ CCR-29S
CURRENT TEMPORARY LEACHATE y 635.31 * �" _ 614.91 58276 CCR-305
e 5fi6.35
FORCEMAIN 6,0
RETIRED ASH BASIN ASH LANDFILL
WASTE BOUNDARY fl MEd ~ .-
ACTIVE ASH BASIN WASTE .F • 4
BOUNDARY i +� r• `rw....
RETIRED ASH BASIN WASTE *" V.11 � s ap L^- :• j. ' l
BOUNDARY �° ,I �' F oe,
ASH BASIN GEOGRAPHIC
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DUKE ENERGY CAROLINAS 400 0 400 800
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SURFACE WATER FLOW DIRECTION ENERGY GRAPHIC SCALE (IN FEET) DIRECT MEASUREMENT POTENTIOMETRIC SURFACE
UPPERMOST AQUIFER - FEBRUARY 2025
-10 STREAM {AMEC NRTR} DRAWN BI"-E.ORDEMart DATE:05/01/2023REVISED BY ENVIRONMENTAL CONTROLS MONITORING PLAN
147 CHECKED
B PATTON DATE:05/22J2025 SOUTH STARTER LANDFILL 3620-INDUS
WETLAND {AMEC NRTR}CHECKED BY: C. SIJTTELL DATE: os�z2,zo25 { 1
CHECKED BY. C. SIJTTELL DATE:05/22/2025 ALLEN STEAM STATION
TOPOGRAPHIC CONTOUR {10' PROJECT MANAGER: C. SIJTTELL GASTON COUNTY, NORTH CAROLINA
''7"
INTERVAL} Terra
w.s n rracor .D

South Starter Landfill (3620-INDUS)
Environmental Controls Monitoring Plan
Revision 2, May 23, 2025
Appendix I — Sample Collection Guidelines

Landfill
Sample Collection Guideline
� DUKE
ENERGY
Revision 1
December 14, 2020

Duke Energy
Landfill Sample Collection Guideline
Revision History
Revision 1, December 14, 2020
Revision
0
Company
Duke Energy
Date of Revision
10/27/2020
DescriptionRevision
Initial release
1
Duke Energy
12/14/2020
Replaced Section 5.0 reference NCDENR
2008 Solid Waste Section, Guidelines for
Groundwater, Soil, and Surface Water
Sampling with NCDEQ 2020 Environmental
Monitoring — Field Measurements and
Sampling Procedures
Page i of ii

Duke Energy Revision 1, December 14, 2020
Landfill Sample Collection Guideline
Table of Contents
1.0
General Information........................................................................................1
1.1
Introduction......................................................................................................................1
1.2
Sampling General Requirements.....................................................................................1
2.0
Labeling, Documentation, and Records.......................................................2
2.1
Sample Container Labeling..............................................................................................2
2.1.1
Prior to field mobilization..................................................................................................
2
2.1.2
At sample collection location...........................................................................................
2
2.2
Field Documentation........................................................................................................2
2.3
Chain -of -Custody Record................................................................................................3
3.0
Sample Collection...........................................................................................3
3.1
Grab Sample Method.......................................................................................................3
3.2
Unpreserved Container or Intermediate Vessel...............................................................4
3.3
Peristaltic Pump and Tubing............................................................................................4
4.0
Custody and Laboratory Receipt...................................................................4
4.1
Custody of Sample..........................................................................................................4
4.2
Laboratory Receipt..........................................................................................................5
5.0
References......................................................................................................5
List of Attachments
Example Chain of Custody Record and Analysis Request Form
Page ii of ii

