HomeMy WebLinkAboutNC0001422_LV Sutton 9-29-2016_20160929�� DUKE
f'C EAERGY.
September 29, 2416
I�Ir. �. gay cimmerman_ P.G.
Director, Division of Water Resources
North Carolina Department of Environmental Quality
i'oii Flail service Center
Raleigh, NC 27699-1611
RE: Response Lo DEQ letter uated Hugusi ly, �D.L6
L.V. Sutton Energy Complex
Comments on Geochemical Modelins (Corrective Action Plan Part 1, ANpendix D, and Corrective
HRion Plan PaR c_ Kppendix C)
Dear Iglr. cimmerman:
ouRe Energy, along witR our con,eltants, and Department of Environmental Quality i;DEQ) staff discussed
the above -referenced letter during a conference call on �eptemDer ��, �O.t6. � Re list of participants on
this conference call is included in Attachment 1 to this letter. Below is Duke Energy's understanding
from tRis conference call.
Steve Lancer, DEQ Central Office, oNened the discussion by paraphrasing the four genera[ comments
provided in tRe aRove-referenced letter. In summary, DEQ requested o n=oised Site Conceptual Model
using the geochemical model information to describe the distribution of constituents with predictions
on how conditions may chanee with future remedial actions.
Morella Sanchez -King, DEQ Wilmington Regional Office, reiterated specific comment �� from tRe aRove-
referenc�d letter re�ardins specific information for Sutton describing the unique conditions on the
north side of the sys� asR Qasin �ivoRR ,cones; tRe central raR or tPfe site tTransition N-5 Zones; and
southeast of the 1971 ash basin {South Zone].
Dr. FaILa stated tRai LRe TIOW LranspoR mecnarnsms slioald uho Be ��nsidered. The anomalies observed
at Sutton may not have purely geochemical explanations. � here may be other source contributions or
e..planations. For Example, boron is assumed to be larsely unaffected by geochemistry; thus, changes
along a transect are more IiRely due to LranspoR anti geologic conditions.
Dr. Powell stated that the existine global �eochemical model way developed as a guide to determine if
LRe retardation factors will Re signincantly cRansed morn those used in the groundwater transport
model, understanding that pH and redox are the primary parameters that may change Lhe mobility of
constituents. It is not t�Lhnically possible to construct a completely coupled transport/geochemical
model oecause dear gradients are generally not oBsersed, there is extreme variability in the data, and
groundwater chemistry at the Sutton site is not at equilibrium (geochemica� modes are Gasea on an
assumption of eMuilibrium). Therefore, the global model provides a predictive estimation tool; for
examp�e_ if oxygen is introduced to tRe system as a result of a remediati;,n ;tip the model predicts how
the K� (mobility of constituents) could change (increase or decrease). � Re next step for tRe geocnemical
ICI. for CiR1R1e� tea.-� [eC[c�
September ty, �Oib
model would be to rnoia�l �peciflc sites, narrow down the Kd values, and answer specific water chemis�ry
related quesrions.
Dr. Falra aescrioea iRai iRe iran,port modelins conducted to date used conservative Ka values for each
consci�uen� (such as zero for boron} co reflex actual size observed conditions or tRe lowest .alae
measured br the University of North Carolina -Charlotte (UNCC} labora�ory. Dr. Powell Hared rhac is is
unlikely additional geocRemical mo�eling woal� predict lower Kd values than those currently used in the
flow and transport model.
.ed Campbell, Ksnevil�e Regions, orrice, tRen n=gaested additional clariryon the planned approach. Dr.
Powell described PHREEQC as one dimensional. Dr. Powell further describeC rRar rRe nex� step of rRe
geocRemical n+oaeling would be to run in batch mode alone transects for comparison �o ac�ual site
condirions wichour incorporaring i�ow.
bill DeuucR, DEQ contractor, Hated this approach uses a single Ko without PHREEQC flow capabilities
and does nor provide undersranding of rRe capacities or venous RyiaroxiCes and other adsorbents.
PHREEQC will show dissolving process and their effect. Dr. Powell indicated rhe capaciry comments in
rReobove-reverence iener .mere ve�,r helpful. Dr. Powell stated that titrations could be run to evalua�e
the stability ar exrreme high and low con0irions ro assess Row mucR or a ceRo;n constituent could be
sequestered under varying conditions.
