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HomeMy WebLinkAboutNCDEQ 02-02-17 JZimmermanDUKE ENERGY, February 2, 2017 Mr. S. Jay Zimmerman, P.G. Director, Division of Water Resources North Carolina Department of Environmental Quality 1611 Mail Service Center Raleigh, NC 27699-1611 Paul Draovitch Senior Vice President Environmental, Health & Safety 526 S. Church Street Mail Code: EC3XP Charlotte, NC 28202 (980) 373-0408 RE: Response to DEQ Letters Dated December 21, 2016 & January 11, 2017 Facility Interim Monitoring Plans Networks and Sampling Requirements and Corrections Thereto Dear Mr. Zimmerman: Duke Energy is in receipt of the above referenced letters from you which specify surface water, seep and groundwater monitoring well locations that are to be sampled quarterly beginning second quarter of 2017. Below Duke Energy provides general comments applicable to all 14 active and retired coal-fired facilities across the state. Site specific comments are also enclosed in Attachment 1. The comments below are grouped by Surface Water/Seep, Groundwater and Annual Reporting. Surface Water/Seep General Comments Currently there are a number of overlapping regulatory requirements that require various sampling efforts of seeps and surface waters. These requirements are largely intended to cover sampling and identification efforts until such time as any NPDES permit coverage is obtained. As such, we believe that any seep or surface water location specified in the above -referenced letters that is authorized in an NPDES permit or considered for coverage and confirmed by DEQ to not require NPDES permit coverage should not be sampled as part of the Interim Monitoring Plan effective immediately. Sampling results associated with NPDES permitted points are submitted monthly on required Discharge Monitoring Reports. Duke Energy will also include these results within the groundwater and other media updates provided to DEQ monthly. We request your timely concurrence with this position as soon as possible. With Riverbend as an example, the recently renewed NPDES permit authorizes seep discharges. Therefore, seep and surface water sampling will not be included in the Interim Monitoring Plan or Discharge Identification Plan (DIP) required by the Coal Ash Management Act. Rather, as NPDES permits are updated, sites will move from sampling seep and surface water locations under the Interim Monitoring Plan and DIP to that as specified by the updated NPDES permit. As noted above, the results of sampling required by the permit for any given month will still be submitted to DEQ in the monthly groundwater data submittal. Further, while the parameter list for seeps and surface water under the Interim Monitoring Plan will be the parameter list completed during Quarter 4 of 2016, as the NPDES permits are updated, the parameter list will change to that as specified in the NPDES permit. This is appropriate given that the NPDES permit evaluation requirements utilize conservative statistical analysis as to what chemical constituents require analysis and/or have a "reasonable potential" to cause contravention of receiving surface water criteria. Page 1 of 3 In accordance with established procedures and guidance found in the EPA's Zone of initial dilution guidance, NPDES Permit writers manual (Section 6.2.5)and the Water Quality Standards handbook (Section 5.), determination of compliance with 15A NCAC 28 surface water criteria will be determined after appropriate mixing and/or dilution credits are considered. This will be determined by sampling within appropriate, well -mixed surface water locations. The language in the December 21, 2016 letter states, "Surface water sampling locations will be situated adjacent to the bank of the surface water body where potential discharge of contaminated groundwater may enter as base flow." This language and interpretation is contrary to the referenced citations and inconsistent with state and federal surface water guidance and practice. Groundwater General Comments There are some discrepancies between proposed groundwater monitoring lists specified in the Comprehensive Site Assessment Plans and Corrective Action Plans Part 1. In order to eliminate confusion, Duke Energy proposes to sample the following constituents in groundwater as part of the quarterly Interim Monitoring Plans: aluminum, antimony, arsenic, barium, beryllium, boron, cadmium, calcium, cobalt, chromium, copper, iron, lead, magnesium, manganese, molybdenum, mercury, nickel, potassium, selenium, sodium, strontium, thallium, vanadium, zinc, chloride, sulfate, alkalinity, bicarbonate, carbonate, total dissolved solids (TDS), total suspended solids (TSS), sulfide, total organic carbon (TOC) and radium 226 & 228. Duke Energy proposes to continue to sample for sulfide and TOC as these parameters can assist determinations for monitored natural attenuation (MNA). Radium 226 & 228 will be included in the constituent list at only select wells as noted in the site specific comments in Attachment 1. Duke Energy proposes to discontinue sampling for methane and hexavalent chromium. The North Carolina 2L groundwater standard for chromium is 10 ug/I and this standard was developed under the assumption that all of the chromium was in the hexavalent state. Therefore, there is no need to continue to speciate chromium. Annual Report General Comments With regard to the Annual Interim Monitoring reports, Duke Energy interprets that the first report would be submitted to DEQ by April 30, 2018 and would consist of data and interpretations from the three sampling events in 2017 (Quarter 