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INTERIM ACTION PLAN
ASHEVILLE STEAM ELECTRIC PLANT
200 CP&L DRIVE
ARDENT NC 28704
APRIL 2016
PREPARED FOR
DUKE ENERGY PROGRESS,, LLC
RALEIGH,, NORTH CAROLINA
DUKE
NERG
PRRE.'
nfoy�llebb, NC PG 1328
Project Director
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Interim Action Plan April 2016
Asheville Steam Electric Plant SynTerra
TABLE OF CONTENTS
SECTION
PAGE
1.0 BACKGROUND............................................................................................................1-1
1.1
Area of Interest..........................................................................................................1-2
1.2
Constituents of Interest............................................................................................1-2
2.0
INTERIM ACTION OBJECTIVES............................................................................
2-1
3.0
ADDITIONAL ASSESSMENT ACTIVITIES.........................................................
3-1
3.1
Status...........................................................................................................................3-1
3.2
Proposed Additional Assessment...........................................................................
3-1
3.2.1
MW-18BRL...........................................................................................................
3-2
3.2.2
West of the French Broad River........................................................................
3-2
3.2.2.1 Groundwater Sampling...............................................................................
3-2
3.2.2.2 Water Supply Well Inspection....................................................................3-3
3.2.2.3 Borehole Geophysical Logging...................................................................3-3
3.2.2.4 Surface Water Sampling..............................................................................
3-4
4.0
INTERIM ACTION TASKS.......................................................................................4-1
4.1 Property Acquisition................................................................................................ 4-1
4.2 Alternate Water Supply........................................................................................... 4-1
4.3 Proposed Remedial Alternatives............................................................................ 4-1
4.3.1 Evaluation............................................................................................................ 4-2
4.3.2 Status.....................................................................................................................4-3
5.0 SCHEDULE.................................................................................................................... 5-1
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LIST OF FIGURES
Figure 1-1 Site Location Map
Figure 1-2 Site Layout and Area of Interest
Figure 3-1 Proposed Additional Site Assessment
Figure 4-1 Modeled Boron Distribution With and Without Groundwater Extraction
Figure 4-2 Aquifer Test - Site Plan
LIST OF TABLES
Table 1-1 Groundwater Results for Select Monitoring Wells
Table 1-2 Exceedances of 2L Standards for Select Monitoring Wells
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EXECUTIVE SUMMARY
Duke Energy Progress, LLC (Duke Energy), owns and operates the Asheville Steam
Electric Plant (Asheville Plant), located near Asheville in Buncombe County, North
Carolina. Corrective Action Plan Part 2 was developed and submitted on February 19,
2016 to satisfy requirements of the North Carolina Coal Ash Management Act (NC
CAMA). In addition to CAMA, a Settlement Agreement (Agreement) between DEQ
and Duke Energy, signed on September 29, 2015, provided an additional requirement to
implement accelerated remediation at sites that demonstrated off-site groundwater
impacts.
Based on data collected for the CSA, potential off-site groundwater impacts were
identified west of the 1964 ash basin, beneath a 12 acre parcel within the I-26 right of
way. Boron, chloride, cobalt, iron, manganese, selenium, sulfate, total dissolved solids
(TDS), and vanadium are likely present at levels greater than the 2L Standard or IMAC
in the groundwater beneath this parcel. Duke Energy is currently evaluating the
purchase of the subject 12 acre property. As an alternative to property acquisition,
groundwater extraction is being evaluated to meet the requirements of the September
29, 2015 Settlement Agreement.
Aquifer tests are planned to provide necessary information to evaluate the feasibility
and conduct preliminary design of a groundwater extraction system. A series of step -
drawdown tests are planned at bedrock monitoring wells CB-08BR, MW-09BR, and
CCR-103BR. These tests are scheduled to be complete by May 30, 2016 with data
evaluation complete by June 30, 2016.
Based on review comments from the CSA, additional assessment has been conducted at
the Asheville Plant. Two additional bedrock wells have been installed. One deep
boring at background location CB-01BRL indicates the lack of a bedrock flow system in
this area, and bedrock well ABMW-11BR, installed beneath the divider dike of the 1964
and 1982 ash basins, has recently been sampled.
