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HomeMy WebLinkAboutNC0001422_Appdx P - Effectiveness Monitoring Plan_20200814Corrective Action Plan Update August 2020 L.V. Sutton Energy Complex SynTerra APPENDIX P POST -EXCAVATION GROUNDWATER AND SURFACE WATER EFFECTIVENESS MONITORING I 9wT►1 tip synTerra GROUNDWATER AND SURFACE WATER EFFECTIVENESS MONITORING PLAN 1971/1984 ASH BASINS AND FPA (SOURCE AREA 1) FADA AND FCPA (SOURCE AREA 2) L.V. SUTTON ENERGY COMPLEX 801 SUTTON STEAM PLANT ROAD WILMINGTON,r NORTH CAROLINA 28401 REVISION 0 AUGUST 2020 PREPARED FOR DUKE ENERGY. PROGRESS DUKE ENERGY PROGRESS, LLC /////A, , e-, , " 0, zy, (/ v 141-, � � C otte Harrison Project Scientist Bil ie, NC LG 2602 Project Manager Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra The following table describes the revisions made to this document. - DOCUMENT REVISION RECORD L.V. SUTTON ENERGY COMPLEX DOCUMENT Revision DATE REVISION DESCRIPTION Groundwater Initial document release for Groundwater Effectiveness 0 08/03/2020 Effectiveness Plan Monitoring at L.V. Sutton Energy Complex Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra TABLE OF CONTENTS SECTION PAGE 1.0 BACKGROUND............................................................................................................1-1 1.1 Monitoring Plans.......................................................................................................1-1 1.2 Site Description.........................................................................................................1-3 1.3 Geology and Hydrogeology....................................................................................1-4 2.0 MONITORING WELL NETWORK.......................................................................... 2-1 3.0 SAMPLING AND ANALYSIS PLAN.......................................................................3-1 3.1 Data Quality Objectives........................................................................................... 3-1 3.2 Sampling Requirements........................................................................................... 3-3 3.2.1 Analytical Requirements.................................................................................... 3-3 3.3 Sampling Procedures................................................................................................3-4 3.3.1 Sampling Equipment..........................................................................................3-4 3.3.2 Calibration Procedures.......................................................................................3-4 3.3.3 Groundwater Level Measurements.................................................................. 3-6 3.3.4 Well Purging and Sampling.............................................................................. 3-6 3.3.5 Surface Water Sample Collection..................................................................... 3-6 3.3.6 Sample Preservation and Handling................................................................. 3-7 3.3.7 Equipment Cleaning Procedures...................................................................... 3-8 3.3.8 Field Documentation.......................................................................................... 3-8 3.4 Chain-of-Custody......................................................................................................3-9 3.4.1 Sample Labels.................................................................................................... 3-10 3.4.2 Sample Container Packing............................................................................... 3-10 3.4.3 Sample Delivery................................................................................................ 3-10 4.0 QUALITY ASSURANCE PLAN.................................................................................4-1 4.1 Field Quality Control Samples................................................................................4-1 4.1.1 Field Duplicates...................................................................................................4-1 4.1.2 Matrix Spike and Matrix Spike Duplicates.....................................................4-1 4.1.3 Field Blank...........................................................................................................4-1 4.2 Laboratory Quality Control Sample.......................................................................4-2 4.2.1 Method Blank...................................................................................................... 4-2 4.2.2 Laboratory Control Samples (LCS)..................................................................4-2 4.2.3 Completeness Goals............................................................................................4-2 4.3 Equipment Calibration and Maintenance............................................................. 4-2 Page i Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra TABLE OF CONTENTS (CONTINUED) SECTION PAGE 4.3.1 Field Equipment Calibration............................................................................. 4-2 4.3.2 Laboratory Equipment Calibration.................................................................. 4-3 4.3.3 Field Equipment Maintenance.......................................................................... 4-3 4.3.4 Laboratory Equipment Maintenance............................................................... 4-3 4.4 Data Tracking and Management............................................................................ 4-3 4.4.1 Data Tracking Procedures.................................................................................4-4 4.4.2 Data Management Strategy............................................................................... 4-4 4.5 Assessment and Oversight...................................................................................... 4-4 4.5.1 Assessment Actions............................................................................................ 4-4 4.5.1.1 Field Assessment.......................................................................................... 4-4 4.5.1.2 Laboratory Assessment............................................................................... 4-5 4.5.2 Oversight Response Actions..............................................................................4-5 4.5.2.1 Field Response Action.................................................................................4-5 4.5.2.2 Laboratory Response Action Procedures .................................................. 4-5 4.6 Data Management.....................................................................................................4-5 4.6.1 Data Reduction, Verification and Reporting...................................................4-5 4.6.1.1 Data Reduction and Reporting................................................................... 4-5 4.6.1.2 Laboratory Data Verification and Review ................................................ 4-6 4.6.2 Data Validation...................................................................................................4-6 4.7 Data Usability............................................................................................................ 4-7 5.0 REFERENCES................................................................................................................ 5-1 Page ii Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra LIST OF FIGURES Figure 1 USGS Site Location Map Figure 2 Post -Excavation Effectiveness Monitoring Plan Systems and Flow Paths LIST OF TABLES Table 1 Post -Excavation Effectiveness Monitoring Plan Elements Table 2 Well Construction Summary LIST OF ATTACHMENTS Attachment A Field Data Records Attachment B Low Flow Sampling Plan, Duke Energy Facilities Ash Basin Groundwater Assessment Program Attachment C Duke Energy Environmental Services Quality Assurance Manual Attachment D Surface Water Evaluation Plan - April 25, 2018 and NCDEQ Approval Letter - May 10, 2018 Page iii Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra LIST OF ACRONYMS ASTM American Society for Testing and Materials Bgs below ground surface C Celsius CAMA Coal Ash Management Act CAP Corrective Action Plan CCR Coal Combustion Residuals CFR Code of Federal Regulations CLP Contract Laboratory Protocol COC chain -of -custody CSA Comprehensive Site Assessment CSM Conceptual Site Model DO dissolved oxygen DQO data quality objectives DQL data quality level DTW depth to water EDD Electronic data deliverables EMP Effectiveness Monitoring Plan FDR field data record IMP Interim Monitoring Plan LCS Laboratory control samples MNA monitored natural attenuation NCAC North Carolina Administrative Code NCDEQ North Carolina Department of Environmental Quality NTU Nephelometric turbidity unit ORP oxidation-reduction potential QA/QC Quality Assurance/Quality Control QAP Quality Assurance Plan RPD relative percent difference SAP Sampling and Analysis Plan SD standard deviation TOC top -of -casing USEPA United States Environmental Protection Agency Page iv Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra 1.0 BACKGROUND The L.V. Sutton Energy Complex (Sutton, Site) is a steam -generating electric power facility located on the east side of Cape Fear River near the City of Wilmington, in New Hanover County, North Carolina (Figure 1). Duke Energy Progress, LLC (Duke Energy) owns the site property. Power generation operations began in 1954. The Site is currently a natural gas -fired electricity -generating facility in operation since 2013. The primary purpose for the activities and procedures described in this Groundwater Effectiveness Monitoring Plan (EMP) is to obtain accurate and reliable groundwater data for the purposes stated in the Corrective Action Plan Update (SynTerra, August 3, 2020). The EMP is designed to effectively monitor groundwater and surface water associated with the Sutton coal combustion residuals (CCR) impoundments, including the 1971 Ash Basin, 1984 Ash Basin (collectively Ash Basins) and additional source areas, which collectively are the following; former process area (FPA), former ash disposal area (FADA), and the former coal pile area (FCPA). This document addresses anticipated data collection activities. Included in this EMP are the following: 1. A brief introduction to CAMA-related monitoring plans, site features, and site geology and hydrogeology; 2. Design of the EMP groundwater monitoring network; 3. Sampling and Analysis Plan (SAP) including requirements, procedures, documentation, laboratory analytical procedures and quality control; and 4. Quality Assurance Plan (QAP). 1.1 Monitoring Plans Sampling and analysis of groundwater associated with the ash basins and additional source areas are conducted in accordance with an Interim Monitoring Plan (IMP). As defined in North Carolina Department of Environmental Quality (NCDEQ) correspondence, Facility Interim Monitoring Plans Networks and Sampling Requirements (December 21, 2016), the IMP was implemented to facilitate completion of the Comprehensive Site Assessment (CSA) and Corrective Action Plan (CAP) for the Site. Implementation of the IMP commenced in the first quarter of 2018. Analytical results from IMP sampling are submitted to NCDEQ quarterly. An Effectiveness Monitoring Plan is required by G.S. Section 130A-309.211 (b)(1)(e) for evaluating the effectiveness of proposed groundwater corrective action. The EMP will be implemented within 30 days of CAP approval and will continue throughout the Page 1-1 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra groundwater corrective action program. After remediation goals are met, a long-term groundwater monitoring system would be implemented at the Site in accordance with G.S. Section 130A-309.214(4)(k)(2). Duke Energy has implemented, or plans to implement, the following multi -component Corrective Action Plan at the Site: Source Control Measures • Excavation of ash from the 1971 and 1984 ash basins in accordance with CAMA was completed by July 2019. • Excavation of ash from the FADA was completed by June 2020. • Removal of coal from the FCPA was completed by 2015. • Excavation of the FPA was completed by April 2020. • Groundwater extraction and treatment along the eastern Site boundary began in 2017 and is ongoing. Proposed Corrective Action • Continued operation of the nine -well groundwater extraction system along the eastern Site boundary that was installed in 2017 to reduce off -Site migration of COIs in groundwater. Although the COI concentrations have substantially decreased in the area, continued operation is planned because the system must run until specific decommissioning requirements defined in the Basis of Design (BOD) report are met (CAP approval and implementation, and four consecutive monitoring events with all COIs at concentrations less than applicable criteria). With ash pore water removal and basin excavation, the groundwater flow direction has returned to natural conditions (with the exception of the area influenced by the groundwater extraction system). The natural groundwater flow direction from the source areas is toward the southwest. The former eastward groundwater flow, and the resulting COI migration to the east, is no longer occurring (with the exception of the area influenced by the extraction wells). The reversal in groundwater flow direction near the source areas and the operation of the extraction system have effectively reduced COI concentrations along the eastern property line. Decommissioning requirements are expected to be met within five years. At that time, termination of the groundwater extraction system under these conditions is allowed under Subchapter 02L .0106(m). Page 1-2 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra • Implement MNA and effectiveness monitoring along with a restricted groundwater use designation (RS). Based on limited groundwater data after source area excavation, generally stable plume conditions, the limited extent of COI migration beyond the compliance boundary, and modeling results, this is the most viable option for remediating groundwater to standards at the compliance boundary. • Combine water in the former 1971 ash basin and FADA with water from the Site's cooling water effluent canal for discharge to the National Pollution Discharge Elimination System (NPDES) permitted outfall. This would address the water remaining in the excavated 1971 basin and FADA to allow completion of closure of these areas. • The RS is proposed for the small areas beyond the compliance boundary where COI concentrations in groundwater could persist for a period of time. The current and future anticipated use of the property is industrial with an active combined -cycle power -generating facility. The RS area would be within the Duke Energy Site boundary and therefore can be maintained. The proposed EMP includes a five-year review period after which time the effectiveness of source control, operation of the extraction system, treatment of groundwater in the former 1971 basin and FADA, and MNA can be evaluated using post -excavation data. 1.2 Site Description Detailed descriptions of the Site facilities are included in the Sutton CAP Update (SynTerra, 2020) and provide the basis for the monitoring system design discussed in Section 2 of this document. A brief summary of the source areas at the Site is provided here. CCR materials, composed primarily of fly ash and bottom ash, were historically managed by depositing ash in on -Site ash storage areas, collectively referred to as the ash management area. The former ash management area is located adjacent to the cooling pond, north of the plant, as shown on Figure 1. The former ash management area consists of four locations: • The former ash disposal area (FADA), also known as the lay of land area, is located south of the ash basins, on the south side of the cooling water discharge canal. It is believed that ash might have been placed in this area from approximately 1954 to 1972. Page 1-3 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra • The 1971 ash basin is an unlined ash basin built in about 1971. A portion of the 1971 basin was constructed by excavation below the water table as a borrow pit for construction of earthen dikes separating the basins. • The 1984 ash basin was built with a 12-inch-thick clay liner and was entirely above the water table. It is located toward the northern portion of the ash management area, and was operated from 1984 to 2013. • An area known as the FPA is adjacent to the southeast corner of the 1971 basin. The FPA was a small settling basin used for a short time period when the Site was co -firing fuel oil. At that time, sluice waters were directed to the settling basin before being directed to the 1971 basin. The settling basin was approximately 250 feet by 150 feet with concrete -lined side walls. The settling basin was subsequently filled with CCRs and solids. Coal -burning operations ceased in 2013 when the facility was converted to natural gas; ash has not been generated at the Site since that time. Coal was removed from the facility between 2014 and 2015 after coal -burning operations ceased in 2013 and has not been stored on -Site since. 1.3 Geology and Hydrogeology Detailed discussions of regional and Site geology and hydrogeology and an updated conceptual Site model (CSM) are included in the Sutton CAP Update (SynTerra, 2020) and provide the basis for the monitoring system design discussed in Section 2 of this document. As additional information becomes available, the CSM and monitoring system would be updated or modified, as appropriate. Page 1-4 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra 2.0 MONITORING WELL NETWORK This EMP is designed to be adaptable and target key areas where changes to groundwater conditions are most likely to occur. EMP key areas for monitoring are the following: • Background locations • Locations along designated flow paths • Within areas of observed or anticipated changing Site conditions, and/or have increasing constituent concentration trends • Locations to monitor constituent plume stability and verify model simulations EMP elements including well systems, locations, frequency, parameters, schedule and reporting evaluation are outlined on Table 1. Effectiveness monitoring surface water and groundwater monitoring well locations are shown on Figure 2. A total of 77 monitoring wells and 12 surface water locations will be used to monitor groundwater in the surficial flow zones beneath the Site. Of these, eight monitoring wells and two surface water locations are located upgradient of the source areas for background monitoring across the Site. A well construction summary is provided in Table 2. Page 2-1 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra 3.0 SAMPLING AND ANALYSIS PLAN A sampling and analysis plan is provided to satisfy sampling and analysis consistency requirements. This plan addresses the collection of groundwater samples, preservation and shipment of samples, sample analysis, and chain -of -custody (COC) control. This plan provides the methodology and protocols to be utilized throughout the effectiveness monitoring program to complete the following: • Maintain consistent procedures and techniques throughout sampling and analysis; • Obtain the data necessary to evaluate constituents of interest (COIs) occurrence and trends in groundwater; • Determine if constituent concentrations are greater than relevant standards; and • Effectively monitor changes in groundwater COI concentrations. Groundwater monitoring procedures and protocols used to monitor COIs, including low -flow sampling, were developed in accordance to the USEPA Region IV Field Branches Quality System and Technical Procedures, (USEPA, January 2012). 3.1 Data Quality Objectives The data quality objectives (DQOs) for the site are described in the following sections, where applicable. DQOs have been developed to provide guidelines for data collection such that data collected are of sufficient quantity and quality to support future decision - making efforts. These DQOs are developed according to the DQO Process outlined in the USEPA publication Guidance on Systematic Planning Using the Data Quality Objectives Process, EPA QAIG-4 (USEPA, February 2006). The DQO process comprises a series of planning steps that are designed to: • State the problem; • Identify the goals of the study; • Identify information inputs; • Define the boundaries of the study; • Develop the analytical approach; • Specify performance/acceptance criteria; and • Develop the plan for obtaining data. Page 3-1 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra The activities described in this document focus on the sampling of groundwater in the vicinity of the ash basins and the downgradient additional source areas. The primary COIs were selected using a constituent management approach, as described in Sections 5.0 and 5.6 of the CAP Update. An overall DQO for the work addressed by this document is to obtain a sufficient number of samples from representative monitoring wells to ascertain 1) groundwater flow rate and direction; 2) background constituent concentrations; 3) groundwater quality at the compliance boundary; 4) a determination if constituents are detected at concentrations that reflect a statistically significant increases or decreases relative to background; and 5) evaluate the effectiveness of the groundwater corrective action. The specific Quality Assurance/Quality Control (QA/QC) data requirements will vary depending upon the type of data being collected. USEPA's Region IV Field Branches Quality System and Technical Procedures (USEPA, January 2012) four data quality levels (DQLs) that may be used include the following: 1. Field screening 2. Field analysis 3. Screening data with definitive confirmation 4. Definitive data The majority of the data to be collected will have a DQL of 4 (Definitive data). However, some field screening and field analyses are anticipated. These DQLs are defined below: • Field Screening — Characterized by the use of portable instruments, which can provide real-time data to assist in the optimization of sampling locations and health and safety support. Data can be generated regarding the presence or absence of certain constituents at sampling locations. Field screening data is not definitive and will be used strictly, in combination with field observations, as a tool to assist in making more efficient, effective decisions such as the need to collect additional samples and/or select potential sample locations. • Field Analysis — Characterized by the use of portable analytical instruments which can be used on -site (e.g., turbidity meter). Depending upon the types of parameters, sample matrix, and personnel skills, qualitative and quantitative data can be obtained. Field analysis data is considered a non -critical measurement and is collected to monitor field and sample conditions at the time of sample collection. Field meters will be properly calibrated as detailed in Section 3.3.2. Page 3-2 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra • Screening Data with Definitive Confirmation — Generated by rapid, less precise methods of analysis with less rigorous sample preparation. Sample preparation steps may be restricted to simple procedures such as dilution with a solvent, instead of elaborate extraction/digestion and cleanup. Screening data provides analyte identification and quantification, although the quantification may be relatively imprecise. • Definitive Data — Generated using rigorous analytical methods, such as approved USEPA reference methods. Data of this level will be generated by a laboratory certified by the state in which the samples are collected. The definitive data will be analyte-specific, with confirmation of analyte identity and concentration. These methods produce tangible raw data in the form of paper printouts and computer -generated electronic files. To be definitive, either the analytical or total measurement error will be determined. Definitive data is considered a critical measurement because it is a significant component of the groundwater monitoring process. 3.2 Sampling Requirements Under the EMP, groundwater and surface water sampling will be conducted on quarterly basis for one year followed by a semi-annual basis. During groundwater sampling activities, water levels are measured at each well to generate potentiometric maps of monitored hydrogeologic flow zones. Water levels used for preparation of flow maps are collected during a single 24 to 48 hour period. Field parameters listed on Table 1 will also be measured during well purging and immediately before samples are collected for laboratory analysis. Groundwater and surface water samples will be analyzed by a certified laboratory for the list of parameters in Table 1. 3.2.1 Analytical Requirements Duke Energy Analytical Laboratory or certified vendor laboratory will analyze the groundwater and surface water constituents following approved USEPA methods. The laboratory must be certified for each constituent by the state in which the sample was collected. The record of analyses will include the methods used (by number), the extraction date (if applicable), and the date of analysis. Data obtained from samples that are not analyzed within the recommended holding times will be considered suspect and flagged accordingly. Any deviation from approved methods will be adequately tested to ensure that the quality of the results meets the performance specifications (e.g., detection limit, sensitivity, precision, accuracy) of the reference method. The Duke Energy Environmental Services Quality Assurance Manual is included in Attachment C. Page 3-3 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra 3.3 Sampling Procedures Only trained personnel may conduct site -sampling activities. Personnel will follow procedures and utilize equipment outlined in the following sections, the Low Flow Sampling Plan. Duke Energy Facilities. Ash Basin Groundwater Assessment Program. North Carolina, June 10, 2015 (Attachment B), and the updated Groundwater Monitoring and Sample Collection, Duke Energy Environmental Science, May 18, 2020 (Procedure 3175.6) to minimize sampling error and prevent cross contamination of samples. 3.3.1 Sampling Equipment Well Purging Well purging and sampling is conducted via low -flow sampling techniques using dedicated pumps. If new wells are installed and sampled prior to installation of dedicated systems, peristaltic and/or submersible pumps are employed. Measurement of Groundwater/Surface Water Quality Field Parameters Measurements of field parameters including dissolved oxygen (DO), oxidation- reduction potential (ORP), pH, specific conductance, and temperature are measured using a YSI Professional Plus multi -parameter water quality meter, or similar instrument. Field parameters are recorded during low -flow purging and sampling as groundwater is pumped through a flow -through chamber. Measurement of Turbidity The turbidity meter is calibrated according to instruction provided by the manufacturer. Batteries are checked, and the meter calibration is checked against known standards. Sample results are expressed in Nephelometric turbidity units (NTUs) and recorded with the other field parameters. 3.3.2 Calibration Procedures Field sampling equipment (e.g., water quality meter) is properly maintained and calibrated prior to and during continued use to assure that measurements are accurate within the limitations of the equipment. Personnel will follow the manufacturers' instructions to determine if the instruments are functioning within their established operation ranges. The calibration data are recorded on a field data record (FDR) (Attachment A). To be acceptable, a field test must be bracketed between acceptable calibration results. The first check may be an initial calibration, but the second check must be a continuing verification check. Page 3-4 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra • Each field instrument must be calibrated prior to use using traceable standards. • Verify the calibration at no more than 24-hour intervals during use and at the end of the use if the instrument will not be used the next day or periods greater than 24 hours. • Initial calibration and verification checks must meet established acceptance criteria. • If an initial calibration or verification check fails to meet the acceptance criteria, immediately recalibrate the instrument or remove it from service. • If a calibration check fails to meet the acceptance criteria and it is not possible to reanalyze the samples, the following actions must be taken: o Report results between the last acceptable calibration check and the failed calibration check as estimated (qualified with a "J"); o Include a narrative of the problem; and o Shorten the time between verification checks or repair/replace the instrument. • If historically generated data demonstrate that a specific instrument remains stable for extended periods, the interval between initial calibration and calibration checks may be increased. o Acceptable field data must be bracketed by acceptable checks. Data that are not bracketed by acceptable checks must be qualified. o Base the selected time interval on the shortest interval that the instrument maintains stability. o If an extended time interval is used and the instrument consistently fails to meet the final calibration check, then the instrument may require maintenance to repair the problem or the time is too long and must be shortened. • For continuous monitoring equipment, acceptable field data must be bracketed by acceptable checks or the data must be qualified. A sampling or field measurement instrument determined to be malfunctioning must be taken out of service, repaired, or replaced with a new piece of equipment. Page 3-5 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra 3.3.3 Groundwater Level Measurements Depth -to -water (DTW) is measured in each well in the EMP monitoring network during a 24 to 48 hour period for each monitoring event. Groundwater levels are measured using an electronic water level indicator that is cleaned between each well prior to measurement activities. The DTW measurements are referenced to the well top -of -casing (TOC) mark established by the site survey and provides data to generate potentiometric surface maps for monitored groundwater flow layers at the site. In addition, water surface elevations of the former LOLA and former 1971 ash basin and select nearby rivers may be determined during each groundwater sampling event, as necessary, to supplement water level measurements and development of potentiometric surface maps. Potentiometric surface maps allow for determination of groundwater flow direction and horizontal gradient. Measuring the depth to the groundwater surface is accomplished following the steps outlined in Section 6 of Duke Energy's updated sampling plan titled Groundwater Monitoring Sampling and Collection procedures document, and Section 3.2 of Duke Energy's 2015 Low Flow Sampling Plan (Attachment B). Slight deviations from the low flow sampling plan may be necessary to achieve desired sampling conditions. For instance, the low flow sampling plan recommends measuring total well depth prior to purging. However, to reduce the potential to suspend sediment accumulated at the bottom of the well, which affects well turbidity (desired turbidity for sample collection <_10 NTU), total depth measurements will be measured following sample collection. 3.3.4 Well Purging and Sampling Monitoring wells are purged to remove stagnant water from the well casing and obtain a representative groundwater sample. Well purging and sampling procedures are provided in Duke Energy's updated sampling plan titled Groundwater Monitoring Sampling and Collection and in Duke Energy's 2015 Low Flow Sampling Plan (Attachment B). 3.3.5 Surface Water Sample Collection Sample collection methods would be similar to NCDEQ 2B/2L guidance protocol (Attachment D). Multiple (acute and chronic) samples would not be collected. One sample would be collected from each location during the EMP event. To assess potential influence from groundwater migration to surface water bodies and "to avoid lateral mixing," NCDEQ requested "near bank" sample collection. Samples would be collected by direct grab within 2 feet from the edge of the Page 3-6 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra pond/river bank. At locations where the banks were excessively steep or undercut to preclude walking to the water's edge, sampling equipment (e.g., dipper, peristaltic pump) was used to collect the samples. Attempts would be made to collect samples during low flow conditions after a period of five days with limited precipitation. However, as was discussed during the June 21, 2018, meeting with NCDEQ, daily thunderstorms in summer are common at the Site. Therefore, some precipitation is acceptable, and sampling can proceed, absent the occurrence of extraordinary precipitation. Locations would be sampled at a frequency that would enable an assessment that adheres with 15A NCAC 02B water quality standards. Rule 15A NCAC 02B .0211 (11) (e) states: "Compliance with acute instream metals standards shall only be evaluated using an average of two or more samples collected within one hour. Compliance with chronic instream metals standards shall only be evaluated using an average of a minimum of four samples taken on consecutive days, or as a 96-hour average." One sample would be collected at each location. This differs from the established 2B/2L sampling protocol, which calls for multiple acute and chronic samples collected over multiple days (Attachment D). This sampling protocol was designed to support a 2B/2L future conditions model. The samples proposed to be collected as part of the EMP are to be used as confirmation of the model predictions. Acute and chronic sample are not necessary to accomplish that goal. Samples would be collected from the same physical locations during each sampling event. Flagging tape and stakes would be placed to mark the sampling locations in the event additional sampling was needed. 3.3.6 Sample Preservation and Handling Sample preservation and handling procedures are specified in Section 7.3 of Duke Energy's updated sampling plan titled Groundwater Monitoring Sampling and Collection and in Section 3.5.1 of Duke Energy's 2015 Low Flow Sampling Plan (Attachment B). Analyte-specific sample containers, preservation methods, and holding times that meet approved standards are used in accordance with methods identified on the Low Flow Sampling Log (Attachment A) and Duke Energy Environmental Services QA Manual (Attachment C). Page 3-7 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra 3.3.7 Equipment Cleaning Procedures Equipment cleaning procedures are included in the (Decontamination of Equipment Standard Operating Procedure) of Duke Energy's updated sampling plan titled Groundwater Monitoring Sampling and Collection and in Duke Energy's 2015 Low Flow Sampling Plan (Attachment B). 3.3.8 Field Documentation Documentation of field activities is completed using a combination of logbooks and FDRs, sample tracking systems, and sample custody records. Site field logbooks are completed to provide a general record of activities and events that occur during each field task that may not be documented on FDR or similar form. FDRs have been designated for each exploration and sample collection task to provide a complete record of data obtained during the activity. Field Logbooks The field logbooks provide a daily hand written account of field activities. Logbooks are hardcover books that are permanently bound. All entries are made in indelible ink and corrections are made with a single line with the author initials and date. Each page of the logbook includes the job number, date, and initials of the person completing the log. Partially completed pages have a line drawn through the unused portion at the end of each day with the author's initials. The following information may be entered into the field logbooks: • The date and time of each entry; • The daily log generally begins with the Pre -Job Safety Brief; • A summary of important tasks or subtasks completed during the day; • A description of field test completed in association with the daily task; • A description of samples collected including documentation of any quality control samples that were prepared (rinse blanks, duplicates, matrix spike, split samples, etc.); • Documentation of equipment maintenance and calibration activities; • Documentation of equipment decontamination activities; and • Descriptions of deviations from this work plan. Other information that may be included in field logbooks is listen in Section 3.7 of the Low Flow Sampling Plan (Attachment B). Page 3-8 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra Field Data Records Sample FDRs contain sample collection and/or exploration details. A FDR is completed each time a field sample is collected. The goal of the FDR is to document exploration and sample collection methods, materials, dates and times, and sample locations and identifiers. Field measurements and observations associated with a given exploration or sample collection task are recorded on the FDRs. FDRs are maintained throughout the field program in files that become a permanent record of field program activities. A listing of FDRs is presented below. Each FDRs listed will not be required for each step - specific activity that may or may not be required over the entire project. The provided list has been incorporated so that the groundwater sampling, analysis, and QA/QC plan will not need to be amended if additional data collection methods are subsequently added. Examples of listed FDRs are provided in Appendix C of the Low Flow Sampling Plan (Attachment B), including: • Groundwater Potentiometric Level Measurement Log • Well Sampling/Low Flow Sampling Log • Daily Field Report Other FDRs may include the following: • Surface Water Sampling Log • Field Instrument Calibration Record • Site Specific Low Flow Sampling Log 3.4 Chain -of -Custody A program of sample custody is followed during sample handling activities in both field and laboratory operations. This program is designed to assure that each sample is accounted for at all times. The appropriate sampling and laboratory personnel complete sample FDRs, chain -of -custody records, and laboratory receipt sheets. Sample chain -of -custody procedures and document information is provided in Section 7.2 of Duke Energy's updated sampling plan titled Groundwater Monitoring Sampling and Collection (Attachment B). Additional information documented in the chain -of -custody may be required, such as shipping information for samples sent by courier. Page 3-9 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra 3.4.1 Sample Labels Prepared labels are normally developed for each sample container prior to sample collection. At a minimum, each label affixed to the sample container will contain the following information: • Sample location and depth (if applicable); • Date and time collected; • Sampler identification; and, • Analyses requested and applicable preservative. 3.4.2 Sample Container Packing Sample containers are packed in plastic coolers for shipment or pick up by courier. Bottles are packed so that motion is minimized during transport. Styrofoam and "bubble pack" may be used as packing materials in some instances. Ice is placed in the cooler. Paperwork (chain -of -custody form) is placed in a separate, re -sealable, watertight, plastic bag within the cooler. A temperature blank provided by the laboratory will also be placed in each cooler prior to shipment to verify the cooler was maintained at 4° Celsius (C), +/- 2° C, during sample shipment. Custody seals are placed across the lid and cooler body interface prior to shipment to, or pick up by, the laboratory. Cooler custody seals are used to determine whether the coolers may have been opened or otherwise tampered with prior to receipt by the laboratory. 3.4.3 Sample Delivery During shipment to the laboratory, shipping containers are sealed and accompanied by the chain -of -custody record, with appropriate signatures. The transfer of custody is the responsibility of field sampling personnel, sample courier, and the laboratory. Sample shipping may be conducted by courier service. Upon receipt by the laboratory, samples are handled according to laboratory QA/QC procedures. Typically, a laboratory custodian will perform the following procedures: • Inspect shipping containers and note the physical condition and presence or absence of custody seals and the condition, if present. • Inspect each sample container for damage or leakage and inspect the label. Page 3-10 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra • Reconcile the sample(s) received against the chain -of -custody record including the type of sample container, the volume of sample, the preservative, and the consistency with the information on the label. • Log the sample(s) in the laboratory logbook, prepare a sample receipt report, assign a laboratory identification number, and store the sample(s) in a secured sample storage room or cabinet until assigned to an analyst. Notify the sampler of a broken or missing bottle, broken or missing custody seal, or other deficiencies so that appropriate action may be taken (e.g., resample, notify Duke Energy, and notify shipping service). Discrepancies observed between received samples and the information on the chain -of -custody record are resolved before the sample is assigned for analysis. The sampler is informed of any such discrepancy as well as its resolution. Results of the inspection are documented in the laboratory sample logbook. Discrepancies are documented in the analytical case narrative, as appropriate. Page 3-11 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra 4.0 QUALITY ASSURANCE PLAN The Quality Assurance Plan (QAP) has been prepared to specify quality assurance/quality control (QA/QC) procedures for collection, analysis, and evaluation of data that will be legally and scientifically defensible. The QAP provides general information and references standard operating procedures applicable to the analytical sampling program. This information includes definitions and generic goals for data quality and required types and quantities of QA/QC samples. The procedures address field documentation; sample handling, custody, and shipping; instrument calibration and maintenance; auditing; data reduction, validation, and reporting; corrective action requirements; and QC reporting specific to the analysis performed by the North Carolina Department of Environmental Quality -approved laboratory. 4.1 Field Quality Control Samples These samples are not included specifically as laboratory QC samples but are analyzed when submitted to provide quality control data relative to the field sampling and sample management procedures. Data for these QC samples are reported with associated samples. Field QA/QC will be performed in accordance with the procedures outlined in Section 7.5 Duke Energy's updated sampling plan titled Groundwater Monitoring Sampling and Collection and in Duke Energy's 2015 Low Flow Sampling Plan (Attachment B). 4.1.1 Field Duplicates Field duplicates are two samples of the same matrix, which are collected, to the extent possible, from the same location at the same time using the same techniques. Field duplicates provide information on the precision of the sampling and analysis process. Field duplicates will be collected at a frequency of one duplicate per 20 samples being collected. 4.1.2 Matrix Spike and Matrix Spike Duplicates A matrix spike sample is an aliquot of a field sample, which is fortified with the analyte(s) of interest or a similar surrogate analyte and analyzed to monitor measurement bias associated with the sample matrix. A matrix spike and a matrix spike duplicate are performed by the analytical laboratory on samples selected by the analytical laboratory. 4.1.3 Field Blank Field blanks are prepared in the field to evaluate the potential for contamination of a sample by site contaminants from a source not associated with the sample collected (examples include dust or organic vapors). Analyte-free water provided Page 4-1 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra by the laboratory is brought to the field by the sampling crew and transferred to the proper sample container for shipment along with the other samples collected. One field blank sample is collected per sampling day. Field QA/QC samples are analyzed for the same constituents as the groundwater samples identified on Table 1, unless otherwise noted. 4.2 Laboratory Quality Control Sample Samples from the monitoring wells are analyzed by a laboratory certified for each constituent by the state in which the sample was collected. Primarily, Duke Energy Analytical Laboratory provides analytical services, possibly supported by one or more certified vendor laboratories. At a minimum, laboratory quality control includes analysis of method blank samples and laboratory control samples. 4.2.1 Method Blank The method blank is used to monitor for laboratory contamination. This is usually a sample of laboratory reagent water processed through the same analytical procedures as the sample (i.e., digested, extracted, and distilled). One method blank is prepared and analyzed with each analytical batch. 4.2.2 Laboratory Control Samples (LCS) A fortified method blank is analyzed with each analysis. These samples generally consist of a standard aqueous matrix fortified with the analytes of interest for single-analyte methods and selected analytes for multi-analyte methods according to the appropriate analytical method. The analyte recovery from each is used to monitor analytical accuracy and precision. 4.2.3 Completeness Goals Completeness goals are addressed in the Duke Energy Environmental Services Quality Assurance Manual (Attachment C). 4.3 Equipment Calibration and Maintenance 4.3.1 Field Equipment Calibration Procedures for calibration of field equipment and their associated quality control objectives are outlined below: YSI Professional Plus Multi -Meter: 15A NCAC 2H .0805 (a)(6)(F) and (g)(3) and EPA approved 40 CFR Part 136.3. The meter will be calibrated per North Carolina Administrative Code (NCAC) and USEPA approved methods. Page 4-2 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra • Hanna Instruments -HI 98703 Portable Turbidimeter: Calibrated by equipment provider using USEPA Method 180.1 for wastewater and Standard Method 2130 B for drinking water. • GeoTech water level indicator: ASTM International Standard Guide for Passive Sampling, D7929-14. Does not require calibration. Cole-Parmer Masterflex Portable Peristaltic Pump: Power source is self- contained 12-V battery. Potentiometer knob for speed control does not require calibration. 4.3.2 Laboratory Equipment Calibration Written procedures are used for all instruments and equipment subject to calibration. Whenever possible, recognized procedures, such as those published by ASTM International or USEPA, or procedures provided by manufacturers, are adopted. If established procedures are not available, a procedure is developed considering the type of equipment, stability characteristics of the equipment, required accuracy, and the effect of operational error on the quantities measured. 