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HomeMy WebLinkAboutNC0003468_DRSS CSA Rpt_20150814Comprehensive Site Assessment Report Dan River Steam Station Ash Basin Site Name and Location Dan River Steam Station 900 South Edgewood Road Eden, NC 27288 Groundwater Incident No. Not Assigned NPDES Permit No. Date of Report NC0003468 August 14, 2015 Permittee and Current Property Owner Duke Energy Carolinas, LLC 526 South Church St Charlotte, NC 28202 800.559.3853 Consultant Information HDR Engineering, Inc. of the Carolinas 440 South Church St, Suite 900 Charlotte, NC 28202 704.338.6700 Latitude and Longitude of Facility 360 48' 70" N, 790 71' 80" W This document has been reviewed for accuracy and quality commensurate with the intended application. Mark Filardi, L.G. Senior Geologist Senior Geologist �>DUKE I= ENERGY )� This page is intentionally left blank. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-1 Executive Summary On August 20, 2014, the North Carolina General Assembly passed Senate Bill 729, the Coal Ash Management Act of 2014 (CAMA). Section § 130A-309.209 of the bill requires the owner of a coal combustion residuals surface impoundment to submit a Groundwater Assessment Work Plan (Work Plan) to the North Carolina Department of Environment and Natural Resources (NCDENR) no later December 31, 2014 and a Groundwater Assessment Report (herein referred to as a Comprehensive Site Assessment [CSA]) no later than 180 days following approval of the Work Plan. Duke Energy Carolinas, LLC (Duke Energy) submitted a Work Plan to NCDENR for assessment and characterization of the Dan River Steam Station (DRSS) ash basin and ash storage areas on December 29, 2014. The Work Plan was subsequently conditionally approved by the NCDENR in correspondence dated February 16, 2015. This CSA report was prepared to comply with the CAMA and is submitted to NCDENR within the allotted 180 day timeframe. Data generated during the CSA will be used in development of the Corrective Action Plan (CAP), due 90 days after submittal of this CSA. The purpose of this CSA is to characterize the extent of contamination resulting from historical production and storage of coal ash, evaluate the chemical and physical characteristics of the contaminants, investigate the geology and hydrogeology of the site including factors relating to contaminant transport, and examine risk to potential receptors and exposure pathways. This CSA was prepared in general accordance with requirements outlined in the following regulations and documents:  Classifications and Water Quality Standards Applicable to the Groundwaters of North Carolina in Title 15A NCAC 02L .0106(g);  Coal Ash Management Act in G.S. 130A-309.209(a);  Notice of Regulatory Requirements (NORR) issued by NCDENR on August 13, 2014;  Conditional Approval of Revised Groundwater Assessment Work Plan issued by NCDENR on February 16, 2015; and  Subsequent meetings and correspondence between Duke Energy and NCDENR. The assessment addresses the horizontal and vertical extent of contamination in soil, groundwater, and surface water. If a constituent1 concentration exceeded the North Carolina Groundwater Quality Standards, as specified in T15A NCAC .0202L (2L Standards) or Interim Maximum Allowable Concentration (IMAC)2, it has been designated as a “Constituent of Interest” (COI). Some COIs (e.g., iron and manganese) are also present in background monitoring wells and thus require careful examination to determine whether their presence downgradient of the ash basin or ash storage areas is naturally occurring or a result of ash 1 Constituents are elements, chemicals, or compounds that were identified in the approved Work Plan for sampling and analysis, and include antimony, arsenic, boron, chromium, cobalt, iron, manganese, selenium, thallium, vanadium, sulfate, and total dissolved solids (TDS). 2 Appendix #1 of 15A NCAC Subchapter 02L Classifications and Water Quality Standards Applicable to The Groundwaters of North Carolina, lists Interim Maximum Allowable Concentrations (IMACs). The IMACs were issued in 2010 and 2011; however, NCDENR has not established a 2L Standard for these constituents as described in 15A NCAC 02L.0202(c). For this reason, IMACs noted in this report are for reference only. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-2 handling and storage. In addition to evaluating the distribution of constituents across the DRSS site, significant factors affecting constituent transport, and the geological and hydrogeological features influencing the movement and chemical and physical character of the COIs were also evaluated. The assessment consisted of the following activities:  Completion of soil borings and installation of groundwater monitoring wells to faciliatate collection and analysis of chemical, physical, and hydrogeological parameters of subsurface materials encountered within and beyond the waste and compliance boundaries;  Evaluation of testing data to supplement the Site Conceptual Model (SCM);  Revision to the Receptor Survey previously completed in 2014; and  Completion of a Screening-level Risk Assessment. Based on scientific evaluation of historical and new data obtained during completion of the above-referenced activities, the following conclusions can be drawn:  No imminent hazard to human health or the environment has been identified as a result of groundwater migration from the ash basin or ash storage areas. Recent groundwater assessment results are consistent with previous results from historical and routine compliance boundary monitoring well data.  Upgradient, background monitoring wells contain naturally occurring metals and other constituents at concentrations that exceeded their respective 2L Standards or IMACs. This information is used to evaluate whether concentrations in groundwater downgradient of the basin and ash storage areas are also naturally occurring or might be influenced by migration of constituents from the ash basin and ash storage areas. Examples of naturally occuring metals and consituents include cobalt, iron, manganese, thallium, total dissolved solids (TDS), and vanadium. These metals and constituents were detected in background groundwater samples at concentrations greater than 2L Standards or IMACs.  Groundwater in the shallow aquifer under the DRSS ash basin and under the ash storage areas flows horizontally to the southeast and discharges to the Dan River. This flow direction is away from the direction of the nearest public or private water supply wells. The Dan River serves as a lower hydrologic boundary for groundwater within the shallow aquifer, and serves as a discharge feature for shallow groundwater flow from the ash basin. Regional groundwater flow in the vicinity of the DRSS is south/southeast toward the Dan River.There are no water supply wells located between the ash basin and the Dan River.  Groundwater data identified a local groundwater divide north of Ash Storage 1 where groundwater in the shallow aquifer intially flows north prior to intersecting an unnamed tributary to the Dan River which then flows in a southeasterly direction towards the Dan River. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-3  There are no indications of exceedances of 2L Standards or IMACs north of the DRSS site attributable to the ash storage areas. Residences located north of the ash storage areas are serviced by municipal water.  Surface water quality data for samples collected within the Dan River during this CSA indicate that the water quality in the river has not been imapcted by ash above the North Carolina Surface Water Quality Standards (2B Standards).  There are no known exceedances of 2L Standards for arsenic and boron beyond the DRSS property boundary. Arsenic and boron are the primary constituents detected in shallow aquifer in the three-dimensional area beneath the ash basin with measured concentrations exceeding background concentrations and 2L Standards.  The horizontal migration of boron in the shallow aquifer best represents the dominant flow and transport system. Vertical migration of constituents is genearlly limited by underlying bedrock.Boron is highly soluble and was identified by the USEPA as one of the leading indicators for releases of contaminants from ash. Because of these characteristics, boron can be used to represent the general extent of the shallow aquifer impacted by the ash basin and ash storage areas  TDS and sulfate exceeded the 2L Standards in an isolated area east of the DRSS historical site property boundary. Based on the relatively low concentrations of other ash-related constituents in these wells, the presence of TDS and sulfate may not be attributed to groundwater migration from the ash basin.  Aluminum, arsenic, chromium, cobalt, copper, lead, thallium, and zinc exceeded the 2B Standards in the surface water sample (SW-3) collected from the unnamed tributary to the Dan River located east of the Secondary Cell. It should be noted that boron was not detected in levels that exceeded 2B Standards at this location. However, analyses of surface water sample SW-6, collected from the Dan River near the confluence with the tributary stream, indicate that the Dan River has not been adversely affected by the water quality at sample location SW-3. Note that as required to by CAMA, Duke Energy has agreed to remove the ash in the ash basin and ash storage areas via excavation. Approximately 1.2 million tons of ash will be transported to a lined landfill. It is anticipated that the remainder of ash will be placed into a lined landfill to be constructed in the vicinity of Ash Storage 1. The initial phase of ash removal is scheduled to commence 60 days after all necessary permits and approvals are obtained. Closure of the ash impoundments is anticipated to occur by August 2019. ES.1 Source Information Duke Energy owns and formerly operated the Dan River Steam Station, located on the Dan River in Rockingham County near Eden, North Carolina. DRSS began operation as a coal-fired generating station in 1949 and was retired from service in 2012. The Dan River Combined Cycle Station (DRCCS) natural gas generating facility was constructed at the site and began operations in 2012. Historically, coal ash residue from DRSS’s coal combustion process was disposed of in the ash basin system located northeast of the station and adjacent to the Dan River. Discharge from the ash basin system is currently permitted by the NCDENR’s Division of Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-4 Water Resources (DWR) under the National Pollutant Discharge Elimination System (NPDES) Permit NC0003468. The ash basin system at the plant was used to retain and settle ash generated from coal combustion at DRSS. The ash basin system is located adjacent to the Dan River and consists of a Primary Cell, a Secondary Cell, and associated embankments and outlet works. The ash basin cells are unlined and are not currently closed. Two ash storage areas also exist to the north and upgradient of the Primary and Secondary Cells and consist of ash dredged from the Primary Cell. The ash storage areas are unlined and have a vegetative soil cap. The ash basin was operated as an integral part of the site’s wastewater treatment system. During operation of the coal-fired units, the ash basin received variable inflows of fly ash, bottom ash, pyrites, stormwater runoff (including runoff from the coal pile), cooling water, powerhouse floor drains, sanitary waste effluent, station yard drainage sump, and boiler chemical cleaning wastes. The coal ash was historically sluiced to the southwest corner of the Primary Cell on a variable basis (i.e., dependent on DRSS operations) via sluice pipes. The CSA found that exceedances of ash-related constituents in soil, groundwater, and surface water are likely the result of leaching from the coal ash contained in the ash basin and ash storage areas. However, exceedances of iron, manganese, and vanadium may be due in part to naturally occurring conditions based on a review of background groundwater quality data. ES.2 Initial Abatement and Emergency Response On February 2, 2014, a portion of the 36-inch corrugated metal stormwater pipe, which was located under the Primary Cell of the ash basin, failed and released up to 39,000 tons of coal ash into the Dan River. Immediate action was taken to stop the release and begin assessment of the environmental impact. Ash deposits were removed from the immediate vicinity of the pipe failure and other downstream locations. Duke Energy has worked extensively with various federal, state, and local agencies to address the coal ash release to the Dan River including removal of an estimated 4,000 cubic yards of coal ash and extensive environmental quality monitoring. According to a January 27, 2015 U.S. Environmental Protection Agency (USEPA) Information Update related to the release, “Following extensive surface water and sediment sampling, no further ash removal is planned. There have been no exceedances of human health screening thresholds, or any recent exceedances of ecological screening thresholds, for contaminants associated with ash. Further, removal of ash [in] some places could be more detrimental to the ecosystem than leaving it in place.” Long-term ash deposition monitoring through July 2015 was also directed by an Administrative Order of Consent between the USEPA and Duke Energy. The USEPA has overseen ash deposition sampling to date and will determine whether additional ash deposition sampling is required beyond July 2015. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-5 ES.3 Receptor Survey Properties located within a 0.5-mile radius of the DRSS ash basin compliance boundary are located in and southeast of Eden, Rockingham County, North Carolina. The majority of the land is undeveloped property. Residential properties are located north and northwest of the ash basin compliance boundary within the 0.5-mile radius. One residence is located south of DRSS across the Dan River within the 0.5-mile radius. Two industrial properties are located northeast of DRSS; one of these properties has a wastewater treatment plant discharging into the Dan River. Farm land is located southeast of the station across the Dan River. Duke Energy submitted a receptor survey to the NCDENR (HDR 2014a) in September 2014, and subsequently submitted to NCDENR a supplement to the receptor survey (HDR 2014b) in November 2014. The update included contacting and/or reviewing the agencies/records to identify public and private water supply sources identified and reviewing questionnaires that were received after the submittal of the November 2014 supplement to the September 2014 receptor survey (i.e. questionnaires received af ter October 31, 2014). The purpose of the receptor survey was to identify the exposure locations that are critical to be considered in the groundwater transport modeling and human health risk assessment. The updated survey activities included contacting the following agencies and/or reviewing the following records to identify public and private water supply sources, confirm the location of wells, identify surface water features, and/or identify any wellhead protection areas located within a 0.5-mile radius of the DRSS ash basin compliance boundary:  NCDENR Department of Environmental Health (DEH) Public Water Supply Section’s (PWSS) most current Public Water Supply Water Sources GIS point data set;  NCDENR DWR Source Water Assessment Program (SWAP) online database for public water supply sources;  Environmental Data Resources (EDR) local/regional water agency records review;  Rockingham County Environmental Health Department;  City of Eden Director of Environmental Services;  Dan River Water Inc., a private water utility company; and  United States Geological Survey (USGS) National Hydrography Dataset (NHD) The review of these records identified three private water supply wells and one private water supply spring, not currently in use, and several tributaries to the Dan River within a 0.5-mile radius of the ash basin compliance boundary. All three water supply wells are located more than 2,000 feet away from the Dan River ash basin compliance boundary and are either upgradient or across the Dan River from the ash basin system. No public water supply wells or wellhead protection areas were identified within a 0.5-mile radius of the ash basin compliance boundary. No water supply wells (including irrigation wells and unused or abandoned wells) were identified within the ash basin potential area of interest. Several unnamed tributaries were identified adjacent to or downgradient of the DRSS site. No information gathered as part of this assessment suggests that water supply wells or springs located within the 0.5-mile radius of the compliance boundary are impacted by the Dan River ash basin system. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-6 ES.4 Sampling / Investigation Results ES.4.1 Background Findings As part of the CSA, Duke Energy installed four additional background monitoring wells (one shallow, two deep, and one bedrock monitoring well) and three soil borings to provide background soil and groundwater quality data. The background locations selected were away from areas that may have potentially been impacted by site activities and would not be impacted by groundwater flow from areas potentially impacted by ash. Analyses of groundwater samples collected from these additional and existing background wells indicated that the following naturally occurring constituents exceeded 2L Standards or IMACs in background locations: cobalt, iron, manganese, pH, thallium, TDS, and vanadium. The results for all other constituents were reported below 2L Standards or IMACs. Constituent of Interest Groundwater 2L Standard or IMACs (µg/L) Range of Exceedances Antimony 1 <0.5 µg/L (BG-5S) to 1.21 µg/L (MW-23BR) Arsenic 10 <0.5 µg/L (BG-5D) to 6.36 µg/L (MW-23BR) Beryllium 4 0.087 µg/L (MW -23BR) to <0.2 µg/L (BG-5S) Chromium 10 0.22 µg/L (MW -23BR) to 1.2 µg/L (BG-5D) Cobalt 1 1 µg/L (MW -23BR) to 2.1 µg/L (BG-5D) Iron 300 110 µg/L (MW -23BR) to 890 µg/L (BG-5S) Lead 15 0.057 µg/L (MW -23D) to 0.078 µg/L (BG-5D) Manganese 50 110 µg/L (BG-5S) to 910 µg/L (BG-5D) pH 6.5-8.5 6.89 µg/L (MW-23D) to 7.45 µg/L (MW -23D) Selenium 20 <1.0U µg/L (MW-23BR) to <0.5 µg/L (BG-5S) Sulfate 250,000 29,800 µg/L (BG-5D) to 41,300 µg/L (MW -23D) Thallium 0.2 < 0.1 µg/L (MW-23D) to 0.019 µg/L (BG-5S) TDS 500,00 175,000 µg/L (BG-5S) to 252,000 µg/L (MW -23D) Vanadium 0.3 <1.0 µg/L (BG-5D) to 2.6 µg/L (MW-23D) ES.4.2 Nature and Extent of Contamination Soil and groundwater beneath the ash basin and ash storage areas (within the compliance boundary) have been impacted by ash handling and storage at the DRSS site as described below. Concentrations of selected constituents exceeded their respective 2L Standards or IMACs in groundwater beyond the compliance boundary. The extent of the contamination is noted below: ES.4.2.1 Groundwater – Shallow Aquifer Arsenic and boron were the primary constituents detected in groundwater at concentrations that exceeded the background concentrations and 2L Standards. Both constituents were detected above the 2L Standards in a three-dimensional area beneath the ash basin and ash storage areas in the shallow aquifer. Boron is highly soluble and was identified by the USEPA as one of Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-7 the leading indicators for releases of contaminants from ash. There are no known exceedances of 2L Standards for arsenic or boron beyond the DRSS property boundary. TDS and sulfate exceeded the 2L Standards in an isolated area east of the DRSS historical site property boundary. Based on the relatively low concentrations of other ash-related constituents in these wells, the presence of TDS and sulfate may not be attributable to groundwater migration from the ash basin. Within the shallow aquifer, three COIs were identified boron, sulfate, and TDS. Boron, sulfate, and TDS rarely exceeded their respective 2L Standards in shallow groundwater samples but are mobile and were noted at higher concentrations within and in the immediate vicinity of the ash basin and ash storage areas than in background wells and other areas of the site likely not influenced by the ash basin or ash storage areas. Four other COIs identified in the shallow aquifer were isolated in specific locations and do not appear to be transported across the site: antimony, chromium, selenium, and thallium. Because of these characteristics, boron can be used to represent the general extent of the shallow aquifer impacted by the ash basin and ash storage areas. Boron, TDS and sulfate concentrations in shallow aquifer are shown on Figure ES-1. Vertical migration of constituents is generally limited by the underlying bedrock. ES.4.2.2 Groundwater - Bedrock Aquifer Three of the constituents with concentrations in excess of 2L Standards and IMAC in the bedrock aquifer (iron, manganese, and vanadium) were found to be naturally occurring metals in the background wells. Nine other constituents were found in the bedrock aquifer in concentrations greater than their 2L Standards or IMAC: antimony, arsenic, boron, chromium, cobalt, selenium, sulfate, TDS, and thallium. These were detected in isolated locations and existing evidence indicates that they have not migrated extensively across the site or beyond the compliance boundary. ES.4.2.3 Groundwater - East of the Ash Basin The unnamed tributary stream located to the east of the Secondary Cell is likely a discharge location for groundwater flowing east from the Secondary Cell. Analytical results from surface water sample location SW -3 exceeded the 2B Standards for aluminum, arsenic, chromium, cobalt, copper, lead, and zinc. The results of analyses from surface water sample location SW - 6, collected from the Dan River near the confluence with the tributary stream, indicate that the Dan River has not been adversely affected by the water quality in the stream containing sample location SW -3. A review of constituent data from adjacent well MW -21S is inconclusive as to the correlation of the groundwater chemistry, background well data, and the SW -3 results. ES.4.2.4 Seep Samples Seep sampling results at the DRSS site have identified four COIs as primary constituents in the seep water: cobalt, iron, manganese, and vanadium. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-8 Comparing COI concentrations in the seep water to the maximum COI concentrations encountered in groundwater sampled from the background wells indicates four seep locations (CCSW001, CCSW002, DRRC001, and S-1) where at least one seep COI concentration exceeded the maximum groundwater COI concentration. Four COIs were identified in the seep water are cobalt, iron, manganese, and vanadium. One or more of the identified COIs exceeded applicable standards for all seep samples collected. ES.4.2.5 Soil, Rock, and Sediment Samples Soil samples were obtained from 38 separate locations during CSA drilling activities within the DRSS site (including locations beneath the ash basin and ash storage areas). Seven COIs were identified in soil samples obtained from these locations: arsenic (21 locations), boron (4 locations), cobalt (37 locations), iron (38 locations), manganese (37 locations), selenium (16 locations), and vanadium (38 locations). With the exception of boron and selenium, all of these COIs appear in one or more of the background soil boring locations at concentrations exceeding the applicable soil standard. The COI concentrations observed in the soil from the various locations within the DRSS site generally bracket the concentrations observed in soil samples from the background locations or within reasonable proximity of the bracketed background concentrations. Rock samples (including partially weathered rock [PWR] samples) were obtained from 15 separate locations during CSA drilling activities within the DRSS site, including locations beneath the ash basin and ash storage areas. Seven COIs were identified in rock samples obtained from these locations: arsenic (9 locations), barium (1 location), cobalt (14 locations), iron (15 locations), manganese (14 locations), selenium (5 locations), and vanadium (14 locations). With the exception of barium, all of these COIs appear within the background locations where rock was obtained (BG-5D and MW-23BR) at concentrations exceeding the applicable soil standards. Sediment samples were obtained from 3 seep and 6 surface water locations at the DRSS site. Five COIs were identified in the sediment samples: arsenic (3 locations), cobalt (8 locations), iron (9 locations), manganese (9 locations), and vanadium (9 locations). With the exception of arsenic, all of these COIs appear within the background locations where sediment was obtained (SW -5 and SW -8) at concentrations exceeding the applicable soil standards. ES.4.3 Maximum Contaminant Concentrations The maximum contaminant concentrations reported in groundwater, ash porewater, seep water, and ash basin surface water samples collected during the CSA are listed below. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-9 Constituent of Interest Maximum Constituent of Interest Concentrations Groundwater (µg/L) Ash Porewater (µg/L) Seep Water (µg/L) Ash Basin Surface Water (µg/L) Aluminum 6,940 13,200 3,410 613 Antimony 2.9 9.8 N/A 1.21 Arsenic 809 422 1.68 51.1 Barium 380 810 74 99 Beryllium 3.7 12.1 N/A N/A Boron 1,310 630 130J+ 364 Cadmium 1.8 1.3 N/A N/A Chromium 30.1 50 3.86 N/A Cobalt 29.2 34.1 4.88 N/A Copper 10.9 197 6.15J+ 5.11J+ Iron 36,400 25,100 5,720 323 Lead 9.42 77.4 3.97 N/A Manganese 3,700 1,500 2,200 154 Nickel 46.9 70.1 3.3 2.5 Selenium 35.3 12.2 N/A 2.87 Sulfate 416,000 125,000 38,400 90,000 TDS 873,000 358,000 211,000 270,000 Thallium 0.55 3.4 0.036J N/A Vanadium 15.3 254 8.06 6.65 Zinc 390 51 11J+ 212 Notes: 1. N/A indicates that a constituent was not detected above the reporting detected limit. 