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Marshall Ash Basin (NPDES Permit NC0004987)
Groundwater Monitoring Program
Reports and Recommendations
Groundwater monitoring is conducted around the ash basin system at the Marshall Steam Station
under NPDES Permit NC0004987. The following items are presented to describe potential on-
site and off-site receptors, the nature of the groundwater flow regime around the Marshall site,
and the Marshall groundwater monitoring program.
• Item 1 - Receptor Survey Marshall Steam Station Ash Basin
• Item 2-Generalized Groundwater Flow Direction Figure
• Item 3 - Groundwater Monitoring Program Sampling, Analysis, and Reporting Plan
The referenced items and documents are included to describe the current state of the groundwater
monitoring program and any changes to the existing monitoring plan. Changes to the current
program (including installation of additional observation or monitoring wells) which are
proposed by Duke Energy in the future may be allowed following consultation with NCDENR
and should not require a re-opening of the Marshall NPDES permit.
Item 1 -Receptor Survey Marshall Steam Station Ash Basin
A receptor survey has been completed to identify private water supply wells, public water
supplies, surface water bodies, and wellhead protection areas (if present) within a 0.5-mile radius
of the Marshall ash basin compliance boundary. The report presents the methodology and
findings of the survey. This report is included as Enclosure 1.
Item 2- Generalized Groundwater Flow Direction Figure
The Marshall ash basin site and the generalized groundwater flow directions for the shallow
water table are presented in a figure contained in Enclosure 2. The figure presents the
generalized groundwater flow direction around the ash basin with arrows depicting probable
generalized groundwater flow directions for the shallow water table. These generalized flow
directions were developed based on the site hydrogeologic conceptual groundwater flow model,
site topography, and historic site groundwater elevation data.
Item 3 - Groundwater Monitoring Program Sampling,Analysis,and Reporting Plan
The groundwater monitoring program sampling, analysis, and reporting plan (Plan) was
developed to support the requirement for groundwater monitoring around the Marshall ash basin.
1
The Plan describes the groundwater monitoring network, methodologies of field sampling,
record-keeping protocols, analytical procedures, data quality objectives, data validation, and
reporting that will be used to support the Marshall ash basin groundwater monitoring program.
This document is included as Enclosure 3.
As stated in the Plan, it is recommended that sample reporting requirements be changed to
require reporting within 60 days of the date of sample collection. It is recommended that the
compliance monitoring wells at the Marshall site continue to be sampled at a frequency of three
times per year and analyzed for the same constituents that have been historically analyzed for the
NPDES-required groundwater monitoring.
We also plan to develop a groundwater flow model of the site predicting expected groundwater
flow paths from areas around the ash pond system to the appropriate receiving water body. The
groundwater flow model would be used to verify the current understanding of the groundwater
flow directions at the site and could be used to evaluate exceedances if any are found to be
related to impacts from the ash basin. We propose that model will be developed and the
groundwater flow modeling report be submitted to NCDENR within 120 days of the NPDES
permit being issued. As plans are made to develop the groundwater flow model, the installation
of additional observation wells in or around the ash basin system may be beneficial to enhance
the model. If Duke's evaluation deems additional observation wells to be beneficial, we will
communicate our recommendations to NCDENR prior to well installation.
NCDENR Aquifer Protection Section (APS) developed a policy for compliance evaluation of
groundwater results at ash basins with no prior groundwater monitoring and published a
memorandum providing that policy on June 17, 2011. The memorandum titled Policy for
Compliance Evaluation of Long-Term Permitted Facilities with No Prior Groundwater
Monitoring Requirements outlined the process for evaluating compliance of groundwater
monitoring results based on the requirements in 15A NCAC 2L.0106.
The memorandum acknowledges the factors that monitoring well placement and existing
conditions at the ash basins have on determination of exceedances of 2L Standards in
groundwater monitoring results at ash basins.