Bill Deutsch brought rhe discussion bacR ro rRe specinc areas at �ution ansa tRat o,-.on+alies should be
explained by the Geochemical Site Conceptual Model to help with prediction of future condirions. � he
model sRoule vaciliiate evaluaiio�,s .here the pH and arsenic concentrations are high, and where
selenium is high and p� is low.
Dr. Power inf7icatea tRe plan woal� be to look at these sNecific areas with lower extractable iron to test
the global model understandings. Redox is srable. Exrraaable iron concentrations need io oe
determined for the model to be Nredictive. It was also noted that errors in the original mutton text
regarding conversion ov ER �o pe roe incorporation into the PHREEQC model were in the text only, the
actual modeling was correLt. The measured i�fzP values were correcref7 vor tRe reference elei`tro�e anti
tPiose values were appropriately converted to pe prior to incorporation into PHREEQC input files. � he
conclusions are oases on correE[ mottel information. Bill Deutsch suggested conductins ferric hydroxide
analysis in the anomalous areas and when dissolurion/IeacRing resrs are Done, Re recommenbeti
analrzin� for other chemicals. Dr. Powell stated that conducting additional laboratory analyses coupled
wirh rhe adairiona� geocrtemical moi�el�ng or new site data wilt not be possible by the November 1
Submittal deadline. However, Dr. Powell scared char Dune irnergy could use existing sol�R dna aqueous
phase data to calculate irrsitu Ko values for sampling events where both sees of dare are available.
Ted Campbell commenced char rhe current Corrective Hcrion Plans �CHPi pro�ia� predictive flow and
transport models with a single Kp for each constituent and asked what would be done in rhe furore. Dr.
Falta seared Rat �Re gra,-.sport models dont support certain constituents of interest �CQI} migra�ing
from the ash basin in certain areas, even wirR a very low Rd, suggesting otRe� sod, ces. Dr. Falta also
stated that the fate and transport models could be rerun if the geochemical modeling indicates it is
possible ro Rave a lower Rd ;,aloe than what was previously modeled. However, boron was modeled
with a Kd of zero ac Sutton.
Mr. Jay zimmerman getter
5ei7tc Rlbc� Z9, ��26
Dr. Powell sugtiested that rather than coupling she flaw and geochemical model, she recommenaetl
approach woulia De to maze the n�oselinti iterative i.e., if the seochemicai model sugtiests a lower Kp
may occur Shan had been previously evaluated in �I1e CKP_ toes ��e rlow anis transport model coelLl be
re,,eated with the lower Kd). Knowins specific areas of in�eres� for each site, as provided in she above-
referencela letter ror sunon. woui� Qe lielpiul to focus future efforts.
Bolin i oerfer, Duke Energy, asked if comments on the other six puke Energy Progress, LLC. {DEP) models
would be forthcoming �o Relp locus the worn to specific transects of interest. Steve Laster indicated
that DEQ comments are fo<<h-coming buy nog sure of exac� aiming. ,oho �oepier inRicaie� it woulia tse
�ener��ial to have an extension for submittal of sites other than Sut�on �o capture she pending
commen�s. ��eve [osier reques�ee tRat Dune Enerby p�o.ide a letter askinti for the extension and a
plan for what will be provided.
Ted Campbell sugges�e0 a follow-up action item woelia �� ror suture submittals to better ex,,lain the
rationale and applicability of she global geochemical model as a quali;wive. preaiaive pool ane 11ow it
can Qe used io evaleate possible chanties as a result of the anticipated remedial actions.
Pro osed Path Forward for Sutton Geochemical Modelin
6asea on the aRove saiscussion, Dune Energy will update the Sutton tieochemical model in order �ha� i�
be mare sire -specific as reques�ed by DEQ. µlong wits �I1a�, the rational anti applicability of the global
model will be further described on a site specific basis �o support a beer unders�anding of sire specific
conditions ane pateniia! ruiure cnanties to site conditions that may occur as a result of remedial action.
Mare specifically for Su«on:
- The geochemical model for Sutton will be run to examine �11e sianiliry of iron ons aluminen�
phases across the geochemical candi�ions of ►he sire (DEu ueneral Comment � � � rrom the
above -referenced lett�rj. More specific �o General Commen� �_ solid phase Cul concentrations
will b� used in the PHREEQC model where available. The sys�ems when bash she solid phase
ons aMeeous phase COI concentrations are available are the ideal sys�ems �o model using
PFIREEQC ansa to ia�termine if the distribution can be predicted. However, due Lo sire condi ions
(such as oearocx flow zones, not applicable to Suttonl the solid phase data may not be available
�hroughou� all Transect areas.