2. J indicates an estimated concentration. 3. J+ indicates an estimated concentration, biased high. ES.4.4 Source Characterization Source characterization was performed through the completion of borings and installation of groundwater monitoring wells within the footprint of the ash basin cells and ash storage areas, and associated solid matrix (ash) and aqueous sample (ash porewater) collection and analysis. Ash samples were collected for analysis of physical characteristics (e.g., grain size, porosity) to provide data for evaluation of retention/transport properties within and beneath the ash basin and ash storage areas. Ash samples were collected for analysis of chemical characteristics (e.g., total inorganics, leaching potential). The results of the characterization will be used to refine the SCM and provide data for use in the CAP. Review of laboratory analytical results of ash samples collected from the ash basin and ash storage areas identified eight COIs: arsenic, barium, boron, cobalt, iron, manganese, selenium, and vanadium. COIs identified in porewater in the ash basin included antimony, arsenic, barium, beryllium, chromium, cobalt, iron, lead, manganese, thallium, and vanadium. COIs identified in porewater in the ash storage areas included arsenic, boron, chromium, cobalt, iron, manganese, pH, and vanadium. COIs identified in surface water within the basin included aluminum, arsenic, copper, and zinc. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-10 SPLP (Synthetic Precipitation Leaching Procedure (SPLP) testing was conducted to evaluate the leaching potential of constituents from ash. Results of the SPLP analyses indicated that the following COIs exceeded their 2L Standards: antimony, arsenic, barium, beryllium, chromium, cobalt, iron, lead, manganese, selenium, thallium, and vanadium. However, many factors influence the transport of these COIs and potential impacts to groundwater over time will be investigated through modeling as part of the CAP. Four seeps (S-1 through S-4) associated with the DRSS ash basin and four NCDENR-identified seeps (INFSW009, CSSW001, CCSW002OUT, and DRRC001) were planned to be sampled during this CSA. Seeps S-2, S-3, S-4 and INFSW009 were dry at the time of sampling. Several attempts were made to obtain these samples, but were unsuccessful. Constituents that exceeded the 2L Standards in seep samples were cobalt, iron, manganese, and vanadium. ES.4.5 Regional Geology and Hydrogeology The DRSS site is located in the Dan River Triassic Basin within the Piedmont Physiographic province. The Dan River Triassic Basin is in the western belt of rift basins and is bounded on the southeast by the Milton terrane. The basin is one of several exposed rift basins that form two parallel belts that strike northeasterly within the Piedmont province. The basins are aligned subparallel to the Appalachian terranes (Figure 5-1). The Appalachian terranes formed along pre-existing zones of faulting and then subsided during a period of crustal stretching (Olsen et al. 1991). The contact between the Triassic rocks of the basin and the crystalline rocks of the Milton belt along the southeast basin margin is an unconformity, but several minor, northwest dipping normal faults are present locally (Thayer 1970). Minor, interbasin normal faults are present. The sedimentary rocks of the basin consist of interbedded conglomerate, sandstone, mudstone, siltsone, shale, and thin coal beds (Olsen et al. 1991; Thayer and Robbins 1992). The rocks dip moderately to steeply northwest toward the Chatham fault zone (Thayer 1970). The hydrogeologic regime in the Dan River Basin is characterized by fractured, bedded sedimentary sequences underlying soil and saprolite. Groundwater may occur under both unconfined, water table conditions (similar to most Piedmont crystalline sites) and confined conditions. Controls of groundwater flow are a combination of the interaction of factors including topography, stratigraphic sequence and lithology, distribution and intensity of fractures, presence of diabase intrusions (both dikes and sills), basalt flows, and weathering processes of the bedrock (Venkatakrishnan and Gheorghiu 2003). ES.4.6 Site Geology and Hydrogeology Geology at the DRSS site is comprised of two interconnected layers, or mediums: 1) residual soil/saprolite and weathered fractured rock (regolith) overlying 2) fractured bedrock (Figure 5-3). The regolith layer is a thoroughly weathered and structureless residual soil that occurs near the ground surface with the degree of weathering decreasing with depth. The residual soil grades into saprolite, a coarser grained material that retains the structure of the parent bedrock. Beneath the saprolite, partially weathered/fractured bedrock occurs with depth until sound Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-11 bedrock is encountered. The site is underlain by rocks of the Pine Hall (Tph) and Cow Branch (Tcb) Formations (Figure 6-1). Alluvial and terrace deposits consisting of unconsolidated sand, silt, and clay with occasional sub-rounded to well-rounded pebbles occur along the Dan River and major tributaries. A transition zone (TZ) at the base of the regolith has been interpreted to be present in many areas of the Piedmont and, based on this investigation, is present in the Dan River Basin. Harned and Daniel (1989) characterize the TZ zone as consisting of partially weathered/fractured bedrock and lesser amounts of saprolite that grade into bedrock, describing the TZ zone as “being the most permeable part of the system, even slightly more permeable than the soil zone”. Harned and Daniel (1989) suggest the zone may serve as a conduit of rapid flow and transmission of water. In general, groundwater within the shallow aquifer (S wells), TZ (D wells), and fractured bedrock (BR wells) flows from the northern extent of the property boundary south and southeast toward the Dan River. However, in the area north of Ash Storage 1, groundwater elevation data suggest the presence of a groundwater divide extending from MW -12 to GWA-1 where groundwater within the shallow aquifer and TZ flows north, away from the DRSS site. Shallow groundwater flow direction is shown on Figure 6-5. Groundwater flow within the TZ is shown on Figure 6-6. Groundwater flow within fractured bedrock is shown on Figure 6-7. ES4.7 Existing Groundwater Monitoring Data Groundwater monitoring prior to 2015 consisted of nine voluntary and seven compliance wells installed within the DRSS property boundary. Duke Energy implemented NPDES compliance groundwater monitoring around the DRSS ash basin in 1993, with three wells installed in 1993 and an additional well installed in 1995. During this period, the compliance wells were generally sampled two times per year. Four additional wells were added to an expanded voluntary monitoring program in 2008. Beginning in 2008, the complete network of eight compliance and voluntary groundwater monitoring wells were sampled two times per year, and the analytical results were submitted to NCDENR. In 2010, additional compliance groundwater monitoring wells were installed at the site. Groundwater monitoring as required by the DRSS NPDES Permit NC0003468 began in March 2011 utilizing the compliance monitoring wells. NPDES Permit Condition A (11), Version 1.1, dated June 15, 2011, lists the groundwater monitoring wells to be sampled, the parameters and constituents to be measured and analyzed, and the requirements for sampling frequency and reporting results. Elevated concentrations of boron, iron, and manganese have been detected in one or more of the following groundwater monitoring wells: MW -20S, MW -21S/D, MW-22S/D, and MW-23D. The distribution and magnitude of iron and manganese exceedances is indicative of background conditions. Historical analytical results from compliance and voluntary groundwater monitoring wells were utilized to assess background groundwater quality and calculate statistical analyses of groundwater results. Compliance groundwater monitoring wells were sampled as part of this CSA to supplement the expanded groundwater assessment. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-12 ES.4.8 Screening-Level Risk Assessments The human health and ecological screening-level risk assessments were performed as part of this CSA and identified media-specific Contaminants of Potential Concern (COPCs) that may adversely impact human and/or ecological receptors under site-specific exposure scenarios. COPCs were determined by comparing maximum concentrations or Reporting Limits (RLs) of COIs in on- and off-site sampling locations to risk-based screening level criteria for soil, groundwater, surface water, and sediment. Those COPCs identified during the human health screening-level risk assessment are noted below:  In groundwater, antimony, arsenic, barium, beryllium, boron, cadmium, chromium, cobalt, iron, manganese, mercury, molybdenum, nickel, selenium, strontium, thallium, and vanadium exceeded their respective screening values.  In soil, arsenic, cobalt, iron, manganese, sodium, and thallium exceeded their respective screening values.  In surface water, aluminum, arsenic, cobalt and thallium maximum concentrations exceeded their respective screening values. Beryllium, boron, total chromium, copper, iron, lead, manganese, mercury, sodium, vanadium and zinc were also retained as COPCs by default, based on a lack of criteria for comparison.  In sediment, aluminum, antimony, arsenic, cobalt, iron, manganese, thallium, and vanadium exceeded their respective screening values. COPCs identified during the ecological screening-level risk assessment are noted below: In soil, all COIs except cadmium, sodium, and strontium exceeded their respective screening levels. Cadmium is the only COI that was excluded as a COPC in soil, as the other two have no ecological criteria and were thereby retained as COPCs by default. See Table 12-6 for detailed information, including the maximum concentrations detected. The exceedances were typically within the same order of magnitude as the screening levels, with the exceptions of aluminum, boron, total chromium, iron, manganese, molybdenum, selenium, and vanadium, which were relatively higher.  In surface water (freshwater), beryllium, cadmium, and copper exceeded their respective screening values. Barium, cobalt, manganese, molybdenum, strontium, and vanadium were retained based on a lack of criteria for comparison. See Table 12-7 for detailed information on the screening performed and contaminant category for each COPC.  In sediment, COPCs included antimony, arsenic, cadmium and copper. In addition, aluminum, barium, beryllium, boron, cobalt, iron, manganese, molybdenum, strontium and vanadium were retained due to issues related to their RL exceeding the screening value or based on a lack of criteria for comparison. Details on the COPC screening and contaminant category are provided in Table 12-8. COIs were not screened out as COPCs based on a comparison to background concentrations, as the NCDENR Division of Waste Management’s Screening Level Environmental Risk Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-13 Assessment guidance (2003) does not allow for screening based on background. Site-specific background concentrations will be considered in the uncertainty section of the baseline ecological risk assessment, if determined to be necessary. This initial screening does not specifically identify that health or environmental risks are present; however, the results indicate constituents in environmental media could be of concern and further investigation by a site-specific risk assessment may be warranted. ES.4.9 Development of Site Conceptual Model The human health and ecological risk assessment conceptual site models, illustrating potential pathways of exposure from source to receptors are provided in this report. In the initial site conceptual hydrogeologic model presented in the Work Plan, the geological and hydrogeological features influencing the movement, chemical, and physical characteristics of contaminants were related to the Piedmont hydrogeologic system at the site. A hydrogeological site conceptual model was developed from data generated during previous assessments, existing groundwater monitoring data, and 2015 groundwater assessment activities. The CSA found that the direction of the movement of the contaminants is generally to the south/southeast towards the Dan River with a northerly component of groundwater flow north of Ash Storage 1 towards an unnamed tributary to the Dan River that exists north of the DRSS site. ES.4.10 Identification of Data Gaps Data gaps were identified that will require further evaluation to refine the SCM through completion of additional groundwater assessment field activities and evaluation of data collected during those activities. The data gaps have been organized into two groups: 1) data gaps resulting from temporal constraints and 2) data gaps resulting from evaluation of data collected during the CSA. ES.4.10.1 Data Gaps Resulting from Temporal Constraints Data gaps identified in this category are generally present due to insufficient time to collect, analyze, or evaluate data collected during the CSA activities. It is expected that the majority of these data gaps will be remedied in a CSA supplement to be submitted to NCDENR following completion of the second comprehensive groundwater sampling event. Temporal data gaps include refinement of speciation sampling in groundwater monitoring wells. The CSA speciation sampling effort was based upon anticipated groundwater flow paths and constituents whose valence state may affect toxicity or mobility.  Mineralogical Characterization of Soil and Rock – a total of 16 soil, three TZ, and 9 bedrock samples were submitted to three third-party mineralogical testing laboratories for analysis of soil and rock composition. As of the date of this report, Duke Energy has not received all of the results of this testing; however, results will be provided in the CSA supplement. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-14  Additional Speciation of Monitoring Wells – in order to meet the requirements of the NORR, Duke Energy conducted speciation of groundwater samples for arsenic, chromium, iron, manganese, and selenium from selected wells along inferred groundwater flow transects. Speciation sampling will be performed at the following locations during the second comprehensive sampling event: along flow transects, at ash basin surface water sample locations, and at wells with exceedances of 2L Standards for speciation constituents. Adjustments to the speciation sampling are proposed in Section 15.0, the results of which will be reported in the CSA supplement. ES.4.10.2 Data Gaps Resulting from Review of Data Obtained During CSA Activities Data gaps resulting from evaluation of data collected include:  Evaluation of the need for additional monitoring wells north and east of Ash Storage 1  Evaluation of additional bedrock background groundwater monitoring wells (and continued sampling attempts at previously dry wells such as BG-1D)  Evaluation of impacts to surface water at SW -3 (located in the tributary stream along the eastern property boundary), collection of seep samples (S-2 through S-4) to assess potential groundwater discharge to surface water, and  Additional review of information regarding areas of non-ash contamination to evaluate potential interference with remedial efforts, if applicable. ES.5 Conclusions The CSA identified the horizontal and vertical extent of groundwater contamination at the DRSS site, and found that the source of the contamination within that boundary is the coal ash contained in the ash basin and ash storage areas. The cause of contamination is leaching of constituents from the coal ash into the underlying soil and groundwater. Background monitoring wells contained naturally occurring metals and other constituents at concentrations that exceeded their respective 2L Standards or IMACs. These included cobalt, iron, manganese, thallium, TDS, and vanadium.. The CSA identified arsenic, boron, cobalt, iron, manganese, selenium, and vanadium as soil COIs. Groundwater COIs were identified as antimony, arsenic, boron, chromium, cobalt, iron, manganese, selenium, sulfate, thallium, TDS, and vanadium. Cobalt, iron, manganese, and vanadium occur naturally in regional groundwater. The CSA identified the horizontal and vertical extent of soil contamination, with the exception of off-site areas east and north of Ash Storage 1 (as described in Section 14.1.1). Duke Energy has notified NCDENR of the need for refinement of COI delineation north and east of Ash Storage 1, and is coordinating additional fieldwork with NCDENR. Movement of each contaminant is related to the groundwater flow direction, the groundwater flow velocity, and the rate at which a particular contaminant reacts with materials in the aquifer. The data indicates that geologic conditions present beneath the ash basins impedes the vertical migration of contaminants. The CSA found that the direction of mobile contaminant transport is Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin EXECUTIVE SUMMARY ES-15 generally in a southeasterly direction towards the Dan River, as anticipated, and not towards other off-site receptors. North of Ash Storage 1 there is evidence of a northerly flow of groundwater into an unnamed tributary which flows southeasterly towards the Dan River. No information gathered as part of this CSA suggests that water supply wells or springs within the 0.5-mile radius of the compliance boundary are impacted by the DRSS ash basin system. The human health and ecological screening-level risk assessments did not specifically identify the presence of health or environmental risks; however, the results indicate that constituents in environmental media could be of concern and further investigation by a site-specific risk assessment may be warranted. No imminent hazards to human health and the environment were identified during the screening-level risk assessments. Duke Energy is required by CAMA to remove the ash in the DRSS ash basin and ash storage areas. Based on the results of soil and groundwater samples collected beneath the ash basin and the ash storage areas, some residual contamination will remain after excavation; however, the degree of contamination and the persistence of this contamination over time cannot be determined at this time. Duke Energy will pursue corrective action under 15A NCAC 02L .0106. The approaches to corrective action under rule .0106(k) or (l) will be evaluated along with other remedies depending on the results of groundwater modeling and evaluation of the site’s suitability to use Monitored Natural Attenuation or other industry-accepted methodologies. This page is intentionally left blank. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin TABLE OF CONTENTS i Table of Contents Section Page No. 1.0 Introduction ..................................................................................................................... 1 1.1 Purpose of Comprehensive Site Assessment .............................................................. 1 1.2 Regulatory Background ............................................................................................... 2 1.2.1 NCDENR Requirements ....................................................................................... 2 1.2.2 Notice of Regulatory Requirements ...................................................................... 3 1.2.3 Coal Ash Management Act Requirements ............................................................ 3 1.3 NCDENR-Duke Energy Correspondence ..................................................................... 4 1.4 Approach to Comprehensive Site Assessment ............................................................ 5 1.4.1 NORR Guidance ................................................................................................... 5 1.4.2 USEPA Monitored Natural Attenuation Approach ................................................. 5 1.4.3 ASTM Site Conceptual Model Guidance ............................................................... 5 1.5 Limitations and Assumptions ....................................................................................... 6 2.0 Site History and Description ............................................................................................ 8 2.1 Site Location, Acreage, and Ownership ....................................................................... 8 2.2 Site Description ............................................................................................................ 8 2.3 Adjacent Property, Zoning, and Surrounding Land Uses .............................................. 8 2.4 Adjacent Surface Water Bodies and Classifications ..................................................... 9 2.5 Meteorological Setting ................................................................................................. 9 2.6 Hydrologic Setting ........................................................................................................ 9 2.7 Permitted Activities and Permitted Waste ...................................................................10 2.8 NPDES and Surface Water Monitoring .......................................................................10 2.9 NPDES Flow Diagram ................................................................................................10 2.10 History of Site Groundwater Monitoring .......................................................................11 2.10.1 Voluntary Groundwater Monitoring Wells .............................................................12 2.10.2 Compliance Groundwater Monitoring Wells .........................................................12 2.11 Assessment Activities or Previous Site Investigations .................................................13 2.12 Decommissioning Status.............................................................................................14 3.0 Source Characteristics ...................................................................................................16 3.1 Coal Combustion and Ash Handling System ...............................................................16 3.2 Description of Ash Basin and Other Ash Storage Areas ..............................................16 Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin TABLE OF CONTENTS ii 3.2.1 Primary and Secondary Ash Basin Cells ..............................................................16 3.2.2 Ash Storage 1 ......................................................................................................17 3.2.3 Ash Storage 2 ......................................................................................................17 3.2.4 Dredge Dikes .......................................................................................................18 3.3 Physical Properties of Ash ..........................................................................................18 3.4 Chemical Properties of Ash .........................................................................................19 4.0 Receptor Information ......................................................................................................21 4.1 Summary of Previous Receptor Survey Activities .......................................................21 4.2 Summary of CSA Receptor Survey Activities and Findings .........................................22 4.3 NCDENR Well Water Testing Program .......................................................................23 5.0 Regional Geology and Hydrogeology .............................................................................24 5.1 Regional Geology .......................................................................................................24 5.2 Regional Hydrogeology ...............................................................................................25 6.0 Site Geology and Hydrogeology .....................................................................................29 6.1 Site Geology ...............................................................................................................29 6.1.1 Soil Classification .................................................................................................29 6.1.2 Rock Lithology .....................................................................................................30 6.1.3 Structural Geology ...............................................................................................31 6.1.4 Fracture Trace Study ...........................................................................................31 6.1.5 Effects of Structure on Groundwater Flow ............................................................33 6.1.6 Soil and Rock Mineralogy and Chemistry .............................................................33 6.2 Site Hydrogeology.......................................................................................................34 6.2.1 Groundwater Flow Direction .................................................................................34 6.2.2 Hydraulic Gradient ...............................................................................................34 6.2.3 Effects of Geologic/Hydrogeologic Characteristics on Contaminants ...................35 6.2.4 Site Hydrogeologic Conceptual Model .................................................................35 7.0 Source Characterization .................................................................................................36 7.1 Ash Basin ...................................................................................................................36 