2 through Quarter 4). Subsequent annual reports would consist of data and interpretations from four annual sampling events (e.g., the April 30, 2019 report would summarize data collected during the four quarters of 2018). Duke Energy would like to meet and discuss with DEQ the format and content of the requested Annual Interim Monitoring Report. Duke Energy and DEQ agreed to a Table of Content for the Basis of Design Report for accelerated remediation and Duke Energy seeks something similar here. This agreed -to Table of Contents would allow Duke Energy and our consultants to prepare the requested Annual Interim Monitoring Report for submittal to DEQ by April 30, 2028. Closing Thank you for your attention to this matter. Duke Energy would appreciate the ability to meet with your staff and regional office individuals to discuss these responses and proposals. As sampling is expected to begin April 1, 2017, the details need to be agreed to well in advance of April 1". If you have any Page 2 of 3 questions or need any clarification regarding the information provided, please contact Ed Sullivan at ed.sullivan@duke-enerev.com or at 980-373-3719 at your convenience. Respe ully submitte Paul Draovi SVP — Environmental, Health & Safety cc: Ed Sullivan — Duke Energy Mark Filardi - HDR Kathy Webb — Synjerra DEO Regional Offices Page 3 of 3 Attachment 1 to the S. Jay Zimmerman Letter Dated February 2, 2017 Site Specific Comments to the Interim Monitoring Plans Allen Steam Station — Belmont, NC Groundwater Monitoring Location Comments and Clarifications • AB-8 was a voluntary monitoring well abandoned in 2010. Suggest removing from sample list. • GWA-91311 was not included on the sample list. Suggest adding to the sample list. • DEQ added the following replacement wells that were not previously agreed upon: AB-21D, AB- 25BRU, AB-25BR, and AB-31D. o AB-21D —wells AB-20D (located to the west) and AB-22D (located to the east) are viable transition zone wells (for future sampling) located along the same transect as AB-21 wells. Due to AB-216RL providing vertical delineation at this well cluster and high pH in AB-21D, do not suggest reinstalling AB-21D or continuing to sample AB-21D at this time. o AB-25BRU and AB-25BR—wells AB-24BR (located to the west) and GWA-31311 (located to the east) provide delineation in the bedrock flow layer. If going to reinstall, why install both AB-25BRU and AB-25BR? Suggest reinstalling only AB-25BRU due to bedrock wells being located west and east to provide delineation if a D/BRU well is needed within the footprint of the north portion of the active ash basin. If AB-25BR is not reinstalled, do not suggest continuing to sample AB-25BR due to high pH and the BR wells located to the west and east provide delineation. o AB-31D —wells GWA-4S/D/BR are located immediately downgradient of AB-31S/D. Due to GWA-4D being located downgradient and between the ash basin and the Catawba River, do not suggest reinstalling AB-31D or continuing to sample AB-31D due to high pH. DEQ did not note that reinstallation is planned for wells GWA-5BR and GWA-21D. For consistency purposes, asterisks should have been added to 13G-11), BG-2BR, GWA-3BR, and GWA-14D. Wells that have exhibited high pH (>10 SU) that were not noted by NC NCDEQ include: AB-21BR, AB-23BRU, AB-24D, AB-26D, AB-35D, GWA-23D, GWA-24D, GWA-24BR. o AB-21BR — assuming AB-21BRL is a viable well to continue sampling (have not seen field parameters or results from this well), do not recommend continuing to sample AB-21BR due to high pH. o AB-23BRU — do not recommend continuing to sample AB-23BRU due to high pH, or it may need to be reinstalled. In addition, it's not located along an anticipated transect and there are transition zone wells located upgradient and downgradient of this part of the ash basin. o AB-24D — a bedrock well is located at this well cluster to provide vertical delineation. Do not recommend continuing to sample AB-24D due to high pH. o AB-26D — due to wells GWA-3S/D/BR being located immediately downgradient of AB- 26D at the toe of the dam, do not suggest continuing to sample AB-26D due to high pH. o AB-35D—due to AB-35BR not exhibiting high pH and providing vertical delineation at this well cluster, do not suggest continuing to sample AB-35D due to high pH. o GWA-23D — pH has been high but decreasing to nearly below 10 SU, therefore recommend continuing to monitor GWA-23D. Attachment 1 February 2, 2017 o GWA-24D and GWA-24BR- wells are located upgradient of the site and GWA-9D/BR provide upgradient results and delineation west of the active ash basin. Do not suggest continuing to sample GWA-24D and GWA-24BR due to high pH. o Note that we recommend collecting water levels only from all these wells during future sampling events. • GWA-24S -similar to the suggestion for GWA-24D and GWA-24BR, GWA-9S provides upgradient results and delineation west of the active ash basin. GWA-24S has not produced enough water to sample during previous sampling events. Do not suggest continuing to sample GWA-24S, but rather collect water levels only from this well during future sampling events. • Suggest collecting water levels only from GWA-18S/D, GWA-19S/D, and GWA-26S/D. Proposed Radionuclide Monitoring Locations The following wells are suggested for the radionuclide monitoring requested: AB-41311, AB-41), A13-4S, BG-2BR, BG-2D, BG-2S, GWA-21BR, GWA-21D, GWA-21S, AB-6A, A13-611, AB-91), AB-9S, AB-10D, AB-10S, AB-11D, GWA-1BR, GWA-1D, GWA-1S, GWA-21), GWA-25, GWA-3BR, GWA-31), GWA-3S, GWA-4BR, GWA-41), GWA-4S, GWA-5BR, GWA-51), GWA-55, GWA-6BR, GWA-6DA, GWA-6S, GWA-7D, and GWA-7S. Note