1809_Duke_FGD_PTOAppRevised_DIN26608_20160811

Prepared
For:
Duke Energy Carolinas, LLC
526 S. Church St., Charlotte, NC 28202
Date August 10, 2016
Prepared
By:
Amec Foster Wheeler
2801 Yorkmont Rd., Suite 100, Charlotte, NC 28208

Landfill Operations Plan

Marshall Flue Gas Desulfurization Residue Landfill
(Permit No. 1809-INDUS)

Duke Energy Carolinas – Marshall Steam Station

Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654

M.A. “Mark” Shumpert, PE
Amec Foster Wheeler
North Carolina Professional Engineering Firm No. F-1253
Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 TOC August 10, 2016
DESCRIPTION OF REVISIONS
The Operations Plan was originally submitted to the North Carolina Department of Environmental Quality
(NCDEQ) in August of 2011 and modified as shown in the following table:

Revision Date of Document Description of Revisions
Initial Issue August 19, 2011 Initial issuance of document.
Revision 1 December 9, 2011 The following revisions were performed to respond to the
Permit to Operate Completeness Determination and Technical
Review performed by DENR and to provide consistent
requirements for Operational and Intermediate Cover between
this landfill and the Marshall Steam Station Industrial Landfill
No. 1 Permit No. 1812 (MSS ILF#1). Editorial changes to the
text are not noted.

Landfill Operations Plan
 Section 2.1.1—Revised acreage for landfill footprint to
17.9 acres to include stormwater basin.
 Section 2.1.6.3—Revised to delete reference to cover
requirements for asbestos from this section.
 Section 2.1.8.1—Revised cover requirements for
asbestos per NCDEQ comments
 Section 2.1.8.3 – Revised cover requirements to be
consistent with MSS ILF #1 Operations Plan.
 Section 2.1.8.3—Revised cover requirements to be
consistent with MSS ILF#1 Operations Plan.
 Section 2.1.8.4—Revised cover requirements to be
consistent with MSS ILF#1 Operations Plan.
 Section 2.1.8.5—Deleted previous section (Interim
Cover) to be consistent with MSS ILF#1 Operations
Plan. (Initial Issue Section 2.1.8.6 Final Cover
becomes Section 2.1.8.5).
 Section 2.7—Revised wording to state that monitoring
of landfill gas is not required until the final cover system
is installed.
 Section 6.0—Revised section for 10-Year Waste
Management Plan to include annual submittal of
implementation report per NCDEQ comments

Appendix A Dust Control Plan
 Section 1.0—Deleted acreage of landfill footprint.
 Section 2.0—Revised section to delete reference
to thickness of soil cover
 Section 4.0—Revised cover requirements for
asbestos per NCDEQ comments
Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 TOC August 10, 2016

Revision Date of Document Description of Revisions
Revision 1 December 9, 2011 Appendix C
 Added Letter from Mr. Larry Frost, DENR to Mr. Ed
Sullivan, P.E., Duke Energy Carolinas, LLC, dated
September 27, 2011, Permit to Operate, Amendment,
Five (5) Year Renewal, Completeness Determination
and Technical Review, Marshall Steam Station Flue
Gas Desulfurization (FGD) Residue Landfill, Permit No.
1809, Catawba County, DIN 15221
Revision 2 November 13, 2013 Landfill Operations Plan
Section 1.5 Operating Hours – Included language for
Operational Flexibility

Section 2.1 Waste Acceptance
 Revised approved waste and operational process for
handling waste
 Updated intermediate cover requirements

Section 2.3 Leachate Collection System – Included chimney
drain system and modified leachate collection pipe
maintenance plan.

Phasing Diagrams – Added chimney drain locations and added
Drawing PD-9 for chimney drain details.
Revision 3 August 10, 2016 Landfill Operations Plan

Section 2.1 Waste Handling and Landfill Sequencing –
 2.1.2 Added soil material and geotextile
 2.1.5 Updated landfill sequencing
 2.1.6.5 Added vacuum truck waste

Section 2.5 Stormwater Basin Maintenance Requirements –
Removed from Plan

Section 4 Vegetation – Updated to site specific vegetation
management plan

Section 6 Required Regulatory Submittals – Updated the
timeline for reporting sampling events

Existing Conditions and Dust Control Plan figures updated with
2016 topographic survey mapping

Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 TOC August 10, 2016
Table of Contents
1 GENERAL FACILITY OPERATIONS .................................................................................................... 1
1.1 Overview ....................................................................................................................................... 1
1.2 Contact Information ....................................................................................................................... 1
1.3 Safety ............................................................................................................................................ 1
1.4 Access and Security Requirements .............................................................................................. 1
1.5 Operating Hours ............................................................................................................................ 2
1.6 Signs ............................................................................................................................................. 2
1.7 Training ......................................................................................................................................... 2
1.8 Record Keeping for Operations Plan ............................................................................................ 2
1.9 Design Drawings ........................................................................................................................... 3
2 OPERATIONS MANAGEMENT ............................................................................................................ 5
2.1 Waste Handling and Landfill Sequencing ..................................................................................... 5
2.1.1 Landfill Capacity ........................................................................................................................ 5
2.1.2 Waste Acceptance, Disposal, and Screening Requirements .................................................... 5
2.1.3 Dust, Litter, Odor, and Vector Control ....................................................................................... 6
2.1.4 Fire Control ................................................................................................................................ 6
2.1.5 Landfill Sequencing ................................................................................................................... 6
2.1.6 Waste Placement ...................................................................................................................... 6
2.1.7 Compaction Requirements and Testing .................................................................................... 8
2.1.8 Cover Requirements ................................................................................................................. 9
2.1.9 Groundwater Monitoring Well Access Requirements ............................................................. 10
2.2 Leachate and Stormwater Management ..................................................................................... 10
2.3 Leachate Collection System (LCS) ............................................................................................. 10
2.3.1 LCS Maintenance .................................................................................................................... 10
2.3.2 LCS Record Keeping and Sampling ....................................................................................... 10
2.3.3 Contingency Plan .................................................................................................................... 10
2.4 Stormwater Collection and Conveyance ..................................................................................... 11
2.4.1 Stormwater Discharge ............................................................................................................. 11
2.5 Landfill Gas Management ........................................................................................................... 11
3 EROSION AND SEDIMENT CONTROL ............................................................................................. 11
3.1 E&SC Measures Monitoring and Maintenance ........................................................................... 11
3.2 Surface Erosion Monitoring ......................................................................................................... 12
4 VEGETATION MANAGEMENT ........................................................................................................... 13
4.1 Temporary Seeding ..................................................................................................................... 13
4.2 Permanent Seeding .................................................................................................................... 13
4.3 Over-Seeding .............................................................................................................................. 14
5 LANDFILL CLOSURE .......................................................................................................................... 14
6 REQUIRED REGULATORY SUBMITTALS ........................................................................................ 15

Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 TOC August 10, 2016

List of Tables
Table 1 Design Drawings
Table 2 Lined Landfill Capacity
Table 3 Required Regulatory Submittals

List of Figures
Figure 1 Existing Conditions

List of Appendices
Appendix I Dust Control Plan
Appendix II Engineering Drawings
Appendix III Closure/Post-Closure Plan

Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 1 of 15 August 10, 2016
1 General Facility Operations
1.1 Overview

The purpose of this Operations Plan is to outline a plan for the safe and efficient operations of the
Marshall Flue Gas Desulfurization (FGD) Residue Landfill. This Operations Plan presents the operational
requirements for: 1) General Facility Operations, 2) Operations Management, 3) Erosion and
Sedimentation Control, and 4) Vegetation Management, along with guidance for Landfill Closure and
Required Regulatory Submittals. The Operations Plan was prepared consistent with 15A NCAC 13B
.0505 Operational Requirements for Sanitary Landfills rules.

The Marshall Steam Station is located at 8320 East North Carolina Highway 150 in Terrell, Catawba
County, North Carolina. The Marshall FGD Landfill is owned and operated by Duke Energy Carolinas,
LLC (Duke). The landfill is located on Marshall Steam Station property, northwest of the Marshall plant
and bounded by Steamplant Road to the east and existing railroad track to the west.
1.2 Contact Information
Correspondence and questions concerning the operation of the Marshall FGD Landfill should be directed
to the appropriate entity as follows:

Owner

Duke Energy Carolinas, LLC – Marshall Steam Station
8320 East NC Hwy 150, Terrell, NC 28682
[phone]
Facility Contact: Landfill System Owner

State Regulatory Agency

North Carolina Department of Environmental Quality
Division of Waste Management, Solid Waste Section
Asheville Regional Office
2090 US Highway 70, Swannanoa, North Carolina 28778
Permitting Engineer: Mr. Larry Frost
1.3 Safety
Landfill operations at the Marshall FGD Landfill were developed considering the health and safety of the
facility’s operating staff. The operating staff receives site-specific safety training prior to landfill operations,
and on-site activities are conducted according to the applicable sections of Duke’s Safe Work Practices.
1.4 Access and Security Requirements
The Marshall FGD Landfill is located entirely within Duke’s property limits. Security for the site is currently
in place, consisting of fencing, gates, wooded buffers and security check stations. Unauthorized vehicle
access to the site is prevented around the landfill property by security check stations, wooded buffers,
fencing, gates and stormwater conveyance features.

The access road to the site is of all-weather construction and will be maintained in good condition.
Potholes, ruts, and debris on the road(s) will receive attention as soon as practical in order to avoid
damage to vehicles.
Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 2 of 15 August 10, 2016
1.5 Operating Hours
The Marshall FGD Landfill is operated seven days a week, as needed. On weekends and holidays when
the Landfill Operator may be offsite but when the station wastewater treatment system remains
operational, the following conditions apply:
► The Landfill Operator shall place and compact all existing waste in the landfill prior to leaving
the site.
► The Landfill Operator shall clearly and visibly indicate the location for weekend clarifier
sludge placement in the landfill through use of signs, barrels, or other delineation aid prior to
leaving the site.
► Only designated station personnel who are properly equipped and informed shall transport
and place clarifier sludge in the landfill during the weekend or holiday.
► A certified Landfill Operator shall be available by phone to address issues should they arise
during the weekend or holiday.
► On the first business day following the weekend or holiday, the Landfill Operator shall
incorporate any clarifier sludge placed in the FGD Landfill during the weekend or holiday in
accordance with the Operations Plan.
1.6 Signs
A sign providing the landfill permit number, hours of operation, and a statement reading, “NO
HAZARDOUS OR LIQUID WASTE PERMITTED” is posted at the site entrance, and shall be maintained
in good condition.

Directional signs are placed along the access road to the landfill and shall be maintained in good
condition at all times.

Edge-of-waste markers are installed and delineate the edge of waste. These markers shall be maintained
in good condition and remain visible at all times.
1.7 Training
Due to the diversity and nature of job tasks required at the Marshall FGD Landfill, personnel shall be
adequately trained to handle facility operations and maintenance.

The System Owner for Landfill Operations shall have a general understanding of all the tasks required for
site operations. Individuals performing the various tasks shall have adequate training for the site-specific
tasks to which they are assigned. Duke shall offer a site-specific training program for facility personnel.

Noteworthy operations and maintenance tasks to be addressed in training include:

► Maintaining accurate records of waste loading (quantitative and qualitative)
► Operating requirements for stormwater segregation from exposed waste areas
► Operating and maintaining the leachate collection system (LCS)

All training will be documented and training records will be kept on-site. The System Owner for Landfill
Operations will conduct Operations Plan training courses in accordance with the permit requirements.
1.8 Record Keeping for Operations Plan
An operating record is to be maintained on-site and include the following records:

► Leachate Collection Systems (LCS) – Periodic Maintenance Documentation
► Stormwater Maintenance and Inspection Logs
Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 3 of 15 August 10, 2016
► Erosion and Sedimentation Control Inspection Logs
► Periodic Landfill Inspection Reports
► Dust Control Monitoring Logs
► Groundwater Monitoring (and Sampling) Documentation
► Operations Plan

The above records are to be kept in the operating record for the active life of the Marshall FGD Landfill
and the post-closure care period. Information contained in the operating record must be furnished upon
request to the North Carolina Department of Environmental Quality (NCDEQ), Division of Waste
Management, Solid Waste Section (Division) or be made available for inspection by the Division.
Additional records kept on-site, or made accessible electronically at the site, should include:

► Solid waste facility permits
► Record of the amount of solid waste received summarized on a monthly basis based on scale
records
► Documentation of LCS system performance observations
► Documentation of erosion and sedimentation control observations
► Regulatory agency inspection reports
► Permit-to-Construct Application
► Employee training program and records
► Landfill drawings and specifications
1.9 Design Drawings
Landfill design drawings are listed in the table below. The design drawings display the location of landfill
features, landfill construction details, and technical design and construction notes.

Table 1 – Design Drawings

2005 Approved Design Drawings

M-6024-02.00 Cell 1 Excavation
M-6024.03.00 Cell 1 Profile and Sections
M-6024.04.00 Cell 1 Perimeter Road Realignment
M-6024-08.00 Cell 1 and Cell 2 Perimeter Road Sections
M-6024-09.00 Cell 1 and Cell 2 Perimeter Road Profile
MM6451.00-0002.001* Gas Venting System Plan
MM6451.01-0001.001 Cell 1 Erosion and Sediment Control Plan
MM6451.01-0002.001 Cell 2 Erosion and Sediment Control Plan
MM6451.01-0003.001 Final Closure Erosion and Sediment Control Plan
MM6451.01-0004.001* Gypsum Landfill Erosion Control Details
MM6451.00-0001.001* Final Closure Details
MM6451.00-0003.001* Cell 1 Leachate Collection and Removal System
MM6451.00-0004.001 Cell 1 Operational Cover Grading Plan
MM6451.00-0005.001* Cell 1 Final Configuration
MM6451.00-0006.001 Cell 1 Stormwater Basin
MM6451.00-0007.001** Cell 1 and Cell 2 Details
MM6451.00-0008.001 Cell 1 and Cell 2 Leachate Collection and Removal System
MM6451.00-0009.001 Cell 2 Landfill Excavation
MM6451.00-0010.001 Cell 2 Leachate Collection and Removal System
MM6451.00-0011.001 Cell 2 Operational Cover Grading Plan
MM6451.00-0012.001 Cell 2 Stormwater Basin
Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 4 of 15 August 10, 2016
MM6451.00-0012.001 Cell 1 Cell 2 Final Configuration
MM6451.00-0014.001 Cell 1 and Cell 2 Sections

Notes:
1. Unless otherwise noted, the design drawing is from the Construction Plan Application dated
December 15, 2005.
2. * indicates design drawing revised August 19, 2011 and April 6, 2012.
3. ** indicates sump closure detail revised November 1, 2013.