7.1.1 Ash (Sampling and Chemical Characteristics) .....................................................36 7.1.2 Ash Basin Surface Water (Sampling and Chemical Characteristics) ....................36 7.1.3 Ash Porewater (Sampling and Chemical Characteristics) ....................................36 7.1.4 Ash Porewater Speciation ....................................................................................37 7.1.5 Radiological Laboratory Testing ...........................................................................37 Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin TABLE OF CONTENTS iii 7.2 Ash Storage Areas ......................................................................................................37 7.2.1 Ash (Sampling and Chemical Characteristics) .....................................................37 7.2.2 Ash Porewater (Sampling and Chemical Characteristics) ....................................38 7.3 Leaching Potential of Ash ...........................................................................................38 7.4 Seeps .........................................................................................................................38 7.4.1 Review of NCDENR March 2014 Sampling Results .............................................38 7.4.2 Ash Basin and NCDENR Seep Sampling Results – CSA Activities ......................39 7.5 COIs Exceeding Applicable Standards........................................................................39 7.5.1 COIs in Ash .........................................................................................................39 7.5.2 COIs in Surface Water .........................................................................................40 7.5.3 COIs in Ash Porewater ........................................................................................40 7.5.4 COIs in Seeps and Stormwater ............................................................................40 8.0 Soil and Rock Characterization ......................................................................................41 8.1 Background Sample Locations ...................................................................................41 8.2 Analytical Methods and Results ..................................................................................41 8.3 Comparison of Soil Results to Applicable Levels ........................................................41 8.4 Comparison of Soil Results to Background .................................................................42 8.4.1 Background Soil, PWR, and Rock ........................................................................42 8.4.2 Soil, PWR, and Rock Beneath the Ash Basin ......................................................42 8.4.3 Soil, PWR, and Rock Beneath the Ash Storage Areas .........................................42 8.4.4 Soil, PWR and Rock Outside the Waste Boundary ..............................................42 9.0 Surface Water and Sediment Characterization ...............................................................44 9.1 Surface Water .............................................................................................................44 9.1.1 Comparison of Exceedances to 2B Standards .....................................................44 9.1.2 Comparison of Exceedances to Background........................................................44 9.1.3 Discussion of Results for Constituents without 2B Standards ..............................45 9.2 Surface Water Speciation ...........................................................................................46 9.3 Sediments ...................................................................................................................47 10.0 Groundwater Characterization ........................................................................................48 10.1 Regional Groundwater Data for Constituents of Interest .............................................48 10.1.1 Antimony ..............................................................................................................48 10.1.2 Arsenic.................................................................................................................49 10.1.3 Barium .................................................................................................................49 Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin TABLE OF CONTENTS iv 10.1.4 Beryllium ..............................................................................................................50 10.1.5 Boron ...................................................................................................................51 10.1.6 Chromium ............................................................................................................51 10.1.7 Cobalt ..................................................................................................................51 10.1.8 Iron ......................................................................................................................51 10.1.9 Lead ....................................................................................................................52 10.1.10 Manganese ......................................................................................................52 10.1.11 Selenium ..........................................................................................................53 10.1.12 Sulfate ..............................................................................................................54 10.1.13 Thallium ...........................................................................................................54 10.1.14 Vanadium .........................................................................................................55 10.1.15 pH ....................................................................................................................55 10.2 Background Wells .......................................................................................................56 10.3 Discussion of Redox Conditions ..................................................................................57 10.4 Groundwater Analytical Results ..................................................................................57 10.4.1 Ash Basin: Primary and Secondary Cells .............................................................58 10.4.2 Ash Storage Areas ...............................................................................................58 10.4.3 Beyond the Waste Boundary ...............................................................................58 10.4.4 Off-Site ................................................................................................................58 10.5 Comparison of Results to 2L Standards ......................................................................59 10.6 Comparison of Results to Background ........................................................................59 10.6.1 Background .........................................................................................................59 10.6.2 Ash Basin: Primary and Secondary Cells .............................................................60 10.6.3 Ash Storage Areas ...............................................................................................60 10.6.4 Beyond the Waste Boundary ...............................................................................60 10.6.5 Off-Site ................................................................................................................60 10.7 Groundwater Geochemistry ........................................................................................61 10.8 Groundwater Speciation .............................................................................................61 10.9 Radiological Laboratory Testing ..................................................................................62 10.10 CCR Rule Groundwater Detection and Assessment Monitoring Parameters ...........62 11.0 Hydrogeological Investigation .........................................................................................64 11.1 Hydrostratigraphic Layer Development .......................................................................64 11.2 Hydrostratigraphic Layer Properties ............................................................................65 Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin TABLE OF CONTENTS v 11.2.1 Borehole In-Situ Tests .........................................................................................65 11.2.2 Monitoring Well and Observation Well Slug Tests ................................................66 11.2.3 Laboratory Permeability Tests .............................................................................67 11.2.4 Hydrostratigraphic Layer Parameters ...................................................................67 11.3 Vertical Hydraulic Gradients ........................................................................................67 11.4 Groundwater Velocity ..................................................................................................67 11.5 Contaminant Velocity ..................................................................................................68 11.6 Plume's Physical and Chemical Characterization ........................................................68 11.6.1 Shallow Aquifer ....................................................................................................69 11.6.2 Bedrock Aquifer ...................................................................................................70 11.7 Groundwater / Surface Water Interaction ....................................................................70 11.8 Estimated Seasonal High and Seasonal Low Groundwater Elevations – Compliance and Voluntary Wells ...............................................................................................................70 12.0 Screening Level Risk Assessment ..................................................................................71 12.1 Human Health Screening ............................................................................................71 12.1.1 Introduction ..........................................................................................................71 12.1.2 Site Conceptual Model .........................................................................................71 12.1.3 Human Health Risk-Based Screening Levels .......................................................74 12.1.4 Site-Specific Risk Based Remediation Standards ................................................75 12.1.5 NCDENR Receptor Well Investigation .................................................................75 12.1.6 Human Health Screening Summary .....................................................................75 12.2 Ecological Screening ..................................................................................................76 12.2.1 Introduction ..........................................................................................................76 12.2.2 Ecological Setting ................................................................................................76 12.2.3 Fate and Transport Mechanisms ..........................................................................81 12.2.4 Comparison to Ecological Screening Levels ........................................................81 12.2.5 Uncertainty and Data Gaps ..................................................................................82 12.2.6 Scientific/Management Decision Point .................................................................83 12.2.7 Ecological Risk Screening Summary ...................................................................83 13.1 Fate and Transport Groundwater Modeling .................................................................84 13.2 Batch Geochemical Modeling .....................................................................................85 13.3 Geochemical Site Conceptual Model ..........................................................................85 14.0 Data Gaps – Site Conceptual Model Uncertainties .........................................................88 Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin TABLE OF CONTENTS vi 14.1 Data Gaps ..................................................................................................................88 14.1.1 Data Gaps Resulting from Temporal Constraints .................................................88 14.1.2 Data Gaps Resulting from Review of Data Obtained During CSA Activities .........89 14.2 Site Heterogeneities ....................................................................................................89 14.3 Impact of Data Gaps and Site Heterogeneities ...........................................................89 15.0 Planned Sampling for CSA Supplement .........................................................................90 15.1 Sampling Plan for Inorganic Constituents ...................................................................90 15.2 Sampling Plan for Speciation Constituents .................................................................90 16.0 Interim Groundwater Monitoring Plan .............................................................................91 16.1 Sampling Frequency ...................................................................................................91 16.2 Constituent and Parameter List ...................................................................................91 16.3 Proposed Sampling Locations ....................................................................................91 16.4 Proposed Background Wells .......................................................................................91 17.0 Discussion ......................................................................................................................92 17.1 Summary of Completed and Ongoing Work ................................................................92 17.2 Nature and Extent of Contamination ...........................................................................93 17.2.1 Groundwater – Surficial Aquifer ...........................................................................93 17.2.2 Groundwater - Bedrock Aquifer ............................................................................93 17.2.3 Groundwater - East of the Ash Basin ...................................................................94 17.3 Maximum Contaminant Concentrations ......................................................................94 17.4 Contaminant Migration and Potentially Affected Receptors .........................................95 18.0 Conclusions ....................................................................................................................96 18.1 Source and Cause of Contamination ..........................................................................96 18.2 Imminent Hazards to Public Health and Safety and Actions Taken to Mitigate them in Accordance to 15A NCAC 02L .0106(f) .................................................................................96 18.3 Receptors and Significant Exposure Pathways ...........................................................96 18.4 Horizontal and Vertical Extent of Soil and Groundwater Contamination and Significant Factors Affecting Contaminant Transport ..............................................................................96 18.5 Geological and Hydrogeological Features influencing the Movement, Chemical, and Physical Character of the Contaminants ................................................................................98 18.6 Proposed Continued Monitoring ..................................................................................99 18.7 Preliminary Evaluation of Corrective Action Alternatives .............................................99 19.0 References ................................................................................................................... 100 Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF FIGURES vii List of Figures (organized by CSA report section) Executive Summary  ES-1: Site Conceptual Model – Plan View Map 1.0 Introduction <No Figures> 2.0 Site History and Description  Figure 2-1: Site Location Map  Figure 2-2: Site Layout Map  Figure 2-3: Pre-Ash Basin USGS Map  Figure 2-4: Site Features Map  Figure 2-5: Site Vicinity Map  Figure 2-6: Dan River Steam Station Water Schematic Flow Diagram  Figure 2-7: Compliance and Voluntary Monitoring Wells 3.0 Source Characteristics  Figure 3-1: Photo of Fly Ash and Bottom Ash  Figure 3-2: Elemental Composition for Bottom Ash, Fly Ash, Shale, and Volcanic Ash  Figure 3-3: Coal Ash TCLP Leachate Concentration vs. Regulatory Limits  Figure 3-4: Trace Elements in Fly Ash vs Soil  Figure 3-5: Trace Elements in Bottom Ash vs Soil 4.0 Receptor Information  Figure 4-1: Receptor Map – USGS Base  Figure 4-2: Receptor Map – Aerial Base  Figure 4-3: Ash Basin Underground Features Map  Figure 4-4: Ash Storage Area Underground Features Map  Figure 4-5: Surface Water Bodies s  Figure 4-6: Contiguous Property Owners to the Ash Basin Waste Boundary 5.0 Regional Geology and Hydrogeology  Figure 5-1: Tectonostratigraphic Map of the Southern and Central Appalachians  Figure 5-2: Regional Geologic Map  Figure 5-3: Interconnected, Two-Medium Piedmont Groundwater System  Figure 5-4: Conceptual Variations of the Transition Zone due to Rock Type / Structure Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF FIGURES viii  Figure 5-5: Piedmont Slope-Aquifer System 6.0 Site Geology and Hydrogeology  Figure 6-1: Site Geologic Map  Figure 6-2: Monitoring Well and Sample Location with Transects Map  Figure 6-3: Topographic Lineaments and Rose Diagram  Figure 6-4: Aerial Photography Lineaments and Rose Diagram  Figure 6-5: Water Table Surface Map – S Wells  Figure 6-6: Potentiometric Surface Map – D Wells  Figure 6-7: Potentiometric Surface Map – BR Wells 7.0 Source Characterization  Figure 7-1: Source Characterization Sample Location Map 8.0 Soil and Rock Characterization  Figure 8-1: Soil Analytical Results – Plan View (PSRG Exceedances)  Figure 8-2: Cross Section A-A’ Solid Matrix Analytical Results  Figure 8-3: Cross Section B-B’ Solid Matrix Analytical Results  Figure 8-4: Cross Section C-C’ Solid Matrix Analytical Results  Figure 8-5: Cross Section D-D’ Solid Matrix Analytical Results 9.0 Surface Water and Sediment Characterization  Figure 9-1: Seep and Surface Water Sample Locations  Figure 9-2: NCDENR March 2014 Sample Locations 10.0 Groundwater Characterization  Figure 10-1: Mean Arsenic Groundwater Concentrations by County  Figure 10-2: Mean Iron Groundwater Concentrations by County  Figure 10-3: Manganese Concentrations in Well Water Compared to Soil Systems  Figure 10-4: Regional Groundwater Quality – Manganese  Figure 10-5: Regional Groundwater Quality - pH  Figure 10-6: Thallium Distribution in Soil  Figure 10-7: Regional Groundwater Quality - Vanadium  Figure 10-8: Monitoring Well and Sample Location Map  Figure 10-9: Typical Well Construction Details  Figure 10-10: Time Series Plot: Compliance Well MW -20S Antimony vs. Turbidity  Figure 10-11: Time Series Plot: Compliance Well MW -21S Antimony vs. Turbidity  Figure 10-12: Time Series Plot: Compliance Well MW -22D Antimony vs. Turbidity  Figure 10-13: Time Series Plot: Compliance Well MW -21S Arsenic vs. Turbidity Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF FIGURES ix  Figure 10-14: Time Series Plot: Compliance Well MW-20S Iron vs. Turbidity  Figure 10-15: Time Series Plot: Compliance Well MW -22S Iron vs. Turbidity  Figure 10-16: Time Series Plot: Compliance Well MW -22D Iron vs. Turbidity  Figure 10-17: Time Series Plot: Compliance Well MW -23D Iron vs. Turbidity  Figure 10-18: Time Series Plot: Compliance Well MW -20S Manganese vs. Turbidity  Figure 10-19: Time Series Plot: Compliance Well MW -20D Manganese vs. Turbidity  Figure 10-20: Time Series Plot: Compliance Well MW -21S Manganese vs. Turbidity  Figure 10-21: Time Series Plot: Compliance Well MW -21D Manganese vs. Turbidity  Figure 10-22: Time Series Plot: Compliance Well MW -22S Manganese vs. Turbidity  Figure 10-23: Time Series Plot: Compliance Well MW -22D Manganese vs. Turbidity  Figure 10-24: Time Series Plot: Compliance Well MW-23D Manganese vs. Turbidity  Figure 10-25: Time Series Plot: Compliance Well MW -20S pH vs. Turbidity  Figure 10-26: Time Series Plot: Compliance Well MW -21S pH vs. Turbidity  Figure 10-27: Time Series Plot: Compliance Well MW -23D pH vs. Turbidity  Figure 10-28: Time Series Plot: Compliance Well MW -21D Sulfate vs. Turbidity  Figure 10-29: Time Series Plot: Compliance Well MW -21D Total Dissolved Solids (TDS) vs. Turbidity  Figure 10-30: Time Series Plot: Shallow Compliance Monitoring Wells - Antimony  Figure 10-31: Time Series Plot: Deep Compliance Monitoring Wells - Antimony  Figure 10-32: Time Series Plot: Shallow Compliance Monitoring Wells – Arsenic  Figure 10-33: Time Series Plot: Deep Compliance Monitoring Wells – Arsenic  Figure 10-34: Time Series Plot: Shallow Compliance Monitoring Wells – Boron  Figure 10-35: Time Series Plot: Deep Compliance Monitoring Wells – Boron  Figure 10-36: Time Series Plot: Shallow Compliance Monitoring Wells – Iron  Figure 10-37: Time Series Plot: Deep Compliance Monitoring W ells – Iron  Figure 10-38: Time Series Plot: Shallow Compliance Monitoring Wells – Manganese  Figure 10-39: Time Series Plot: Deep Compliance Monitoring Wells – Manganese  Figure 10-40: Time Series Plot: Shallow Compliance Monitoring Wells – pH  Figure 10-41: Time Series Plot: Deep Compliance Monitoring Wells – pH  Figure 10-42: Time Series Plot: Shallow Compliance Monitoring Wells – Sulfate  Figure 10-43: Time Series Plot: Deep Compliance Monitoring Wells – Sulfate  Figure 10-44: Time Series Plot: MW -20S vs MW -23D(BG) – Manganese (Total)  Figure 10-45: Time Series Plot: MW -20D vs MW -23D(BG) – Manganese (Total)  Figure 10-46: Time Series Plot: MW -21S vs MW-23D(BG) – Manganese (Total)  Figure 10-47: Time Series Plot: MW -21D vs MW -23D(BG) – Manganese (Total)  Figure 10-48: Time Series Plot: MW -22S vs MW-23D(BG) – Manganese (Total)  Figure 10-49: Time Series Plot: MW -22D vs MW -23D(BG) – Manganese (Total)  Figure 10-50: Time Series Plot: MW -20S vs MW-23D(BG) – Iron (Total)  Figure 10-51: Time Series Plot: MW -22S vs MW-23D(BG) – Iron (Total) Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF FIGURES x  Figure 10-52: Time Series Plot: MW -22D vs MW -23D(BG) – Iron (Total)  Figure 10-53: Time Series Plot: MW -20S vs MW-23D(BG) – pH (Field)  Figure 10-54: Time Series Plot: MW -21S vs MW-23D(BG) – pH (Field)  Figure 10-55: Stacked Time Series Plot: Manganese Exceedances for Compliance Wells  Figure 10-56: Stacked Time Series Plot: Iron Exceedances for Compliance Wells  Figure 10-57: MW-20S vs MW -23D (BG) Ratio of Concentrations  Figure 10-58: MW-20D vs MW-23D (BG) Ratio of Concentrations  Figure 10-59: MW-21S vs MW -23D (BG) Ratio of Concentrations  Figure 10-60: MW-21D vs MW-23D (BG) Ratio of Concentrations  Figure 10-61: MW-22S vs MW -23D (BG) Ratio of Concentrations  Figure 10-62: MW-22D vs MW-23D (BG) Ratio of Concentrations  Figure 10-63: Groundwater Analytical Results – Plan View (2L Exceedances)  Figure 10-64: Antimony Isoconcentration Contour Map – Shallow Aquifer (S Wells)  Figure 10-65: Antimony Isoconcentration Contour Map – Shallow Aquifer (D Wells)  Figure 10-66: Figure 10-3: Antimony Isoconcentration Contour Map – Shallow Aquifer (BR Wells)  Figure 10-67: Arsenic Isoconcentration Contour Map – Shallow Aquifer (S Wells)  Figure 10-68: Arsenic Isoconcentration Contour Map – Shallow Aquifer (D Wells)  Figure 10-69: Arsenic Isoconcentration Contour Map – Deep Aquifer (BR Wells)  Figure 10-70: Beryllium Isoconcentration Contour Map – Shallow Aquifer (S Wells)  Figure 10-71: Beryllium Isoconcentration Contour Map – Shallow Aquifer (D Wells)  Figure 10-72: Beryllium Isoconcentration Contour Map – Shallow Aquifer (BR Wells)  Figure 10-73: Boron Isoconcentration Contour Map – Shallow Aquifer (S Wells)  Figure 10-74: Boron Isoconcentration Contour Map – Shallow Aquifer (D Wells)  Figure 10-75: Boron Isoconcentration Contour Map – Deep Aquifer (BR Wells)  Figure 10-76: Chromium Isoconcentration Contour Map – Shallow Aquifer (S Wells)  Figure 10-77: Chromium Isoconcentration Contour Map – Shallow Aquifer (D Wells)  Figure 10-78: Chromium Isoconcentration Contour Map – Deep Aquifer (BR Wells)  Figure 10-79: Cobalt Isoconcentration Contour Map – Shallow Aquifer (S Wells)  Figure 10-80: Cobalt Isoconcentration Contour Map – Shallow Aquifer (D Wells)  Figure 10-81: Cobalt Isoconcentration Contour Map – Deep Aquifer (BR Wells)  Figure 10-82: Iron Isoconcentration Contour Map – Shallow Aquifer (S Wells)  Figure 10-83: Iron Isoconcentration Contour Map – Shallow Aquifer (D Wells)  Figure 10-84: Iron Isoconcentration Contour Map – Deep Aquifer (BR Wells)  Figure 10-85: Manganese Isoconcentration Contour Map – Shallow Aquifer (S Wells)  Figure 10-86: Manganese Isoconcentration Contour Map – Shallow Aquifer (D Wells)  Figure 10-87: Manganese Isoconcentration Contour Map – Deep Aquifer (BR Wells)  Figure 10-88: Selenium Isoconcentration Contour Map – Shallow Aquifer (S Wells)  Figure 10-89: Selenium Isoconcentration Contour Map – Shallow Aquifer (D Wells)  Figure 10-90: Selenium Isoconcentration Contour Map – Deep Aquifer (BR Wells)  Figure 10-91: Sulfate Isoconcentration Contour Map – Shallow Aquifer (S Wells)  Figure 10-92: Sulfate Isoconcentration Contour Map – Shallow Aquifer (D Wells) Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF FIGURES xi  Figure 10-93: Sulfate Isoconcentration Contour Map – Deep Aquifer (BR Wells)  Figure 10-94: TDS Isoconcentration Contour Map – Shallow Aquifer (S Wells)  Figure 10-95: TDS Isoconcentration Contour Map – Shallow Aquifer (D Wells)  Figure 10-96: TDS Isoconcentration Contour Map – Deep Aquifer (BR Wells)  Figure 10-97: Thallium Isoconcentration Contour Map – Shallow Aquifer (S Wells)  Figure 10-98: Thallium Isoconcentration Contour Map – Shallow Aquifer (D Wells)  Figure 10-99: Thallium Isoconcentration Contour Map – Deep Aquifer (BR Wells)  Figure 10-100: Vanadium Isoconcentration Contour Map – Shallow Aquifer (S Wells)  Figure 10-101: Vanadium Isoconcentration Contour Map – Shallow Aquifer (D Wells)  Figure 10-102: Vanadium Isoconcentration Contour Map – Deep Aquifer (BR Wells)  Figure 10-103: Cross Section A-A’ with Groundwater Analytical Results  Figure 10-104: Cross Section B-B’ with Groundwater Analytical Results  Figure 10-105: Cross Section C-C’ with Groundwater Analytical Results  Figure 10-106: Cross Section D-D’ with Groundwater Analytical Results  Figure 10-107: Cation/Anion Concentrations in Ash Basin Porewater Samples  Figure 10-108: Cation/Anion Concentrations in Surface Water and Ash Basin Water  Figure 10-109: Cation/Anion Concentrations in Seeps  Figure 10-110: Cation/Anion Concentrations in Background Wells  Figure 10-111.1: Cation/Anion Concentrations in Shallow Wells (S Wells)  Figure 10-111.2: Cation/Anion Concentrations in Shallow Wells (S Wells)  Figure 10-112.1: Cation/Anion Concentrations in Deep Wells (D Wells)  Figure 10-112.2: Cation/Anion Concentrations in Deep Wells (D Wells)  Figure 10-112.3: Cation/Anion Concentrations in Deep Wells (D Wells)  Figure 10-113.1: Cation/Anion Concentrations in Bedrock Wells (BR Wells)  Figure 10-113.2: Cation/Anion Concentrations in Bedrock Wells (BR Wells)  Figure 10-114: Sulfate/Chloride Ratio in Ash Basin Porewater Samples  Figure 10-115: Sulfate/Chloride Ratio in Surface Water and Ash Basin Samples  Figure 10-116: Sulfate/Chloride Ratio in Seep Samples  Figure 10-117: Sulfate/Chloride Ratio in Background Monitoring Wells  Figure 10-118.1: Sulfate/Chloride Ratio in Shallow Wells  Figure 10-118.2: Sulfate/Chloride Ratio in Shallow Wells  Figure 10-119.1: Sulfate/Chloride Ratio in Deep Wells  Figure 10-119.2: Sulfate/Chloride Ratio in Deep Wells  Figure 10-120: Sulfate/Chloride Ratio in Bedrock Wells  Figure 10-121: Piper Diagram: Seeps and Surface Water  Figure 10-122: Piper Diagram: Ash Basin Water, Porewater, Seeps, and Background Wells  Figure 10-123: Piper Diagram: Ash Basin Water, Porewater, and Backgrounds Monitoring Wells  Figure 10-124: Piper Diagram: Ash Basin Porewater, Surface Water and Downgradient Monitoring Wells  Figure 10-125: Detection Monitoring Constituents Detected in Shallow Wells  Figure 10-126: Detection Monitoring Constituents Detected in Deep Wells  Figure 10-127: Detection Monitoring Constituents Detected in Bedrock Wells  Figure 10-128: Assessment Monitoring Constituents Detected in Shallow Wells  Figure 10-129: Assessment Monitoring Constituents Detected in Deep Wells Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF FIGURES xii  Figure 10-130: Assessment Monitoring Constituents Detected in Bedrock Wells Hydrogeological Investigation  Figure 11-1: Major Transects  Figure 11-2: Hydrostratigraphic Cross Section A-A’  Figure 11-3: Hydrostratigraphic Cross Section B-B’  Figure 11-4: Hydrostratigraphic Cross Section C-C’  Figure 11-5: Hydrostratigraphic Cross Section D-D’  Figures 11-6: Comparison of Groundwater and Surface Water – Plan View (2L Exceedances)  Figure 11-7: Groundwater Velocities – S Wells  Figure 11-8: Groundwater Velocities – D Wells  Figure 11-9: Groundwater Velocities – BR Wells Screening Level Risk Assessment  Figure 12-1 Human Health Screening Conceptual Site Model  Figure 12-2: Ecological Screening Conceptual Site Model Groundwater Modeling <No Figures> Data Gaps – Conceptual Site Model Uncertainties <No Figures> Planned Sampling for CSA Supplement <No Figures> Interim Groundwater Monitoring Plan <No Figures> Discussion <No Figures> Conclusions and Recommendations <No Figures> References <No Figures> Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF TABLES xiii List of Tables (organized by CSA report section) Executive Summary <No Tables> 1.0 Introduction  Table 1-1: Comparison of Sampling Data to Federal and State Regulatory Standards 2.0 Site History and Description  Table 2-1: NPDES Groundwater Monitoring Requirements  Table 2-2: Exceedances of 2L Standards at Compliance Wells (January 2011 – May 2015)  Table 2-3: Summary of Onsite Environmental Incidents 3.0 Source Characteristics  Table 3-1: Range (10th percentile – 90th percentile) in Bulk Composition of Fly Ash, Bottom Ash, Rock, and Soil 4.0 Receptor Information  Table 4-1: Public and Private Water Supply Wells within 0.5-mile Radius of Ash Basin Compliance Boundary  Table 4-2: Property Owner Addresses Contiguous to the Ash Basin Waste Boundary 5.0 Regional Geology and Hydrogeology <No Tables> 6.0 Site Geology and Hydrogeology  Table 6-1: Soil Mineralogy Results  Table 6-2: Soil Chemistry Results – Oxides  Table 6-3: Soil Chemistry Results – Elemental  Table 6-4: Transition Zone Mineralogy Results  Table 6-5: Transition Zone Mineralogy Results – Oxides  Table 6-6: Whole Rock Chemistry – Oxides  Table 6-7: Whole Rock Chemistry – Elemental  Table 6-8: Summary of Horizontal Hydraulic Gradient Calculations 7.0 Source Characterization  Table 7-1: Solid Matrix Parameters and Analytical Methods Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF TABLES xiv  Table 7-2.1: Ash Sample Results - Ash Basin  Table 7-2.2: Ash Sample Results – Ash Storage Area  Table 7-3: Aqueous Matrix Parameters and Analytical Methods  Table 7-4: Ash Basin Surface Water Sample Results  Table 7-5: Ash Basin Porewater Sample Results  Table 7-6: Porewater Speciation Results  Table 7-7: Porewater Radiological Testing Results  Table 7-8: Ash Sample SPLP Results  Table 7-9: NCDENR March 2014 Sampling Results  Table 7-10: Seep Sample Results  Table 7-11: Seep Speciation Results 8.0 Soil and Rock Characterization  Table 8-1: Solid Matrix Sampling Plan  Table 8-2: Soil, Ash, and Rock Parameters and Constituent Analysis – Analytical Methods  Table 8-3: Total Inorganic Results – Background Soil  Table 8-4: Total Inorganic Results – Background PWR and Bedrock  Table 8-5: Total Inorganic Results – Soil  Table 8-6: Totals Inorganic Results – PWR and Bedrock  Table 8-7: Frequency and Concentration Ranges for COI Exceedances of North Carolina PSRGs  Table 8-8: Range of Constituent Concentrations and Comparison to Range of Background Soil, PWR, and Bedrock Concentrations – Beneath Ash Basin  Table 8-9: Range of Constituent Concentrations and Comparison to Range of Background Soil, PWR, and Bedrock Concentrations – Beneath the Ash Storage Areas  Table 8-10: Range of Constituent Concentrations and Comparison to Range of Background Soil, PWR, and Bedrock Concentrations – Outside Waste Boundary 9.0 Surface Water and Sediment Characterization  Table 9-1: Surface Water Sample Results – Totals and Dissolved  Table 9-2: Frequency and Concentration Ranges for COI Exceedances of North Carolina 2B Standards  Table 9-3: Range of Constituent Concentrations and Comparison to Range of Background Surface Water Concentrations – Ash Basin Surface Water  Table 9-4: Range of Constituent Concentrations and Comparison to Range of Background Surface Water Concentrations – Dan River Surface Water  Table 9-5: Range of Constituent Concentrations and Comparison to Range of Background Surface Water Concentrations – Tributary Stream Surface Water Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF TABLES xv  Table 9-6: Range of Constituent Concentrations Without 2B Standards and Comparison to Range of Background Surface Water Concentrations – Ash Basin Surface Water  Table 9-7: Range of Constituent Concentrations Without 2B Standards and Comparison to Range of Background Surface Water Concentrations – Dan River Surface Water  Table 9-8: Range of Constituent Concentrations Without 2B Standards and Comparison to Range of Background Surface Water Concentrations – Tributary Stream Surface Water  Table 9-9: Surface Water Speciation Results  Table 9-10: Sediment Sample Results – Totals 10.0 Groundwater Characterization  Table 10-1: COIs Near DRSS with Associated State and Federal Drinking Water Standards  Table 10-2: Regional Average Concentrations of Iron in Groundwater  Table 10-3: Regional Average Concentrations of Manganese in Groundwater  Table 10-4: Concentration of Manganese in 20-Mile Radius Surrounding DRSS  Table 10-5: Concentration of Vanadium in 20-Mile Radius Surrounding DRSS  Table 10-6: Monitoring Well Construction Information  Table 10-7: Compliance and Voluntary Well Construction Information  Table 10-8: Redox Potential  Table 10-9: Background Groundwater Sample Results  Table 10-10: Ash Basin Groundwater Sample Results  Table 10-11: Groundwater Sample Results  Table 10-12: Groundwater Sample Results Compared to North Carolina 2L Standards  Table 10-13: Range of Constituent Concentrations and Comparison to Range of Background Groundwater Concentrations – Beneath Ash Basin  Table 10-14: Range of Constituent Concentrations and Comparison to Range of Background Groundwater Concentrations – Beneath Ash Storage Area  Table 10-15: Range of Constituent Concentrations and Comparison to Range of Background Groundwater Concentrations – Beyond Waste Boundary  Table 10-16: Range of Constituent Concentrations and Comparison to Range of Background Groundwater Concentrations – Off-Site  Table 10-17: Groundwater Speciation Results  Table 10-18: Groundwater Radiological Testing Results 11.0 Hydrogeological Investigation  Table 11-1: Soil/Material Properties for Ash, Fill, Alluvium, Soil/Saprolite  Table 11-2: Field Permeability Test Results  Table 11-3: Slug Test Permeability Results Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF TABLES xvi  Table 11-4: Historic Slug Test Permeability Results  Table 11-5: Laboratory Permeability Test Results  Table 11-6: Hydrostratigraphic Layer Properties – Horizontal Hydraulic Conductivity  Table 11-7: Hydrostratigraphic Layer Properties – Vertical Hydraulic Conductivity  Table 11-8: Total Porosity for Upper Hydrostratigraphic Units (A, F, S, M1, and M2)  Table 11-9: Estimated Effective Porosity/Specific Yield and Specific Storage for Upper Hydrostratigraphic Units (A, F, S, M1, and M2)  Table 11-10: Total Porosity, Secondary (Effective) Porosity/Specific Yield, and Specific Storage for Lower Hydrostratigraphic Units (TZ and BR)  Table 11-11: Hydraulic Gradients –Vertical  Table 11-12: Groundwater Velocities 12.0 Screening Level Risk Assessment  Table 12-1: Selection of Human Health COPCs – Groundwater  Table 12-2: Selection of Human Health COPCs – Soil  Table 12-3: Selection of Human Health COPCs – Surface Water  Table 12-4: Selection of Human Health COPCs – Sediment  Table 12-5: Contaminants of Potential Human Health Concern  Table 12-6: Selection of Ecological COPCs – Soil  Table 12-7: Selection of Ecological COPCs – Freshwater  Table 12-8: Selection of Ecological COPCs – Sediment  Table 12-9: Contaminants of Potential Ecological Concern  Table 12-10: Threatened and Endangered Species in Rockingham County 13.0 Groundwater Modeling <No Tables> 14.0 Data Gaps – Conceptual Site Model Uncertainties <No Tables> 15.0 Planned Sampling for CSA Supplement  Table 15-1: Wells with 2L Standard Exceedances – Constituents to be Speciated 16.0 Interim Groundwater Monitoring Plan  Table 16-1: Recommended Parameters and Constituents  Table 16-2: Sample Locations in Interim Groundwater Monitoring Plan 17.0 Discussion  Table 17-1: Maximum Contaminant Concentrations Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF TABLES xvii 18.0 Conclusions and Recommendations <No Tables> 19.0 References <No Tables> Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF APPENDICES xviii List of Appendices (provided electronically) Appendix A: Introduction  NORR Letter  Summary of Work Plan Submittals and NCDENR-Duke Energy Correspondence  Revised Groundwater Assessment Work Plan Appendix B: Receptor Information  Updated Receptor Survey Report Appendix C: Source Characterization  Drilling Procedures  Drilling and Installation Variances Appendix D: Soil and Rock Characterization  Sampling Procedures  Sampling Variances Appendix E: Field, Sampling, and Data Analysis Quality Assurance / Quality Control  Field and Sampling Quality Assurance / Quality Control Procedures  Data Analysis Quality Assurance / Quality Control Procedures Appendix F: Surface Water and Sediment Characterization  Sampling Procedures  Sampling Variances Appendix G: Groundwater Characterization  Well Development Procedure  Well Development Forms  Sampling Procedures  Sampling Forms  Sampling Variances  Evaluation of Turbidity in Existing Voluntary and Compliance Wells  Evaluation of Need for Off-site Monitoring Wells Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF APPENDICES xix Statistical Analysis of Groundwater Results Appendix H: Hydrogeological Investigation  Boring Logs  Well Construction Records  Historical Boring Logs and Well Construction Records  Soil Physical Lab Reports  Mineralogy Lab Reports  Slug Test Reports  Field Permeability Data  Historic Permeability Data  Fetter-Bear Diagrams – Porosity  Estimated Seasonal High and Low Groundwater Elevations Calculation Appendix I: Screening Level Risk Assessment Supporting Data  Trustee Letters and Responses  Checklist for Ecological Assessments/Sampling Appendix J: Historical Analytical Results Table Appendix K: Laboratory Reports Appendix L: Soil Sample and Rock Core Photographs Appendix M: Certification Form for CSA Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF ACRONYMS AND ABBREVIATIONS xx List of Acronyms and Abbreviations µg/L micrograms per liter 2L Standards 15A NCAC 02L .0202 Groundwater Quality Standards AMEC AMEC Environment & Infrastructure APS NCDENR DWR Aquifer Protection Section AST Aboveground Storage Tank ASTM American Society for Testing and Materials BG Background bgs Below ground surface BR Bedrock CAMA Coal Ash Management Act CAP Corrective Action Plan CCR Coal Combustion Residuals COI Constituent of Interest COPC Contaminant of Potential Concern CSA Comprehensive Site Assessment CSM Conceptual Site Model DEH NCDENR Department of Environmental Health DO Dissolved oxygen DRCCS Dan River Combined Cycle Station DRSS Dan River Steam Station DTW Depth to Water Duke Energy Duke Energy Carolinas, LLC DWR NCDENR Division of Water Resources EDR Environmental Data Resources EPD Georgia Environmental Protection Division EPRI Electric Power Research Institute ESH Estimated Seasonal High ESL Estimated Seasonal Low GSCM Geochemical Site conceptual model GIS Geographic Information Systems HFO Hydrous ferric oxide HQ Hazard Quotient IMAC Interim Maximum Allowable Concentration Kd Sorption Coefficient mD millidarcies MDL Method detection limit mg/kg Milligrams per kilogram Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF ACRONYMS AND ABBREVIATIONS xxi mm milligrams MNA Monitored Natural Attenuation MRL Method reporting limit MW Megawatt N Standard Penetration Testing Values NRCS Natural Resources Conservation Service NCAC North Carolina Administrative Code NCDENR North Carolina Department of Environment and Natural Resources NCDHHS North Carolina Department of Health and Human Services NCNHP North Carolina Natural Heritage Program NCWRC North Carolina Wildlife Resources Commission ng/L Nanograms per liter NHD USGS National Hydrography Dataset NORR Notice of Regulatory Requirements NPDES National Pollutant Discharge Elimination System NTU Nephelometric Turbidity Unit NURE National Uranium Resource Evaluation PL Prediction Limit PMCL Primary Maximum Contaminant Level ppb parts per billion ppm parts per million PSRG Preliminary Soil Remediation Goal PWR Partially Weathered Rock PWSS NCDENR Department of Environmental Health Public Water Supply Section RCRA Resource Conservation and Recovery Act REC Recovery RL Reporting Limit RQD Rock Quality Designation RSL USEPA Regional Screening Level SCM Site Conceptual Model SCS U.S. Department of Agriculture Soil Conservation Service SLERA Screening Level Ecological Risk Assessment SMCL Secondary Maximum Contaminant Level SMDP Scientific/Management Decision Point SPLP Synthetic Precipitation Leaching Procedure SQL Sample Quantitation Limit SWAP NCDENR DWR Source Water Assessment Program TCLP Toxicity Characteristic Leaching Procedure TDS Total Dissolved Solids Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin LIST OF ACRONYMS AND ABBREVIATIONS xxii TZ Transition Zone UNC University of North Carolina UNCC University of North Carolina at Charlotte USCS Unified Soil Classification System USDA U.S. Department of Agriculture USEPA U.S. Environmental Protection Agency USGS U.S. Geological Survey UST Underground Storage Tank Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 1.0 INTRODUCTION 1 1.0 Introduction Duke Energy Carolinas, LLC (Duke Energy) owns and operated the Dan River Steam Station (DRSS), located on the Dan River in Rockingham County near Eden, North Carolina. DRSS began operation as a coal-fired generating station in 1949 and was retired from service in 2012. The Dan River Combined Cycle Station (DRCCS) natural gas generating facility was constructed at the site and began operations in 2012. Historically, coal ash residue from DRSS’s coal combustion process was disposed of in two ash basins located northeast of the station and adjacent to the Dan River. Discharge from the ash basins is currently permitted by the North Carolina Department of Environment and Natural Resources (NCDENR) Division of Water Resources (DWR) under the National Pollutant Discharge Elimination System (NPDES) Permit NC0003468. Duke Energy has implemented voluntary and NPDES permit-required compliance groundwater monitoring at DRSS. Compliance groundwater monitoring as required by the NPDES permit began in 1993and included MW -9, MW -10, MW -11, and MW-12. In 2007, additional monitoring wells, MW -9D, MW -10D, MW -11D, and MW-12D, were installed as part of Duke Energy’s voluntary monitoring program. From 1993 to 2010, biannual voluntary groundwater monitoring was performed around the DRSS ash basin with analytical results submitted to NCDENR DWR. In October 2010, new compliance monitoring wells, MW -20S/D, MW-21S/D, MW -22S/D, and MW -23D, were installed and the monitoring wells previously installed became part of the voluntary monitoring program. Additional groundwater monitoring was required beginning in March 2011 with the frequency of sampling and the parameters to be analyzed outlined in the NPDES permit. From January 2011 through May 2015, the compliance groundwater monitoring wells at the DRSS site have been sampled a total of 14 times as part of triannual sampling required in the NPDES permit. NPDES Permit Condition A (11), Version 1.1, dated June 15, 2011, lists the groundwater monitoring wells to be sampled, the parameters and constituents to be measured and analyzed, and the requirements for sampling frequency and reporting results. Recent monitoring events have indicated exceedances of 15A NCAC 02L .0200 Groundwater Quality Standards (2L Standards; refer to North Carolina Administrative Code Title 15A Department of Environmental and Natural Resources Division of Water Quality Subchapter 2L Section .0100, .0200, .0300 Classifications and Water Quality Standards Applicable to the Groundwaters of North Carolina) at DRSS, prompting NCDENR’s requirement for Duke Energy to perform a groundwater assessment at the site and prepare a Comprehensive Site Assessment (CSA) report. The Coal Ash Management Act of 2014 (CAMA) also directed owners of coal combustion residuals (CCR) surface impoundments to conduct groundwater monitoring and assessment and submit a Groundwater Assessment Report. This CSA is submitted to meet the requirements of both NCDENR and the CAMA. 1.1 Purpose of Comprehensive Site Assessment The purpose of this Comprehensive Site Assessment (CSA) is to characterize the extent of contamination resulting from historical production and storage of coal ash, evaluate the Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 1.0 INTRODUCTION 2 chemical and physical characteristics of the contaminants, investigate the geology and hydrogeology of the site including factors relating to contaminant transport, and examine risk to potential receptors and exposure pathways. This CSA was prepared in general accordance with requirements outlined in the following regulations and documents:  Classifications and Water Quality Standards Applicable to the Groundwaters of North Carolina in Title 15A NCAC 02L .0106(g);  Coal Ash Management Act in G.S. 130A-309.209(a);  Notice of Regulatory Requirements (NORR) issued by NCDENR on August 13, 2014;  Conditional Approval of Revised Groundwater Assessment Work Plan issued by NCDENR on February 16, 2015; and  Subsequent meetings and correspondence between Duke Energy and NCDENR. This assessment includes evaluation of possible impacts from the ash basins and related ash storage facilities, and consisted of the following activities:  Completion of soil borings and installation of groundwater monitoring wells to faciliatate collection and analysis of chemical, physical, and hydrogeological parameters of subsurface materials encountered within and beyond the waste and compliance boundaries;  Evaluation of testing data to supplement the site conceptual model (SCM);  Update of the receptor survey previously completed in 2014; and  Completion of a screening-level risk assessment. In this report, constituents are those chemicals or compounds that were identified in the approved W ork Plan for sampling and analysis. For DRSS, these include antimony, arsenic, boron, chromium, cobalt, iron, manganese, selenium, thallium, vanadium, sulf ate, and total dissolved solids (TDS). If a constituent exceeded its respective regulatory standard or screening level in the medium in which it was found, the constituent was then termed a Constituent of Interest (COI) and evaluated in the human health and ecological screening-level risk assessment (Section 12.0). 1.2 Regulatory Background 1.2.1 NCDENR Requirements NCDENR DWR regulates wastewater discharges from coal ash ponds to state waters, streams, and lakes, and requires groundwater monitoring and stormwater management at these facilities. Duke Energy’s coal-fired power facilities are regulated through federal NPDES wastewater permits. As part of these permits, the facilities must also comply with the state water quality standards and U.S. Environmental Protection Agency (USEPA) water quality criteria. Groundwater monitoring is performed at Duke Energy facilities in accordance with approved monitoring plans and NPDES permits for each site. Included in these monitoring evaluations is a determination if site-specific background concentrations (i.e., naturally occurring constituents in Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 1.0 INTRODUCTION 3 the soil profile and groundwater) for various constituents (e.g., iron and manganese) are contributing to reported concentrations. For each facility, if it is determined that activities on the property are causing noncompliance with NCDENR DWR regulatory requirements, the agency will require the permittee to perform an assessment and to develop and implement a Corrective Action Plan (CAP) in accordance with state regulations. 1.2.2 Notice of Regulatory Requirements Chapter 143, North Carolina General Statutes, authorizes and directs the Environmental Management Commission of the Department of Environment and Natural Resources to protect and preserve the water and air resources of the State. NCDENR DWR has the delegated authority to enforce adopted pollution control rules. NCDENR DWR Rule 15A NCAC 02L .0103(d) states that “no person shall conduct or cause to be conducted any activity which causes the concentration of any substance to exceed that specified in” 15A NCAC 02L .0202, Groundwater Quality Standards. On August 13, 2014, NCDENR issued a Notice of Regulatory Requirements (NORR) letter notifying Duke Energy that exceedances of the groundwater quality standards 15A NCAC 02L .0200 Classifications and Water Quality Standards Applicable to the Groundwaters of North Carolina were reported at 14 coal ash facilities owned and operated by Duke Energy, including DRSS. The NORR stipulated that for each coal ash facility, Duke Energy shall conduct a CSA following submittal of a Groundwater Assessment Work Plan (Work Plan) and receptor survey. In accordance with the NORR requirements, a Work Plan was developed, a receptor survey was performed to identify all receptors within a 0.5-mile radius (2,640 feet) of the ash basin compliance boundary, and a CSA was conducted for each coal ash facility. The NORR letter is included in Appendix A. 1.2.3 Coal Ash Management Act Requirements The Coal Ash Management Act (CAMA) of 2014 – General Assembly of North Carolina Senate Bill 729 Ratified Bill (Session 2013) identifies the Dan River site as one of four high priority coal combustion impoundments that are to be closed no later than August 1, 2019. CAMA requires that the CCR in the high priority impoundments be removed and disposed in a landfill, used in a structural fill, or for beneficial reuse. As a component of implementing this objective, CAMA provides instructions for owners of CCR surface impoundments to perform various groundwater monitoring and assessment activities. Section §130A-309.209 of the CAMA ruling specifies groundwater assessment and corrective actions, drinking water supply well surveys and provisions of alternate water supply, and reporting requirements as follows: (a) Groundwater Assessment of Coal Combustion Residuals Surface Impoundments. – The owner of a coal combustion residuals surface impoundment shall conduct groundwater monitoring and assessment as provided in this subsection. The requirements for groundwater monitoring and assessment set out in this subsection are in addition to any other groundwater monitoring and assessment Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 1.0 INTRODUCTION 4 requirements applicable to the owners of coal combustion residuals surface impoundments. (1) No later than December 31, 2014, the owner of a coal combustion residuals surface impoundment shall submit a proposed Groundwater Assessment Plan for the impoundment to the Department for its review and approval. The Groundwater Assessment Plan shall, at a minimum, provide for all of the following: a. A description of all receptors and significant exposure pathways. b. An assessment of the horizontal and vertical extent of soil and groundwater contamination for all contaminants confirmed to be present in groundwater in exceedance of groundwater quality standards. c. A description of all significant factors affecting movement and transport of contaminants. d. A description of the geological and hydrogeological features influencing the chemical and physical character of the contaminants. 