The memorandum included a flow chart showing the process for determining if a measured
groundwater concentration greater than 15A NCAC 02L .0202 would cause the facility to be
non-compliant and would result in implementation of corrective action.
Duke recommends continued utilization of the June 17, 2011, NCDENR memorandum to
evaluate exceedances of 2L Standards at the Marshall ash basin. For exceedances that are not
the result of naturally occurring site conditions, the process prescribed in the memorandum
requires the permittee to comply with corrective action requirements as specified in 15A NCAC
02L.0106.
Enclosures: Enclosure 1 —Receptor Survey Marshall Steam Station Ash Basin
Enclosure 2—Generalized Groundwater Flow Direction Figure
Enclosure 3—Groundwater Monitoring Program Sampling,Analysis,and
Reporting Plan
1
' RECEPTOR SURVEY
MARSHALL STEAM STATION ASH BASIN
' NPDES PERMIT NC0004987
111 INet 1
DUKE
ENERGY®
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Prepared for:
DUKE ENERGY CAROLINAS, LLC
' Charlotte, North Carolina
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Prepared by:
HDR ENGINEERING, INC. OF THE CAROLINAS
Charlotte, North Carolina
October 10, 2014
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111
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REPORT VERIFICATION
PROJECT: RECEPTOR SURVEY
MARSHALL STEAM STATION ASH BASIN
NPDES PERMIT NC0004987
' This document has been reviewed for accuracy and quality commensurate with the intended
application.
Prepared by: Date: 1°//e/a
Checked by: „rfe,ke--,11.441— Date: g1/40/c2i"it
1
Approved by: Vhartc,t, , Date: 16 /10 /Z014—
Project
ZO(4.Project Manager: Brooke Ahrens,PE
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RECEPTOR SURVEY
I MARSHALL STEAM STATION ASH BASIN
NPDES PERMIT NC0004987
ITABLE OF CONTENTS
ISection Pane No.
ISECTION 1 INTRODUCTION 1
SECTION 2 BACKGROUND 2
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2.1 Plant and Ash Basin Description 2
2.2 Description of Surrounding Properties 3
I SECTION 3 RECEPTOR SURVEY ACTIVITIES 4
3.1 NCDENR Records Review 4
I 3.2 Catawba County Records Review 4
3.3 Utility Department Records Review 5
I3.4 HDR Field Survey 5
3.5 USGS Hydrography Review 6
I SECTION 4 FINDINGS 7
4.1 NCDENR Records 7
I 4.2 Catawba County Records
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4.3 Utility Department Records g
I4.4 HDR Field Survey 8
4.5 Summary of Receptor Survey Findings 9
FIGURES
IFigure 1 Receptor Survey Map
TABLES
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Table 1 Public and Private Water Supply Wells
' (Within 0.5 Mile Radius of Ash Basin Compliance Boundary)
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Section 1
1 Introduction
Duke Energy Carolinas, LLC's(Duke Energy) Marshall Steam Station(MSS) is located on Lake
Norman in Catawba County near Terrell, North Carolina (Figure 1). MSS is a coal-fired
' electricity generating facility with a capacity of 2,090 megawatts which began commercial
operation in 1965.
' Coal ash residue from the MSS coal combustion process has historically been disposed of in the
station's ash basin. The ash basin system consists of a single cell, impounded by an earthen dike,
located on the southeast end of the ash basin. Clarified effluent is discharged to Lake Norman
through a discharge tower located within the ash basin. The discharge from the ash basin is
permitted by the North Carolina Department of Environment and Natural Resources (NCDENR)
Division of Water Quality (DWQ) under the National Pollutant Discharge Elimination System
(NPDES)Permit NC0004987.