2005 Approved Phasing Drawings
PD-1 – PD-7 Phasing Plan
PD-8 Cell 1 Final Closure
PD-9 Chimney Drain Details

Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 5 of 15 August 10, 2016
2 Operations Management
The primary objective of operations management at the Marshall FGD Landfill is to dispose of waste
material in compliance with permit conditions while operating in a safe manner.

As needed, soil diversion berms will be used to divert non-contact stormwater away from exposed ash.
Areas of exposed ash will be graded to direct contact water to chimney drains. Intermediate cover will be
placed on exterior slopes as each slope section reaches a height of approximately 10 feet.

In general, the landfill operations contractor will limit the area of exposed CCR (i.e., the active area) to 2
acres or less, at the operator’s discretion and CCR in other areas will be covered with stabilizing agent or
operational or intermediate cover in accordance with the Dust Control Plan. Contact water from the active
area will be directed to chimney drains in the landfill interior.

2.1 Waste Handling and Landfill Sequencing

2.1.1 Landfill Capacity
The Marshall FGD Landfill Phase I, Cell 1 was permitted to operate on November 21, 2006. The Cell 1
footprint consists of approximately 17.9 acres.

The capacity of the landfill is presented in Table 2 below.

Table 2 – Lined Landfill Capacity

Landfill Phase Gross Volume (CY)
Previously Permitted Gross Volume
for Phase 1 Cell 1
1,170,000

2.1.2 Waste Acceptance, Disposal, and Screening Requirements
The Marshall FGD Landfill is permitted to accept CCR (including fly and bottom ash, pyrites, and coal mill
rejects) generated at Duke Energy Corporation facilities. The Marshall Steam Station generated waste
includes the following:

► Gypsum produced during the Flue Gas Desulfurization (FGD) process
► FGD clarifier sludge
► Waste limestone material, broiler slag, and sand blast material
► Ball mill rejects
► Asbestos
► Construction and demolition debris
► Land clearing and inert debris
► Waste water treatment sludge, and other waste streams produced by coal-fired electric or
steam generation unit wastes
► Soil material that contains any of the above material and soil used for operations
► Incidental amounts of geotextile used in the management of CCPs

The landfill owner or operator shall notify the Division within 24 hours of attempted disposal of any wastes
the landfill is not permitted to receive. At a minimum, hazardous waste, yard waste, liquid wastes,
regulated medical waste, sharps not properly packaged, polychlorinated biphenyls (PCB) waste as
defined in 40 Code of Federal Regulations (CFR) 761, and wastes banned from disposal in North
Carolina by General Statute 130A-309.10(f), must not be accepted at the landfill.
Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 6 of 15 August 10, 2016

The removal of waste from the landfill is prohibited without owner approval. See Section 2.1.6 – Waste
Placement for storage and removal (mining) of gypsum. Waste will be hauled and disposed of by
dedicated and consistent operators from the waste source to the landfill. Access to the interim waste
storage locations (i.e. fly ash silos, gypsum storage areas, etc.), haul roads, and landfill are restricted;
therefore, no screening of waste is recommended.

2.1.3 Dust, Litter, Odor, and Vector Control
Litter, odors, and vectors are not anticipated to be concerns at the Marshall FGD Landfill. The waste
placed in the landfill does not attract vectors, and windblown material is not anticipated to be a problem.
Odors are typically not a problem at CCR waste landfills.

Dust control is addressed in the Dust Control Plan included as Appendix I. Generally, dust control
measures will be implemented when necessary, and will include at a minimum, watering of dusty roads
with non-contact water and the active area with contact or non-contact water. Other measures include
physical measures such as fencing and/or berms, temporary covers (like tarps), spraying dust
suppressants, and modifying the active area. Additionally, interim cover will be vegetated as soon as
practical in order to minimize the blowing of dust on-site.

2.1.4 Fire Control
No open burning shall be permitted at the Marshall FGD Landfill. There are limited explosive gas
concerns with aforementioned permitted waste types; therefore, the threat of fire is considered to be
minimal.

Although it is unlikely, if a fire occurs at the landfill, the Station Control Room (phone number: 828-478-
7521) shall be notified, and equipment and stockpiled soil shall be furnished to control accidental fires.
Marshall Plant will notify the local fire department, which will be immediately dispatched to assist with fire
control. Any fire that occurs at the landfill shall be reported to the Division within 24 hours, and a written
notification will be submitted within 15 days by the Station Sponsor for Landfill Operations.

2.1.5 Landfill Sequencing
The Marshall FGD Landfill is developed within the area shown on Figure 1. A 200-foot buffer will be
maintained around the entire perimeter of the landfill. A 500-foot buffer will be maintained from existing
residences and water supply wells. The majority of the areas within the buffer will remain in its current
condition. In order to effectively manage leachate, temporary perimeter berms will be maintained around
the active area. The active area surface shall be graded to promote surface water drainage to the contact
water collection system. No waste shall be placed in standing water. The actual filling sequence, fill
heights, and grades may be modified at the Owner’s discretion.

2.1.6 Waste Placement

2.1.6.1 Fly Ash, Bottom Ash, and FGD Gypsum
Fly ash, bottom ash, and FGD Gypsum shall be compacted using compactors and dozers in approximate
1-foot lifts to achieve a vertical operational lift thickness of 10 feet.

In order to protect the liner system and leachate components, gypsum placed in the active landfill with the
potential of future mining will be stored in designated areas with a minimum separation of:

► Horizontal: 50’-0” from the landfill side slope or anchor trench
► Vertical: 10’-0” vertical separation from the top of protective cover (drainage layer). The
vertical separation layer typically consists of ash or other waste material

Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 7 of 15 August 10, 2016
2.1.6.2 FGD Clarifier Sludge, Coal Mill Rejects, Waste Limestone Material, Boiler Slag, Sand Blast
Material, Ball Mill Rejects, Coal Waste, Wastewater Sludge, and Pyrites
FGD clarifier sludge, coal mill rejects, waste limestone material, boiler slag, sand blast material, ball mill
rejects, coal waste, wastewater sludge, and pyrites will be spread in 6-inch lifts in the center of the
operational area and shall not be placed within 25 feet of the exterior slopes. FGD clarifier sludge shall be
blended with the other waste (i.e. ash) prior to placement of the next fill lift. FGD clarifier sludge, coal mill
rejects, waste limestone material, boiler slag, sand blast material, ball mill rejects, coal waste, and pyrites
shall be compacted as densely as practical. In-place density testing of these materials is not required.

2.1.6.3 Asbestos
Asbestos waste shall be packaged in accordance with 40 CFR 61, and it shall be disposed of away from
the working face or in an area not contiguous with other disposal areas. Separate areas shall be clearly
marked so that asbestos is not exposed by future land-disturbing activities. From lift to lift, if asbestos
disposal areas are relocated, records of the areas must be maintained.

Asbestos material shall not be placed within 25 feet of the exterior slopes. Asbestos material shall be
placed in relatively thin lifts limited to only a few feet thick. Asbestos material shall be compacted as
densely as practical and specific monitoring and in-place density testing for asbestos materials is not
required. Asbestos material shall be covered as described in Section 2.1.8.1.

2.1.6.4 Construction and Demolition (C&D) Waste and Land Clearing and Inert Debris (LCID)
The landfill may receive construction and demolition waste, land clearing waste, inert debris, untreated
wood, and yard trash (leaves, sticks). These materials shall not be placed within 25 feet of the exterior
slopes. Waste will be placed on the smallest active face as practical and compacted with a dozer as
densely as practical. Specific monitoring and in-place density testing of C&D waste and LCID is not
required. Compacted C&D waste and LCID will be covered as described in Section 2.1.8.2.

2.1.6.5 Vacuum Truck Waste
Vacuum trucks are used to remove waste materials from the plant areas that consist of various permitted
CCR. The origin of the vacuum truck waste materials is typically from various sumps, catch basins, wheel
wash stations, and coal pile sumps located within the plant.

The moisture contents of the vacuum truck waste materials may vary considerably with the waste varying
in consistency from a relatively dry state to a wet, fluid-like state depending on the amount of liquid
present in the sumps or vacuumed areas.

Vacuum trucks used to transport CCR will be dedicated to Duke operations or documentation will be
obtained to ensure that the vacuum truck contains no human or other non-permitted waste streams.
Vacuum truck waste could also mean similar waste material transported in smaller water tight units.

Vacuum truck waste shall consist of permitted waste materials. Non-permitted waste materials
inadvertently included with the vacuum truck waste, including but not limited to, yard trash (paper, plastic,
wood, aluminum, Styrofoam, etc.) shall be visually screened and immediately removed from the vacuum
truck waste after the waste material is dumped in the operational area by vacuum contractor.

Vacuum truck waste shall only be placed within the landfill during landfill operating hours when landfill
operator personnel are present. The vacuum contractor shall coordinate vacuum truck waste placement
with landfill operator personnel.

A Vacuum Truck Waste Disposal Log shall be used to document vacuum waste placement within the
landfill. A Vacuum Truck Waste Disposal Log shall be used to verify the origin of vacuum truck waste and
will include the date, time, weather conditions, estimated waste volume, visual waste screening and non-
permitted waste removal, and Operator representative approval. The Vacuum Truck Waste Disposal Log
Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 8 of 15 August 10, 2016
may be modified as needed by the Owner or Operator to supply additional site specific operations
information.

The estimated volume of vacuum truck waste generated will be documented by the landfill operator along
with monthly truck scale log records to estimate the cumulative vacuum truck waste transported and
placed within the landfill.

The consistency of the vacuum truck waste may vary from a relatively dry state to a relatively wet, fluid-
like state. Vacuum truck waste material shall be moisture conditioned by initial decanting of excess
moisture from the waste or by mixing the waste with fly ash, bottom ash, or gypsum materials depending
on its consistency. The vacuum truck waste shall be placed and spread in maximum 6-inch lifts near the
center of the operational area. The vacuum truck waste shall not be placed within 50 feet horizontally
from exterior landfill slopes or within 50 feet of chimney drain structure locations. The vacuum truck waste
material shall be thoroughly mixed with fly ash, bottom ash, or gypsum material during waste placement
using a dozer or other similar grading equipment to produce additional moisture conditioning prior to
compaction. In-place density testing of the vacuum truck waste material is not required.

2.1.7 Compaction Requirements and Testing

2.1.7.1 In-Place Density and Moisture Content Testing
In-place density and moisture content testing shall be performed at a minimum frequency of one test per
10,000 cubic yards. Waste shall be compacted to a minimum 95 percent of its Standard Proctor (ASTM
D698) maximum dry density. Compacted moisture content shall be within 5 percent of the material’s
optimum moisture content as determined by ASTM D698.

In-place density tests shall be performed using the Drive-Cylinder Method (ASTM D2937), or Nuclear
Method (ASTM D6938). If the nuclear method is selected, a minimum of one comparison density test
using the Drive Cylinder method shall be performed for every 10 nuclear density tests. All test results
shall be reported to the Engineer of Record for the landfill. A sample of ash material shall be collected
from each density test location and placed in a sealed container for subsequent field and laboratory
moisture testing. The reported dry density shall be calculated based on the results of laboratory moisture
testing.

A family of Proctor curves shall be developed for the on-site ash material as standard Proctor moisture-
density tests are performed as a reference for the field density testing. A minimum of one (1) one-point
field Proctor test shall be performed during each compaction testing event. If the estimated standard
Proctor maximum dry density based on the results of one-point Proctor testing indicates that the
maximum dry density varies by more than 5 pounds per cubic foot (pcf) from the nearest representative
standard Proctor moisture-density relationship, an additional bulk sample of ash material shall be
obtained and standard Proctor testing shall be performed and used to evaluate the degree of compaction
for the related in-place density tests. If in the course of testing, the technician believes that due to
changes in material a Proctor curve should be referenced other than that indicated by the initial one-point
field Proctor, then an additional one-point field Proctor shall be performed.

2.1.7.2 Laboratory Testing
Laboratory moisture content testing shall be performed in conjunction with the field density testing as
described above. The laboratory moisture content testing shall be performed using the Oven Method
(ASTM D2216), at an oven temperature of 60 degrees Celsius.

Standard Proctor moisture-density relationship (ASTM D698) testing shall be performed at a minimum
frequency of one test for every 50,000 cubic yards of material placed. As previously mentioned, additional
standard Proctor samples shall be obtained and tested if one-point Proctor testing indicates that the
estimated maximum dry density of the material varies by more than 5 pcf from the nearest representative
standard Proctor moisture-density relationship.

Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 9 of 15 August 10, 2016
2.1.8 Cover Requirements
2.1.8.1 Operational Cover – Asbestos Material
Asbestos waste material that has been deposited in the Marshall FGD Landfill will be covered within eight
hours of placement with at least 6 inches of soil, ash, and/or gypsum material and compacted by a dozer.

2.1.8.2 Operational Cover – C&D Waste
When the C&D waste disposal area exceeds one-half acre, and at least weekly, the compacted C&D
waste will be covered with a minimum of 6 inches of earthen material (i.e., soil, ash and/or gypsum
material).

2.1.8.3 Operational Cover
For wastes other than asbestos waste and C&D waste, operational soil cover should be applied, as
needed, for dust control and stormwater management. The operational cover may be applied at a
thickness suited to its purpose. For example, operational soil cover may be applied thinner to achieve
dust control and it may be applied in thicker layers where protection from surface erosion is desired.
Operational soil cover is not required, provided the Dust Control Plan included as Appendix I is followed.

2.1.8.4 Intermediate Cover
A 12-inch thick intermediate cover layer shall be placed on exterior slopes and areas where final grades
have been reached. Intermediate cover material shall be free of protruding roots, stumps, and debris.
Intermediate cover may not contain more than 5 percent gravel (particle sizes larger than 0.5 inches) by
weight as determined by ASTM D422. Isolated rock fragments not exceeding 6 inches in diameter may be
placed within the intermediate cover if completely surrounded by compacted soil if approved by the
Engineer. Rock fragments shall not protrude more than 3 inches from the intermediate cover surface.
Intermediate cover will be seeded within 7 days in accordance with Erosion and Sediment Control
requirements. Vegetation shall be removed and the intermediate cover soil shall be scarified or removed
prior to placing any overlying waste. For areas where waste placement will be inactive for 12 months or
more within interior landfill areas (excluding exterior slope area), will not require intermediate soil cover,
provided the Dust Control Plan included in Appendix I is followed.