4.3.3 Field Equipment Maintenance Periodic preventative maintenance is required for all sensitive equipment. Instrument manuals will be kept on file for reference and if equipment is in need of repair. The troubleshooting chapter of factory manuals may be used in assisting personnel in performing maintenance tasks. The frequency of preventative maintenance for field equipment is indicated in each operating instruction manual. Manually operating sampling equipment is routinely checked to ensure proper operation and that excessive wear has not occurred. If necessary, equipment is taken out of service for repair or replacement. Field equipment is checked by field personnel under the supervision of the task manager. 4.3.4 Laboratory Equipment Maintenance The maintenance procedures for the analytical equipment used by the analytical laboratory are found in their Quality Assurance Manual. 4.4 Data Tracking and Management During field activities, field logbooks and field data sheets are maintained by sampling personnel and the Project Manager. The field log books and field data sheets document site activities, sample locations, notes from sampling crew, equipment calibration data, and any pertinent observations made during drilling, well development, and sampling Page 4-3 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra activities. It is the responsibility of the Project Manager to periodically review field documentation to confirm that information/data is being properly documented during field activities. If documentation is found to be out of compliance, the deviation is documented and immediate action is taken to resolve the situation. After review of field data collected, it is reduced to tabular form for inclusion in the project report. Groundwater sampling field parameters are provided in a format designated by Duke Energy. 4.4.1 Data Tracking Procedures Data received pertaining to the project is tracked by the Owner or owner's designee. This tracking information is used to verify sampling completeness, and completeness of receipt of analytical data. Data tracking is electronic and will be determined by Duke Energy and its contractor. 4.4.2 Data Management Strategy The Duke Energy Analytical Laboratory provides results in the form of laboratory reports and electronic data deliverables (EDDs). When received, the EDDs are imported into the electronic database. Standard checks of completeness and congruency of data fields are performed during data upload to the chosen database. Reporting corrective actions may be required by the laboratory prior to final upload, based on database checks. Field data, such as field parameters are uploaded in an electronic format, such as Excel, either manually or automatically if electronic field data collection is completed, and is reviewed by an independent member of the project team prior to submittal to the database for upload and use. 4.5 Assessment and Oversight 4.5.1 Assessment Actions The Owner or owner's designee has overall responsibility for providing supervision of data collection activities conducted in accordance with this document. The Project Manager evaluates implementation of procedures by checking field data sheets, and/or field logbooks. If activities are found to be out of compliance with procedures, the deviation is documented and action is taken to resolve the situation. 4.5.1.1 Field Assessment The Owner or owner's designee may assess field activities at any time to evaluate adherence to procedures in this document. This may include but not limited to observation of drilling, well development and/or sampling activities. Page 4-4 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra Field documentation (i.e., COCs, equipment calibration data, sampling sheets) is reviewed for compliance to ensure forms are being properly filled out and maintained during the activity. 4.5.1.2 Laboratory Assessment The QA Manager or designee may conduct laboratory assessments at any time. This may include but is not limited to evaluation of analytical instruments, personnel, facilities and/or adherence to laboratory procedures documented in the Quality Assurance Plan from the laboratory. 4.5.2 Oversight Response Actions 4.5.2.1 Field Response Action Field response actions are implemented, as needed. 4.5.2.2 Laboratory Response Action Procedures Laboratory response or corrective action is addressed in the Duke Energy Environmental Services Quality Assurance Manual (Attachment C). 4.6 Data Management 4.6.1 Data Reduction, Verification and Reporting 4.6.1.1 Data Reduction and Reporting Data reduction is the process of converting raw data into results. Project - specific data reduction methods are designed to ensure that data are accurately and systematically reduced to a usable form. The data generated for the EMP is used to monitor the effectiveness of the groundwater remedy and determine whether a statistically significant increase or decrease in COI concentrations is occurring. Therefore, data reduction for the EMP includes computation of summary statistics (e.g., means, geometric means, and medians), and their standard errors (standard deviations), calculation of confidence intervals, testing of hypotheses relative to the parameters, and model validation. The data generated at the site and/or in the laboratory are used to support the professional judgement -based decisions and the risk evaluations. The laboratories provide their standard report package format. These data are detained in tabular form (e.g., a summary spreadsheet format), identifying all detections greater than detection limit by well. Information can be entered into appropriate models or plotted to illustrate level and extent of COI distribution. Page 4-5 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra Supplementary data produced for internal records and not reported as part of the analytical data may include laboratory worksheets, laboratory notebooks, sample tracking forms, instrument logs, standards records, maintenance records, calibration records, and associated quality control records. These data are available for inspection during audits, and when needed to determine the validity of data. Data from other sources (such as previous site investigations and existing groundwater monitoring programs) are not used in project analysis or reports until the QC Manager can be assured that the data were collected and analyzed according to procedures and protocols specified in this QAP. The source of outside data will be included in project reports where these data are used. 4.6.1.2 Laboratory Data Verification and Review Data verification refers to the process of evaluating a data set for completeness. Personnel verify that data received from the laboratory complies with specified requirements. All project decisions, conclusions, and recommendations are based upon verified (validated) data. The purpose of data verification is to insure that all data used for subsequent evaluations and calculations are scientifically valid, of known and documented quality, and legally defensible. Field data verification is used to eliminate data not collected or documented in accordance with the protocols specified in the approved sampling plans. Laboratory data verification is used to eliminate data not obtained using prescribed laboratory procedures. 4.6.2 Data Validation Data validation describes an analyte and sample specific process of evaluating that a data set meets method, procedure and contract requirements. Data review and validation is performed by the analytical laboratory in accordance with the USEPA Contract Laboratory Program (CLP) National Functional Guidelines for Superfund Organic Methods Data Review (USEPA, 2014a) and the USEPA CLP National Functional Guidelines for Inorganic Data Review (USEPA, 2014b). Analytical data are reviewed and validated at a rate of 100 percent. Analytical results and qualifiers are assessed using professional judgment to determine the final quality and usability of the data. Page 4-6 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra Examples of data validation qualifiers include: u The analyte was analyzed for, but was not detected to the method detection limit, and was not quantifiable to the reporting limit. J The result is an estimated quantity. The associated numerical value is the approximate concentration of the analyte in the sample. J+ The result is an estimated quantity, but the result may be biased high. J- The result is an estimated quantity, but the result may be biased low. UJ The analyte was not detected; however, the result is estimated due to discrepancies in meeting certain analyte-specific quality control criteria. The data are unusable. The sample results are rejected due to serious R deficiencies in meeting QC criteria. The analyte may or may not be present in the sample. 4.7 Data Usability Measurement quality objectives specify the criteria that data must meet in order to support the program data quality objectives. The measurement quality objectives describe the expected performance or acceptance criteria for individual data quality indicators, such as precision, bias, lower reporting limit and completeness. Therefore, the measurement quality objectives serve two critical functions. First, they provide the basis for determining the procedures that should be used for sampling and analysis because they specify the level of quality that generated data must achieve. Second, they establish benchmarks against which collected data are compared to determine whether the data are of sufficient quality to be used in the program. Measurement quality objectives used for this program include: • Precision is the degree of agreement between replicate analyses of a sample under identical conditions. It is a measure of the random error associated with the analysis, usually expressed a relative percent difference (RPD) or standard deviation (SD). Precision will be determined on both field data and laboratory analysis by analyzing field duplicates, laboratory replicates, and matrix spike duplicates. Calculation of RPD or SD between these paired measurements will evaluate precision. Duplicate laboratory sample error values include laboratory and field variability. In general, higher errors are expected for point source effluent and storm event samples. The data quality indicators for precision in field measurements are presented in Attachment A; the indicators for laboratory parameters are presented in the Duke Energy Environmental Services Quality Assurance Manual (Attachment C). Page 4-7 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra • Accuracy (percent R) is the measure of difference between an analytical result and the true value, usually expressed as percent. The accuracy of a result is affected by both systematic errors (bias) and random errors (imprecision). Bias is a systematic error in one direction. Accuracy and bias will be assessed by using laboratory blanks, matrix spikes, and check standards. Prior to use, instruments will be calibrated per the manufacturer's instructions. • Representativeness expresses the degree to which sample data accurately and precisely represent a characteristic of a population, parameter variations at the sampling point, or an environmental condition. Groundwater samples collected for COI monitoring will be collected only from monitoring wells in the EMP program; the rationale for the selection of EMP well locations is presented in the CAP Update. In general, sampling sites were selected to detect the migration of COIs in groundwater at or near the compliance boundary. Groundwater samples are collected using low flow sampling procedures in Section 7.4.2 in Duke Energy's updated sampling plan titled Groundwater Monitoring Sampling and Collection and in Duke Energy's 2015 Low Flow Sampling Plan (Attachment B) to minimize sample turbidity that can contribute naturally occurring inorganic constituents that are not dissolved, and therefore, not be attributed to groundwater quality. Field staff follows low flow sampling procedures for collecting representative samples. Turbidity can contribute naturally occurring inorganic constituents that are not dissolved in groundwater, and therefore, not representative of in situ groundwater quality. Laboratory representativeness is achieved by proper preservation and storage of samples along with appropriate sub -sampling and preparation for analysis. • Completeness is defined as the total number of samples analyzed for which acceptable analytical data are generated, compared to the total number of samples collected. • Comparability is a qualitative parameter expressing the confidence with which one data set can be compared with another. This goal is achieved through using standardized techniques to collect and analyze representative samples, along with using standardized data validation and reporting procedures. All data should be reported and calculated in units consistent with standard reporting procedures to enable comparison. • Sensitivity is the ability of the method or instrument to detect the target analytes at the level of interest. Data will be compared to the appropriate regulatory limits and the laboratory's method reporting limits will be equal to or less than these limits where possible. Page 4-8 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra 5.0 REFERENCES Duke Energy Environmental Sciences, 2020. Groundwater Monitoring and Sampling Collection. May 18, 2020. Narkunas, James, 1980. Groundwater evaluation in the central Coastal Plain of North Carolina: Raleigh, N.C., North Carolina Department of Natural Resources and Community Development, 119 p. SynTerra, 2020. Corrective Action Plan Update — L.V. Sutton Energy Complex, Wilmington, NC. USEPA, February 2006; Guidance on Systematic Planning Using the Data Quality Objectives Process (QAIG-4), EPA/240/R-06001 Office of Environmental Information. USEPA, January 2012; Region IV Field Branch Quality System and Technical Procedures (Field Branches Quality System and Technical Procedures), SESDPLAN-001-R4. USEPA, August 2014a; National Functional Guidelines for Superfund Organic Methods Data Review; EPA-540-R-014-002; OSWER 9355.0-132. USEPA, August 2014b; National Functional Guidelines for Superfund Inorganic Methods Data Review; EPA-540-R-013-001; OSWER 9355.0-131. Page 5-1 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex FIGURES SynTerra - x ♦ J SUTTON PLANT / PARCEL LINE • ♦• 1000, 10010 • I ♦ I • ♦ COMPLIANCE I BOUNDARY • FORMER ASH BASIN �•� `•� ` LANDFILL WASTE WASTE BOUNDARY • ♦ BOUNDARY r� I Lake Sutton FORMER 1984 F ASH BASIN „ • 40, • I • , l♦ • `• • . �� EXCAVATED 1971 FORMER PROCESS AREA .`� • � I • ` ASH BASIN • ♦, FORMER ASH DISPOSAL •� AREA WASTE BOUNDARY ` � FORMER COAL PILE AREA` ^` WASTE BOUNDARY .� -EFFLUENT DISCHARGE CANAL t I I POWER PLANT s� INTAKE CANAL SOURCE: •� 2019 USGS TOPOGRAPHIC MAP, CASTLE HAYNE AND LELAND QUADRANGLES, OBTAINED FROM THE USGS STORE AT https://store.usgs.gov/map-locator. DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE PLANE COORDINATE SYSTEM FIPS 3200 (NAD83/2011). t�ENERGY FIGURE 1 DUKE w)NsroN-sALEm USGS SITE LOCATION MAP GROUNDWATER AND SURFACE WATER EFFECTIVENESS PROGRESS CHARLOTTE MONITORING PLAN L.V. SUTTON ENERGY COMPLEX WILMINGTON, NORTH CAROLINA HANOVER DRAWN BY: J. KIRTZ DATE: 11/18/2019 COUNTY REVISED BY: C. CURRIER DATE: 07/27/2020 000 oGRAPHIC SCALEo00 000 CHECKED BY: T. HARTMAN DATE: 07/27/2020 APPROVED BY: B. WYLIE DATE: 07/27/2020 (IN FEET) PROJECT MANAGER: B. WYLIE LEGEND WELL IN UPPER SURFICIAL FLOW ZONE WELL IN LOWER SURFICIAL FLOW ZONE ■ SURFACE WATER SAMPLE LOCATION (APPROXIMATE) EXTRACTION WELL • SUPPLY WELL ANTICIPATED COOLING POND EXTENSION -4EFFECTIVENESS MONITORING FLOW PATH ASH BASIN COMPLIANCE BOUNDARY ASH BASIN WASTE BOUNDARY ONSITE LANDFILL BOUNDARY ONSITE LANDFILL COMPLIANCE BOUNDARY FORMER ASH DISPOSAL AREA WASTE BOUNDARY FORMER PROCESS AREA BOUNDARY FORMER COAL PILE AREA BOUNDARY DUKE ENERGY PROGRESS PROPERTY LINE EFFLUENT DISCHARGE CANAL SURFACE WATER FLOW DIRECTION GROUNDWATER FLOW DIRECTION AREAS 1 A/1 B/4 - CONFIRMATION GROUNDWATER MONITORING _ AREAS 2/3A- ONGOING CLOSURE ACTIVITIES r1 AREA 3B - MNA REMEDY APPROXIMATE HYDROLOGIC DIVIDE 1. SEE APPENDIX P FOR MORE DETAILED INFORMATION RELATED TO EFFECTIVENESS MONITORING PLAN (EMP) ELEMENTS FOR THE ASH BASINS, FADA, FPA, AND FCPA. MONITORING WELLS SHOWN ON THIS FIGURE ARE PLANNED TO BE SAMPLED AS PART OF THE EMP. 2. THE OUTLINE OF AREAS 1A, 1 B, 2, 3A, 3B AND 4 REPRESENT THE AREAS WHERE THE MAXIMUM EXTENT OF COIS ARE GREATER THAN COMPARISON CRITERIA IN GROUNDWATER ASSOCIATED WITH THE SUTTON SOURCE CCP - COAL COMBUSTION PRODUCTS. PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY 5. ALL BOUNDARIES ARE APPROXIMATE 6. AERIAL PHOTOGRAPHY OBTAINED FROM TERRA SERVER ON JUNE 17, 2019. IMAGE COLLECTED APRIL 4, 2019. 7. DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE PLANE COORDINATE SYSTEM FIPS 3200 (NAD83/2011). MW-41B MW-41C 10 SW-2 MW-08B M W-8 0 4-�A'q • MW-5B ♦ � _ MW-5C ♦ MW-27B MW-27C ` • � MW-40B SW-3 MW-40C AREA CCR-114B CCR-114C CCR-113B l , ♦ LCCR-113C , � CCR-112B CCR-112C ® CCR-119B CCR-119C CCR-111BSW-4 • �•o CCR-120B CCR-111C ■ CCR-120C SW-5 4 CCR-110C CCR-122RB CCR-109B CCR-122RC • CCR-109C �'�+ mw 12R� AW-6RB SW-6 �` CCR-108RB MW-23B • `� CCR-108RC MW-23C � . ♦ • , CCR-107R6 •, ® AW-4B CCR-107RC CCR-124RB SW 7 --' CCR-124RC r lI AW-4C ♦- .:-r" w MW-22C AREA 2 FPA-4B FPA-4C n SW-8 FPA-9B �� FPA-9C • • • AREA 4 SMW-1 B • SMW-1C • • • • / MW-21C • - • FPA-3B MW-28B ` • • • 3W--9 • - FPA-3C MW-16 • MW-16D AREA 1A MW�6B MW�6C rMW-1R-BC _ V 456 M W-20 111 MW-2OD - -44C iii��► MW-50C � • - � ♦ % MW-43B MW-43C R„ AMINO- - .r I " ` -.. AREA 3B / MW-37B �� MW-37C � ♦ s _ , GRAPHIC SCALE ' 500 0 500 ,_,000 ESUKE RGY �N IN FEET) PROGRESS DRAWN BY: J. KIRTZ DATE: 11/15/2019 REVISED BY: C. CURRIER CHECKED BY: H. SHARITT DATE: 07/27/2020 DATE: 07/27/2020 APPROVED BY: B. WYLIE DATE: 07/27/2020 �. T .�....• PROJECT MANAGER: B. WYLIE FIGURE 2 POST -EXCAVATION EFFECTIVENESS MONITORING PROGRAM ELEMENTS GROUNDWATER AND SURFACE WATER EFFECTIVENESS MONITORING PLAN L.V. SUTTON ENERGY COMPLEX WILMINGTON, NORTH CAROLINA Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex TABLES SynTerra T U C iU Cr d L U. c a rn L i� iv E M L M IL oI e a E M rn ■ TABLE 1 POST -EXCAVATION EFFECTIVENESS MONITORING PLAN ELEMENTS SOURCE AREAS 1 AND 2 GROUNDWATER AND SURFACE WATER EFFECTIVENESS MONITORING PLAN L.V. SUTTON ENERGY COMPLEX DUKE ENERGY PROGRESS, LLC, WILMINGTON, NC Post -Excavation Effectiveness Monitoring Plan (EMP) Implemented 30 days after CAP Approval Post -Excavation EMP Groundwater Well Monitoring Network 77 Wells (background, downgradient of source areas) AW-04B CCR-113B FPA-03C MW-16D MW-40C SMW-06B AW-04C CCR-113C FPA-04B MW-20 MW-41B1 SMW-06C AW-06B CCR-114B FPA-04C MW-20D MW-41C1 CCR-107RB CCR-114C FPA-09B M W-21C M W-43B CCR-107RC CCR-119B FPA-09C M W-23B M W-43C CCR-108RB CCR-119C M W-05B1 M W-23C M W-44B CCR-108RC CCR-120B MW-05C1 MW-27B MW-44C CCR-109B CCR-120C M W-07B M W-27C M W-45B CCR-109C CCR-122RB M W-07C M W-28B M W-45C CCR-110B CCR-122RC M W-081 M W-28C M W-46B CCR-110C CCR-124RB MW-08B1 MW-37B1 MW-46C CCR-111B CCR-124RC MW-12R MW-37C1 MW-50B CCR-111C CCR-204C M W-15R-B M W-39B M W-50C CCR-112B DMW-04 MW-15R-C MW-39C SMW-01B CCR-112C FPA-03B MW-16 MW-40B SMW-01C Post -Excavation EMP Surface Water Monitoring Network 12 Locations (background, downgradient of source areas) SW-2 SW-5 SW-8 SW-141 SW-3 SW-6 SW-9 SW-151 SW-4 SW-7 SW-10 SW-17 Post -Excavation EMP Groundwater Quality 3, 4 (Quarterly for 1 Year Followed by Semi -Annual Sampling Frequency) Alkalinity (CO3/HCO3) Chromium (hexavalent)^ Magnesium^ Phosphorous^ Strontium^ Aluminum^ Arsenic^ Cobalt^ Manganese^ Potassium^ Sulfate^ Barium^ Boron2^ Fluoride^ Molybdenum^ Selenium^ TDS (Total Dissolved Solids)2 Nitrate + Nitrite Calcium^ Iron^ pH Sodium^ Vanadium^ TOC (Total Organic Carbon) Chloride^ Lithium^ Post -Excavation EMP Surface Water Quality 3, 4 (Quarterly for 1 Year Followed by Semi -Annual Sampling Frequency) Aluminum^ Boron^ Cobalt^ Manganese^ Potassium Thallium (low level)^ Alkalinity (as CaCO3) Cadmium^ Copper^ Mercury^ Selenium^ TDS Antimony^ Calcium Fluoride Methane Silver^ TOC Arsenic^ Carbonate Hardness Molybdenum^ Sodium TSS (Total Suspended Solids) Barium^ Chloride Iron^ Nickel^ Strontium^ Vanadium (low level)^ Beryllium^ Chromium (VI)^ Lead^ Nitrate + Nitrite Sulfate Zinc^ Bicarbonate Chromium^ Magnesium Phosphorous^ Sulfide Post -Excavation EMP Groundwater and Surface Water Field Parameters Dissolved Oxygen (DO) pH Oxidation Reduction Potential Specific Conductivity Temperature (ORPost-Excavation Turbidity EMP Duration Annual Effectiveness monitoring Evaluation and Keporting 1) Summary of annual groundwater monitoring results 2) Evaluate statistical concentration trends 2) Comparison of observed concentrations to model predictions 3) Evaluation of compliance with applicable Standards 4) Evaluation of system performance and effectiveness 4) Recommend plan adjustments, if applicable, to optimize the remedial action 5-Year Post -Excavation EMP Review Reporting 1) Update background analysis 2) Confirm Risk Assessment assumptions remain valid 3) Re-evaluate effectiveness of technology 4) Verify modeling results, update model if needed 5) Modify corrective action approach, as needed, to achieve compliance goal established Post -Excavation EMP Review 30 days after CAP approval, the EMP will be implemented at the Site and will continue until there is a total of three years of data confirming COIs are below applicable Standards at or beyond the compliance boundary, at which time a request for completion of active remediation will be filed with NCDEQ. If applicable standards are not met after five years, the EMP will continue and the air sparging contingency option will be implemented if necessary. i Approved background groundwater monitoring location Geochemically non -reactive constituent (i.e., conservative corrective action COI) that best depicts the areal extent of the plume; monitors plume stability and physical attenuation ' The number of sample locations and parameters may be adjusted based on additional data and the effects of corrective action. 4 Groundwater standards may be modified over time in accordance with 02L .0106(k) ^Dissolved parameters are recommended to be collected for all 2018 CSA Update COIs and aluminum, fluoride, and lithium CAP - Corrective Action Plan COI - Constituent of Interest CSA - Comprehensive Site Assessment DO - Dissolved Oxygen EH - Redox Potential EMP - Effectiveness Monitoring Plan NCDEQ - North Carolina Department of Environmental Quality ORP - Oxidation Reduction Potential TDS - Total Dissolved Solids TOC - Total Organic Carbon Page 1 of 1 TABLE 2 MONITORING WELL CONSTRUCTION SUMMARY GROUNDWATER AND SURFACE WATER EFFECTIVENESS MONITORING PLAN L.V. SUTTON ENERGY COMPLEX DUKE ENERGY PROGRESS, LLC, WILMINGTON, NC Well ID Program Date Installed Monitoring Zone Material Diameter (Inches) Northing (Ft-NAD 83) Easting (Ft-NAD 83) Measuring Point TOC Elevation (Ft -NAND 88) Stick Up Height (Ft) Ground Surface Elevation (Ft -NAND 88) DTW From TOC z (Ft) Water Level Elevation (Ft - NAVD 88) Total Well Depth Elevation (Ft - NAVD 88) Total Well Depth s (Ft BGS) Measured Well Depth i (Ft TOC) Screened Interval s (Ft BGS) Screen Length (Ft) Top of Screen Elevation (Ft - NAVD 88) Bottom of Screen Elevation (Ft - NAND 88) AW-04B CAMA 1/30/2015 Upper Surficial PVC 2 198813.04 2307820.80 19.31 -0.38 19.69 NM NM -6.99 27 26.30 22 27 5 -2.00 -7.00 AW-04C CAMA 1/29/2015 Lower Surficial PVC 2 198803.16 2307818.22 18.94 -0.44 19.38 10.80 8.14 -27.96 47 46.90 42 47 1 5 -23.00 -28.00 AW-06R-13 CAMA 3/29/2017 Upper Surficial PVC 2 199662.47 2307519.73 21.56 2.92 18.64 NM NM -6.29 25 27.85 20 25 5 -1.30 -6.30 CCR-107R-B CCR 1/21/2020 Upper Surficial PVC 2 198682.63 2304262.33 15.10 2.89 12.21 NM NM -20.71 31 35.81 21 31 10 -10.71 -20.71 CCR-107R-C CCR 1/21/2020 Lower Surficial PVC 2 198677.812 2304260.434 15.087 2.78 12.31 NM NM -46.09 56.0 61.18 46 56 10 -36.09 -46.09 CCR-108R-B CCR 1/23/2020 Upper Surficial PVC 2 199110.67 2304123.97 15.05 2.90 12.15 NM NM -10.35 22.0 25.40 12 22 10 -0.35 -10.35 CCR-108R-C CCR 1/23/2020 Lower Surficial PVC 2 199107.33 2304121.09 15.16 3.07 12.09 NM NM -36.17 47.0 51.33 37 47 10 -26.17 -36.17 CCR-109B CCR 5/19/2016 Upper Surficial PVC 2 199546.93 2304319.32 14.96 3.12 11.84 NM NM -13.30 25 28.26 15 25 10 -3.30 -13.30 CCR-109C CCR 5/19/2016 Lower Surficial PVC 2 199540.48 2304320.35 14.90 3.17 11.73 NM NM -33.24 45 48.14 35 45 10 -23.24 -33.24 CCR-11013 CCR 5/24/2016 Upper Surficial PVC 2 199975.21 2304062.24 14.24 3.09 11.15 NM NM -13.37 25 27.61 15 25 10 -3.37 -13.37 CCR-110C CCR 5/24/2016 Lower Surficial PVC 2 199969.27 2304064.03 14.21 3.09 11.12 NM NM -30.87 42 45.08 32 42 10 -20.87 -30.87 CCR-11113 CCR 5/25/2016 Upper Surficial PVC 2 200428.51 2304077.85 12.83 3.17 9.66 NM NM -12.66 22 25.49 12 22 10 -2.66 -12.66 CCR-111C CCR 5/25/2016 Lower Surficial PVC 2 200432.23 2304079.62 12.78 3.14 9.64 NM NM -33.18 43 45.96 33 43 10 -23.18 -33.18 CCR-112B CCR 5/27/2016 Upper Surficial PVC 2 200963.16 2304267.23 14.38 3.26 11.12 NM NM -11.72 23 26.10 13 23 10 -1.72 -11.72 CCR-112C CCR 5/26/2016 Lower Surficial PVC 2 200967.63 2304267.31 14.20 3.33 10.87 NM NM -31.16 42 45.36 32 42 10 -21.16 -31.16 CCR-113B CCR 5/14/2016 Upper Surficial PVC 2 201424.44 2304254.06 13.93 3.16 10.77 NM NM -13.25 24 27.18 14 24 10 -3.25 -13.25 CCR-113C CCR 5/16/2016 Lower Surficial PVC 2 201430.88 2304257.74 13.69 3.06 10.63 NM NM -35.11 46 48.80 36 46 10 -25.11 -35.11 CCR-114B CCR 5/10/2016 Upper Surficial PVC 2 201861.76 2304322.60 20.81 3.02 17.79 11.90 8.91 -7.18 25 27.99 15 25 10 2.82 -7.18 CCR-114C CCR 5/10/2016 Lower Surficial PVC 2 201863.08 2304327.43 20.60 2.98 17.62 11.61 8.99 -26.59 44 47.19 34 44 10 -16.59 -26.59 CCR-119B CCR 4/23/2016 Upper Surficial PVC 2 200649.10 2305739.44 20.51 3.03 17.48 NM NM -7.70 25 28.21 15 25 10 2.30 -7.70 CCR-119C CCR 4/23/2016 Lower Surficial PVC 2 200666.16 2305733.84 20.63 3.18 17.45 NM NM -27.53 45 48.16 35 45 10 -17.53 -27.53 CCR-120B CCR 4/25/2016 Upper Surficial PVC 2 200211.13 2305901.31 21.36 2.80 18.56 NM NM -6.72 25 28.08 15 25 10 3.28 -6.72 CCR-120C CCR 4/25/2016 Lower Surficial PVC 2 200205.69 2305903.14 21.46 2.99 18.47 NM NM -30.70 49 52.16 39 49 10 -20.70 -30.70 CCR-122RB CCR 1/16/2020 Upper Surficial PVC 2 199369.86 2306195.01 22.80 2.75 20.05 NM NM -9.81 29 32.61 19 29 10 0.19 -9.81 CCR-122RC CCR 1/16/2020 Lower Surficial PVC 2 199366.88 2306197.60 22.80 2.69 20.11 NM NM -34.02 62 56.82 44 54 10 -24.02 -34.02 CCR-124RB CCR 1/15/2020 Upper Surficial PVC 2 198347.63 2306506.94 22.72 2.80 19.92 NM NM -7.19 26 29.91 16 26 10 2.81 -7.19 CCR-124RC CCR 1/15/2020 Lower Surficial PVC 2 198342.73 2306509.08 22.74 3.06 19.68 NM NM -32.24 57 54.98 41 51 10 -22.24 -32.24 CCR-204C CCR 2/27/2017 Lower Surficial PVC 2 199926.40 2307355.65 27.89 2.29 25.60 NM NA -26.20 52 54.09 42 52 10 -16.20 -26.20 DMW-4 CCR 2/27/2017 Upper Surficial PVC 2 199916.76 2307359.24 28.15 2.33 25.82 NM NA -0.49 26 28.64 16 26 10 9.51 -0.49 FPA-36 CAMA 7/15/2019 Upper Surficial PVC 2 197613.40 2306363.68 19.75 3.24 16.51 11.23 8.52 -8.89 26 28.64 16 26 10 1.11 -8.89 FPA-3C CAMA 7/15/2019 Lower Surficial PVC 2 197606.08 2306371.91 18.97 2.55 16.42 10.73 8.24 -34.82 59 53.79 49 59 10 -24.82 -34.82 FPA-4B CAMA 7/19/2019 Upper Surficial PVC 2 197780.08 2306755.37 14.75 2.54 12.22 6.29 8.46 -9.70 22 24.45 12 22 10 0.30 -9.70 FPA-4C CAMA 7/18/2019 Lower Surficial PVC 2 197789.37 2306749.33 14.75 2.51 12.24 6.08 8.67 -33.46 49 48.21 39 49 10 -23.46 -33.46 FPA-96 CAMA/CCR 7/15/2019 Upper Surficial PVC 2 197832.54 2306377.17 25.49 2.13 23.36 17.08 8.41 -8.86 32 34.35 22 32 10 1.14 -8.86 FPA-9C CAMA/CCR 7/15/2019 Lower Surficial PVC 2 197826.04 2306374.48 25.39 2.82 22.57 16.94 8.45 -34.87 57.5 60.26 47.5 57.5 10 -24.87 -34.87 MW-05B CAMA 12/15/1986 Upper Surficial PVC 2 205913.11 2303859.22 13.65 0.94 12.71 4.47 9.18 -13.90 27 27.55 22 27 5 -9.00 -14.00 MW-05C NPDES 12/15/1986 Lower Surficial PVC 2 205901.75 2303862.83 13.37 0.26 13.11 4.25 9.12 -31.29 44 44.66 39 44 5 -26.30 -31.30 MW-07B CAMA 12/14/1986 Upper Surficial PVC 2 196603.05 2307572.21 16.59 0.96 15.63 NM NM -11.36 27 27.95 22 27 5 -6.40 -11.40 MW-07C NPDES 12/14/1986 Lower Surficial PVC 2 196599.00 2307569.14 15.98 0.24 15.74 7.42 8.56 -28.92 45 44.90 35 45 10 -18.90 -28.90 MW-08 CAMA 2/7/1990 Lower Surficial PVC 2 206893.50 2304447.55 16.43 2.70 13.73 6.95 9.48 -36.07 50 52.50 45 50 5 -31.10 -36.10 MW-08B CAMA 6/11/2018 Upper Surficial PVC 2 206899.50 2304428.16 16.81 3.13 13.69 7.40 9.41 -10.82 25 27.63 14.5 24.5 10 -0.82 -10.82 MW-12R NPDES 3/27/2017 Lower Surficial PVC 2 199657.64 2307521.43 21.70 3.09 18.61 13.42 8.28 -36.00 55 57.70 45 55 10 -26.00 -36.00 MW-15RB CAMA 7/12/2019 Upper Surficial PVC 2 196491.15 2306132.25 13.57 3.77 9.80 6.28 7.29 -15.68 26 29.25 16 26 10 -5.68 -15.68 MW-15RC CAMA 7/12/2019 Lower Surficial PVC 2 196490.55 2306121.78 13.47 3.72 9.75 6.19 7.28 -39.87 50 53.34 40 50 10 -29.87 -39.87 MW-16 CAMA 6/22/2004 Upper Surficial PVC 2 196976.18 2306753.30 16.91 2.80 14.11 7.43 9.48 1.81 12 15.10 2 12 10 12.10 2.10 MW-16D CAMA 2/4/2004 Lower Surficial PVC 2 196963.07 2306758.20 16.43 2.43 14.00 7.06 9.37 -32.87 47 49.30 42 47 5 -31.30 -36.30 MW-20 CAMA 2/4/2005 Upper Surficial PVC 2 196258.05 2305318.06 13.70 2.92 10.78 6.85 6.85 -3.38 14 17.08 4 14 10 6.60 -3.40 MW-20D CAMA 2/4/2005 Lower Surficial PVC 2 196257.01 2305326.19 13.66 2.93 10.73 6.87 6.79 -37.63 48 51.29 43 48 5 -32.60 -37.60 MW-21C NPDES 9/16/2011 Lower Surficial PVC 2 197773.24 2306913.33 30.14 2.50 27.64 21.50 8.64 -18.11 46 48.25 41 46 5 -13.10 -18.10 MW-23B CAMA 9/6/2011 Upper Surficial PVC 2 198967.48 2306901.58 21.34 3.60 17.74 12.82 8.52 -13.54 31 34.88 27 32 5 -8.54 -13.54 Page 1 of 2 TABLE 2 MONITORING WELL CONSTRUCTION SUMMARY GROUNDWATER AND SURFACE WATER EFFECTIVENESS MONITORING PLAN L.V. SUTTON ENERGY COMPLEX DUKE ENERGY PROGRESS, LLC, WILMINGTON, NC Well ID Program Date Installed Monitoring Zone Material Diameter (Inches) Northing (Ft-NAD 83) Easting (Ft-NAD 83) Measuring Point TOC Elevation (Ft-NAVD 88) Stick Up Height (Ft) Ground Surface Elevation (Ft-NAVD 88) DTW From TOC z (Ft) Water Level Elevation (Ft - NAVD 88) Total Well Depth Elevation (Ft - NAVD 88) Total Well Depth s (Ft BGS) Measured 1 Well Depth (Ft TOC) Screened Interval s (Ft BGS) Screen Length (Ft) Top of Screen Elevation (Ft - NAVD 88) Bottom of Screen Elevation (Ft - NAVD 88) MW-23C NPDES 9/7/2011 Lower Surficial PVC 2 198972.43 2306903.62 21.50 3.61 17.89 12.96 8.54 -31.74 50 53.24 50 55 5 -26.74 -31.74 MW-27B NPDES 9/8/2011 Upper Surficial PVC 2 202583.30 2304678.40 14.34 1.64 12.70 4.75 9.59 -16.26 29 30.60 24 29 5 -11.26 -16.26 MW-27C CAMA 5/12/2014 Lower Surficial PVC 2 202583.80 2304674.50 14.50 3.00 11.50 5.10 9.40 -34.22 46 48.72 41 46 5 -29.20 -34.20 MW-28B NPDES 9/28/2011 Upper Surficial PVC 2 197368.42 2307360.26 31.85 3.22 28.63 23.12 8.73 -2.11 31 33.96 26 31 5 2.90 -2.10 MW-28C NPDES 9/21/2011 Lower Surficial PVC 2 197356.57 2307354.01 31.05 2.88 28.17 22.31 8.74 -17.35 46 48.40 41 46 5 -12.40 -17.40 MW-37B NPDES 2/4/2015 Upper Surficial PVC 2 193820.03 2308956.68 23.71 2.83 20.88 15.69 8.02 -3.79 25 27.50 20 25 5 1.20 -3.80 MW-37C NPDES 2/4/2015 Lower Surficial PVC 2 193819.39 2308959.44 23.72 2.78 20.94 15.72 8.00 -21.18 42 44.90 37 42 5 -16.20 -21.20 MW-39B CAMA 6/6/2016 Upper Surficial PVC 2 202605.27 2303609.74 21.39 3.08 18.31 12.40 8.99 -5.96 24 27.35 19 24 5 -1.00 -6.00 MW-39C CAMA 5/6/2016 Lower Surficial PVC 2 202601.57 2303603.73 21.01 2.96 18.05 12.70 8.31 -26.50 45 47.51 40 45 5 -21.50 -26.50 MW-40B CAMA 6/2/2016 Upper Surficial PVC 2 202121.73 2304378.80 13.94 2.77 11.17 4.60 9.34 -10.68 22 24.62 17 22 5 -5.70 -10.70 MW-40C CAMA 6/2/2016 Lower Surficial PVC 2 202121.79 2304384.84 14.03 2.91 11.12 4.70 9.33 -31.28 42 45.31 37 42 5 -26.30 -31.30 MW-41B CAMA 6/19/2018 Upper Surficial PVC 2 206428.67 2303617.73 21.19 2.80 18.39 12.00 9.19 -6.61 25 27.80 15 25 10 3.39 -6.61 MW-41C CAMA 6/13/2018 Lower Surficial PVC 2 206434.84 2303614.61 21.57 3.03 18.54 12.40 9.17 -26.46 45 48.03 35 45 10 -16.46 -26.46 MW-43B CAMA 7/10/2019 Upper Surficial PVC 2 195608.59 2305810.15 9.54 2.19 7.35 5.04 4.50 -9.94 18 19.48 8 18 10 0.06 -9.94 MW-43C CAMA 7/10/2019 Lower Surficial PVC 2 195613.46 2305817.73 9.61 2.04 7.57 5.04 4.57 -34.97 43 44.58 33 43 10 -24.97 -34.97 MW-44B CAMA 7/19/2019 Upper Surficial PVC 2 195927.15 2305331.05 12.83 -0.35 13.19 8.40 4.43 -11.94 25 24.77 15 25 10 -1.94 -11.94 MW-44C CAMA 7/19/2019 Lower Surficial PVC 2 195916.75 2305334.04 12.68 -0.38 13.06 8.44 4.24 -37.34 50 50.01 40 50 10 -27.34 -37.34 MW-45B CAMA 7/20/2019 Upper Surficial PVC 2 196349.16 2305031.87 12.48 -0.28 12.77 6.99 5.49 -5.87 19 18.35 9 19 10 4.13 -5.87 MW-45C CAMA 7/20/2019 Lower Surficial PVC 2 196359.70 2305029.23 12.58 -0.24 12.82 7.24 5.34 -32.97 45 45.55 35 45 10 -22.97 -32.97 MW-46B CAMA 7/11/2019 Upper Surficial PVC 2 196250.72 2305770.04 11.78 2.57 9.21 5.65 6.13 -9.72 19 21.50 9 19 10 0.28 -9.72 MW-46C CAMA 7/11/2019 Lower Surficial PVC 2 196251.65 2305758.04 11.80 2.68 9.12 5.62 6.18 -33.23 44 45.03 34 44 10 -23.23 -33.23 MW-50B CAMA 7/10/2019 Upper Surficial PVC 2 195948.65 2306096.48 10.18 2.63 7.55 4.42 5.76 -10.54 18 20.72 8 18 10 -0.54 -10.54 MW-50C CAMA 7/10/2019 Lower Surficial PVC 2 195959.22 2306094.66 10.07 2.22 7.86 4.28 5.79 -32.08 41 42.15 31 41 10 -22.08 -32.08 SMW-01B CAMA 4/14/2015 Upper Surficial PVC 2 199292.01 2308712.96 13.87 -0.04 13.91 5.32 8.55 -10.23 24 24.10 19 24 5 -5.20 -10.20 SMW-01C CAMA 4/14/2015 Lower Surficial PVC 2 199295.12 2308717.75 13.90 -0.09 13.99 5.38 8.52 -32.28 46 46.18 41 46 5 -27.30 -32.30 SMW-06B CAMA 4/10/2015 Upper Surficial PVC 2 200222.83 2309008.69 15.86 1.99 13.87 7.45 8.41 -11.54 25 27.40 20 25 5 -6.50 -11.50 SMW-06C CAMA 4/10/2015 Lower Surficial PVC 2 200222.29 2309012.80 16.05 3.02 13.03 7.72 8.33 -31.07 44 47.12 39 44 5 -26.10 -31.10 Notes: ' - Well depths initially measured by SynTerra June 15, 2015 and updated as new wells are installed. 2 - Water levels collected February, 2020 3 - Values measured during well installation BGS - Below ground surface MSL - Mean sea level NA - Not available NAD 83 -North American Datum of 1983 NAVD 88 -North American Vertical Datum of 1988 NM - Not measured TOC - Top of casing Prepared by: WJW Checked by: ALA Revised by: TAW Page 2 of 2 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex ATTACHMENT A FIELD DATA RECORDS SynTerra GROUNDWATER MONITORING DUKE ENERGY PROGRESS, LLC synTerra 148 River Street, Suite 220 Greenville, South Carolina 29601 (864) 421-9999. (864) 421-9909 Fax www.synTerracorp.com WELL ID: MEASURING POINT: TOC WELL DIAMETER: (IN) WELL DEPTH: (FT) DEPTH TO WATER: (FT) Site: LOW FLOW SAMPLING LOG FIELD PERSONNEL: WEATHER: ❑ SUNNY ❑ OVERCAST ❑ RAIN TEMPERATURE (APPROX): MULTI METER TYPE/S#: TUBITIDY METER TYPE/S# PUMP/TUBING INTAKE DEPTH: START PURGE DATE: END PURGE DATE: TOTAL VOLUME PURGED: SAMPLE DATE: (FT) START PURGE TIME: END PURGE TIME: FINAL READING TIME: !x xx GAI 1 SAMPLE COLLECTION TIME: PURGE METHOD: ❑ Grundfos Pump ❑ 12 Volt Pump ❑ Peristaltic Pump ❑ Dedicated Pump ❑ Teflon Bailer ❑ Polyethylene Bailer SAMPLE METHOD: ❑ Grundfos Pump ❑ 12 Volt Pump ❑ Peristaltic Pump ❑ Dedicated Pump ❑ Teflon Bailer ❑ Polyethylene Bailer WATER LEVEL FLOW RATE TEMPERATURE DO CONDUCTANCE pH ORP* TURBIDITY* OBSERVATION TIME (X.XX FT) (Whole # mL/min) (Whole # ° Celsius) (X.XX mg/L) (Whole # PS/CM) (X.XX su) (Whole # My) (X.X NTU) Clear, Cloudy, w/Floc, w/Fines NOTES NUMBER OF CONTAINERS PRESERVATION 0 E E E E E E E E z o o CONSTITUENTS SAMPLED w METALS ✓ SULFIDE ✓ ALKALINITY, BICARBONATE, CARBONATE ✓ TOTAL ORGANIC CARBON ✓ F, CL, SO4 ✓ TDS ✓ TSS ✓ CHROMIUM (VI) ✓ RADIUM ✓ COMMENTS: IF TURBIDITY >10 NTUS, REDEVELOPMENT NEEDED ❑ YES ❑ NO ALL SAMPLES ON ICE ❑ YES IF YES, OBSERVATIONS FOLLOWING LOWERING OF TUBING OR PUMP IN WELL: IF NO, PROVIDE OBSERVATIONS REGARDING NATURAL CONDITIONS: FIELD VEHICLE ACCESSIBLE ❑ YES ❑ NO Associated midday/end-of-day DO, conductivity, pH within range? (See calibration sheet for this sample date) ❑ YES ❑ NO. If NO, which parameter . NOTE that reported data should be considered as flagged accordingly. * SynTerra is not NC -certified for these parameters. Data collected for information purposes only. To convert ORP to Eh using YSI Professional Plus Multi -Meter, add 205 mV. WELL TAG PROTECTIVE CASING LOCK CAP CONCRETE PAD ..................................... . ......... , ..... ........ .......................... ......................... .......................... ......................... ❑ GOOD ❑ BAD ❑ NONE ❑ GOOD ❑ BAD ❑ NONE ❑ GOOD ❑ BAD 0 NONE 0 GOOD ❑ BAD 0 NONE 0 GOOD 0 BAD 0 NONE 10 synTerra Instrument ID: YSI Professional Plus Serial #• Analyst: Instrument Calibration Log SynTerra Corporation 148 River Street, Suite 220 Greenville, South Carolina 29601 NC Field Parameter Certification No. 5591 Date: Location: PH Initial Calibration (standard units) Reference Method: SW846 9040C Cal. Time Cal. Buffer Cal. Buffer Cal Buffer Check Buffer Measured Value 4.0 7.0 10.0 *pH buffer checks are to be within ± 0.1 pH units of the standards true value 4 Buffer Reference: 10 Buffer Reference: 7 Buffer Reference: Check Buffer Reference: H Calibration Check standard units Time Check Buffer True Value *Check Buffer Measured Value Mid -Day 7.0 End -of -Day 7.0 Other *pH buffer checks are to be within ± 0.1 pH units of the standards true value Check Buffer Reference: Action Required: Specific Conductance (umhos/cm) Reference Method: SW846 9050A Time Calibration Standard True Value Verification standard Measured Value Initial Cal 1409 Mid -Day 1409 End -of -Day 1409 *Verification standard ± 10 percent of the standards true value Calibration Standard Reference: Verification Standard Reference: Action Required: Dissolved Oxygen (mg/L) Reference Method: SM 4500 O G-2001 Time Temp Barometric Meter DO Correction DO at Theoretical °C Pressure (mm Reading Factor Temperature DO Hg) (mg/L) (mg/L) (mg/L) Initial* Mid -Day End -of - Day *Initial meter calibration Theoretical DO = DO from "Dissolved Oxygen Meter Calibration Verification" Table at ambient temp X Correction Factor at Barometric Pressure Theoretical DO and Meter DO reading within + 0.5 mg/l, if not recalibrate meter. Action Required: Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra ATTACHMENT B LOW FLOW SAMPLING PLAN, DUKE ENERGY FACILITIES ASH BASIN GROUNDWATER ASSESSMENT PROGRAM DUKE ENERGY, Low Flow Sampling Plan Duke Energy Facilities Ash Basin Groundwater Assessment Program North Carolina June 10, 2015 Duke Energy I Low Flow Groundwater Sampling Plan Table of Contents & DUKE It'ENERGY. TABLE OF CONTENTS LowFlow Sampling Plan.......................................................................................................1 1.0 PURPOSE...............................................................................................................................1 2.0 GENERAL CONSIDERATIONS.............................................................................................1 3.0 PROCEDURES.......................................................................................................................2 3.1 Pre -Job Preparation.............................................................................................................2 3.2 Water -Level Measurements.................................................................................................3 3.3 Well Purging........................................................................................................................4 3.3.1 Low -Flow Well Purging............................................................................................4 3.3.2 Volume -Averaging Well Purging..............................................................................8 3.4 Sampling.......................................................................................................................10 3.4.1 Low -Flow Sampling...............................................................................................10 3.4.2 Sampling after Volume -Averaging Purge...............................................................11 3.5 Sample Handling, Packing, and Shipping.....................................................................11 3.5.1 Handling................................................................................................................11 3.5.2 Sample Labels.......................................................................................................11 3.5.3 Chain -of -Custody Record......................................................................................12 3.6 Field Quality Control Samples.......................................................................................12 3.7 Field Logbook Documentation.......................................................................................13 3.8 Decontamination and Waste Management...................................................................14 4.0 REFERENCES.....................................................................................................................14 APPENDIX A —Decontamination of Equipment SOP...................................................................15 1.0 Purpose & Application......................................................................................................16 2.0 Equipment & Materials..........................................................................................................16 3.0 Procedure.............................................................................................................................16 3.1 Decontamination of Non -Disposable Sampling Equipment..........................................16 3.2 Decontamination of Field Instrumentation....................................................................16 3.3 Decontamination of Groundwater Sampling Equipment...............................................17 3.4 Materials from Decontamination Activities....................................................................17 APPENDIX B—Sampling Equipment Check List — Table 1..........................................................18 APPENDIX C—Field Logbook/Data Sheets.................................................................................20 Duke Energy I Low Flow Groundwater Sampling Plar 1.0 PURPOSE (DUKE W' ENERGY, 1.0 PURPOSE The purpose of this low flow sampling plan is to establish a standard operating procedure (SOP) to describe collection procedures for groundwater samples from monitoring wells using low -flow purging and sampling techniques or by the volume - averaged purging and sampling method at Duke Energy Ash Basin Groundwater Assessment Program facilities. 2.0 GENERAL CONSIDERATIONS Potential hazards associated with the planned tasks shall be thoroughly evaluated prior to conducting field activities. The Ready -To -Work Plan developed for each facility provides, among other items, a description of potential hazards and associated safety and control measures. Sampling personnel must wear powder -free nitrile gloves or equivalent while performing the procedures described in this SOP. Specifically, gloves must be worn while preparing sample bottles, preparing and decontaminating sampling equipment, collecting samples, and packing samples. At a minimum, gloves must be changed prior to the collection of each sample, or as necessary to prevent the possibility of cross -contamination with the sample, the sample bottles, or the sampling equipment. Field sampling equipment shall be decontaminated in accordance with the Decontamination of Equipment SOP (Appendix A) prior to use. Although sampling should typically be conducted from least to most impacted location, field logistics may necessitate other sample collection priorities. When sampling does not proceed from least to most impacted location, precautions must be taken to ensure that appropriate levels of decontamination are achieved. An example of equipment needed to properly conduct low -flow purging and sampling or volume- averaged groundwater purging and sampling is listed on the example checklist in Table 1 (Appendix B). If a portable generator is used to power the purge pump, it shall be attempted to be located downwind of the well being sampling to avoid cross -contamination of the sample with exhaust from the generator motor. Duke Energy I Low Flow Groundwater Sampling Plan 3.0 PROCEDURES (.,DUKE W' ENERGY, 3.0 PROCEDURES The following sections describe the general operating procedures and methods associated with groundwater sampling. Any variation in these procedures must be approved by the Project Manager (PM) and Quality Assurance/Quality Control (QA/QC) Lead and must be fully documented. Field work cannot progress until deviations are approved or resolved. 3.1 Pre -Job Preparation The information listed below may be reviewed prior to sampling activities, if available, and can be beneficial on -site for reference in the field as necessary: • A list of the monitoring wells to be sampled; • Information describing well location, using site -specific or topographic maps or Global Positioning System (GPS) coordinates and descriptions tied directly to prominent field markers; • A list of the analytical requirements for each sampling location; • Boring logs and well construction details, if available; • Survey data that identify the documented point of reference (V-notch or other mark on well casing) for the collection of depth -to -groundwater and total well depth measurements; • Previous depth -to -groundwater measurements; • Previous pump placement depths (dedicated pumps as well as portable pumps) for each sampling location, if available; • Previous pump settings and pumping and drawdown rates, if available; and • Previous analytical results for each monitoring well, if known. The information above is useful when determining the sampling order, pump intake depth, and purge and recharge rates, and can facilitate troubleshooting. The following activities should be completed prior to mobilizing to the site: • Obtain equipment necessary for completing the sampling activities (see the example checklist in Table 1). • Ensure appropriate laboratory -provided bottles are available for both the required analyses and for QC samples and that there has been thorough coordination with the analytical laboratory. E Duke Energy I Low Flow Groundwater Sampling Plan 3.0 PROCEDURES &L)uKE V' ENERGY. • Obtain site -specific maps or GPS coordinates showing clearly marked monitoring well locations or groundwater sample points. • Review the project work control documents such as the Ready -To -Work Plan, and appropriate SOPs in an effort to determine project -specific sampling requirements, procedures, and goals. • Verify that legal right -of -entry has been obtained and site access has been granted, where required. • Instruct the field team to avoid discussing project data with the public and to refer questions to the Project Manager. 