HDR Engineering, Inc. of the Carolinas(HDR)has completed a receptor survey to identify water
supply wells, public water supplies, surface water bodies, and wellhead protection areas (if
present) within a 0.5 mile radius of the MSS ash basin compliance boundary (Figure 1).1 The
Icompliance boundary for groundwater quality in relation to the ash basin is defined in
accordance with 15A NCAC 02L .0107(a) as being established at either 500 feet from the waste
boundary or at the property boundary,whichever is closer to the source.
IThe survey activities performed and the findings of those activities are presented in Sections 3
and 4,respectively.
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' A Drinking Water Supply Well and Receptor Survey, Marshall Steam Station Ash Basin, NPDES Permit
NC0004987 report dated September 30,2014(submitted to NCDENR under separate cover), was completed to
satisfy the requirements outlined in The Coal Ash Management Act 2014 — General Assembly of North
Carolina Senate Bill 729 Ratified Bill(Session 2013)and the NCDENR August 13,2014 Notice of Regulatory
' Requirements.
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Section 2
I Background
1 2.1 Plant and Ash Basin Description
IMSS is a coal-fired electricity generating facility with a capacity of 2,090 megawatts located in
Catawba County,North Carolina near the community of Terrell. The site is located north of NC
IHwy 150, east of Sherrills Ford Road and south of Island Point Road, and is generally situated
between residential properties and Lake Norman (Figure 1). The ash basin is situated between
Ithe MSS to the south,primarily residences to the west and north, and Lake Norman to the east.
A topographic divide is located along Sherrills Ford Road and along Island Ford Road. The
topography at the site generally slopes downward from that divide toward Lake Norman.
IThe ash basin was constructed in 1965 and is located approximately 2,000 feet northeast of the
power plant, as shown on Figure 1. The waste boundary associated with the ash basin is
Iapproximately 382 acres in area and is also shown on Figure 1. The approximate pond elevation
for the ash basin is 790 feet. The normal pond elevation of Lake Norman is approximately 760
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feet.
The ash basin system is an integral part of the station's wastewater treatment system, which
Ireceives inflows from the ash removal system, coal pile runoff, landfill leachate, FGD
wastewater, the station yard drain sump, stormwater flows, and station wastewater. During
Istation operations, inflows to the ash basin are highly variable due to the cyclical nature of
station operations. Inflows from the station to the ash basin are discharged into the southeast
Iportion of the ash basin. The ash basin pond elevation is controlled by the use of concrete stop
logs. The discharge from the ash basin is through a concrete discharge tower located in the
Ieastern portion of the ash basin. The concrete discharge tower drains through a 30-inch diameter
slip-lined corrugated metal pipe which discharges into Lake Norman.
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ISection 2 Background
1 2.2 Description of Surrounding Properties
Properties located within a 0.5 mile radius of the MSS ash basin compliance boundary generally
Iconsist of undeveloped land and Lake Norman to the east, residential properties located to the
north and west, the MSS station and several residences to the south, and commercial properties
Ito the southeast along NC Hwy 150.
IFigure 1 depicts the general land use surrounding the MSS.
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Section 3
Receptor Survey Activities
1 3.1 NCDENR Records Review
1 On July 10, 2014, Mr. Justin Schumacher with HDR contacted Mr. Sean McGuire, Geographic
Information System (GIS) Specialist with the NCDENR Department of Environmental Health
(DEH) Public Water Supply Section (PWSS), by telephone. Mr. McGuire stated that the Public
Water Supply Water Sources GIS point data set was in the process of being updated. The most
Icurrent GIS data set of public water supply locations available from North Carolina state
agencies was provided by Mr. McGuire via electronic mail on July 14, 2014. The GIS point data
for the public water supply wells includes, but is not limited to information such as public water
supply (PWS) system identification numbers, ownership information, PWS source type, well
depth, and well yield. HDR reviewed the GIS data set to identify public water supply sources
within a 0.5 mile radius of the MSS ash basin compliance boundary.