2.1.8.5 Final Cover
The final cover system for the Marshall FGD Landfill will be completed within 180 days following the
beginning of closure activities unless otherwise approved by the Division.

The final cover system will consist of the following components, from top to bottom:

► A 24-inch thick final cover soil layer (i.e., a 6-inch thick vegetative support layer overlying an
18-inch thick cover soil layer) consisting of a soil capable of supporting native plant growth
► A double-sided geocomposite drainage layer
► A 40-mil thick double-sided textured linear low density polyethylene (LLDPE) geomembrane
► Intermediate soil cover layer (may be thinner than the initial 12-inch thickness; geomembrane
may be installed directly on waste)

The soil components will yeild a surface suitable to sustain vegetative growth while protecting the
underlying geosynthetic components of the cover system. Infiltration through the cover soils will be
collected by the geocomposite drainage layer, while the geomembrane will function as a hydraulic barrier
to reduce infiltration into the waste mass. The cover system stormwater management structures will
collect both infiltration and surface water runoff. The final cover will be vegetated within six months
following closure.

Refer to the Appendix III, Closure and Post-Closure Plan for final cover specifications and maintenance
and operations requirements.

Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 10 of 15 August 10, 2016
2.1.9 Groundwater Monitoring Well Access Requirements
Groundwater monitoring wells will be located around the landfill perimeter. A readily accessible,
unobstructed path shall be maintained so that monitoring wells may be accessed using four-wheel drive
vehicles. Care must be taken around the wells to prevent any damage to the wells.

2.2 Leachate and Stormwater Management
A leachate collection system (LCS) is in place to gravity drain the leachate from the landfill. A 12-inch
thick layer of operational cover is over the geomembrane liner and leachate collection and removal
system.

Leachate and stormwater are conveyed by pipe to the Marshall Ash Basin, which discharges in
accordance with the MSS plant’s National Pollutant Discharge Elimination System (NPDES) permit.
2.3 Leachate Collection System (LCS)
The leachate collection system consists of a geonet/geotextile with a perforated collection/header piping
system that drains by gravity into a pipe at the previous location of the stormwater storage basin riser.
The leachate is then directed by gravity flow to the Marshall Ash Basin.

Two chimney drains with a header pipe are designed through the center of the landfill and are connected
to the sump. The landfill grading will be sloped toward each chimney drain to facilitate drainage of contact
storm water through the landfill. As each lift of waste is filled, a section of chimney drain will be added
until final landfill grades are achieved. The chimney drain will have an inverted filter with No. 57 stone, No.
78M stone, and C-33 sand or bottom ash. The inverted filter will reduce the clogging potential of the
chimney drain. The chimney drain design and details are presented in the Phasing Diagrams.

2.3.1 LCS Maintenance
The maintenance of the leachate management system's physical facilities (consisting of high-density
polyethylene (HDPE) piping) and records will be performed by or under the direct supervision of Duke.
Visual observations of the LCS system performance will be made monthly by Duke staff to verify that the
LCS is performing properly.

Clean-out pipes will be located on the LCS leachate pipes and header pipes. LCS pipes will be cleaned
out by the use of a clean-out snake or high-pressure water flushing at least once a year, and the LCS
piping will be remote-camera monitored at least once every 5 years. The frequency of clean-out and
camera inspections may be modified based on consecutive inspection results and observed operating
conditions.

2.3.2 LCS Record Keeping and Sampling
Records will be maintained documenting the leachate line cleanout and camera monitoring. Untreated
leachate shall be sampled and analyzed at least semi-annually concurrent with the groundwater water
sampling. A grab sample will be obtained from the outlet of each leachate pipe. The leachate must be
analyzed for the same constituents as the groundwater monitoring wells in the approved Water Quality
Monitoring Plan. The results must be submitted to NCDEQ Solid Waste with groundwater results.

2.3.3 Contingency Plan
In the unlikely event that leachate cannot be drained to the Marshall Ash Basin, leachate will be
temporarily stored within the landfill until such time that draining operations to the active ash basin can be
restored. In such an event, the Division shall be notified in writing, within 30 days, about the events and
corrective actions taken.

Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 11 of 15 August 10, 2016
2.4 Stormwater Collection and Conveyance
Stormwater that does not come in contact with waste will be treated as non-contact water. Non-contact
water will be managed separately from contact water and may be used for dust control or other
operational purposes. The stormwater collection system has been designed to pass the 25-year, 24-hour
storm event, and generally consists of the following components:

► Diversion Berms
► Subsurface drains
► Slope drains
► Perimeter ditches

Intermediate cover will be placed over waste at the exterior side slopes. Diversion berms will be placed to
convey non-contact surface water from the exterior side slopes to slope drains. The diversion berms and
slope drains will be constructed and extended as operations progress. The slope drains discharge to
perimeter ditches, which in turn ultimately discharge to the Marshall Ash Basin via a system of culverts
and channels.

Stormwater collection and conveyance measures will be checked regularly and maintained such that
necessary repairs can be made as early as practical.

2.4.1 Stormwater Discharge
The stormwater system at the landfill was designed to assist in prevention of the discharge of pollutants.
Landfill operation shall not cause a discharge of pollutants into waters of the United States, including
wetlands, that violates any requirement of the Clean Water Act, including but not limited to NPDES
requirements, pursuant of Section 402. In addition, under the requirements of Section 404 of the Clean
Water Act, the discharge of dredge or fill material into waters of the state would be a violation of the
requirements and shall not be allowed by landfill operations.

Operations of the landfill shall not cause the discharge of a non-point source of pollution to waters of the
United States, including wetlands, that violates any requirements of an area-wide or statewide water
quality management plan that has been approved under Section 208 or 319 of the Clean Water Act, as
amended.

A jurisdictional wetland and stream are located to the west of the landfill. Maintenance of the stormwater
system shall be performed to ensure these areas are not impacted by stormwater or sediment.
2.5 Landfill Gas Management
Because the nature of the waste to be placed in the Marshall FGD Landfill, the Owner does not anticipate
that methane or hydrogen sulfide will be generated or that odor will be an issue during operations.
Therefore, landfill gas monitoring and management is not proposed.
3 Erosion and Sediment Control
Erosion and sediment control (E&SC) during landfill operations will consist of monitoring and repairing
E&SC stormwater conveyance features and surface erosion as defined in this Operations Plan and the
E&SC measures included on Drawing No. MM6451.00-0005.001 (Cell 1 Final Configuration) and Drawing
No. MM6451.01-0004.001 (Gypsum Landfill Erosion Control Details), both dated August 19, 2011.
3.1 E&SC Measures Monitoring and Maintenance
Erosion control principles include:

► Disturbing as little area as possible at any one time for landfilling operations
Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 12 of 15 August 10, 2016
► Seeding/mulching of disturbed areas commencing as soon as practically possible. Employing
erosion control matting or seeding and mulch on steep slopes and other erosion prone areas
► Use of earthen berms, hay bales, wattles, silt fences, riprap, or equivalent devices down
gradient of disturbed areas, stockpiles, drainage pipe inlets and outlets, and at intervals along
grassed waterways, until such time as permanent vegetation is established
► Placement of riprap at the inlets and outlets of stormwater piping

Erosion and sedimentation control structures include stormwater best management practice (BMP)
systems, settling basins, and channels. Stormwater BMP’s shall be inspected every 7 days and within 24
hours of rainfall events 0.5 inches or greater. Sediment shall be removed from each structure when
sediment accumulates to one half of the design depth. Sediment removal shall bring BMP’s to their
original design depth. The BMP’s, embankments, spillways and outlets shall also be observed for erosion
damage. Necessary repairs shall be made immediately. Trash or debris within the riser structures or
outfalls shall be removed.

Channels shall be observed for damage every 7 days and within 24 hours of rainfall events 0.5 inches or
greater. Riprap-lined channels and outlet protection aprons used to prevent damage to channel
vegetation shall be observed for washouts. Riprap shall be added to those areas, as needed, to maintain
the integrity of the structure.

Embankment slopes shall be inspected for erosion every 7 days and within 24 hours of rainfall events 0.5
inches or greater. The embankment slopes shall be mowed at least three times a year. The embankment
slopes shall be fertilized in the second year unless vegetation growth is fully adequate. Damaged areas
shall be reseeded, fertilized and mulched immediately. Seeding, fertilizing, and mulching shall be in
accordance with the North Carolina Erosion and Sedimentation Control Guidelines and in accordance
with the active Erosion and Sediment Control Plan, furnished in the Engineering Plan drawings.

Ground stabilization shall be performed within 7 calendar days on perimeter areas and slopes greater
than 3H:1V. Ground stabilization shall be performed within 14 calendar days in other areas. Seedbed
preparation, seeding, soil amendments, and mulching for the establishment of vegetative ground cover
will be applied in accordance with North Carolina Erosion and Sedimentation Control Guidelines.

3.2 Surface Erosion Monitoring
Adequate erosion control measures shall be practiced to prevent sediment from leaving the site.
Channels will be observed once every seven days and within 24 hours after any rainfall event of 0.5
inches or greater.

Slopes will be periodically checked for erosion and vegetative quality, fertilized, and mowed. A slope or
portion thereof shall be identified as needing maintenance if it meets one of the following conditions:

► Exposed waste on exterior slopes
► Areas of cracking, sliding, or sloughing
► Areas of seepage

Slopes identified as needing maintenance shall be repaired as soon as practical and as appropriate to
correct deficiencies. Repair activities may include re-dressing the slope, filling in low areas, and/or
seeding.
Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 13 of 15 August 10, 2016
4 Vegetation Management
Within six months after final termination of disposal operations at the site, the area shall be stabilized with
vegetation as required by the Closure and Post-Closure Plan, included in Appendix III. Temporary
seeding will be applied as required.

Temporary methods of erosion control may be required until vegetation is established. Mulching, until a
vegetative cover is established, can stabilize areas where final grade has been reached. Soil mulching
can be achieved using wood chips, straw, hay, asphalt emulsion, jute matting, and synthetic fibers.
Mulches allow for greater water retention; reduce the amount of runoff; retain seeds, fertilizer, and lime in
place; and improve soil moisture and temperature conditions.
4.1 Temporary Seeding
Temporary seeding will be applied as follows or as required by the site’s vegetation management plan:

SUMMER (May – August)

Seeds Pounds Per Acre
German Millet 50

FALL, WINTER, (September – December)

SPRING (January - April)

4.2 Permanent Seeding
Permanent Seeding will be applied as follows or as required by the site’s vegetation management plan:

Warm Season Planting (May – Aug)

Nurse Crop Seed Pounds Per Acre
German Millet 50

SPRING (January - April)

Soil Amendments Application Rate
Agricultural limestone Per soil test or 1 ton/ac
Fertilizer (10-10-10) Per soil test or 1000 lbs/ac
Mulch 2 tons/ac
Seeds Pounds Per Acre
Rye (grain) 125
Seeds Pounds Per Acre
Annual Rye 50
Rye (Grain) 125
Seeds Pounds Per Acre
Kentucky 31 Tall Fescue 150
Rye (Grain) 50
Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 14 of 15 August 10, 2016

Note: Perform soil test to determine proper soil amendments; if not available, use the quantities above,
and are applicable year round
4.3 Over-Seeding
Over-seeding will be applied as follows:

SUMMER (May – August)

Seeds Pounds Per Acre
German Millet 25

FALL, WINTER, (September – December)

SPRING (January - April)

Note: Cut the existing turf to be over-seeded to an approximate 1-inch height. Aerate the soil and turf area
to be over-seeded. Apply soil amendments pursuant to nutrient testing results.
5 Landfill Closure
The Marshall FGD Landfill will be closed in accordance with the design drawings and Closure and Post-
Closure Plan. The Closure and Post-Closure Plan outlines the sequence for closing the landfill and the
post-closure maintenance activities. Closure is designed to minimize the need for long-term maintenance
and control the post-closure release of contaminants. Closure activities may be revised as appropriate for
materials, specifications, technology advancements, or changes in regulations at the time the landfill is
closed or in post-closure. In general, the landfill development is designed so that final cover can be
established as soon as practical.

Seeds Pounds Per Acre
Kentucky 31 Tall Fescue 50
Rye (Grain) 25
Seeds Pounds Per Acre
Kentucky 31 Tall Fescue 50
Rye (Grain) 25
Landfill Operations Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 15 of 15 August 10, 2016
6 Required Regulatory Submittals
Table 3 – Required Regulatory Submittals

Submittal Requirement
Reporting/Action
Frequency

Groundwater
Monitoring
Reports
Maintain a record of all monitoring events and analytical data
in accordance with the Water Quality Monitoring Plan.
Reports of the analytical data for each water quality
monitoring sampling event shall be submitted to DEQ Division
of Waste Management (DWM) within 120 days of sampling
event.

Semiannually

Annual
Tonnage
Reports
Tons of waste received and disposed of in the landfill shall be
reported to the DWM and to all counties from which waste
was accepted on forms prescribed by the DWM. Refer to the
Permit to Operate for annual reporting requirement
information.

Annually

Must be submitted no
later than August 1
each year

10-Year
Waste
Management
Plan
Per North Carolina G.S. 130A-309.09D (c):
► A 10-year waste management plan shall be
developed for this landfill and submitted to DWM.
► The plan shall be updated and submitted to DWM
at least every three years.
► A report on the implementation of the plan is
required to be submitted to DWM by August 1 of
each year.

10-year plan
prepared every 10
years

10-year plan
updated every 3
years

Implementation
report annually

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REFERENCES:1.EXISTING TOPOGRAPHIC INFORMATION WAS PRODUCED FROM PHOTOGRAMMETRIC METHODS FROM AERIALPHOTOGRAPHY OBTAINED ON APRIL 4, 2014 BY WSP GROUP.2.EXISTING TOPOGRAPHIC INFORMATION WAS PRODUCED FROM PHOTOGRAMMETRIC METHODS FROM AERIALPHOTOGRAPHY OBTAINED ON MAY 7, 2016 BY WSP GROUP, HATCHED AREAS ARE OBSCURED AS REPORTED BYSURVEYOR.