2) The Department shall approve the Groundwater Assessment Plan if it determines that the Plan complies with the requirements of this subsection and will be sufficient to protect public health, safety, and welfare; the environment; and natural resources. (3) No later than 10 days from approval of the Groundwater Assessment Plan, the owner shall begin implementation of the Plan. (4) No later than 180 days from approval of the Groundwater Assessment Plan, the owner shall submit a Groundwater Assessment Report to the Department. The Report shall describe all exceedances of groundwater quality standards associated with the impoundment. 1.3 NCDENR-Duke Energy Correspondence In response to both the NORR letter and CAMA requirements, Duke Energy submitted a Work Plan to NCDENR DWR on September 25, 2014 establishing proposed site assessment activities and schedules for the implementation, completion, and submission of a CSA report in accordance with 15A NCAC 02L .0106(g). NCDENR DWR reviewed the Work Plan and provided Duke Energy with initial comments on November 4, 2014. A revised Work Plan was subsequently submitted to the NCDENR DWR on December 30, 2014, and NCDENR DWR provided final comments and conditional approval of the revised Work Plan on February 19, 2015. In addition, Duke Energy submitted proposed adjustments to the CSA guideline and requested clarifications regarding groundwater sampling and speciation of selected constituents to NCDENR on May 14 and May 22, 2015. NCDENR provided responses to these proposed revisions and clarifications in June 2015. Copies of relevant correspondence including Work Plan submittals are included in Appendix A. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 1.0 INTRODUCTION 5 1.4 Approach to Comprehensive Site Assessment The CSA approach was developed based on the NORR guidelines and CAMA requirements. Development of the SCM is based on several documents including but not limited to USEPA’s Monitored Natural Attenuation tiered approach, ASTM 1689-95 (2014) Standard Guide for Developing Site Conceptual Models for Contaminated Sites, and comments received by NCDENR. 1.4.1 NORR Guidance The NORR letter (Appendix A) outlines general guidelines for the CSA report, including guidance from 15A NCAC 02L .0106(g) as described in Section 1.1. The NORR letter also includes Guidelines for Comprehensive Site Assessment for those involved in the investigation of contaminated soil and/or groundwater. The components included in the NORR guidelines were used in developing the site Work Plan and this CSA report. 1.4.2 USEPA Monitored Natural Attenuation Approach In accordance with NCDENR requirements and the February 16, 2015 Conditional Approval letter (Appendix A), the elements of the USEPA’s Monitored Natural Attenuation (MNA) tiered approach has been utilized as part of the investigation associated with the CSA. MNA may be used as a component to meet corrective action requirements if site conditions meet the requirements associated with use of MNA. The approach involves a detailed analysis of site characteristics controlling and sustaining attenuation to support evaluation and selection of MNA as part of a cleanup action for inorganic contaminant plumes in groundwater (USEPA 2007). The site characterization is conducted in a step-wise manner to facilitate collection of data necessary to progressively evaluate the effectiveness of natural attenuation processes within the site aquifer(s). Four general elements are included in the tiered site analysis approach:  Demonstration of active contaminant removal from groundwater and dissolved plume stability;  Determination of the mechanism and rate of attenuation;  Determination of the long-term capacity for attenuation and stability of immobilized contaminants, before, during, and after any proposed remedial activities; and  Design of performance monitoring program, including defining triggers for assessing the remedial action strategy failure, and establishing a contingency plan. Duke Energy will evaluate the USEPA MNA approach further during preparation of the CAP. 1.4.3 ASTM Site Conceptual Model Guidance American Society of Testing and Materials (ASTM) standard guidance document E1689-95 Developing Conceptual Site Models for Contaminated Sites (ASTM 2014) was used as a general component of this CSA. The guidance document provides direction in developing conceptual site models used for the integration of technical information from multiple sources, selection of sampling locations to establish background concentrations of substances, Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 1.0 INTRODUCTION 6 identification of data needs and guidance of data collection activities, and evaluation of risks to human and environmental health posed by a contaminated site. According to ASTM E1689-95, six basic activities are associated with developing a conceptual site model:  Identification of potential contaminants;  Identification and characterization of the source(s) of contaminants;  Delineation of potential migration pathways through environmental media, such as groundwater, surface water, soils, sediment, biota, and air;  Establishment of background areas of contaminants for each contaminated medium;  Identification and characterization of potential environmental receptors (human and ecological); and  Determination of the limits of the study area or system boundaries. Development of a conceptual site model is typically iterative and the complexity of the model should be consistent with the complexity of the site and available data. Information gained through site investigation activities is used to characterize existing physical, biological, and chemical systems at a site. The SCM describes and integrates processes that determine contaminant releases, contaminant migration, and environmental receptor exposure to contaminants. Development of the model is essential to determine potential exposure routes and identify possible impacts to human health and the environment (ASTM 2014). The conceptual site model is used to integrate site information, identify data gaps, and determine whether additional information is needed at the site. The model is also used to facilitate selection of remedial alternatives and determine effectiveness of remedial actions in reducing the exposure of environmental receptors to contaminants (ASTM 2014). This CSA was conducted in accordance with the conditionally approved Work Plan to meet the NCDENR, NORR, and CAMA regulatory requirements described in Section 1.2, and using the NORR, USEPA, and ASTM approaches described above. This assessment information will be used to develop a CAP, to be submitted separately, for the DRSS site that will provide a demonstration of these criteria in support of the recommended site remedy. Data obtained from sampling during this CSA are compared to federal and state regulatory standards shown in Table 1-1. Beginning in Section 7.0, laboratory results are compared to the above-referenced regulatory standards and discussed as either “exceeding” or “not exceeding” those standards. The evaluation of exceedances of these standards forms the basis for determining the need for additional work later in this document. 1.5 Limitations and Assumptions Development of this CSA is based on information provided to HDR by both public and private entities including universities, federal, state and local governments, and information and analytical reports generated by Duke Energy. HDR assumes the information in these documents to be accurate and reliable. This information was used to estimate exposure routes and migration pathways in the subsurface. This CSA was developed using a standard of care Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 1.0 INTRODUCTION 7 ordinarily used by engineering practice under the same or similar circumstances, but may include assumptions based on the accuracy and reliability of data from various entities. CAMA Section §130A-309.209 requires that “No later than 180 days from approval of the Groundwater Assessment Plan, the owner shall submit a Groundwater Assessment Report to the Department”. The schedule dictated by CAMA is compressed relative to the normal schedule required for CSA reports; therefore, data interpretation is limited and subject to change upon receipt of additional data in subsequent rounds of sampling and additional data collected to resolve data gaps identified in Section 14.0. The additional data will be used to inform the corrective actions identified in the CAP. This page is intentionally left blank. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 2.0 SITE HISTORY AND DESCRIPTION 8 2.0 Site History and Description This section provides a description of the DRSS site based on relevant historical data and representative information. The purpose of this characterization is to familiarize readers with the DRSS site. 2.1 Site Location, Acreage, and Ownership The DRSS site is located on the north bank of the Dan River in Eden, Rockingham County, North Carolina (Figure 2-1). The entire DRSS and DRCCS site (Dan River site) occupies approximately 380 acres of land (Figure 2-2). Construction began at the DRSS in 1948 and commercial operation began in 1949. In December 2009, construction commenced on the DRCCS. The DRCCS began commercial operation in 2012 and generates at a capacity of 620 megawatts (MW). Based on the NORR Guideline heading, Provide a history of property ownership and use under the Site History and Source Characterization, this CSA report includes a history of Duke Energy ownership. As of the date of this report, multiple inquiries have not revealed site history information prior to Duke Energy ownership. 2.2 Site Description DRSS is a former coal-fired electricity generating facility along the Dan River. The three-unit station began commercial operation in 1949 with operation of a single coal-fired unit (Unit 1) with a second unit (Unit 2) being added in 1950. A third unit was added by 1955 and resulted in a total installed capacity of 276 MW . A 1953 United States Geological Survey (USGS) topographic map depicting the site prior to construction of the ash basin features is shown on Figure 2-3. All three coal-fired units, along with three 28 MW oil-fired combustion turbine units, were retired in 2012. The DRCCS, a 620 MW combined cycle natural gas facility, began commercial operations on December 10, 2012. The natural topography at the DRSS site generally slopes from northwest to southeast and ranges from an approximate high elevation of 606 feet near the northern property boundary just west of Edgewood Road to an approximate low elevation of 482 feet at the interface with the Dan River. Ground surface elevation varies about 124 feet over an approximate distance of 0.7 miles. Surface water drainage generally follows site topography and flows from the northwest to the southeast across the site except where drainage patterns have been modified by the ash basins or other construction (refer to Section 3.2). A site features map is shown on Figure 2-4. 2.3 Adjacent Property, Zoning, and Surrounding Land Uses Properties located within a 0.5-mile radius of the DRSS ash basin compliance boundary are located in and southeast of Eden, in Rockingham County, North Carolina. The majority of the land is undeveloped property and land use is found to be typical of rural property. Residential properties are located north and northwest of the ash basin compliance boundary within the 0.5- mile radius. One residence is located south of DRSS across the Dan River within the 0.5-mile radius. Two industrial properties are located northeast of DRSS; one of these properties has a Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 2.0 SITE HISTORY AND DESCRIPTION 9 wastewater treatment plant discharging into the Dan River downstream of the site. Farm land is located southeast of the station across the Dan River. Figure 2-5 depicts these properties surrounding the Dan River site. 2.4 Adjacent Surface Water Bodies and Classifications The DRSS site is situated within the Upper Dan River watershed in the Roanoke River Basin. The ash basin location is adjacent to the Dan River. Two unnamed tributaries are located along the eastern and western boundaries of the DRCCS property (Figure 4-5). Two other unnamed tributaries are located south of the DRSS site and across the Dan River. No other surface water bodies exist within 0.5 mile of the compliance boundary. Surface water classification for Dan River is Class C, as defined in 15A NCAC 02B.0101(c-1). Class C waters are protected for secondary recreation, fishing, wildlife, consumption of fish, aquatic life including propagation, maintenance and survival of biological integrity, and agriculture. Surface water features located at the site are shown on Figure 2-2 and Figure 4-5. 2.5 Meteorological Setting According to the U.S. Department of Agriculture Soil Conservation Service (USDA-SCS) soil survey (1994), the average summer temperature in Rockingham County is 74°F and the average daily maximum temperature is 85°F. During winter, the average temperature is 38°F and the average daily minimum temperature is 28°F. The total annual precipitation in Rockingham County is 42 inches, with over half of this rainfall (22 inches) occurring from April through September. Thunderstorms occur approximately 45 days each year (USDA-SCS 1994). The average relative humidity in midafternoon is approximately 55 percent, with humidity reaching higher levels at night. The prevailing wind is from the southwest; average wind speed is approximately nine miles per hour (USDA-SCS 1994). 2.6 Hydrologic Setting Two unnamed tributaries of the Dan River are located along the eastern and western sides of the DRSS site. Edgewood Road generally runs north to south and is located along a surface water divide. Contours for the groundwater surface generally mimic the site surface topography, such that east of Edgewood Road groundwater generally flows toward the unnamed tributary located on the east side of the property and toward the ash basins, ultimately discharging into the Dan River. Similarly, groundwater on the western side of Edgewood Road generally flows toward the unnamed tributary located on the west side of the property or towards the Dan River. Groundwater flow is discussed in further detail in Section 6.0. Water levels within the Primary Cell of the ash basin have historically fluctuated approximately 11 feet from October 1984 until April 2013. The water elevation in the Primary Cell has ranged from approximately 526 to 537 feet. Water levels within the Secondary Cell of the ash basin have historically fluctuated approximately 12 feet from October 1984 until April 2013. The water elevation in the Secondary Cell has ranged from approximately 518 to 526 feet. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 2.0 SITE HISTORY AND DESCRIPTION 10 The ash basin affects the local groundwater elevations that underlie the basin. Water level measurements recorded downgradient of the Secondary Cell indicate localized groundwater mounding due to the presence of the basin The hydrologic setting is described in further detail in Section 5.0. 2.7 Permitted Activities and Permitted Waste Duke Energy is authorized to discharge wastewater to the surface waters of North Carolina or to a separate storm sewer system that has been adequately treated and managed in accordance with NPDES Permit NC0003468, which was renewed on March 1, 2013 and expires on April 30, 2017. Any other point source discharge to surface waters of the state is prohibited unless it is an allowable non-stormwater discharge or is covered by another permit, authorization, or approval. The NPDES permit authorizes discharges in accordance with effluent limitations, monitoring requirements, and other conditions set forth in the permit. An inactive (closed) asbestos and land clearing and inert debris landfill, Permit 79B-LCID, is located on the west side of Edgewood Road. 2.8 NPDES and Surface Water Monitoring The NPDES program regulates wastewater discharges to surface waters to ensure that surface water quality standards are maintained. The NPDES permitting program requires that permits be renewed every five years. The current NPDES permit requires surface water monitoring as part of the permit conditions. Surface water samples are required to be collected at Outfall 001 and Outfall 002 (see Section 2.9). The sample locations, parameters, and constituents to be measured and analyzed, and the requirements for sampling frequency and reporting results are specified in the permit. 2.9 NPDES Flow Diagram As stated in the NPDES Permit NC0003468, the NPDES permit allows continued discharge into the Dan River from the following:  Once-through cooling water and cooling tower blowdown from the combined cycle unit, intake screen backwash, plant collection sumps (low volume wastes), and treated domestic wastewater from Outfall 001;  Wastes from the filtered water plant including miscellaneous wash down water and laboratory wastes (low volume waste sources) from internal Outfall 001A;  An ash basin discharge consisting of low volume wastes, boiler cleaning wastewater, ash disposal, stormwater, boiler blowdown, and metal washing wastewater from Outfall 002; and  A yard sump overflow consisting of stormwater runoff, miscellaneous sumps, and coal yard runoff from Outfall 002A. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 2.0 SITE HISTORY AND DESCRIPTION 11 The NPDES flow diagram for DRSS is provided on Figure 2-6. This figure shows the sources of inflows into the basin. Outfalls 004 and 006, shown on Figure 2-6, are not included in the current NPDES permit. Located at the south end of the Service Water Settling Pond, they are believed to be stormwater outfalls. 2.10 History of Site Groundwater Monitoring Duke Energy has implemented voluntary and NPDES permit-required compliance groundwater monitoring at DRSS. Compliance groundwater monitoring as required by the NPDES permit began in 1993 which included sampling of the following monitoring wells: MW -9, MW -10, MW- 11, and MW -12. In 2007, additional monitoring wells, MW -9D, MW -10D, MW-11D, and MW - 12D, were installed as part of Duke Energy’s voluntary monitoring program. From 1993 to 2010, biannual voluntary groundwater monitoring was performed around the DRSS ash basin with analytical results submitted to NCDENR DWR. In October 2010, new compliance monitoring wells, MW -20S/D, MW -21S/D, MW -22S/D, and MW-23D, were installed and the monitoring wells previously installed became part of the voluntary monitoring program. Additional groundwater monitoring was required beginning in March 2011 with the frequency of sampling and the parameters to be analyzed outlined in the NPDES permit. From January 2011 through May 2015, the compliance groundwater monitoring wells at the DRSS site have been sampled a total of 14 times as part of triannual sampling required in the NPDES permit. NPDES Permit Condition A (11), Version 1.1, dated June 15, 2011, lists the groundwater monitoring wells to be sampled, the parameters and constituents to be measured and analyzed, and the requirements for sampling frequency and reporting results The location of the ash basin voluntary and compliance monitoring wells, the approximate ash basin waste boundary, and the compliance boundary are shown on Figure 2-7. The compliance boundary for groundwater quality at the DRSS ash basin site is defined in accordance with Title 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 waste boundary. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 2.0 SITE HISTORY AND DESCRIPTION 12 2.10.1 Voluntary Groundwater Monitoring Wells Groundwater monitoring prior to 2015 consisted of eight voluntary and seven compliance wells installed within the DRSS site boundary. Duke Energy implemented voluntary groundwater monitoring around the DRSS ash basin in 2007 and continued until 2010... During this period, the voluntary groundwater monitoring wells were sampled two times per year and the analytical results were submitted to NCDENR. 2.10.2 Compliance Groundwater Monitoring Wells In 2010, compliance groundwater monitoring wells were installed at the DRSS site. Groundwater monitoring as required by the DRSS NPDES Permit NC0003468 began in March 2011 utilizing the compliance monitoring wells. NPDES Permit Condition A (11), Version 1.1, dated June 15, 2011, lists the groundwater monitoring wells to be sampled, the parameters and constituents to be measured and analyzed, and the requirements for sampling frequency and reporting results (provided in Table 2-1). Compliance groundwater monitoring wells were installed in December 2010. Locations for the compliance groundwater monitoring wells were approved by the NCDENR DWR Aquifer Protection Section (APS). All compliance monitoring wells listed in Table 2-1 are sampled three times per year (January, May, and September). Analytical results are submitted to NCDENR DWR before the last day of the month following the month of sampling for all compliance monitoring wells. The compliance groundwater monitoring is performed in addition to the current NPDES monitoring of the discharge flows from the ash basin. From January 2011 through May 2015, the compliance groundwater monitoring wells at the DRSS site have been sampled a total of 14 times. During this period, these monitoring wells were sampled in:  January, May, and September 2011  January, May, and September 2012  January, May, and September 2013  January, May, and September 2014  January and May 2015 The results of each sampling event are submitted to NCDENR as required by the permit. The compliance groundwater monitoring system for the DRSS ash basin system consists of the following monitoring wells: MW -20S, MW -20D, MW-21S, MW -21D, MW-22S, MW -22D, and MW -23D. Monitoring well MW -23D serves as the background well for compliance groundwater monitoring. As documented in NCDENR’s NORR letter dated August 13, 2014, one or more 2L Standards have been exceeded in groundwater samples collected from each of the compliance monitoring wells, including the background well. Exceedances have occurred in one or more wells during one or more sampling events for arsenic, boron, iron, manganese, pH, antimony, sulfate, and Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 2.0 SITE HISTORY AND DESCRIPTION 13 TDS. Table 2-2 presents exceedances measured at each of these groundwater monitoring wells from January 2011 through May 2015. Monitoring wells MW -20S and MW-20D are located north of the ash storage areas. Monitoring wells MW -21S and MW -21D are located east of and adjacent to the Secondary Cell. Monitoring wells MW -20S and MW -21S were installed via rotary drilling methods using hollow stem augers, with the well screen installed above auger refusal to monitor the shallow aquifer within the saprolite layer. These wells were installed with screen lengths of 15 feet and 5 feet, respectively. The wells were installed with the screened interval for MW -20S from 4 feet to 19 feet below ground surface (bgs) and the screened interval for MW -21S from 3.5 feet to 8.5 feet bgs. Monitoring wells MW -20D and MW -21D were installed via rotary drilling methods using hollow stem augers and by rock coring techniques (HQ-diameter barrel) with the well screen installed in the uppermost region of the fractured rock transition zone (TZ). These wells were installed with 5-foot-long screens. The wells were installed with the screened interval for MW-20D from 36.5 feet to 41.5 feet bgs and the screened interval for MW-21D from 13.6 feet to 18.6 feet bgs. Monitoring wells MW -22S and MW-22D are located south of the Primary Cell. Monitoring wells MW -22S and MW -22D are located at the toe of the earthen dam impounding the Primary Cell, where large-diameter cobbles/boulders prevented installation by the drilling techniques used for wells MW -20S, MW -20D, MW-21S, and MW-21D. Wells MW -22S and MW-22D were installed using an air-powered ODEX drilling system. Well MW -22S was installed to monitor the surficial aquifer with a 10-foot-long screen from 12.35 feet to 22.35 feet bgs. MW -22D was installed to monitor the fractured rock TZ with a 5-foot-long screen from 31.95 feet to 36.95 feet bgs. Monitoring well MW -23D, the background well, is located approximately 3,100 feet northwest of the Primary Cell. Well MW -23D was installed to evaluate background water quality at the site. Well, MW -23D was installed by rotary drilling methods using hollow stem augers and by rock coring techniques (HQ-diameter barrel) with the well screen installed in the uppermost region of the fractured rock TZ. This well was installed with a 10-foot-long screen from 6.7 feet to 16.7 feet bgs. 2.11 Assessment Activities or Previous Site Investigations Between 1990 and 2013, several historical onsite investigations have been conducted in response to fuel oil releases linked to the piping and aboveground storage tanks (ASTs) associated with the former combustion turbine system and leaks from former gasoline underground storage tanks (USTs). A summary of the historical environmental incidents on-site is provided in Table 2-3. In September 2013, assessment activities in support of the conceptual closure design of the DRSS ash basin. The work performed as part of this study included the installation and sampling of 27 observation wells between June and July 2013. Results from this assessment have been used to supplement data obtained from the current groundwater assessment. Select Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 2.0 SITE HISTORY AND DESCRIPTION 14 existing monitoring wells installed as part of the ash basin conceptual closure assessment were resampled to supplement the current groundwater assessment. On February 2, 2014, a portion of a 36-inch corrugated metal storm water pipe, located under the Primary Cell of the ash basin, failed and released up to 39,000 tons of coal ash into the Dan River. Immediate action was taken to stop the release and begin assessment of the environmental impact. Ash deposits were removed from the property and other downstream locations. Duke Energy has worked extensively with various federal, state and local agencies to address the coal ash release to the Dan River, including removal of an estimated 4,000 cubic yards of coal ash and extensive environmental quality monitoring. According to a January 27, 2015 USEPA Information Update related to the release, “Following extensive surface water and sediment sampling, no further ash removal is planned. There have been no exceedances of human health screening thresholds, or any recent exceedances of ecological screening thresholds, for contaminants associated with ash. Further, removal of ash [in] some places could be more detrimental to the ecosystem than leaving it in place.” Long-term monitoring through July 2015 was also directed by an Administrative Order of Consent between the USEPA and Duke Energy. The USEPA has overseen sampling to date and will determine whether additional sampling is required beyond July 2015. 