On August 15, 2014, HDR reviewed the NCDENR Division of Water Resources (DWR) Source
Water Assessment Program (SWAP) online database for public water supply sources to identify
1 wells located within a 0.5 mile radius of the ash basin compliance boundary, to confirm the
location of wells included in the Public Water Supply Water Sources GIS point data set, and to
identify wellhead protection areas located within a 0.5 mile radius of the compliance boundary.
The NCDENR SWAP database provides detailed assessments of all public drinking water
intakes and wellhead protection areas in North Carolina. The website address is:
(http://swap.ncwater.org/website/swap/viewer.htm).
3.2 Catawba County Records Review
' HDR contacted the Catawba County Environmental Health Department to inquire about the
location and details (if available) for registered private water supply wells located in Catawba
County within a 0.5 mile radius of the ash basin compliance boundary. On August 20,2014,Ms.
Brooke Ahrens with HDR contacted Mr. Mike Cash, Environmental Health Supervisor with the
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Section 3 Water Supply Well Survey Activities
Catawba County Environmental Health Department. Mr. Cash indicated that Catawba County
began collecting well record information for private water supply wells in 1998. Mr. Cash
provided well record information for four wells located within a 0.5 radius of the compliance
boundary.
Mr. Chad Hearn with HDR contacted the Catawba County Utilities and Engineering Department
on April 15, 2014 to inquire about municipal water supply to properties located in Catawba
County within a 0.5 mile radius of the ash basin compliance boundary. Mr. Jonathan Greer,
Project Manager with the Utilities and Engineering Department indicated that the City of
Hickory provides municipal water supply to properties located within a 0.5 mile radius of the
compliance boundary.
3.3 Utility Department Records Review
1 HDR contacted the City of Hickory Public Utilities Department to inquire about municipal water
supply to properties located within a 0.5 mile radius of the ash basin compliance boundary. On
1 August 20, 2014, Ms. Brooke Ahrens of HDR contacted Ms. Tracy Church with the City of
Hickory,by telephone. Ms. Ahrens subsequently provided Ms. Church a list of properties where
neither a water supply well or a water meter was observed in the field to confirm municipal
water service to these addresses. Ms. Church reviewed the City's billing records to confirm
which properties were currently connected to the City's water service.
3.4 HDR Field Survey
HDR personnel performed a field reconnaissance on March 31, 2014 to attempt to identify water
supply wells and surface waters located within a 0.5 mile radius of the ash basin compliance
boundary. A windshield survey was conducted from public roadways to identify water meters,
Ivalves, and any potential well heads/well houses. Prior to conducting the field reconnaissance,
HDR personnel reviewed orthophotography obtained from NC OneMap GeoSpatial portal (dated
1 2010) to identify potential well heads/well houses and surface waters within a 0.5 mile radius of
the ash basin compliance boundary.
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Section 3 Water Supply Well Survey Activities
IIn addition, HDR personnel contacted Duke Energy site personnel to identify water supply wells
located on Duke Energy property.
1 3.5 USGS Hydrography Review
IHDR reviewed the United States Geological Survey (USGS) National Hydrography Dataset
(NHD) obtained from the USGS National Map Viewer (http://viewer.nationalmap.gov/viewer/)
I to identify surface waters within a 0.5 mile radius of the ash basin compliance boundary.
Hydrography data obtained from the USGS NHD is included on Figure 1.
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Section 4
1 Findings
IDetails of the findings from the local and state records review and field survey activities are
provided in Sections 4.1 through 4.5. A general summary of the receptor survey findings is
Iprovided in Section 4.6.
1 4.1 NCDENR Records
Four public water supply wells were identified in the Public Water Supply Water Sources GIS
Ipoint data set (obtained from NC OneMap GeoSpatial Portal) and on the NCDENR SWAP
online database within a 0.5 mile radius of the ash basin compliance boundary. These wells are
Iidentified with PWS preceding the Public Water Supply System ID Number. Available well
information for the identified public wells is provided in Table 1. The locations of these wells
Iare identified on Figure 1.