APPENDIX I

Dust Control Plan

Prepared
For:
Duke Energy Carolinas, LLC
526 S. Church St. Charlotte, NC 28202
Date August 10, 2016
Prepared
By:
Amec Foster Wheeler
2801 Yorkmont Rd., Charlotte, NC 28208

Dust Control Plan

Marshall Flue Gas Desulfurization Residue Landfill
(Permit No. 1809-INDUS)

Duke Energy Carolinas– Marshall Steam Station

Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654

Dust Control Plan Duke Energy – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 TOC August 10, 2016
Table of Contents
1 INTRODUCTION AND SITE DESCRIPTION ........................................................................................ 1
2 DUST CONTROL METHODS ............................................................................................................... 1
3 MONITORING AND CORRECTIVE ACTION RESPONSE .................................................................. 2
3.1 Monitoring ...................................................................................................................................... 2
3.2 Corrective Action Response .......................................................................................................... 3

List of Figures
Figure 1 Landfill Operations Grid
List of Attachments
Attachment I Dust Monitoring Form

Dust Control Plan Duke Energy – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 1 of 3 August 10, 2016
1 Introduction and Site Description
This Dust Control Plan is for the Marshall FGD Landfill at Duke Energy’s Marshall Steam Station. This
Plan outlines dust control methods for managing dust emissions at the landfill. The Plan also establishes
a monitoring program and corrective action responses to contain coal combustion residuals (CCR) on site
and to prevent dust nuisances to employees and the public. The monitoring program will aid Duke
Energy and the landfill operator in evaluating the dust control methods, or combination of dust control
methods, that prove effective with site specific conditions.

The Marshall FGD Landfill is principally used for CCR management. CCR managed by the landfill
primarily consist of FGD residue (i.e., gypsum, clarifier sludge), fly ash, bottom ash, and mill rejects. The
landfill is also used for asbestos and construction and demolition debris (C&D) waste management.

This Plan is included as an Appendix to the Landfill Operations Plan. Please refer to the Operations Plan
for a description of revisions as necessary.
2 Dust Control Methods
The primary potential source of dust emissions from the landfill is the active area of waste placement.
This area is at a higher risk for producing dust due to exposed ash surfaces, vehicular and equipment
traffic and earthworks such as dumping and spreading ash. Exterior landfill slopes are less of a dust
control concern, as they have intermediate or operational soil cover which is vegetated as required in the
Operations Plan.

Dust emissions from the landfill can be controlled through a variety of dust control methods. Possible
dust control methods are identified herein. Dust control methods may be characterized as products
and/or applications, structural wind breaks and/or covers, and operational methods.

Dust control methods for the landfill area include:

► Watering;
► Establishing vegetative cover;
► Mulching;
► Structural controls consisting of:
► Wind breaks (i.e. fencing and/or berms); and
► Temporary coverings (i.e. tarps);
► Spray applied dust suppressants consisting of, and not limited to:
► Anionic asphalt emulsion;
► Latex emulsion;
► Resin in water;
► Polymer based emulsion; and
► Mineral mortar coatings (i.e. posi-shell);
► Calcium chloride;
► Soil stabilizers (e.g. soil cement);
► Operational soil cover;
► Modifying the active working area; and
► Modifying operations during dry and windy conditions.

Dust Control Plan Duke Energy – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 2 of 3 August 10, 2016
The operator may use, and is not limited to, combinations of these dust control methods or any method
that is technically sound to control dust for specific site conditions. If the operator intends to use a dust
control method not presented above, the proposed dust control method will be evaluated on a case by
case basis to assess the effectiveness with specific site conditions. For the purposes of this Plan,
operational soil cover will be defined as soil material applied at a suitable thickness to result in dust
control. The effectiveness of the dust control methods implemented should be evaluated through a dust
monitoring program outlined in Section 3.

Operational equipment may consist of dump trucks, vibratory smooth drum rollers, sheepsfoot
compactors, bulldozers, water trucks, spray trailers, track hoes, and service trucks. Operational
equipment will be used to construct, install, apply, and/or repair dust control methods. The operator will
make provisions to alleviate any on-site issues that arise when primary equipment is being maintained or
is inoperable. In the event that the landfill site contains multiple facilities in the future, the landfill operator
will make provisions to have the necessary equipment to control multiple fugitive CCR dust emission
events.

3 Monitoring and Corrective Action Response
This section describes the dust monitoring program and suggests corrective action responses should
fugitive emissions be observed.
3.1 Monitoring
During landfill operations, a dust monitoring program will be implemented to evaluate the performance of
dust control measures. The dust monitoring program will consist of performing visual observations of dust
prone areas, dust control measures, and monitoring existing and forecasted weather conditions.

Dust emissions can occur under many conditions. For the purposes of this Plan, dust emissions are
characterized as fugitive emissions, where CCR dust may be transported outside the limit of landfill
waste. This is most likely to occur during windy, dry, and hot weather conditions. Therefore, the operator
will monitor both existing and forecasted weather conditions and use dust control measures accordingly.
The dust control measures shall be implemented prior to the forecasted weather conditions.

Equipment operators shall continuously observe the active face and other areas within the landfill limit for
dust emissions. In addition, preventative dust control measures should be observed and documented at
least twice daily (morning and afternoon) when the landfill is in operation, to evaluate the dust control
measure performance. Observations will be recorded using a form such as the one furnished in Appendix
I. Additional observations may be necessary as site and weather conditions dictate.

Observations will be documented on the attached “Monitoring Worksheet,” or online database/worksheet,
etc. Due to the frequent maintenance necessary on exposed ash areas (i.e., moisture conditioning or
spray-application of dust suppressants), the operator shall pay particular attention to these areas.
Structural controls shall be observed to monitor that they are achieving their intended purpose.
Observations in the landfill area may be made with reference to the Operations Grid system shown in the
attached Figure 1.

Monitoring will be conducted during times when the landfill is in operation. The operator shall continue to
deliver necessary dust control measures during periods when operations are inactive (i.e. outages,
weekends, and holidays). Operators are to establish appropriate measures so that dust emissions are
not reasonably likely to occur during inactive operation periods when monitoring is not being conducted.

Dust Control Plan Duke Energy – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 3 of 3 August 10, 2016
3.2 Corrective Action Response
If fugitive dust emissions are observed and observations indicate dust control measures are not achieving
their intended purpose, then appropriate corrective actions will be taken. Dust control measures should
be reapplied, repaired, or added, as necessary, to control dust emissions. The operator will construct,
install, apply, and/or repair dust control measures prior to the end of the work day to control dust
emissions during non-operating hours. The operator will implement dust control measures as
preventative controls rather than in response to fugitive dust emissions.

FIGURES

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REFERENCES:1.EXISTING TOPOGRAPHIC INFORMATION WAS PRODUCED FROM PHOTOGRAMMETRIC METHODS FROM AERIALPHOTOGRAPHY OBTAINED ON APRIL 4, 2014 BY WSP GROUP.2.EXISTING TOPOGRAPHIC INFORMATION WAS PRODUCED FROM PHOTOGRAMMETRIC METHODS FROM AERIALPHOTOGRAPHY OBTAINED ON MAY 7, 2016 BY WSP GROUP, HATCHED AREAS ARE OBSCURED AS REPORTED BYSURVEYOR.ABCDEF 12
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APPENDIX II Engineering Drawings (Included are PD-8 and PD-9, others by reference only)

APPENDIX III

Closure/Post-Closure Plan

Prepared
For:
Duke Energy Carolinas, LLC
526 S. Church St. Charlotte, NC 28202
Date May 19, 2016
Prepared
By:
Amec Foster Wheeler
2801 Yorkmont Rd., Suite 100, Charlotte, NC 28208

Closure and Post-Closure Plan

Marshall Flue Gas Desulfurization Residue Landfill
(Permit No. 1809-INDUS)

Duke Energy Carolinas– Marshall Steam Station

Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654

Closure & Post-Closure Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 TOC May 19, 2016
Table of Contents
1 INTRODUCTION ................................................................................................................................... 1
1.1 Project Information ........................................................................................................................ 1
2 CLOSURE PLAN ................................................................................................................................... 1
2.1 Description of Cover System ......................................................................................................... 1
2.1.1 Vegetative Soil Cover ................................................................................................................ 1
2.1.2 Final Cover Soil ......................................................................................................................... 1
2.1.3 Geocomposite Drainage Layer ................................................................................................. 1
2.1.4 Geomembrane .......................................................................................................................... 1
2.1.5 Intermediate Cover .................................................................................................................... 1
2.2 Gas Management System ............................................................................................................. 2
2.3 Stormwater Management System ................................................................................................. 2
2.4 Largest Area Requiring Cover System ......................................................................................... 2
2.5 Estimated Maximum Waste Inventory........................................................................................... 2
2.6 Closure Schedule .......................................................................................................................... 2
3 POST-CLOSURE PLAN ........................................................................................................................ 3
3.1 Maintenance Activities .................................................................................................................. 3
3.2 Inspection Activities ....................................................................................................................... 3
3.2.1 Groundwater and Surface Water Monitoring............................................................................. 3
3.3 Facility Contact Information ........................................................................................................... 4
3.4 Anticipated Post-Closure Use ....................................................................................................... 4
3.5 Cost Estimate for Closure and Post-Closure Activities ................................................................. 4
3.6 Certification ................................................................................................................................... 4

List of Figures
Figure 1 Site Map

List of Appendices
Appendix I Post-Closure Inspection Form
Appendix II Cost Estimate for Closure and Post-Closure Activities

Closure & Post-Closure Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 1 of 4 May 19, 2016
1 Introduction
This Closure and Post-Closure (Closure/Post-Closure) Plan is being submitted as part of the Landfill
Operations Plan and was prepared for the Marshall FGD Landfill in accordance with Title 15A Subchapter
13B of the North Carolina Administrative Code (NCAC) to meet the requirements of .0503(2), .0504(2),
and .0505 for industrial landfills. The information contained in this plan will be used to assist Duke Energy
Carolinas (Duke) in the closure of the landfill and the maintenance and monitoring required during the
post-closure care period.
1.1 Project Information
The Marshall FGD Landfill consists of Phase1, Cell 1 approximately 17.9 acres of lined area. The general
location of the Marshall FGD Landfill is shown on Figure 1.

2 Closure Plan
The landfill cover system has been designed to reduce infiltration into the landfill and to resist erosion.
The proposed landfill cover system components, size, and closure schedule are described in the following
sections of this report.
2.1 Description of Cover System
The proposed cover system will consist of the following components, from top to bottom:
► 6-inch thick vegetative soil cover;
► 18-inch thick final cover soil;
► Geocomposite drainage layer;
► 40-mil thick double-sided textured linear low density polyethylene (LLDPE) geomembrane; and
► Intermediate soil cover layer (no minimum thickness).

2.1.1 Vegetative Soil Cover
The vegetative soil layer will consist of 6 inches of soil materials capable of sustaining vegetation, which
will promote the integrity of the cover system by resisting erosion.
2.1.2 Final Cover Soil
The final cover soil layer will consist of 18 inches of soil materials. The final cover soil layer will protect
the geosynthetic components of the cover system from exposure.
2.1.3 Geocomposite Drainage Layer
A geocomposite drainage layer will be located beneath the final cover soil layer. The geocomposite will
promote veneer stability and reduce infiltration through the closed landfill by conveying infiltration to
regularly spaced geocomposite outlets.
2.1.4 Geomembrane
A 40-mil thick double-sided textured LLDPE geomembrane barrier will be installed between the
geocomposite drainage layer and the interim cover to minimize infiltration through the closed landfill. The
geomembrane will have texturing on both sides to improve veneer stability.
2.1.5 Intermediate Cover
A 12-inch thick intermediate soil cover will be placed during landfill operations prior to cover system
construction. At the time of final closure, there is no minimum thickness of intermediate cover required.
Closure & Post-Closure Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 2 of 4 May 19, 2016
2.2 Gas Management System
The majority of waste disposed in the Marshall FGD Landfill will consist CCR materials consisting of fly
ash and bottom ash. Based on the nature of CCR materials and our experience, it is not anticipated that
landfill gases such as methane or hydrogen sulfide gas will be generated or that nuisance odors will be an
issue. Therefore, Duke does not propose monitoring for landfill gas or landfill gas management
measures.
2.3 Stormwater Management System
The proposed Marshall FGD Landfill is designed with stormwater conveyances to manage runoff for
active landfill operations, interim closure, and final closure conditions. Upon final closure, stormwater will
be collected by diversion berms and conveyed to a series of slope drains which will discharge to the
perimeter channel system. Plans and details illustrating the stormwater management system are
illustrated in the Engineering Plan drawings.
2.4 Largest Area Requiring Cover System
The proposed Marshall FGD Landfill will be operated until closure. The largest area requiring cover
system construction is the entire footprint of the proposed landfill which is approximately 17.9 acres in
plan area.
2.5 Estimated Maximum Waste Inventory
The proposed landfill design yields approximately 1,170,000 cubic yards of gross capacity as measured
from the top of the protective cover soil to the top of final cover.
2.6 Closure Schedule
Following the completion of waste placement, a final cover system will be constructed. The primary
purpose of a final cover system is to minimize infiltration into the waste. The proposed final cover system
cross section is presented in the Engineering Plan Drawings.
Final closure of the landfill will commence when final design grades are achieved, Duke declares that no
more waste will be accepted, or as directed by the North Carolina Department of Environmental Quality
(NCDEQ) Division of Waste Management – Solid Waste Section (the Division). Duke may elect to close
the landfill incrementally during landfill operations once an area large enough to warrant cover system
construction has reached final grades. Prior to beginning closure of the proposed landfill, the Owner or
Operator shall notify the Division that a notice of intent to close the landfill has been placed in the
operating record.
Closure activities for the landfill shall begin no later than 30 days after final receipt of waste unless
otherwise approved by the Division or, if the landfill has remaining capacity and there is a reasonable
likelihood that the landfill will receive additional wastes, no later than one year after the most recent
receipt of wastes. Extensions beyond the one-year deadline for beginning closure may be granted by the
Division if the Owner or Operator demonstrates that the landfill has the capacity to receive additional
wastes and the Owner or Operator has taken and will continue to take the steps necessary to prevent
threats to human health and the environment from the unclosed landfill.
The final cover system will be finished within 180 days following the beginning of closure activities unless
otherwise approved by the Division. Extensions of the closure period may be granted by the Division if
the Owner or Operator demonstrates that closure will, of necessity, take longer than 180 days and they
have taken and will continue to take the necessary steps to prevent threats to human health and the
environment from the unclosed landfill unit. The final cover system for the closed phase will be certified
by a professional engineer as being completed. Duke Energy shall record a notation on the deed to the
landfill property stating that the property has been used as a landfill and its use is restricted under the
Closure/Post-Closure Plan approved by the Division. The Division will be notified by Duke Energy of the
closure completion, certification, deed notation, and placement of these records into the landfill’s
operating record.
Closure & Post-Closure Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 3 of 4 May 19, 2016
Following cover system construction, the landfill will be vegetated with grass and maintained. If the
landfill must be closed prior to reaching the final contours, the surface of the landfill will be sloped to a
minimum grade of 5 percent and maximum grade of 33.33 percent (3H:1V). A final cover will be
established over the landfill unit being closed. The maximum waste-filled area of the proposed landfill
that would require closure operations at any one time is approximately 17.9 acres in plan area, which is
the entire footprint of the proposed Marshall FGD Landfill.