2.12 Decommissioning Status The multi-year DRSS decommissioning process is being accomplished using a phased approach that involves cleaning and removing equipment, demolishing the powerhouse and auxiliary buildings, and restoring the site. Phase 1 began in the fall of 2013 and included removal of a small portion of the exterior brick on the power plant near the river to allow for modifications to the new natural gas plant's water-intake system. Auxiliary buildings and the decommissioned combustion turbine units and fuel oil tank were then demolished. Phase 2 of the decommissioning process is scheduled to begin in 2015 and will include demolition of the power plant. Between these two decommissioning phases, electrical equipment that is critical to Duke Energy’s power transmission system has been relocated. In conjunction with decommissioning activities and in accordance with CAMA requirements, Duke Energy shall permanently close the DRSS ash basin by August 1, 2019. Closure of the DRSS ash basin was defined in CAMA as excavation of ash from the site, and beneficial reuse of the material or relocation to a lined structural fill or landfill. As part of the DRSS closure process, Duke Energy submitted a coal ash excavation plan to state regulators in November 2014. The excavation plan details a multiphase approach for removing coal ash from the site with an emphasis on the first 12 to 18 months of activities. During Phase I of the excavation, an estimated 1.2 million tons of material will be excavated from the Primary and Secondary cells or dry ash stacks (described further in Section 3.2). This material is planned to be taken to the Maplewood (Amelia) Landfill in Jetersville, Virginia. An alternate landfill, Atlantic Landfill in Waverly, Virginia, was identified to accept material excavated in the event of any issues at the Maplewood Landfill. Ash will be transported by rail car to the landfill and installation of a rail loading system to accommodate this transport of ash is Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 2.0 SITE HISTORY AND DESCRIPTION 15 currently in progress. Should the situation arise that rail car transportation is disrupted, truck transportation will be utilized. Subsequent phase(s) will remove the remaining ash at the site. Duke Energy is in the permitting process for an on-site landfill that will be located approximately where Ash Storage 1 is located. The landfill will be lined and construction is projected to be completed by June 2017. The permit-to-construct application is scheduled to be submitted to the NCDENR Division of Waste Management in the third quarter of 2015. The construction schedule will depend upon receipt of the required permits. Duke Energy will begin moving coal ash within 60 days after receiving necessary permits and approvals. Dewatering of the ash basins will begin along with project planning for later phases to identify storage options for the remaining ash on the plant property. Ash impoundments will be closed by August 1, 2019. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 3.0 SOURCE CHARACTERISTICS 16 3.0 Source Characteristics This section provides a general description of the DRSS coal combustion and ash handling system, a description of the ash basin and other ash storage areas, and a discussion of the general physical and chemical properties of ash. 3.1 Coal Combustion and Ash Handling System Coal ash is produced from the combustion of coal. The coal is dried, pulverized, and conveyed to the burner area of a boiler. The smaller particles produced by coal combustion, referred to as fly ash, are carried upward in the flue gas and are captured by an air pollution control device, such as an electrostatic precipitator. The larger particles of ash that fall to the bottom of the boiler are referred to as bottom ash. Coal ash residue from the coal combustion process was disposed in the DRSS ash basin from approximately 1956 until the last coal-fired generating units were retired in 2012. Fly ash from the electrostatic precipitators was collected in hoppers. Bottom ash and boiler slag was collected in the bottom of the boilers. After collection, both fly ash and bottom ash/boiler slag were sluiced to the ash basin using conveyance water withdrawn from the Dan River. The sluice lines conveyed the water/ash slurry and other flows to the southwest corner of the Primary Cell. Refer to Figure 2-2 for a depiction of these features. DRSS historically produced approximately 50,000 tons of ash per year. Note that this quantity is an estimate and actual quantities fluctuated based on burn rates, coal types, and outages. During operation of the coal-fired units, the ash basin received variable inflows from the ash removal system and discharge of cooling water. The ash basin no longer receives sluiced ash but currently receives variable inflows from the station yard drain sump and stormwater flows. Duke Energy is in the process of evaluating alternatives for removing these flows from the ash basin to allow total decommissioning of the ash basin. 3.2 Description of Ash Basin and Other Ash Storage Areas The DRSS ash basin is located adjacent to the Dan River and consists of a Primary Cell, a Secondary Cell, and associated embankments and outlet works, as shown on Figure 2-2. The ash basin is impounded by earthen dams and an earthen/ash divider dam separates the Primary Cell from the Secondary Cell. The dry ash storage areas are located topographically upgradient of the ash basin and consist of Ash Storage 1, Ash Storage 2, a former dredge pond, and associated dredge dikes. The ash storage areas contain ash that was removed from the ash basin. 3.2.1 Primary and Secondary Ash Basin Cells The current ash basin was constructed over three phases beginning in 1956 and ending in 1976. Based on a review of historical construction drawings, it appears that the dams were constructed of earthen materials borrowed from within the ash basin footprint. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 3.0 SOURCE CHARACTERISTICS 17 The original ash basin was constructed in 1956 with a footprint that lies within the current Primary Cell. The dam was constructed as a homogenous sandy silt embankment with an approximate crest elevation of 525 feet. In 1968 and 1969, the footprint of the ash basin was expanded to the footprint of the current Primary and Secondary Cells by constructing an earthen dam with a crest elevation of 530 feet. At this period, the ash basin was a single impoundment. In 1976, the single basin was divided into the current Primary and Secondary Cells by construction of an interior dike on top of existing ash. This divider dike was constructed as an earthen embankment at elevation 540 feet. The embankment for what is now the Primary Cell was raised to 540 feet. The area contained within the waste boundary for the Primary and Secondary Cells currently extends over an area of approximately 53 acres. The Primary Cell extent is approximately 28.1 acres and contains approximately 1 million tons of ash material. The Primary Cell has a crest elevation of approximately 540 feet and has an impoundment surface area of approximately 21.8 acres. The Secondary Cell extent is approximately 15.3 acres and contains approximately 200,000 tons of ash material. The Secondary Cell has a crest elevation of approximately 530 feet and has a current impoundment surface area of approximately 12.2 acres. The elevation of the Dan River adjacent to the ash basin is approximately 482 feet. During operation of the coal-fired units, the ash basin received variable inflows of fly ash, bottom ash, pyrites, stormwater runoff (including runoff from the coal pile), cooling water, powerhouse floor drains, sanitary waste effluent, station yard drainage sump, and boiler chemical cleaning wastes. Flow was historically routed from the Primary Cell to the Secondary Cell through a concrete discharge tower. Since the February 2, 2014 release within the Primary Cell, all inflows into the ash basin are now routed directly to the Secondary Cell. Effluent from the Secondary Cell is routed to the Dan River via a concrete discharge tower located in the Secondary Cell. The water surface in both the Primary and Secondary Cells is controlled by the use of stop logs. 3.2.2 Ash Storage 1 The ash storage area identified as Ash Storage 1 is located north of the Primary and Secondary Cells on an upland area of the site. The unit is bounded by a topographic rise to the north, filling former drainages of the rise to the south (Figure 2-2). The surface area within the waste boundary for Ash Storage 1 encompasses approximately 20.1 acres. The CCR and soil material stored in the Ash Storage 1 footprint was placed during several projects between 1994 and 2010 and totals approximately 1.1 million tons. Ash was previously dredged to the southernmost portion of Ash Storage 1, and free liquids were allowed to gravity drain to the topographically lower dredge pond located between the dry ash storage areas. Once dewatered, ash was hauled and placed dry in Ash Storage 1 and Ash Storage 2 and a vegetated soil cap covers the storage area footprint (Figure 2-2). 3.2.3 Ash Storage 2 The ash storage area identified as Ash Storage 2 is located southwest of Ash Storage 1 and on the southwest slope of a former ridge on the site. The cell is bounded by a topographic rise to Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 3.0 SOURCE CHARACTERISTICS 18 the north, filling a former drainage at the southwest base of the former ridge (Figure 2-2). The area contained within the waste boundary for Ash Storage 2 encompasses approximately 13.4 acres. The CCR and soil material in Ash Storage 2 was placed in 1994 and during 1997-1998 and totals approximately 372,000 tons. Ash Storage 2 was created in a similar manner as Ash Storage 1, using ash removed from the ash basin. A vegetated soil cap covers the surface of Ash Storage 2, and the footprint this capped surface is currently used as a laydown area when needed for various projects at the site. 3.2.4 Dredge Dikes In 1980, newer dikes, referred to as the dredge dikes, were constructed north of the Primary and Secondary Cells using on-site earthen fill material to create a dredge pond between the ash basin and two dry storage areas referred to as Ash Storage 1 and 2 (discussed above). The crest of these dikes was constructed at an elevation of 560 feet. Ash that was removed from the ash basin was placed upgradient of these dikes and allowed to drain into the topographically lower dredge pond. The drained ash was then removed from the dredge pond and compacted in the ash storage areas. The discharge tower for the dredge pond discharges to the Secondary Cell of the ash basin. 3.3 Physical Properties of Ash Ash in the DRSS ash basin consists of fly ash and bottom ash produced from the combustion of coal. The physical and chemical properties of coal ash result from reactions that occur during the combustion of the coal and subsequent cooling of the flue gas. In general, coal is dried, pulverized, and conveyed to the burner area of a boiler for combustion. As described in Section 3.1, material that forms larger particles of ash and falls to the bottom of the boiler is referred to as bottom ash. Smaller particles of ash, known as fly ash, are carried upward in the flue gas and are captured by an air pollution control device. Approximately 70 to 80 percent of the ash produced during coal combustion is fly ash (EPRI 1993). Typically 65 to 90 percent of fly ash has particle sizes that are less than 0.010 millimeter (mm). In general, fly ash has a grain size distribution similar to that of silt. The remaining 20 to 30 percent of ash produced is considered to be bottom ash. Bottom ash consists of angular particles with a porous surface and is normally gray to black in color. Bottom ash particle diameters can vary from approximately 0.05 to 38 mm. In general, bottom ash has grain size distribution similar to that of fine to very coarse sand (EPRI 1995). Based on published literature not specific to the DRSS site, the specific gravity of fly ash typically ranges from 2.1 to 2.9 and the specific gravity of bottom ash typically ranges from 2.3 to 3.0. The permeability of fly ash and bottom ash vary based on material density, but would be within the range of a sand-gravel with a similar gradation, grain size distribution and density (EPRI 1995). Permeability and other physical properties of the ash found in the DRSS ash basin are presented in later sections of this report. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 3.0 SOURCE CHARACTERISTICS 19 3.4 Chemical Properties of Ash In general, the specific mineralogy of coal ash varies based on many factors including the chemical composition of the coal, which is directly related to the geographic region where the coal was mined, the type of boiler where the combustion occurs (i.e., thermodynamics of the boiler), and air pollution control technologies employed. The overall chemical composition of coal ash resembles that of siliceous rocks from which it was derived, particularly shale. Oxides of silicon, aluminum, iron, and calcium make up more than 90 percent of most siliceous rocks, soils, fly ash, and bottom ash. Other major and minor elements (sulfur, sodium, potassium, magnesium, titanium) make up an additional 8 percent, while trace constituents account for less than 1 percent. The following constituents are considered to be trace elements: arsenic, barium, cadmium, chromium, lead, mercury, selenium, copper, manganese, nickel, lead, vanadium, and zinc (EPRI 2010). According to Duke Energy, the coal sources generally used for combustion at DRSS were low sulfur coal from Central Appalachia, comprised of Eastern Kentucky, Southern West Virginia, and Southwestern Virginia. The majority of fly ash particles are glassy spheres mainly composed of amorphous or glassy aluminosilicates, crystalline matter, and carbon. Figure 3-1 presents a photograph of ash collected from the ash basin at Duke Energy’s Cliffside Steam Station showing a mix of fly ash and bottom ash at 10 µm and 20 µm magnifications. The glassy spheres can be observed in the photograph. The glassy spheres are generally resistant to dissolution. During the later stages of the combustion process and as the combustion gases are cooling after exiting the boiler, molecules from the combustion process condense on the surface of the glassy spheres. These surface condensates consist of soluble salts (e.g., calcium (Ca2+)); sulfate (SO42-); metals (e.g., copper (Cu), zinc (Zn)); and other minor elements (e.g., boron (B), selenium (Se), and arsenic (As)) (EPRI 1994). The major elemental composition of fly ash (approximately 95 percent by weight) is composed of mineral oxides of silicon, aluminum, iron, calcium. Oxides of magnesium, potassium, titanium and sulfur comprise approximately 4 percent by weight (EPRI 1995). Trace elemental composition typically is approximately 1 percent by weight and may include arsenic, antimony, barium, boron, cadmium, chromium, copper, manganese, mercury, nickel, lead, selenium, silver, thallium, zinc, and other elements. For comparison, Figure 3-2 shows the elemental composition of fly ash and bottom ash compared with typical values for shale and volcanic ash. Table 3-1 shows the bulk composition of fly ash and bottom ash compared with typical values for soil and rock. In addition to these constituents, fly ash may contain unburned carbon. Bituminous coal ash typically yields slightly acidic to alkaline solutions with pH levels ranging from approximately 5 to 10 on contact with water. The geochemical factors controlling the reactions associated with leaching of ash are complex. Factors such as the chemical speciation of the constituent, solution pH, solution-to-solid ratio, and other factors control the chemical concentration of the resultant solution. Constituents that are held on the glassy surfaces of fly ash such as boron, arsenic, and selenium may initially Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 3.0 SOURCE CHARACTERISTICS 20 leach more readily than other constituents. As noted in Table 3-1, aluminum, silicon, calcium, and iron represent the larger fractions of fly ash and bottom ash by weight. The presence of calcium may limit the release of arsenic by forming calcium-arsenic precipitates. Formation of iron hydroxide compounds may also sequester arsenic and retard or prevent release of arsenic to the environment. Similar processes and reactions may affect other constituents of concern; however, certain constituents such as boron and sulfate will likely remain highly mobile. In addition to the variability that might be seen in the mineralogical composition of the ash, which is based on different coal types, different age of ash in the basin, and other factors, it is anticipated that the chemical environment of the DRSS ash basin varies over time, distance, and depth. EPRI (2010) reports that 64 samples of coal combustion products (including fly ash, bottom ash, and flue gas desulfurization residue) from 50 different power plants were subjected to USEPA Method 1311 Toxicity Characteristic Leaching Procedure (TCLP) (USEPA 2008) leaching and no TCLP result exceeded the TCLP hazardous waste limit. Figure 3-3 provides the results of that testing. The report also presents the trace element concentrations for fly ash and bottom ash compared to USEPA Residential Soil Screening Levels (RSLs) for ingestion and dermal exposure. Figure 3-4 shows the 10th to 90th percentile range for trace element concentrations (milligrams per kilogram [mg/kg]) in fly ash and the associated USEPA RSLs. The trace element concentrations for arsenic were greater than the RSLs for arsenic. The RSLs of the remaining constituents were greater than or within the 10th to 90th percentile range for their trace element concentrations. Figure 3-5 shows similar data for bottom ash. As with fly ash, the trace element concentrations for arsenic in bottom ash were greater than the RSLs for arsenic. The RSLs for chromium were within the 10th to 90th percentile range of concentrations for chromium in bottom ash. The 10th to 90th percentile range for the remaining constituents were below their respective RSLs. Site-specific ash data is discussed further in Section 7.0 of this report. This page is intentionally left blank. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 4.0 RECEPTOR INFORMATION 21 4.0 Receptor Information Section §130A-309.201(13) of the CAMA defines receptor as “any human, plant, animal, or structure which is, or has the potential to be, affected by the release or migration of contaminants. Any well constructed for the purpose of monitoring groundwater and contaminant concentrations shall not be considered a receptor.” In accordance with the NORR CSA Guidelines, receptors cited in this section refer to public and private water supply wells (including irrigation wells and unused wells) and surface water features. Refer to Section 12.0 for a discussion of non-water supply wells and other receptors that were evaluated as part of this CSA effort. Note that one of the receptor survey requirements in the NORR CSA Guidelines is that subsurface utilities are to be mapped within 1,500 feet of the known extent of contamination in order to evaluate the potential for preferential pathways. For the DRSS, the subsurface utilities are not viewed as potential preferential pathways for contaminant migration through underground utility corridors because the Dan River serves as the lower hydraulic boundary for groundwater flow from potentially impacted areas. For this reason, subsurface utilities within 1,500 feet down-gradient of the ash basin were not mapped. However, pertinent structures (e.g., stormwater drainage pipes) located proximal to ash management features were identified and are presented on Figure 4-3. 4.1 Summary of Previous Receptor Survey Activities Duke Energy submitted a receptor survey to NCDENR (HDR 2014a) in September 2014, followed by a supplement to the receptor survey (HDR 2014b) submitted to NCDENR in November 2014. The purpose of the receptor survey was to identify the potential exposure locations that are critical to be considered in the groundwater transport modeling and screening- level risk assessment activities. The supplementary information was obtained from responses to water supply well survey questionnaires mailed to property owners within a 0.5-mile (2,640-foot) radius of the DRSS ash basin compliance boundary requesting information on the presence of water supply wells and well usage. The survey activities included contacting and/or reviewing the following agencies/records to identify public and private water supply sources, confirm the location of wells, and/or identify any wellhead protection areas located within a 0.5-mile radius of the DRSS ash basin compliance boundary:  NCDENR Department of Environmental Health (DEH) Public Water Supply Section’s (PWSS) most current Public Water Supply Water Sources GIS point data set;  NCDENR DWR Source Water Assessment Program (SWAP) online database for public water supply sources;  Environmental Data Resources (EDR) local/regional water agency records review;  Rockingham County Environmental Health Department;  City of Eden’s Director of Environmental Services; Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 4.0 RECEPTOR INFORMATION 22  Dan River Water Inc., a private water utility company; and  United States Geological Survey (USGS) National Hydrography Dataset (NHD). In addition, a field reconnaissance was performed on June 18, 2014 and July 9, 2014, to identify public and private water supply wells (including irrigation wells and unused or abandoned wells) and surface water features located within a 0.5-mile radius of the DRSS ash basin compliance boundary. A windshield survey was conducted from public roadways to identify water meters, fire hydrants, valves, and any potential well heads/well houses, and Duke Energy site personnel identified water supply wells located on Duke Energy property. During the week of October 8, 2014, 252 water supply well survey questionnaires were mailed to property owners requesting information on the presence of water supply wells and well usage information for each property. The mailing list was compiled from a query of the parcel addresses included in the Rockingham County GIS database utilizing the 0.5-mile offset. Between July 16 and July 22, 2015, the agencies/records listed above were contacted to provide additional information. Updated information is provided in Appendix B. 4.2 Summary of CSA Receptor Survey Activities and Findings As part of this CSA report, Duke Energy updated the previously completed receptor survey activities based on the CSA Guidelines provided in the NORR issued by NCDENR. The update included contacting and/or reviewing the agencies/records to identify public and private water supply sources identified in Section 4.1 and reviewing questionnaires that were received after submittal of the November 2014 supplement to the September 2014 receptor survey (i.e., questionnaires received after October 31, 2014). A summary of the receptor survey findings is provided below. The identified water supply wells are shown in the USGS receptor map on Figure 4-1. Available property and well information for the identified wells is provided in Tables 4-1. Table 4-2 provides a summary of surrounding property owner’s names and addresses. Figures 4-2 through 4-6 present an aerial receptor map, ash basin underground features map, ash storage area underground features map, aerial map of surface water bodies, and surrounding property owners map, respectively.  