IOne of the public wells identified is registered to Duke Energy Carolinas LLC (PWS ID:
0118676). HDR contacted MSS personnel to confirm the location of the well. Mr. George
I Tolbert, Environmental Coordinator at MSS, confirmed that one water supply well is located on
the MSS site in the location depicted by the Public Water Supply Water Sources GIS point data
Iset, as shown on Figure 1.
No wellhead protection areas were identified on the NCDENR SWAP online database within a
1 0.5 mile radius of the ash basin compliance boundary.
I4.2 Catawba County Records
Based on records reviewed, the Catawba County Environmental Health Department has record
Iof four registered private water supply wells located within a 0.5 mile radius of the ash basin
compliance boundary. These wells are identified with PRW preceding the identification number
tas it is referenced to available well information provided in Table 1. The locations of these wells
are identified on Figure 1.
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1 Section 4 Findings
1 4.3 Utility Department Records
On August 21, Ms. Tracy Church with the City of Hickory Public Utilities Department indicated
the City currently provides municipal water service to 12 of the properties located within a 0.5
mile radius of the ash basin compliance boundary where a water supply well or municipal water
1 service meter was not observed during HDR's field reconnaissance.
Ms. Church also indicated that several properties where a water supply well or municipal water
service meter was not observed in the field were not currently connected to the City's water
1 service.
4.4 HDR Field Survey
'
During the field reconnaissance, HDR field personnel identified 57 private water supply wells at
properties located within a 0.5 mile radius of the ash basin compliance boundary. Fifty-three of
the 57 identified wells are included on Figure 1 as"field identified"private water supply wells.
Catawba County provided records for 4 of the 57 identified wells, plus the well record for the
public water supply well owned by Duke Energy Carolinas, LLC (PWS ID: 0118676). The
wells that Catawba County had records for are included on Figure 1 as "recorded"private water
supply wells. These four wells (PRW-1 through PRW-4), along with the four public water
' supply wells (described in Section 4.1) are the only wells included in Table 1. The locations of
the four public water supply wells included in NCDENR's records and located within a 0.5 mile
radius of the compliance boundary were confirmed in the field, and by Duke Energy personnel
(PWS ID: 0118676).
' From the public roadway, HDR personnel identified municipal water service meters for several
1 properties located within a 0.5 mile radius of the ash basin compliance boundary along Sherrills
Ford Road and the neighborhood where Cape Cove Drive is located. Wells are not shown on
Figure 1 at these properties.
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Section 4 Findings
For properties where water supply wells were not visible from a public right-of-way, HDR was
not able to confirm the location or presence of a well. As described in Section 4.3, the City of
Hickory indicated that several properties where a water supply well or municipal water service
meter was not observed in the field were not currently connected to the City's water service.
Therefore, it is assumed that the properties which are not currently connected to the City's water
service and where a water supply well was not observed from a public right-of-way are supplied
water by private water supply wells. Approximate locations based on structures identified during
the field reconnaissance and/or orthophotography review are included on Figure 1 as "assumed"
private water supply wells. A total of 17 assumed private water supply wells are located within a
0.5 mile radius of the ash basin compliance boundary.
Several surface water bodies were identified and/or confirmed during HDR's field
reconnaissance. The surface water bodies located within a 0.5 mile radius of the ash basin
compliance boundary generally toward Lake Norman from the topographic divide along Sherrills
Ford Road.
4.5 Summary of Receptor Survey Findings
111
A summary of the receptor survey findings is provided below. The identified water supply wells
and surface water bodies are shown on Figure 1. Available property and well information for the
8 water supply wells registered with Catawba County and NCDENR is provided in Table 1.
• A total of 57 private water supply wells were identified within a 0.5 mile radius of the ash
basin compliance boundary. The Catawba County Environmental Health Department
had records for 4 of the 57 identified private water supply wells.