As a result of water supply well sampling, further assessment of the fractured bedrock
flow system and other potential source areas west of the French Broad River are
proposed. Proposed assessment activities include water supply well inspection,
groundwater sampling, borehole geophysics, and surface water sampling at select
private water supply wells and their respective properties.
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1.0 BACKGROUND
Duke Energy Progress, LLC (Duke Energy), owns and operates the Asheville Steam
Electric Plant (Asheville Plant), located near Asheville in Buncombe County, North
Carolina (Figure 1-1). The Asheville Plant occupies approximately 786 acres south of
Asheville and began commercial operation in 1964. The Plant consists of two coal-fired
units along with two combustion turbines to generate power. The Asheville Plant
utilizes adjacent 300 -acre Lake Julian as cooling water, as well as the French Broad River
for water supply (Figure 1-2). Coal combustion residuals (CCR) have been managed at
the Plant's on-site ash basins and used as structural fill at the nearby Asheville Airport.
In order to satisfy requirements of the North Carolina Coal Ash Management Act
(CAMA), a Comprehensive Site Assessment (CSA) and Corrective Action Plan (CAP)
Parts 1 and 2 were prepared and submitted to the North Carolina Department of
Environmental Quality (DEQ). The most recent document, the CAP Part 2, was
submitted to DEQ on February 19, 2016.
The CAP (Parts 1 and 2) was designed to describe means to restore groundwater quality
to the level of the standards, or as close as economically and technologically feasible in
accordance with T15A NCAC 02L.0106. Exceedances of numerical values contained in
Subchapter 2L and Appendix 1 Subchapter 02L (IMACs) at or beyond the compliance
boundary were determined to be the basis for corrective action with the exception of
parameters for which naturally occurring background concentrations are greater than
the standards. The CAP Part 2 identified the preferred corrective action, developed a
detailed conceptual design, and provided implementation and monitoring plans.
In addition to CAMA, a Settlement Agreement (Agreement) between DEQ and Duke
Energy signed on September 29, 2015, provided an additional requirement to
implement accelerated remediation at sites that demonstrated off-site groundwater
impacts. Based on data collected for the CSA, potential off-site groundwater impacts
were identified west of the 1964 ash basin, beneath a 12 acre parcel within the I-26 right
of way. Duke Energy provided an Accelerated Remediation Summary to DEQ on
February 17, 2016 which supplemented and updated information included with the
CAP Part 2. In correspondence dated March 28, 2016, DEQ acknowledged receipt of the
Remediation Summary and requested additional information. This report is prepared in
response to the DEQ request for additional information related to the accelerated
remediation activities.
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1.1 Area of Interest
Constituents associated with coal ash pore water migration have been identified within
groundwater in the surficial, transition, and bedrock flow zones at the compliance
boundary. The area of highest concentration is immediately northwest of the 1964 ash
basin extending toward the French Broad River.
The concentrations in this area are influenced by the former flue gas desulfurization
(FGD) wastewater treatment wetlands as evident by chemical analysis and hydraulic
conditions in the area. Groundwater flow in this area is from the basin to the west,
towards the French Broad River. Figure 1-2 shows the 1964 ash basin, the area of FGD
wastewater treatment wetlands and the offsite parcel (area of interest) within the I-26
right of way.
Groundwater monitoring wells delineating concentrations in this area are located on
Duke Energy property; however there is a 12 acre parcel of property within the I-26
corridor not owned by Duke Energy (refer to shaded area on Figure 1-2). Groundwater
beneath this parcel is likely similar to the groundwater up and downgradient. Seep and
surface water data in the same area indicate exceedances of 2L standards or IMACs for
boron, chloride, cobalt, iron, manganese, mercury, selenium, sulfate, TDS, and
vanadium.
1.2 Constituents of Interest
Groundwater sampling performed for the Asheville Steam Electric Plant CSA found
exceedances of 2L Standards or IMACs for boron, chloride, cobalt, iron, manganese,
selenium, sulfate, total dissolved solids (TDS), and vanadium in monitoring wells
located west of the 1964 ash basin and west of Interstate 26. These constituents are
assumed to be present above the 2L Standard in the groundwater beneath the area of
interest described above. Table 1-1 displays analytical results for wells in the vicinity of
the area of interest. Table 1-2 reduces the data to exceedances of the 2L Standard or
IMAC at these select wells.