3.2 Water -Level Measurements Prior to pump placement, an initial depth -to -water level and total well depth should be measured. For monitoring wells screened across the water table, this measurement shall be used to determine the required depth to the pump intake (typically, approximately the mid -point of the saturated screen length for low -flow purging and sampling). The procedure for measuring water levels may include the following: 1) Inspect the well head area for evidence of damage or disturbance. Record notable observations in the field logbook. 2) Carefully open the protective outer cover of the monitoring well noting the presence of bee hives and/or spiders, as these animals are frequently found inside well covers. Remove any debris that has accumulated around the riser near the well plug. If water is present above the top of the riser and well plug, remove the water prior to opening the well plug. Do not open the well until the water above the well head has been removed. 3) If practical, well plugs shall be left open for approximately five minutes to allow the static water level to equilibrate before measuring the water level (if well plugs are vented, then a waiting period is not applicable). 4) Using an electronic water -level indicator accurate to 0.01 feet, determine the distance between the established point of reference (usually a V-notch or indelible mark on the well riser) and the surface of the standing water present in the well. Record these data in the field logbook. Repeat this measurement until two successive readings agree to within 0.01 feet. 5) Using an electronic water -level indicator accurate to 0.01 feet, determine the distance between the established point of reference (usually a V-notch or indelible mark on the well riser) and the bottom of the well. Note that there should not be considerable slack in the water -level indicator cable. Record these data in the field logbook. Repeat this measurement until two successive readings agree to within 0.01 feet. 6) If the monitoring well has the potential to contain non -aqueous phase liquids (NAPLs), probe the well for these materials using an optical interface probe. These wells will be attempted to be identified by the Project Manager prior to 3 Duke Energy I Low Flow Groundwater Sampling Plan 3.0 PROCEDURES (.,DUKE W' ENERGY, mobilizing to the well. If NAPL is present, consult the Project Manager for direction on collecting samples for analysis. In general, do not collect groundwater samples from monitoring wells containing NAPL. 7) Decontaminate the water -level indicator (and interface probe, if applicable) and return the indicator to its clean protective casing. 3.3 Well Purging Wells must be purged prior to sampling to ensure that representative groundwater is obtained from the water -bearing unit. If the well has been previously sampled in accordance with this sampling plan, then the depth to the pump intake and the pumping rates should be duplicated to the extent possible during subsequent sampling events. Section 3.3.1 provides a description of low -flow well purging, and Section 3.3.2 provides a description of volume -averaging well purging (in the case it's needed). 3.3.1 Low -Flow Well Purging Adjustable -rate peristaltic, bladder and electric submersible pumps are preferred for use during low -flow purging and sampling activities. Since purging and sampling are joined together as one continuous operation, care will be given to pump selection as it applies to the specific well conditions and analytes to be tested. Note that a ball valve (or similar valve constructed of polyethylene) may need to be installed to reduce the flow rate to the required level. The low -flow purging and sampling guidance is provided below: 1) Using the specific details of well construction and current water -level measurement, determine the pump intake set depth (typically the approximate mid -point of the saturated well screen or other target sample collection depth adjacent to specific high -yield zones). 2) Attach tubing and supporting rope (if applicable) to the pump and very slowly lower the unit until the pump intake depth is reached. Measure the length of supporting rope required, taking into account the pump length, to attain the required depth. Record the depth to the pump intake in the field logbook. Notes: 1 ) Sampling shall use new certified -clean disposable tubing. 2) Rope shall be clean, unused, dedicated nylon rope. If a pump is to remain in a well as part of a separate monitoring program, then the rope shall be suspended within the well above the water column for future use. If the pump is removed after sample collection, the rope shall be disposed. 3) After allowing time for the water level to equilibrate, slowly lower the electronic water -level probe into the well until the probe contacts the groundwater. Record the water level in the field logbook. M Duke Energy I Low Flow Groundwater Sampling Plan 3.0 PROCEDURES (.,DUKE W' ENERGY, 4) If the well has been previously sampled using low -flow purging and sampling methods, begin purging at the rate known to induce minimal drawdown. Frequently check the drawdown rate to verify that minimum drawdown is being maintained. If results from the previous sampling event are not known, begin purging the well at the minimum pumping rate of approximately 100 milliliters per minute (mL/min) (EPA, July 1996). Slowly increase the pumping rate to a level that does not cause the well to drawdown more than about 0.3 feet, if possible. Never increase the pumping rate to a level in excess of 500 mL/min (approximately 0.13 gallon per minute [gpm]). Record the stabilized flow rate, drawdown, and time on the field data sheets. 5) If the drawdown does not stabilize at 100 mL/min (0.026 gpm), continue pumping. However, in general, do not draw down the water level more than approximately 25% of the distance between the static water level and pump intake depth (American Society for Testing and Materials [ASTM], 2011). If the recharge rate of the well is lower than the minimum pumping rate but the drawdown is less than 25% of the distance between the static water level and pump intake depth after three volumes of well water are removed, then collect samples at this point even though indicator field parameters have not stabilized (EPA, July 1996). Commence sampling as soon as the water level has recovered sufficiently to collect the required sample volumes. Otherwise, the Volume -Averaging Well Purging method should be considered.Allow the pump to remain undisturbed in the well during this recovery period to minimize the turbidity of the water samples. Fully document the pump settings, pumping rate, drawdown, and field parameter readings on the Well Sampling / MicroPurge (Low Flow) Log in the field logbook. Note: For wells that either have very slow recharge rates, that draw down excessively (more than 25% of the distance between the static water level and pump intake depth) at the minimum pumping rate (100 mL/min or 0.026 gpm), or require a higher pumping rate (greater than 500 mL/min or 0.13 gpm) to maintain purging, the procedures described above may not apply. For these "special case" wells, the Field Team Leader shall seek guidance from the Project Manager about the appropriate purging and sampling methodologies to be employed (such as volume -averaged purging and sampling described in Section 3.3.2). 6) Once an acceptable flow rate has been established, begin monitoring designated indicator field parameters. Indicator parameters are pH, specific conductance, dissolved oxygen (DO), and turbidity. Although not considered purge stabilization parameters, temperature and oxidation reduction potential (ORP) will be recorded during purging. Base the frequency of the measurements on the time required to completely evacuate one volume of the flow through the cell to ensure that independent measurements are made. For example, a 500-mL cell in a system pumped at a rate of 100 mL/min is evacuated in five minutes; accordingly, measurements are made and recorded on the field data form (Appendix C) approximately five minutes apart. Indicator parameters have stabilized when three consecutive readings, taken at three to five-minute intervals, meet the following criteria (EPA, March 2013): 5 Duke Energy I Low Flow Groundwater Sampling Plan 3.0 PROCEDURES ,if-. DUDE V' ENERGY. • pH • Specific Conductance • DO • Turbidity ± 0.1 standard unit ± 5% in pS/cm ± 0.2 mg/L or 10% saturation less than 10 NTUs The target for monitoring turbidity is readings less than ten nephelometric turbidity units (NTUs). In some instances, turbidity levels may exceed the desired turbidity level due to natural aquifer conditions (EPA, April 1996). When these conditions are encountered, the following guidelines shall be considered. • If turbidity readings are slightly above 10 NTU, but trending downward, purging and monitoring shall continue. • If turbidity readings are greater than 10 NTU and have stabilized to within 10% during three successive readings, attempt to contact the Project Manager prior to collecting the groundwater sample. • If turbidity readings are greater than 10 NTU and are not stable, well sampling shall be based upon stabilization of more critical indicator parameters (such as dissolved oxygen) without attainment of the targeted turbidity. Attempt to contact the Project Manger if this condition is encountered prior to collecting the groundwater sample. • If after 5 well volumes or two hours of purging (whichever is achieved first), critical indicator field parameters have not stabilized, discontinue purging and collect samples. Fully document efforts used to stabilize the parameters (such as modified pumping rates). Note: While every effort should be taken to ensure that indicator parameters stabilize, some indicator parameters are more critical with respect to certain contaminant types. It is important to identify which indicator parameters are most important to the project prior to commencement of field activities so that unnecessarily protracted purge times can be avoided. For example, the critical indicator parameter associated with metals is turbidity. While it is desirable to sample wells when turbidity measurements are less than 5 NTU, Duke Energy recognizes that these values may not be attainable. Duke Energy, and its sub - consultants, have taken multiple steps (e.g., use of pre -packed screens, carefully selected sand pack, etc.) to alleviate the potential for elevated turbidity in newly installed wells. However, even with these conservative and targeted well installation specifications, other naturally occurring conditions (e.g., iron fluctuation) may prevent sampling of wells at turbidity values less than 5 NTU. Following sample collection and laboratory data evaluation, Duke Energy may review these data with respect to turbidity values to determine if additional well development is needed or if well construction has affected groundwater conditions. It may be necessary to redevelop wells from time to time to minimize It Duke Energy I Low Flow Groundwater Sampling Plan 3.0 PROCEDURES &L)uKE V' ENERGY. sample turbidity. Fine silt and clay can collect at the base of a well over time. The effect on future sampling events can be reduced by lowering the tubing or pump to the bottom of the well (after all the groundwater samples have been collected) and pumping until the purge water from the bottom of the well screen is clear. Note: If purging of a well does not result in turbidity measurements of 10 NTU or less, the field sampler shall alert the Project Manager. The sampling team will assess options to reduce the turbidity as soon as possible. There are a variety of water -quality meters available that measure the water quality parameters identified above. A multi -parameter meter capable of measuring each of the water quality parameters referenced previously (except for turbidity) in one flow -through cell is required. Turbidity shall be measured using a separate turbidity meter or prior to flow into the flow through cell using an inline T-valve, if using one multi -meter during purging. The water quality meter (and turbidity meter) shall be calibrated as per manufacturer's instructions. Calibration procedures shall be documented in the project field logbook including calibration solutions used, expiration date(s), lot numbers, and calibration results. 7 Duke Energy I Low Flow Groundwater Sampling Plan 3.0 PROCEDURES ,ff L)uKE V' ENERGY, 3.3.2 Volume -Averaging Well Purging For wells that either have very slow recharge rates, that draw down excessively at the minimum pumping rate (100 mL/min or 0.026 gpm), or require a higher pumping rate (greater than 500 mL/min or 0.13 gpm) to maintain purging (i.e., low -flow well purging and sampling is not appropriate), the volume -averaging well purging and sampling method may be used. The Field Team Leader shall seek approval from the Project Manager before utilizing the volume -averaging method instead of the low -flow method. 3.3.2.1 CALCULATE PURGE VOLUMES Based on the depth -to -water (DTW) and total depth (TD) measurements, the volume of standing water in the well must be calculated using the following procedures. 1) Subtract DTW from TD to calculate the length of the standing water column (Lv,-) in the well. TD — DTW = LWC 2) Multiply the length of the standing water column by the volume calculation (gallon per linear foot of depth) based on the inner casing diameter (see example list below) to determine the total standing water volume; this represents one well volume. VW = LWc x 2rcr2 1-inch well = 0.041 gallon per linear foot 2-inch well = 0.163 gallon per linear foot 4-inch well = 0.653 gallon per linear foot 6-inch well = 1.469 gallons per linear foot 8-inch well = 2.611 gallons per linear foot 3) Multiply the well volume calculated in the previous step by three and five to obtain the approximate respective total purge volume (the target purge volume is between three and five standing well volumes). For wells with multiple casing diameters (such as open bedrock holes), calculate the volume for each segment. Take the sum of the values and multiply by three and five to determine the minimum and maximum purge volumes, respectively. 4) Fully document the volume calculation in the field logbook or on the Groundwater Sampling Field Sheets. E: Duke Energy I Low Flow Groundwater Sampling Plan 3.0 PROCEDURES (.,DUKE W' ENERGY, 3.3.2.2 PURGE THE MONITORING WELL Determine the appropriate pump to be used for purging —the preferred and most commonly used methods involve the use of a surface centrifugal or peristaltic pump whenever the head difference between the sampling location and the water level is less than the limit of suction and the volume to be removed is reasonably small. Where the water level is below the limit of suction or there is a large volume of water to be purged, use the variable speed electric submersible pump as the pump of choice (EPA, 2013). In some cases (shallow wells with small purge volumes), purging with a bladder pump may be appropriate. Once the proper pump has been selected: 1) Set the pump immediately above the top of the well screen or approximately three to five feet below the top of the water table (EPA, 2013). 2) Lower the pump if the water level drops during purging. Note: Use new certified -clean disposable tubing for purging and sampling. Note: Although volume -averaged sampling involves purging a specified volume of water (such as three to five well volumes) rather than basing purge completion on the stabilization of water quality indicator parameters, measuring and recording water -quality indicator parameters during purging provides information that can be used for assessment and remedial decision -making purposes. Indicator parameters are pH, specific conductance, DO, and turbidity as described in Section 3.3.1. Temperature and ORP will also be recorded during purging. 3) During well purging, monitor the discharge rate using a graduated cylinder or other measuring device, water -quality indicator parameters (if desired), and DTW as follows: • Initially, within approximately three minutes of startup, • Approximately after each well volume is purged, and then • Before purge completion. 4) Record pump discharge rates (mL/ min or gpm) and pump settings in the field logbook. Also, record any changes in the pump settings and the time at which the changes were made. 5) Maintain low pumping rates to avoid overpumping or pumping the well to dryness, if possible. If necessary, adjust pumping rates, pump set depth, or extend pumping times to remove the desired volume of water. 6) Upon reaching the desired purge water volume, turn off the purge pump. Do not allow the water contained in the pump tubing to drain back into the well when the pump is turned off. Use an inline check valve or similar device, or if using a peristaltic pump, remove the tubing from the well prior to turning off the pump. It is E Duke Energy I Low Flow Groundwater Sampling Plan 3.0 PROCEDURES &L)uKE V' ENERGY. preferred to collect samples within two hours of purging, but acceptable for collection up to 24 hours of purging. Do not collect samples after 24 hours of purging. Note: The removal of three to five well volumes may not be practical in wells with slow recovery rates. If a well is pumped to near dryness at a rate less than 1.9 L/min (0.5 gpm), the well shall be allowed to completely recover prior to sampling. If necessary, the two-hour limit may be exceeded to allow for sufficient recovery, but samples should be collected within 24 hours of purge completion. 3.4 Sampling 3.4.1 Low -Flow Sampling Following are the procedures for the collection of low -flow groundwater samples. These procedures apply to sample collection for unfiltered and filtered samples using a 0.45 micron filter. See Appendix A for use of 0.1 micron filtered samples. 1) Record the final pump settings in the field logbook prior to sample collection. 2) Measure and record the indicator parameter readings prior to sample collection on both the stabilization form and in the field logbook. 3) Record comments pertinent to the appearance (color, floc, turbid) and obvious odors (such as sulfur odor or petroleum hydrocarbons odor) associated with the water. 4) Arrange and label necessary sample bottles and ensure that preservatives are added, as required. Include a unique sample number, time and date of sampling, the initials of the sampler, and the requested analysis on the label. Additionally, provide information pertinent to the preservation materials or chemicals used in the sample. 5) Collect samples directly from pump tubing prior to the flow -through cell or via the in -line T-valve used for turbidity measurements (as described Section 3.3.1 (6) above). Ensure that the sampling tubing remains filled during sampling and attempt to prevent water from descending back into the well. Minimize turbulence when filling sample containers, by allowing the liquid to run gently down the inside of the bottle. Fill the labeled sample bottles in the following order: • Metals and Radionuclides, • Filtered Metals and Radionuclides, if required, and then • Other water -quality parameters. 6) Seal each sample and place the sample on ice in a cooler to maintain sample temperature preservation requirements. 10 Duke Energy I Low Flow Groundwater Sampling Plan 3.0 PROCEDURES ,ff L)uKE V' ENERGY: 7) Note the sample identification and sample collection time in field logbook and on Chain -of -Custody form. 8) Once sampling is complete, retrieve the sample pump and associated sampling equipment and decontaminate in accordance with procedures outlined in the Decontamination of Equipment SOP (Appendix A). 9) Close and secure the well. Clean up and remove debris left from the sampling event. Be sure that investigation -derived wastes are properly containerized and labeled, if applicable. 10)Review sampling records for completeness. Add additional notes as necessary. 3.4.2 Sampling after Volume -Averaging Purge The procedures described below are for the collection of groundwater samples after a volume -averaged purge has been conducted. Volume- averaging purge methods are described in Section 3.3.2. 1) If sampling with a pump, care shall be taken to minimize purge water descending back into the well through the pump tubing. Minimize turbulence when filling sample containers by allowing the liquid to run gently down the inside of the bottle. Fill the labeled sample bottles in the following order: • Metals and Radionuclides, • Filtered Metals and Radionuclides, if required, and then • Other water -quality parameters. 2) If sampling with a bailer, slowly lower a clean, disposable bailer through the fluid surface. Retrieve the bailer and fill the sample bottles as described above. Care shall be taken to minimize disturbing the sample during collection. 3.5 Sample Handling, Packing, and Shipping Samples shall be marked, labeled, packaged, and shipped in accordance with the sections outline below. 3.5.1 Handling The samples will be stored in coolers for transport to the site. Collected samples will be placed on ice in the sampling coolers for pickup or transport to the laboratory for analysis. 3.5.2 Sample Labels All sample containers will be new, laboratory cleaned and certified bottles. The bottles will be properly labeled for identification and will include the following information: • Project Site/ID 11 Duke Energy I Low Flow Groundwater Sampling Plan 3.0 PROCEDURES ,ff L)uKE V' ENERGY. • Sample identifier (Well ID) • Name or initials of sampler(s) • Date and time of collection • Analysis parameter(s)/method • Preservative 3.5.3 Chain -of -Custody Record Sample transport and handling will be strictly controlled to prevent sample contamination. Chain -of -Custody control for all samples will consist of the following: • Sample containers will be securely placed in coolers (iced) and will remain under the supervision of project personnel until transfer of the samples to the laboratory for analysis has occurred. Upon delivery to the laboratory, the laboratory director or his designee will sign the Chain -of -Custody control forms and formally receive the samples. The laboratory will ensure that proper refrigeration of the samples is maintained. The Chain -of -Custody document contains information which may include: • Client name • Client project name • Client contact • Client address • Client phone/fax number • Sampler(s) name and signature • Signature of person involved in the chain of possession • Inclusive dates of possession • Sample identification • Sample number • Date & time of collection • Matrix • Type of container and preservative • Number of containers • Sample type - grab or composite • Analysis parameter(s)/ method • Internal temperature of shipping container upon opening in the laboratory 3.6 Field Quality Control Samples Field quality control involves the routine collection and analysis of QC blanks to verify that the sample collection and handling processes have not impaired the quality of the samples. 12 Duke Energy I Low Flow Groundwater Sampling Plan 3.0 PROCEDURES (.,DUKE W' ENERGY, • Equipment Blank — The equipment blank is a sample of deionized water, which is taken to the field and used as rinse water for sampling equipment. The equipment blank is prepared like the actual samples and returned to the laboratory for identical analysis. An equipment blank is used to determine if certain field sampling or cleaning procedures result in cross -contamination of site samples or if atmospheric contamination has occurred. One equipment blank sample will be prepared per day or per 20 groundwater samples, whichever is more frequent. Field and laboratory QA/QC also involves the routine collection and analysis of duplicate field samples. These samples are collected at a minimum rate of approximately one per 20 groundwater samples per sample event. A field duplicate is a replicate sample prepared at the sampling locations from equal portions of all sample aliquots combined to make the sample. Both the field duplicate and the sample are collected at the same time, in the same container type, preserved in the same way, and analyzed by the same laboratory as a measure of sampling and analytical precision. 3.7 Field Logbook Documentation Field logbooks shall be maintained by the Field Team Leader to record daily activities. The field logbook may include the following information for each well: • Well identification number • Well depth • Static water level depth • Presence of immiscible layers (yes — no) • Estimated well yield, if known • Purge volume and purge pumping rate • Time well purge began and ended • Well evacuation procedure and equipment • Field analysis data • Climatic conditions including air temperature • Field observations on sampling event • Well location • Name of collector(s) • Date and time of sample collection • Sampling procedure • Sampling equipment • Types of sample containers used and sample identification numbers • Preservative used 13 Duke Energy I Low Flow Groundwater Sampling Plan 4.0 REFERENCES (.,DUKE V'ENERGY, The Field Team Leader shall review the field logbook entries for completeness and accuracy. The Field Team Leader is responsible for completion of the required data collection forms. Example field logs are in Appendix C. 3.8 Decontamination and Waste Management Sampling equipment decontamination shall be performed in a manner consistent with the Decontamination of Equipment SOP (Appendix A). Decontamination procedures shall be documented in the field logbook. Investigation -derived wastes produced during sampling or decontamination shall be managed in accordance with State and Station -specific rules for disposal of wastes. 4.0 REFERENCES American Society for Testing and Materials (ASTM). Standard Practice for Low -Flow Purging and Sampling for Wells and Devices Used for Ground -Water Quality Investigations, D 6771-02. 2011. Test Methods for Evaluating Solid Waste - Physical/Chemical Methods (SW-846), Third Edition. U.S. Environmental Protection Agency. Update I, II, IIA, IIB, III, IIIA, IVA and IVB. United States Environmental Protection Agency (EPA), Office of Research and Development, Office of Solid Waste and Emergency Response. Ground Water Issue, "Low -Flow (Minimal Drawdown Sampling Procedures). Document Number EPA/540/S- 95/504," April 1996. U.S. EPA. Region 4, Groundwater Sampling Operating Procedure. Document Number SESDPROC-301-R3, November 2013. U.S. EPA. Region I, Low Stress (Low Flow) Purging and Sampling Procedure for the Collection of Ground Water Samples from Monitoring Wells, Revision 2, July 1996. 14 Duke Energy I Low Flow Groundwater Sampling Plar Decontamination of Equipment SOP jrDuKF *' ENERGY, 0- t#00r, Decontamination of Equipment SOP 15 Duke Energy I Low Flow Groundwater Sampling Plar Purpose & Application (.� DUKE V' ENERGY, 1.0 Purpose & Application This procedure describes techniques meant to produce acceptable decontamination of equipment used in field investigation and sampling activities. Variations from this SOP should be approved by the Project Manager prior to implementation and a description of the variance documented in the field logbook. 2.0 Equipment & Materials • Decontamination water, • Alconox detergent or equivalent non -phosphate detergent • Test tube brush or equivalent • 5-gallon bucket(s) • Aluminum foil • Pump 3.0 Procedure 3.1 Decontamination of Non -Disposable Sampling Equipment Decontamination of non -disposable sampling equipment used to collect samples for chemical analyses will be conducted prior to each sampling as described below. Larger items may be decontaminated at the decontamination pad. Smaller items may be decontaminated over 5-gallon buckets. Wastewater will be disposed in accordance with applicable State and Station -specific requirements. 1. Alconox detergent or equivalent and water will be used to scrub the equipment. 2. Equipment will be first rinsed with water and then rinsed with distilled/deionized water. 3. Equipment will be air dried on plastic sheeting. 4. After drying, exposed ends of equipment will be wrapped or covered with aluminum foil for transport and handling. 3.2 Decontamination of Field Instrumentation Field instrumentation (such as interface probes, water quality meters, etc.) will be decontaminated between sample locations by rinsing with deionized or distilled water. If visible contamination still exists on the equipment after the rinse, an Alconox (or equivalent) detergent scrub will be added and the probe thoroughly rinsed again. Decontamination of probes and meters will take place in a 5-gallon bucket. The decontamination water will be handled and disposed in accordance with applicable State and Station -specific requirements. 16 Duke Energy I Low Flow Groundwater Sampling Plar 3.0 Procedure jfft DUKE V'ENERGY. 3.3 Decontamination of Groundwater Sampling Equipment Non -disposable groundwater sampling equipment, including the pump, support cable and electrical wires in contact with the sample will be thoroughly decontaminated as described below: 1. As a pre -rinse, the pump will be operated in a deep basin containing 8 to 10 gallons of water. Other equipment will be flushed with water. 2. The pump will be washed by operating it in a deep basin containing phosphate - free detergent solution, such as Alconox, and other equipment will be flushed with a fresh detergent solution. Detergent will be used sparingly, as needed. 3. Afterwards, the pump will be rinsed by operating it in a deep basin of water and other equipment will be flushed with water. 4. The pump will then be disassembled and washed in a deep basin containing non -phosphate detergent solution. All pump parts will be scrubbed with a test tube brush or equivalent. 5. Pump parts will be first rinsed with water and then rinsed with distilled/deionized water. 6. For a bladder pump, the disposable bladder will be replaced with a new one for each well and the pump reassembled. 7. The decontamination water will be disposed of properly. 3.4 Materials from Decontamination Activities All wastewater and PPE generated from decontamination activities will be handled and disposed in accordance with applicable State and Station -specific requirements. 17 Duke Energy I Low Flow Groundwater Sampling Plar Sampling Equipment Check List — Table 1 j�DUKE ENERGY, Sampling Equipment Check List — Table 1 W Duke Energy I Low Flow Groundwater Sampling Plar Sampling Equipment Check List — Table 1 DUDE t ENERGY, Table 1: Suggested Groundwater Sampling Equipment & Material Checklist Item Description Check Health & Safety Nitrile gloves Hard hat Steel -toed boots Hearing protection Field first -aid kit Fire Extinguisher Eyewash Safety glasses Respirator and cartridges (if necessary) SaranexTM/Tyvek® suits and booties (if necessary) Paperwork Health and Safety Plan Project work control documents Well construction data, location map, field data from previous sampling events Chain -of -custody forms and custody seals Field logbook Measuring Equipment Flow measurement supplies (for example, graduated cylinder and stop watch) Electronic water -level indicator capable of detecting non -aqueous phase liquid Sampling Equipment GPS device Monitoring well keys Tools for well access (for example, socket set, wrench, screw driver, T-wrench) Laboratory -supplied certified -clean bottles, preserved by laboratory (if necessary) Appropriate trip blanks and high -quality blank water Sample filtration device and filters Submersible pump, peristaltic pump, or other appropriate pump Appropriate sample and air line tubing (Silastie, Teflon°, Tygono, or equivalent) Stainless steel clamps to attach sample lines to pump Pump controller and power supply Oil -less air compressor, air line leads, and end fittings (if using bladder pump) In -line groundwater parameter monitoring device (for example, YSI-556 Multi - Parameter or Horiba U-52 water quality meter) Turbidity meter Bailer Calibration standards for monitoring devices 19 Duke Energy I Low Flow Groundwater Sampling Plar Field Logbook/Data Sheets J�DUKE ENERGY, Logbook/Data 20 Duke Energy I Low Flow Groundwater Sampling Plar Field Logbook/Data Sheets DUDE t ENERGY, Groundwater Potentiometric Level Measurement Log `A DUKE � ENERGY Well Number Time Depth to Water (ft)* Depth to Bottom (ft)* water Column Thickness (ft) Reference Point Elevation (ft, MSL) potentiometric Elevation (ft, MSL) Remarks Field Personnel: Checked By: * - Measurements are referenced from the top of the PVC inner casing (TOC) for each respective monitoring well. TOCs shall be surveyed by a Professional Land Surveyor and referenced to NAVD88. 21 Duke Energy I Low Flow Groundwater Sampling Plar Field Logbook/Data Sheets J�DUKE ENERGY, Well Sampling / MicroPurge Log ' DUKE ENERGY, Project Name: Sheet: of Well Number: Date: Well Diameter: Top of Casing Elevation (ft, MSL): Pump Intake Depth (ft): Total Well Depth (ft): Recharge Rate (sec): Initial Depth to Water (ft): Discharge Rate (sec): Water Column Thickness (ft): Controller Settings: Water Column Elevation (ft, MSL): Purging Time Initiated: 1 Well Volume (gal): Purging Time Completed: 3 Well Volumes (gal): ITotal Gallons Purged: WELL PURGING RECORD Time Volume Purged (gallons) Flow Rate mL/min Depth to Water ft Temperature °C pH s.u. Specific Conductance (mS/cm) Dissolved Oxygen (mg/L) ORP m Turbidity T Comments Stabilization Criteria Min. 1 Well Volume + 3°C + 0.1 + 3% + 10% + 10 mV < s n ru or+ io i if, s NTu GROUNDWATER SAMPLING RECORD Sample Number Collection Time Parameter Container Preservative 22 Duke Energy I Low Flow Groundwater Sampling Plar Field Logbook/Data Sheets J�DUKE ENERGY, Project Name: Field Manager: Date: Weather: Labor Field Observations: DAILY FIELD REPORT J<jpfiDUKE ENERGY. Hours Field Personnel: Equipment Materials Submitted by: 23 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex ATTACHMENT C SynTerra DUKE ENERGY ENVIRONMENTAL SERVICES QUALITY ASSURANCE MANUAL ENVIRONMENTAL SERVICES QUALITY ASSURANCE MANUAL Revision 8 Our signatures below indicate our approval of the Environmental Services Quality Assurance Program. We give our full support to Quality Assurance Program requirements as stated in this manual. '2w 16 -r Signature i date QA officer, Environmental Services Daniel C. Arndt a'AIAL-40;-25-43 Signaturt 1 ate QA Ad i strator. Environmental Services Sherry . Reid ln1e. `/1" / I- is ",, Signature / date QA Officer, Environmental Services W. Reid Garrett �.��. , 44-11 ._ jb-slt3 Signature / date QA Officer, Analytical Laboratory GC Sharma DUKE ENERGY®r, Environmental Services MG03A2 13339 Hagers Ferry Rd Huntersville, NC 28078 Effective 11 /07/2013 This page left blank intentionally. Environmental Services QA Manual (revision 8) Page ii of x Effective 11/07/2013 Letter of Promulgation A robust Quality Assurance Program is foundational to the success of Environmental Services. Its complete execution will help to ensure that the data provided to our clients is accurate, defensible, compliant with regulatory requirements and timely. It is my expectation that these program provisions are followed. This Quality Assurance Program has our full endorsement. Signature / to Manager, Natural Resources Penny C. Franklin SigIger, ure / date Ma Analytical Laboratory Zachary S. Hall :Signature/ date Signature / date Manager, Environmental Monitoring Manager, Water Resources R. Duane Harrell Linda D. Hickok Environmental Services QA Manual (revision 8) Page iii of x Effective 11 /07/2013 This page left blank intentionally. Environmental Services QA Manual (revision 8) Page iv of x Effective 11/07/2013 TABLE OF CONTENTS Letterof Promulgation................................................................................................................... iii TABLE OF CONTENTS.................................................................................................................v REVIEW / REVISION HISTORY................................................................................................ ix CHAPTER 1- INTRODUCTION..............................................................................................1-1 CHAPTER2- SCOPE................................................................................................................ 2-1 CHAPTER 3- CODE OF ETHICS........................................................................................... 3-1 CHAPTER 4- QUALITY ASSURANCE RESPONSIBILITIES AND ORGANIZATION 4-1 CHAPTER 5- PROJECTS......................................................................................................... 5-1 CHAPTER 6- CERTIFICATIONS AND INTER -LABORATORY QUALITY ASSURANCE............................................................................................................................. 6-1 A. CERTIFICATIONS..................................................................................................... 6-1 B. INTER -LABORATORY PERFORMANCE EVALUATION (PE) PROGRAMS .... 6-3 C. RESPONSIBILITIES FOR PE PROGRAMS............................................................. 6-3 1. QA Officers.............................................................................................................. 6-3 2. Supervisors, Project Leads, or Designees................................................................ 6-3 CHAPTER 7- WORK PLACE.................................................................................................. 7-1 A. GENERAL FACILITIES............................................................................................ 7-1 B. LABORATORY REQUIREMENTS.......................................................................... 7-2 CHAPTER 8- HOUSEKEEPING............................................................................................. 8-1 A. GENERAL.................................................................................................................. 8-1 B. WORK AREAS........................................................................................................... 8-1 C. WALKWAYS AND AISLES..................................................................................... 8-2 D. ALL AREAS............................................................................................................... 8-2 CHAPTER 9- INSTRUMENTATION AND EQUIPMENT..................................................9-1 A. MAINTENANCE........................................................................................................9-1 B. MAINTENANCE RECORDS.................................................................................... 9-1 C. CALIBRATIONS........................................................................................................ 9-2 1. Balance Calibrations................................................................................................ 9-3 2. Temperature Device Calibrations............................................................................ 9-3 3. Meteorological Instrument Calibrations.................................................................. 9-4 D. EQUIPMENT CONTROL.......................................................................................... 9-4 E. RECORDS...................................................................................................................9-4 Environmental Services QA Manual (revision 8) Page v of x Effective 11/07/2013 F. OUT-OF-TOLERANCE............................................................................................. 9-5 CHAPTER 10- SAMPLE CONTROL......................................................................................10-1 A. SAMPLE IDENTIFICATION AND TRACEABILITY ........................................... 10-1 B. SAMPLING AND ANALYSIS REQUESTS........................................................... 10-1 C. SAMPLE COLLECTION AND PRESERVATION ................................................. 10-2 D. SAMPLE LOG-IN..................................................................................................... 10-2 E. SAMPLE STORAGE................................................................................................ 10-2 F. SAMPLE DISPOSAL............................................................................................... 10-3 CHAPTER 11- REAGENTS AND CHEMICALS..................................................................11-1 A. QUALITY................................................................................................................. 11-1 B. LABORATORY PURE WATER............................................................................. 11-1 C. REAGENTS/SOLUTIONS/STANDARDS..............................................................11-2 D. STANDARD AND REAGENT CHEMICAL DISPOSAL ...................................... 11-3 CHAPTER 12- PROCEDURES................................................................................................12-1 A. GENERAL PROCEDURE REQUIREMENTS........................................................ 12-1 B. PROCEDURE REVIEW AND APPROVAL........................................................... 12-2 C. PROCEDURE PREPARATION............................................................................... 12-2 D. PROCEDURE REVISION........................................................................................ 12-4 E. PROCEDURE RETIREMENT................................................................................. 12-4 F. PROCEDURE CONTROL....................................................................................... 12-5 CHAPTER 13- TRAINING.......................................................................................................13-1 A. QUALIFICATIONS.................................................................................................. 13-1 B. TRAINING RECORDS............................................................................................ 13-1 C. QUALITY ASSURANCE PROGRAM TRAINING ................................................ 13-1 D. TRAINING REVIEW............................................................................................... 13-1 E. TRAINING REQUIREMENTS................................................................................ 13-2 F. ENVIRONMENTAL SERVICES PROCEDURE TRAINING REQUIREMENTS 13-2 CHAPTER 14- LABORATORY QUALITY CONTROL......................................................14-1 CHAPTER 15- QUALITY ASSURANCE PROGRAM REVIEW........................................15-1 A. QUALITY PROGRAM REVIEW............................................................................ 15-1 B. QA MANUAL REVIEW.......................................................................................... 15-2 CHAPTER 16- REPORT REVIEW AND APPROVAL........................................................16-1 A. REVIEW AND APPROVAL OF REPORTS AND DATA RELEASES ................. 16-1 B. EXEMPTIONS FROM REVIEW REQUIREMENTS ............................................. 16-2 CHAPTER 17- VENDOR QUALIFICATION........................................................................17-1 A. BLIND SAMPLES.................................................................................................... 17-1 1. Requests for Blind Samples................................................................................... 17-1 2. Results of Blind Samples....................................................................................... 17-1 Environmental Services QA Manual (revision 8) Page vi of x Effective 11 /07/2013 B. ON -SITE AUDITS OF VENDORS.......................................................................... 17-1 C. ENVIRONMENTAL SERVICES REQUIRED DOCUMENTATION .................... 17-2 D. LEAD AUDITOR PREPARATION GUIDELINES FOR AUDITING A VENDOR LABORATORY........................................................................................................ 17-2 CHAPTER 18- DATA MANAGEMENT.................................................................................18-1 A. DATA........................................................................................................................18-1 1. Data Recording...................................................................................................... 18-1 2. Automated Data Acquisition and Recording......................................................... 18-2 3. Worksheets.............................................................................................................18-2 4. Laboratory Notebooks............................................................................................ 18-2 5. Validation of Data and Computer Programs.......................................................... 18-2 6. Data Security.......................................................................................................... 18-3 B. SOFTWARE AND DATA QUALITY ASSURANCE ............................................ 18-3 C. DOCUMENT CONTROL......................................................................................... 18-3 1. Document Type...................................................................................................... 18-4 2. Document Storage.................................................................................................. 18-5 3. Long -Term Data Storage........................................................................................ 18-7 4. Document Retention.............................................................................................. 18-7 D. METEOROLOGICAL DATA QUALITY ASSURANCE ....................................... 18-8 CHAPTER 19- CORRECTIVE ACTION...............................................................................19-1 A. PURPOSE AND SCOPE.......................................................................................... 19-1 B. DOCUMENTATION................................................................................................ 19-1 C. CORRECTIVE ACTION PROCEDURES............................................................... 19-1 CHAPTER 20- AUDITS............................................................................................................ 20-1 A. PURPOSE................................................................................................................. 20-1 B. INTERNAL AUDITS................................................................................................ 20-1 C. EXTERNAL AUDITS.............................................................................................. 20-1 CHAPTER 21- ACRONYMS AND GLOSSARY................................................................... 21-1 A. ACRONYMS............................................................................................................ 21-1 B. GLOSSARY..............................................................................................................21-4 LITERATURE CITED................................................................................................................ L-1 Appendix 1. Additional Information for Environmental Services Analytical Laboratory......... A-1 Appendix 2. Additional Information for Asbestos Functional Area of Environmental Services................................................................................................................ B-1 Appendix 2a. Asbestos Laboratory Client/Customer Satisfaction Survey . ................................ C-1 Appendix 3. Additional Information for Microbiology Functional Area of Scientific Services............................................................................................................... D-1 Environmental Services QA Manual (revision 8) Page vii of x Effective 11/07/2013 Appendix 4. Inter -laboratory QA Programs and Schedules........................................................ E-1 Appendix 5. Environmental Services Procedure Numbering System ........................................ F-1 Appendix 5a. Procedure Coversheet.......................................................................................... G-1 Appendix 6. Report, Publication, or Presentation Review........................................................ H-1 Appendix7. Final Report Approval.............................................................................................1-1 Appendix 8. Vault Record Inventory...........................................................................................J-1 Appendix 9. Vault Check -Out Log............................................................................................ K-1 Appendix 10. Storage Box Contents...........................................................................................L-1 Appendix 11. Additional Information for Midwest Water Resources Quality Assurance Manual................................................................................................................ M-1 Appendix 12. Additional Information for Duke Energy Progress Quality Assurance Manual.. N-1 Appendix 13. Additional Information for Duke Energy Florida Quality Assurance Manual.... 0-1 Environmental Services QA Manual (revision 8) Page viii of x Effective 11 /07/2013 Environmental Services QA Manual REVIEW / REVISION HISTORY Revision # References Date Signature 1 1/12/2006 Ma Santini ................................. 2 .............................................................................................................................................................................................................................. ............................................................................................................................t.'................................................................. 3/26/2007 Sherry M. Reid ............................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................. 3 ............................................................................................................................................................................................................................................................................................................................................................................................................................. 2/21/2008 Sherr'M. Reid ................... 4 2008 interim revision memos to file 2/24/2009 Sherry M. Reid ............................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................. 5 ............................................................................................................................................................................................................................................................................................................................................................................................................................................................................................ 4/16/2010 Sherry M. Reid 6 2010 interim revision memos to file 02/12/2011 Sherry M Reid ............................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................. 7 ........................................ ................................. 2011 interim revision memos to file .......................................................................................................................................................................................................................................................................................................................................................n`'............................................................. 10/19/2012 She M Reid 8 Combined DEC and DEP QA 11/07/2013 Sherry M Reid Program Environmental Services QA Manual (revision 8) Page ix of x Effective 11 /07/2013 This page left blank intentionally Environmental Services QA Manual (revision 8) Page x of x Effective 11/07/2013 CHAPTER 1 INTRODUCTION Environmental Services (ES) of Duke Energy shall adhere to the Environmental Services Quality Assurance (QA) Program manual as written. This manual denotes instances where specific exemptions apply or guidance is unique to only one or several sections. Quality assurance requirements that require more detailed explanation will be addressed under the appropriate Chapter heading or Appendices within this manual. Refer to Chapter 21 for a list of acronyms and definitions used in this manual. Questions or comments concerning the content of this manual should be referred to the respective section/functional area or the ES QA Administrator. Environmental Services QA Manual (revision 8) Page 1-1 of 2 Effective 11 /07/2013 This page left blank intentionally. Environmental Services QA Manual (revision 8) Page 1-2 of 2 Effective 11/07/2013 CHAPTER 2 SCOPE This document defines an overall QA Program for Environmental Services under the Regulated Utilities Operations. The QA Program outlines all quality assurance requirements for various laboratory certifications common to certain functions within Natural Resources, Water Resources, Water Programs, Environmental Monitoring, and the Analytical Laboratory. QA Program requirements apply to all activities which may potentially affect the quality or validity of products or services. Implementation of these basic program requirements will help ensure the production of quality, scientifically defensible results by laboratory and field personnel operating under, and accountable to, the QA Program guidance. For various subordinate functional areas or laboratories, additional specific guidance may be required to address regulatory or laboratory certification requirements, or unique practical considerations. In those instances, supplemental, specific written quality assurance guidance (in the form of either specific procedures and/or laboratory -specific quality assurance plans) shall be developed, issued and retained within those functional areas or laboratories. Any such supplemental, laboratory -specific documents shall be approved by the appropriate manager. This QA Program shall be effective immediately upon approval by the Director, Water/Natural Resources and the Director, Environmental Support Systems. Environmental Services QA Manual (revision 8) Page 2-1 of 2 Effective 11 /07/2013 This page left blank intentionally. Environmental Services QA Manual (revision 8) Page 2-2 of 2 Effective 11/07/2013 CHAPTER 3 CODE OF ETHICS Environmental Services is committed to ensuring the integrity of data and meeting client/customer quality. We pledge to manage our business according to Duke Energy policies, including the Code of Business Ethics. Refer to Appendix 1 for the Environmental Services Analytical Laboratory guiding principles. Environmental Services QA Manual (revision 8) Page 3-1 of 2 Effective 11 /07/2013 This page left blank intentionally. Environmental Services QA Manual (revision 8) Page 3-2 of 2 Effective 11/07/2013 CHAPTER 4 QUALITY ASSURANCE RESPONSIBILITIES AND ORGANIZATION Duke Energy's Environmental Services functions are organized into five sections (Figure 4- 1). Each group is led by a manager. The managers of these sections are responsible for the overall management, administration, and technical direction of work. This includes staffing, budgeting, and strategic planning. Managers, supervisors, and/or project leaders are responsible for the technical direction of various functional areas. This includes implementing Quality Assurance/Quality Control (QA/QC) policies related to their functional areas, directing and maintaining in-house training activities, directing the updating of analytical methods, data review, ensuring that the corrective action process is followed, and reporting problems to the next level of management. Managers, supervisors, project leaders and/or QA Officers shall exercise actual day-to-day oversight of laboratory and field operations, and reporting of results. The Analytical Laboratory of Environmental Services shall appoint at least one Quality Assurance Officer for their group. Quality Assurance Officer's responsibilities include overseeing the QA/QC programs, administering inter -laboratory proficiency testing and round robin programs, acting as liaison with certifying authorities, performing periodic system audits, reviewing the QA manual with updates as necessary, reporting on performance to managers, coordinating transfer of records, and initiating corrective actions. The directors of Water/Natural Resources and Environmental Support Systems shall appoint a Quality Assurance Administrator. The QA Administrator shall report directly to the directors on Quality Assurance issues. The QA Administrator's responsibilities include: • Oversee the Environmental Services QA Program. • Coordinate and serve as editorial lead for annual review of the QA Manual. • Maintain a list indicating the persons who are assigned controlled copies of the QA Manual and/or appendices. • Distribute revisions to each person who is assigned a controlled copy of the QA Manual and/or appendices. Environmental Services QA Manual (revision 8) Page 4-1 of 4 Effective 11 /07/2013 • Ensure that QA Manual training is completed by all personnel and that annual retraining (in association with revisions) is addressed. • Serve as single point of contact (SPOC) for McGuire Environmental Center Document Storage Vault (coordinate access, ensure usage rules are followed, maintain activity files, etc.). • Distribute reminders to review and update resumes and training records annually. • Serve as lead audit facilitator for internal and external audits involving more than one section. • Prepare audit responses. • Prepare and coordinate annual internal audit schedule for all functional areas. • Participate as requested and available in QA/QC initiatives. • Provide assistance in the maintenance and operation of QA databases. • Serve as a resource to functional areas in the coordination and completion of Laboratory Certifications. • Provide Quality reports to the directors. Each Environmental Services section member has the authority and responsibility to stop work if the quality of any work is in question. All members of Environmental Services are responsible for reporting quality problems by implementing the Corrective Action process (Chapter 19). Refer to Appendices 1 for additional QA responsibilities in Environmental Services Analytical Laboratory. Environmental Services QA Manual (revision 8) Page 4-2 of 4 Effective 11 /07/2013 Chairman, President, and CEO,6wmwwI Exec VP & COO, I Director, Water / Natural Resources Manager, Natural Resources QA Functional Areas • Macroinvertebrates • Plankton • Wildlife/Botanical • Quality Assurance oversight QA Administrator Manager, Water Programs QA Functional Areas • Groundwater • Storm water Figure 4-1. Organizational structure. Executive Vice President, ronmental, Health, and Sa Vice President, Environmental Services Manager, Water Resources QA Functional Areas • Fish • Surface water Director, ---m Environmental Support Systems Manager, nental Monitoring QA Functional Areas • Ambient Monitoring • Field biology • Field chemistry Manager, Analytical Laboratory QA Functional Areas • Central Fuels • Customer Support • Sample Receipt • Trace Metals QA Officer Environmental Services QA Manual (revision 8) Page 4-3 of 3 Effective 11/07/2013 This page left blank intentionally. Environmental Services QA Manual (revision 8) Page 4-4 of 4 Effective 11 /07/2013 CHAPTER 5 PROJECTS Environmental Services monitoring project requirements shall be documented and reviewed at least annually or more frequently as required by project leaders, regulatory agencies or customer expectations and maintained in a central location in each functional area. Recommended project documentation may include the following: • Project name - Project title. • Program - Project team program (Example: macroinvertebrates). • Project description - Brief description of work. • Project start date - Beginning date. • Project end date - End date (if known) or Ongoing. • Project review date - Date of project documentation review (at least annually) for ongoing projects that extend beyond one year. • Customer - Facility/organization sponsoring project. • Contact - Customer contact. • Project leader — Environmental Services subject matter expert responsible for project leadership and direction. • Project coordinator - Liaison between subject matter experts, station contacts, and regulatory authorities. May be a member of another Environmental Services section or a different Duke Energy Department. • Budget accounting information - Budgetary information for project billing. • Scheduling - Project schedule information such as sample locations, frequency of sampling, sample analysis schedule, reporting schedule. • Procedures - Operation, maintenance, calibration, QA/QC and other procedure requirements. • Project responsibilities - Identifies project lead and field crews. • Project file storage location - Identifies physical location of project records, documentation, etc. • Other project requirements - Additional requirements such as data management, data analysis, lab equipment and instrumentation. Environmental Services QA Manual (revision 8) Page 5-1 of 2 Effective 11 /07/2013 This page left blank intentionally. Environmental Services QA Manual (revision 8) Page 5-2 of 2 Effective 11 /07/2013 CHAPTER 6 CERTIFICATIONS AND INTER -LABORATORY QUALITY ASSURANCE A. CERTIFICATIONS Environmental Services Analytical Laboratory is presently certified in the following states and categories: • North Carolina Department of Environment and Natural Resources (NCDENR), Certification Number 248 Parameters: Wastewater/Groundwater — Inorganics and metals • South Carolina Department of Health and Environmental Control (SCDHEC), Laboratory Identification Number 99005 Parameters: Clean Water Act — Inorganics and metals Solid and Hazardous Wastes — Inorganics, metals, and hazardous waste characteristics. (For information about specific parameters for which we are certified, contact the Analytical Laboratory QA Officer.) Environmental Services QA Manual (revision 8) Page 6-1 of 4 Effective 11 /07/2013 Other areas of Environmental Services are presently certified in the following states and categories: Duke Energy Carolinas • North Carolina Department of Environment and Natural Resources; Division of Water Quality (NCDENR DWQ), Certification Number 008. Parameters: Aquatic Population Survey - Fish, Macroinvertebrates, Algae, Aquatic Macrophytes Taxonomy - Freshwater Fish, Freshwater Macroinvertebrates, Phytoplankton, Zooplankton • South Carolina Department of Health and Environmental Control (SCDHEC), Certification Number 99046001 Parameters: Taxonomy - Freshwater Fish, Freshwater Macroinvertebrates, Phytoplankton, Zooplankton • NCDENR DWQ, Certification Number 5193 Field parameters: Temperature, Dissolved Oxygen, Specific Conductance, Total Residual Chlorine and pH • SCDHEC, Certification Number 99046004 Field parameters: Temperature, Dissolved Oxygen, Residual Chlorine and pH Duke Energy Progress • NCDENR DWQ, Certification Number 006. Parameters: Aquatic Population Survey - Fish, Macroinvertebrates, Algae, Aquatic Macrophytes Taxonomy - Freshwater Fish, Freshwater Macroinvertebrates, Phytoplankton, Zooplankton • SCDHEC, Certification Number 99017001 Parameters: Taxonomy - Freshwater Fish, Freshwater Macroinvertebrates, Phytoplankton, Zooplankton Environmental Services QA Manual (revision 8) Page 6-2 of 4 Effective 11 /07/2013 B. INTER -LABORATORY PERFORMANCE EVALUATION (PE) PROGRAMS Various functional areas participate in PE programs to further ensure data validity. These programs encompass a wide variety of sample types and matrices. The current programs and schedules in Environmental Services are listed in Appendix 4. C. RESPONSIBILITIES FOR PE PROGRAMS 1. QA Officers • Administer all PE sample programs. • Maintain the certification and inter -laboratory PE program records and files. • Receive performance reports from certifying bodies and inter -laboratory PE programs. • Issue reports of overall performance to the section manager, supervisor, and/or project leader. • Initiate corrective actions for all unacceptable results and track for closure. Loss of certification and subsequent re -certification shall also be addressed within the corrective action program. 2. Supervisors, Project Leads, or Designees • Address any deficiencies in reports from the section or functional area QA Officer. • Ensure that corrective action options are considered and that selected actions are implemented. Environmental Services QA Manual (revision 8) Page 6-3 of 4 Effective 11 /07/2013 This page left blank intentionally. Environmental Services QA Manual (revision 8) Page 6-4 of 4 Effective 11 /07/2013 CHAPTER 7 WORK PLACE To establish a working environment that encourages quality performance from personnel, Environmental Services Management shall ensure that adequate facilities are provided and maintained in the Environmental Services -occupied portions of the McGuire Island Environmental Center and Harris Energy and Environmental Center. A. GENERAL FACILITIES • Adequate and acceptable facilities such as lighting, ventilation, temperature, and humidity. These facilities shall be maintained to the levels described in appropriate industry standards [for example, American Society of Heating, Refrigerating and Air - Conditioning Engineers (ASHRAE) standards]. • Adequate and acceptable utility service such as voltage control, air, water, and vacuum. • Adequate and acceptable general laboratory facilities and equipment such as chemical fume hoods, biological safety cabinets, sinks, bench areas, and refrigerators. Chemical fume hoods and biological safety cabinets shall be routinely monitored and calibrated as necessary for proper function, air flow and personal protection of laboratory workers. • Certain areas within the Laboratory shall have effective separation from neighboring areas to prevent cross contamination, to avoid affecting the quality of the analyses practiced within and to protect building inhabitants. For safety reasons, inorganic facilities should be in separate rooms and should also be separated to prevent cross contamination. The analytical and sample storage areas should be isolated from all potential sources of contamination. Areas with controlled access include but are not the Inorganic Chemistry functional areas. These areas can be controlled by locked doors with key or keypad entry. Access to the entire building is controlled by locked doors with badge entry. • All areas where chemical wastes are generated shall make provisions for disposal of such wastes. Environmental Services QA Manual (revision 8) Page 7-1 of 2 Effective 11 /07/2013 B. LABORATORY REQUIREMENTS • Safety glasses are required at all times in laboratory areas of Environmental Services Analytical Laboratory. Procedures used in other areas of Environmental Services shall specify when safety glasses are required. • Lab coat, gloves and other specific personal protective equipment (PPE) are required when handling chemicals and samples in the Analytical Laboratory. Procedures used in other areas of Environmental Services shall specify when lab coats, gloves and other specific PPE are required in their laboratories. • Thermoluminescent dosimeters (TLD) are required when working in the radiochemistry laboratory (RCL). All other Radiation Protection (RP) requirements are listed on the Radiation Work Permit (RWP) posted on the entrance door to the RCL. RP may require more stringent controls depending upon changing radiological conditions in the RCL. For additional information please review the following documents: Duke Energy Safe Work Practices Environmental Center Chemical Hygiene Plan Harris Energy and Environmental Center Chemical Hygiene Plan Nuclear Policy Manual: Nuclear Safety Directive (NSD) 507 — Radiation Protection Environmental Services QA Manual (revision 8) Page 7-2 of 2 Effective 11 /07/2013 CHAPTER 8 HOUSEKEEPING Housekeeping is the visual condition of the equipment, structures, components and areas that reflect organization, cleanliness, and safety. All housekeeping activities must be in conformance with the Chemical Hygiene Plan. Housekeeping includes all activities related to the control of cleanliness and to the reduction and elimination of trash, dust, dirt, and work related debris. A. GENERAL All supplies and reagents shall have a designated storage location and shall be properly stored when not in use. Countertops, instrumentation, and equipment should be clean and well maintained. There should not be visible oil, grease, dust or dirt. Drawers and cabinets should be closed when not in use. B. WORK AREAS Work areas shall be kept sufficiently clean and orderly so that work can be done efficiently, safely, and with high quality. The area should be free of clutter. Small spills of dry chemicals, liquid reagents, acids, etc. shall be cleaned up immediately. Work areas including bench tops and work surface of hoods should be cleaned before work begins, as work is underway, and thoroughly at completion to reduce potential of contamination. Balances and surrounding work surfaces should be cleaned after each use. Chemicals, samples, and supplies shall be returned to designated storage locations after use. Environmental Services QA Manual (revision 8) Page 8-1 of 2 Effective 11 /07/2013 Chemical containers shall be kept closed when not in use. C. WALKWAYS AND AISLES Walkways and work surfaces shall be kept free of oil, grease, water, ice or other slippery materials. Carts, equipment, boxes, etc. shall not be allowed to block main evacuation aisles or doors. Floors should be cleaned regularly as dust and other assorted chemicals may pose respiratory and contamination problems. D. ALL AREAS Garbage, trash, scraps, litter and other excess materials shall be disposed of in designated areas following accepted practices. Environmental Services QA Manual (revision 8) Page 8-2 of 2 Effective 11 /07/2013 CHAPTER 9 INSTRUMENTATION AND EQUIPMENT A. MAINTENANCE Environmental Services sections will maintain equipment and instruments in good working order. The desired goal is to reduce downtime, maximize instrument life, and ensure the generation of reliable, accurate, and defensible data. Where applicable, a description of required maintenance activities shall be included in standard operating procedures or other documents as appropriate [e.g., daily monitoring of incubator, air quality site monitoring plans]. Refer to standard operating procedures and Appendices 1 and 2 for additional information about instruments and equipment in Environmental Services Analytical Laboratory, and Environmental Monitoring. B. MAINTENANCE RECORDS Environmental Services sections shall keep records of instrument maintenance performed either on a routine or as -needed basis. Maintenance records shall be readily accessible in the laboratory or at fixed monitoring sites. Types of maintenance and initial frequency of maintenance should be based on manufacturer's recommendations. Frequency of maintenance may be adjusted based on frequency of equipment usage and experience with the equipment. Frequency may be specified either on the maintenance record, monitoring plan, or other documents. Maintenance records for laboratory and field instrumentation and sampling equipment that is used at multiple sampling locations shall include the following information: • description of the equipment • manufacturer • model number • instrument ID number or serial number • calibration events (if not part of routine analytical process) • frequency of required maintenance Environmental Services QA Manual (revision 8) Page 9-1 of 6 Effective 11 /07/2013 Maintenance records for site installed air and water quality monitoring equipment are unique and may or may not include the information listed above. Maintenance records of this type are approved by state air and water quality authorities. Where applicable, instrumentation troubleshooting, corrective action, non -routine repairs, and repairs made by the instrument manufacturer shall also be documented in the maintenance record. C. CALIBRATIONS The frequency of calibration of instruments and equipment will be procedure specific and based on one or more of the following: • Regulatory requirements • EPA procedures • American Society for Testing and Materials (ASTM) procedures • Manufacturer or vendor recommendation • Calibration vendor recommendation • Experience The analyst or operator is responsible to ensure that the instrument(s) or equipment used to obtain data meet current procedural requirements for calibration. If there is any doubt, the instrument should not be used until verification can be obtained. Any calibrated equipment (thermometers, balances, etc.) that is not calibrated daily or at each use should be tagged or labeled to indicate date of last calibration and date due for recalibration. In circumstances where no other calibrated equipment is available, equipment that is past due for recalibration may still be used for a period of one quarter the length of the calibration interval of the instrument (i.e. three months past the calibration due date for a twelve month calibration cycle). This applies to Environmental Services Analytical Laboratory if the instrument/equipment is still in calibration and if the calibration is extended by the calibration vendor. Any equipment used that is past the calibration due date shall be recalibrated or certified as soon as possible after use. Daily calibration does not apply to site installed air quality and water quality monitoring equipment. Individual components of these systems are maintained regularly and systems are calibrated quarterly, semi-annually, or annually as a whole. Environmental Services QA Manual (revision 8) Page 9-2 of 6 Effective 11 /07/2013 Instruments shall be calibrated using only standards of an appropriate quality as specified by procedures. Documentation of each calibration shall be retained and shall include employee's name, date, method, instrument conditions, standards, and result for each standard including adjustments made, if any. Before any calibrated equipment is removed from service due to replacement or other reason, the calibration of the item shall be checked to evaluate its calibration status since the last calibration check. This check is to verify that data collected by the instrument since the date of last calibration is valid. If the instrument is found to be out of tolerance, Section F of this Chapter and other functional area specific procedures that apply shall be followed. 1. Balance Calibrations Balance calibrations will be verified at least annually. Each balance must also be checked with at least three NIST traceable class S standard weights each day it is used, by using the "Conventional Mass @ 8.0 g/cm3" value from the weight set's Calibration Report. The values obtained must be recorded in a log and initialed by the analyst. The weights used shall be in the ranges of the routine use of the balance to include the mid -point weight (Table 9-1). Calibration check requirements of this section do not apply to portable balances (field balances). Guidance for calibration checks of these balances will be addressed in functional area specific procedures. Relevant Procedures: • FSH-111.01 2. Temperature Device Calibrations All thermometers will be checked against a NIST-traceable thermometer by the calibration vendor unless calibration by Environmental Services Analytical Laboratory personnel is approved by the appropriate section manager. Calibration of thermometers by Environmental Services Analytical Laboratory personnel will be conducted according to procedure 2871, "Calibration Verification of Thermometers." Environmental Services QA Manual (revision 8) Page 9-3 of 6 Effective 11 /07/2013 The calibration frequency will not exceed one year. Liquid -in -glass thermometers are checked with each use to assure legibility and uniformity of the liquid. High -precision thermistor or resistance temperature detector (RTD) devices used to make temperature measurements in the field are spot-checked periodically or with each use against an NIST-traceable device, with the comparative data recorded in the field records. Instrument -specific procedures should be consulted for further details and acceptance criteria. 3. Meteorological Instrument Calibrations Meteorological instrumentation is periodically calibrated to assure the validity of the meteorological data and accuracy of the meteorological instrumentation, as required by station Selected Licensee Commitments and Regulatory Guide 1.23. Real-time data from the meteorological system is classified as SDQA Category C. Special NRC reporting requirements exist when meteorological channels are non-functional for more than 7 days, or annual data recovery rates are less than 90%. Checks and calibration of the meteorological instrumentation are performed per station procedures, which are subject to the pertinent requirements of Dukes IOCFR50 Appendix B Quality Assurance Program. Strip -charts or small -increment electronic data are sent from the station to the Environmental Monitoring group at Dukes Environmental Center for use in checking the validity of the hourly averaged data, which is later archived for the life of the plant. The stripchart or small -increment electronic data is kept for a period of five years. D. EQUIPMENT CONTROL In Environmental Services, there are a number of calibrated items (thermometers, balances, microscopes, etc.) that are assigned to particular functional areas. These items are under the control of those functional areas and are not to be moved, loaned, or traded from their area of assignment without first verbally notifying the manager and QA Officer of the applicable section or functional area. E. RECORDS Environmental Services QA Manual (revision 8) Page 9-4 of 6 Effective 11 /07/2013 The most recent hard copy or electronic calibration and maintenance records for instruments and equipment will be maintained in Environmental Services sections or functional areas. Hard copy records shall be stored in fireproof files or the onsite storage vault. Electronic records shall be password protected or stored within protected databases/LAN shares. Maintenance and calibration records shall be retained for the life of the facility where it is used. Calibration and maintenance vendors must appear on the Corporate QA Approved Vendors List before accepting certification of any items used for nuclear safety related analyses. The certificates will be retained in the document files of Environmental Services sections. F. OUT -OF -TOLERANCE If measuring and testing equipment is found to be out -of -tolerance, an investigation shall be performed to determine the validity of test results since the last acceptable calibration. This investigation shall be conducted and documented, by the functional area to which the equipment is assigned, in accordance with individual functional area corrective action procedures. If individual functional areas do not have specific corrective action procedures, then investigations shall be conducted in accordance with the Corrective Action Chapter of this manual (Chapter 19). Investigations may be documented on the calibration report if the out -of -tolerance condition had no impact on data and no corrective action is necessary. The section or functional area QA Officer or designee will inform teams when equipment is discovered to be out of tolerance. Relevant Procedures: • Environmental Services Analytical Laboratory, 2874, "Corrective Action Using the Incidents Module of eTRAC" • Ambient Monitoring, 7404, "Data Validation" Environmental Services QA Manual (revision 8) Page 9-5 of 6 Effective 11 /07/2013 Table 9-1. Guidelines for Use of Laboratory Balances Guidelines for Use of Laboratory Balances I. Check balance daily (when used) with at least THREE NIST traceable class S weights. 1. Clean balance pan. 2. Level the balance, if necessary. Leveling bubble may be on the back of the balance. 3. Tare balance. 4. Select weights in the range you are using. 5. Place one of the three weights on the pan. 6. Record this information in the balance logbook. 7. Compare weight to the "Conventional Mass @ 8.0 g/cmY listed on the calibration report for the weight set. 8. If the difference is outside the balance tolerance, record this information in the balance logbook. a) Do the internal user calibration, if available, then return to Step 5. b) If internal calibration is not available, stop the calibration and inform the supervisor and the QA Officer. 9. If the difference is within the balance tolerance, record this in the logbook. 10. Repeat Steps 5-8 for remaining weights. Environmental Services QA Manual (revision 8) Page 9-6 of 6 Effective 11 /07/2013 CHAPTER 10 SAMPLE CONTROL The objective of this program is to prescribe minimal generic requirements that apply during the acquisition of environmental samples from the time of collection until disposal. Topics covered in this section includes: sample identity/traceability, sample storage, sample log -in, and disposal. Refer to Appendix 1 for additional information on sample control in Environmental Services Analytical Laboratory areas. A. SAMPLE IDENTIFICATION AND TRACEABILITY Traceability shall be maintained to facilitate tracking sample collection and custody information, procedures and equipment used in collecting data, and data management records. A sample identification system shall be employed to assign a unique, traceable identity to each sample physically collected and/or accepted for analysis. Laboratory or functional area -appropriate sample chain -of -custody documents, and sample custody and log -in procedures shall be followed within each section. Appropriate procedure numbers and/or method reference, dates of collection and/or analysis, collector and/or analyst initials, holding time, if applicable, unique equipment/instrument identification (e.g. instrument model number and serial number, calibration certificate number, etc.), and unique sample description or numbers shall be listed on data sheets or electronic data files. Hard copy records of data collection and/or analyses that produce reportable (i.e., will be provided to a client/customer - internal or external - in any form) data shall be stored in approved fireproof files or the onsite storage vault. Electronic copies shall be password protected or stored within protected databases/LAN shares. B. SAMPLING AND ANALYSIS REQUESTS Client/customer contacts or functional area managers are responsible for evaluating work requests to determine whether the lab has adequate resources and applicable certifications. Environmental Services QA Manual (revision 8) Page 10-1 of 4 Effective 11 /07/2013 C. SAMPLE COLLECTION AND PRESERVATION Sample collection records may optionally be combined with the sample analysis and chain -of -custody record (see below). A sample collection record shall include at a minimum: • Procedure number and/or method reference • Collection/analysis date (and time if applicable) • Initials or names of collectors/analysts • Holding time if applicable and not readily available via reference to the described analytical method(s) • Number of sample containers • Sample replicate (if applicable) and sample blank identification • Sample preservation techniques • Unique equipment/instrument identification (e.g., instrument model number and serial number, calibration certificate number, etc.) • Sample descriptions, sample ID numbers, or unique sample location ID A chain -of -custody form shall accompany all samples to individual laboratories and accurately correspond to information recorded on every sample container. A copy of the chain -of -custody form shall accompany samples sent to vendor laboratories for analysis D. SAMPLE LOG -IN Samples that are delivered to Environmental Services sections for analysis will be logged in on individual functional area login sheets. Refer to Appendix 1 for additional information about sample login in Environmental Services Analytical Laboratory. E. SAMPLE STORAGE Samples are stored in individual functional areas. Refer to Appendix 1 for additional information about sample storage in Environmental Services Analytical Laboratory areas. Environmental Services QA Manual (revision 8) Page 10-2 of 4 Effective 11 /07/2013 F. SAMPLE DISPOSAL Samples and acid digested samples will be disposed in accordance with regulatory requirements or Duke Energy guidelines. Refer to Appendix 1 for additional information about sample disposal in Environmental Services Analytical Laboratory. The disposal of performance evaluation/certification samples should be performed with the approval of the section or functional area QA Officer, supervisor, or section manager of the specific area. If the sample results are not within acceptance limits, the samples will need to be saved until reanalysis can be performed as part of the corrective action investigation. Environmental Services QA Manual (revision 8) Page 10-3 of 4 Effective 11 /07/2013 This page left blank intentionally. Environmental Services QA Manual (revision 8) Page 10-4 of 4 Effective 11 /07/2013 CHAPTER 11 REAGENTS AND CHEMICALS The objective of this program is to prescribe minimal generic requirements that apply during the acquisition of environmental samples from the time of collection until disposal. Topics covered in this section includes: sample identity/traceability, sample storage, sample log -in, and disposal. Refer to Appendix 1 for additional information on sample control in Environmental Services Analytical Laboratory areas. A. QUALITY All chemicals shall be American Chemical Society Reagent Grade (AR) unless stated otherwise by procedure. Vendor -prepared standards or reagents are acceptable for use as specified by procedure. All standards shall be National Institute of Standards and Technology (MIST) -traceable, where available. Trace metals grade acids shall be used for metals analyses. These requirements shall be specified in the purchase orders for these chemicals, where necessary. B. LABORATORY PURE WATER Environmental Services Analytical Laboratory will supply two analytical grades of pure water. The first grade, designated as De -ionized (DI) or Demineralized water, is supplied by the McGuire Nuclear Station and distributed through a discrete DI system. The second grade is a high purity grade (e.g., Milli-Q® or Super-Q® or equivalent, produced by on - site water purification systems or purchased by volume) and will have a minimum resistivity of 10 megohms/cm at 25°C. Further specifications, if needed, will be stated within individual procedures. Water purification systems are maintained and maintenance activities documented as directed in specific analytical procedures for each functional area listed at the end of this section. If required, monthly and annual checks are performed as directed in specific analytical procedures for each functional area. Environmental Services QA Manual (revision 8) Page 11-1 of 4 Effective 11 /07/2013 Relevant Procedures: • Environmental Services Analytical Laboratory, 1011, "Maintenance of Laboratory Water Purification System," C. REAGENTS/SOLUTIONS/STANDARDS All reagents, solutions and standards shall be stored and handled in accordance with the Chemical Hygiene Plan. Additional functional area requirements for handling, tracking, labeling and storage are found in procedures. The person receiving a chemical shall verify that it meets the requirements specified in Section A of this Chapter. All reagents, solutions, or secondary standards will be prepared according to individual analytical procedures. Once a chemical has been removed from its original container, it shall not be returned to that container. Minimum labeling requirements for purchased reagents and standards in addition to original labeling include: date received, date opened, expiration date, and initials. Minimum labeling requirements for prepared reagents and standards include concentration, reagent name, preparation date, expiration date and preparer's initials. Expiration dates for prepared reagents and standards shall be based on regulatory requirements or standard reference procedure and will be specified in analytical procedures or general quality control procedures for specific functional areas. With the exception of Environmental Services Analytical Laboratory, all reagents and solutions prepared fresh daily are labeled with concentration, reagent name, "daily" or the date prepared and preparer's initials. Other sections of Environmental Services are exempt from the above requirements for the following reagents/chemicals when used as preservatives in biological specimen containers: • All solutions of ethanol and water • All solutions of ethanol, water and rose bengal stain • Mounting medium CMCP • All solutions of formalin and water • Preservative M3 Environmental Services QA Manual (revision 8) Page 11-2 of 4 Effective 11 /07/2013 • All solutions of isopropyl alcohol and water The certificate of analysis for all calibration and quality control standards shall be retained in accordance with specific functional area procedures and the Records Retention Schedule. Relevant Procedures: • Environmental Services Analytical Laboratory, 1024, "Receipt, Handling, and Storage of Chemicals in the Laboratory" • Environmental Services Analytical Laboratory, 2851, "Traceability and Documentation of Standards and Reagents" • Environmental Services Analytical Laboratory, 1002, "Preparation of Analytical Standards" D. STANDARD AND REAGENT CHEMICAL DISPOSAL Chemical disposal shall be in accordance with the applicable Material Safety Data Sheet (MSDS) instructions. The analyst shall refer to the MSDS or Chemical Fact Sheets for information related to handling, disposal, and spillage of those chemicals involved in that procedure. Any person unsure of the proper disposal process for a particular reagent, sample, or waste chemical should consult the Chemical Hygiene Officer. Relevant Procedure: • Environmental Services Analytical Laboratory, 1025, "Management of Obsolete, Surplus, and Expired Chemicals In The Laboratory" Environmental Services QA Manual (revision 8) Page 11-3 of 4 Effective 11 /07/2013 This page left blank intentionally. Environmental Services QA Manual (revision 8) Page 11-4 of 4 Effective 11 /07/2013 CHAPTER 12 PROCEDURES A. GENERAL PROCEDURE REQUIREMENTS A procedure is defined as a controlled set of written instructions, assembled in a specified format that describes how to perform a task. Each functional area within Environmental Services sections shall prepare written procedures specifying activities to be followed whenever: • Samples are collected, prepared or analyzed. • The performance of the work activity affects the quality of reportable data and is performed more than twice a year. • Written procedures are required per the QA Program requirements or by regulatory agencies. Procedures shall be prepared for routine analytical functions and work processes. Whenever the same equipment or instruments are used within a functional area for the same purposes, identical procedures shall be adopted. Individuals performing procedures designated as "Reference Use" shall have a controlled copy of the procedure present, and follow it exactly as written. "Reference Use" procedure deviations without written approval from the section manager or designee are prohibited. Procedures in Environmental Services are designated as "Reference Use" when analyzing nuclear QA-1 related samples in a laboratory environment. Current nuclear QA-1 activities are diesel fuel analyses and tech spec backup for reactor coolant analyses McGuire and Catawba Nuclear Stations. When an Analytical Lab procedure is used to analyze nuclear QA-1 related samples a controlled copy of the procedure shall be present and the user shall perform the procedure using step-by-step adherence unless flexibility is allowed by the procedure. Environmental Services QA Manual (revision 8) Page 12-1 of 6 Effective 11 /07/2013 Procedures designated "Information Use" should be accessible, but need not be present when the task is performed. Performance of steps in an "Information Use" procedure may be non -sequential provided the data and/or results are not affected. The user is accountable for procedure conformance and responsible for verifying that any uncontrolled copies of procedures are the current versions. Supervisors or project leaders shall have the responsibility to assure all routine analyses/work is performed using approved procedures. No data shall be released unless produced using an approved procedure or approved by Environmental Services management for release. B. PROCEDURE REVIEW AND APPROVAL As a minimum, new procedures shall be reviewed for accuracy and completeness, for QA Program conformance and the approval of the section manager. Procedures shall be reviewed at a minimum of once every five years. Relevant Procedure: • Environmental Services, 2876, "Procedure Preparation, Technical Review, Revision, and Method Validation" C. PROCEDURE PREPARATION When possible, procedures shall be based on standard references from ASTM, Environmental Protection Agency (EPA), American Industrial Hygiene Association (AIHA), National Institute for Occupational Safety and Health (NIOSH), American Public Health Association/American Water Works Association (APHA/AWWA), U.S. Geological Survey (USGS) or other professional/regulatory agencies. Functional areas shall determine the need for procedures and are responsible for the writing, distribution and control of procedures. Procedures shall be written in active voice, in step-by-step fashion and must be free of ambiguity. In the development of procedures, references such as ASTM methods, EPA methods, Standard Methods and manufacturers' manuals should be referenced for pertinent information. The supervisor or project leader will have primary responsibility Environmental Services QA Manual (revision 8) Page 12-2 of 6 Effective 11 /07/2013 for writing and reviewing procedures. This responsibility may be delegated to other competent individuals based on business needs and expertise. Each procedure shall be assigned a unique identification number by the appropriate QA Officer or designee using the numbering system in Appendix 5. A cover sheet with all appropriate signatures is required for each procedure. As a minimum, the procedure cover sheet (Appendix 5a) shall include the