that wells BG-2BR, GWA-21D, GWA-31311, GWA-5BR are being replaced. Radionuclide monitoring is recommended for the replacement well after installation. Asheville Steam Electric Plant - Arden, NC Groundwater Monitoring Location Comments and Clarifications • As previously documented, due to the lack of sufficient well recharge, the following wells are only appropriate for use as piezometers and therefore will be included for collection of water levels only for the IMP: MW-3BR, MW-15BR, C13-813, MW-81311, B-1, B-1A, B-2, MW-7BR, P-102, P-103, MW-19BR, APZ-30, AMW-2B, C13-1613 and CB-18RL. • MW-1D, MW-1BR and PZ-26 have been abandoned in the recent past due to the construction of the combined cycle plant in the footprint of the 1982 basin. PZ-16 has turbidity issues and has not been proposed for replacement. • As previously documented, AMW-3A has elevated pH despite redevelopment efforts. Well replacement has not been recommended at this location due to limited access. • MW-11D, MW-21D and MW-22BR are recommended for inclusion in the IMP. The addition of these wells will facilitate monitoring of various flow zones downgradient of the source area as well as conditions adjacent to the unnamed tributary of the French Broad River south of the site. • CB-1 and CB-9 (NPDES compliance monitoring wells), designated as background wells, are also recommended for inclusion in the IMP to monitor background conditions. Proposed Radionuclide Monitoring Locations • The following wells are suggested for the radionuclide monitoring requested: MW-24S, CB-9, CB-9SL, C13-91313, CB-1, CB-11), MW-10, AMW-3B, MW-3D, GW-5, MW-6S, MW-6D, MW-68R, GW-4, PZ-19, PZ-17S, PZ-17D, GW-3, MW-9S, MW-9D, MW-9BR, CB-81311, MW-15A, MW-15D, MW-16A, MW-16BR, MW-18D, MW-18BR, MW-18BRL, AMW-1B, MW-21D, MW-22D and MW- 22BR. Attachment 1 February 2, 2017 Surface Water and/or Seep Monitoring Location Comments and Clarifications The following locations are suggested to be sampled until the pending NPDES permit is updated: A-01, B-01, C-01, E-01, F-01 and P-01. Recent observations of E-01, F-01 and F-02 have found insufficient water to sample. Proposed locations will be observed and sampled if sufficient water is present until monitoring under the new NPDES permit begins Belews Creek Steam Station - Belews Creek, NC Groundwater Monitoring Location Comments and Clarifications • Wells MW-102S and MW-102D have been abandoned and should be removed from the sampling list. • Wells GWA-4D and GWA-5S/D/BR2 will be abandoned in January 2017 and should be removed. These wells are being abandoned due to construction taking place at these locations. Any replacement wells for these wells should be added after installation. • Wells that have exhibited high pH (>10 SU) that were not noted by NC NCDEQ include: AB- 4SL/BR, GWA-101), GWA-16D/BR. o AB-4SL-This well has shown pH>10 SU since Round 1 sampling in July 2015 and is not recommended for continued sampling. AB-5SL is in the vicinity of AB-4SL and should be acceptable as a sample location for this area. o AB-4BR - This well has shown pH>10 SU since Round 1 sampling in July 2015 and is not recommended for continued sampling. o GWA-10D -This well has shown pH>10 SU since Round 1 sampling in July 2015 (except in May 2016 which has a pH of 0.3 SU) and is not recommended for continued sampling. This well is planned to be abandoned and replaced due to grout contamination. The replacement well should be added for sampling after installation. o GWA-I6D-This well has shown pH>10 SU since Round 1 sampling in July 2015 and is not recommended for continued sampling. This well is planned to be abandoned and replaced due to grout contamination. The replacement well should be added for sampling after installation. a GWA-I6BR-This well has shown pH>10 SU since its first round (Round 5) of sampling in April 2016, however pH has been dropping (from 12 to 10.6 SU) and sampling should continue in order to see if pH will drop be low 10 SU. Proposed Radionuclide Monitoring Locations • The following wells are suggested for the radionuclide monitoring requested: BG-1S, BG-1SD BG- 2S, BG-21), 8G-3S, BG-4D, GWA-1S, GWA-11), GWA-iBR, GWA-6S, GWA-61), GWA-7S, GWA-71), GWA-8S, GWA-81), GWA-24S, GWA-241), GWA-251311, GWA-26S, GWA-261), GWA-26BR, GWA- 30S, GWA-301), MW-3, MW-200S, MW-200D, and MW-200BR. Note that well BG-2BR is being replaced. Radionuclide monitoring is recommended for the replacement well after installation. Buck Steam Station - Salisbury, NC Groundwater Monitoring Location Comments and Clarifications • Monitoring well BG-2BR does not exist and has never been proposed. Remove from sample list. • Three well ID's were in question: AB-9D/BRU, BG-3D/BRU and GWA-12D/BRU o The correct IDs for these wells are AB-9BRU, BG-3BRU and GWA-12BRU. o HDR will revise any analytical results tables where there are discrepancies with IDs Attachment 1 February 2, 2017 o Suggest notifying the sampling crews of the correct IDs. Revising the well tags may be needed to ensure consistency. • Monitoring wells GWA-16S/D/BR are planned to be installed before Q2-2017. Note that DEQ did not include GWA-16SR on the sample list. We also recommend including GWA-16BR in the Interim Monitoring Plan once installed. Results from this cluster may end up being able to be included in the PPBTV determinations. • The following wells were not included on the sample list, but should likely be added: AB-5SL, GWA-28RU, GWA-14S, MW-2D, MW-8S, and GWA-16BR (as mentioned above). • An asterisk was provided for AB-5S in the sample list, but reinstallation is not necessary. We recommend removing the asterisk • DEQ did not note that reinstallation is planned for wells AB-9BRU, AB-9BR, GWA-2BR, GWA-98R, and GWA-18D. For consistency purposes, asterisks should be added for these wells. • Wells that have exhibited high pH (>10 SU) that were not noted by NCDEQ include: AB-21311, AB- 4BR, AB-5BRU, AB-75L, and GWA-14D. o AB-21311 - spatial coverage of bedrock wells downgradient to the north and west, and upgradient to the south provide delineation within the bedrock flow layer. pH has been dropping and getting close to 10 during recent sampling events. Suggest additional development to see if pH will continue to drop. Suggest keeping AB-2BR on the sample list due to exceedances reported in AB-2D. o AB-4BR - assuming AB-4BRL is a viable well to continue sampling (have not seen field parameters or results from this well), do not recommend continuing to sample AB-413R due to high pH. o AB-5BRU - spatial coverage of deep wells downgradient and upgradient in this area of Cell 3 (AB-4BRU, AB-6BRU, AB-81) and AB-7BRU) provides delineation with the deep flow layer. Do not suggest continuing to sample AB-5BRU due to high pH. o AB-7SL - well AB-7S provides source concentrations in porewater at this well cluster. Also, there are five other porewater wells located in Cell 2 that can be used for collecting source concentration data (AB-4S/SL, AB-5S/SL, and AB-8S). Do not suggest continuing to sample AB-7SL due to high pH. o GWA-14D - assuming GWA-14BR is a viable well to continue sampling (have not seen field parameters or results from this well), do not recommend continuing to sample GWA-14D due to high pH. o Note that we recommend collecting water levels only from all these wells during future sampling events. Proposed Radionuclide Monitoring Locations The following wells are suggested for the radionuclide monitoring requested: BG-3BRU, BG-3S, GWA- 15D, GWA-15S, GWA-16BR, GWA-16D, GWA-16S, MW-6D, MW-6S, MW-8BR, MW-8D, MW-8S, GWA-413, GWA-4S, GWA-5BRU, GWA-5S, GWA-6BRU, GWA-6BR, GWA-6S, GWA-7D, GWA-75, GWA-9BR, GWA-91), GWA-9S, GWA-12BRU, GWA-12S, GWA-18D, GWA-18S, GWA-19D, GWA-195, GWA-20D, GWA-20S, GWA-22D, MW-3D, MW-3S, MW-9S, MW-11BR, MW-11D, and MW-11S. Note that wells MW-8BR and GWA-18D are being replaced. Radionuclide monitoring is recommended for the replacement well after installation. Note that wells GWA-168R, GWA-16% and GWA-16S are planned for installation in Q1- 2017. Suggest sampling for radionuclides in Q1, Q2, Q3, and Q4 in 2017, and evaluating the need for further radionuclide sampling after Q4-2017. Attachment 1 February 2, 2017 Cape Fear Steam Electric Plant - Moncure, NC Well Replacement and Installation Comments and Clarifications • As previously documented and agreed upon with DEQ RRO, well CMW-5 will be abandoned and replaced. Replacement well (CMW-5R) will likely be installed slightly deeper than the original so the entire screened interval is within sandy deposits of the lower surficial zone. • Similarly, as previously documented and agreed upon with DEQ-RRO, an additional well cluster (MW-24) will be installed east of the existing MW-23 well cluster. The MW-24 wells will be located adjacent to the Duke Energy property boundary and will consist of, at a minimum, a well installed within the surficial zone and a well installed within bedrock. An additional well may be installed if a discrete zone is identified and is of sufficient thickness for monitoring. Groundwater Monitorine Location Comments and Clarifications • Replacement well CMW-5R and wells in the planned MW-24 cluster will be included in the IMP, once installed. • Although requested by DEQ-RRO for groundwater sampling, wells ABMW-35, MW-14, and MW- 51311 have been abandoned and therefore cannot be used for routine monitoring. Replacement wells ABMW-3SR and MW-SBRR will be sampled instead. MW-14 has not been replaced. However, well CTMW-8 is located adjacent to the former MW-14 and will be used to monitor bedrock groundwater quality in the area. • The DEQ-RRO-requested sampling location CHATH-79-P100 is a piezometer installed within the west dike of the 1985 ash basin. Although sampled inadvertently in 2015, when it was mistaken for to be well PZ-5, results from those samples may be misleading since the screen interval of the piezometer is constructed within dike fill materials; the piezometer was not constructed to be used for water quality monitoring; and the piezometer has not been properly developed. Well PZ-5 is used to monitor groundwater quality on the west side of the 1985 ash basin. Therefore, piezometer CHATH-79-P100 should be omitted from the list of wells sampled as part of the Interim Monitoring Program. • The DEC! RRO-requested sampling location CF-2 is a private water supply well located off of Duke Energy property and across the Haw River in an upgradient direction from the Cape Fear Plant. Previous sampling was conducted by DEQ and analytical results indicate the well is not affected by potential constituents of concern from the Cape Fear plant. Routine quarterly monitoring as part of the IMP would require frequent contact and coordination with the well owner that may be unnecessarily burdensome on that owner. If continued and routine sampling of this private supply well is determined necessary, then it may be more appropriate for North Carolina officials to coordinate and conduct this sampling and on a less frequent basis. If routine sampling of this private well is determined unnecessary, omit this well from the list of wells sampled as part of the IMP. Proposed Radionuclide Monitoring Locations • The following wells are suggested for the radionuclide monitoring