3 Post-Closure Plan
The Post-Closure Plan outlines the monitoring and maintenance activities intended to maintain cover
system integrity during the post-closure care period. Consistent with the requirements of MSW landfill
rules, the proposed post-closure period is 30 years. During the post-closure period, the landfill cover
system and related facilities must be monitored and maintained.
3.1 Maintenance Activities
Maintenance activities will be conducted as soon as practical to address items of concern identified during
monitoring events. Mowing will occur at a minimum once per year, other maintenance activities will be
performed as needed and are anticipated to include the following:
► Filling in animal burrows and re-locating the animal;
► Localized placement of fill to prevent ponding of water caused by differential settlement;
► Removal of trees or brushy vegetation within the cover system limits;
► Application of seed and soil amendments to maintain a healthy vegetative cover; and
► Repair of stormwater conveyance measures.
Any disturbed areas will be seeded and soil amendments applied as necessary to establish a healthy
vegetative cover.
3.2 Inspection Activities
Post-closure inspection events will be conducted quarterly for the first two years and semi-annually
thereafter during the post-closure care period. Post-closure inspections will include a review of the
following:
► The condition of site security features such as gates and/or fencing;
► Evidence of erosion, settlement, and/or animal burrows within the cover system;
► Type and quality of vegetation within the cover system;
► Evidence of erosion and integrity of stormwater conveyance features; and
► Integrity of the leachate collection and removal system (LCRS).
The inspection events will be documented. The form included in Appendix I may be used. Completed
post-closure inspection forms will be maintained in the facility operating record.
3.2.1 Groundwater and Surface Water Monitoring
Groundwater and surface water monitoring requirements are described in the Water Quality Monitoring
Plan dated May 2016.

Closure & Post-Closure Plan Duke Energy Carolinas, LLC – Marshall Steam Station
Marshall FGD Landfill Terrell, Catawba County, North Carolina

Amec Foster Wheeler Project No. 7810160654 Page 4 of 4 May 19, 2016
3.3 Facility Contact Information
Duke will be responsible for post-closure inspections, maintenance and monitoring. Correspondence
regarding the Marshall FGD Landfill should be directed to:
Duke Energy Carolinas, LLC
Marshall Steam Station
8320 East NC Hwy 150
Terrell, North Carolina 28682
[phone]
System Owner for Landfill Operations
The physical address of the Marshall FGD Landfill is the same as above.
3.4 Anticipated Post-Closure Use
The Marshall FGD Landfill will be vegetated following closure. Site access to the public will remain
restricted throughout landfill closure and the post-closure care period. There are no current anticipated
post-closure uses for the Marshall FGD Landfill. Duke Energy will obtain approval from NCDEQ if a
proposed post-closure use is identified.
3.5 Cost Estimate for Closure and Post-Closure Activities
Preliminary cost estimates for landfill closure and for post-closure care activities are presented in
Appendix II. In accordance with North Carolina Solid Waste Management Rules, Duke Energy Carolinas
provides financial assurance in the form of the Corporate Financial Test. Cost estimates for financial
assurance will be updated annually to incorporate changes to unit costs and changes in closed landfill
area.
3.6 Certification
Consistent with regulations, the end of the closure/post-closure care period must be certified by a
registered professional engineer. To accomplish certification over the required 30-year duration, a
registered professional engineer will prepare annual certifications. The annual certifications will document
that the cover system has been monitored and maintained in accordance with the Post-Closure Plan.
The annual certifications shall be based on observations and results documented on regular post-closure
monitoring reports, maintenance records, and compliance monitoring reports maintained in the Operating
Record.

FIGURES

)
Copyright:© 2013 National Geographic Society, i-cubed
1PROJECT NO:FIGURE NO:7810-16-0654
¯
0 2,0001,000 Feet
NOTE: THIS FIGURE IS FOR REFERENCE ONLY.
LEGEND
)MARSHALL STEAM STATION CELL 1 APPROXIMATE BOUNDARY MARSHALL STEAM STATIONCATAWBA COUNTY, NORTH CAROLINA
SITE MAPCLOSURE AND POST-CLOSURE PLANFGD RESIDUE LANDFILL
F:\AMEC_Projects\2016\7810-16-0654 Marshall\GIS\MXDs\SiteMap.mxd, User: maddison.sutton; Date: 5/3/2016 4:18:07 PM, Checked by: RK Date: 5/03/2016
ÊÊ
PROJECT LOCATION

APPENDIX I

Post-Closure Inspection Form

Date/Time:
Observation Personnel:
Weather/Temperature:
Question No Yes
If yes, 
location Description Corrective Actions 
Recommended
Date 
Corrected
Is there evidence of erosion, 
settlement, rutting, or potholes?
Is there evidence of cover 
system intrusion (ruts, burrows, 
excavation)?
Is there evidence of stressed 
vegetation or bare spots, or 
evidence of woody vegetation 
(small trees and/or shrubs)?
Is there evidence of erosion or 
sedimentation in storm water 
channels, down drain pipes, or 
other stormwater features?
Is there evidence of 
penetrations (poles, posts, 
stakes)?
Is there evidence of human 
encroachment (trash, fire pits, 
tire/footprints)?
General Notes:
Duke Energy Carolinas ‐ Marshall FGD Residue Landfill
Post‐Closure Inspection Form
1 / 1