• 17 private water supply wells are assumed at residences located within a 0.5 mile radius
I of the ash basin compliance boundary.
• Four public water supply wells were identified within a 0.5 mile radius of the ash basin
compliance boundary. The Catawba County Environmental Health Department had
records for one of the public water supply wells (PWS ID: 0118676, owned by Duke
Energy Carolinas, LLC).
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Section 4 Findings
I • Several surface water bodies that flow from the topographic divide along Sherrills Ford
Road toward Lake Norman were identified within a 0.5 mile radius of the ash basin.
I • No wellhead protection areas were identified within a 0.5 mile radius of the ash basin
compliance boundary.
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ITABLES
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Table I
Public and Private Water Supply Wells
Within 0.5 Mile Radius of Marshall Ash Basin Compliance Boundary
Duke Energy Carolinas, LLC/Marshall Steam Station
Approximate
Well
Well m
PubSystem
Property Address
Reported Well
Distsoce from Ash
Direction
Well
Cuing
well
(shown on Figure 1)
Naterme
System Name
well location
( )
Pared ID Number
Use
Basin
from Ash
Depth
Depth
Yield
Bouad, n
Boundary
Basia
(n-bgs)
( -bg
Wen)
PWS 0118622
Midway Restaurant and
8693 E NC I50 Hwy
461708998493
Transient,
2,325
SE
Marina
Terrell, NC 28682
Non -Community
245
N/A
20
PWS 0119736
Country
The Old Count Church
8455 E NC 150 Hwy
461707773629
Transient,
1.225
S-SE
N/A
N/A
Terrell, NC 28682
Non -Community
40
PWS 0118780
Mott's Grove UhIC
8790 Sherrills Ford Rd
461803100104
Transient'
1,475
SW
N/A
N/A
40
Sherrills Ford, NC 28673
Non -Community
PWS 01 19676 2
Duke Energy Carolinas LLC
8320 E NC 150 Hwy
461803426350
Non -Transient,
1,700
S
Terrell, NC 28682
Non -Community
540
91
30
PRW-1
N/A
2971 Steam Plain Rd
Sherrills Ford, NC 28673
460804939276
Domestic
475
W
185
80
10
PRW-2
N/A
8526 Sherrills Ford Rd
Sherrdls Ford. NC 28673
461303021923
Domestic
650
W
205
145
10
PRW-3
N/A
8883 Sherrills Ford Rd
Sherrills Ford, NC 28673
461701097362
Domestic
2,250
W-SW
240
100
3
PRW-4
N/A
8846 Greenwood Rd
Terrell, NC 28682
461708984339
Domestic
1,625
SE
206
108
37
N=:
1. Public water supply well (PWS) information obtained from NCDENR's Public Water Supply Water Sources Geographic Information System (GIS) point data set and NCDENR's SWAP online database
2. Well construction information (well depth, casing depth, and well yield) for public well PWS 0118676 obtained from well construction record provided by Catawba County Environmental Health Department.
3. Private water supply well (PRW) information obtained from the Catawba County Environmental Health Department's available records on May 13, 2014. (Notes Catawba County began obtaining well records in 2008. )
4. Owner and property information for private water supply wells obtained from Catawba County Interactive GIS Website.
5. Distances between well and the Marshall Ash Basin Compliance Boundary are approximate and based on location information provided by NCDENR's data set, Catawba County GIS website, the
Catawba County Environmental Health Department records, and observations during HDR's field survey.
6. Non -Transient, Non -Community Well serves at least 25 of the same persons 6+ months per year (a g., schools, dayeares, nndustnes).
7. Transient, Non -Community Well serves 25+ people at least 60 days per year (e.g., restaurants, churches, DOT rest seas).
8. N/A indicates not available
9. n-bgs indicates feet below ground surface
10. gpm indicates gallons per minute
1 I S = South, W = West, SW = Southwest, SE = Southeast, S-SE = South -Southeast, W-SW = West -Southwest
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