requested: ABMW-1, ABMW- 1S, ABMW-1BR, ABMW-3, ABMW-3SR, ABMW-4, ABMW-4S, BGMW-4, BGTMW-4, CMW-1, CTMW-1, CMW-3, CMW-6, CMW-7, CMW-8, CTMW-8, MW-6BR, MW-9, MW-9BR, MW-10, MW- 10BR, MW-11, MW-12, MW-15SU, MW-15SL, MW-15BR, MW-165, MW-16BR, MW-17SU, MW- 17SL, MW-185, MW-21SU, MW-21SL, MW-235, MW-23D, PZ-5, and planned wells MW-24S and M W-24D. Attachment 1 February 2, 2017 Surface Water and/or Seep Monitoring Location Comments and Clarifications • The DEQ's requested sampling location southeast of the 1985 ash basin can be included in the IMP. However, the exact sampling location should be vetted by DEQ as the approximate GPS coordinates provided in DEQ's December 21, 2016 letter do not directly correspond with previously sampled locations such as SW-85DS (located 300 feet southwest) or 5-10 (located further southwest). • The DEQ-requested sampling locations S-1 and S-6 are typically dry. Flow is routinely observed in separate water bodies proximate to both locations. If the intended sample locations are somewhere other than at S-1 and S-6, then exact sample locations should be vetted with DEQ. • Samples have previously been collected from the DEQ-requested sampling location along "Branch A at crossing of Railroad spur" as location "SW-BA2". Samples will continue collected from this location as part of the IMP using the SW-BA2 designation. • DEQ's requested sampling location "SW-UNTA" is presumed to be located where samples were collected during the CSA activities at a location named "SW-UNT". This location is adjacent to Outfall 007. Therefore, samples will not be collected from "SW-UNTA". However, if DEQ's intended location for "SW-UNTA" is different than "SW-UNT", then the additional sampling location should be vetted by DEQ before potentially being included in the IMP. Cliffside Steam Station (James E. Rogers Energy Complex) -- Mooresboro, NC Groundwater MonItorinR Location Comments and Clarifications The following wells have either not be installed or may have been abandoned. • AB-7BR has not be installed at the site. • AS-7BRL has not be installed at the site. It was proposed but not installed due to lack of a water bearing bedrock fracture. • GWA-1D has not be installed at the site. GWA-1BRU is the correct well ID and is listed on the monitoring plan. • GWA-29S has not be installed at the site. Groundwater was not encountered above refusal at this location. • MW-34D has not be installed at the site. MW-34BRU is the correct well ID and is listed on the monitoring plan. • US-3D may have been abandoned. This needs to be field verified. If it has been abandoned it will not be able to be sampled. • GWA-46B has not be installed at the site. GWA-46D is the correct well ID and could be added to the monitoring plan. • GWA-48S has not be installed at the site. Groundwater was not encountered above refusal at this location. • GWA-21D has not be installed at the site. GWA-21BRU is the correct well ID and is listed on the monitoring plan. • GWA-22D has not be installed at the site. GWA-22BRU is the correct well ID and is listed on the monitoring plan. • CLMW-5D may have been abandoned. This needs to be field verified. If it has been abandoned it will not be able to be sampled. • GWA-46S has not be installed at the site. Groundwater was not encountered above refusal at this location. • GWA-47S has not be installed at the site. Groundwater was not encountered above refusal at this location. Attachment 1 February 2, 2017 • GWA-13BRU has not be installed at the site. GWA-13BR is the correct well ID and is listed on the monitoring plan. • US-25 has not be installed at the site. Groundwater was not encountered above refusal at this location. The following wells have been abandoned and cannot be sampled: • CLMW-4, GWA-27D, IB-1D, IB-lS, IB-2S-SL, IB-4S-SL, MW-4D, U5-3S-A, US-7D, U5-7S, U5-7SL, and MW-2D. The following wells were installed for water level measurements only and were not constructed/intended to be sampled for analysis. • GWA-39S, GWA-42S, CLP-1, and CLP-2 Recommended not sampling due to pH>10 consistently: • GWA-22BRU — Well is scheduled for replacement. • GWA-25D — Based on discussions with DEQ well was decided to be used for water level measurements only. • GWA-30BRU — Discussion pending with DEQ to determine if this well will be replaced in the future. • GWA-32BRU — Discussion pending with DEQ to determine if this well will be replaced in the future. • GWA-45D — Discussion pending with DEQ to determine if this well will be replaced in the future. • GWA-61) — Discussion pending with DEQ to determine if this well will be replaced in the future. • MW-11D — Discussion pending with DEQ to determine if this well will be replaced in the future. • MW-42D — Well is scheduled for replacement. • U5-4BR — Well is scheduled for replacement. Regarding the sample IDS missing from the master spreadsheet: • GWA-13BR — Data added to master spreadsheet. • GWA-20BR — Newly installed well. Data will be added when available. • GWA-27BR — Newly installed well. Data will be added when available. • GWA-2BR — Newly installed well. Data will be added when available. • GWA-30BRU — Data added to master spreadsheet. • GWA-38S —Water level only well that was not installed. • GWA-46B — Well ID is incorrect. Should be GWA-46D. Newly installed well. Data will be added when available. • GWA-48BR — Data added to master spreadsheet. • GWA-48S — Well not installed. Groundwater was not encountered above refusal at this location. • IB-2S-SL — Data added to master spreadsheet. • IB-4S-SL— Data added to master spreadsheet. • MW-2D — No data available. Well was abandoned