APPENDIX II

Cost Estimate for Closure and Post-Closure Activities

Quantity Unit Cost1 Total
Final Cover System
Demolition of Interim Cover Measures 17.9 AC 1,000.00$             17,900$           
Fine Grading of Interim Cover 17.9 AC 3,800.00$             68,020$           
Vegetative Layer (6" thick) 14,500 CY 11.00$                    159,500$         
Protective Cover (18" thick) 43,300 CY 5.50$                      238,150$         
Drainage Geocomposite 780,000 SF 0.98$                      764,400$         
40‐mil Text. LLDPE Geomembrane 780,000 SF 0.63$                      491,400$         
Stormwater Management
Erosion Control Bench w/ Toe Drain 6,400 LF 65.00$                    416,000$         
30" Nyoplast Inline Drain 9 EA 1,000.00$             9,000$              
Slope Drains (18" CPP) 1,030 LF 35.00$                    36,050$           
Subsurface Drains 1,600 LF 50.00$                    80,000$           
RCP Headwall 1 EA 2,745.00$             2,745$              
Surveying 17.9 AC 1,400.00$             25,060.00$      
Permanent Vegetative Stabilization 17.9 AC 1,800.00$             32,220.00$      
Subtotal 2,340,445$      
Mobilization (5% of Subtotal)117,022$         
Engineering and CQA (12% of Subtotal)280,853$         
Contingency (15% of Subtotal)351,067$         
TOTAL 3,089,387$       
COST PER ACRE 172,591$         
Notes:
1. Costs are based on 2016 dollars.
May 2016
Table 1
Closure Cost Estimate
Marshall FGD Landfill
Permit No. 1809‐INDUS
Terrell, North Carolina
Quantity Unit Unit Cost1 Annual Cost
Compliance Monitoring Reporting2
Reporting and Administration 1 LS 9,600$      9,600$              
Compliance Monitoring Sampling and Analytical (semi‐annual)2
Groundwater3 9 Well 1,500$       13,500$           
Leachate4 1 Location 500$          500$                 
Maintenance (annual)
Fencing, Gates, Signs, etc. 1 LS 1,000$      1,000$              
Access Roads 1 LS 5,000$      5,000$              
Mowing 17.9 AC 100$         1,790$              
Stormwater Structures 1 LS 5,000$      5,000$              
Leachate Collection Pipe Cleaning and 
Camera Inspection5
Every 5th 
Year Event 5,000$       1,000$              
Groundwater Monitoring Wells 1 LS 4,500$      4,500$              
Final Cover System6 17.9 AC 1,500$       26,850$           
Annual Permit Fee 1 EA 500$         500$                 
Subtotal 69,240$           
Mobilization (5% of Subtotal)3,462$              
Engineering and CQA (12% of Subtotal)8,309$              
Contingency (15% of Subtotal)10,386$           
ANNUAL TOTAL 91,397$           
30‐YEAR TOTAL 2,741,904$      
Notes:
1. Costs are based on 2016 dollars.
2. The sampling, analytical and reporting costs are based on actual 2016 costs.
3. The monitored wells are MS‐8, 9, 10, 11, 12, 13, 14, 15, and 16.
4. Leachate discharge point is monitored.
5. It is assumed that a post‐closure pipe cleaning schedule of every 5 years will be approved.
6. Final cover system maintenance assumes erosion repair and seeding for 25 percent of
     the cover annually.
May 2016
Table 2
Post‐Closure Cost Estimate
Marshall FGD Landfill
Permit No. 1809‐INDUS
Terrell, North Carolina
Quantity Unit Unit Cost1 Annual Cost
Assessment Monitoring Reporting
Reporting and Administration2 1 LS 19,000$        19,000$            
Assessment Monitoring Sampling and Analytical (annual)
Groundwater3,4 9 Well 1,500$          13,500$            
Subtotal 32,500$            
Contingency (15% of Subtotal)4,875$              
ANNUAL TOTAL 37,375$            
30‐YEAR TOTAL 1,121,250$      
REQUIRED MINIMUM 2,000,000$      
Notes:
1. Costs are based on 2016 dollars.
2. The assessment reporting cost is assumed to be twice the cost for routine reporting.
3. The monitored wells are MS‐8, 9, 10, 11, 12, 13, 14, 15, and 16.
4. The assessment sampling and analytical costs are estimated to be twice the routine cost per well. 
May 2016
Table 3
Potential Assessment and Corrective Action Costs
Marshall FGD Landfill
Permit No. 1809‐INDUS
Terrell, North Carolina
To: Duke Energy Carolinas, LLC
Date 7/28/2016
From: Amec Foster Wheeler
Water Quality Monitoring Plan
Revised July 28, 2016
Marshall Flue Gas Desulfurization Residue Landfill,
Phase 1, Cell 1, Permit No. 18-09
Duke Energy – Marshall Steam Station
Terrell, North Carolina
Amec Foster Wheeler Project No. 7810160654
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
MSS FGD Landfill-Permit No. 18-09 Terrell, North Carolina
Amec Foster Wheeler Project No. 7810160654 TOC
Table of Contents
EXECUTIVE SUMMARY...............................................................................................................................................1
1 PROGRAM DESCRIPTION ...................................................................................................................................3
1.1 Scope of Work ...............................................................................................................................................3
1.2 Background and Site Hydrogeological Description .......................................................................................3
1.3 Well Locations and Installation ......................................................................................................................4
1.4 Surface Water Sample Location....................................................................................................................5
1.5 Monitoring Frequency....................................................................................................................................6
1.6 Parameters ....................................................................................................................................................6
1.7 Data Quality Objectives .................................................................................................................................6
2 SAMPLING PROCEDURES...................................................................................................................................6
2.1 Sampling Equipment......................................................................................................................................6
2.1.1 Equipment Cleaning Procedures...............................................................................................................6
2.2 Groundwater Sampling..................................................................................................................................7
2.2.1 Development of Wells................................................................................................................................7
2.2.2 Groundwater Level and Total Depth Measurements.................................................................................7
2.2.3 Well Purging and Sampling........................................................................................................................7
2.2.4 Sample Collection......................................................................................................................................9
2.2.5 Sample Containers, Volume, Preservative, and Holding Time..................................................................9
2.3 Surface Water Sampling..............................................................................................................................10
2.4 Sample Tracking..........................................................................................................................................10
2.5 Sample Labeling ..........................................................................................................................................10
2.6 Field Documentation....................................................................................................................................10
2.7 Chain-of-Custody Record ............................................................................................................................11
2.8 Sample Custody, Shipment, and Laboratory Receipt..................................................................................12
3 ANALYTICAL PROCEDURES.............................................................................................................................12
4 INTERNAL QUALITY CONTROL CHECKS.........................................................................................................12
5 VALIDATION OF FIELD DATA PACKAGE..........................................................................................................13
6 VALIDATION OF LABORATORY DATA..............................................................................................................14
7 REPORT SUBMITTAL .........................................................................................................................................14
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
MSS FGD Landfill-Permit No. 18-09 Terrell, North Carolina
Amec Foster Wheeler Project No. 7810160654 TOC
Tables
Table 1 Monitoring Well Information
Table 1.1 Surface Water Sample Location
Table 2 Sample Parameters and Analytical Methods
Table 3 Sample Containers, Preservatives, and Holding Times
Figures
Figure 1 Site Location Map
Figure 2 Sample Locations
Figure 3 Typical Monitoring Well Construction Details
Figure 4 Groundwater Monitoring Data Sheet
Figure 5 Field Sampling Calibration Form
Figure 6 Chain-of-Custody Form
Figure 7 Groundwater Sampling Site Checklist
Appendix
Appendix A Monitoring Well Construction Records
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
MSS FGD Landfill-Permit No. 18-09 Terrell, North Carolina
Amec Foster Wheeler Project No. 7810160654 Page 1 of 14
Executive Summary
The following Water Quality Monitoring Plan (WQMP) – Revised July 28, 2016, represents the
second 5-year update to the WQMP for the Duke Energy (Duke) Flue Gas Desulfurization
(FGD) Residue Landfill at Marshall Steam Station.
The original WQMP was approved in November 2006. The current WQMP (the first 5-year
update) was prepared by Altamont Environmental, Inc. (Altamont) and titled Groundwater
Sampling and Analysis Plan, dated August 19, 2011.
The current Permit to Operate is scheduled to expire on November 21, 2016. As part of the
permit amendment (renewal), Amec Foster Wheeler was requested to review and update the
current WQMP as needed per the requirements stated in 15A NCAC 13B .0504 (1)(g)(iv).
The water quality monitoring network remains unchanged for the Marshall FGD Landfill facility
since the last update; therefore, the overall content of the current WQMP remains relevant and
applicable. In general, Amec Foster Wheeler retained Altamont’s 2011 plan content and
organization for this WQMP update with the exception of the following revisions:
Minor text edits, primarily changing absolute terms to qualifier terms
Updated Department of Environment and Natural Resources (DENR) references to
Department of Environmental Quality (DEQ)
Table 1 total depths for MS-8 and MS-16 were revised to reflect the bottom of the well
and not the bottom of the borehole.
Table 2 detection limits column was removed since it is lab-specific. Detection limits
are generally specified by the analytical methods which are still listed.
Table 2 dissolved oxygen (DO) and oxidation reduction potential (ORP) rows were
added under in situ parameters.
Table 2 analytical method for in situ parameters was changed to “Multi-Parameter
Water Quality Meter” and “Turbidimeter” as appropriate instead of listing a specific
brand of equipment.
Table 2 units were changed for chloride, fluoride, nitrate, sulfate, and total dissolved
solids from micrograms per liter to milligrams per liter, which is the more common
laboratory reporting format for those parameters.
Table 2 and 3 parameters Antimony, Beryllium, Thallium, and Vanadium were added
as requested in a Permit to Operate Renewal Application letter from the North Carolina
Department of Environmental Quality (DEQ), Division of Waste Management (DWM),
Solid Waste Section (SWS) dated June 17, 2016.
Table 2 and 3 parameter Cobalt was added as requested in an email to Mr. Mark
Shumpert of Amec Foster Wheeler from Ms. Tyler Hardin of Duke Energy dated July
19, 2016.
Table 3 ORP row added under in situ parameters.
Table 3 holding times corrected from 6 months to 28 days for mercury and fluoride.
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
MSS FGD Landfill-Permit No. 18-09 Terrell, North Carolina
Amec Foster Wheeler Project No. 7810160654 Page 2 of 14
Replaced Duke Energy Field Sampling Forms, as provided by Duke (Figures 4
through 7)
Revised report submittal timeframe from within 90 days post-sampling to within 120
days post-sampling to be consistent with requirement stated in the facility’s Permit to
Operate.
Amec Foster Wheeler included Figures 1 through 3 and Appendix A as unrevised from
Altamont’s 2011 WQMP.
Courtney W. Murphy, P.G.
Amec Foster Wheeler
NC Geology Firm License C-247
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
MSS FGD Landfill-Permit No. 18-09 Terrell, North Carolina
Amec Foster Wheeler Project No. 7810160654 Page 3 of 14
1 Program Description
1.1 Scope of Work
This Water Quality Monitoring Plan (WQMP) is designed to guide the monitoring efforts that are
used to evaluate the effects of the Marshall Steam Station (Marshall) Flue Gas Desulfurization
(FGD) Residue Landfill, Phase 1, Cell 1, on the groundwater in the area. This plan has been
prepared according to the guidelines set forth by the North Carolina Department of
Environmental Quality (DEQ) Water Quality Guidance Document for Solid Waste Facilities (SW-
1001-87), and by the Environmental Protection Agency (EPA) in "Interim Guidelines and
Specifications for Preparing Quality Assurance Plans" (QAMS-500/80), and documents the
methodologies of field sampling, record-keeping protocols, data quality objectives, and data
validation procedures that will be used in this program.
1.2 Background and Site Hydrogeological Description
Marshall Steam Station (Marshall) is located in Catawba County, on Highway NC 150, just
west of Lake Norman. The station is owned and operated by Duke Energy Carolinas, LLC
(Duke). Marshall is located in the Piedmont physiographic region. Figure 1 shows the
location of the plant and the location of the FGD landfill, Phase 1, Cell 1.
The Marshall Steam Station has a generating capacity of 2,090 megawatts (MW) of electric
power by the combustion of coal. Therefore, the Marshall station generates enough
electricity to power over one-and-a- half million homes.
The FGD Residue Landfill will consist of two cells. When completed, the landfill footprint
will contain approximately 31.9 acres. Construction of Cell 1 was completed in 2006, and
a Permit to Operate was issued on November 21, 2006. Duke has not requested a Permit
to Construct for Cell 2.
Cell 1 has a footprint of approximately 14.8 acres. In general the landfill is permitted to
receive industrial wastes generated by Duke at Marshall and at other Duke facilities. The
waste received at the FGD residue landfill consists primarily of gypsum. The FGD residue is
conveyed to the landfill site by truck, where the material is spread and compacted.
The landfill was constructed with a leachate collection and removal system and an engineered
liner system to prevent impacts to groundwater. When closed, the completed landfill will
receive an engineered cover system to reduce infiltration.
The FGD landfill is located entirely on Duke property, northwest of the Marshall Station and to
the west of the Marshall Ash Basin. The landfill is located to the east of a north-south trending
railroad line. . Located to the west of this railroad line is Sherrill’s Ford Road, which also runs
north-south along a surface water divide. Located between the landfill footprint and the railroad
line is a surface water drainage feature. This feature drains to the south, to an intermittent
stream that drains to Lake Norman. There is a topographic divide running north-northwest
through the landfill footprint, along Steam Plant Road. Surface drainage to the west of Steam
Plant Road drains to the surface drainage feature and surface drainage to the east of Steam
Plant Road drains to the Marshall Ash Basin.
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
MSS FGD Landfill-Permit No. 18-09 Terrell, North Carolina
Amec Foster Wheeler Project No. 7810160654 Page 4 of 14
As described in the site hydrogeological study (Hydrogeological Study FGD Scrubber
Landfill, Duke Power-- Marshall Steam Station, Terrell, North Carolina, S&ME Project No:
1264-02-578, May 30, 2003), the subsurface conditions in the landfill area consist of
residual soils and partially to fully weathered rock (saprolite) , which have formed by the in-
place weathering of the parent rock. As is typical in the groundwater systems located in the
Piedmont region, groundwater at the landfill site occurs within the residuum and saprolite
under unconfined aquifer conditions. The predominant discharge areas for groundwater in
the landfill area are expected to be the drainage feature and the ash basins located to the
east of the landfill.
The subsurface conditions at the landfill were described by S&ME as follows:
Residuum: Beneath the ground surface, residual material consisting of silts, silty clays,
clayey silts, and silty sands. Sandy silts were found at depths ranging from 2.5 to 14
feet below ground surface.
Saprolite: Saprolite material was found at depths ranging from 13.5 feet to 68.5 feet
below ground surface. This material is a product of weathered bedrock, consisting of
silts to clayey silts and sandy silts to silty sands, having a Standard Penetration Test
(SPT) resistance of 50 blows per foot or more.
Partially Weathered Rock: This material is defined as material exhibiting SPT
resistances in excess of 100 blows per foot. This material was found at depths ranging
from 25.5 feet to 90 feet below ground surface.
Bedrock: Bedrock was found at depths ranging from 25.5 feet to 79.5 feet. When
sampled, this material was classified as granite, schist, and gneiss. Horizontal to high-
angle fractures were found in the upper ten feet of the bedrock areas. Many fractures
were found to be iron stained, indicating flow of water into the fractures.
1.3 Well Locations and Installation
Groundwaterandsurfacewater conditionsat the landfill aremonitoredusingninegroundwater
monitoring wells and one surface water sampling location. Monitoring well locations and
construction information are provided in Table 1. The locations of these wells are shown on
Figure 2. Monitoring well MS-8 will be used as the backgroundwell for this sampling program.
The wells were constructed of two-inch diameter polyvinyl chloride (PVC) well screen and
casing. The well screens were placed where they would intercept the aquifer and have slot
sizes of 0.010 inch. The screen lengths are shown in Table 1.
The wells were installed by a well driller registered in North Carolina in accordance with
applicable DEQ regulations. The locations of the wells and the elevations of the tops of the
casings were surveyed under the direction of a Professional Surveyor, licensed in North
Carolina. Figure 3 shows a typical construction diagram for the wells. Each well is equipped
with dedicated bladder- type pump systems. Well construction records for the existing wells
are included in Appendix A. A brief description of the monitoring locations and their
monitoring function is provided below.
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
MSS FGD Landfill-Permit No. 18-09 Terrell, North Carolina
Amec Foster Wheeler Project No. 7810160654 Page 5 of 14
Monitoring Well MS-8—BackgroundWell
Monitoring well MS-8 will be used as a background monitoring well. This well is located
approximately 250 feet north of the landfill, on the west side of Steam Plant Road. This well
is screened to monitor groundwater in the saprolite layer.
Monitoring Well MS-9
This existing well is located north of the landfill. This well is screened to monitor groundwater
in the saprolite layer.
Monitoring Well MS-10
This well is located west of the landfill. This well is screened to monitor groundwater in the
saprolite layer.
Monitoring Well MS-11
This well is located west of the landfill. This well is screened to monitor groundwater in the
saprolite layer.
Monitoring Well MS-12 (Formerly Designated as Well OW-3)
This well is located south of the landfill. This well is screened to monitor groundwater in the
saprolite layer.
Monitoring Well MS-13 (Formerly Designated as Well MS-6)
This well is located south of the landfill. The well is screened to monitor groundwater in the
saprolite layer.
Monitoring Well MS-14 (Formerly Designated as Well B-5)
This well is located to the southeast of the landfill. This well is screened to monitor
groundwater in the saprolite layer.
Monitoring Well MS-15 (Formerly Designated as Well B-4)
This well is located to the east of the landfill. This well is screened to monitor groundwater
in the saprolite layer.
Monitoring Well MS-16
This well is located to the northeast of the landfill. This well is screened to monitor
groundwater in the saprolite layer.
1.4 Surface Water Sample Location
A surface water sample will be collected from location SW-1. This surface water sampling
location is located south of the landfill, between wells MS-12 and MS-13, as shown on Figure 2.