• vvhen peRarming simula�ions esing site-specific groundwater ion concentrations, simulations
using she Fe{II)/Fe{IIIA aara will �e consented to buffer the redox conditions (DEQ General
Commen� as from she above -references lenerl anti compare that to simulations using the site
measured Eh values. During she call bill Deu�scR suggesie� spat auRe Ene�sy couple the
reaction to Fe{Ilj/Fe{OHj3{sj. Duke Energy apprecia�ed chis feeoGacR ansa will aRempt anis rattier
than using aqueous Fe{Illj values.
- DEQ General Commen� 3 from she above -references letter requested ailiaiiional
discussion on fil�ra�ion �es�ing. � his will be incorporate0 as part or the site-specific
models, targeting the analysis �o specific COIs where colloid �ranspoR cou10 Have an
impact.
- The site densities of iron and aluminum will be modified in the new sire-specirc models.
The information wi11 then be used as a comparison �o she global model.
- A fully integrated geochemical specia�ion/reaRive �ranspoR moQel will not Ge
conducted. Rather changes in Ko values across she �ranseRs will be compared ro Elie Rd
values reWuired in the flow and transport models �o approxima�e re�arda�ion of she
3
Mr. Jay Simmerman letter
5�ptem6�r Z9, 2D16
COIs. Note complete agreemen� is essen�ially impossible for many of she %uls which
have a sienificant naturally occurring component because of the uncertainty in she
lo�at;o�, of a source term" for example, sources of iron and manganese are ubi4uitous,
in addition to wfiai may fie derived from the ash basinsl.
i die sites ,pe�ir,c model transects will focus onsite specific COIs except where the global
model dna file wafer quality r�;elts i�aicate that Kdvalues will not change significantly
(up or down) fay cRanging site conditions. Recall tRai �f'i� r�toraation factor, R, is the
bes� measure of cons�i�uent mobility an0 tPiat Rd is included in tf3e calculation. � Ae rale
and �ranspoR model uses she re�arda�ion factor co model consti�uenz migration.
For �ut�on_ the site specific geocnemical moiacl inTor,,,ocion ..ill be provided by November 1, 2016 as
reques�ed. For she remaining six DEr facilities, tRe up�ate� geocnemical rnoa�lins .ill be comYleted in
a fashion similar �o �ha� for Su«on. puke Energy requests dna extension f3eyona Idovemner 1 for tRese
six facilities and as specific DEQ commence have nog been received. nuke Energy will update the
geochemical model for these six facili�ies wi�hin 90 days of receip� of specific Df*u commen�s and
requested flow transects.
nuke Energy appreciates tfie Open ai,ca�;;on regarding the DEP beochemical models. if you have any
ques�ions or need any clarification regarding tf�e inrormation pro�itl��, please contact Ed Sullivan at
ed.sullivanC�duke-enersv.corn or at ysD-�»-s,ly at your convenience.
RespeRTully suf3mitt�o,
Rarry R. �iaeris
SVP — Environmenr.al. P9eal�h � safety
cc/a«: Mr. Bill ICliller—ADR
Ms. Kathy Webb — SynTerra
ICIr. Ryan Czop —17uRe Enemy
Ms. Kim vviu—Duke Energy
Mr. Ed Sullivan —Duke Energy
IOIr. �oRn i oepfer —Duke Energy
4
Rt�tacRntent 1
DEq/Duke Energy Conference Call
September 15, 2016
Ati�..Dunacyio Phone
Sieve Lamer— DEQ Cenral office
Eric �miih —DEQ C�ncrai Office
Ted Campbell —DEQ Asheville Regional Office
'aeon Regie, — DEQ wil,�.in5ton Regional Office
Morella Sanchez -King --DEQ Wilmington Regional Office
bill Deutsch — DEQ Cvntru�o�
john ioepier—Dune Enema
Kathy Webb—SynTerra Corporation
Perry vvaiGrep - syn i erra Lorpo�arion
Erin Black - Synierra Corporacion
Dr. Ran Faha - syn � erra Corporation
Or. Brian Powell -SynTerra Corporacion
Codd vvilson—P9DR inc.
Bill Miller—HDR, Inc.