Three reported private water supply wells were identified within a 0.5-mile radius of the ash basin compliance boundary.  One private water supply spring, reportedly not currently in use, was identified within a 0.5-mile radius of the ash basin compliance boundary.  No public water supply wells were identified within a 0.5-mile radius of the ash basin compliance boundary.  Several unnamed tributaries of the Dan River were identified within a 0.5-mile radius of the ash basin compliance boundary.  No water supply wells (including irrigation wells and unused or abandoned wells) were identified within a 0.5-mile radius of the ash basin compliance boundary.  No wellhead protection areas were identified within a 0.5-mile radius of the ash basin compliance boundary. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 4.0 RECEPTOR INFORMATION 23 Based on the returned water supply well questionnaires since October 31, 2014, no additional receptors were identified. Further details of HDR’s receptor survey activities and findings are presented in Appendix B. 4.3 NCDENR Well Water Testing Program Section § 130A-309.209 (c) of the CAMA requires the owner of a CCR surface impoundment to conduct a Drinking Water Supply Well Survey that identifies all drinking water supply wells within one-half mile down-gradient from the established compliance boundary of the impoundment and submit the Survey to the Department. Since the direction of groundwater flow had not been fully established at the sites, NCDENR required the sampling to include all potential drinking water receptors within 1,500 feet of the compliance boundary in all directions. Between February and July 2015, NCDENR arranged for independent analytical laboratories to collect and analyze water samples obtained from private wells identified during the Drinking Water Supply Well Survey, if the owner agreed to have their well sampled. At the DRSS site, no private wells within 1,500 feet of the compliance boundary were sampled per the directive of NCDENR. It is important to note that all three water supply wells are located more than 2,000 feet away from the DRSS ash basin compliance boundary and are either upgradient or across the Dan River from the ash basin system. No information gathered as part of this CSA suggests that water supply wells or springs within the 0.5-mile radius of the compliance boundary are impacted by the DRSS ash basin system. This page is intentionally left blank. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 5.0 REGIONAL GEOLOGY AND HYDROGEOLOGY 24 5.0 Regional Geology and Hydrogeology 5.1 Regional Geology North Carolina is divided into three physiographic provinces: the Atlantic Coastal Plain, Piedmont, and Blue Ridge (Fenneman 1938). DRSS is located in the Dan River Triassic Basin within the Piedmont province. The Piedmont province is bounded to the east and southeast by the Atlantic Coastal Plain and to the west by the escarpment of the Blue Ridge Mountains, with a width ranging from 150 miles to 225 miles in the Carolinas (LeGrand 2004). The topography of the Piedmont region is characterized by low, rounded hills and long, rolling, northeast- to southwest-trending ridges (Heath 1984). Stream valley to ridge relief in most areas ranges from 75 feet to 200 feet. Along the Coastal Plain boundary, the Piedmont region rises from an elevation of 300 feet, to the base of the Blue Ridge Mountains at an elevation of up to 1,500 feet (LeGrand 2004). Rocks within the Dan River Basin consist of relatively hard and brittle sedimentary rocks that result in linear strike ridges, narrow valleys, and high relief (Olsen et al. 1991) in contrast to the low hills and subdued ridges of the Piedmont province proper. The Dan River Triassic Basin (Danville Basin in Virginia) is one of several exposed rift basins that form two parallel belts that strike northeasterly within the Piedmont province. The basins are aligned subparallel to the Appalachian terranes (Figure 5-1) and formed along pre-existing zones of faulting and then subsided during a period of crustal stretching (Olsen et al. 1991). The Dan River Basin is located in the western belt of rift basins and is bounded on the southeast by the Milton terrane, one of a number of tectonostratigraphic terranes that have been defined in the southern and central Appalachians, and on the northwest by the Sauratown Mountains Anticlinorium and the Smith River allochthon (Figure 5-1; Horton et al. 1989; Hibbard et al. 2002; Hatcher et al. 2007). The Milton belt is characterized by strongly foliated gneisses and schists, commonly with distinct compositional layering and felsic composition; quartzite, calc- silicate gneiss, and marble are minor units (Carpenter 1982; Butler and Secor 1991). The majority of the rocks in the belt are metamorphosed to the sillimanite and kyanite grade of amphibolite metamorphism (Butler and Secor 1991). The Sauratown Mountains anticlinorium consists of four stacked thrust sheets and subsequent erosion has exposed a complex, multitiered window or exposure of these thrust sheets (Horton and McConnell 1991). A complex sequence of interlayered and faulted calc-silicate gneiss, biotite-augen gneiss, quartz-feldspar gneiss, epidosite, and amphibolite characterize the anticlinorium (Horton and McConnell 1991). The Smith River allochthon consists predominately of biotite gneiss in North Carolina (Horton and McConnell 1991). In terms of structural position of the Dan River Basin, it is bounded on the northwest by the Chatham fault zone, a southeast dipping normal fault system. The fault zone strikes N30E to N40E and dips at approximately 45 degrees to the southeast (Thayer and Robbins 1992). Movement along the fault zone occurred during and after basin filling with a total displacement along the zone of as much as 4,500 meters (Thayer 1970). The contact between the Triassic rocks of the basin and the crystalline rocks of the Milton belt along the southeast basin margin is Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 5.0 REGIONAL GEOLOGY AND HYDROGEOLOGY 25 an unconformity, but several minor, northwest dipping normal faults are present locally (Thayer 1970). Minor, interbasin normal faults are present. The sedimentary rocks of the basin consist of interbedded conglomerate, sandstone, mudstone, siltsone, shale, and thin coal beds (Olsen et al. 1991; Thayer and Robbins 1992). The rocks dip moderately to steeply northwest toward the Chatham fault zone (Thayer 1970). Thayer (1970) divided the rocks of the basin into three stratigraphic formations (oldest to youngest): 1) Pine Hall Formation, 2) Cow Branch Formation, and 3) Stoneville Formation. The Pine Hall Formation is along the southeast margin of the basin and consists of gray to red, medium- to coarse-grained conglomerate, pebbly sandstone grading upward into massive, bioturbated red siltstone and mudstone. This sequence defines an upward fining sequence suggesting braided river deposits (Thayer 1970; Thayer and Robbins 1992). The Cow Branch Formation conformably overlies and interfingers with the Pine Hall Formation and consists of black and gray bedded, carbonaceous shales and mudstones, sandstones, and thin coal beds deposited in a lacustrine environment (Thayer 1970; Thayer and Robbins 1992). Overlying and interfingering with the Cow Branch Formation is the Stoneville Formation that consists of red, gray, and brown, poorly-sorted conglomerates, arkosic sandstones, and mudstones deposited in alluvial fans and braided streams that developed adjacent to the northwest border fault zone (Thayer 1970; Thayer and Robbins 1992). Alluvial and terrace deposits consisting of unconsolidated sand, silt, and clay with occasional sub-rounded to well-rounded pebbles occur along the Dan River and major tributaries. A geologic map of the region is shown on Figure 5-2. 5.2 Regional Hydrogeology The hydrogeologic regime in the Dan River Basin is characterized by fractured, bedded sedimentary sequences underlying soil and saprolite. Groundwater may occur under both unconfined, water table conditions (similar to most Piedmont crystalline sites) and confined conditions. Controls of groundwater flow are a combination of the interaction of factors including topography, stratigraphic sequence and lithology, distribution and intensity of fractures, presence of diabase intrusions (both dams and sills), basalt flows, and weathering processes of the bedrock (Venkatakrishnan and Gheorghiu 2003). Groundwater flow has both local and regional components with shallow groundwater discharging locally to nearby streams (and some movement downward into the deeper flow system) and deeper groundwater flow toward points of regional discharge, that are generally higher order stream courses (Venkatakrishnan and Gheorghiu 2003). Both shallow and deep groundwater systems generally flow in a direction similar to the topographic gradient. Although the DRSS site is not underlain by metamorphic and/or igneous rocks, the conceptual groundwater system for fractured crystalline rocks developed by Heath (1980), Harned and Daniel (1992), and LeGrand (1988, 1989, 2004) is applicable based on review of the available data from previous studies and investigations and the data collected during the CSA field investigation. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 5.0 REGIONAL GEOLOGY AND HYDROGEOLOGY 26 The groundwater system is comprised of two interconnected layers, or mediums: 1) residual soil/saprolite and weathered fractured rock (regolith) overlying 2) fractured bedrock (Heath 1980; Harned and Daniel 1992; Figure 5-3). The regolith layer is a thoroughly weathered and structureless residual soil that occurs near the ground surface with the degree of weathering decreasing with depth. The residual soil grades into saprolite, a coarser grained material that retains the structure of the parent bedrock. Beneath the saprolite, partially weathered/fractured bedrock occurs with depth until sound bedrock is encountered. This mantle of residual soil/regolith, saprolite, and weathered/fractured rock is a hydrogeologic unit that covers and crosses various types of rock (LeGrand 1988). This soil/regolith layer serves as the shallow unconfined groundwater system and provides an intergranular medium through which the recharge and discharge of water from the underlying fractured rock occurs. Within the fractured sedimentary bedrock, the fractures control both the hydraulic conductivity and storage capacity of the rock mass. A TZ at the base of the regolith has been interpreted to be present in many areas of the Piedmont and based on this investigation is present in the Dan River Basin. Harned and Daniel (1989) describe the TZ as consisting of partially weathered/fractured bedrock and lesser amounts of saprolite that grade into bedrock. They also describe the TZ as “being the most permeable part of the system, even slightly more permeable than the soil zone” (Harned and Daniel 1992). Harned and Daniel (1992) suggested the zone may serve as a conduit of rapid flow and transmission of water. Until recently, most of the information supporting the existence of the TZ was qualitative based on observations made during the drilling of boreholes and water-wells, although some quantitative data is available for the Piedmont region (Stewart 1964; Stewart et al. 1964; Nutter and Otton 1969; Harned and Daniel 1992). Using a database of 669 horizontal hydraulic conductivity measurements in boreholes at six locations in the Carolina Piedmont, Schaeffer (2009; 2014a) statistically showed that a TZ of higher hydraulic conductivity exists in the Piedmont groundwater system when considered within Harned and Daniel’s (1989) two types of bedrock conceptual framework. The TZ is comprised of partially weathered rock (PWR), open, steeply dipping fractures, and low angle stress relief fractures, either singly or in various combinations below drilling refusal (auger, roller cone, or casing advancer; Schaeffer 2011; 2014b). The TZ has less advanced weathering relative to the regolith and generally the weathering has not progressed to the development of clay minerals that would decrease the permeability of secondary porosity developed during weathering (i.e., the new fractures developed during the weathering process, and/or the enhancement of existing fracture systems). The characteristics of the TZ can vary widely based on the interaction of rock type, degree of weathering, degree of systematic fracturing, presence of stress-relief fracturing, and the general characteristics of the bedrock (foliated/layered, massive, or in between). The TZ is not a continuous layer between the regolith and bedrock; it thins and thickens within short distances and is absent in places (Schaeffer 2011; 2014b). The absence, thinning, and thickening of the TZ are related to the characteristics of the underlying bedrock (Schaeffer 2014b). As previously described, the TZ may vary due to different rock types and associated rock structure. Harned and Daniel (1992) divided bedrock into two conceptual models: 1) Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 5.0 REGIONAL GEOLOGY AND HYDROGEOLOGY 27 foliated/layered structures (metasedimentary and metavolcanic sequences; in the case of the DRSS site, sedimentary bedding) and 2) massive/plutonic structures (plutonic and metaplutonic complexes) (Figure 5-4). Strongly foliated/layered (sedimentary) rocks are thought to have a well-developed TZ due to the breakup and weathering along the foliation planes or layering, resulting in numerous rock fragments (Harned and Daniel 1992). More massive/plutonic rocks are thought to develop an indistinct TZ because they do not contain foliation/layering and tend to weather along relatively widely spaced fractures (Harned and Daniel 1992). Schaeffer (2014a) proved the Harned and Daniel (1989) hypothesis that foliated/layered bedrock would have a better developed TZ than massive/plutonic bedrock. The foliated/layered bedrock TZ has a statistically significant higher hydraulic conductivity than the massive/plutonic bedrock TZ (Schaeffer 2014a). LeGrand’s (1988, 1989) conceptual model of the groundwater setting in the Piedmont, applicable to the DRSS site, incorporates the Daniel and Harned (1992) two-medium regolith//bedrock with TZ system into an entity that is useful for the description of groundwater conditions. That entity is the surface drainage basin that contains a perennial stream (LeGrand 1988). Each basin is similar to adjacent basins and the conditions are generally repetitive from basin to basin. Within a basin, movement of groundwater is generally restricted to the area extending from the drainage divides to a perennial stream (Slope-Aquifer System; Figure 5-5; LeGrand 1988, 1989, 2004). Rarely does groundwater move beneath a perennial stream to another more distant stream or across drainage divides (LeGrand 1989). The crests of the water table underneath topographic drainage divides represent natural groundwater divides within the slope-aquifer system and may limit the area of influence of wells or contaminant plumes located within their boundaries. The concave topographic areas between the topographic divides may be considered as flow compartments that are open-ended down slope. Therefore, the groundwater system is a two-medium system generally restricted to the local drainage basin. The groundwater occurs in a system composed of two interconnected layers: residual soil/saprolite and weathered rock (TZ) overlying fractured sedimentary rock. The systems are separated by the TZ portion of the residual soil, saprolite, and weathered rock. Typically, the residual soil/saprolite is partially saturated and the water table fluctuates within it. Water movement is generally preferential through the weathered/fractured and fractured bedrock of the TZ (i.e., enhanced permeability zone). The character of such aquifers results from the combined effects of the rock type, fracture system, topography, and weathering. Topography exerts an influence on both weathering and the opening of fractures, while the weathering of the crystalline rock modifies both transmissive and storage characteristics. The sedimentary rocks in the Dan River Basin are hard with tight grain packing (Thayer and Robbins 1992). The primary porosity and permeability of the conglomerates and sandstones are very low. Thayer and Robbins (1992) found that the average primary porosity of eight sandstones from the basin is 3.8% with a low mean permeability of 0.05 millidarcies (mD), both due to the tight grain packing and high percentage of allogenic clay matrix. The fine-grained shales and mudstones have lower primary porosity and permeability than the sandstones. Groundwater flow paths in this geologic environment are almost invariably restricted to the zone underlying the topographic slope extending from a topographic divide to an adjacent stream. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 5.0 REGIONAL GEOLOGY AND HYDROGEOLOGY 28 Under natural conditions, the general direction of groundwater flow can be approximated from the surface topography (LeGrand 2004). Groundwater recharge in the region is derived entirely from infiltration of local precipitation. Groundwater recharge occurs in areas of higher topography (i.e., hilltops) and groundwater discharge occurs in lowland areas bordering surface water bodies, marshes, and floodplains (LeGrand 2004). Average annual precipitation contributing to recharge in the Piedmont ranges from 42 to 46 inches. Mean annual recharge in the Piedmont ranges from 4.0 to 9.7 inches per year (Daniel 2001). This page is intentionally left blank. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 6.0 SITE GEOLOGY AND HYDROGEOLOGY 29 6.0 Site Geology and Hydrogeology 6.1 Site Geology DRSS and its associated ash basin system are located in the Dan River Triassic Basin, one of several northeast-trending Triassic basins that occur within the Piedmont Province. Thayer (1970) divided the rocks of the basin into three stratigraphic formations (oldest to youngest): 1) Pine Hall Formation, 2) Cow Branch Formation, and 3) Stoneville Formation. The Pine Hall Formation is along the southeast margin of the basin and consists of gray to red, medium- to coarse-grained conglomerate, pebbly sandstone grading upward into massive, bioturbated red siltstone and mudstone. This sequence defines an upward fining sequence suggesting braided river deposits (Thayer 1970; Thayer and Robbins 1992). The Cow Branch Formation conformably overlies and interfingers with the Pine Hall Formation and consists of black and gray bedded, carbonaceous shales and mudstones, sandstones (arkosic), and thin coal beds deposited in a lacustrine environment (Thayer 1970; Thayer and Robbins 1992). The site is underlain by rocks of the Pine Hall (Tph) and Cow Branch (Tcb) Formations (Figure 6-1). Alluvial and terrace deposits consisting of unconsolidated sand, silt, and clay with occasional sub-rounded to well-rounded pebbles occur along the Dan River and major tributaries. A site geologic map, based on Carpenter (1982), field reconnaissance, and the first rock type encountered in boreholes installed for this CSA, is presented on Figure 6-1. Diabase boulders were found on the DRSS site north of the DRCCS (Figure 6-1) near the inferred diabase dike of Carpenter (1992) confirming its existence at that location and suggesting that it continues to the southeast as shown on the regional and site geologic maps. None of the boreholes encountered the dike. The alluvial contact, with a location different than that shown on Figure 5-2, along the Dan River south of the ash basin system, is based on borehole data and field reconnaissance. The installed well and sample locations are shown on Figure 6-2. 6.1.1 Soil Classification A total of 67 borings were installed as part of this assessment. The following soils/materials were encountered in the boreholes:  Ash – Ash was encountered in borings advanced within the ash basin and ash storage areas, as well as in some borings advanced through the basin perimeter and intermediate dams. Ash several inches thick was encountered in one location within the ash dredge area located between Ash Storage 1 and Ash Storage 2. Ash was generally described as gray to dark bluish gray with a silty to sandy texture, consistent with fly ash and bottom ash.  Fill – Fill material generally consisted of re-worked silts and clays that were borrowed from one area of the site and re-distributed to other areas. Fill was used in the construction of dams and as cover for ash storage areas.  Alluvium – Alluvium is unconsolidated soil and sediment that has been eroded and redeposited by streams and rivers. Alluvium may consist of a variety of materials ranging Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 6.0 SITE GEOLOGY AND HYDROGEOLOGY 30 from silts and clays to sands and gravels. During site construction and plant operation, alluvial deposits have been removed or covered. Alluvium was encountered in borings along the Dan River during the project subsurface exploration activities. Designations between alluvium and fill are approximate and were challenging to distinguish due to the similarities in material.  Residuum (Residual soils) – Residuum is the in-place weathered soil that consists of red, brown, yellow, and gray clayey silt to silty clay. This unit was encountered in various thicknesses across the site. It is believed that substantial thicknesses of residuum were removed to practical excavation depths and used for fill. Designations between residuum and fill are approximate and were challenging to distinguish due to the similarities in material.  Saprolite – Saprolite is soil developed by in-place weathering of rock similar to the bedrock that consists of red, brown, yellow, and gray clayey silt to silty clay with traces of sand and rock fragments. The primary distinction from residuum is that saprolite typically retains some structure (e.g., mineral banding) from the parent rock. This unit was found across the site as a generally thin (e.g., less than 5 feet thick) stratigraphic unit. It is assumed that historical earthwork on-site may have been carried vertically downward through the residuum to or near the PWR, thus removing much of the saprolite. Undisturbed and split-spoon samples collected during the field investigation were tested for various geotechnical parameters including natural moisture content, Atterberg Limits (undisturbed samples only), grain size with hydrometer, total porosity (undisturbed samples only), and vertical hydraulic conductivity (undisturbed samples only), and were classified using the Unified Soil Classification System (USCS). Geotechnical index property testing was completed for disturbed and undisturbed samples in accordance with ASTM standards. Twenty- eight undisturbed (“Shelby Tube”) samples received a full suite of geotechnical index testing. The index property testing program for undisturbed samples comprised USCS classification (ASTM D 2487), natural moisture content (ASTM D 2216), Atterberg Limits (ASTM D 4318), grain size distribution, including sieve analysis and hydrometer (ASTM D 422), total porosity calculated from Specific Gravity (ASTM D 854), and hydraulic conductivity (ASTM D 5084). Five undisturbed samples were unable to receive the complete index property testing program due to low recovery, wax and gravel mixed in the tube, loose material, or damaged tubes. Twenty-two disturbed (“Split Spoon” or “Jar”) samples received grain size distribution with hydrometer (ASTM D 422), and natural moisture content (ASTM D 2216). The results are presented in Section 11.0. 6.1.2 Rock Lithology Major rock types at the DRSS site are sandstones, siltstones, mudstones, shales, and conglomerates. The sandstones are gray to red, fine-grained, poorly sorted, mineralogically immature, and exhibit tight grain packing. Coarser, detrital micas (biotite and muscovite) are oriented parallel to bedding. The finer-grained matrix consists of angular quartz and feldspar mixed with detrital sericite, illite, and chlorite. The siltstones are gray to red, very fine-grained and are similar to the sandstone units in mineralogy and structure. Layers of interlayered sandstone and siltstone (layers up to 1 inch thick) are present in the core and exhibit fining Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 6.0 SITE GEOLOGY AND HYDROGEOLOGY 31 upwards sequences. The mudstones are red to black, non-fissile, very fine-grained, poorly sorted with larger grains of quartz, minor plagioclase, and muscovite. They exhibit tight grain packing. Well-developed laminations with larger mica flakes and calcite stringers are present parallel to the laminations. The matrix consists of angular quartz and feldspar mixed with detrital sericite, illite, and chlorite and is calcareous. The darker mudstones are carbonaceous. The shale, generally black, is fissile and is similar to the mudstones in mineralogy and texture. The conglomerates occur in thin layers within sandstone beds and both matrix-supported and clasts- supported conglomerates were noted in the rock core. The conglomerates consist of angular to subrounded quartz and alkali and plagioclase feldspars grains with the finer portions of the conglomerates having mineralogy and texture as the sandstones. 