The North Carolina State Plane coordinates and elevation for this sampling location are shown
in Table 1.1.
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
MSS FGD Landfill-Permit No. 18-09 Terrell, North Carolina
Amec Foster Wheeler Project No. 7810160654 Page 6 of 14
1.5 Monitoring Frequency
The wells and surface water sample location will be sampled semiannually in March and
September.
1.6 Parameters
The parameters to be sampled and analyzed, units of measure, and analytical methods are
presented in Table 2.
1.7 Data Quality Objectives
The overall Quality Assurance (QA) objective is to provide reliable data of known and
acceptable quality. Measurements will be documented to yield results that are representative
of the groundwater and surface water quality. Data will be calculated and reported in units as
required by DEQ.
The analytical QA objectives for precision, accuracy, and completeness have been
established by the laboratories in accordance with EPA or other accepted agencies for each
measurement variable, where possible. The objectives are outlined in the Duke Energy
Analytical Laboratory Procedures Manual and are available upon request.
Detection limits for the water analyses are generally specified by the analytical method. As
stated above, appropriate methods have been selected to meet applicable standards for
groundwater quality. Instances may occur, however, in which the condition of the sample may
not allow detection of the desired limits for various parameters either because of matrix
interference or elevated analyte concentrations requiring sample dilution. The laboratory(s) will
provide sufficient documentation with each data package to notify reviewers about any analytical
issues with the data, if needed.
2 Sampling Procedures
2.1 Sampling Equipment
Development, purging, and sampling equipment are selected so that materials are compatible
with the sample parameters and comply with state and federal regulatory requirements for
sampling. Positive-gas- displacement fluorocarbon resin bladder pumps are installed in each
monitoring well and are dedicated purging and sampling systems.
2.1.1 Equipment Cleaning Procedures
Dedicated sampling equipment has been installed in each monitoring well. In the event non-
dedicated equipment is used between wells, equipment will be cleaned before and after use in
each well in accordance with standard EPA-approved cleaning procedures for field equipment.
This standard is outlined in the Standard Operating Procedures and Quality Assurance Manual,
Engineering Support Branch, EPA Region IV, February 1, 1991.
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MSS FGD Landfill-Permit No. 18-09 Terrell, North Carolina
Amec Foster Wheeler Project No. 7810160654 Page 7 of 14
2.2 Groundwater Sampling
2.2.1 Development of Wells
Each of the nine wells addressed in this WQMP have been developed. If new wells are
installed they will be developed before they are sampled.
After installation of new wells, and prior to initial sampling, the monitoring wells will be
developed. Development reduces silt that has settled into the bottom of the well following
installation, and reduces fine silt and clay particles from the well screen and sandpack
surrounding the screen. Well development is performed to reduce potential for clogging and
promote well performance. Development involves removing an estimated ten or more well
volumes from the well using a positive-gas-displacementfluorocarbon resin bladder pump with
up-and-down agitation to loosen particles from the well screen. After development of a well, a
true well depth is recorded, referenced to the top of well casing (TOC).
2.2.2 Groundwater Level and Total Depth Measurements
Water level measurements are collected and recorded to determine the groundwater
elevations, determine groundwater flow direction, and to calculate the volume of standing
water in the well. Each monitoring well has been surveyed to determine the elevation of the
TOC. Total well depth and water level measurements are referenced to the TOC and
recorded to the nearest one-hundredth of a foot.
Water level measurements are collected with an electronic measuring device consisting of a
spool of dual conductor wire and sensor. When the sensor comes in contact with water, the
circuit is closed and a meter light and/or buzzer is attached to the spool to signal the contact.
The sensor is lowered further until it rests on the bottom of the well to determine the total depth
of the well reference to the TOC. The depth and water level measurements are used to verify
that the well has not filled with silt and to calculate the volume of water in the well. The volume
of well water (in gallons) is calculated using the following equation:
V=h*πr2 * (7.48052 gal/ft
3)
where V = volume of water in the well screen and casing (gallons)
h = height of standing water (feet) = total well depth – water level
r = radius of well casing (feet)
In dedicated sampling systems, an accurate well depth is determined, as indicated above, after
development of the well and prior to installation of the dedicated bladder pump. The well
depth, water level measurement,and calculated well volume are recorded on the Groundwater
Monitoring Data Sheet (Figure 4).
2.2.3 Well Purging and Sampling
The selection of purging technique is dependent on the hydrogeologic properties of the aquifer
and hydraulic characteristics of each well. Hydraulic conductivity, water column, well volume,
screen length, and other information are evaluated to select the purging technique to acquire
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
MSS FGD Landfill-Permit No. 18-09 Terrell, North Carolina
Amec Foster Wheeler Project No. 7810160654 Page 8 of 14
groundwater representative of the aquifer conditions. The Groundwater Monitoring Data Sheet
(Figure 4) is used to record purging methods and measurements.
A multi-parameter water quality monitoring instrument is used to measure field stabilization or
indicator parameters for determining representative groundwater during purging. These
instruments measure pH, specific conductance, temperature, dissolved oxygen (DO), and
oxidation-reduction potential (ORP). Instrument calibration must be performed and
documented before and after each sampling event. The pH subsystem will be calibrated with
two pH standards (pH 7.0 and 4.0) bracketing the expected groundwater pH. The specific
conductance subsystem will be calibrated using two standards bracketing the expected
groundwater conductivity. Calibration results will be recorded on a Field Sampling Calibration
Form (Figure 5).
Various well purging techniques are described below. Currently, each well is fitted with
dedicated pumps. The purging method utilized at any particular well will be selected after
considering the characteristics of the well and the purging method(s) used during previous
sampling events.
Conventional Purging
This technique entails removing one equivalent well volume and measuring the indicator
parameters (temperature, pH, and specific conductance). When the parameters have stabilized
to within ±0.2 pH units and ±10% for temperature and conductivity over three to five well
volumes, representative groundwater has been achieved for sampling. It is acceptable to begin
sampling after five complete well volumes have been removed, even when indicator parameters
have not stabilized. Groundwater is pumped into a graduated container to measure the volume
of water purged. Under normal rates of recovery, samples should be collected immediately after
purging, in accordance with EPA guidelines.
For low-yield wells, incapable of yielding three to five well volumes in a reasonable amount of
time (e.g., 2 hours or less), groundwater is purged to the elevation of the pump intake while
measuring indicator parameters. Typically, low-yield wells are evacuated to dryness one
time and sampled when sufficient water level recovery occurs.
Low-Flow Purging
Low-flow purging and sampling are appropriate when the recharge rate of the well
approximates or equals the discharge rate of the pump with minimal drawdown of the water
column (≤1 foot).
During low-flow purging and sampling, groundwater is pumped into a flow-through chamber at
flow rates that stabilize water level drawdown within the well. Indicator parameters are
measured over time (usually at five-minute intervals). When parameters have stabilized within
±0.2 pH units and ±10% for temperature, conductivity, and DO, and ±10 milli-Volts (mV) for
ORP over three consecutive readings, representative groundwater has been achieved for
sampling. Turbidity is not included as a stabilization parameter, but turbidity levels of 10
nephelometric turbidity units (NTU) or less should be targeted.
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
MSS FGD Landfill-Permit No. 18-09 Terrell, North Carolina
Amec Foster Wheeler Project No. 7810160654 Page 9 of 14
Modified Low-Flow Purging
This technique is considered a viable option particularly in the Piedmont region due to clay
soils where water level drawdown cannot be stabilized while pumping.
When the well recharge rate is less than the pump discharge rate, excessive drawdown (> 1
foot) of the water column occurs and mixes with stagnant water located above the screened
interval. One equivalent well volume is removed initially before measuring indicator parameters.
Frequently, removal of the initial well volume reduces the hydraulic head and allows for matching
of the recharge rate with the pumping rate, providing stabilization of drawdown. Indicator
parameters should be measured, at five-minute intervals, using a flow-through chamber attached
to a multi-parameter water quality instrument.When parameters have stabilized to within ±0.2
pH units, ±10% for temperature, conductivity, and DO, and ±10 mV for ORP over three
consecutive readings, representative groundwater has been achieved for sampling. Turbidity is
not included as a stabilization parameter, but turbidity levels of 10 NTU or less should be
targeted.
Very Low Yield Well Purging
This technique provides the best option for wells that historically purge to dryness and do not
sufficiently recharge to provide adequate volume for sample collection. The volume of the
pumping system (i.e., the pump bladder, tubing, and flow-through chamber) is calculated for
removal. Two volumes will be removed by the pumping system if pumping occurs at the lowest
possible rate (≤100 milliliters per minute [mL/min]). Indicator parameters will be measured and
recorded initially, and then sample collection will begin.
2.2.4 Sample Collection
After representative groundwater has been obtained by purging and the indicator parameters
have stabilized,sampling may begin. Sampling personnel must wear new, clean, disposable,
non-powdered latex or nitrile gloves during sample collection for each well. Samples are
collected in the following order:
Metals
Sulfate and chloride
Nitrate
Total dissolved solids
Pertinent notations, water-level measurements, removed well volumes, and indicator
parameters are documented on the Groundwater Monitoring Data Sheet.
2.2.5 Sample Containers, Volume, Preservative, and Holding Time
Sample containers supplied by the laboratory for the collection of groundwater samples shall be
new and precleaned, as approved by EPA procedures appropriate for the parameters of
interest. Table 3 summarizes the sample containers, sample volume, preservation procedures,
and holding times required for each type of sample and parameter. Sample containers are kept
closed until used. Sample containers are provided by Duke or vendor laboratories.
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
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Amec Foster Wheeler Project No. 7810160654 Page 10 of 14
2.3 Surface Water Sampling
Surface water samples are collected using techniques and equipment that provide
representative characteristics of the water body being investigated and reduces the chance for
sample contamination. Typically, samples are collected by grab or peristaltic pump.
When filling a sample container by grab, use new, clean, non-powdered latex or nitrile gloves.
Grasp the sample container by the lower half and position the container opening to face
upstream. When using a peristaltic pump to collect a surface water sample, position the intake
opening above the stream bottom to reduce the potential for collecting sediment. Run the pump
for several minutes so that representative water is being collected after positioning the intake
opening.
2.4 Sample Tracking
The Chain-Of-Custody (COC) program allows for tracing the possession and handling of
individual samples from the time of field collection through laboratory analysis and report
preparation. Samples are pre-logged prior to sample collection. This process assigns a unique
tracking number for each sample and generates corresponding labels. An example of the COC
Record is provided as Figure 6.
2.5 Sample Labeling
Sample containers are pre-labeled and organized prior to field activities as part of the pre-
sampling staging process. As samples are actually collected, the sampling personnel write the
following information directly on the label: sampling date and time, and initials of sample
collector. This information is also recorded on the Groundwater Monitoring Data Sheet (Figure
4) and the COC Record (Figure 6).
2.6 Field Documentation
Field documentation from each sampling event is recorded on the Groundwater Monitoring Data
Sheets, the Field Sampling Calibration Form, and the Chain-of-Custody Record. These sheets
are arranged in sequential order and filed by project and date. Additionally, a Groundwater
Sampling Site Checklist (Figure 7) is completed indicating information of the monitoring well
such as proper identification (ID) tag, condition of protective casing and pad. Field notations are
made during the course of the field work to document the following information:
Identification of well
Well depth
Static water level depth and measurement technique
Presence of immiscible layers and detection method
Well yield—high or low
Purge volume or pumping rate
Sample identification numbers
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
MSS FGD Landfill-Permit No. 18-09 Terrell, North Carolina
Amec Foster Wheeler Project No. 7810160654 Page 11 of 14
Well evacuation procedure/equipment
Sample withdrawal procedure/equipment
Date and time of collection
Types of sample containers used
Identification of replicates or blind samples
Preservative(s) used
Parameters requested for analysis
Field analysis data and methods
Sample distribution and transporter
Field observations during sampling event
Name of sample collector(s)
Climatic conditions including estimate of air temperature
Recorded entries are made in indelible ink. Errors should be corrected by drawing one line
through the error, initialing and dating the correction, and starting a new entry on the next line (if
necessary).
2.7 Chain-of-Custody Record
The chain-of-custody (COC) Record (Figure 6)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 record includes
the following types of information:
Sample identification number
Signature of collector
Date and time of collection
Sample type (e.g., groundwater, immiscible layer)
Identification of well
Number of containers
Parameters requested for analysis
Preservative(s) used
Signature of persons involved in the chain of possession
Inclusive dates of possession
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
MSS FGD Landfill-Permit No. 18-09 Terrell, North Carolina
Amec Foster Wheeler Project No. 7810160654 Page 12 of 14
2.8 Sample Custody, Shipment, and Laboratory Receipt
For the purpose of these procedures, a sample is considered in custody if it is:
In actual possession of the responsible person
In view, after being in physical possession
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 the sampling crew during the sampling event. At the
end of each sampling day and prior to the transfer of the samples off-site, COC entries are
completed on the COC for each sample. Upon transfer of custody, the COC form is signed by a
sampling crew member, including the date and time. If outside vendor laboratories are utilized,
samples are delivered to these facilities by Duke personnel or courier.
COC forms received by the laboratory(s) are signed and dated by the respective supervising
scientist(s) or their designee (at the Duke Energy lab), or the laboratory sample custodian (at
vendor labs) immediately following receipt by the laboratory.
The analysts at the laboratory(s) maintain a sample-tracking record that will follow each
sample through each stage of laboratory processing. The sample tracking records show the
date of sample extraction or preparation, and analysis. These records are used to determine
compliance with holding time limits during lab audits and data validation.
Custody procedures followed by Duke laboratory personnel are described in detail in the Duke
Energy Laboratory Services Procedures Manual.
3 Analytical Procedures
The main analytical laboratory used in this program is the Duke Energy Laboratory Services
Laboratory, which has North Carolina Drinking Water (NC37804) and Wastewater (#248)
Certifications. The organizational structure and staff qualifications of the laboratory are
discussed in its generic Quality Assurance Program (QAP). The QAP and Laboratory
Services Procedures Manual are available for review upon request.
Vendor laboratories that meet EPA and North Carolina certification requirements may be used
for analyses which cannot be performed in-house.
The analytical procedures are listed in Table 2. Indicator parameters are measured in the field
according to:Duke Energy Scientific Services Section Quality Assurance Plan and Procedure
3210.X.1
4 Internal Quality Control Checks
Internal laboratory quality control (QC) checks used by the laboratories are described in their
generic QAP and procedures manual. The laboratories demonstrate the ability to produce
acceptable results using the methods specified.
1 “X” indicates the most current version of the procedure
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
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Amec Foster Wheeler Project No. 7810160654 Page 13 of 14
Internal quality control checks for sampling procedures and laboratory analyses will be
conducted with each sampling event. These checks will consist of the preparation and submittal
of field blanks, trip (travel) blanks,and/or field replicates for analysis of each parameter at
frequencies described in the laboratory(s) procedures manuals. Equipment rinsate blanks for
laboratory-cleaned equipment will be collected quarterly.
The field QC blanks and replicates may be included as internal QC checks are described as
below. The specific type and number of blanks used may vary depending on the sampling event
and will be determined by the Duke 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.
Trip Blanks: A trip (travel) blank is a sample container filled with organic-free water in
the laboratory that travels unopened with the sample bottles. It 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 each 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.
Equipment Blanks: If non-dedicated equipment is used between wells, it is
recommended that equipment blanks be collected. The field equipment is cleaned
following documented cleaning protocols. An aliquot of the final control rinse water is
passed over the cleaned equipment directly into a sample container and submitted for
analyses.
5 Validation of Field Data Package
The field data package includes complete field records and measurements developed by the
sampling team personnel. The field data package validation procedure consists of the
following:
A review of field data contained on the Groundwater Monitoring Data Sheet for
completeness
Verification that equipment blanks, field blanks, and trip blanks were properly prepared,
identified, and analyzed
A check of the Field Sampling Calibration Form for equipment calibration and
instrument conditions
Water Quality Monitoring Plan – July 28, 2016 Duke Energy – Marshall Steam Station
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Amec Foster Wheeler Project No. 7810160654 Page 14 of 14
A review of the Chain-Of-Custody Record for proper completion, signatures of field
personnel and the laboratory sample custodian, dates, and for verification that the
correct analyses were specified.
6 Validation of Laboratory Data
The laboratory will perform a validation review of the submitted samples and analytical results to
check that the laboratory QA/QC requirements are acceptable.
7 Report Submittal
A report of monitoring results will be submitted to the DEQ Division of Waste Management
(DWM) within 120 days following the date of sampling. The report submittal will consist of the
following:
Environmental Monitoring Reporting Form (DEQ Form)
Table of Detections and Discussion of 2L Exceedances
Groundwater Elevation Contour Map
Electronic Data Deliverable (EDD) in Excel Format
DEQ will be notified in the event that vendor lab analyses have not been completed within this
time frame. The Groundwater Monitoring Data Sheet, Field Calibration Forms, Chain-of-
CustodyRecords, Laboratory(s) QA data, and Data Validation Checklists are kept on file by
Duke and are available upon request.
FIGURES
APPROXIMATE
LANDFILL
BOUNDARY
LAKENORMAN
HIGHWAY NC 150