procedure title; procedure number; revision number; dated signature of the primary reviewer*; dated, approval signature of the QA Officer; dated, approval signature of the section manager; and the date the revision becomes effective. SDQA and Chemical Hygiene approval shall be used as necessary or required in each section. Procedure cover sheets shall designate procedure status as "Reference Use", or "Information Use" as appropriate. The procedure cover sheet shall not be paginated within the procedure. The following sections are recommended for procedures. Additional sections may also be included: • Title of Procedure, Procedure Number - The title shall clearly identify the procedure. The procedure number shall be a unique number as determined by the functional area. The procedure number shall also identify any revisions through use of a revision number. • Purpose - Identifies the applicability and scope of the procedure. • References - Citations consulted during procedure preparation including any regulatory references, publications or other written material that may support the procedure. • Materials or Equipment - Identifies any equipment, instrumentation, or materials required for performance of the procedure. • Reagents (if applicable) - A list of reagents that are required. Applicable MSDS and Stock Code numbers should be associated with each reagent. • Limits and Precautions - Limiting factors for the procedure or equipment along with safety or procedural cautions. Specific safety information and required PPE shall appear (or be included as procedures are revised). • Method - Detailed step-by-step directions for performing the procedure. . A primary reviewer thoroughly reviews and revises a new procedure and signs the coversheet as "Primary Reviewer". Environmental Services QA Manual (revision 8) Page 12-3 of 6 Effective 11 /07/2013 • Enclosures - Additional information. This may include drawings, maintenance instructions, troubleshooting guides and other information not required in the main body of the procedure or too lengthy for the procedure. Relevant Procedure: • Environmental Services, 2876, "Procedure Preparation, Technical Review, Revision, and Method Validation" D. PROCEDURE REVISION Any procedure change shall be considered a revision and result in a change to the procedure revision number and completion of a new coversheet and approvalst as described in section C of this chapter. Hard copy procedures shall contain no handwritten comments, notes or marks. No correction fluids (Liquid Paper(&, White Out®, etc.) shall be used on any part of the procedure, including the cover sheet. All revisions shall be made as typewritten changes. An existing procedure may be used until a new procedure is written when a similar new instrument is purchased for an analysis as long as the reference method/methods remain the same. If the reference method is different, a procedure with a new procedure number may be required. Relevant Procedure: • Environmental Services, 2876, "Procedure Preparation, Technical Review, Revision, and Method Validation" E. PROCEDURE RETIREMENT When procedures are no longer used or are revised, they shall be superseded or retired by destroying all copies except the master paper or electronic copy. The first page of master paper copies shall be marked as "SUPERSEDED BY REVISION # if or "Retired". Electronic master copies shall be designated as "SUPERSEDED BY REVISION # t A primary reviewer thoroughly reviews and revises an existing procedure and signs or initials the coversheet as "Primary Reviewer." Environmental Services QA Manual (revision 8) Page 12-4 of 6 Effective 11 /07/2013 if or "Retired" by electronic watermark or another manner within specific software. Master copies of superseded or retired procedures shall be kept on file for historical documentation by the QA Officer and the revised document shall become the new master copy. Unique procedure numbers of retired procedures shall not be reused on another procedure. F. PROCEDURE CONTROL Each functional area is responsible for controlling the distribution of its procedures. Procedure copies may be made by the QA Officer or designee as described below: • Master copy - The original copy of QA practices and procedures from which controlled copies are made. • Controlled copy - Photocopies made from the master copy. These copies are clearly stamped "controlled copy." Copies are updated whenever changes are made to the master copy and distributed only to controlled copy holders. Electronic copies that are password protected or stored within protected databases/LAN shares are considered controlled copies. Reprints of electronic copies must be compared to controlled copies before use. • Uncontrolled copy - A working copy that is clearly marked "uncontrolled copy", will not be tracked or updated and must be verified by the user as the most current revision before use. Master copies of all procedures with approval signatures shall be maintained by the applicable QA Officer or designee within each functional area in locked fireproof cabinet(s) or stored on a secure server (with scanned coversheets showing approval signatures). Copies of references not readily available (e.g., journal articles, symposium notes, manufacturer procedures) shall be filed with the master copy of the procedure in the procedure file or traceable through procedure documentation. Controlled copies of procedures may be maintained electronically within controlled -access network shares or databases. Controlled copies of procedures may be distributed either as part of a complete set of procedures (procedure manual), or as an individual copy. Individual, uniquely numbered copies will clearly be stamped or printed in ink "controlled copy." The section or functional area QA Administrator or designee shall maintain a Environmental Services QA Manual (revision 8) Page 12-5 of 6 Effective 11 /07/2013 database or list indicating the number, functional area, and storage location (file cabinet, office, or lab) of "controlled copy" procedures. The QA Officer shall distribute revisions to each functional area supervisor or designee, and they shall revise their controlled copies accordingly. Uncontrolled or working copies of procedures may be used as long as the user has verified that it is the current revision and the copy is clearly stamped or printed in ink "uncontrolled copy". It shall be the individual's responsibility to ensure that any copy of a procedure is the current revision before using it to collect data. Outdated, uncontrolled copies shall be destroyed. Environmental Services Analytical Laboratory will use controlled copies of procedures only. Environmental Services QA Manual (revision 8) Page 12-6 of 6 Effective 11 /07/2013 CHAPTER 13 TRAINING A. QUALIFICATIONS It is the responsibility of the section managers to ensure that each individual receives appropriate documented training. Personnel are encouraged to maintain any pertinent professional certifications or licenses. B. TRAINING RECORDS Training shall include procedure training, formal education, equivalent professional experience, in-house programs and/or vendor supplied training, etc. Training records are to be stored in a secure and stable environment. For nuclear -related training, groups may contact the designated Nuclear Training group in charge of training records (e.g. CNS Nuclear Training) to implement a process, update their nuclear training records on file, or verify that the section or functional area's process for documenting training is sufficient. Personnel shall update their training records annually or more frequently as needed. All personnel shall be trained prior to the initial performance of any work activities. C. QUALITY ASSURANCE PROGRAM TRAINING The Environmental Services QA Administrator, section or functional area QA Officers, section managers, or a designee shall provide initial training on the QA Program for new employees. The QA Administrator or section or functional area QA Officers shall communicate programmatic changes to all employees. All QA Program training and program change communications shall be documented and retained with training records. D. TRAINING REVIEW Personnel or their supervisors shall review and update training records annually or more frequently as needed. This review shall be documented and filed. Environmental Services QA Manual (revision 8) Page 13-1 of 2 Effective 11/07/2013 Section managers should review personnel training records periodically and correct any deficiencies. Project leaders should review the qualifications and pertinent training records of any contract employees they hire, to ensure appropriate training has been received prior to the performance of work. E. TRAINING REQUIREMENTS Functional areas should expand upon the specifics of training for their areas. Some sections or functional areas may have standard training required of all employees, while others may need to tailor the training to the individual by development of Individual Training Plans (ITPs). F. ENVIRONMENTAL SERVICES PROCEDURE TRAINING REQUIREMENTS Procedures that result in reportable data shall be performed only by 1) qualified, trained analysts who have been approved to perform the procedure or 2) personnel being trained whose data sheet (analytical record) is reviewed and approved by a supervisor, project leader, or qualified analyst. The supervisor, project leader, or qualified analyst shall be available to answer questions during the performance of the procedure. Section managers shall direct in-house employee procedure training and orientation of new employees and contractors unless functional area training procedures exist. Relevant Procedures: ■ Environmental Services, 2875, "Procedure Training, Qualification, and Documentation using Training Tracking Enterprise Software" ■ Environmental Services Analytical Laboratory, 2866, "Employee Orientation" Environmental Services QA Manual (revision 8) Page 13-2 of 2 Effective 11/07/2013 CHAPTER 14 LABORATORY QUALITY CONTROL Quality control is an overall system of activities, the objective of which is "to fine tune and maintain a measurement process in a desired state of stability and reproducibility" (Taylor, 1987) Quality control activities are performed to help ensure data validity. The Environmental Services Analytical Laboratory area of Environmental Services follows quality control activities that are specified in Appendix 1. All other functional areas in Environmental Services follow quality control practices that are specified in procedures. Environmental Services QA Manual (revision 8) Page 14-1 of 2 Effective 11/07/2013 This page left blank intentionally. Environmental Services QA Manual (revision 8) Page 14-2 of 2 Effective 11 /07/2013 CHAPTER 15 QUALITY ASSURANCE PROGRAM REVIEW A. QUALITY PROGRAM REVIEW Managers, QA Officers, and the QA Administrator shall review QA processes and related QA documentation. The QA Administrator shall ensure that the Duke QA Topical Report and Environmental Services Nuclear Departmental Interface Agreement is reviewed annually or on an ongoing basis by Environmental Services managers or their designees to ensure their continuing suitability, consistency, and effectiveness and to implement necessary changes and improvements. The review may involve interviews with customers, in-house personnel, certifying authorities, etc. The results of the review shall be documented and shared with employees. Quality Program Reviews in Environmental Services Analytical Lab shall include all elements from the following list. Other areas of Environmental Services may include elements from the following list in their Quality Program Reviews. • The suitability of policies, procedures, and tools • Quality reports from supervisors, scientists and project leaders • The outcome of recent internal audits • Corrective and preventive actions • Assessments by external bodies • The results of proficiency tests • Changes in volume or type of work • Client/customer feedback and complaints • Staffing resources and training requirements • Quality control/quality assurance activities • Other relevant QA information. Corrective or preventive actions that result from Quality Program reviews shall be documented via a corrective action documentation process that is consistent among all Environmental Services sections participating in this QA Program and communicated by management. The QA Administrator, QA Officers and/or managers shall maintain records of reviews and revisions. Environmental Services QA Manual (revision 8) Page 15-1 of 4 Effective 11/07/2013 B. QA MANUAL REVIEW Managers, QA Officers, and the QA Administrator shall review the Environmental Services QA Manual and appendices annually to implement improvements and keep the documents current. The QA Manual shall have a revision number and a Revision History page that documents each revision. Each specific revision shall be documented with an interim QA Manual revision memo to file that describes the revision in detail, includes a date that the revision becomes effective, and includes approval signatures of the QA Administrator and at least one QA Officer. These memos shall be distributed to each controlled copy holder for inclusion in their manual. The QA Administrator shall maintain a master file of all interim revision memos to file. The QA Manual will be updated annually with changes from QA interim revision memos to file. Any change to the QA Manual shall be considered a revision and result in a change of the revision number. Hard copy QA Manuals and appendices shall contain no handwritten comments, notes or marks. No correction fluids (Liquid Paper®, White Out®, etc.) shall be used on any part of the QA Manual or appendices, including the Revision History sheet. All QA document revisions shall be made as typewritten changes and the revision documentation shall include the original signature of the individual making the revision. Controlled copies of the QA Manual and appendices may be maintained in hard copy format or electronically within controlled -access network shares or databases. Controlled copies of the QA Manual and appendices may be distributed separately or as a complete set. Individual, uniquely numbered controlled copies will clearly be stamped or printed in ink "controlled copy." The QA Administrator shall maintain a list indicating the person(s) to whom each controlled copy of the QA Manual and/or appendices were assigned. The QA Administrator shall distribute revisions to persons assigned controlled copies, and they shall revise their controlled copies accordingly. Uncontrolled copies of the QA Manual and appendices may be used as long as they are clearly stamped or printed in ink "uncontrolled copy". It shall be the individual's responsibility to ensure that any copies of the QA Manual and/or appendices are the current revisions before using as a reference. Outdated, uncontrolled copies shall be destroyed. Environmental Services QA Manual (revision 8) Page 15-2 of 4 Effective 11/07/2013 Master copies of the QA Manual with approval signatures and master copies of appendices shall be maintained by the QA Administrator in a lockable fireproof cabinet. When the QA Manual is revised, the respective master copy will be stamped in red "SUPERSEDED BY REVISION # if or otherwise the master copy shall be clearly identified as "superseded" if stored in a secure on-line database or file server. Superseded master copies shall be kept on file for historical documentation by the QA Administrator. The revised document shall become the new master copy and the Review / Revision History sheet will be updated in the new master copy. Environmental Services QA Manual (revision 8) Page 15-3 of 4 Effective 11/07/2013 This page left blank intentionally. Environmental Services QA Manual (revision 8) Page 15-4 of 4 Effective 11 /07/2013 CHAPTER 16 REPORT REVIEW AND APPROVAL A. REVIEW AND APPROVAL OF REPORTS AND DATA RELEASES Reports, memos (except as exempted; described in the following section) and technical papers that include data, data summaries or conclusions based on Duke Energy environmental or operational data resources shall undergo a thorough technical review by in-house subject matter experts and/or other appropriate staff selected by the author and/or the author's manager. Figure 16-1 illustrates the report review guideline that is used in Environmental Services. Each reviewer shall document in writing approval, qualification, or rejection of the finalized reports and summary memos they review. Management shall document in writing approval, qualification, or rejection of the finalized reports and summary memos. These reviews shall be documented by completing Section 1 of a Report, Publication or Presentation Review form (Section 1, Appendix 6). Completed form(s) from all principal reviewers shall be maintained on file with the completed document. For technical papers authored by Environmental Services personnel that are to be submitted for publication or presented orally at meetings or conferences attended by external audiences, further approval by a representative from the legal department, Duke Energy Public Affairs, and/or departmental management may be required, at management's discretion. These reviews and approvals shall be documented by completing Section 2 of the Report, Publication or Presentation Review form (Section 2, Appendix 6). Report, Publication or Presentation Review forms shall be maintained on file with the completed presentation or publication. Final approval of regulatory reports shall be documented on a Final Report Approval form (Appendix 7) and filed with the completed report. For data requests from external parties, prior to release of the data the applicable Data Manager shall ensure that the release of written or electronic data complies with the procedure outlined in the Duke Energy EHS Manual. Environmental Services QA Manual (revision 8) Page 16-1 of 4 Effective 11/07/2013 B. EXEMPTIONS FROM REVIEW REQUIREMENTS Some routine reports or communications (e.g., data listings or routine summaries sent to a generating station on a periodic basis) may be exempted from the requirement for a technical review. The decision to exempt a report (or certain classifications of reports or memos) will be made at the discretion of the responsible section manager or supervisor. Documentation of reports or memos (or certain classifications thereof) exempted from review shall be maintained by management. Environmental Services QA Manual (revision 8) Page 16-2 of 4 Effective 11/07/2013 Author SME(s) and \ functional area writes 1 St Approved? draft. manager reviews / 1 st draft. , resoive wan autnor. Complete functional No. Author files review area review Publication? documentation in documentati functional area files. on (Section 1, Appendix. 6). Yes. Incorporate comments. No. Complete Selected publication review reviewers Approved? form (Section 2, review Appendix. 6). report. Yes. Author files publication review documentation in functional area files. End. Continue on next page. Figure 16-1. Report Review Guideline. Author incorporates comments and submits report for publication. Yes. Environmental Services QA Manual (revision 8) Page 16-3 of 4 Effective 11 /07/2013 Continued from previous page. Regulatory Yes. Author(s) produce 2nd Co-author(s) review 2 Report? draft. d raft. No. End. Managers Report and authors 1 coordinator or Author(s) review entire lead author incorporates report. combines comments. chapters. Approved? No (Only minor editorial Yes. changes requested.) Report coordinator or lead author incorporates comments. Report coordinator or lead author incorporates comments and converts to Adobe format. IFinal report distributed to authors and I customers. Report coordinator or lead author files the approval page and final report in paper or electronic format. End. / authors request changes. Station/compliance personnel review report. No. Resolve Yes. N. , with author. Approved? js Report coordinator or lead author produces approval page (Appendix 7). IManagers and co-authors sign I approval page. 1-The report coordinator role does not apply to every report. Check with your manager if you are unsure. Figure 16-1. (continued) Environmental Services QA Manual (revision 8) Page 16-4 of 4 Effective 11 /07/2013 CHAPTER 17 VENDOR QUALIFICATION Environmental Services management and employees must go through proper Duke Energy channels for contracting work performed by vendors. Management will ensure that vendors have met specific Duke Energy requirements. Management and project leaders are responsible for assuring that any vendor that is employed is aware and adhering to all specific QA expectations. A. BLIND SAMPLES 1. Requests for Blind Samples Blind samples, where available, will be sent to vendor labs along with regular shipments as requested by the customer. 2. Results of Blind Samples Results of blind samples will be documented and any deficiencies noted. Vendors will be informed of deficiencies noted and requested to initiate corrective action. A new blind sample will be sent when corrective action is completed B. ON -SITE AUDITS OF VENDORS Audits of vendors that support Environmental Services sections may be requested by management, customers, or project leaders. Onsite audits will be performed when the results of performance samples or blind samples indicate a trend of decreasing quality of work by the vendor or upon request of the customer. Audit planning and scope will be the responsibilities of section managers or their designees. Management is also responsible for conducting the audit or assigning it to one or more qualified section members. Personnel selected to participate because of their technical expertise may also participate in the planning as well as the audit itself. Audit results including vendor QA information and blind QC sample results will be documented and maintained for the life of the facilities that are being supported by that particular vendor. Environmental Services QA Manual (revision 8) Page 17-1 of 4 Effective 11/07/2013 C. ENVIRONMENTAL SERVICES REQUIRED DOCUMENTATION All vendors performing scientific or analytical work on Nuclear safety -related or technical specifications samples for the Nuclear Stations are required to be on the Nuclear Approved Supplier List. Vendors performing scientific or analytical work on all other types of samples should at a minimum provide the following information: • Quality Assurance Program Manual • Qualifications of management and supervision • Results of the last two rounds of certification performance samples [such as Water Pollution (WP), Water Supply (WS), state certification samples, etc.], when available, or results from a third party round robin or PE program such as APG PET, when certification is not available • Copies of applicable state certifications • Copies of recent external audit reports. D. LEAD AUDITOR PREPARATION GUIDELINES FOR AUDITING A VENDOR LABORATORY Environmental Services employees may follow the guidelines below when preparing to audit a vendor laboratory. • Request copies of QA Manual, resumes of analysts, pertinent procedures, prior audit reports, etc. before the audit. • Prepare audit checklists from findings, deviations, good practices, etc. mentioned in prior audit reports. • Prepare audit checklists from vendor's QA requirements as stated in their QA Manual. • Prepare audit checklists from a sampling of vendor procedures. • Note areas that may not meet/match our in-house QA requirements as stated in our QA Manual. • Select Duke Energy subject matter experts, as needed, to assist with the audit. • Provide copies of pertinent vendor documents and/or checklists prepared for the audit to subject matter experts who will assist with the audit. Environmental Services QA Manual (revision 8) Page 17-2 of 4 Effective 11/07/2013 • Meet with Duke Energy subject matter experts to give specific assignments and instructions. • Randomly select procedure(s) to be performed by a vendor analyst during the audit. • Interview randomly selected vendor manager(s) to ascertain their level of awareness and commitment to QA procedures and protocols. • Meet with Duke Energy subject matter experts who assisted with the audit and determine if the vendor's QA program and practices are acceptable and adequate to justify continued use of that vendor. (This determination will probably rely on subject matter expert opinions and observations.) • Present findings to vendor lab management, etc., during the last day of the audit. • Prepare audit report within a mutually agreeable timeframe that does not exceed 90 days. • Request audit response within a mutually agreeable timeframe that does not exceed 90 days. • Meet with internal managers to go over the audit, audit report, and audit response and make recommendations on future use of vendor. • File audit documents in section or functional area document file. Environmental Services QA Manual (revision 8) Page 17-3 of 4 Effective 11/07/2013 This page left blank intentionally. Environmental Services QA Manual (revision 8) Page 17-4 of 4 Effective 11 /07/2013 CHAPTER 18 DATA MANAGEMENT A. DATA 1. Data Recording Laboratory data and quality control records must be kept in indelible black ink. Data recorded in a field environment where use of ink may produce illegible results may be written in pencil. Once data has been entered on a datasheet or form it may not be erased, obliterated, or page torn out. Any errors shall be struck through once, the correction written beside, and initialed. If an entire page is in error, a large X shall be drawn across the whole page and a new page shall be used for the correct data. An explanation shall be written on the erroneous page and initialed. Records of data collection and/or analyses that produce reportable (i.e., will be provided to a client/customer - internal or external - in any form) data shall be stored in a retrievable format. Data records shall include at a minimum: • Project or client/customer name • Procedure number and/or method reference • Date of data collection/analysis (and time if applicable) • Initials or names of collectors/analysts (initials in the collectors field following a slash (/) denotes the individual(s) who served as the second analyst in verifying identifications) • Holding time, if applicable • Unique equipment/instrument identification (e.g., instrument model number and serial number, calibration number, etc.) • Sample ID numbers or unique sample location ID Environmental Services QA Manual (revision 8) Page 18-1 of 8 Effective 11/07/2013 2. Automated Data Acquisition and Recording Data recording may be automated. Such data shall be validated for accuracy. Modifications or corrections made shall be documented in writing, initialed, dated, and retained. 3. Worksheets Worksheets used to record data and calculations shall be initialed and dated by the analyst. To document conformance with written approved procedures, all worksheets shall be labeled with the procedure number(s). 4. Laboratory Notebooks Laboratory notebooks are maintained for data acquired in laboratory quality control procedures (i.e., media and reagent quality control, etc.). Data in notebooks shall be dated and initialed by the analyst. 5. Validation of Data and Computer Programs Data are either validated by the analyst, alternate designee, or may be subjected to a computerized validation process. The validation of data must be documented and traceable. Database users and/or administrators, where applicable, shall follow practices that maintain the integrity of database records, limiting uploads to validated data only. It is the project leader's responsibility to ensure that only valid data are subsequently included in a database or reported. Custom computer programs (i.e., those specifically developed by or for Duke Energy personnel) to be employed in the analysis of, and subsequent reporting of results from the analysis of validated data, shall be subject to an initial validation. Validation may be assured and documented by a program user, or other appropriate designee. Output of such custom computer programs, wherever practical, must be verified by independent means; either manually by calculator operations, by reproducing the calculation using alternate software, or by comparison of results with an existing, well documented source. Environmental Services QA Manual (revision 8) Page 18-2 of 8 Effective 11/07/2013 Modifications to custom computer programs that affect calculation techniques must be fully documented by the programmer, including the date, a description of the modification, and the name of the programmer making the modification. Program validation and subsequent documentation are required where calculations are affected by the modification. 6. Data Security Critical data files, including standardized databases, shall be protected by restricted access where practical. At least one backup copy shall be maintained for data used, or intended for use in subsequent analyses or reports. Backup copies shall be maintained off site (e.g., remote server backups or media storage), or on site in a fireproof storage facility. Records shall be backed up, using methods designated by in-house information technology providers and/or management, at a frequency that ensures any potential loss is minimized. Data security measures other than these may be required or implemented by company or corporate information technology providers. B. SOFTWARE AND DATA QUALITY ASSURANCE Data or software applications used for generating reportable information shall comply with the Environmental Services SDQA Program. Excluded are general-purpose commercial software applications (e.g. operating systems, compilers, spreadsheet programs, word processors, etc.) that are market -proven and/or Company -supported. Data used and/or generated by commercial software may require validation based upon the intended business use (e.g. a SDQA Plan for EXCEL is not required, but a spreadsheet developed using EXCEL that contains macros or formulas may need one). Questions concerning SDQA should be directed to the section or functional area QA Officer or the Environmental Services SDQA Coordinator. C. DOCUMENT CONTROL A document is defined as any written or pictorial information describing, defining, specifying, reporting, or certifying activities, requirements, procedures, or results. Document generation, use, and maintenance shall be handled in a controlled and Environmental Services QA Manual (revision 8) Page 18-3 of 8 Effective 11/07/2013 systematic manner to provide identifiable and retrievable Environmental Services documentation. Document control also includes procedures to ensure that all documents clearly indicate the time period during which the procedure was active. The purpose of document control is to provide identifiable and retrievable documentation for Environmental Services personnel to use in performance of their required functions, and to allow for verification that these functions are being properly performed. 1. Document Type Documents can be divided into three categories: Project Records, Sample Data Records and Quality Assurance Records. These categories include: Project Records • Field data sheets or collection records • Study descriptions • Project Reports and data releases • Internal and external correspondence Sample Data Records • Data sheets • Analysis reports • Strip charts, chromatograms • Sample collection (chain -of -custody forms) storage, disposal records QA Records • Notebooks • Procedures and QA Manual • QC charts • Instrument inventory, maintenance and calibration records • Personnel training records and resumes • Method development records • Method detection limit (MDL) records • Certification records including audit reports • PE records • Corrective action records • Employee signature files • Vendor QA files Environmental Services QA Manual (revision 8) Page 18-4 of 8 Effective 11/07/2013 • Comparability studies 2. Document Storage Environmental Services project related files shall be maintained in approved fireproof facilities, or stored electronically with off -site backup. Documents presented to customers via a report or scientific study and not raw data are the QA documents and are owned by our customers (PIP M-04-02364). It is our customer's responsibility to store and retain such documents. Specific storage requirements for Environmental Services documents are included below. a. Project Records All hardcopy project records are stored in approved fireproof files. Electronic project records are stored in secure on-line databases or Local Area Network (LAN) shares. b. Sample Data Records All hard copies of data sheets, client/customer reports, and chain -of -custody are stored in fireproof files. All data sheets removed from the files shall be returned at the end of each work shift. Data sheets shall be filed in such a way as to allow all "in -control' data for an individual work order to be easily retrieved. Electronic sample data records are stored in secure on-line databases or Local Area Network (LAN) shares. In the Analytical Laboratory, client/customer reports will be kept electronically and uploaded biweekly to a secure LAN share. Environmental Services QA Manual (revision 8) Page 18-5 of 8 Effective 11/07/2013 The original instrument analysis records (raw electronic data files) for analyses conducted under NELAC requirements shall be uploaded at least monthly to the LAN following printout of the hard copy. These records should be maintained for five years and then deleted. Relevant Procedure: Environmental Services Analytical Laboratory, 2872, "Standard Operating Procedure for Filing Analytical Data" c. QA Records The following documents shall be stored in QA Files of each section or functional area when printed: ■ Master copies of procedures and manuals (current and superseded) ■ Method development/method qualification records ■ Training records ■ Instrument and equipment calibration and maintenance ■ Certification/PE data ■ QC charts and records ■ Logbook inventory records ■ MDL records ■ Standard and reagent preparation records ■ Comparability studies The following documents are stored electronically on shared servers that are controlled by Duke Energy information technology organization. ■ Corrective actions ■ Instrument and equipment inventories ■ Standard and reagent receipt records ■ Employee resumes ■ Certification/PE data Environmental Services QA Manual (revision 8) Page 18-6 of 8 Effective 11/07/2013 3. Long -Term Data Storage All Project, Sample and Quality Assurance Records may be transferred to the onsite long term storage vault or corporate storage at any time. The permanent transfer of records into and out of the vault is documented on the Vault Record Inventory (Appendix 8). The temporary borrowing of records from the vault is documented on the Vault Check -Out Log (Appendix 9). Vault Record Inventories and the Vault Check -Out Log shall be stored in notebooks inside the onsite long term storage vault. All boxes must contain a completed Storage Box Contents form (Appendix 10) and must be clearly labeled with the Record Number and a retention period. 4. Document Retention Due to the nature of the work that is performed in different Environmental Services functional areas and the specific needs of numerous client/customer departments and facilities, records must be maintained for various periods of time. All Documents will be retained in accordance with the Duke Energy Records Retention Schedule. Listed below are some specific retention and disposal requirements. ■ Strip charts shall be maintained for five years and then destroyed. ■ Data generated by the Fuels functional area during routine coal analysis shall be maintained as hard copy original data for three years then destroyed. Permanent storage of coal data will be on the Comtrac computer system and LIMS. ■ Personnel training records shall be retained for the duration of employment and three years following termination of employment. Hard copy records will be stored in fire-resistant files. ■ Equipment calibration and maintenance records shall be stored for the life of the facility where it is used. Each section or functional area is responsible for documenting the movement and destruction of records. Environmental Services QA Manual (revision 8) Page 18-7 of 8 Effective 11/07/2013 D. METEOROLOGICAL DATA QUALITY ASSURANCE Hourly averaged meteorological data from the previous day is automatically down -loaded from the onsite datalogger at the meteorological tower by an offsite data management computer within the Environmental Monitoring group at Dukes Environmental Center routinely. The Environmental Monitoring group performs reviews of the hourly data for quality assurance purposes. The hourly data and QA edits are then reviewed monthly by a Certified Consulting Meteorologist within the Meteorology group and signed off, before final edits are made and the quality assured data is archived by Environmental Monitoring. This offsite historical archive of the nuclear station's hourly meteorological data is maintained for the life of the plant, and is accessible via Dukes network servers. The historical, quality assured meteorological data archive is used to provide meteorological inputs to air dispersion models, supporting Radiological Engineering's design basis accident analyses (e.g. control room habitability and offsite impacts) and the station's Offsite Dose Calculation Manual. Annual air dispersion modeling is also performed by Dukes Meteorology group for Radiation Protection's annual radiological effluent release report, as well as assessment of long-term trends in the station's meteorological data. Since design basis accident analyses impact plant operability and QA-Condition 1 systems, the meteorological data from the archive must be checked a third time, prior to air dispersion modeling in support of Radiological Engineering, to meet SDQA Category B requirements, as specified by Nuclear Engineering management. Real-time meteorological data is used by emergency response personnel in field monitoring and dose assessment areas during an event, to track a gaseous plume and develop offsite protective action recommendations for the state and county emergency coordinators. Procedures for use of the meteorological data under accident conditions (i.e. conditions covered by the Emergency Plan) are also controlled by the pertinent portions of Dukes Appendix B Quality Assurance Program and Emergency Response procedures. Real-time data from the meteorological system for emergency response applications is SDQA Category C. Emergency response personnel should always be mindful of any status flags on the real-time data channels displayed, or when used as input to air dispersion models. Verification of the meteorological data for consistency with an independent source is a good quality assurance practice, and can help ascertain how onsite conditions may differ from offsite conditions (e.g. wind direction, wind speeds, temperatures, and precipitation). Environmental Services QA Manual (revision 8) Page 18-8 of 8 Effective 11/07/2013 CHAPTER 19 CORRECTIVE ACTION A. PURPOSE AND SCOPE Conditions adverse to quality shall be promptly identified and corrective action taken. Corrective action may be initiated by any section member as the result of unacceptable quality control results, equipment malfunction, a chronic problem such as unusual quality trends, the result of an audit or management review, etc. Preventive corrective action may be initiated by any section member as the result of identification of potential sources of nonconformance, needed improvements, etc. All corrective actions shall be well documented from initiation through resolution and implementation. B. DOCUMENTATION Management shall implement a corrective action documentation process that is consistent throughout Environmental Services. All corrective action documentation shall include at a minimum: ■ Statement of problem or potential source of nonconformance ■ Assignment of problem investigation and resolution to an individual ■ Target completion date ■ Statement of final resolution ■ Management approval C. CORRECTIVE ACTION PROCEDURES Specific procedures may be written to describe the corrective action process in each section or functional area. Relevant Procedure: ■ Environmental Services Analytical Laboratory, 2874, "Corrective Action Using the Incidents Module of eTRAC" Environmental Services QA Manual (revision 8) Page 19-1 of 2 Effective 11/07/2013 This page left blank intentionally. Environmental Services QA Manual (revision 8) Page 19-2 of 2 Effective 11 /07/2013 CHAPTER 20 AUDITS A. PURPOSE The purpose of an audit is to provide an independent evaluation of processes and performance, and to ensure that the organization meets or exceeds requirements of regulatory agencies, certifying organizations, and this Quality Assurance Program. B. INTERNAL AUDITS Environmental Services management shall arrange for annual audits of group activities to verify that operations continue to comply with the requirements of the stated quality objectives. Audits may be performed by Environmental Services managers or their designee(s). Any audit findings or deviations which cast doubt on the correctness or validity of the information audited shall be examined and corrective actions employed. Any client/customer whose work is affected shall be notified immediately in writing. Findings, deviations, and corrective actions shall be documented by using a corrective action documentation process that is consistent throughout Environmental Services sections and communicated by management. Any corrective action process shall adhere to the requirements of Chapter 19, "Corrective Action," of this manual. Findings, deviations, and corrective actions shall be addressed within a time period that is established between the auditor and audited organization. C. EXTERNAL AUDITS External audits are those performed by groups or agencies outside of Environmental Services sections and Duke Energy. These audits may be requested by a functional area Environmental Services QA Manual (revision 8) Page 20-1 of 2 Effective 11/07/2013 or mandated by a certifying body. State agencies or certifying authorities usually perform external audits. Findings, deviations, and corrective actions shall be documented by using a corrective action process that is consistent throughout Environmental Services sections and communicated by management. Findings and deviations that are discovered during an external audit shall be addressed and corrective actions employed within a specified time period as defined by the auditing authority. Environmental Services QA Manual (revision 8) Page 20-2 of 2 Effective 11/07/2013 CHAPTER 21 ACRONYMS AND GLOSSARY A. ACRONYMS 1. AIHA - American Industrial Hygiene Association 2. APG - Analytical Products Group 3. APG PET - Analytical Products Group Performance Evaluation Testing 4. AR - American Chemical Society Reagent Grade 5. ASHRAE - American Society of Heating, Refrigerating and Air -Conditioning Engineers 6. ASTM - American Society for Testing and Materials 7. APHA - American Public Health Association 8. AWWA - American Water Works Association 9. BFB - 4-bromofluorobenzene 10. BOD - Biological Oxygen Demand 11. CCB - Continuing Calibration Blank 12. CCC - Calibration Check Compounds 13. CCV - Continuing Calibration Verification 14. DEP - Duke Energy Progress 15. DFTPP - Decafluorotriphenylphosphine 16. DI - De -ionized 17. DMRQA - Discharge Monitoring Report Quality Assurance 18. EHS - Environment, Health and Safety Environmental Services QA Manual (revision 8) Page 21-1 of 10 Effective 11/07/2013 19. ELAP - Environmental Laboratory Accreditation Program 20. ELPAT - Environmental Lead Proficiency Analytical Testing 21. EM - Electromagnetic 22. EMPAT - Environmental Microbiology Proficiency Analytical Testing 23. EPA - Environmental Protection Agency 24. ERA - Environmental Resources Association 25. ES - Environmental Services 26. ESQAM - Environmental Services Quality Assurance Manual 27. FDEP - Florida Department of Environmental Protection 28. FMS - Fuel Management System 29. GC - Gas Chromatograph 30. GUMS - Gas Chromatograph/Mass Spectrometer 31. HEPA - High Efficiency Particulate Air 32. ICB - Initial Calibration Blank 33. ICV - Initial Calibration Verification 34. IDL - Instrument Detection Limit 35. LAN - Local Area Network 36. LCS - Laboratory Control Sample 37. LIMS - Laboratory Information Management System 38. MB - Method Blank 39. MCE - Mixed Cellulose Ester 40. MDL - Method Detection Limit 41. MPN - Most Probable Number Environmental Services QA Manual (revision 8) Page 21-2 of 10 Effective 11/07/2013 42. MS - Mass Spectrometry 43. MSD - Matrix Spike Duplicate 44. MSDS - Material Safety Data Sheet 45. MUR - Method Update Rule 46. NCDENR - North Carolina Department of Environment and Natural Resources 47. NCDENR DWQ - North Carolina Department of Environment and Natural Resources, Division of Water Quality 48. NCDHHS - North Carolina Department of Health and Human Services 49. NELAC - National Environmental Laboratory Accreditation Conference 50. NELAP - National Environmental Laboratory Accreditation Program 51. NIOSH - National Institute for Occupational Safety and Health 52. NIST - National Institute of Standards and Technology 53. NPDES - National Pollutant Discharge Elimination System 54. NVLAP - National Voluntary Laboratory Accreditation Program 55. PAT - Proficiency Analytical Testing 56. PCB - Polychlorinated biphenyls 57. PCM - Phase Contrast Microscopy 58. PE - Performance Evaluation 59. PET - Performance Evaluation Testing 60. PLM - Polarized Light Microscopy 61. PPE - Personal Protective Equipment 62. PT - Proficiency Testing 63. QA - Quality Assurance Environmental Services QA Manual (revision 8) Page 21-3 of 10 Effective 11/07/2013 64. QA/QC - Quality Assurance/Quality Control 65. QC - Quality Control 66. RCL - Radiochemistry Laboratory 67. RCF - Refractive Ceramic Fiber 68. RSD - Relative Standard Deviation 69. RTD - Resistance Temperature Detector 70. RTI - Research Triangle Institute 71. RWP — Radiation Work Permit 72. SCDHEC - South Carolina Department of Health and Environmental Control 73. SD - Sample Duplicate 74. SDQA - Software and Data Quality Assurance 75. SDWA - Safe Drinking Water Act 76. SPCC - System Performance Check Compounds 77. SPOC - Single Point of Contact 78. SRM - Standard Reference Materials 79. TLD Thermoluminescent dosimeter 80. TSS - Total Suspended Solids 81. WP - Water Pollution 82. WS - Water Supply B. GLOSSARY The following definitions are applicable to terms used in this manual: Accuracy - The degree of agreement of a measured value with the true or expected value of a standard. Environmental Services QA Manual (revision 8) Page 21-4 of 10 Effective 11/07/2013 Analyst - Employee who is skilled in a particular laboratory function. Audit - A documented activity performed in accordance with written procedures or checklists to verify, by examination and evaluation of objective evidence, that applicable elements of the quality assurance program have been developed, documented, and effectively implemented in accordance with specified requirements. Audit