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2.0 INTERIM ACTION OBJECTIVES
Interim action objectives at the Asheville Plant include:
,61, Acquire the 12 acre parcel (area of interest) within the I-26 right of way
01 Conduct initial aquifer tests to evaluate feasibility and aid in the preliminary
design of a groundwater extraction system
10 Conduct additional assessment of private water wells to the west of the French
Broad River
,67 Install and assess a deep bedrock location on the eastern shore of the French
Broad River
,610 Initiate preliminary groundwater extraction system design
`0 Initiate groundwater extraction system permitting
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3.0 ADDITIONAL ASSESSMENT ACTIVITIES
Additional assessment needs were identified following review of the CSA. The primary
data needs requiring additional assessment included the consideration of replacing
three background monitoring wells (AMW-3A, CB-01BR, and MW-24BR) and
additional hexavalent chromium sampling.
3.1 Status
Transition zone background well AMW-03A exhibits elevated pH relative to naturally
occurring levels. Aggressive redevelopment of this well was attempted in order to add
this location to the background well dataset. Redevelopment of this well was
unsuccessful. AMW-03A will not be included in the background well data set and there
are no plans to replace this well at this time.
CB-01BR was installed as a piezometer to a depth of 84 feet below ground
surface. Water yield at this location is insufficient to support development or
sampling. Therefore a deeper bedrock well designated CB-01BRL was planned and
recently installed. CB-01BRL was drilled to a total depth of 328 feet below ground
surface. Water yield at this location is insufficient to support development or
sampling. No water bearing fracture zones were observed in the rock core or found
during drawdown/falling head tests. This boring was completed as an open borehole.
A deeper bedrock well was considered at the MW-24BR location, however there is
insufficient access at this location to allow the installation of an additional monitoring
well. There are no plans to install a substitute for MW-24BR at this time. CB-09BR
provides a background bedrock well location for the northern portion of the site, while
AMW-03B provides a background bedrock well for the southern portion of the site.
Site wide sampling for hexavalent chromium was conducted in December 2015 and a
summary of all hexavalent chromium sampling to date was included in Table 2-3 of the
CAP Part 2 document. Hexavalent chromium sampling is planned at background and
select downgradient well locations in 2016.
3.2 Proposed Additional Assessment
The objective of evaluating groundwater and other potential source areas west of the
French Broad River is to evaluate the potential for CCR influence on groundwater
beyond a regional groundwater divide. The described scope of work is designed to
confirm groundwater analytical results, evaluate the nature and extent of bedrock
fractures, and investigate potential alternative source areas near select water supply
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wells. Information obtained during this effort will be evaluated in conjunction with the
recently completed borehole geophysical logging of five water supply wells along Bear
Leah Trail. Additional groundwater assessment on the eastern shore of the French
Broad River is also proposed to supplement data collected during the CSA. Figure 3-1
shows areas where additional assessment activities are proposed.
3.2.1 MW-18BRL
In addition to the water supply well assessment west of the French Broad River,
a deep bedrock monitoring well (MW-18BRL) will be installed within the vicinity
of the MW -18 cluster. This location was chosen based on the groundwater
chemistry data, observed geologic structures, and geographic relationship
between the Plant, French Broad River, and select water supply wells west of the
French Broad River. Exploratory drilling will be conducted to a depth of 250'
below ground surface (bgs) to elevation 1,780' mean sea level. This elevation is
based on the assumed depth of the well located at 115 Justin Trail (reported top
of pump at 280' bgs with assumed total well depth of 330' bgs). MW-18BRL will
be initially installed as an open borehole well. Following the installation of this
boring, geophysical logging will be conducted. Once the boring has been logged
a monitoring well will be constructed if a fracture zone with sufficient flow is
identified at a deeper interval than MW-18BR.
3.2.2 West of the French Broad River
Five water supply wells and their respective properties have been identified west
of the French Broad River to conduct targeted assessment of the bedrock flow
system, groundwater chemistry, and surface water chemistry. Evaluation of this
data is intended to clarify water supply well characteristics, the nature and extent
of the bedrock flow system, and the presence of potential alternative source
areas.
3.2.2.1 Groundwater Sampling
Collection of a groundwater sample from the water supply wells to be
further assessed will provide confirmation of previously reported results.