1000 2000

0 1000




ALTAMONT ENVIRONMENTAL,INC.



Notes:
1. Source: USGS Topographic Map - Lake Norman NorthQuadrangle. Created 1993.2. Map does not reflect realignment of Steam Plant Road.


1



Typical Well Construction Details
(no scale)


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

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
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









3



ALTAMONT ENVIRONMENTAL,INC.

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
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WEATHER CONDITIONS:
DATE: TIME: DATE: TIME:
Calibation Instrument Standard Instrument Standard
Standard Value Value Value Value
SS 0.0 ŷ/ŷŹ 0.0 0.0 ŷ/ŷŹ 0.0
SS ŷŷŹ 227 ŷŷŹ 227
SS ŷ/ŷŹ 75 ŷ/ŷŹ 75
SS ŷ/ŷŹ 1410 ŷ/ŷŹ 1410
B (7.00)ŷŷŹ 7.13 ŷŷŹ 7.13
B (4.00)ŷŷŹ 4.01 ŷŷŹ 4.01
B (10.00)ŷ/ŷŹ 10.24 ŷ/ŷŹ 10.24
0.00 0.00
pH Check B (7.00)ŷŷŹ 7.13
Time:0.00
ŷŷŹ 489 ŷ/ŷŹ 489
N/A ŷ/ŷŹ N/A N/A ŷ/ŷŹ N/A
Zobell's 0.00 0.00
TEMP (CO)
BP (mmHg)
COND
100 % mg/L ŷŷŹ -0.09 ŷŷŹ -0.09
After Cal
LCS
LCSD
SS ŷ/ŷŹ ŷ/ŷŹ
NIST N/A ŷ/ŷŹ N/A N/A ŷ/ŷŹ N/A
KEY:
NOTES:
SS = Standard solution AW = Average Winkler ŷ/ŷŹ= Not Adjusted To
(mmHg)
B = Buffer W = Winkler ŷŷŹ = Adjusted To N/A = Not Applicable
Replaced DO electrolyte See Notes
Field Barometric Pressure
Beginning BP (mmHg) Ending BP
Tested - OK See Notes Tested - OK See Notes
Dissolved Oxygen Subsystem
Replaced Teflon Membrane Cleaned Electrode
Tested - OK See Notes
Oxidation Reduction Subsystem Temperature Subsystem
Cleaned Electrode Cleaned Electrode
Tested - OK Replaced ref Electrode KCL
See Notes Replaced Ref. Electrode Tip
INSTRUMENT MAINTENANCE DATE / TIME
Conductance Subsystem pH Subsystem
Cleaned Electrodes Cleaned Electrodes
Temp Cert Device #
TEMP
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Adjustment Not Available Adjustment Not Available
TURB
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DO
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ORP Temp. ORP Temp.
ORP
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Buffer Temp. Buffer Temp.
pH
(units)
Specifc conductance checkpoint (used if sampled well is outside of initial calibration range).
SPEC. COND.
CHECK (uS/cm)
SPEC. COND.
(uS/cm)
INSTRUMENT ZEROED INSTRUMENT ZEROED
Parameter Calibration Results Calibration Results
CALIBRATION BP (mmHg)0.00 CALIBRATION BP (mmHg)0.00
COLLECTORS: SURFACE UNIT SERIAL #:
ANALYZER MODEL#:
Calibration Date / Time
PROCEDURE #:HYDROLAB 3210.6 VALIDATED BY:
FIELD SAMPLING CALIBRATION FORM
STUDY:
DATE (s): SURFACE UNIT READER:
OTHER EQUIPMENT:TURBIDIMETER NO.2 - 3260-GW
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TABLES
MS
-
8

M
S
-
9

M
S
-
1
0

M
S
-
1
1

M
S
-
1
2

M
S
-
1
3

M
S
-
1
4

M
S
-
1
5

M
S
-
1
6
Pr
e
v
i
o
u
s

W
e
l
l

N
a
m
e

N
/
A

N
/
A

N
/
A

N
/
A

O
W
-
3

M
S
-
6

B
-
5

B
-
4

N
/
A
No
r
t
h
i
n
g

6
8
0
,
7
1
7
.
8
9

6
8
1
,
3
8
4
.
4
5

6
8
1
,
0
2
7
.
6
5

6
8
0
,
2
9
7
.
4
9

6
7
9
,
5
4
0
.
0
4

6
7
9
,
7
3
2
.
8
0

6
7
9
,
9
6
8
.
4
1

6
8
0
,
4
2
8
.
0
2

6
8
1
,
1
4
3
.
0
2
Ea
s
t
i
n
g

1
,
4
1
2
,
0
2
7
.
9
8

1
,
4
1
2
,
1
8
1
.
7
4

1
,
4
1
1
,
6
2
2
.
4
6

1
,
4
1
1
,
5
6
4
.
8
2

1
,
4
1
2
,
0
8
6
.
5
0

1
,
4
1
2
,
5
0
0
.
6
8

1
,
4
1
3
,
1
2
3
.
8
9

1
,
4
1
2
,
9
9
3
.
2
7

1
,
4
1
2
,
4
8
6
.
1
9
Ty
p
e

o
f

C
a
s
i
n
g

P
V
C

P
V
C

P
V
C

P
V
C

P
V
C

P
V
C

P
V
C

P
V
C

P
V
C
To
p

o
f

C
a
s
i
n
g

E
l
e
v
a
t
i
o
n

(
f
t
)

8
7
2
.
3
4

8
6
8
.
0
4

8
5
1
.
2
9

8
5
9
.
7
8

8
3
5
.
6
6

8
4
1
.
9
0

8
4
4
.
0
7

8
6
1
.
4
7

8
3
6
.
9
8
Well D
i
a
m
e
t
e
r

(
i
n
c
h
e
s
)

2
2
2
2
2
2
2
2
2
We
l
l

S
t
i
c
k
-
u
p

(
f
t
-
a
g
s
)

3

2
.
6
8

3

2
.
9
1

2
.
9
6

2
.
7
1

2
.
8
0

3
.
0
5

3
Total D
e
p
t
h

(
f
t
-
b
g
s
)

4
8
5
0
2
0
3
9
2
7
3
8
4
1
5
9
3
4
Sc
r
e
e
n

L
e
n
g
t
h

(
f
t
)

1
0

1
0

1
0

1
0

1
0

1
0

1
0

1
0

1
0
Sc
r
e
e
n

I
n
t
e
r
v
a
l

(
f
t
-
b
g
s
)

3
8

t
o

4
8

4
0

t
o

5
0

1
0

t
o

2
0

2
9

t
o

3
9

1
7

t
o

2
7

2
8

t
o

3
8

3
1

t
o

4
1

4
9

t
o

5
9

2
4

t
o

3
4
No
t
e
s
:
As
-
b
u
i
l
t

w
e
l
l

c
o
o
r
d
i
n
a
t
e
s

a
n
d

t
o
p

o
f

P
V
C

c
a
sin
g

e
l
e
v
a
t
i
o
n
s

p
r
o
v
i
d
e
d

b
y

D
u
k
e

E
n
e
r
g
y
We
l
l

d
e
p
t
h

a
n
d

s
c
r
e
e
n

i
n
f
o
r
m
a
t
i
o
n

w
a
s

o
b
t
a
i
n
e
d

f
r
o
m

t
h
e

W
e
l
l

C
o
n
s
t
r
u
c
t
i
o
n

R
e
c
o
r
d
s
Co
o
r
d
i
n
a
t
e
s

a
r
e

N
C

S
t
a
t
e

P
l
a
n
e

G
r
i
d
,

N
A
D
8
3
SW
-
1
El
e
v
a
t
i
o
n
s

a
r
e

N
A
V
D
8
8







67
9
,
6
1
1
.
0
0

N
/
A

=

N
o
t

A
p
p
l
i
c
a
b
l
e







1,
4
1
2
,
3
4
1
.
3
0
ft

=

f
e
e
t


















82
2
.
3
0
ft
-
a
g
s

=

f
e
e
t

a
b
o
v
e

g
r
o
u
n
d

s
u
r
f
a
c
e
ft
-
b
g
s

=

f
e
e
t

b
e
l
o
w

g
r
o
u
n
d

s
u
r
f
a
c
e
Ta
b
l
e

1
Mo
n
i
t
o
r
i
n
g

W
e
l
l

I
n
f
o
r
m
a
t
i
o
n
Ta
b
l
e

1
.
1
Su
r
f
a
c
e

W
a
t
e
r

S
a
m
p
l
e

L
o
c
a
t
i
o
n
PARAMETER UNITS ANALYTICAL METHOD
In Situ Parameters
Field pH pH Units Multi-Parameter Water Quality Meter
Field Specific Conductance μmhos/cm Multi-Parameter Water Quality Meter
Field Temperature
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 ft Water Level Meter
Laboratory Analyses
Antimony μg/L EPA 200.7/EPA 6010
Arsenic μg/L EPA 200.8/EPA 6020
Barium μg/L EPA 200.7/EPA 6010
Beryllium μg/L EPA 200.7/EPA 6010
Boron μg/L EPA 200.7/EPA 6010
Cadmium μg/L EPA 200.8/EPA 6020
Chloride mg/L EPA 300.0
Chromium μg/L EPA 200.7/EPA 6010
Cobalt μg/L EPA 200.7/EPA 6010
Copper μg/L EPA 200.7/EPA 6010
Fluoride mg/L EPA 300.0
Iron μg/L EPA 200.7/EPA 6010
Lead μg/L EPA 200.8/EPA 6020
Manganese μg/L EPA 200.7/EPA 6010
Mercury μg/L EPA 7470
Nickel μg/L EPA 200.7/EPA 6010
Nitrate mg/L EPA 300.0
Selenium μg/L EPA 200.8/EPA 6020
Silver μg/L EPA 200.7/EPA 6010
Sulfate mg/L EPA 300.0
Thallium μg/L EPA 200.8/EPA 6020
Total Dissolved Solids mg/L SM 2540C
Vanadum μg/L EPA 200.8/EPA 6020
Zinc μg/L EPA 200.7/EPA 6010
Notes:
mhos/cm = micro-ohms per centimeter
mg/L = milligrams per liter
mV = millivolts
NTU = nephelometric turbidity units
ft = feet
g/L = micrograms per liter
Sample Parameters and Analytical Methods
Table 2
PARAMETER CONTAINERS PRESERVATIVES HOLDING TIMES
In Situ Parameters
Field pH In Situ None Analyze Immediately
Field Specific Conductance In Situ None Analyze Immediately
Field Temperature In Situ None Analyze Immediately
Field Dissolved Oxygen In Situ None Analyze Immediately
Field Oxidation Reduction Potential In Situ None Analyze Immediately
Field Turbidity In Situ None Analyze Immediately
Laboratory Analyses
Antimony 500 mL HDPE 
6 months
Arsenic 500 mL HDPE 
6 months
Barium 500 mL HDPE 
6 months
Beryllium 500 mL HDPE 
6 months
Boron 500 ml HDPE 
6 months
Cadmium 500 mL HDPE 
6 months
Chloride 500 mL HDPE Cool to 4°Celsius 28 days
Chromium 500 mL HDPE 
6 months
Cobalt 500 mL HDPE 
6 months
Copper 500 mL HDPE 
6 months
Fluoride 500 mL HDPE 
28 days
Iron 500 mL HDPE 
6 months
Lead 500 mL HDPE 
6 months
Manganese 500 mL HDPE 
6 months
Mercury 500 mL HDPE 
28 days
Nickel 500 mL HDPE 
6 months
Nitrate 500 mL HDPE Cool to 4°Celsius 48 hours
Selenium 500 mL HDPE 
6 months
Silver 500 mL HDPE 
6 months
Sulfate 500 mL HDPE Cool to 4°Celsius 28 days
Thallium 500 mL HDPE 
6 months
Total Dissolved Solids 500 mL HDPE Cool to 4°Celsius 7 days
Vanadium 500 mL HDPE 
6 months
Zinc 500 mL HDPE 
6 months
Notes:
mL = milliliter
HDPE = high density polyethylene
HNO3 = nitric acid
Table 3
Sample Containers, Preservatives, and Holding Times

APPENDIX A

Monitoring Well Construction Records

:
MONITORING WELL CONSTRUCTION
WELL ID: MS-8 TOTAL DEPTH: 48.5 ft bls
S&ME PROJECT AND NO: WELL USE / TYPE: INSTALLATION DATE:
Marshall Steam Station, 1356-06-728 Monitoring 9/12/2006
DRILLING CONTRACTOR: DRILLER AND LICENCE NO.: DRILLING METHOD:
S&ME, Inc. Larry Shrader, 3349 4.25 H.S.A.
WATER LEVEL AT TOB: NORTHING: EASTING: TOP OF CASING ELEV. GROUND SURFACE ELEV.:
42.45 ft bls 681496.7 1412015.4 872.34 869.35
PAD TYPE:
Stickup (ft): ~ 3 ft 872.34 2'x2' Concrete
PROTECTIVE CASING:
Depth BLS 4"x4" Lockable Steel
0 ft - Top of Grout 869.35 CASING TYPE:
2-inch Sch. 40 PVC
CASING INTERVAL:
0 to 38 ft bls
SCREEN TYPE:
2-inch 0.010 Slot Sch. 40 PVC
SCREEN INTERVAL
38 to 48 ft bls
GROUT TYPE:
Neat Cement
GROUT INTERVAL
34 ft - Top of Seal 835.35 0 to 34 ft bls
SEAL TYPE:
36 ft - Top of Filter Pack 833.35 Bentonite
SEAL INTERVAL:
38 ft - Top of Screen 831.35 36 to 38 ft bls
FILTER PACK:
#1 Filter Sand
FILTER PACK INTERVAL:
36 to 48 ft bls
Screened DEVELOPMENT:
Interval Purged ~15 Gallons
10 feet NOTES:
TBD - To Be Determined
48 ft - Bottom of Screen 821.35
Cave In 820.85 For Lithologic Information See
48.5 ft bls - Total Depth Attached Boring Log
:
MONITORING WELL CONSTRUCTION
WELL ID: MS-16 TOTAL DEPTH: 35 ft bls
S&ME PROJECT AND NO: WELL USE / TYPE: INSTALLATION DATE:
Marshall Steam Station, 1356-06-728 Monitoring 9/11/2006
DRILLING CONTRACTOR: DRILLER AND LICENCE NO.: DRILLING METHOD:
S&ME, Inc. Larry Shrader, 3349 4.25 H.S.A.
WATER LEVEL AT TOB: NORTHING: EASTING: TOP OF CASING ELEV. GROUND SURFACE ELEV.:
26 ft bls 681142.3 1412485.1 837.31 834.25
PAD TYPE:
Stickup (ft): ~3.0 ft 837.31 2'x2' Concrete
PROTECTIVE CASING:
Depth BLS 4"x4" Lockable Steel
0 ft - Top of Grout 834.25 CASING TYPE:
2-inch Sch. 40 PVC
CASING INTERVAL:
0 to 24 ft bls
SCREEN TYPE:
2-inch 0.010 Slot Sch. 40 PVC
SCREEN INTERVAL
24 to 34 ft bls
GROUT TYPE:
Neat Cement
GROUT INTERVAL
20 ft - Top of Seal 814.25 0 to 20 ft bls
SEAL TYPE:
22 ft - Top of Filter Pack 812.25 Bentonite
SEAL INTERVAL:
24 ft - Top of Screen 810.25 20 to 22 ft bls
FILTER PACK:
#1 Filter Sand
FILTER PACK INTERVAL:
22 to 34 ft bls
Screened DEVELOPMENT:
Interval Purged ~15 Gallons
10 feet NOTES:
TBD - To Be Determined
34 ft - Bottom of Screen 800.25
Cave In 799.25 For Lithologic Information See
35 ft - Total Depth Attached Boring Log