process - The sequence of events that begins with notification of the activity to be audited and ends with the audit closure letter. Batch - Samples that are prepared and/or analyzed together with the same process and personnel, using the same lot(s) of reagents. A preparation batch is composed of one to 20 samples of the same matrix, meeting the above mentioned criteria and with a maximum time between the start of processing of the first and last sample in the batch to be 24 hours. An analytical batch is composed of prepared samples (extracts, digestates or concentrates) which are analyzed together as a group by the same analyst. An analytical batch can include prepared samples originating from various matrices and can exceed 20 samples. Bias - Consistent deviation of measured values from the true value, caused by systematic error(s) in a procedure. Blind samples - quality control known samples that appear as normal samples to a vendor. Calibration - Comparison of a measurement standard or instrument with another standard or instrument to report, or eliminate by adjustment, any variation (deviation) in the accuracy of the item being compared. Case Narrative - Documentation of analytical problem or out -of -control event that may have occurred with samples, instrumentation, data and/or quality control, submitted with data reports to assist the client/customer in properly interpreting analytical results. Chemical Fact Sheets - Duke Energy program administered by the Environment Health and Safety organization that includes MSDS information on chemicals within Duke Energy's Commodities System. Chemical Hygiene Officer - Employee who is responsible for administering the Chemical Hygiene Plan. Chemical Hygiene Plan - Duke Energy McGuire Island Environmental Center plan to safeguard employees against short and long-term health effects associated with specific chemicals through education about potential hazards of chemicals used in Environmental Services QA Manual (revision 8) Page 21-5 of 10 Effective 11/07/2013 laboratories. Written to comply with Federal Register 29CFR1910, subpart Z, identified as Section 1910.1450. Comparability study - A study to determine whether a valid comparison can be made between data collected using two different procedures. Conformance - An affirmative indication or judgment that a product or service has met the requirements of the relevant specification, contract, or regulation; also, the state of meeting the requirements. Consultant — A professional who provides expert advice or services and who is not under direct supervision of a Duke Energy supervisor or manager. Contract employee - An individual who is employed by and paid by another company for services to Duke Energy during a specified period of time and under the direct supervision of a Duke Energy supervisor or manager. Controlled copy - A copy of a document that receives the same revisions as the master copy. Controlled copies are issued to a limited number of individuals. Revisions are issued to each controlled copy holder as they are made. Photocopies and other reproductions of these documents may be allowed in some functional areas, however, they are considered working and/or uncontrolled copies and must be destroyed after each use or verified with the master copy prior to reuse. Corrective Action - The act of adjusting a system or process that is out of conformance with a requirement in order to bring it back into conformance. Data Management - All activities involved in recording, storing, processing, and manipulating data. Data Manager - The Duke Energy employee (typically a manager or supervisor) who is responsible for the collection and maintenance of the data being requested. The Data Manager must ensure that the data request is handled in accordance with the Duke Energy EHS Manual Chapter "Data Request and Release". Data reviewer - An individual who verifies calculations, analytical results, or other forms of data. Document - Any written or pictorial information describing, defining, specifying, reporting, or certifying activities, requirements, procedures, or results. Documentation - Records and documents which encompass the system of preparing written or pictorial information describing, defining, specifying, reporting, or certifying the completion and/or accuracy of activities, requirements, procedures, or results. Environmental Services QA Manual (revision 8) Page 21-6 of 10 Effective 11/07/2013 Duplicate - One of two separate samples taken from the same source (i.e., in separate containers and analyzed independently). EnRad - Duke Energy Nuclear Generation work group that performs radiological analyses. Error - An incorrect entry of any kind. Finding - The failure to develop or implement effectively any applicable element of the quality assurance program. A finding that results from an audit will require a written response. Functional area —work group formed on the basis of work activities performed. Functional areas are generally led by a manager who reports to and Environmental Services director. Good practice - An activity that promotes the success of the organization but is not tied into a procedure or a regulation. Holding time - The number of days or hours between the time of collection and time of analysis or sample preparation, as appropriate. Information use - Procedure should be accessible, but need not be present when performed. Performance of steps in an "INFORMATION USE" procedure may be non -sequential provided that all steps are performed and the data and/or results are not affected. Major revision - A change of a procedure other than correction of typographical errors or clarification of existing requirements. Master copy - The original copy of QA practices and procedures from which controlled copies are made. Method Blank - A clean sample processed simultaneously with and under the same conditions (digested) as samples containing an analyte of interest through all steps of the analytical procedure. Method Detection Limit - The minimum concentration of a substance that can be measured and reported with 99% confidence that the value is above zero. Minor revision - Handwritten modifications to procedures or text which correct typographical errors or clarify existing requirements. Environmental Services QA Manual (revision 8) Page 21-7 of 10 Effective 11/07/2013 Non -routine study - A study which is usually not required by regulatory agencies or management. Non -routine studies usually originate to investigate specific issues. Observation - An item identified during the course of the audit which is not a conformance issue with licensing requirements or QA procedures but is an area where opportunity for improvement is noted. Management should evaluate the necessity for follow-up or corrective action. Precision - The variability of individual results of replicate measurements. Procedure - A controlled set of written instructions that describe how to perform a task. Project - Functional area work done to accomplish particular objectives for a customer. Project leader - Employee who is ultimately responsible for a particular project. QA Administrator - Designated member of the organization who is responsible for oversight of the Environmental Services QA Program. Designation is made by the director(s). QA Officer - Designated member of the organization who is responsible for the Quality Assurance Program of a section or functional area such as the Analytical Laboratory. Such designations are generally made by managers. Quality Assurance - Planned activities that provide assurance of effective quality control. Quality Assurance Plan - A written plan (typically in the form of a manual) that contains quality policy information and describes the quality system of an organization. Quality control - An overall system of activities, the objective of which is "to fine tune and maintain a measurement process in a desired state of stability and reproducibility." (Taylor, 1987) Quarterly - Every three months, plus or minus fifteen days. Reagent Blank - A sample consisting of reagent(s), without the target analyte or sample matrix, introduced into the analytical procedure at the appropriate point and carried through all subsequent steps to determine the contribution of the reagents and of the involved analytical steps to error in the observed value. Environmental Services QA Manual (revision 8) Page 21-8 of 10 Effective 11/07/2013 Recommendation - A suggestion that could improve an already adequate program. Record - Recorded information that is useful in the operation of the organization. Records management - The scientific and systematic control of all records that are required for conducting business within an organization. The steps include the creation or receipt of records, processing, distribution, organization, storage, retrieval, and ultimate disposition. Records Retention Schedule - A comprehensive list of records, indicating for each the maintenance time and when such records may be reviewed for purging or archival retention. Recovery - Ratio of a determined concentration to an expected concentration for a spiked sample or reference material (usually expressed as a percentage). Reference use - Controlled copy of procedure must be present, open, and be referenced at least once during the performance of the procedure. (refer to procedure 2876). Relative Percent Difference - The absolute difference between two measurements divided by the mean of the measurements, and multiplied by 100. Replicate - One of two or more aliquots taken from the same container and analyzed independently. Retention period - The time records must be kept according to legal and/or organizational requirements. SDQA Coordinator — Environmental Services employee who is responsible for ensuring that SDQA requirements are implemented in Environmental Services. Sample - A small part of a substance (e.g. water, etc.) or population (e.g. fish, benthos, etc.) that is logged -in to a functional area for further analyses. "Shall" - The use of "shall" mandates that instruction, it must be followed. "Should" - The use of "should" means highly recommended but not required. Spike - Addition of a known volume and known concentration of an analyte to a known volume of sample. Standards Laboratory - Duke Energy Nuclear Generation work group that provides NIST calibrations. Environmental Services QA Manual (revision 8) Page 21-9 of 10 Effective 11/07/2013 Stock code - Organized system of letters, numbers and characters that represent items in a supply. Uncontrolled copy - A copy that is clearly marked "uncontrolled copy" and will not be tracked or updated. Variance - Any difference from a regulatory procedure. Vendor — A company that sells goods or services. Environmental Services QA Manual (revision 8) Page 21-10 of 10 Effective 11/07/2013 LITERATURE CITED American Public Health Association (APHA); American Water Works Association; Water Environment Federation. 1998. Standard methods for the examination of water and wastewater. 201h Edition. APHA, Washington, DC. 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants. AIHA, AIHA LQAP Policy Document, January 2004. APHA, Standard Methods for the Examination of Water and Wastewater, 20th Ed. APHA, Washington, DC, 1998. Duke Energy Corporation, Duke Energy Environment, Health & Safety Manual (online document). Duke Energy Corporation, Duke Energy Records Retention Schedule Database, (online document). Duke Energy Corporation, Analytical Laboratory Services, Quality Assurance Program, February 2003. Duke Power Company, Electric System Support, Scientific Services Section, Fish Team Quality Assurance Program, 1996. Duke Power Company, Group Environment, Health and Safety, Scientific Services Section, Environmental Chemistry Team Quality Assurance Program, July 16, 1998. Duke Power Company, Group Environment, Health and Safety, Scientific Services Section, Aquatic Ecology Team Quality Assurance Program, March 8, 1999. Duke Power Company, Engineering and Compliance Services, Quality Assurance Manual, July 19, 2002. Duke Power Company, EHS Software and Data Quality Control, January 2004. Duke Power Company, EHS, Environmental Engineering, Nuclear Quality Assurance Manual, 2004. NELAC, Quality System, 2003. Taylor, J. K., Quality Assurance of Chemical Measurements, CRC Press, Inc, 1987. USEPA, Manual for Certification of Laboratories Analyzing Drinking Water, 4th Edition, 1997. Environmental Services QA Manual (revision 8) Page L-1 of 2 Effective 11/07/2013 USEPA, Manual for Certification of Laboratories Analyzing Drinking Water, 5th Edition, 2005 Environmental Services QA Manual (revision 8) Page L-2 of 2 Effective 11/07/2013 Appendix 1. Additional Information for Environmental Services Analytical Laboratory. 1. INTRODUCTION The objective of Duke Energy's Environmental Services Analytical Laboratory is to provide accurate analytical data that is legally defensible. We will accomplish this objective by adhering to all aspects of this QA Program as describe in this manual and all applicable appendices. 2. SCOPE This QA Program is intended to meet the requirement of the environmental laboratory certification programs for the states in which we are certified, NELAP and 10 CFR 50 Appendix B. 3. CODE OF ETHICS Environmental Services Analytical Laboratory guiding principles: • To produce results that are technically sound and legally defensible; • To assert competency only for work for which adequate equipment and personnel are available; • To present services in a confidential, honest, and forthright manner; • To have a clear understanding with the client/customer as to the extent and kind of services to be rendered; • To provide employees with training and an understanding of the ethical and quality standards required in this industry; • To operate facilities in a manner that protects the environment and the health and safety of employees and the public; • To obey all pertinent federal, state, and local laws and regulations; • To continually improve product quality and service delivery; and • To deal openly, honestly, and fairly in all business and financial matters with employees, clients/customers and the public. Appendix 1 Environmental Services QA Manual (revision 8) Page A-1 of 26 Effective 11/07/2013 We have developed a proactive program for prevention and detection of improper, unethical, or illegal actions. Components of this program include: documented training on the Duke Energy Code of Business Ethics and this QA Program; internal proficiency testing (single and double blind); data audits by the section or functional area QA Officer and post -analysis data review by scientists/engineers and other qualified analysts; analyst notation and sign -off on manual integration changes to data; and a list (below) identifying improper, unethical, or illegal laboratory and instrument manipulation practices. Improper actions are defined as deviations from contract -specified or method - specified analytical practices and may be intentional or unintentional. Unethical or illegal actions are defined as the deliberate falsification of analytical or quality assurance results, where failed method or contractual requirements are made to appear acceptable. Examples of improper, unethical, or illegal practices are identified below: • Improper use of manual integrations to meet calibration or method QC criteria (e. g., peak shaving or peak enhancement are considered improper, unethical, or illegal actions if performed solely to meet QC requirements); • Intentional misrepresentation of the date or time of analysis (e.g., intentionally resetting a computer system's or instrument's date and/or time to make it appear that a time/date requirement was met); • Falsification of results to meet method requirements; • Reporting of results without analyses to support; • Selective exclusion of data to meet QC criteria (e.g., method detection limit results dropped without technical or statistical justification); • Misrepresentation of laboratory performance by presenting calibration data or QC limits within data reports that are not linked to the data set reported, or QC control limits presented that are not used for batch control; • Unwarranted manipulation of computer software (e.g., improper background subtraction to meet ion abundance criteria for GC/MS tuning, chromatographic baseline manipulations); • Improper alteration of analytical conditions (e.g., modifying electromagnetic (EM) voltage, changing GC temperature program to shorter analytical run time) from standard analysis to sample analysis; • Misrepresentation of QC samples (e.g., adding surrogates after sample extraction, omitting sample preparation steps for QC samples, over -spiking or under - spiking); • Substituting invalid calibration data with valid data from a different time so that the analysis appears to be successful; • Reporting results from the analysis of one sample for those of another, and • Concealing a known analytical or sample problem as well as concealing a known ethical problem. Appendix 1 Environmental Services QA Manual (revision 8) Page A-2 of 26 Effective 11/07/2013 Intentional improper actions, unethical or illegal action will result in a detailed investigation per Duke Energy Human Resources Corrective Action Policy that could lead to serious consequences including verbal/written warnings or discharge depending on the seriousness of the infraction. During the annual training on the QA manual, the QA officer will review the Code of Ethics section of the QA manual with all employees. Upon completion of the training, all employees will initial and date the Annual QA Manual/Code of Ethics procedure training form. In addition to the annual training, verification of data integrity will be conducted during internal audits as well as periodic inspection of the lab by area managers. These items are covered in Appendix 1 — Chapter 20, Audits. 4. QUALITY ASSURANCE RESPONSIBILITIES AND ORGANIZATION A. Quality Assurance Responsibilities and Organization The Environmental Services Analytical Laboratory is divided into three groups (Central Fuels, Inorganics/Metals, and Customer Support) which include five functional areas (Inorganic, Coal, Fuels, Trace Metals, and Customer Support). Each group includes a supervisor, 1-2 exempt personnel and 3-6 non-exempt personnel. The supervisors of each group, an administrative assistant and the QA Officer report directly to the Environmental Services Analytical Laboratory Manager. The responsibilities of the Environmental Services Analytical Laboratory Manager and group supervisors are covered in QA manual Section 4.0. Exempt staff responsibilities include analytical method development, special projects, data review, providing specialized technical expertise and client/customer contact interface. They may also conduct analyses as needed. The non-exempt staff responsibilities include performing the various tasks associated with the routine operation of Environmental Services Analytical Laboratory and generating accurate and complete data. They may also assist in method development and provide technical expertise. All Environmental Services Analytical Laboratory groups are responsible for adhering to all QA/QC procedures, including documenting training, performing MDL/Instrument detection limit (IDL) as required by procedure, generating, investigating and responding to all corrective actions in a timely matter, ensuring that all equipment and instruments are properly maintained and calibrated, investigating and properly documenting all failed QC parameters. The Central Fuels group includes the functional areas of Coal and Oil. This group is responsible for sample receipt, log -in, sample preparation, sample analysis, Appendix 1 Environmental Services QA Manual (revision 8) Page A-3 of 26 Effective 11/07/2013 customer contact, data review and data reporting for all samples that require coal and oil analyses. The Inorganic/Metals group is responsible for the preparation, analysis and data review of all samples that require trace metals analyses. Additionally, this group is responsible for the preparation, analysis and data review of all samples that require inorganic analyses. The Customer Support group is responsible for client/customer interface, ensuring sample integrity, initiating and closing chain -of -custody records, sample receipt and log -in, and report generation for inorganic, metals, and radiochemistry samples. This group also does some reporting for coal and oil analyses and is also responsible for shipping and receiving, ordering supplies and maintaining vendor contracts. Customer Support is also responsible for vendor lab management and Laboratory Information Management System (LIMS) administration and maintenance. B. Personnel Qualifications Duke Energy's Environmental Services Analytical Laboratory retains personnel with a variety of backgrounds to accomplish its mission. All employees receive laboratory training to complement previous laboratory experience. Job classifications within the Environmental Services Analytical Laboratory meet education and experience qualifications set forth by the North Carolina Department of Environment and Natural Resources (Title 15A NCAC 2H .0801- .0810), the South Carolina Department of Health and Environmental Control, and NELAP. Specific qualifications for the various positions may be found in the Duke Energy Position Guides and Position Analyses. In addition, in-house training programs and vendor training enhance basic education and experience requirements by providing additional information on technical subjects, safety, quality assurance, and supervisory and managerial techniques. C. Commercial Grade Testin_q Inspectors Personnel approving analyses for the Commercial Grade Testing program are certified as Chemical Inspectors, as required by Duke Energy Nuclear Supply Chain QA Procedure SCD-310 (Materials Inspector/Tester Training and Certification). They must meet the applicable requirements relating to the following numbers: 1. Education (310.4.8) (minimum high school graduation or GED equivalent), 2. Experience (310.4.8) (minimum six months of related experience in equivalent inspection, examination, or testing activities), Appendix 1 Environmental Services QA Manual (revision 8) Page A-4 of 26 Effective 11/07/2013 3. On-the-job participation in the category (310-Appendix C) (training on specific Commercial Grade Testing procedures), 4. Capability Demonstration (310-Appendix C) (satisfactory performance of procedure for manager or designee), 5. Physical Requirements (310.4.10) (eye examinations for near distance acuity and color differentiation), and A list of procedures relating to the Commercial Grade Testing program, and a list of qualified Inspectors, shall be maintained and updated periodically by the Laboratory QA Officer. 5. PROJECTS No additional information. 6. CERTIFICATIONS AND INTER -LABORATORY QUALITY ASSURANCE PROGRAMS The current inter -laboratory QA programs in Environmental Services Analytical Laboratory are listed in Appendix 4. 7. WORK PLACE No additional information. 8. HOUSKEEPING No additional information. Appendix 1 Environmental Services QA Manual (revision 8) Page A-5 of 26 Effective 11/07/2013 9. INSTRUMENTATION AND EQUIPMENT A. Ovens, Waterbaths, and Refrigerators Each workday that an incubator, oven, waterbath, or refrigerator in Environmental Services Analytical Laboratory is used to store a sample or process an analysis, temperature (and pressure, if applicable) shall be checked, recorded in a log or on the analytical data sheet, and initialed. [Due to exposure concerns, the radiochemistry functional area refrigerator will be monitored only when regulatory samples (e.g., NPDES) are stored in it.] The temperatures of refrigerators in Environmental Services Analytical Laboratory are recorded once per day. If temperature of a refrigerator is <1 or > 6.0 °C, adjust temperature control. If not 1-6.0 °C within 4 hours, move samples to another refrigerator. If temperature exceeds 10°C, move the samples, inventory the samples, and inform clients/customers, supervisors, project leaders, and QA Officer. Record the sample inventory and a description of the problem in a memo to the QA Officer. All corrective action performed when the temperature is outside of 1-6.0 °C shall be recorded in the Refrigerator Log. B. Temperature Device Calibrations Calibration of thermometers by Environmental Services Analytical Laboratory personnel will be conducted according to procedure 2871, "Calibration Verification of Thermometers." The calibration frequency will not exceed one year. Thermometers used as reference standards shall be used for calibration only and for no other purpose, unless it can be demonstrated that their performance as reference standards have not been invalidated. Temperature readings for storage or analyses of regulatory conformance samples shall be corrected using the calibration values from the Calibration Report or the Environmental Services Analytical Laboratory calibration check. For example, if the Report or calibration check indicates that a thermometer used for refrigerator monitoring reads 0.3°C low at 4°C, add 0.3°C to any reading from that thermometer before recording in the temperature log. C. Mechanical Pipettes Calibration of mechanical pipettes in Environmental Services Analytical Laboratory shall be checked according to Procedure 2800 "Microliter Pipette Calibration Check." Appendix 1 Environmental Services QA Manual (revision 8) Page A-6 of 26 Effective 11/07/2013 10. SAMPLE CONTROL A. Sample Receipt All Environmental Services Analytical Laboratory samples except coal and oil shall be received according to Procedure 2853, "Sample Receipt, Login, Storage, Distribution, and Disposal." Environmental Services Analytical Laboratory Samples that are sent to vendor laboratories for analysis will be handled according to Procedure 2867, "Subcontracting Analytical Services." All coal samples shall be received according to Procedure 2863. All oil samples shall be received according to Procedure 2864. Radioactive samples that require Environmental Services Analytical Laboratory analyses are received by EnRad. Environmental Services Analytical Laboratory, Customer Support will ensure that environmental sample collectors have appropriate sample containers and chemical preservatives when samples are to be delivered to Environmental Services Analytical Laboratory for analysis. They will also verify that the signature of the collector is recorded on the chain -of -custody form that accompanies all samples. Preservation and holding times of all groundwater, wastewater, and regulatory surface water samples will comply with requirements of 40 CFR 136 Table H (4). See Table 10-1 for a summary of sampling and preservation requirements. Analysis request/chain-of-custody forms will be filed in accordance with Procedure 2872, "Standard Operating Procedure for filling Analytical Data." Appendix 1 Environmental Services QA Manual (revision 8) Page A-7 of 26 Effective 11/07/2013 Table 10-1 Sample Storage and Preservation Requirements (FEDERAL REGISTER RULE Vol. 77, No. 97/Friday, May 18, 2012 pp. 29806-29807; 40 CFR 136) Parameter numberinama Container' Preservation Maximum holding time Table IA ---Bacterial Tests: 1-5. Coltform, total, decal, and E. c0i ..................... PA, G.,............................... 6- Fecal strept❑coxi -• ..--... .-----•------- ------------ PA, G................................. 7. Enterococcl......... -......... -.................................. PA, G ............. -.................. 8. Salmonella............................................................ PA, G................................. Table IA --Aquatic Toxicity Tests: 9-12. Toxicity, acute and chronic ........................... P, FP, G ............................ Table ll'-Inorganic Tests: 1. Acidity ...- .................................... ......................... P, FP, G ............................ 2. Alkallnity............................................................... P, FP, G ............................ 4. Ammonia.............................................................. P. FP, G ............................ 9. Biochemical oxygen demand ......................... P. FP, G ............................ 10. Boron................................................................. P, FP, or Quartz ............... 11. Bromide ............ ........................... - ...... ............... P, FP, G ........ .............. -.. 14. Bbochemical oxygen demand, carbonaceous .... P, FP G ............- ............... 15. Chemical oxygen demand ................................. P, FP, G ...................,........ 16. Chloride - .. ......................... P..,.,,..,..,.,,,,..,.,.,...., P. FP, G ........................... 17. Chlorine, total residual ....................................... P. G................................... 21. Color . •. •.........•..--................................... P, FP, G ............................ 23-24. Cyanide, total or available (or CATC) and P. FP, G ............................ free. 25. Fluoride.............................................................. P........................................ 27. Hardness ......................................................... P. FP, G ............................ 28. Hydrogen ion (PH) .............................................. P, FP, G .... .... -........... -.... 31, 43. Kjetdahl and organic N ............................... P, FP, G .......... I................. Table IB--Metals:7 18. Chromium VI ... ......................... ..................... -- P, FP, G ............................ 35. Mercury (CVAA) .............................................. P. FP. G ............................ 35. Mercury (CVAFS) ............................................... FP, G; and FP -lined cap 17' 3, 54, 12, 13, 19, 20, 22, 26. 29. 30, 32-34, 36. P, FP, G ............................ 37. 45, 47, 51, 52, 58-60, fit, 63, 70-72, 74, 75, Metals, except boron, chromium V1, and mercury. 38. Nilrate................................................................. P, FP, G ............................ 39. N4rate-nitrite....................................................... P, FP, G ............................ 40. Nilrite.................................................................. P, FP, G ............,..- ...... ..... 41. OH and grease .................................................... G........................................ 42. Organic Carbon .................................................. P, FP, G ............................ �- 44. Orlhophosphate.................................................. P. FP, G ........................... 46. Oxygen. Oissolved Probe .................................. G, Bottle and top ............. - 47. Winkler ... ............ -........ .... .......... ....................... G. Bottle and top ............. 48. Phenols.............................................................. G ..................................... - 49. Phosphorous (elemental) ................................... G........................................ 50- PhosPhor"r total ............................................. P, FP. G ... I .... .................... 53. Rasidue, total ..... I P FP G..... .......... .... -- 54. Residue, Filterable ............................................. P. FP. G .„......................... Coot, <10'C, 0.0008% Na,S,0,5. Cool, 04 °C, 0.00080% Na;S;Os s. Cool, <10 °C, 0.0008% Na,S,00. Coot, <10'C, 0.6008% Na2Si00. Cool, �6'C1e Cad, s8'C'e .................... Cool, S6 °C Tit ............... Cool, 56'C i0, H.5M to PH <2. Cool, 56 Vs .................... HNO3 to pH t2 - .......... None required .................... Cool, s6 °C 16 ........ ...... Cool, <g °C's, H250, to PH <2. None required None required .................... Co. s6 °C 16 ... ...,,,, Cod, <6 °CIS, NaOH to pH reducing agent If oxidizer present. None required .................... HNO, or H230.r to pH <2 .. None required .................... Coat, 56'C1O, H;$04 to PH <2. Cool, 58 VC PH - 9.3- 9.7 20, HNO, to PH r2 .................. 5 mUL 12N HCl or 5 mL/L BrCi 17, HW to pH <2, or at laast 24 hours prior to anal- ys�s 19. Cool, 58 'C's .................... Cool, sfi'C's, HISO4 to pH <2. Cool, 56 °C'e ......I...... Coot to --'6 'CIO, HCl or 112SO, to pH <2. 3 Cool 10 56 'C's, HCI. H2SO,, or HRO., to pH <2. Coat, to 56 °Ci 111211 ........... None required .................... Fix on site and store in dark_ Cool, s6 °Cls, H,SO, to pH <2. Cool, <6 *CIS ........ I........... Cool, 56'C's, H,50, to PH K2. Coot, s6'C's ................... Caul, 56 °C's ._- .... ........... B hours-'�•z1 $ hours? 0 hours.22 8 hours.2? 38 hours 14 days. 14 days. 26 days. 48 hours. 6 months. 28 days. 48 hours. 28 days. 28 days. Analyze within 15 minutes 48 hours. 14 days. 28 days. 6 months. Analyze within 15 minutes 28 days. 28 days. 28 days. 90 days.' 7 6 month& 48 hours. 28 days. 48 hours. 28 days. 28 days. Filter within 15 minutes; Analyze within 48 hours. Analyze within 15 minutes. 8 hours. 28 days. 48 hours. 28 days. 7 days. 7 days. Appendix 1 Environmental Services QA Manual (revision 8) Page A-8 of 26 Effective 11/07/2013 Parameter numberiname ContainerPreservation 2.1 Maximum holding lime 4 55, Residue, Nonfilterable (TSS) ............................ P, FP, G ............................ Cod, 56 °C 1s .................. 7 days. 58. Residue. Settleable .........................._.. P, FP, G ............................ Cool, 56 °016 .................,.. 48 hours. 57, Residue, Volatile ....................................... • ._ P, FP, G ............................ P or Quartz Cool, s6 °C 10 .................... Cool. s8 °G'a .................... 7 days. 28 days. 61. Silica................................................................... 64. Specific conductance ......................... ........................ P. FP. G............................ Cool, ;8 aC is.................... 28 days. 65. 5uffate .............................. P, FP, G ............................ Cool, s6 C _ ................. 28 days. 66- Sulfide................................................................ P, FP, G ............................ Cool. 56 'C 1@. add zinc 7 days. acetate plus sodium hy- droxide to pH >9. 67. Sullite P, FP, G-........................... None required .................... Analyze within 15 minutes. ................................................................. 68. Surfactants......................................................... P. FP, G ............................ Cool, 58 G 40 hours. 69. Temperature .................................. P. FP, G ...............,............ P FP G None required ................... Cool 56 °C +a ............. Analyze. 48 hours. 73. Turbidity ... ........................................ . ........................... Table IC --Organic Tests:8 13, 18-20. 22, 24-•28, 34-37, 3". 45--47, 56, G, FP -tined septum .........1. Cool, s6 °G 1so 0.0061/6 14 days. 76. 104, 105, 108-111, 113. Purgeable Na,S20.5. Hatocarbons 6, 57, 106. Purgeable aromatic hydrocarbons ......... G, FF-lined septum .........., Coal, s6 'CIO, 0,008% 14 days.9 NaIStO, 5, HCI to pH 29. 3, 4. Acrolein and acrylonitriie.................................. G. FP -lined septum ........... Cool, s6 °C 16, 0.009% 14 days-10 NazS20.%, pH to 4-510. 23. 30, 44, 49. 53. 77. 80. 81, 98. 100. 112, Phe- Q, FP -lined cap ................. Conf, 56 'C 16, 0-0081/6 7 days until extraction, 40 nols 11. N82%Os• days after extraction. 7, 36. Ban zidines • .....................................I........ G, FP -lined cap ................. Cool. 56 °C 16, 0.008% 7 days until extraction.la Na2S,Od5. 14, 17, 48, 50-52. Phthalate esters" ..................... G. FP -lined cap ................. Cool, s6 °C 16 .................... 7 days until extraction, 40 days after extraction. 82-84. Nitrosamines'r•'4.......................................... G. FP -lined cap ................. Coot, 56 °C1a, store in 7 days until extraction, 40 dark, 0.008% Na+SzOss• days alter extraction, a8•-94. PCBs II ......................................................... G, FPlined cap .........,....... Coot, S6 °C 10 .................... 1 year until extraction, 1 year after extraction. 54, 55. 75. 79. Nstroaromalics and isophorone" .... G, FP -tined cap ................. Cool, 58 `C 18, store in 7 days unfit extraction, 40 dark, 0.008% Na2S3O,s. days after extraction. 1, 2, 5, 8-12, 32. 33, 58, 59. 74. 78, 99, 101. G, FP -lined cap ................. Cool, s8 °C'a, store in 7 days until extraction, 40 Polynuclear aromatic hydrocarbona", 15, 16. 21. 31, 87. Haloethers" ..................... I........ G, FP -lined cap ................. dark, 0.008% Naj8,0,6. Cool, 56 °C 10, 0.008% days after extraction. 7 days until extraction. 40 %2Sz035• days after extraction. 29. 35-37. 6345, 107. Chlorinated hydro- G, FP•lined cap.. Cool, s6'C 1s .................... 7 days until extraction, 40 f1 days after extraction. Carbons . 6t7-62, 66-72, 85, 86. 95-97. 102, 103. COW GDFs"- Aqueous Samples: Field and Lab Preservation ...... G........................................ Coal, 56 °C16, 0,008% 1 year. NazS-203-9, pH <9. Solids and Mixed -Phase Samples: Field Preserva- G........................................ Cool, 56 0016 .................... 7 days. lion. Tissue Samples: Field Preservation ........................ G........................................ Cool, 58 °C,a .................... 24 homs- Solids, Mixed -Phase, and Tissue Samples; Lab G........................................ Freeze, s -10'C ............. 1 year. Preservation. 114-118. Alkylated phenols ..................................... G........................................ Cool. e6 'C, HjSO., to pH 28 days until extraction, 40 <2, days after extraction. 119. Adsorbable Organic Halides (AOX) ................. a ........................................ Gool. <6 °C. 0.006% Hold at leas! 3 days, but Na2S20, HNO, to pH <2, not more than 6 months- 120. Chlorinated Phenolics.................................................................................. Cool, <6 °C, 0.008% 30 days until acetylatlon, Na:S.O.i H,SQ, to pH 30 days after acetyiation. c2. Table i0—Pesticides Tests: 1-70. Pesticides"................................................... G, FP -lined cap ................. Cool, s6'C19, pH r9-19 ... 7 days until extraction, 40 days after extraction. Table 15—Radiological Tests: 1-5. Alpha, beta, and radium ................................... P. FP. G .....................,...... HNO, to pH <2 .................. 6 months. Table 1H—Bacterial Tests: 1- E colf................................................................... PA, G-.......... ...................... Cool, <10 °C, 0,0008% 8 hours 22 Na,S203s. 2. Enterococci........................................................... PA, G................................. Cool. 04 °C. 0.DD08% 8 hours r1 NazS,O: 5. Table IH—Protozoan Tests. 6. Crypfosporidium............ ..................... ................. I LDPE; Feld filtration ........... 1-f0 °C ............................. 96 hours.n 9. Gian*a.................................................................. LDPE; field ftration ........... 1-10 °C ............................. 96 hours.21 ' "P" is for polyethylene; -FP" is lsuompolymer (polytetrafluoroethyyl�ene (PTFE); Teflon*). or other Huoropolymer, unless stated otherwise in this "G" is "PA" is any rhat is made of a stanlizable material (poiypropylane or other auloclavable plastic); "LDPE" is low den• Table tt; glass; plastic ssry polyethylene. Appendix 1 Environmental Services QA Manual (revision 8) Page A-9 of 26 Effective 11/07/2013 2 Except where noted in this Table 11 and the method for the parameter. preserve each grab sample within 15 minutes of collection. For a com- posite sample collected with an automated sample (e.g., using a 24-hour composite sample; see 40 CFR 122.21(g)(7)(i) or 40 CFR Part 403. Appendix E), refrigerate the sample at 5 6 `C during collection unless specified otherwise in this Table ll or in the melhod(s). For a composite sample to be split into separate aliquots for preservatlon and/or analysis, maintain lha sample at 5 6 'C. unless specified otherwise in Ihis Table 11 or in the method(s), until collection, splitting. and preservation is completed. Add the preservative to the sample container prior to sample col- leclion when the preservative will not compromise the integrity of a grab sample, a composite sample, or aliquot split from a composite sample within 15 minutes of collection. If a composite measurement is required but a composite sample would compromise sample integrity, individual grab samples must be collected at prescribed time intervals (e.g., 4 samplas over the course of a day, at 6-hour intervals). Grab samples must be analyzed separately and the concentrations averaged. Alternatively. grab samples may be collected in the field and composited in the labora- tory if the compositing procedure produces results equivalent to results produced by arithmetic averaging of results of analysis of individual grab samples. For examples of laboratory compositing procedures, see EPA Method 1664 Rev. A (oil and grease) and the procedures at 40 CFR 141.34(€](14)(iv) and (v) (volatile organics). 3 When any sample is to be Shipped by common carrier or sent via the U.S. Postal Service, it most comply with the Department of Transpor- tation Hazardous Materials Regulations (49 CFR part 172). The person offering such material for transportation is responsible for ensuring such compliance. For the preservation requirement of Table II, the Office of Hazardous Materials, Materials Transportation bureau, Department of Transportation has determined that the Hazardous Materials Regulations do not apply to the following materials: Hydrochloric acid (MCI) in water solutions at concentrations of 0.04% by weight or less (pH about 1,96 or greater; Nitric acid (HNOA) in water solutions at concentrations of 0,15% by weight or less (pH about 1.62 or greater); Sulfuric acid MSQ,) in water solutions at concentrations of 0.35 % by weight or less (pH about 1.15 or greater); and Sodium hydroxide (NaOH) in water solutions at concentrations of 0.080% by weight or less (pH about 12.30 or lass). d Samples should be analyzed as soon as possible after collection. The times listed are the maximum time$ that samples may be field before the start of analysis and still be considered valid. Samples may be held for longer periods only if the parmiltee or monitoring laboratory has data on File to show that, for the spectfic types of samples under study, the analytes are stable for the longer time, and has received a variance from the Regional Administrator under Sec. 136.3(e). For a grab sample, the holding time begins at the time of Collection. For a composite sample collected with an automated sampler (e.g., using a 24-hour composite sampler; see 40 CFR 122,21 (g) (7)(i) or 40 CFR part 403, Appendix E), the holding time begins at the time of the end of collection of the composite sample. For a set of grab samples composded in the field or laboratory, the holding time begins at the lime of collection of the fast grab sample in the set. Some samples may not be stable for the maximum time period given in the table. A permittee or monitoring laboratory is obligated to hold the sample for a shorter time d it knows that a shorter lime is nec- essary to maintain sample stability. See 136,3(e) for details. The date and time of collection of an individual grab sample is the date and time at which the sample is collected. For a set of grab samples to be compvsited, and that are all collected on the same calendar date, the date of col- lection is the date on which the samples are collected. For a set of grab samples to be composted, and that are collected across two calendar dates, the date of collection is the dates of the two days; e.g., November 14--15. For a composite sample collected automatically on a given date, the date of collection is the date on which the sample is collected. For a composite sample collected automatically, and that is collected across two calendar dates, the date of collection is the dates of the two days; e.g., November 14-15. For stake -renewal toxicity tests, each grab or composite sample may also be used to prepare test solutions for renewal at 24 h, 48 h, and/or 72 h after first use, if stored at 0-6 "C, with minimum head space. 5 ASTM 07365-09a specifies treatment options for samples containing oxidants (a.g., chlorine), Also, Section 9060A of Standard Methods for the Examination of Water and Wastewater (20th and 21st editions) addresses dechlorination procedures. s Sam ling, preservation and mihng interferences in water samples for analysis of cyanide are described in ASTM 07365-oga. There may be interferences that are not mitigatengad by the analytical Iasi methods or D7365-09a. Any technique for removal or suppression of interference may be employed, provided the laboratory demonstrates that it more accurately measures cyanide through quality control measures described in the analytical test method. Any removal or suppression technique not described in D7365-09a or the analytical test method must be documented along with supporting data. 7 For dissolved metals, filter grab samples within 15 minutes of collection and before adding preservatives. For a composite sample collected with an automated sampler (e.g., using a 24-hour composite sampler; see 40 CFR 122.21(g)(7)(i) or 40 CFR Part 403, Appendix E), filter the sample within 15 minutes after completion of collection and before adding preservatives. If it is known or suspected that dissolved sample integ- rity will be compromised during collection of a composite sample collected automatically over time (e.g., by interchange of a metal between dis- solved and suspended forms), collect and filter grab samples to be composited (footnote 2)1 in place of a composite sample collected automati- cally. 6Guidance applles to $ampfes to be analyzed by GC, LC, or GC/MS for specific compounds. a If the sample is not adjusted to pH 2, then the sample musi be analyzed within seven days of sampling. '0The pH adjustment is not required if acrofein will not be measured. Samples for acrolein receiving ro pH adjustment must be analyzed with- in 3 days of sampling- ' When the extractable analytes of concern fall within a single chemical category, the specified preservative and maximum holding times should be observed for optimum safeguard of sample integrity (i.o., use all necessary preservatives and hold for the shortest time listed). When the analytes of concern fall within two or more chemical categories, the sample may be preserved by cooling to 5 6 °C, reducing residual chlo• nine with 0.008% sodium thiosulfate, storing in the dark, and adjusting the pH to 6-9; samples preserved in this manner may be held for seven days before extraction and for forty days after extraction. Exceptions to this Optional preservation and holding time procedure are noted in foot- note 5 (regarding the requirement for thiosuffate reduction), and footnotes 12, 13 (regarding the analysis of benzidine). 