Laboratory analysis will be run for parameters consistent with the recently
completed 3rd and 4th round sample event. Samples will be shipped to the
Duke Energy Analytical Laboratory by private courier.
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3.2.2.2 Water Supply Well Inspection
A North Carolina licensed well driller will remove well pumps to facilitate
borehole inspection with a series of geophysical logs. The driller will be
required to:
'67 Obtain access to water supply well (remove associated plumbing and
be prepared to replace as necessary);
'67 Remove pump and associated plumbing using appropriate tools;
�7 Conduct inspection of water supply system and conduct routine
maintenance (including pump, electrical, plumbing, and tank);
'67 Troubleshoot observed maintenance items at time of inspection (up
to pump replacement); and
'67 Following a series of geophysical tests conduct well disinfection,
replace pump, and check proper operation prior to leaving site.
3.2.2.3 Borehole Geophysical Logging
A series of borehole geophysical logs will be conducted at select water
supply wells. Logs will include fluid temperature/resistivity/3-arm
caliper/Single Point Resistance, acoustic or optical televiewer, and heat
pulse flowmeter under ambient and pumping conditions. This series of
logs is expected to take between four and six hours per well to complete,
therefore, one water supply well per day will be surveyed. A report
documenting findings of the geophysical survey will include logs,
interpretations, and results. Using acoustic/optical televiewer data, dip,
azimuth, and aperature will be calculated for each detected fracture, and the
results will be presented in tadpole and stereographic plots. This
information, along with well construction details will be used to further
characterize the nature and extent of groundwater flow within the CSA
addendum or subsequent reports.
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3.2.2.4 Surface Water Sampling
Surface water sampling of seeps and drainages within the flood plain area
(agricultural use) along the western shore of the French Broad River will be
used to investigate potential alternative source areas. The primary area
targeted for investigation is located on the same parcel as AS -14 (115 Justin
Trail). Site reconnaissance and sampling will be conducted during the same
event. Final seep and surface water sampling locations will be determined
in the field.
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4.0 INTERIM ACTION TASKS
The Asheville Steam Electric Plant CAP Part 2 was submitted to DEQ on February 19,
2016. Once approved, the CAMA sates: "No later than 30 days from the approval of the
Groundwater Corrective Action Plan, the owner shall begin implementation of the Plan in
accordance with the Plan's schedule." The following tasks are planned to be implemented
prior to CAP approval and are designed to accelerate remediation of impacted
groundwater beneath the 12 acre parcel within the I-26 right of way.
4.1 Property Acquisition
Duke Energy is currently pursuing the purchase of the 12 acre parcel (area of interest)
located within the I-26 right of way located to the west of the 1964 ash basin. This area
of interest is highlighted on Figure 1-2. While negotiations with the current property
owner continue, evaluation of aquifer characteristics will be conducted to aid in the
preliminary design of a groundwater extraction system. Groundwater extraction may
be a viable alternative to a property transaction.
4.2 Alternate Water Supply
The majority of the area within a half -mile of the compliance boundary is serviced by
municipal water lines. Five water supply wells were identified along Bear Leah Trail
during previous receptor surveys. Recently a municipal water line has been provided
to these nearby residences by extending a water line along Bear Leah Trail. Following
installation of the water line, the water supply wells located along Bear Leah Trail were
abandoned in March, 2016.
NCDEQ contacted nearby residents regarding wells and managed the sampling of the
wells in accordance with CAMA. Based on results of the water supply well sampling,
NCDEQ recommended that seven of the residences use an alternate water supply for
drinking. Since these letters have been issued, the water line along Bear Leah Trail has
been installed and the North Carolina Department of Health and Human Services
Standard for hexavalent chromium has been revised. The NCDEQ recommendations
for the remaining five locations were based on results for iron, manganese, sulfate, and
TDS which were above 2L. Currently, Duke Energy is providing bottled water to these
five well owners west of the French Broad River at 213, 215, and 218 Sumner Drive and
105 and 115 Justin Trail near Arden, NC.
4.3 Proposed Remedial Alternatives
The area of highest observed concentrations at the Asheville site adjacent to the
northwest corner of the 1964 ash basin occur within an area of relatively low aquifer
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hydraulic conductivity. The fate and transport model shows that elevated
concentrations remain in this location and will continue to influence downgradient
areas beyond the year 2045. Field observations and measurements as well as model
calibration support the presence of the low conductivity zone.