and replaced with MW-2D-A. • MW-2D-A — Data added to master spreadsheet. • MW-38BR — Newly installed well. Data will be added when available. • U5-5BR — Newly installed well. Data will be added when available. • GWA-29S - Well not installed. Groundwater was not encountered above refusal at this location. • CLP-1— Well was installed for water level measurements only. No data available. • CLP-2 — Well was installed for water level measurements only. No data available. • GWA-21D - has not be installed at the site. GWA-21BRU is the correct well ID and data is included in the spreadsheet. Attachment 1 February 2, 2Q17 • GWA-22D - has not be installed at the site. GWA-22BRU is the correct well ID and data is included in the spreadsheet. • CLMW-SD - No historical data available. Need to field verify if this well has been abandoned. • MW-23BR-Well ID is incorrect. Should be MW-23DR. Data is included in spreadsheet. • GWA-46S - Well not installed. Groundwater was not encountered above refusal at this location. • GWA-47S - Well not installed. Groundwater was not encountered above refusal at this location. • GWA-13BRU - has not be installed at the site. GWA-13BR is the correct well 1D and data is included in the spreadsheet. • GWA-29S - Well not installed. Groundwater was not encountered above refusal at this location. • US-2S - Well not installed. Groundwater was not encountered above refusal at this location. • GWA-1D - has not be installed at the site. GWA-iBRU is the correct well ID and data is included in the spreadsheet. Proposed Radionuclide Monitoring Locations • The following wells are suggested for the radionuclide monitoring requested: BG-1S, BG-1D, BG- 2D, CCPMW-1S, CCPMW-1D, MW-24D, MW-24DR, MW-30S, MW-301), MW-32S, MW-32D, MW- 32BR, GWA-2S, GWA-2BRU, GWA-2BR, GWA-4S, GWA-41), GWA-11S, GWA-11BRU, GWA-20S, GWA-20D, GWA-20BR, AS-2S, AS-21), GWA-21S, GWA-21BRU, GWA-216R, GWA-27D-A, GWA- MR, MW-38S, MW-38D, MW-38BR, GWA-36S, GWA-36D, GWA-29D, and GWA-22S. Note that monitoring well GWA-22BRU is being replaced due to high pH. Radionuclide monitoring is recommended for the replacement well after installation. Surface Water and or Seep Monitoring Location Comments and Clarifications • CLFSTRO53 (NCDEQ sample ID) and S-3 (Duke sample ID) are the same sample location. Recommend collecting S-3 and removing CLFSTRO53 from the monitoring plan. • CLFTDO04 (NCDEQ sample ID) and S-2 (Duke sample ID) are the same sample location. Recommend collecting S-2 and removing CLFTDO04 from the monitoring plan. • CLFWW57 is NPDES outfall 002. The outfall is sampled under the NPDES permit and recommend removing it from the monitoring plan. • CLFSP051(NCDEQ sample ID) and S-10 or S-11(Duke sample ID) are the same sample location. Recommend collecting S-10 and S-11 and removing CLFSP051 from the monitoring plan. • CLFTDO52 (NCDEQ sample ID) and S-10 or S-11(Duke sample ID) are the same sample location. Recommend collecting 5-10 and S-11 and removing CLFTD052 from the monitoring plan. • CLFSP058 (NCDEQ sample ID) and S-5, S-23, or S-24 (Duke sample ID) are the same sample location. Recommend collecting S-5, S-23, and S-24 and removing CLFSP058 from the sampling plan. • CLFSP059 (NCDEQ sample ID) and 5-12 (Duke sample ID) are the same sample location. Recommend collecting S-12 and removing CLFSP059 from the sampling plan. • CLFSP061(NCDEQ sample ID) and S-14 (Duke sample ID) are the same sample location. Recommend collecting S-14 and removing CLFSP061 from the monitoring plan. • CLFTDO05 (NCDEQ sample ID) and S-18 or S-19 (Duke sample ID) are the same sample location. Recommend collecting S-18 and S-19 and removing CLFTDO05 from the monitoring plan. • CLFSP060 (NCDEQ sample ID) and 5-4 (Duke sample ID) are the same sample location. Recommend collecting S-4 and removing CLFSP060 from the monitoring plan. • CLFSTR064 (NCDEQ sample ID) and S-7 (Duke sample ID) are the same sample location. Recommend collecting S-7 and removing CLFSTRO64 from the monitoring plan. Attachment 1 February 2, 2017 • CLFSTR065 (NCDEQ sample ID). In looking through the sample information it appears that this sample came from the Broad River. Surface water sample locations SW-10A, SW-10B, and SW- 10C are located downstream in the Broad River from CLFSTR065 and are included in the monitoring plan. Recommend removing CLFSTR065 from the monitoring plan. • S-9 should be removed from the monitoring plan due to safety hazards obtaining this sample. The terrain getting to the sample is steep and adjacent to a 30-foot drop at the retaining wall. Dan River Steam Station -- Eden, NC Groundwater Monitoring Location Comments and Clarifications • Wells that have exhibited high pH (>10 SU) that were not noted by DEQ include: o Well BG-iD-This well is planned to be abandoned and replaced due to grout contamination. The replacement well should be added for sampling after installation. o AB-10D -This well has shown pH>10 SU since Round 1 sampling in June 2015 and is not recommended for continued sampling. o MW-317BR -This well has shown pH>10 SU since Round 1 sampling in June 2015. Assuming MW-317BRL is a viable well to continue sampling; MW-317BR is not recommended for continued sampling. Proposed Radionuclide Monitoring Locations • The following wells are suggested for the radionuclide monitoring requested: BG-10S, BG-101), BG-10BR, GWA-6S, GWA-61), GWA-9S, GWA-91), GWA-18S, GWA-18D, MW-10, MW-10D, MW- 11, MW-111), MW-12, MW-121), MW-121311, MW-20S, MW-201), MW-22S, MW-22D, and MW- 22BR. H.F. Lee Energy Complex -Goldsboro, NC Groundwater Monitoring Location Comments and Clarifications • AMW-4BC and CMW-10 