72It 1,2-diphenylhydraaine is likely to be present, adjust the pH of the sample to 4.0 t 0.2 to prevent rearrangement to benzidine. s Extracts may be stored up to 30 days at < 0 'C. ^ For the analysis of diphenylnitrosamine, add 0.008% NkS203 and adjust pH to 7-10 with NaOH within 24 hours of sampling. 13 The pH adjustment may be performed upon receipt at the laboratory and may be omitted it the samples are extracied within 72 hours of cof- lection. For the analysis of aldrin, add 0.0080k Na28203. Se Place sufficient ice with the samples in the shipping container to ensure that ice is still present when the sampies arrive at the laboratory. However, even if ice is present when the samples arrive, immediately measure the temperature of the samples and confirm that the preservation temperature maximum has not been exceeded. In the isolated cases where it can be documented that this holding temperature cannot be met, the permittee can be given the option of on -site testing or can request a variance. The request for a variance should include supportive data which show that the toxicity of the effluent samples is not reduced because of the increased holding temperature. Aqueous samples must not be frozen. Hand -delivered samples used on the day of collection do not need to be cooled 10 0 to 6'C prior to test initiation, "Samples collected for the determination of trace level mercury (<100 ngIL) using EPA Method 1631 must be collected in tightly-cappediluoropolymer or glass bottles and preserved with BrCt or HCI solution within 48 hours of sample Collection. The time to preservation may be ex- tended to 28 days if a sample is oxidized in the sample bottle. A sample collected for dissolved trace level mercury should be filtered in the lab- oratory within 24 hours of the time of collection. However, if circumstances preclude overnight shipment, the sample should be filtered in a des- ignated clean area in the field in accordance with procedures given in Method 1669. If sample integrity will not be maintained by shipment to and filtrailon in the laboratory, the sample must be filtered in a designated clean area in the field within the time period necessary to maintain sample integrity. A sample that has been Collected for determination of total or dissolved trace level mercury must be analyzed within 90 days of sample collection, WAqueous samples must be preserved at s 6'Q and should not be frozen unless data demonstrating that sample freezing does not ad- versefy impact sample integrily is maintained on file and accepted as valid by the regulatory authority. Also, for purposes of NPUE5 monitoring, the specification of " s 'C" is used in place of the "4 °C" and "c 4 'C" sample temperature requirements listed in some methods. it is not nec- essary to measure the sample temperature to three significant figures (11100th of 1 degree); rather, three significant figures are specifier/ so that rounding down to 6'C may not be used to meet the 56 °C requirement. The preservation temperature does not apply to samples that are ana- lyzed immediately (less than 15 minutes). Appendix 1 Environmental Services QA Manual (revision 8) Page A-l0 of 26 Effective 11/07/2013 WAow Wnple may be cad arJ e:poa l maw eW 7 per_ Hc.-As ;r. amid no be adubd at tee 24 WL-r t-j?,rk re ffk `� WA&sa 0,51 _ a; &&zed wilrq 24 hOws of wkchn. add the -Yid mve- d a IePy ;saD tch ofe 27. and seJirr,nl s-a- P..r.4 rd rw 6 i to be P a- V& ; he a1 cra r•.c>� it (r�€Ar�olp sM rs a p r- CMe-�rar.em- i i! arm r � �2 To mleve GN-e 28 Ira WGIu-ig brr&. 1—se to ammmn s ie 'e: SCNJiv ad i_fl EPA Ica 215.6. TW allavmrirv- in ih s ion#- r? E sL rSY&-E orawwabco ard tobN _ I MT, iW ih6 n :r�r�,r;, ir: ° �1}� � L� N 3�34 vh �,�lur� �r8 U � Ii'a of ?d. "-,nu caoom1od -c re a' sw-& €sari ki ekffov. irr sp_n-o�as s%jpw 0 h* kbDrdWy in bulk arid t&U ifnT q-- t-re of rn�€e nhral4 a� =�r same hBed r �R. 1F a»al s Lld r a? r =one r sW�nr.Ae . r € s1 ad ai�er�rarl 6 sir = E 1e a1,�a � W e�FLir "WAI S.�r1' Mild S 'or se'ccGe slL*,6 OewlYJs� Y.r•;•._ No �,Mr.Q 1-mR iss !�9P� fDr`he elm EPA Wafi-CMi 16N i T�EC- c, 1 1 I.�-{J Mara A .rpo-.a C1;3VWN - ^r �Li`a�; , �d 8 � �r�i�Ca �es`F�!� Thy ffraflaW won rei,ui �rmm in aMbpknpm Fe rneasu--rrp-.g iS a's � e &ssc or Wawail?�le ;1Ti 9d n'Y ',jscN,rus € 6- # >isll dr Passes H_�;�; a 0.46-rn n . fe e J e re—nireim iu fer Tp � LTUN- ' cdLnhan ji.eL, Wft 15 min- t/ cr# aAdbn� B. Sample Lop -In Samples that are received by Environmental Services Analytical Laboratory are logged into LIMS according to Procedure 2853, "Sample Receipt, Login, Storage, Distribution, and Disposal." Effective October 01, 2010, Analytical Laboratories will utilize a new LIMS database. Quality control and quality assurance procedures will be revised to reflect this change prior to the October I" implementation. All references to LIMS in Analytical Laboratory procedures will be updated as each procedure is revised or is due for review. C. Sample Storage Coal samples and oil samples are stored in the Central Fuels functional area. Radioactive samples are stored in the radiochemistry functional area, which is locked at all times. All other Environmental Services Analytical Laboratory samples are received and stored in the Sample Receipt and Storage Area. This area is under the control of Customer Support. Some samples may be stored temporarily in laboratories while awaiting analysis or re -analysis. See Procedure 2853, "Sample Receipt, Log -in, Storage, Distribution and Disposal." D. Sample Distribution Environmental Services Analytical Laboratory samples that are stored in Sample Receipt and Storage shall be signed out by analysts when removed, and signed in upon return, in accordance with Procedure 2853, "Sample Receipt, Log -in, Storage, Distribution and Disposal." E. Sample Control and Analysis Environmental Services Analytical Laboratory sample containers will be coded to indicate which tests are to be run from each container, in accordance with Appendix 1 Environmental Services QA Manual (revision 8) Page A-11 of 26 Effective 11/07/2013 Procedure 2853, "Sample Receipt, Log -in, Storage, Distribution and Disposal." Analysts are required to run the analysis out of the container designated for that analysis according to the label information. If another container must be used, e.g., when the correct container cannot be found, the analyst must record this information in the analytical record and document it in a Case Narrative. F. Sample Disposal Samples logged into LIMS that are not consumed in the analysis process are stored for the time designated on LIMS. Samples are disposed of properly in accordance with regulatory protocol. Coal samples are routinely disposed after 4 months. All oil samples are disposed in designated collection containers. Radioactive samples are under the control of EnRad personnel. Disposal of all other Environmental Services Analytical Laboratory samples is the responsibility of Customer Support, in conjunction with sample originators. See Procedure 2853, "Sample Receipt, Log -in, Storage, Distribution, and Disposal." 11. REAGENTS AND CHEMICALS No additional information. 12. PROCEDURES A. Procedure Preparation In Environmental Services Analytical Laboratory, method validation shall be performed on all new test method procedures, as applicable, according to Procedure 2876. Documentation of the method validation shall be submitted to the section supervisor and Environmental Services Analytical Laboratory QA Officer with a Method Validation Documentation form. Documentation shall be approved before using the method to report data to customers. All required steps, including those specifying reagents and materials, in reference methods used for regulatory programs shall be followed as written except when deviations are approved by the regulatory authority. Documentation of reasons for any variance from procedural requirements and/or results of any study justifying variance shall be stored in the Environmental Services Analytical Laboratory area document files. All analytical procedures (except digestion preparation procedures and Central Fuels procedures) shall have all quality control requirements as dictated in the EPA Method Update Rule (MUR), May 18, 2012. Appendix 1 Environmental Services QA Manual (revision 8) Page A-12 of 26 Effective 11/07/2013 The header of each page of an Environmental Services Analytical Laboratory procedure shall include the procedure number, revision number, page number and total number of pages. B. Procedure Revision A demonstration of capability must be completed each time there is a significant change (as procedurally defined) in the instrument type or test method. See procedure 2876, "Procedure Preparation, Technical Review, Revision, and Method Validation" for additional information. 1. Procedure Modifications Occasionally the nature of a sample may require deviation from the requirements of a procedure. In this case, the deviations shall be described in detail on the data sheet, initialed, and dated by the supervisor or designee. If the procedure modification is so extensive that it cannot be documented on the data sheet, a separate page should be used. This documentation shall be filed in the LIMS Job files. If the particular sample type or client/customer request becomes routine, the supervisor, project leader, or designee shall address the deviation by recording the change as a revision in the procedure. 2. Special Projects Special projects include modifications of existing procedures requested by clients/customers, sample preparation and/or analyses utilizing methods different from those documented in existing procedures, or investigations requiring new or existing methods requested by clients/customers. Special project methods and reports shall be approved by the supervisor, project leader or designee, but will not require a formal procedure. A detailed account shall be recorded and filed in the LIMS Job files. The final report will be filed in the LIMS Job files. C. Procedure Review All analytical procedures (1200 to 2499) will receive an annual procedure review during the internal audit. The review will document that all parts of the procedure reflect current laboratory practice. If changes are found, and they are in conformance with the reference method, the procedure will be updated. All procedures will receive a detailed review every five years. Relevant procedure • Environmental Services Procedure 2876, "Procedure Preparation, Technical Review, Revision, and Method Validation" Appendix I Environmental Services QA Manual (revision 8) Page A-13 of 26 Effective 11/07/2013 13. TRAINING No additional information. 14. LABORATORY QUALITY CONTROL For the purposes of this section, the term "samples" refers to only actual samples received from a client/customer, and not to QC samples, blanks, or standards. A. Quality Control Checks Several instrument and method quality control checks, described below, shall be analyzed in some combination, depending on the type of analysis, to ensure accurate and precise data are generated. Each Environmental Services Analytical Laboratory procedure shall have the quality control checks specifications. 1. All Methods • Matrix Spike Duplicate (MSD) or Sample Duplicate (SD) - A matrix spike duplicate is an intra-laboratory split sample spiked with target analyte(s) and concentrations identical to those spiked into the matrix spike sample. A sample duplicate is an intra-laboratory split sample. Duplicates are carried through the entire analytical process. The results of the duplicate analyses serve as an indicator of the precision of the method and sample results. For most analyses, analyze a minimum of one sample duplicate or matrix spike duplicate per 20 samples. If the reference method requires duplicates more frequently, follow the reference method. When a matrix spike is performed on a sample, analyze a MSD instead of a SD. If the sample concentration is below the detection limit and a matrix spike is not performed, the use of a standard or reference material for the duplicate analysis is permitted. If the results do not fall within established limits, follow the requirements of Procedures 2802, "Generation of Precision Quality Control Data- Precision Difference," for coal and oil QC analyses not logged into LIMS. Follow Procedure 2809, 'Evaluation of Quality Control Data" for all other areas of the lab. Refer to Procedures 2802 and 2809 for more information about determining precision results. • Laboratory Control Sample (LCS) - The LCS is either a known matrix spiked with independent source (alternate vendor) analytes representative of the target analytes or a certified reference material (QC Standard). The Appendix 1 Environmental Services QA Manual (revision 8) Page A-14 of 26 Effective 11/07/2013 LCS is used to assess and document laboratory performance. The LCS is carried through all preparation steps. The LCS shall be analyzed at a minimum of one per preparation batch of twenty or less samples for all analyses for which a spiking solution is available. For analyses for which a spiking solution is available, but not involving a preparation step, the frequency is daily. The frequency for other analyses [such as Total Suspended Solids (TSS), pH, or turbidity] will be specified in the procedure, but shall be analyzed at least quarterly (when the method is used). A LCS shall also be analyzed whenever a new stock standard stock solution (either purchased or prepared) is used, but at least quarterly when available. Follow Procedure 2809, "Evaluation of Quality Control Data" for evaluation of LCS results. 2. All Instrument Methods • Initial Calibration - Instruments should be calibrated each day the instrument is run unless a master curve is used. The calibration typically consists of analyzing a blank and 3-5 standards; however, the analytical procedure may specify otherwise. The calibration coefficient limit for most procedures is 0.995; however, exceptions may be made if allowed by the reference method. The coefficient shall be specified in the analytical procedure. The % RSD limits will be specified in each procedure where applicable. Calibration standards should be of the same matrix or a similar matrix to the samples. Samples with concentrations greater than the highest calibration standard shall be diluted to fall within the calibration range, or an additional higher calibration standard may be analyzed to prove that the calibration is valid at that concentration. (The standard result must meet the same limit as the Continuing Calibration Verification (CCV). See CCV discussion below for more information.) Some analytical procedures may specify that one of the calibration standards be at the lower reporting concentration. The lowest calibration standard must, however, always be above the calculated method detection limit. Linear regression must be used for the curve fit for all environmental analyses and certified parameter performance samples (e.g., APG). Do not force the calibration line through zero. Quadratic equations are used where appropriate and allowed. Refer to the Master Curve Procedure (2805) for analyses using a master curve. Appendix 1 Environmental Services QA Manual (revision 8) Page A-1 5 of 26 Effective 11/07/2013 • Initial Calibration Verification (ICV) - Where required by the method, immediately following instrument calibration, the accuracy of the initial calibration for each analyte shall be verified by analyzing one or more standards (ICV standards). The ICV is typically at a mid -range concentration; however, the analytical procedure may specify that a standard also be analyzed at a high range concentration. The ICV may or may not be an independent source standard, depending upon method and state certification requirements. When ICV results exceed specified limits, stop the analysis, correct the problem, re -calibrate the instrument, and re -verify the calibration. For most analyses, the limit is ±10% of the prepared concentration. Procedure requirements may be more or less restrictive depending on the reference method requirement. • Initial Calibration Blank (ICB) and Continuing Calibration Blank (CCB) - The ICB and CCB are analyte-free matrices to which all reagents are added in the same volumes or proportions as used in the calibration standards. They are not carried through all sample processing steps, unless the standards are also carried through those steps. The ICB and CCB are analyzed to detect instrument drift and possible contamination. These blanks are utilized for most instrumental methods. Analyze an ICB each time the instrument is calibrated. Analyze a CCB at the end of a run and every 20 samples during the run. If the reference method requires the CCB to be analyzed at a higher frequency, follow the reference method. Frequencies of analysis of the CCB will be documented in the analytical procedure. If the ICB or CCB result is greater than 50% of the reporting limit, investigate, and correct the problem if possible. Otherwise, flag the data. • Reporting Limit Standard - For all certified instrument methods that are calibrated with a daily calibration curve, a calibration or QC check standard shall be analyzed at or below the reporting limit daily. (See Procedure 2805, "Generating a Master Calibration Curve," for Master Curve requirements.) If this standard is analyzed as a sample rather than as part of the calibration curve, the result must be within ± 50% of the prepared concentration. If not, analyze the standard again. If the result is still outside ± 50%, stop the analysis, perform corrective action, and re - calibrate. • CCV - A CCV standard (or standards), generally at a mid -range concentration, is analyzed during each analysis to monitor instrument Appendix 1 Environmental Services QA Manual (revision 8) Page A-16 of 26 Effective 11/07/2013 performance. The CCV may or may not be an independent source standard, depending upon method and state certification requirements. The CCV is analyzed at least every 20 samples unless specified otherwise by the analytical procedure. It is also analyzed at the end of each run. Frequencies of analysis of the CCV will be documented in the analytical procedure. When an initial calibration is not performed on the day of the analysis, and unless the reference method specifies the concentration of the CCV, the concentrations of the calibration verification shall be varied within the established concentration range for all environmental analyses. If the reference method doesn't specify a limit for the CCV, the limit is ±15% of the prepared concentration. It may be higher if permitted by the reference method. A CCV at a concentration close to the reporting limit may have a limit up to ±50% unless the reference method specifies otherwise. When the CCV results exceed the established limits, stop the analysis, investigate the problem, and correct the problem if possible. Recalibrate if necessary. If the instrument is not recalibrated, two consecutive acceptable CCV's must be analyzed before analysis can continue. Repeat analysis of all samples since the last acceptable CCV. • Matrix Spike (MS) - The MS is an aliquot of sample spiked with a known concentration of target analyte(s). The sample is spiked before sample preparation (if applicable), or before analysis if there is no preparation step. The MS is used to document the bias of a method in a given sample matrix. For some analyses such as oil & grease or flash point, there is no practical method of spiking a sample. For most analyses, spike a minimum of one sample out of every 20 samples. MS for some samples may be required at a higher frequency if required by the reference method. These requirements will be recorded in the analytical procedure. Refer to Procedure 2809, "Evaluation of Quality Control Data" for information about determining percent recovery, and corrective action if recoveries are outside of established limits. Spike recovery limits are specified in the analytical procedures and/or the QC spreadsheet databases. 3. All Methods with a Preparation Step • Method Blank (MB) - The MB is used to document contamination, or lack of it, resulting from the analytical process. The MB is an analyte-free matrix to which all reagents are added in the same volume or proportions as used in sample processing. The method blank is carried through the Appendix 1 Environmental Services QA Manual (revision 8) Page A-17 of 26 Effective 11/07/2013 complete sample preparation and analytical procedure. At least one MB of similar matrix as the samples must be prepared, carried through all preparation steps, and analyzed with each batch of samples. The MB concentration for analyses requiring a calibration curve, the concentration of method and reagent blanks must not exceed the following: (1) < 1 /2 of the reporting limit, unless otherwise specified by the reference method, (2) Five percent of the regulatory limit for that analyte, or (3) Five percent of the measured concentration in the sample. Refer to Procedure 2809, "Evaluation of Quality Control Data" for requirements if these limits are exceeded. 4. Summary of QA Requirements Table 14-1 describes the quality control checks that should be performed, when applicable, for each type of analysis. For other analyses not listed, the analytical procedure will specify the quality control requirements. Table 14-1 Summary of nC Requirements Analyses ICP ICP- MS IC Mercury Nutrients General Inor anic Tune Initial Calibration 0 ❑❑���� XOOOOO ICV �X 00 X��X �X ICB OX 00OX OX OX CCB �X 00 X��X �X CCV OX 00OOX OX LCS DDOOOD SD/MSD �X 00�X �X �X Surrogate 0�0000 Internal stds ❑❑���� 0=optional B. Quality Control Tables Results for the following QC parameters will have control limits, and will be recorded for easy retrieval, but are not required to be plotted on a control chart. • LCS • MS recovery Appendix 1 Environmental Services QA Manual (revision 8) Page A-1 8 of 26 Effective 11/07/2013 • SD or MS Duplicate precision • MB Results for the following QC parameters will have acceptance limits, but are not required to be recorded in a table, or plotted on a control chart. • ICB • CCB Control limits for these parameters will be specified in the analytical procedures. C. Quality Control Charts Control charts are set up with warning limits and control limits for percent recovery. The warning limits are determined at ± 2 standard deviations from the mean. The control limits are determined at ± 3 standard deviations. In some cases, administrative limits may be used where the method permits justification or regulatory agencies specify the limits. Refer to Procedure 2811, "Quality Control Chart Evaluation and Calculation of Control Limits," for further guidance on generating control charts and the corrective actions to take when trend conditions occur. D. Blank Correction Blank correction, when required, is normally performed by subtracting a blank response from the total response of a standard. The appropriate method for blank correction shall be determined as part of the development of the analytical method. The blank response used for blank correction of a standard should not exceed the measured sample response. Normally, blank corrections, when used, are performed only on standards. Methods that use reagents that give a detector response must, however, correct for that response in both standards and samples. Examples are TOC or Low-level Silica. E. Detection and Reporting Limits MDLs will be evaluated and calculated initially, each time there is a change in the test method that affects how the test is performed, when a change in instrumentation occurs that affects the sensitivity of the analytes, and as required by the reference method. Appendix 1 Environmental Services QA Manual (revision 8) Page A-l9 of 26 Effective 11/07/2013 MDLs will be calculated using Procedure 2804 or as specified by the analytical procedure. Each procedure shall include quantitation (reporting) limits where applicable. Data may be reported down to the method detection limit; however, sample results falling between the detection limit and the quantitation limit will be reported with a code to flag the result as an "estimate". Data shall not be reported below the method detection limit, unless negotiated with the client/customer and flagged on the report. The MDLs must be verified annually for each quality system matrix, method and NELAC analyte according to procedure 2804. The LOQs must be verified annually for each quality system matrix, method and NELAC analyte that has not completed the annual determination and/or verification of MDLs for the current year. F. Sample Preparation Samples such as soils, sediments, and wastes that require preparation prior to analysis will be homogenized by an appropriate method to ensure that a sub - sample is representative of the whole. G. Dilutions Samples should not be diluted unless necessary to bring the concentration into the calibration range or to reduce matrix effects. When possible, results should be reported from an analysis with no dilution. Samples should be diluted, when necessary, so that the concentration of the diluted sample is in the middle of the calibration range. All sample dilutions shall be made with calibrated pipettes and glassware. H. Manual Integrations Manual integration is defined as adjustment by analysts of the instrument baseline or integration start/stop points. Manual integrations are necessary at times for methods such as chromatography. Other options such as dilution, however, should be explored before manual integration is used. This section is included to assist analysts in determining how and why to perform a manual integration. A variety of situations may occur that make manual integration necessary and acceptable. Peaks may shift or drag due to matrix or condition of the column. Peaks may not be detected because integration conditions are not set properly. Resolution may change and the integration may be different from the calibration integration. All manual integrations should be performed in the same manner as the calibration integration and QC samples. Manual integrations shall not be performed simply to meet QC requirements. Manual integrations shall not Appendix 1 Environmental Services QA Manual (revision 8) Page A-20 of 26 Effective 11/07/2013 include "peak shaving" (reducing the area integrated to decrease the concentration) or "peak enhancing" (extending the integration beyond the peak to increase the concentration). Analysts should verify the identity of any peaks that have shifted due to matrix or column condition. The reason for all manual integrations shall be documented on the quantitation sheet. All original quantitation sheets (prior to the manual integration) shall be included in the worklist data package. The reintegrated quantitation sheet is also included in the worklist data package. 15. QUALITY ASSURANCE PROGRAM REVIEW No additional information. 16. REPORT REVIEW AND APPROVAL No additional information. 17. VENDOR QUALIFICATION No additional information. 18. DATA MANAGEMENT A. Data 1. Data Sheets Every procedure in Environmental Services Analytical Laboratory shall have a data sheet for recording information each time the procedure is performed. The data sheet shall include the following information at a minimum: 1. Procedure number 2. Analyte(s) 3. Analysis date 4. Analyst(s) initials (each analyst involved with analysis) 5. Instrument name (if applicable) 6. Recording units Appendix 1 Environmental Services QA Manual (revision 8) Page A-21 of 26 Effective 11/07/2013 7. Sample/Job number(s) 8. ID number for vendor -calibrated applicable) equipment used in the analysis (if All information pertaining to the performance of the procedure shall be recorded on a data sheet immediately. No data or information relevant to the procedure shall be recorded in any other place before being recorded on the data sheet. If information or data is recorded handwritten on a data sheet before being transferred to an electronic data sheet for calculation, the handwritten sheet shall be attached to the electronic data sheet for review by the data reviewer. (The reviewer may dispose of the handwritten sheet following verification.) Information shall be recorded in sufficient detail that a second qualified employee, using the applicable procedure, would be able to duplicate the analysis accurately. All electronic data sheets shall comply with the requirements of the Environmental Services SDQA Program. See the SDQA Coordinator for a current copy of the SDQA Program and its requirements. The unique sample description shall be clearly noted for each data point generated, including blanks, duplicates and spikes. Rejected data, and the reason for rejection, shall be clearly noted on the data sheet. The analyst shall clearly note and sign -off on manual integrations changes to the data. Chromatograms, strip charts, automatic printouts and the quality control records shall include sufficient information to ensure data validity and traceability. The following information is required at a minimum: LIMS sample number, sample analysis date, analyst initials, procedures number, instrument number, recording units. 2. Data Entry All sample data produced by Environmental Services Analytical Laboratory shall be reviewed by the analyst in accordance with Procedure 2859, "Analyst Data Review and LIMS Data Entry." All routine sample results are entered into Environmental Services Analytical Laboratory LIMS. Special projects results are entered when appropriate. Data may be entered either manually or electronically. Appendix 1 Environmental Services QA Manual (revision 8) Page A-22 of 26 Effective 11/07/2013 3. Data Review Data entered into LIMS shall be reviewed by a qualified data reviewer in accordance with Procedure 2868, "Standard Operating Procedure for Data Review." Individual groups may have procedures that explain specific review requirements for tests performed by that group. 4. Out -of -Control Data The reason for acceptance of all out -of -control data shall be clearly documented on the data sheet and the data sheet shall be signed by the supervisor, scientist or designee. Out -of -control data points shall be clearly labeled by the analyst on data sheets and quality control record. The analyst shall investigate the cause of out -of -control data and correct if possible before proceeding with the analysis, in accordance with QC Procedure 2809, "Evaluation of Quality Control Data". 5. Data Reporting When data on a data sheet is ready for reporting the data sheet shall be stored in a fire-resistant file cabinet. See Procedure 2872, "Standard Operating Procedure for Filing Analytical Data," for detail of the filing process. All data sheets removed from the files shall be returned overnight. Data sheets shall be filed in secure a way so as to allow all "in -control data" for an individual work order to be easily retrieved. All data shall be traceable throughout the analytical process. Sample data in LIMS receives a final review (approval) which is documented in LIMS. This includes a periodic review of any transcriptions or calculations performed after the initial review. The approval and reporting process are described in detail in Procedure 2861, "Approval and Reporting of Chemistry Analytical Results Utilizing LIMS." 6. Certificate of Analysis Coal and performance fuel oil data is reported by the Central Fuels functional area. All other data reporting is the responsibility of the Customer Support group. At a minimum, the following information will be provided in the Certificate of Analysis. • Name of lab • State Certification numbers, if applicable • Job number • Name of analyte(s) • Unique sample description(s) or customer sample ID(s) Appendix 1 Environmental Services QA Manual (revision 8) Page A-23 of 26 Effective 11/07/2013 • Date and time of collection • Name of collector • Date and time received by lab • Methods(s) of analysis • Result(s), with unit(s) of measurement • Remarks about each analysis, if necessary, to qualify the data. • Page number and total number of pages A copy of the chain -of -custody may be used to provide sampling information. Each Certificate of Analysis of environmental conformance data shall include the following if required by the customer: • A title, e.g., "Test Report", or "Test Certificate", "Certificate of Results" or "Laboratory Results"; • Name and address of laboratory and phone number with name of contact person for questions; • Unique identification of the certificate or report (such as serial number) and of each page, and the total number of pages; • Name and address of client/customer, where appropriate and project name if applicable; • Description and unambiguous identification of the tested sample including the client/customer identification code; • Identification of test results derived from any sample that did not meet sample acceptance requirements such as improper container, holding time, or temperature; • Date of receipt of sample, date and time of sample collection, date(s) of performance test, and time of sample preparation and/or analysis if the required holding time for either activity is less than or equal to 48 hours; • Identification of the test method used, or unambiguous description of any non-standard method used; • Any deviations from (such as failed QC), additions to or exclusions from the test method (such as environmental conditions), and any non-standard conditions that may have affected the quality of results, and including the use and definitions of data qualifiers; • Measurements, examinations and derived results, supported by tables, graphs, sketches and photographs as appropriate, and any failures identified; identify whether data are calculated on a dry weight or wet weight basis; identify the reporting units such as mg/L; • When required, a statement of the estimated uncertainty of the test result; • A signature and title, or an equivalent electronic identification of the person(s) accepting responsibility for the content of the certificate or report (however produced), and date of issue; Appendix 1 Environmental Services QA Manual (revision 8) Page A-24 of 26 Effective 11/07/2013 • As necessary, a statement to the effect that the results relate only to the items tested or to the sample as received by the laboratory; • As necessary, a statement that the certificate or report shall not be reproduced except in full, without the written approval of the laboratory; • Clear identification of all test data provided by outside sources, such as subcontracted laboratories, clients/customers, etc; and, • Clear identification of numerical results that are outside of quantitation levels. If out -of -control data must be reported to a customer, it shall be qualified using flags and/or a Case Narrative in accordance with Procedure 2859, "Analyst Data Review and LIMS Data Entry". Certificate of Analysis reports are sent by various methods, depending upon the client's/customer's need. These include Duke Energy courier mail, FAX, or U. S. Mail. If results must be reported by telephone, a written report shall be sent to the customer as soon as possible. If preliminary results must be reported verbally before validation and approval, the customer must be informed that the final result could be different or be qualified due to QC failure. B. Software and Data Quality Assurance (SDQA) No additional information C. Document Control External documents, such as regulations and reference methods, are included as QA records in the external documents database. The external documents database includes information on storage location, record type and retention requirements for each item listed in the database. The external document database will be reviewed annually by the QA officer and lab managers for completeness and accuracy. 19. CORRECTIVE ACTION Whenever any analyte fails on QA or PE samples, a corrective action will be initiated. If the failure occurs consecutively three times, in-house analyses on that analyte will be stopped until the problem is resolved satisfactorily. Appendix 1 Environmental Services QA Manual (revision 8) Page A-25 of 26 Effective 11/07/2013 20. AUDITS To ensure that the requirements of the Quality Assurance program are being met, internal audits will be conducted annually. The QA Administrator in conjunction with the Environmental Services Analytical Laboratory QA Officer will be responsible for internal audits. The audit will include a review of laboratory activities including documentation, procedural conformance and QC. The annual internal audit will also include a detailed data integrity review of data packages from each testing area in the lab (i.e. ICP, ICP MS, Lachat, Dionex, etc.). The annual internal audit will also include a review of analytical SOPS to ensure current practices are reflected in the SOPS. The audit may include a review of the following documents applicable to the audit: previous internal and external audit reports, laboratory data sheets, chain - of -custody, client/customer reports, disposal records, equipment and instrumentation maintenance and calibration records, QC records, corrective actions, data processing or data management records, training and qualification records of the analysts, procedures, and standard and reagent records. The supervisor of the audited area has the responsibility for correcting any deficiencies. Corrective action will be addressed using the Corrective Action Using the Incidents Module of eTRAC procedure 2874. In addition to annual audits, periodic inspections will be performed by the area managers to verify data integrity. These checks will be documented on a checklist and filed in the QA files. Any infraction will be reported to the Lab Director immediately and a detailed investigation will be completed. 21. ACRONYMS AND DEFINITIONS No additional information. Appendix 1 Environmental Services QA Manual (revision 8) Page A-26 of 26 Effective 11/07/2013 Appendix 2. Additional Information for Asbestos Functional Area of Environmental Services. The Asbestos Functional Area appendix (Appendix 2) was retired on November 30, 2012 and is therefore not included in this manual. Appendix 2 Environmental Services QA Manual (revision 8) Page B-1 of 2 Effective 11/07/2013 This page left blank intentionally Appendix 2 Environmental Services QA Manual (revision 8) Page B-2 of 2 Effective 11 /07/2013 Appendix 2a. Asbestos Laboratory Client/Customer Satisfaction Survey. The Asbestos Laboratory Client/Customer Satisfaction Survey appendix (Appendix 2a) was retired on November 30, 2012 and is therefore not included in this manual. Appendix 2a Environmental Services QA Manual (revision 8) Page C-1 of 2 Effective 11/07/2013 This page left blank intentionally. Appendix 2a Environmental Services QA Manual (revision 8) Page C-2 of 2 Effective 11/07/2013 Appendix 3. Additional Information for Microbiology Functional Area of Scientific Services. The Microbiology Functional Area appendix (Appendix 3) was retired on December 22, 2006 and is therefore no longer included in this manual. Appendix 3 Environmental Services QA Manual (revision 8) Page D-1 of 2 Effective 11/07/2013 This page left blank intentionally. Appendix 3 Environmental Services QA Manual (revision 8) Page D-2 of 2 Effective 11 /07/2013 Appendix 4. Inter -laboratory QA Programs and Schedules Program Sample Types(s) Schedule ANALYTICAL LABORATORY Environmental Resources Non -Potable Water — for Annually Proficiency Testing (PT) NC/SC certification Discharge Monitoring Report Water Annually Quality Assurance (DMRQA) Inter -laboratory Coal Coal (60 mesh) Monthly Round Robin QAR - Coal Round Robin Coal (4 mesh/60 mesh) Monthly Canspex - Coal Coal (60 mesh) Quarterly Nuclear Cross-check Inorganic, primary Three times annually and secondary matrices American Society for Testing Diesel fuel Three times annually and Materials (ASTM) #2 Diesel Fuel Inter -laboratory Crosscheck ASTM Engine Lubricating Lubricating oil Three times annually Oil Inter -laboratory Crosscheck ASTM In service hydraulic Hydraulic fluid Three times annually fluid Inter -laboratory Crosscheck ASTM Insulating Fluid Inter- Insulating fluid Semiannually laboratory Crosscheck ASTM Dissolved Gas Dissolved gas Semiannually Analysis Inter -laboratory Crosscheck Environmental Lead Lead in paint and soil Quarterly Proficiency Analytical Testing (ELPAT) Appendix 4 Environmental Services QA Manual (revision 8) Page E-1 of 2 Effective 11/07/2013 Appendix 4. (continued) Program FIELD NCDENR DWQ Field Parameters Performance Evaluation Samples Sample Types(s) Schedule pH, Conductivity, Total Annually Residual Chlorine Appendix 4 Environmental Services QA Manual (revision 8) Page E-2 of 2 Effective 11/07/2013 Appendix 5. Environmental Services Procedure Numbering System DUKE ENERGY CAROLINAS Procedure Type Number Range Analytical Laboratory General Chemistry 1000 to 1199 Chemistry Sample Preparation 1200 to 1399 Chemistry Analytical Procedures 1400 to 1599 Chemistry Instrumentation 1600 to 2499 Gas Chromatograph 1600 to 1699 Gas Chromatograph/Mass Spectrometer 1700 to 1799 Gel Pack Column 1800 to 1899 Ion Chromatograph 1900 to 1999 Flame and Furnace Atomic Absorption 2000 to 2099 Inductively Coupled Plasma Emission 2100 to 2199 Spectroscopy 2200 to 2299 Carbon Analyzer 2300 to 2399 Auto Analyzer 2400 to 2499 Chemistry Quality Control 2800 to 2849 Chemistry Quality Assurance 2850 to 2899 Coal, Oil, and Gas Analysis 2900 to 2999 Aquatic Ecology Sample Identification and Disposition P-1 to P-99 Reference Resources P-100 to P-199 Laboratory and Field Techniques P-300 to P-699 Field Equipment P-1500 to P-2249 Laboratory Equipment P-2250 to P-2999 Sample Collection and Preservation P-3000 to P-3699 Benthos P-3000 to P-3099 Macrophytes P-3100 to P-3199 Periphyton P-3200 to P-3299 Phytoplankton P-3300 to P-3399 Zooplankton P-3400 to P-3499 Population Parameters P-3500 to P-4199 Benthos P-3500 to P-3699 Macrophytes P-3700 to P-3799 Periphyton P-3800 to P-3899 Phytoplankton P-3900 to P-3999 Zooplankton P-4000 to P-4199 Pigment Analysis P-4200 to P-4499 Metabolism, Productivity P-5100 to P-6099 Physical Procedures P-7000 to P-7999 Light P-7000 to P-7049 Current Velocity P-7050 to P-7099 Sediment P-7100 to P-7199 Lake Morphometry P-7200 to P-7299 Chemical Procedures P-8000 to P-8999 Field Equipment P-9000 to P-9249 Laboratory Equipment P-9250 to P-9499 Statistical Quality Control Procedures P-9500 to P-9999 Appendix 5 Environmental Services QA Manual (revision 8) Page F-1 of 2 Effective 11/07/2013 Appendix 5. (continued) Procedure Type Number Range Asbestos (all rocedures retired-1113012012) QA/QC 6000 to 6019 Equipment, Maintenance, Calibration 6020 to 6029 Bulk Asbestos 6030 to 6069 Fiber Asbestos 6070 to 6099 Microbiology (all procedures retired-1212212006) Sample Collection and General Techniques BACT-0100 to BACT-0199 Media and Reagent Preparation BACT-0200 to BACT-0299 Quantitative Techniques BACT-0300 to BACT-0399 Staining and Biochemical Techniques BACT-0400 to BACT-0499 Quality Control BACT-0500 to BACT-0599 Equipment Operation, Maintenance and Calibration BACT-0600 to BACT-0699 Fish General Techniques FSH-1 to FSH-99 Equipment Procedures FSH-100 to FSH-199 Standard Operating Procedures FSH-200 to FSH-399 Maintenance, Test, and Calibration FSH-400 to FSH-499 Statistical Quality Control FSH-500 to FSH-599 Midwest Environmental Services General Techniques MW-1 to MW-500 Chemical/Physical Storm Water 3000 to 3099 Ground Water 3100 to 3199 Surface Water 3200 to 3299 Soil/Site Assessments 3300 to 3399 Hazardous Waste 3400 to 3499 Ambient Monitoring 7000 to 7999 D UKE ENERGY PROGRESS Procedure Type Number Range Standard Operating Procedures NR-00049 to NR-00500 Standard Forms FRM-00803 to FRM-00874 Appendix 5 Environmental Services QA Manual (revision 8) Page F-2 of 2 Effective 11/07/2013 Appendix 5a. Procedure Coversheet. D UKE ENERGY ENVIRONMENTAL SER VICES Procedure Name: Procedure Number: ❑ Information Use and Procedure revision: ❑ Reference Use Author: Functional Area: Primary Reviewer: Technical/Secondary Reviewer: Functional Area Approval: SDQA Approval: QA Approval: Chemical Hygiene Approval: Manager Approval: _ Next review due: REVIEWS AND APPROVALS Title: Title: Date: Date: Title: Date: Citle: Date: Title: Date: Title: Date: Title: Date: Effective Date: TRAINING AND DEMONSTRATION OF CAPABILITY Initial training required Requalification training required Demonstration of Read only ❑ Read only ❑ Capability required? Read and OJT ❑ Read and OJT ❑ Initial Requal Read and classroom ❑ Read and classroom ❑ Yes ❑ Yes ❑ No ❑ No ❑ Appendix 5a Environmental Services QA Manual (revision 8) Page G-1 of 2 Effective 11/07/2013 This page left blank intentionally. Appendix 5a Environmental Services QA Manual (revision 8) Page G-2 of 2 Effective 11/07/2013 Appendix 6. Report, Publication, or Presentation Review. Section 1. Title: Type report title. Type: Report ❑ Publication ❑ Presentation ❑ Author: Select name., Select name., Select name., Select name. Objective(s): Type report obiective(s). Draft #: 1 Date distributed: Date to be returned: Date actually returned: Select review type. Review: Select name. Approval: (reviewer's signature) Yes❑ Not❑ See comments❑ List of reviewers: Primary: Select name., Select name., Select name., Select name. Secondary: Select name., Select name., Select name., Select name. Management: Select name., Select name., Select name., Select name. Reviewers please summarize your comments below or in an attachment and provide detailed comments in the text. Approval of report and validation of data manipulations are indicated by the above dated reviewer signature/initials, unless indicated otherwise. Return completed forms to authors for filing with the completed chapter or final report. Type comments here. Section 2. This section is to be completed when data will be presented or published outside of Duke Energy. I have evaluated this paper/presentation and determined that the information presented is not in conflict with data contained in Duke Energy Reports or other documents that have been submitted to Federal or State regulatory agencies. The attached Abstract or document outlines the substance of the presentation. This publication / presentation represents an exchange of scientific information. Author: To be completed by author's manager: ❑ Approved ❑ Not Approved Manager: Date: Approval pending additional review by: ❑ Legal ❑ Duke Energy Public Affairs ❑ Director ❑ Data Release Policy ❑ Other (specify) Date: Primary -subject matter experts. Secondary -general knowledge. Management -overall responsibility for final report. t Reviewers, please provide explanation. Authors, subsequent draft is required. Appendix 6 Environmental Services QA Manual (revision 8) Page H-1 of 2 Effective 11 /07/2013 This page left blank intentionally. Appendix 6 Environmental Services QA Manual (revision 8) Page H-2 of 2 Effective 11 /07/2013 Appendix 7. Final Report Approval. "Insert station name" "Insert NPDES No." DUKE ENERGY Environmental Services McGuire Environmental Center 13339 Hagers Ferry Road Huntersville, NC 28078 FINAL REPORT APPROVAL: "Click here and type report title." "Insert month, year" Report date: "Click here and type month, year." Principal Investigators: "Click here and type author names." Our signatures below indicate that we have reviewed and approve the above listed report. Director Signature/date Printed Name Position, Group Phone number Manager Signature/date Printed Name Position, Group Phone number Appendix 7 Environmental Services QA Manual (revision 8) Page I-1 of 2 Effective 11/07/2013 This page left blank intentionally. Appendix 7 Environmental Services QA Manual (revision 8) Page I-2 of 2 Effective 11 /07/2013 Appendix 8. Vault Record Inventory VAULT RECORD INVENTORY LOG -IN INSTRUCTIONS: 1 - Place box on track/shelf designated for owner's group. 