Source control is the primary means of achieving compliance with 2L standards
downgradient from the 1964 basin and within the area of interest. Projects are
underway to remove the FGD wetlands and dewater the settling basin. CSA activities
demonstrated each of these areas influences the geochemistry and hydrology
downgradient from the 1964 ash basin. Removal of these areas should reduce transport
of constituents by lowering the overall hydrologic head and reduce downgradient
concentrations by eliminating an active source. Data collected from ongoing
groundwater sampling efforts will be evaluate the response of constituent
concentrations to changing site conditions.
Modeling was performed to view the effect of mass removal within the area of greatest
concentrations (Appendix B). Conservative pumping rates of 0.3 gallons per minute
(gpm) within 10 extraction wells (3 gpm total) show substantial increases in the rate of
boron concentration reduction. Therefore, groundwater extraction could potentially
facilitate accelerated reduction of groundwater transport and constituent concentrations
in the area of interest.
4.3.1 Evaluation
Step -drawdown tests are planned at monitoring wells C13 -0813R, MW -0913R, and
CCR-103BR to evaluate aquifer characteristics and the feasibility of a
groundwater extraction system near the northwest corner of the 1964 ash basin.
Primary goals of the aquifer tests include:
01 Determine sustainable yield
01 Determine potential capture zone of each tested monitoring well
y Gain understanding of interconnected flow systems in the vicinity of each
tested monitoring well
101 Obtain reliable aquifer characteristic data
Aquifer testing is estimated to take up to ten days. During this time, water levels
will be monitored both manually and by means of electronic data loggers.
Approximately 15 data loggers will be installed in a combination of monitoring
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wells and piezometers located along and adjacent to CB -0813R, MW -0913R, and
CCR-103BR. Figure 4-2 shows the area to be evaluated.
Step -drawdown tests are planned at three bedrock monitoring wells. The step
tests will be conducted for a period of approximately four to five hours. Well
development and sampling logs will be used to determine an appropriately
conservative initial pumping rate. The flow rate will be doubled each successive
step until the aquifer is adequately stressed to dewater the well. After
completion, the recovery well will be allowed to return to static conditions. Once
static or near -static conditions have been achieved, the next test can proceed.
The water table will be considered to have reached static conditions when the
difference between water levels measured over a 12- hour period is less than 5%.
4.3.2 Status
The FGD treatment wetlands have been completely removed from the 1964 ash
basin. A pump station is under construction to bypass the settling basin within
the 1964 ash basin. Water will be routed directly to Outfall 001, resulting in the
dewatering of this basin.
Aquifer tests are scheduled to be complete by May 30, 2016. The following
milestones/schedule is proposed:
E1 Complete evaluation of initial aquifer test data - June 30, 2016
101 Assess need for active remediation based on potential property
acquisition - ongoing
y Complete feasibility study and preliminary design for active remediation
(groundwater extraction) - target date September 30, 2016
y Complete permitting process (E&SC, wetlands) - target date December 31,
2016
161, Installation/Startup Groundwater Extraction System - 2nd Quarter, 2017
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5.0 SCHEDULE
A comprehensive schedule of interim action and additional assessment items follows:
,611 Pursue purchase of 12 acre parcel within I-26 right of way - Ongoing
167 Complete aquifer test at select bedrock monitoring wells west of the 1964 ash
basin - May 31, 2016
10 Complete additional assessment scope items west of the French Broad River -
June 30, 2016
,61, Complete MW-18BRL assessment - June 30, 2016
411 Complete evaluation of aquifer test data - June 30, 2016
41, Initiate feasibility study and preliminary groundwater extraction system design
- June 30, 2016
01 Initiate permitting for groundwater extraction system - June 30, 2016
10 Submit CSA Supplemental report summarizing additional assessment findings
- August 31, 2016
161, Complete feasibility study and preliminary groundwater extraction system
design - September 30, 2016
'fir Obtain permitting approval, including modification to the NPDES permit, for
groundwater extraction treatment system - March 2017.
4r Initiate construction of the groundwater extraction treatment system -
Timeframe is difficult to determine until initial aquifer testing is completed and
permitting agencies have provided input.
If acquision of the I-26 parcel is successful, Duke Energy will own the property to the
French Broad River and accelerated remediation may not be necessary at that time.
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