Duke Energy
Landfill Sample Collection Guideline
1.0 General Information
1.1 Introduction
Revision 1, December 14, 2020
This Sample Collection Guideline (Guideline) describes the general processes which
Duke Energy or their designee should follow for collection of a sample at operational
and closed Duke Energy landfills located at fossil power plants (Plant/ Site).
The principal purpose of a sampling and analysis program is to provide data that
accurately reflect the quality of the media being investigated which begins with
assurance that the composition of field samples remains unaltered before laboratory
analysis. This Guideline provides information pertaining to preparation for, and field
collection of, a sample.
1.2 Sampling General Requirements
In addition to the information provided in this Guideline, all personnel collecting
samples from a Site will:
• be knowledgeable of general field collection procedures including operation of
equipment to be utilized, preservatives, and storage temperature requirements,
and familiar with this sampling procedure;
• wear personal protective equipment (PPE) required by the Site or based on field
conditions (may include a high visibility vest, hard hat, eye protection, gloves, and
protective footwear);
• be familiar with preservatives and/or storage temperatures required for the
parameters to be analyzed;
• confirm that receiving laboratory is aware of, and prepared to, accept the samples
prior to mobilizing for field collection;
• use new, clean, non -powdered latex or nitrile gloves at each sample collection
location;
• checked all equipment to ensure that it is in working order and if necessary,
calibrated;
• decontaminate reusable sampling equipment prior to collection of a sample;
• record detailed field notes in a logbook or dedicated field form to include sample
information (e.g. site name, time and date sample was collected, sample code,
personnel, weather etc.), and;
• document the chain of custody for each sample collected.
Samples will be:
• collected in certified pre -clean containers appropriate for the laboratory analyte
which are labeled in accordance with Section 2.0, and supplied or recommended
by the laboratory performing the analysis, filled to the brim to avoid the inclusion of
air in the sample, unless there is a 'fill -to' mark (typically in pre -preserved bottles);

Duke Energy
Landfill Sample Collection Guideline
Revision 1, December 14, 2020
• collected at locations identified in the Environmental Controls Monitoring Plan
(ECMP) unless an alternate location is authorized by Waste and Groundwater
Programs Subject Matter Expert (SME) for the Site;
documented as "Insufficient Flow" and not sampled if a location is experiencing a
low flow condition that would preclude collection without entrainment of sediment,
and;
• stored in iced coolers, out of direct sunlight and delivered to the laboratory with
minimum delay; ideally on the same day and preferably within 24 hours of
sampling.
2.0 Labeling, Documentation, and Records
2.1 Sample Container Labeling
2.1.1 Prior to field mobilization
Field sample containers should be labeled and organized prior to mobilization for
field collection unless an emergent event precludes the ability to pre -label
containers.
2.1.2 At sample collection location
As samples are collected, field personnel record the date and time of collection
and initials of sampler on the container label and records that information on the
Monitoring Data Sheet and the Chain -of -Custody Record and Analysis Request
Form (example included as an attachment to this Guideline).
2.2 Field Documentation
Field documentation for each sample is recorded on the Field Monitoring Data
Sheets, Field Sampling Calibration Form, and Chain -of -Custody Record and Analysis
Request Form (COC Record). These sheets are arranged in sequential order and
filed by project and date.
Notations are made during field collection to document the following information:
• identification of location;
• date and time of collection;
• collection method;
• types of containers used;
• identification of Quality Control (QC) samples (if applicable);
• preservative(s) used;
• parameters for analysis;
• field analysis data and methods;

Duke Energy Revision 1, December 14, 2020
Landfill Sample Collection Guideline
• field observations during sampling event
• name(s) of sample collectors(s), and;
• climatic conditions including an estimate of air temperature.
2.3 Chain -of -Custody Record
The COC Record accompanies the sample(s), traces sample possession from time of
collection to delivery to the laboratory(s), and clearly identifies which sample
containers have been designated for each requested parameter. The COC Record
includes the following information:
• sample identification number;
• signature of collector;
• date and time of collection;
• sample type;
• identification of location;
• number of containers;
• parameters requested for analysis;
• preservative(s) used;
• signature of all persons involved in the chain of possession, and;
• inclusive dates of possession.
3.0 Sample Collection
3.1 Grab Sample Method
The Grab Sample Method is simple and effective for a homogeneous sample matrix.
The use of unpreserved sample containers for direct grab sampling is encouraged
since the same container can be submitted for laboratory analysis after appropriate
preservation. This procedure reduces sample handling and eliminates potential
contamination from other sources.
Sampling personnel will use the container provided or recommended by the
laboratory for collecting samples that will be analyzed for oil and grease, volatile
organic compounds (VOCs), and microbiological samples.
Sample containers with premeasured amounts of preservative shall not be used to
collect field samples using this method.
If homogeneity is not apparent, based on known flow or vertical variations (not
assumed), then use other collection protocols.
General steps field collection using the Grab Sample Method are:

Duke Energy
Landfill Sample Collection Guideline
Revision 1, December 14, 2020
1. Slowly submerge the container opening, neck first, into the sample media.
2. Invert the bottle so the neck is upright and pointing towards the direction of flow (if
applicable). Allow media to flow slowly into the container until filled.
3. Return the filled container quickly to the surface.
4. Pour out a few mL of sample away from and downstream of the sampling location.
This procedure allows for the addition of preservatives and sample expansion. Do
not use this step for volatile organics or other analytes where headspace is not
allowed in the sample container.
5. add preservatives (if applicable), securely cap container, label, and complete field
notes.
If sample containers are attached to a pole via a clamp, submerge the container and
follow steps 3 — 5 but omit steps 1 and 2.
3.2 Unpreserved Container or Intermediate Vessel
If the sample cannot be collected directly into the sample container (e.g.: Grab
Sample Method) to be submitted to the laboratory, or if the laboratory provides pre -
preserved sample containers, use an unpreserved sample container or an
intermediate vessel (e.g., beakers, buckets or dippers) to collect the sample. Vessels
must be constructed appropriately, including any poles or extension arms used to
access the sample location.
General processes for field collection using an intermediate vessel or container are:
• Rinse the intermediate vessel with ample amounts of media prior to collecting the
first sample.
• Use an intermediate vessel or unpreserved container collect the sample as
outlined in the Grab Sample Method, Section 3.1.
• Use a pole mounted intermediate vessel or unpreserved container of appropriate
construction to sample at unsafe distances collect the sample as outlined in the
Grab Sample Method, Section 3.1.
3.3 Peristaltic Pump and Tubing
This technique is not acceptable for Oil and Grease, EPH, VPH or VOCs. Extractable
organics can be collected through a peristaltic pump if flexible interior -wall Teflon,
polyethylene or PP tubing is used in the pump head.
The most portable pump for this technique is a 12-volt peristaltic pump. Use
appropriately precleaned, silicone tubing in the pump head and attach polyethylene,
Tygon, etc. tubing to the pump to fill the sample container.
4.0 Custody and Laboratory Receipt
4.1 Custody of Sample
For the purpose of this Guideline, a sample is considered in custody if it is:

Duke Energy Revision 1, December 14, 2020
Landfill Sample Collection Guideline
• in actual possession of the responsible person;
• in view, after being in physical possession, or;
• locked or sealed in a manner so that no one can tamper with it, after having been
in physical custody; or in a secured area, restricted to authorized personnel.
Samples are maintained in the custody of sampling personnel throughout the duration
of field collection. At the end of each day and prior to the transfer of the samples the
COC Record information is completed for each sample.
Upon transfer of sample custody from sampling personnel to a currier or receiving
laboratory, the COC Record is:
signed by sampling personnel, including date and time.
if a currier is used for transporting the sample, the COC Record is:
signed by the currier accepting the sample for transport, including date and time.
Upon arrival at the receiving laboratory the COC Record is:
signed and dated by the designee immediately following receipt by the
laboratory.
4.2 Laboratory Receipt
The laboratory maintains a sample -tracking record that follows the sample through
each stage of processing. Sample tracking records maintain the date of sample
extraction or preparation, and analysis. The sample tracking records are used to
verify compliance with holding time limits during data validation and reviewed in
laboratory audits.
5.0 References
Environmental Protection Agency 2003. Landfill Manuals - Landfill Monitoring, 2nd Edition.
Office of Environmental Enforcement.
North Carolina Dept. of Environmental Quality. 2020. Environmental Monitoring — Field
Measurements and Sampling Procedures. [online] Available at:
https://deq.nc.gov/about/divisions/waste-management/waste-management-
permitguidance/solid-waste-section/environmental-monitoring.

Duke Energy
Landfill Sample Collection Guideline
Attachments
Revision 1, December 14, 2020

South Starter Landfill (3620-INDUS)
Environmental Controls Monitoring Plan
Revision 2, May 23, 2025
Appendix II — NCDEQ Environmental Monitoring Report Form

DENR USE ONLY ❑Paper Report ❑Electronic Data - Email CD (data loaded: Yes / No Doc/Event #:
NC DENR I IEnvironmental Monitoring
Division of Waste Management - Solid Waste Reporting Form
Notice: This form and any information attached to it are "Public Records" as defined in NC General Statute 132-1. As such, these documents are
available for inspection and examination by any person upon request (NC General Statute 132-6).
Instructions:
Prepare one form for each individually monitored unit.
Please type or print legibly.
Attach a notification table with values that attain or exceed NC 2L groundwater standards or NC 2B surface water standards. The notification
must include a preliminary analysis of the cause and significance of each value. (e.g. naturally occurring, off -site source, pre-existing
condition, etc.).
Attach a notification table of any groundwater or surface water values that equal or exceed the reporting limits.
Attach a notification table of any methane gas values that attain or exceed explosive gas levels. This includes any structures on or nearby the
facility (NCAC 13B .1629 (4)(a)(i).
Send the original signed and sealed form, any tables, and Electronic Data Deliverable to: Compliance Unit, NCDENR-DWM, Solid Waste
Section, 1646 Mail Service Center, Raleigh, NC 27699-1646.
Solid Waste Monitoring Data Submittal Information
Name of entity submitting data (laboratory, consultant, facility owner):
Contact for questions about data formatting. Include data preparer's name, telephone number and E-mail address:
Name:
E-mail:
Phone:
NC Landfill Rule: Actual sampling dates (e.g.,
Facility name: Facility Address: Facility Permit # (.0500 or. 1600) October 20-24, 2006)
Environmental Status: (Check all that apply)
❑ Initial/Background Monitoring ❑ Detection Monitoring ❑ Assessment Monitoring ❑ Corrective Action
of data submitted: (Check all that apply)
Groundwater monitoring data from monitoring wells ❑
Groundwater monitoring data from private water supply wells ❑
Leachate monitoring data El
water monitoring data
Methane gas monitoring data
Corrective action data (specify)
Other(specify)
Notification attached?
B No. No groundwater or surface water standards were exceeded.
Yes, a notification of values exceeding a groundwater or surface water standard is attached. It includes a list of groundwater and surface water
monitoring points, dates, analytical values, NC 2L groundwater standard, NC 2B surface water standard or NC Solid Waste GWPS and
preliminary analysis of the cause and significance of any concentration.
❑ Yes, a notification of values exceeding an explosive methane gas limit is attached. It includes the methane monitoring points, dates, sample
values and explosive methane gas limits.
Certification
To the best of my knowledge, the information reported and statements made on this data submittal and attachments are true and correct.
Furthermore, I have attached complete notification of any sampling values meeting or exceeding groundwater standards or explosive gas
levels, and a preliminary analysis of the cause and significance of concentrations exceeding groundwater standards. I am aware that there
are significant penalties for making any false statement, representation, or certification including the possibility of a fine and imprisonment.
Facility Representative Name (Print) Title (Area Code) Telephone Number
Affix NC Licensed/ Professional Geologist Seal
Signature
Facility Representative Address
Date
NC PE Firm License Number (if applicable effective May 1, 2009)
Revised 6/2009