are both part of the same 'cluster' area and both monitor the surficial hydrogeologic unit. Therefore, inclusion of both wells is redundant. As CMW-10 is already part of the compliance network, AMW-4BC will not be monitored for CAMA purposes. • Due to the lack of sufficient well recharge, AMW-18BC is only appropriate for use as a piezometer and therefore will be included for collection of water levels only for the IMP. • Note that LLMW-3 is located in an area that is often covered with standing water. Access will be very difficult. With the LLMW-1 and LLMW-2 well pairs included in the IMP, this is not a necessary monitoring point. Pro osed Radionuclide Monitoring Locations • The following wells are suggested for the radionuclide monitoring requested: ABMW-1S, AMW- 11S, CCR-1005, AMW-18S, MW-3, IABMW-1S, IABMW-3S, IMW-1S, IMW-3S, IMW-4S, and IMW- 5S. Surface Water and/or Seep Monitoring Location Comments and Clarifications • Seep location S-5 is normally observed as a location of moist soil and does not normally yield water sufficient to sample. Attachment 1 February 2, 2017 Seep location 5-20 is normally observed as a location of moist soil and does not normally yield water sufficient to sample. Marshall Steam Station --Terrell, NC Groundwater Monitoring Location Comments and Clarification • Well GWA-13D was replaced by GWA-13DA. • BG-iBR should be included in the "Wells to be Sampled" list. • GWA-11BR and GWA-15S should be included in the "Wells slated for installation/reinstallation that need to be added to monitoring plan once installed" list. • BG-1BR (as noted above) is also slated for replacement due to water quality issues and should be included in the respective list. • The following FGD Residue landfill monitoring wells were added to the sample list: MS-8, MS- 10, MS-11, MS-12, MS-14, MS-15 and MS-16. Other than MS-10 (which is being sampled as a background well to support PPBTV determination), Duke Energy proposes to continue sampling MS-8, MS-11, MS-12, MS-14, MS-15 and MS-16 as part of semi-annual landfill monitoring program required by DEQ Solid Waste Section and provide data collected on the respective mid - month data submittal. • The following Dry Ash Landfill monitoring wells were added to the sample list: OB-1(dry ash LF), MW-1, MW-2, MW-3, MW-5 and MW-7. OB-1(dry ash LF) and MW-7 (referred to as 08-3 in the Post -Closure Groundwater Monitoring Program Sampling and Analysis Plan for the Dry Ash Landfill) are currently used to collect water levels only. Duke Energy proposes to collect water levels only for OB-1(dry ash LF) and MW-7. Pro used Radionuclide Monitoring Locations • The following wells are suggested for the radionuclide monitoring requested: GWA-12BR, GWA- 12D, GWA-125, GWA-6D, GWA-6S, MS-10, MW-4, MW-4D, AB-1611, AB-11), AB-1S, AB-21), AB-2S, AL-11), AL-1S, GWA-iBR, GWA-1D, GWA-1S, GWA-11D, GWA-115, GWA-155, MW-613, MW-6S, MW-7D, MW-7S, MW-8D, MW-85, MW-9D, MW-9S, MW-10D, MW-105, MW-14BR, MW-14D, and MW-145. Note that well GWA-15S is planned for installation in Q1-2017. Suggest sampling for radionuclides in Q1(dependent upon installation schedule), Q2, Q3, and Q4 in 2017, and evaluating the need for further radionuclide sampling after Q4-2017. Mayo Steam Electric Plant- Roxboro, NC Groundwater Monitoring Location Comments and Clarifications • As previously documented and agreed upon with DEQ-RRO, due to the lack of sufficient well recharge, MW-15BR is only appropriate for use as a piezometer and therefore will be included for collection of water levels only for the IMP. • MW-7D and MW-7BR will be abandoned due to the construction of a new FGD settling basin at the Mayo Plant. A formal request for abandonment was sent to DEQ RRO on January 16, 2017 and approved on January 19, 2017. • MW-9BR has turbidity issues and has been proposed for replacement. DEQ RRO and Duke Energy have agreed that MW-9BR will remain in place for use as a piezometer and a new well (MW-9BRL) will be installed and screened deeper in the bedrock flow zone. MW-9BR will be used for water levels only and MW-9BRL will be included in the IMP following installation. Attachment 1 February 2, 2017 Proposed Radionuclide Monitoring Locations • The following wells are suggested for the radionuclide monitoring requested: ABMW-4, BG-1, BG-2, CW-2, CW-2D, MW-10BR, MW-12D, MW-12S, MW-16D, MW-16BR, and MW-3. Surface Water and/or Seep Monitorinig Location Comments and Clarifications • Surface water location SW-CB1(Crutchfield Branch at the northern Mayo Plant property line) was included in the Comprehensive Site Assessment work but was not included in the IMP "Surface Water and Seep Locations to be Sampled" list provided by DEQ. SW-CB1 is proposed to be added as a surface water monitoring location to provide data for comparison with the surface water sample location further downstream/off-site (SW-CB2). Riverbend Steam Station — Mount Holly, NC Groundwater Monitorine Location Comments and Clarification • GWA-3SA and GWA-3S-A are both listed. This is the same well. Suggest removing GWA-3SA because our database has this well labeled as GWA-3S-A. • Well MW-2S/MW-2S-A identification seems to be in question. The correct well ID is MW-2S-A. o Well MW-2S was abandoned and replaced with MW-2S-A. Suggest changing sampling list from MW-2S/MW-2S-A to MW-25-A • Wells listed to be sampled that have already been abandoned. Recommend removal from sampling list. o AB-3S/D/BR, AB-4S/D, AS-5S/SL, AB-7S/I/D, AS-1S/D, AS-2S/D, AS-3S/SA/D, MW-2S (listed as MW-2S/MW-2S-A, just remove the MW-2S), and MW-12 Wells that have exhibited high pH (>10 SU) that were not noted by DEQ include: a AB-1D—This well has shown pH>10 SU since Round 1 sampling in July 2025 and is not recommended for continued sampling. o GWA-2BRU —This well has shown pH>10 SU since Round 1 sampling in July 2015 and is not recommended for continued sampling. o GWA-4BR —This well has shown pH>10 SU since Round 1 sampling in July 2015 and is not recommended for continued sampling. o GWA-5D — This well has shown pH>10 SU from Round 1 sampling in July 2015 to June 2016 (between 10.2 —10.5 SU), however pH has dropped to 9.8 SU in September 2016; sampling should continue in order to see if the pH will stay below 10 SU. o GWA-6D —This well has shown pH>10 SU since Round 1 sampling in June 2015 and is not recommended for continued sampling. o GWA-10BRU —This well has shown pH>10 SU since Round 2 sampling in September 2015 and is not recommended for continued sampling. o GWA-20BR — This well has shown pH>10 SU since Round 1 sampling in July 2015 and is not recommended for continued sampling. o GWA-21BR —This well has shown pH>10 SU in Rounds 5 and 6 in March and June 2016, respectively. This well also showed a pH of 8.4 in Round 2 in September 2015. It is recommended to keep this well on the sampling list. If pH continues to be above 10 SU well may be recommended to be removed from sampling. o GWA-23BR —This well has shown pH>10 SU since Round 1 sampling in July 2015 and is not recommended for continued sampling. Attachment 1 February 2, 2017 • The following wells are listed for abandonment and replacement due to grout contamination. Recommend removing the following wells from sampling list. The replacement wells are recommended to be added to the sampling list after installation. o BG-1D, C-1BRU, GWA-20D, GWA-23D, MW-151), MW-7BR, MW-9D, and MW-9BR Proposed Radionuclide Monitoring Locations • The following wells are suggested for the radionuclide monitoring requested: BG-4S, BG-4D, BG- OR, GWA-12S, GWA-12D, GWA-15S, GWA-22S, GWA-22D, GWA-22BR-A, GWA-2S, GWA-2BRU, GWA-2BR, GWA-4S, GWA-41), GWA-4BR, GWA-6S, GWA-61), GWA-8S, GWA-81), GWA-9S, GWA- 91), GWA-91311, MW-10, MW-14, MW-7SR, MW-7D, and MW-9. (Vote that wells GWA-15D, MW- 71313, MW-9D, and MW-9BR are being replaced due to high pH. Radionuclide monitoring is recommended for the replacement wells after installation. Roxboro Steam Electric Plant - Semora, NC Groundwater Monitoring Location Comments and Clarifications • Due to the lack of sufficient well recharge, MW-48RL and MW-21BRL are appropriate for use as a piezometer and will therefore be included for collection of water levels only for the IMP. • Well ID clarification in needed for listed well ID MW-1. It has been assumed that the intention of DEQ is to continue the monitoring of MW-1BR, adjacent to CW-1, consistent with 2016 quarterly sampling and as identified in the CSA IMP. • It has been assumed that well MW-1BRL refers to BG-1BRL as MW-1BRL does not exist at the Roxboro Site. Proposed Radionuclide Monitoring Locations • The following wells are suggested for the radionuclide monitoring requested: ABMW-2, ABMW- 2611, ABMW-5, ABMW-51), BG-1, BG-iBR, 13G-113RL, CW-2, CW-21), CW-5, GMW-6, MW-2, MW- 3611, MW-51), MW-5BR, MW-6D, MW-61311, MW-91311, MW-10BR, MW-11BR, MW-13BR, MW- 14BR, MW-15D, MW-15BR, MW-16BR, MW-17BR, MW-18D, MW-18BR, MW-19BRL, MW-23BR • Additional wells are proposed for installation around the east/west basin discharge canals and gypsum storage pad. Upon successful installation and development, Duke Energy will propose to update the Interim Monitoring Plan to include some of these wells. Sutton Energy Complex- Wilmington, NC Groundwater Monitoring Location Comments and Clarifications • MW-2C no longer exists, having been abandoned during construction of the railroad spur servicing the ash removal process. MW-13D, MW-14 and MW-16 no longer exist, having been abandoned for clearing activities in the FADA as preparation for ash removal. MW-35C no longer exists as it was abandoned prior to clearing for the new ash landfill. • MW-12, MW-61) and MW-6E are now located in the middle of the newly -constructed boat ramp access road. Based on recent sampling activities, traffic on these roads poses a significant risk which should be avoided. MW-8 is an existing well that Duke Energy recommends adding to the list to supplement the background database. Attachment 1 February 2, 2017 Proposed Radionuclide Monitoring Locations • The following wells are suggested for the radionuclide monitoring requested: MW-05C, MW- 05CD, MW-05D, MW-08, MW-23D, MW-23E, MW-27C, MW-31C, MW-36C, MW-378, MW-37C, MW-37CD, MW-37D, MW-37E, MW-38C, MW-38D, MW-39C, MW-39D, MW-40C, MW-40D, AW-03C, AW-04C. Weatherspoon Power Plant- Lumberton, NC Groundwater Monitoring Location Comments and Clarifications • Background well BW-021 has turbidity issues and background well BW-02D has apparent grout contamination (pH >11.5). Other background wells will be used for development of background concentrations. Therefore, BW-021 and BW-02D will be used as piezometers and water levels only will be collected. • Monitoring well AW-021 cannot be adequately purged using low -flow sampling techniques due to low recharge rates. Other downgradient wells will be used to assess groundwater impacts. Therefore, AW-021 will be used as a piezometer and water levels only will be collected. Proposed Radionuclide Monitoring Locations • The following wells are suggested for the radionuclide monitoring requested: ABMW-01, BW- 025, BW-03D, BW-031, BW-035, CCR-101-BG CAMA, CW-03, MW-01, MW-02, MW-3, MW-04, MW-05, MW-06, MW-07, MW-08D, MW-081, MW-085, MW-441, MW-445A, MW-491, MW-52, MW-55D and MW-551.