2 - List each box number in "Box Number" column. 3 - List owner's name in "Owner Name" column. 4 - List owner's work group in "Owner Work Group" column. 5 - Record Track and Shelf number in "Storage Track/Shelf' column. 6 - List current date in "Date Placed in Vault Storage" column. LOG -OUT INSTRUCTIONS: TO BE USED WHEN DESTROYING OR PERMANENTLY TRANSFERRING RECORDS FROM VAULT. 1 - Record current date. 2 - Record destination (i.e. Corp Records, destroyed, etc.) LOG -IN LOG -OUT Box Number Owner Name Owner Work Group Storage Track/Shelf Date Placed in Vault Storage Date Permanently Removed from Vault Storage Destination Appendix 8 Environmental Services QA Manual (revision 8) Page J-1 of 2 Effective 11/07/2013 This page left blank intentionally Appendix 8 Environmental Services QA Manual (revision 8) Page J-2 of 2 Effective 11/07/2013 Appendix 9. Vault Check -Out Log VAULT CHECKOUT -LOG CHECK-OUT INSTRUCTIONS: CHECK -IN INSTRUCTIONS: 1 - List or describe record borrowed in "Item Borrowed" column. 1 - Return each item to proper storage box. 2 - List storage box of item borrowed in "Box Number" column. 2 - Write current date in "Date Returned" column. 3 - Write the current date in "Date Borrowed" column. 3 - Sign your name in "Signature" column. 4 - Sign your name in "Signature" column. CHECK-OUT CHECK -IN Item Borrowed Box Number Date Borrowed Signature Date Returned Signature Appendix 9 Environmental Services QA Manual (revision 8) Page K-1 of 2 Effective 11/07/2013 This page left blank intentionally Appendix 9 Environmental Services QA Manual (revision 8) Page K-2 of 2 Effective 11/07/2013 Appendix 10. Storage Box Contents STORAGE BOX CONTENTS INSTRUCTIONS: TO BE COMPLETED ANY TIME RECORDS ARE PLACED IN STORAGE BOXES AND TRANSFERRED TO VAULT STORAGE OR CORPORATE RECORDS. 1 - Complete form. 2 - Make 3 copies of form. 3 - Place 1 copy in front of records inside storage box. 4 - Place 1 copy in your personal files. 5 - Give original and 1 copy to your Quality Assurance Officer for filing with other quality control documents. Box Number Record Description Record Number Retention Value Owner Name and Group Old Storage Location New Storage Location Date Moved Appendix 10 Environmental Services QA Manual (revision 8) Page L-1 of 2 Effective 11/07/2013 This page left blank intentionally Appendix 10 Environmental Services QA Manual (revision 8) Page L-2 of 2 Effective 11/07/2013 Appendix II. Additional Information for Midwest Water Resources Quality Assurance Manual DUKE ENERGY. Environmental Services Water Resources - Midwest WP994 1000 East Main Street Plainfield, IN 46168 Appendix 11 Environmental Services QA Manual (revision 8) Page M-1 of 10 Effective 11/07/2013 This page left blank intentionally. Appendix 11 Environmental Services QA Manual (revision 8) Page M-2 of 10 Effective 11 /07/2013 1. INTRODUCTION Midwest Water Resources shall adhere to the Environmental Services Quality Assurance (QA) Program manual as written. This appendix denotes instances where specific exemptions apply or guidance is unique to only Midwest Water Resources. Questions or comments concerning the content of this appendix should be referred to the Midwest Water Resources QA Officer. 2. SCOPE This document defines an overall QA Program for Midwest Water Resources. The QA Program outlines all quality assurance requirements common to the environmental functions in the Midwest. This QA Program shall be effective immediately upon approval by the Manager of Water Resources. 3. CODE OF ETHICS Midwest Water Resources is committed to ensuring the integrity of data and meeting client/customer quality. We pledge to manage our business according to Duke Energy policies, including the Code of Business Ethics. 4. QUALITY ASSURANCE RESPONSIBILITIES AND ORGANIZATION Duke Energy's Midwest Water Resources is part of Environmental Services (Figure 4-1). These functions are led by the manager of Water Resources. The manager is responsible for the overall management, administration, and technical direction of work. This includes staffing, budgeting, and strategic planning. Midwest Water Resources shall appoint a Quality Assurance Officer for their functions. Quality Assurance Officer's responsibilities include overseeing the QA/QC programs, administering inter -laboratory proficiency testing and round robin programs, acting as liaison with certifying authorities, performing periodic system audits, reviewing the QA manual with updates as necessary, reporting on performance to managers, and coordinating transfer of records. Appendix 11 Environmental Services QA Manual (revision 8) Page M-3 of 10 Effective 11/07/2013 The QA Officer's responsibilities include: • Oversee the Midwest Water Resources QA Program. • Coordinate and serve as editorial lead for annual review of the Midwest Water Resources Appendix of the Environmental Services QA Manual. • Serve as lead audit facilitator for internal and external audits involving more than one section. • Prepare audit responses. • Participate as requested and available in QA/QC initiatives. • Provide assistance in the maintenance and operation of QA databases. • Discuss quality issues with the manager at least annually. Each Midwest Water Resources member has the authority and responsibility to stop work if the quality of any work is in question. All members of Midwest Water Resources are responsible for reporting quality problems by implementing the Corrective Action process (Chapter 19). Figure 4-1. Organizational structure. Chairman, Pres & CEO Duke Energy Appendix 11 Environmental Services QA Manual (revision 8) Page M-4 of 10 Effective 11/07/2013 5. PROJECTS Midwest Water Resources project requirements shall be documented and reviewed at least annually or as required by project leaders, regulatory agencies and customer expectations and maintained in a central location. Recommended project documentation may include the following: • Project name - Project title. • Program - Project team program (Example: Fisheries). • Project description - Brief description of work. • Project start date - Beginning date. • Project end date - End date (if known) or Ongoing. • Project review date - Date of project documentation review (at least annually) for ongoing projects that extend beyond one year. • Customer - Facility/organization sponsoring project. • Contact - Customer contact. • Project leader — Water Resources subject matter expert responsible for project leadership and direction. • Project coordinator - Liaison between subject matter experts, station contacts, and regulatory authorities. May be a member of another Environmental Services section or a different Duke Energy Department. • Budget accounting information - Budgetary information for project billing. • Scheduling - Project schedule information such as sample locations, frequency of sampling, sample analysis schedule, reporting schedule. • Procedures - Operation, maintenance, calibration, QA/QC and other procedure requirements. • Project responsibilities - Identifies project lead and field crews. • Project file storage location - Identifies physical location of project records, documentation, etc. • Other project requirements - Additional requirements such as data management, data analysis, lab equipment and instrumentation. 6. CERTIFICATIONS AND INTER -LABORATORY QUALITY ASSURANCE PROGRAMS The states in the Midwest service territory do not currently require certification of biological laboratories sampling in their states. Midwest Water Resources is presently permitted to scientifically collect flora and fauna in the following states: • Indiana Department of Natural Resources Scientific Purposes License; Parameters: Aquatic Population Survey — Fish, Macroinvertebrates, and Mussels Appendix 11 Environmental Services QA Manual (revision 8) Page M-5 of 10 Effective 11/07/2013 • Kentucky Department of Fish and Wildlife Resources Scientific Wildlife Collecting Permit Parameters: Aquatic Population Survey- Fish, Macroinvertebrates, Mussels 7. WORK PLACE To establish a working environment that encourages quality performance from personnel, Midwest Water Resources Management shall ensure that the following are provided and maintained in the Water Resources -occupied portions of the Plainfield facility: • Adequate and acceptable facilities such as lighting, ventilation, temperature, and humidity. These facilities shall be maintained to the levels described in appropriate industry standards [for example, American Society of Heating, Refrigerating and Air - Conditioning Engineers (ASHRAE) standards]. • Adequate and acceptable utility service such as voltage control, air, water, and vacuum. • Adequate and acceptable general laboratory facilities and equipment such as chemical fume hoods, biological safety cabinets, sinks, bench areas, and refrigerators. Chemical fume hoods and biological safety cabinets shall be routinely monitored and calibrated as necessary for proper function, air flow and personal protection of laboratory workers. • All areas where chemical wastes are generated shall make provisions for disposal of such wastes. • Midwest Water Resources procedures shall specify when safety glasses, lab coats, gloves and other specific PPE are required in their laboratories. For additional information please review the following documents: Duke Energy Safe Work Practices Manual Plainfield Biological Lab Chemical Hygiene Plan 8. HOUSEKEEPING Housekeeping is the visual condition of the equipment, structures, components and areas that reflect organization, cleanliness, and safety. All housekeeping activities must be in conformance with the Plainfield Chemical Hygiene Plan. Housekeeping includes all activities related to the control of cleanliness and to the reduction and elimination of trash, dust, dirt, and work related debris. Appendix 11 Environmental Services QA Manual (revision 8) Page M-6 of 10 Effective 11/07/2013 9. INSTRUMENTATION AND EQUIPMENT A. Maintenance No additional information. B. Maintenance Records No additional information. C. Calibrations 1. Balance Calibrations A certified calibration laboratory or manufacturer will verify balance calibrations at least annually, or as recommended by the manufacturer. Calibration check requirements of this section do not apply to portable balances (field balances). Guidance for calibration checks of these balances will be addressed in Midwest Water Resources procedures. 2. Temperature Device Calibrations All thermometers will be checked against a NIST-traceable thermometer. The calibration frequency will not exceed one year. D. Equipment Control No additional information. E. Records No additional information. F. Out -Of -Tolerance No additional information. 10. SAMPLE CONTROL No additional information. Appendix 11 Environmental Services QA Manual (revision 8) Page M-7 of 10 Effective 11 /07/2013 11. REAGENTS AND CHEMICALS All reagents, solutions and standards used by Midwest Water Resources shall be stored and handled in accordance with the Plainfield Chemical Hygiene Plan. 12. PROCEDURES Midwest Water Resources procedure numbers shall be preceded by the letters "MW" followed by a dash and a number designation from 1 to 500. 13. TRAINING The Midwest QA Officer shall provide initial training on the QA Program for new Midwest Water Resources employees. In addition, the Midwest QA Officer shall communicate programmatic changes to all Midwest Water Resources employees. 14. LABORATORY QUALITY CONTROL Midwest Water Resources follows quality control practices that are specified in Midwest procedures. 15. QUALITY ASSURANCE PROGRAM REVIEW No additional information. 16. REPORT REVIEW AND APPROVAL No additional information. 17. VENDOR QUALIFICATION No additional information. 18. DATA MANAGEMENT No additional information. Appendix 11 Environmental Services QA Manual (revision 8) Page M-8 of 10 Effective 11 /07/2013 19. CORRECTIVE ACTION No additional information. 20. AUDITS No additional information. 21. ACRONYMS AND DEFINITIONS No additional information. 22. REFERENCES No additional information. Appendix 11 Environmental Services QA Manual (revision 8) Page M-9 of 10 Effective 11 /07/2013 This page left blank intentionally. Appendix 11 Environmental Services QA Manual (revision 8) Page M-10 of 10 Effective 11 /07/2013 Appendix 12. Additional Information for Duke Energy Progress Quality Assurance Manual DUKE c ENERGY PROGRESS Environmental Services Duke Energy Progress Harris Energy and Environmental Center 3932 New Hill Holleman Rd. New Hill, NC 27562 Appendix 12 Environmental Services QA Manual (revision 8) Page N-1 of 10 Effective 11/07/2013 This page left blank intentionally. Appendix 12 Environmental Services QA Manual (revision 8) Page N-2 of 10 Effective 11/07/2013 1. INTRODUCTION Duke Energy Progress (DEP) shall adhere to the Environmental Services Quality Assurance Manual (ESQAM) as written. This appendix outlines the integration of the Duke Energy Progress Quality Assurance Manual with the ESQAM. This appendix further denotes instances where specific exemptions apply (e.g., DEP does not conduct nuclear safety related work) or guidance that is unique to only Duke Energy Progress. Questions or comments concerning the content of this appendix should be referred to the DEP QA Officer. 2. SCOPE This document defines an overall QA Program for DEP. The QA Program outlines all quality assurance requirements common to the environmental functions for DEP. This QA Program shall be effective immediately upon approval by the Managers of Water and Natural Resources. 3. CODE OF ETHICS DEP is committed to ensuring the integrity of data and meeting client/customer quality. We pledge to manage our business according to Duke Energy policies, including the Code of Business Ethics. 4. QUALITY ASSURANCE RESPONSIBILITIES AND ORGANIZATION DEP is part of Environmental Services (Figure 4-1). These functions are led by the managers of Water Resources and Natural Resources. The managers are responsible for the overall management, administration, and technical direction of work. This includes staffing, budgeting, and strategic planning. DEP shall appoint a Quality Assurance Officer for these functions. Quality Assurance Officer's responsibilities include overseeing the QA/QC programs, administering inter - laboratory proficiency testing and round robin programs, acting as liaison with certifying authorities, performing periodic system audits, reviewing the QA manual with updates as necessary and coordinating transfer of records. The Environmental Services QA Officer's responsibilities include: • Oversee the DEP QA Program. Appendix 12 Environmental Services QA Manual (revision 8) Page N-3 of 10 Effective 11/07/2013 • Coordinate and serve as editorial lead for annual review of the DEP Appendix (app. 12) of the Environmental Services QA Manual. • Serve as lead audit facilitator for internal and external audits involving more than one section. • Prepare audit responses. • Participate as requested and available in QA/QC initiatives. • Provide assistance in the maintenance and operation of QA databases. • Discuss quality issues with the manager at least annually. All Environmental Services personnel have the authority and responsibility to stop work if the quality of any work is in question. All members of Environmental Services are responsible for reporting quality problems by implementing the Corrective Action process (Chapter 19 of the ESQAM). Figure 4-1. Organizational structure. Chairman, President, and CEO Duke Energy Exec VP & COO Regulated Utilities Operations Senior Vice President Environmental, Health, and Safety Vice President, Environment Services Director, Water/Natural Resources Manager, Water Resources DEP QA Officer Manager, Natural Resources Appendix 12 Environmental Services QA Manual (revision 8) Page N-4 of 10 Effective 11/07/2013 5. PROJECTS DEP project requirements shall be documented and reviewed at least annually or as required by project leaders, regulatory agencies and customer expectations and maintained in a central location. Recommended project documentation may include the following: • Project name - Project title. • Program - Project team program (Example: Fisheries). • Project description - Brief description of work. • Project start date - Beginning date. • Project end date - End date (if known) or Ongoing. • Project review date - Date of project documentation review (at least annually) for ongoing projects that extend beyond one year. • Customer - Facility/organization sponsoring project. • Contact - Customer contact. • Project leader — DEP subject matter expert responsible for project leadership and direction. • Project coordinator - Liaison between subject matter experts, station contacts, and regulatory authorities. May be a member of another Environmental Services section or a different Duke Energy Department. • Budget accounting information - Budgetary information for project billing. • Scheduling - Project schedule information such as sample locations, frequency of sampling, sample analysis schedule, reporting schedule. • Procedures - Operation, maintenance, calibration, QA/QC and other procedure requirements. • Project responsibilities - Identifies project lead and field crews. • Project file storage location - Identifies physical location of project records, documentation, etc. • Other project requirements - Additional requirements such as data management, data analysis, lab equipment and instrumentation. Additionally DEP submits annual study plans to appropriate regulatory agencies. 6. CERTIFICATIONS AND INTER -LABORATORY QUALITY ASSURANCE PROGRAMS DEP currently holds certifications granted by the following state agencies: • North Carolina Division of Water Quality; Parameters: Aquatic Population Survey — Fish, Macroinvertebrates, and Aquatic Vegetation Appendix 12 Environmental Services QA Manual (revision 8) Page N-5 of 10 Effective 11/07/2013 • South Carolina Department of Health and Environmental Control Parameters: Aquatic Population Survey- Fish, Macroinvertebrates, Aquatic Vegetation Scientific Collection permits are obtained and renewed annually for all ES personnel conducting DEP Biology Program activities. 7. WORK PLACE To establish a working environment that encourages quality performance from personnel, DEP management shall ensure that the following are provided and maintained in the DEP facilities: • Adequate and acceptable facilities such as lighting, ventilation, temperature, and humidity. These facilities shall be maintained to the levels described in appropriate industry standards [for example, American Society of Heating, Refrigerating and Air - Conditioning Engineers (ASHRAE) standards]. • Adequate and acceptable utility service such as voltage control, air, water, and vacuum. • Adequate and acceptable general laboratory facilities and equipment such as chemical fume hoods, biological safety cabinets, sinks, bench areas, and refrigerators. Chemical fume hoods and biological safety cabinets shall be routinely monitored and calibrated as necessary for proper function, air flow and personal protection of laboratory workers. • All areas where chemical wastes are generated shall make provisions for disposal of such wastes. • DEP procedures shall specify when safety glasses, lab coats, gloves and other specific PPE are required in their laboratories. For additional information please review the following documents: Duke Energy Safe Work Practices Manual Harris Energy and Environmental Center Chemical Hygiene Plan 8. HOUSEKEEPING Housekeeping is the visual condition of the equipment, structures, components and areas that reflect organization, cleanliness, and safety. All housekeeping activities must be in conformance with the Harris Energy and Environmental Center Chemical Hygiene Plan. Housekeeping includes all activities related to the control of cleanliness and to the reduction and elimination of trash, dust, dirt, and work related debris. Appendix 12 Environmental Services QA Manual (revision 8) Page N-6 of 10 Effective 11/07/2013 9. INSTRUMENTATION AND EQUIPMENT A. Maintenance DEP instrumentation and equipment maintenance is governed by the appropriate DEP Biology Program procedures. B. Maintenance Records DEP maintenance records are governed by the appropriate DEP Biology Program procedures. C. Calibrations 1. Balance Calibrations DEP balance calibrations/checks are governed by the appropriate DEP Biology Program procedures. 2. Temperature Device Calibrations DEP temperature device calibrations/checks are governed by the appropriate DEP Biology Program procedures. D. Equipment Control DEP equipment control is governed by the appropriate DEP Biology Program procedures. E. Records DEP records retention is governed by the appropriate DEP Biology Program procedures. F. Out -Of -Tolerance DEP equipment found to be out -of -tolerance is addressed by the appropriate DEP Biology Program procedures. 10. SAMPLE CONTROL DEP sample control is governed by the appropriate DEP Biology Program procedures. Appendix 12 Environmental Services QA Manual (revision 8) Page N-7 of 10 Effective 11/07/2013 11. REAGENTS AND CHEMICALS All reagents, solutions and standards used by DEP shall be stored and handled in accordance with the Harris Energy and Environmental Center Chemical Hygiene Plan. 12. PROCEDURES DEP procedure numbers shall be preceded by the letters "NR" followed by a dash and a number designation from 1 to 500. 13. TRAINING No additional information. 14. LABORATORY QUALITY CONTROL DEP follows quality control practices that are specified in DEP Biology Program procedures. 15. QUALITY ASSURANCE PROGRAM REVIEW DEP Biology Program Quality Assurance is under the purview of the appropriate DEP Biology Program procedures and the ESQAM. 16. REPORT REVIEW AND APPROVAL No additional information. 17. VENDOR QUALIFICATION No additional information. 18. DATA MANAGEMENT DEP data management is governed by the appropriate DEP Biology Program procedures. Appendix 12 Environmental Services QA Manual (revision 8) Page N-8 of 10 Effective 11/07/2013 19. CORRECTIVE ACTION DEP corrective action is governed by the appropriate DEP Biology Program procedures. 20. AUDITS DEP audits are governed by the appropriate DEP Biology Program procedures. 21. ACRONYMS AND DEFINITIONS DEP acronyms and definitions are defined by appropriate DEP Biology Program procedures and the ESQAM. 22. REFERENCES DEP references are defined by appropriate DEP Biology Program procedures, the ESQAM, laboratory certification requirements and best professional judgment. Appendix 12 Environmental Services QA Manual (revision 8) Page N-9 of 10 Effective 11/07/2013 This page left blank intentionally. Appendix 12 Environmental Services QA Manual (revision 8) Page N-10 of 10 Effective 11 /07/2013 Appendix 13. Additional Information for Duke Energy Florida Quality Assurance Manual DUKE ENERGY Environmental Services Duke Energy Florida St. Petersburg Office Tower Site 299 1st Ave. North St. Petersburg, FL 33705 Appendix 13 Environmental Services QA Manual (revision 8) Page O-1 of 4 Effective 11/07/2013 This page left blank intentionally. Appendix 13 Environmental Services QA Manual (revision 8) Page 0-2 of 4 Effective 11 /07/2013 Additional Information for Duke Energy Florida Quality Assurance Manual This document defines the unique processes utilized by Duke Energy Florida Water Resources to ensure the quality of environmental products and services. This appendix outlines quality assurance (QA) requirements that assure chemical, physical, biological, microbiological, and toxicological data are appropriate, reliable, and are collected and analyzed by scientifically sound procedures. The Florida Department of Environmental Protection (FDEP) has statutory authority to establish, by rule, the appropriate quality assurance requirements for environmental data submitted to the department. The FDEP has adopted and enforces rules for data quality objectives, requirements for training of laboratory and field staff, sample collection methodology, proficiency testing, and audits of laboratory and field sampling activities. It is the policy of the FDEP that all environmental programs conducted as requirements of the FDEP and/or the Environmental Protection Agency (EPA) establish and implement effective quality assurance procedures to support the scientific and legal defensibility of those programs. Key components of the system are the quality assurance policies and procedures that describe the processes for ensuring that work, products or services satisfy stated expectations or specifications. Quality assurance requirements are specified in the FDEP's Quality Assurance Rule, Chapter 62-160, F.A.C. Vendors performing scientific or analytical work for Water Resources Florida are required to meet, at a minimum, all field and laboratory quality assurance, methodological and reporting requirements of the FDEP. Detailed FDEP-approved procedures exist for most aspects of monitoring. Any proposed alternative field procedure or deviation from approved procedures must be approved by FDEP prior to use. For each project, Florida Water Resources requires that specific QA project plans be prepared and incorporated into vendor contract agreements. These QA project plans are prepared in accordance with requirements specified in the FDEP Quality Assurance Rule, and apply to all programs, projects, studies, or other activities that are required by the agencies and involve the measurement, use or submission of environmental data or reports to the agencies. These include, but are not limited to: field activities (sample collection, sample preservation, field measurements, and site evaluations); sample handling, storage and/or transport; laboratory activities (sample receipt, analysis, data review and data validation); data review, summaries Appendix 13 Environmental Services QA Manual (revision 8) Page 0-3 of 4 Effective 11/07/2013 or data presentation activities; and all activities that impact data quality (sample containers, instrument calibration, reagents, standards, etc.). Duke Energy's Florida Water Resources is part of Environmental Services. These functions are led by the manager of Water Resources. The manager is responsible for the overall management, administration, and technical direction of work. This includes staffing, budgeting, and strategic planning. Florida Water Resources subject matter experts (SME) are responsible for ensuring that appropriate QA programs and procedures are incorporated into vendor contractual agreements, technical specifications, and work plans. The SME directs, monitors and coordinates field and laboratory activities conducted by vendors on behalf of Florida Water Resources, and reviews reports and data submissions to assure that QA obligations are met and environmental data generated is adequate to support scientifically valid environmental decisions. Appendix 13 Environmental Services QA Manual (revision 8) Page 0-4 of 4 Effective 11/07/2013 Groundwater and Surface Water Effectiveness Monitoring Plan August 2020 L.V. Sutton Energy Complex SynTerra ATTACHMENT D SURFACE WATER EVALUATION PLAN - APRIL 25, 2018 AND NCDEQ APPROVAL LETTER - MAY 10, 2018 TECHNICAL MEMORANDUM Date: April 25, 2018 To: John Toepfer (Duke Energy) Cc: Kathy Webb (SynTerra) From: Perry Waldrep Ay�� Subject: Surface Water Evaluation Plan to Assess 15A NCAC 2B Compliance - L.V. Sutton Energy Complex Duke Energy Progress, LLC (Duke Energy) owns and operates the L.V. Sutton Energy Complex (Site) located on approximately 3,300 acres near Wilmington, North Carolina. The Site is located along the east bank of the Cape Fear River northwest of Wilmington and west of US Highway 421. Coal combustion residuals (CCR) was originally stored on -site in the 'former ash disposal area (FADA)', also known as the 'lay of land area, then in the 1971 ash basin (old ash basin), and finally the 1984 ash basin (new ash basin). These ash storage areas are referred to as the ash management area. The Site ceased burning coal in November 2013 and switched to natural gas for electricity generation, thus the facility no longer generates coal ash. Removal of ash from the 1971 and 1984 basins is ongoing. Regulatory Background In 2014, The North Carolina General Assembly passed the Coal Ash Management Act (CAMA). CAMA required owners of a CCR surface impoundment to conduct detailed assessment of site groundwater within and around the CCR surface impoundment. Comprehensive Site Assessment (CSA) activities were conducted for the Site from 2015 through submittal of the CSA Update in January 2018. In addition to CAMA, potential corrective action alternatives are to be in accordance with regulation 15A NCAC 02L .0106 (k)(5), (1)(6), and (m)(2)(c) which includes the following requirement: ".., if the contaminant plume is expected to intercept surface waters, groundwater discharge will not possess contaminant concentrations that would result in violations of standards for surface waters contained in 15A NCAC 2B .0200" The work plan is prepared following direction included in the North Carolina Department of Environmental Quality (NC DEQ) Division of Water Resources (DWR) P:\Duke Energy Progress.1026\108. Sutton Ash Basin GW Assessment Plan\51.EHS-Additional Surface Water Sampling\ Work Plan\ Sutton Groundwater -Surface Water Assessment Tech Memo.docx Surface Water Sampling Plan to Assess 15A NCAC 213 Compliance April 2018 L.V. Sutton Energy Complex Page 2 of 5 Internal Technical Guidance: Evaluating Impacts to Surface Water from Discharging Groundwater Plumes - October 31, 2017 (Guidance). The Guidance and this work plan are designed to evaluate site conditions to determine the appropriateness of groundwater corrective action alternatives. This work plan does not supersede any surface water sampling guidance or procedures developed for water quality assessment or NPDES program requirements. Purpose of Proposed Plan Groundwater from the ash management areas flows toward the cooling pond (Sutton Lake) which lies adjacent to the ash management area on the northwest, west, and southwest sides. The Cape Fear River lies directly west of Sutton Lake and flows roughly north to south. The surface water classification for Sutton Lake and the Cape Fear River is Class C, Swamp Waters. The purpose of this work plan is to characterize the groundwater to surface water pathway at the Sutton Plant as necessary to: 0' Determine whether corrective action alternatives under 15A NCAC 02L .0106 (k), (1), and (m) may be pursued by evaluating whether 15A NCAC 02B .0200 (02B) regulatory standards are exceeded in surface water as the result of groundwater discharge, and 0' Locate strategic groundwater and surface water sampling locations to support site assessment and remedial action performance monitoring networks. Proposed Plan According to the Guidance, "To meet requirements for a Comprehensive Site Assessment (CSA) in 15A NCAC 02L .0106(g), samples must be collected in a manner that demonstrates groundwater discharges intercepting surface water do not adversely affect identified receptors. The CSA must identify the area(s) of groundwater contamination that currently, or are predicted to, intercept surface water." The proposed sample locations were identified in accordance with sample location criteria provided in the Guidance including; groundwater flow direction; known extent of groundwater impacts relative to the water bodies; and NPDES permit effluent sample locations. Sample locations to assess the groundwater to surface water pathway are proposed along the eastern edge of Sutton Lake at areas where groundwater assessment indicates a potential for groundwater influence (Figure 1). In addition, three sample locations are P:\Duke Energy Progress.1026\108. Sutton Ash Basin GW Assessment Plan\51.EHS-Additional Surface Water Sampling\ Work Plan\ Sutton Groundwater -Surface Water Assessment Tech Memo.docx Surface Water Sampling Plan to Assess 15A NCAC 213 Compliance April 2018 L.V. Sutton Energy Complex Page 3 of 5 proposed within the main body of Sutton Lake (Figure 1). Up to 13 assessment sample locations are proposed. Surface water and sediment will be sampled at each location. The sampling will be conducted in a phased manner. Additional sampling and analysis may be conducted to further characterize the area depending on the analytical results. Should the initial investigation involve supplemental sampling and analysis, a supplemental work plan will be prepared and submitted by Duke Energy for NC DEQ DWR consideration and approval. Background Water Quality Sample Locations The following previously sampled location is considered to represent background surface water quality conditions at the Site: 10' SW-CFUP (upstream location in the Cape Fear River) In addition to the previous background location, two additional background locations will be sampled as part of the present work plan. The additional background locations are indicated on Figure 1(located in the Cape Fear River). Methods and Analytical Requirements Due to safe access limitations along the active ash removal activities in the 1971 basin, samples in the immediate vicinity (SW-5 through SW-7) will be collected by boat following Duke Energy approved float plans. The samples located in the main body of Sutton Lake (SW-11 through SW-13) will be sampled by boat. The samples located at the edge of the FADA (SW-8 through SW-10) also need to be sampled by boat due to the presence of a concrete apron at the edge of Sutton Lake. The remaining samples in Sutton Lake will be collected from the bank. Samples in the Cape Fear River (SW-14 and SW-15) will also be collected by boat due to limited bank access. The samples will be collected in general accordance with the Guidance and collected at least two feet from the edge of the bank. Sediment samples will be collected at the bank consistent with the water sample location. Samples will be collected and analyzed for the constituents and parameters listed in Table 1(Surface Water) and Table 2 (Sediment), with surface water samples collected and analyzed for total and dissolved concentrations for the indicated constituents and sediment samples analyzed for total concentrations. P:\Duke Energy Progress.1026\108. Sutton Ash Basin GW Assessment Plan\51.EHS-Additional Surface Water Sampling\ Work Plan\ Sutton Groundwater -Surface Water Assessment Tech Memo.docx Surface Water Sampling Plan to Assess 15A NCAC 213 Compliance April 2018 L.V. Sutton Energy Complex Page 4 of 5 Sample collection methods are summarized as follows: 1. Samples are proposed to be collected at the locations shown on Figure 1 using the collection methods used in the CSA sampling and in general accordance with the Guidance. 2. Sample collection is planned at low or base flow conditions to the maximum extent possible and at least five days after a previous rain event of any magnitude. Duke will contact DEQ WRO if these criteria become difficult to meet within a month of plan approval based on weather conditions. 3. Locations would be sampled to allow an assessment of 15A NCAC 02B compliance. 15A NCAC 02B .0211 (11) (e) states: "Compliance with acute instream metals standards shall only be evaluated using an average of two or more samples collected within one hour. Compliance with chronic instream metals standards shall only be evaluated using an average of a minimum of four samples taken on consecutive days, or as a 96-hour average". At each location, two surface water samples would be collected within one hour (for acute evaluation) and the remaining two surface water samples may be collected any time within the following 95 hours. The average of the four events will be used for the chronic evaluation. 4. The four events will be sampled from the same physical locations. GPS coordinates will be recorded and flags or stakes will be placed at each location in case additional sampling is needed. Reporting A report including the following components will be prepared for submittal to DEQ: 1. The following summary tables of laboratory analytical results will be included. • Surface water sample results with comparison to surface water standards (15A NCAC 02B Freshwater/water Supply, Human Health and EPA National Recommended Water Quality Criteria (NRWQC)). Sediment sampling results with comparison to the NC DEQ Protection of Groundwater Preliminary Soil Remediation Goals (PSRGs). • 15t quarter 2018 Interim Monitoring Plan (IMP) groundwater monitoring results or more recent results as available and validated for inclusion. Groundwater monitoring results will be presented with P:\Duke Energy Progress.1026\108. Sutton Ash Basin GW Assessment Plan\51.EHS-Additional Surface Water Sampling\ Work Plan\ Sutton Groundwater -Surface Water Assessment Tech Memo.docx Surface Water Sampling Plan to Assess 15A NCAC 213 Compliance April 2018 L.V. Sutton Energy Complex Page 5 of 5 comparison to the appropriate groundwater standard or IMAC (15A NCAC 02L). 2. List of other parameters sampled including temperature and specific conductivity values in both surface water and groundwater, as applicable for monitoring wells near surface water sample locations. 3. The latitude and longitude for each sample location as collected with handheld GPS device will be included in the results table. 4. Previous sample events (historic and new) for the respective locations in the results table and with date of sample event. 5. Indication of antecedent rainfall (5-day and 48-hour) for the sampling. 6. A single high resolution, large scale map showing: i. Surface water sample locations and associated surface water standards exceedances at each location, ii. All permitted discharge locations, iii. All shallow monitoring well locations and the most recent leading -edge constituent value for each location, and iv. Identified or proposed jurisdictional waters (proposed jurisdictional waters means waters that have been identified as potential jurisdictional waters however the determination process has not been completed). Schedule The sample collection schedule will be dependent on approval of the proposed plan, and weather (rainfall). Once the plan is approved, SynTerra will schedule the sampling and the DEQ WRO will be notified of the schedule. The report will be submitted to DEQ within approximately 45 days after the laboratory results (surface water, sediment, and groundwater) are validated. ATTACHMENTS: Figure 1: Proposed Surface Water Sample Locations Table 1: Surface Water Analytical Methods Table 2: Sediment Analytical Methods P:\Duke Energy Progress.1026\108. Sutton Ash Basin GW Assessment Plan\51.EHS-Additional Surface Water Sampling\ Work Plan\ Sutton Groundwater -Surface Water Assessment Tech Memo.docx Surface Water Sampling Plan to Assess 15A NCAC 2B Compliance April 2018 L.V. Sutton Energy Complex ATTACHMENTS P:\Duke Energy Progress.1026\108. Sutton Ash Basin GW Assessment Plan\51.EHS-Additional Surface Water Sampling\ Work Plan\ Sutton Groundwater -Surface Water Assessment Tech Memo.docx f ` i,&'e, NOTES: AERIAL PHOTOGRAPHY OBTAINED FROM USDA FSA NAIP. DATED 05/23/2014. 0 LEGEND PROPOSED SURFACE WATER SAMPLE LOCATION SOIL SAMPLING LOCATION Q GROUNDWATER SAMPLING LOCATION / SURFACE WATER AND SEDIMENT SAMPLE LOCATION • ABANDONED WELL SAMPLING LOCATION AREA OF CONCENTRATION IN GROUNDWATER ABOVE NC21- FOR BORON, ARSENIC, AND SELENIUM n ASH BASIN WASTE BOUNDARY Q FADA BOUNDARY Q ASH BASIN COMPLIANCE BOUNDARY ■ ■ DUKE ENERGY PROGRESS SUTTON ■ IIIIIIII1IPLANT SITE BOUNDARY DIRECTION OF WATER FLOW PARCEL BOUNDARY WAS OBTAINED FROM THE NC CENTER FOR GEOGRAPHIC INFORMATION AND ANALYSIS, AT (http://services.noonemap.gov/) DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE PLANE COORDINATE SYSTEM FIPS 3200 (NAD83). r MW-OS�IEIREIRE ' -10 PZ-10SID AW 01B1C S-01 OLD WELL MW-27BIC ♦` 7`� ^ MW-11 SMW-0481C MW-36BIC GWPZ-01A/B O MWJSB/C� AW-02B/C/D !' ` 1. M��WEIL2 A GWPZ-02A1B U � MWJ4B/C •� -' AW -0381C AW-07RD MW-31BIC MW-31RB/RC # AW-07D SMW-0581C `� ♦ 5-12 MW-24R8IRC \ � MW-2481C GWPZ-03N8 ♦� `l'" 1- _ 1984 ASH BMW-06B/G/D BASIN (LINED) AW-068181E AW-O6R8IRDIRE MW-12 MW"izR $-02 WELL1&2 1984 ASH 7w-2o2 O BASIN (LINED) $MW-0181C ABMW-0151D TW-132 0 GWPZ-O4A18 (J �'.', MW-238lclolE : Al- TW-136 MW-IAP-iD � _ SW-7 971 ASH PZ-1971 AW -048IC _ 1A • : BASIN O Tw-ua6 Mw-zze/c i smw-0ze/c . - rs?i . 1983 MW-13ID EXTENSION MW-18 ` AW-OseICIDIE Mw i9 $MW-0381C MW-32C ` MWBAY 2 -17 FORMERASH '� Mw-z1c s-06 s-m s-1e SW-13 ' I DISPOSAL MW-33C I AREA Mw-14 Mw-z68laT s-v j �/ \ ABMW-02SID`-L098 421-WELL4 421-WELL3 MW-161D ♦ LIP— TW-L024 MW-15/D AW-0981cID -' MENall ♦ ♦1� PE -SW -OS Nowak_.. PE-$W-068 ■■_II-I� i ' PE-$W-O6D 0�� MW-041-B ''" OL Mw-378/c/cD/D/E i 1�vlp synTem 700 350 0 700 1,400 GRAPHIC SCALE IN FEET 148 RIVER STREET, SUITE 220 GREENVILLE, SOUTH CAROLINA 29601 PHONE 864-421-9999 DRAWN BY: K. KING DATE: 04/24/2018 CHECKED BY: B. WYLIE PROJECT MANAGER: P. WALDREP FIGURE 1 PROPOSED SURFACE WATER SAMPLE LOCATIONS L.V. SUTTON ENERGY COMPLEX DUKE ENERGY PROGRESS, LLC WILMINGTON, NORTH CAROLINA TABLE 1 SURFACE WATER ANALYTICAL METHODS L.V. SUTTON ENERGY COMPLEX DUKE ENERGY PROGRESS, WILMINGTON, NC rPARAMETER I RL JUNITS IMETHOD FIELD PARAMETERS pH NA SU Field Water Quality Meter Specific Conductance NA µS/cm Field Water Quality Meter Temperature NA oC Field Water Quality Meter Dissolved Oxygen NA mg/L Field Water Quality Meter Turbidity NA NTU Field Water Quality Meter INORGANICS (total and dissolved) Aluminum 0.005 mg/L EPA 200.7 or 6010C Antimony 0.001 mg/L EPA 200.8 or 6020A Arsenic 0.001 mg/L EPA 200.8 or 602OA Barium 0.005 mg/L EPA 200.7 or 6010C Beryllium 1 ug/l EPA 200.8 or 6020A Boron 0.05 mg/L EPA 200.7 or 6010C Cadmium 0.1 ug/l EPA 200.8 or 6020A Chromium 0.001 mg/L EPA 200.8 or 6020A Cobalt 0.001 mg/L EPA 200.8 or 6020A Copper 0.001 mg/L EPA 200.8 or 602OA Hexavalent Chromium 0.00003 mg/L EPA 218.7 Iron 0.01 mg/L EPA 200.7 or 6010C Lead 0.001 mg/L EPA 200.8 or 6020A Manganese 0.005 mg/L EPA 200.7 or 6010C Mercury 0.00005 mg/L EPA 245.1 Molybdenum 0.001 mg/L EPA 200.8 or 6020A Nickel 0.001 mg/L EPA 200.8 or 6020A Selenium 0.001 mg/L EPA 200.8 or 6020A Silver 0.3 uq/1 EPA 200.8 or 602OA Strontium 0.005 mg/L EPA 200.7 or 6010C Thallium (low level) 0.0002 mg/L EPA 200.8 or 6020A Vanadium (low level) 10.0003 mg/L I EPA 200.8 or 6020A Zinc 10.005 m L I EPA 200.7 or 6010C ANIONS/CATIONS/OTHER Alkalinity (as CaCO3) 20 mg/L SM 2320B Bicarbonate 20 mg/L SM 2320 Calcium 0.01 mg/L EPA 200.7 Carbonate 20 mg/L SM 2320 Chloride 0.1 mg/L EPA 300.0 or 9056A Fluoride 100 ug/l EPA 300.0 or 9056A Hardness NA mg/L as CaCO3 EPA 130.1 Magnesium 0.005 mg/L EPA 200.7 or 6010C Nitrate + Nitrite 0.01 mg-N/L EPA 353.2 Potassium 0.1 mg/L EPA 200.7 Methane 0.01 mg/L RSK - 175 Sodium 0.05 mg/L EPA 200.7 Sulfate 0.1 mq/L EPA 300.0 or 9056A Sulfide 10.1 mq/I ISM 4500 S2 D Total Dissolved Solids 25 mg/L ISM 2540C Total Organic Carbon 0.1 mg/L SM5310C/EPA9060A Total Suspended Solids 2.5 m L ISM 2450D Notes: 1. Inorganics analyzed for total and dissolved (0.45 micron) concentrations. Prepared by: JDM Checked by: HHS P:\Duke Energy Progress.1026\108. Sutton Ash Basin GW Assessment Plan\51.EHS-Additional Surface Water Sampling\Work Plan\Table 1 Surface Water Analytical Methods Page 1 of 1 TABLE 2 SEDIMENT ANALYTICAL METHODS L.V. SUTTON ENERGY COMPLEX DUKE ENERGY PROGRESS, WILMINGTON, NC INORGANIC COMPOUNDS UNITS METHOD Aluminum mg/kg EPA 6010D Antimony mg/kg EPA 6020B Arsenic mg/kg EPA 6020A Barium mg/kg EPA 6010C Beryllium mg/kg EPA 6020B Boron mg/kg EPA 6010C Cadmium mg/kg EPA 6020A Calcium mg/kg EPA 6010C Chloride mg/kg EPA 9056A Chromium mg/kg EPA 6010C Cobalt mg/kg EPA 6020A Copper mg/kg EPA 6010C Iron mg/kg EPA 6010C Lead mg/kg EPA 6020A Magnesium mg/kg EPA 6010C Manganese mg/kg EPA 6010C Mercury mg/kg EPA Method 7471B Molybdenum mg/kg EPA 6010C Nickel mg/kg EPA 6010C Nitrate as Nitrogen mg/kg EPA 9056A pH Su EPA 9045D Potassium mg/kg EPA 6010C Selenium mg/kg EPA 6020A Silver mg/kg EPA 6010 (or 6020) Sodium mg/kg EPA 6010C Strontium mg/kg EPA 6010C Sulfide mg/kg SW-846 9034 Sulfate mg/kg EPA 9056A Thallium (low level) (SPLP Extract only) mg/kg EPA 6020A Total Organic Carbon mg/kg EPA 9060 Vanadium mg/kg EPA 6020A Zinc mg/kg EPA 6010C Sediment Specific Samples Cation exchange capacity meq/100q LONR 29-B Particle size distribution Percent solids Percent or anic matter % EPA 600 R-02 069 Redox potential mV Faulkner et al. 1898; HACH Method 10228 Prepared by: RBI Checked by: TCP Revised by: HHS Rechecked by: JDM Notes: P:\Duke Energy Progress.1026\108. Sutton Ash Basin GW Assessment Plan\51.EHS-Additional Surface Water Sampling\Work Plan\Table 2 Sediment Analytical Methods Page 1of1 Water Resources Environmental Quality May 10, 2018 Paul Draovitch Senior Vice President Environmental, Health & Safety Duke Energy 526 South Church Street Mail Code EC3XP Charlotte, North Carolina 28202 ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Interim Director Subject: Surface Water Evaluation Plan to Assess 15A NCAC 2B Compliance - L. V. Sutton Energy Complex - Comments Dear Mr. Draovitch: On April 25, 2018, the North Carolina Department of Environmental Quality's Division of Water Resources (DWR) received the "Surface Water Evaluation Plan to Assess 15A NCAC 2B Compliance - L. V. Sutton Energy Complex" (SW Evaluation) for the subject facility. DWR has reviewed the SW Evaluation and approves its implementation with the following conditions. All surface water sampling shall follow the protocol detailed in the DWR Internal Technical Guidance: Evaluating Impacts to Surface Water from Discharging Groundwater Plumes dated October 31, 2017. One additional near -bank surface water/sediment sample location is requested in the cooling pond south of the FADA and adjacent to the former coal stockpile, as depicted on the attached map. Any modifications or revisions to the approved SW Evaluation will need to be reviewed and approved by the DWR prior to implementation. If you have any questions, please feel free to contact Geoff Kegley (Wilmington Regional Office) at (910) 796-7215 or Steve Lanter (Central Office) at (919) 807-6444. Sincerely, r i s' on Rid, Section Chief Water Quality Regional Operations Division of Water Resources Attachment cc: WIRO WQROS Regional Office Supervisor WQROS Central File Copy -r--""Nothin9 Compares -., State of North Carolina I Environmental Quality I Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center I Raleigh, North Carolina 27699-1636 919-707-9129 L. V. Sutton Ene[U Complex — Additional Sediment/Surface Water Sample Request ��4 i*p1�fi1�R9 so � unrc-ucwn :;,J .- TW-132 _ � M1k-73Ei C'p E • - r -13B M W -11 A P-1 D PZ-79T1 1971 ASH "w -04MC BASIN Tw_ z r Mw zzerc 1983 �yrw.l�p EXTENSION _ rEw•ta aw-a . • MW-17 ��M-wM.aWu -19 F ORMER ASH SAL AREA KW-14 Mw 18B C T ^ . 2C 10 �, MW-07Af6lC wwmftaiSam t AW-R86C❑ `. i ftm ; PE .' location L-1