6.1.3 Structural Geology Bedding planes are the major structural feature at the DRSS site. The bedding is oriented N30°- 45°E with dips of 20° to 45° NW with sandstone bedding varying from thinly (0.03 to 0.3 foot) to thickly bedded (1 to 3 feet), mudstone bedding from thinly (0.03 to 0.3 foot) to medium (0.3 to 1 foot) bedded, and minor shale interlayers are thinly laminated (<0.03 foot). Two major joint sets were noted in the rock core: one parallel to the strike of bedding (N30°-45°E) with steep dips and one perpendicular to bedding (N45°-60°W) with steep dips. Other minor fracture orientations were noted. Minor faulted areas were noted in the rock core and were generally parallel to the strike of bedding with dips from 60° to near vertical and are related to movement along the Chatham fault zone during deposition. The map pattern of the Pine Hall and Cow Branch Formations (Figures 5-2 and 6-1) suggests that gentle folding has occurred along northeast axes parallel to the basin boundaries. The map pattern can also result from the intertongue relationship between the two formations or unrecognized intrabasinal faults (Thayer and Robbins 1992). 6.1.4 Fracture Trace Study 6.1.4.1 Introduction Fracture trace analysis is a remote sensing technique used to identify lineaments on topographic maps and aerial photography that may correlate to locations of bedrock fractures exposed at the earth’s surface. Fracture trace analysis is a useful tool for identifying potential fracture locations, and hence potential preferential pathways for infiltration and flow of groundwater near a site; however, results are not definitive. Lineaments identified as part of fracture trace analysis may or may not correspond to actual locations of fractures exposed at the surface, and if fractures are present, it cannot be determined from fracture trace analysis whether these are open, healed, or potential groundwater flow paths. The effectiveness of fracture trace analysis in the Piedmont region is hampered by dense vegetative cover and abundant alteration of the surface by present and past human activity (e.g., agriculture, residential development, commercial/industrial activity). The ability to identify small-scale lineaments on aerial photography that might otherwise be apparent is thereby hindered. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 6.0 SITE GEOLOGY AND HYDROGEOLOGY 32 6.1.4.2 Methods Available geologic maps for the area were consulted prior to performance of aerial photography and topographic map interpretation to identify lithologies and structures in the area, and likely fracture orientations. Both low-altitude aerial photography provided by Duke Energy (from WSP Global, Inc.) covering approximately 4 square miles, and USGS 1:24000 scale topographic maps covering an area of approximately 84 square miles were examined. Maps examined included portions of the Eden Northeast, North Carolina and Eden Southeast, North Carolina USGS 7.5’ (1:24,000 Scale) topographic quadrangles. Digital copies of the quadrangles were obtained and viewed on a monitor at up to 7x magnification. Lineaments identified were plotted directly on the digital images. Photography provided for review included 1”=600’ scale, 9 x 9 inch black-and-white (grayscale) contact prints dated April 17, 2014. Stereo coverage was complete across the area shown on Figure 6-4. The photography was examined using a Lietz Sokkia MS-27 mirror stereoscope with magnifying binocular eyepiece. Lineaments identified on the photographs were marked on hard copies of scanned images (600 dpi resolution), and subsequently compiled onto a photomosaic base. Rose diagrams were prepared for lineament trends identified from both aerial photography and topographic map interpretation, and are included as inserts on the respective figures (Figures 6- 3 and 6-4). 6.1.4.3 Results Lineaments identified from topographic mapping are shown and lineament trends indicated by a rose diagram are included on Figure 6-3. More lineaments were found in the polydeformed and metamorphosed Paleozoic rocks south of Dan River. Three marked lineament trends are apparent in the topography: 1) generally east to east- northeast-trending lineaments subparallel to the structural fabric in the Paleozoic sequence; 2) northeast-trending lineaments in both the Paleozoic and Mesozoic sequences, subparallel to the normal fault north of Eden and possibly related to opening and infilling of the Dan River Basin; and 3) north- to northwest-trending lineaments of the type generally associated with Triassic extensional tectonics and emplacement of diabase dikes in the Piedmont. A cluster of north to northwest-trending lineaments in Paleozoic rocks south and southwest of DRSS may be associated with two large diabase dikes inferred from aeromagnetic data (Carpenter 1982). A long, northward-trending linear segment of Town Creek south-southeast of DRSS suggests the presence of a major structure, possibly a diabase dike that was not inferred by Carpenter 1982. If related to a dike, the dike has a northerly trend and does not pass beneath DRSS. Lineaments identified from aerial photography are shown and lineament trends indicated by a rose diagram are included on Figure 6-4. A total of 15 lineaments were identified from aerial- photography interpretation, all within the Paleozoic sequence south of the Dan River. Most are Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 6.0 SITE GEOLOGY AND HYDROGEOLOGY 33 characterized by a northwest trend. North-trending lineaments located along the lower (northern) reaches of Town Creek potentially indicate the presence of a diabase dike as discussed above. A number of northeast- to east-trending lineaments also occur across the area south of the Dan River. 6.1.5 Effects of Structure on Groundwater Flow The significant geologic structures with respect to groundwater movement in the bedrock of the regolith-fractured rock aquifer system at the site are the bedding planes, joints, and minor faults and a diabase dike that cuts across the other rock units. Differential weathering of the sedimentary rocks related to rock type could result in northeast-trending depressions along the top of the bedrock surface below the regolith and could direct groundwater flow along it as well as result in highly variable thickness of the TZ. The joints are generally discontinuous and confined to sedimentary layers within the bedrock and will not impart significant directionality to overall groundwater flow paths. The extent of the minor northeast-trending faulting noted in the rock core is not known, but would add additional directionality in the northeast direction. The north- to northwest-trending diabase dike could either form a barrier to flow, a flow path, or have no effect on groundwater flow depending on its degree of fracturing and weathering. A non- fractured diabase dike would be a flow barrier and would direct groundwater flow along its contact. A highly fractured, weathered dike could act as a flow channel. 6.1.6 Soil and Rock Mineralogy and Chemistry Soil and rock mineralogy and chemistry analyses are incomplete as of the date of this report. Soil mineralogy and chemistry results through July 31, 2015 are shown in Table 6-1 (mineralogy), Table 6-2 (chemistry, % oxides), and Table 6-3 (chemistry, elemental composition). The mineralogy and chemical composition of TZ materials are presented in Table 6-4 (mineralogy) and Table 6-5 (chemistry). Whole rock chemistry results (% oxides and elemental composition) are shown in Tables 6-6 and 6-7, respectively. Petrographic analysis of rock (thin-sections) and the remaining soil mineralogy and chemistry analyses will be included in the CSA supplement. The dominant mineral constitutes in the soils are quartz, feldspar (both alkali and plagioclase feldspars), and muscovite/illite, Soils exhibiting a higher degree of weathering show an increase in kaolinite with higher percentage amorphous phase (lacking distinct crystalline structure). Other minerals identified include chlorite, biotite, calcite, dolomite, hornblende/amphibole, pyrite, ilmenite, goethite, gypsum and smectiite/chlotite. The major oxides in the soils are SiO2 (41.59% - 75.49%), Al2O3 (13.12% - 34.56%), and Fe2O3 (2.61% - 11.02%). Major TZ minerals are quartz, feldspar, muscovite/vermiculite/illite, kaolinite, chlorite, and smectite. The major oxides are SiO2 (50.4% - 67.9%), Al2O3 (16.2% - 25.5%), and Fe2O3 (8.5% - 15.1%). Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 6.0 SITE GEOLOGY AND HYDROGEOLOGY 34 6.2 Site Hydrogeology 6.2.1 Groundwater Flow Direction Accessible voluntary, compliance, closure, and ash basin assessment monitoring wells were gauged for depth to water and total well depth during a comprehensive groundwater elevation reading event on June 28 and 29, 2015. Depth to water measurements were subtracted from surveyed top of well casing elevations to produce groundwater elevations in shallow, deep, and bedrock monitoring wells. Groundwater flow direction was estimated by contouring these groundwater elevations. The shallow aquifer includes the shallow and deep groundwater monitoring wells (S and D wells) and the deep aquifer only includes the fractured bedrock wells (BR wells). In general, groundwater within the shallow aquifer/TZ (S/D wells), and fractured bedrock (BR wells) flows from the northern extent of the DRSS property boundary south and southeast toward the Dan River. However, in the area north of Ash Storage 1, groundwater elevation data suggest the presence of a groundwater divide extending from MW -12 east to GWA-1. To the north of this divide, localized groundwater within the shallow aquifer/ TZ flows north, away from the DRSS site and toward an unnamed tributary that flows to the Dan River. Data gathered as part of this CSA support the understanding that groundwater flow beneath the ash storage areas is to the south and southeast toward the Dan River rather than to the north. Shallow groundwater flow direction is shown on Figure 6-5. Groundwater flow within the TZ is shown on Figure 6-6. Groundwater flow within fractured bedrock is shown on Figure 6-7. 6.2.2 Hydraulic Gradient Horizontal hydraulic gradients were derived for the shallow aquifer, TZ, and fractured bedrock by calculating the difference in hydraulic heads over the length of the flow path between two wells with similar well construction (e.g., both wells having 15-foot screens within the same water–bearing unit). The following equation was used to calculate horizontal hydraulic gradient: i = dh / dl where i is the hydraulic gradient; dh is the difference between two hydraulic heads (measured in feet); and dl is the flow path length between the two wells (measured in feet). Applying this equation to wells installed during the CSA yields the following average horizontal hydraulic gradients (measured in feet/foot):  S wells: 0.030  D wells: 0.029  BR wells: 0.037 A summary of hydraulic gradient calculations is presented in Table 6-6. Note that vertical hydraulic gradients are discussed in Section 11.3. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 6.0 SITE GEOLOGY AND HYDROGEOLOGY 35 6.2.3 Effects of Geologic/Hydrogeologic Characteristics on Contaminants Migration, retardation, and attenuation of COIs in the subsurface is a factor of both physical and chemical properties of the media in which the groundwater passes. Soil samples were collected and analyzed for grain size, total porosity, soil sorption (Kd), and anions/cations to provide data necessary for completion of the three-dimensional groundwater model discussed in Section 13.0. As agreed upon with NCDENR (Appendix A), results of the groundwater model will be presented in the CAP. 6.2.4 Site Hydrogeologic Conceptual Model The site hydrogeologic conceptual model (referred to as the site conceptual model, or SCM) is a conceptual interpretation of the processes and characteristics of a site with respect to the groundwater flow and other hydrologic processes at the site. The May 31, 2007 NCDENR document, Hydrogeologic Investigation and Reporting Policy Memorandum was used as general guidance to developing the model. General components of the SCM consist of developing and describing the following aspects of the site: geologic/soil framework, hydrologic framework, and the hydraulic properties of site materials. More specifically, the SCM describes how these site-specific aspects affect groundwater flow at the site. In addition to these site- specific aspects, the SCM:  Describes the site and regional geology,  Presents longitudinal and transverse cross-sections showing the hydrostratigraphic layers,  Develops the hydrostratigraphic layer properties required for the groundwater model,  Presents a groundwater contour map showing the potentiometric surface of the shallow aquifer, and  Presents information on horizontal and vertical groundwater gradients. The SCM serves as the basis for developing and understanding the hydrogeologic characteristics of the site and for developing a groundwater flow and transport model. Historic site groundwater elevations and ash basin water elevations were used to develop a historic estimated seasonal high groundwater contour map for the site. A fracture trace analysis (described previously in Section 6.1.4) was also performed for the DRSS site, as well as on- site/near-site geologic mapping, to better understand site geology and to confirm and support the SCM. An updated SCM, based on data obtained during the CSA activities and refined through completion of groundwater modeling, will be presented in the CAP. This page is intentionally left blank. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 7.0 SOURCE CHARACTERIZATION 36 7.0 Source Characterization At the DRSS site, source characterization was performed through the completion of soil borings, installation of monitoring wells, and collection and analysis of associated solid matrix and aqueous samples. Ash samples were collected for analysis of physical characteristics (e.g., grain size, porosity) to provide data for evaluation of retention/transport properties within and beneath the ash basin and ash storage areas. Ash samples were collected for analysis of chemical characteristics (e.g., total inorganics, leaching potential) to provide data for evaluation of constituent concentrations and distribution. Samples were collected in general accordance with the W ork Plan. Drilling and installation variances are documented in Appendix C. For the purpose of this CSA report and for use throughout this section, the term COI is used to refer to any constituent or parameter that exceeded its applicable regulatory standard. Ash, ash basin surface water, porewater, and seep sample locations used for source characterization are shown on Figure 7-1. COIs and laboratory methods used for analysis of solid matrix samples are presented in Table 7-1. Laboratory results of total inorganic and anion/cation analyses of ash samples are presented in Table 7-2. Laboratory results of aqueous matrix (groundwater, surface water, ash porewater and seeps) parameters and analytical methods are presented in Table 7-3. Laboratory results of ash basin surface water samples are presented in Table 7-4. Ash basin porewater sample results are presented in Table 7-5. 7.1 Ash Basin 7.1.1 Ash (Sampling and Chemical Characteristics) Nine borings (AB-5D, AB-10D, AB-15D, AB-20S, AB-25BR, AB-35BR, MW-308BR, MW-311BR, and MW -314BR) were advanced within the ash basin waste boundary to obtain ash samples for chemical analyses. Eight COIs (arsenic, , boron, cobalt, iron, manganese, selenium, and vanadium) were reported above the North Carolina Preliminary Soil Remediation Goals (PSRGs) for Industrial Health and/or Protection of Groundwater Standards in one or more ash samples (see Table 7-2). 7.1.2 Ash Basin Surface Water (Sampling and Chemical Characteristics) Two surface water samples (SW -1 and SW-9) were collected from within the ash basin. Sample SW -9 was collected from the Primary Cell and SW -1 was collected from surface water within the Secondary Cell (see Figure 7-1). Four COIs (aluminum, arsenic, copper, and zinc) were reported above 2B Standards for both SW -1 and SW -9 (see Table 7-4). 7.1.3 Ash Porewater (Sampling and Chemical Characteristics) Ash porewater refers to water samples collected from wells installed within the ash basin and screened in ash. HDR does not consider these results to be representative of groundwater. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 7.0 SOURCE CHARACTERIZATION 37 Four ash porewater monitoring wells (AB-5S, AB-10S, AB-10SL, and AB-25S) were installed within the waste boundary of the ash basin and were screened within ash. In addition, one temporary monitoring well (AB-15S) was installed within the Primary Cell of the ash basin to facilitate collection of an ash porewater sample. Note that a permanent well could not be installed in this location due to concerns with stability of ash within the basin, as documented on the variance table in Appendix C. Six COIs (antimony, arsenic,, cobalt, iron, manganese, and vanadium) were reported above 2L Standards or IMACS in porewater samples collected from wells in the ash storage areas and ash basin (see Table 7-5). Arsenic and vanadium concentrations generally increased in the direction of groundwater flow (e.g., from well MW -5S to well MW-10S). In general, cobalt, iron, and manganese concentrations decreased in the direction of groundwater flow. Several other COIs exceeded 2L Standards or IMACs, but appeared to be isolated instances and not influenced by groundwater flow. Ash porewater sample locations and exceedances of 2L Standards or IMACs are shown on Figure 7-1. 7.1.4 Ash Porewater Speciation Speciation is the analysis of the composition of a particular analyte in a system. Speciation is important for understanding the fate and transport of COIs. Three locations, AB-10S, AB-10SL, and AB-25S, were sampled for chemical speciation analyses of arsenic (III), arsenic (V), chromium (VI), iron (II), iron (III), manganese (II), manganese (IV), selenium (IV), and selenium (VI). Results for chemical speciation of porewater samples are presented in Table 7-6. Further evaluation of chemical speciation results will be included in the CAP. 7.1.5 Radiological Laboratory Testing Dissolved radionuclides from naturally occurring sources (e.g. soil or rock) may exist in water. The USEPA regulates various radionuclides in drinking water. For purposes of this assessment, radium-226, radium-228, natural uranium, uranium-233, uranium-234, and uranium-236 were analyzed. Three locations, AB10S/SL and AB-25S, were sampled for the analytes listed above. Results for radiological laboratory testing of porewater samples are presented in Table 7-7. Further evaluation of radiological laboratory testing results will be included in the CAP. 7.2 Ash Storage Areas 7.2.1 Ash (Sampling and Chemical Characteristics) Eight borings (AS-4D, AS-8D/BR, MW -301BR, MW-303BR, MW-306BR, MW -315BR, and MW- 318D) were advanced within the ash storage waste boundary to obtain ash samples for chemical analyses. Eight COIs (arsenic, barium, boron, cobalt, iron, manganese, selenium, and vanadium) were reported to have exceeded either the North Carolina Industrial Health or Protection of Groundwater PSRGs (see Table 7-2). Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 7.0 SOURCE CHARACTERIZATION 38 7.2.2 Ash Porewater (Sampling and Chemical Characteristics) As part of this CSA, monitoring wells installed within the ash storage areas were constructed with screened intervals set below ash. Prior to this CSA effort, between June and July 2013, AMEC Environment & Infrastructure (AMEC) installed monitoring wells within the ash storage area with well screens set in ash that serve to monitor ash porewater. The following monitoring wells were used to monitor porewater: OW-305S, OW-315D, and OW-320D. A review of data collected by AMEC indicates that arsenic, boron, chromium, cobalt, iron, manganese, and vanadium exceeded the 2L Standards or IMACs in groundwater samples collected from one or more of the above-referenced wells. 7.3 Leaching Potential of Ash In addition to total inorganic testing of ash samples, 16 ash samples collected from borings completed within the ash basin and ash storage areas were analyzed for leachable inorganics using Synthetic Potential Leaching Procedure (SPLP) analysis (see Table 7-8). The purpose of the SPLP testing is to evaluate the mobility, or leaching potential of COIs to impact groundwater above the 2L Standards or IMACs. The results of SPLP analyses indicated that the following COIs exceeded their 2L Standards or IMACs: antimony, arsenic, barium, beryllium, chromium, cobalt, iron, lead, manganese, selenium, thallium, and vanadium. However, it is unclear to what severity these COIs would impact groundwater if infiltration continues over time. Based on this analysis, development of site-specific leaching values would be beneficial as a more realistic screening value to protect groundwater. 7.4 Seeps 7.4.1 Review of NCDENR March 2014 Sampling Results In March 2014, NCDENR sampled the following seeps at DRSS (see Figure 7-1 and Table 7-9):  NPDES Outfall 002  INFSW009  SW009 #2165  NPDES 001, SW021, old NPDES 005 (OUT001)  NPDES004 and SW2  Old NPDES006  CCSW002OUT  CCSW001  DRRC001 (also CCSW002OUT48) Based on review of the March 2014 sampling results and measured field parameters, the following COIs exceed 2B Standards at one or more locations: dissolved oxygen (DO), aluminum, nickel, and zinc. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 7.0 SOURCE CHARACTERIZATION 39 March 2014 sampling results and measured field parameters were also compared to 2L Standards. Iron, manganese, zinc, and pH exceeded their respective 2L Standards. 7.4.2 Ash Basin and NCDENR Seep Sampling Results – CSA Activities 7.4.2.1 Ash Basin Seeps Four seeps (S-1 through S-4) are associated with the DRSS ash basin. Seeps S-1 through S-3 are located near an unnamed tributary along the eastern property boundary and downgradient of the Secondary Cell. Seep S-4 is located at the southwestern toe of the Primary Cell dam, adjacent to the boat ramp and river near the southern property boundary. Seep locations are shown on Figure 7-1. Several attempts were made to sample seeps S-2 through S-4, but these seeps were dry during each attempt and, therefore, were not sampled. Seep S-1 was successfully sampled and analytical results are provided in Table 7-10. Three COIs exceeded 2L Standards or IMACs at Seep S-1: cobalt, manganese, and vanadium. 7.4.2.2 NCDENR Seeps Four NCDENR-identified seeps (INFSW009, CSSW001, CCSW002OUT, and DRRC001) were planned to be sampled during this groundwater assessment. Seep INFSW009 was dry at the time of sampling; however, samples were collected from CSSW001, CCSW002OUT, and DRRC001. Samples collected from one or more of these seep locations exceeded 2L Standards or IMACs for the following COIs: cobalt, iron, manganese, and vanadium (see Table 7-10). 7.4.2.3 Seep Speciation Speciation is the analysis of the composition of a particular analyte in a system. Speciation is important for understanding the fate and transport of COIs. Four locations, CCSW001, CCSW002, DRRC001, and S-1, were sampled for chemical speciation analyses of arsenic (III), arsenic (V), chromium (VI), iron (II), iron (III), manganese (II), manganese (IV), selenium (IV), and selenium (VI). Results for chemical speciation of surface water are presented in Table 7-11. Further evaluation of chemical speciation results will be included in the CAP. 7.5 COIs Exceeding Applicable Standards Based on evaluation of the ash, ash basin surface water, and seep sampling data, the following COIs exceeding applicable standards were identified: 7.5.1 COIs in Ash (based on total inorganics analysis, as shown in Table 7-2)  Arsenic  Barium  Boron  Cobalt  Iron Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 7.0 SOURCE CHARACTERIZATION 40  Manganese  Selenium  Vanadium 7.5.2 COIs in Surface Water (based on water quality analysis, as shown in Table 7-4)  Aluminum  Arsenic  Copper  Zinc 7.5.3 COIs in Ash Porewater (based on water quality analysis, as shown in Table 7-5 and data reviewed from 2013 assessment activities in support of conceptual closure design of DRSS ash basin)  Antimony  Arsenic  Boron  Chromium  Cobalt  Iron  Lead  Manganese  pH  Vanadium 7.5.4 COIs in Seeps and Stormwater (based on water quality analysis, as shown in Table 7-10)  Cobalt  Iron  Managanese  Vanadium This page is intentionally left blank. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 8.0 SOIL AND ROCK CHARACTERIZATION 41 8.0 Soil and Rock Characterization The purpose of soil and rock characterization is to evaluate the physical and geochemical properties in the subsurface with regard to COI presence, retardation, and migration. Soil and rock sampling was performed in general accordance with the procedures described in the Work Plan. Refer to Appendix D for a detailed description of these methods and Appendix E for field and sampling quality control / quality assurance protocols. Soil, PWR, and bedrock samples were collected from background locations, beneath the ash basin and ash storage areas, and beyond the waste boundaries. Table 8-1 summarizes the soil and rock sampling plan utilized for groundwater assessment activities. Variances from the proposed sampling plans are presented in Appendix D. The boring locations are shown on Figure 8-1. The petrographic analysis of rock (thin-sections), rock chemistry (laboratory) and soil mineralogy and chemistry will be included in the CSA Supplement. 8.1 Background Sample Locations Background (BG) boring locations were identified based on the SCM at the time the Work Plan was submitted. The BG locations were selected in areas assumed to not be impacted by and topographically upgradient of the DRSS ash basin and ash storage areas. Based on the groundwater contours shown on Figures 6-5 through 6-7 and the updated SCM, the BG locations are considered to be hydraulically upgradient of the ash basin and ash storage areas. The BG boring locations (BG-5S/D, BG-1D, MW -23BR, and SB-1 through SB-3) are considered to be representative of background soil conditions at the site. 8.2 Analytical Methods and Results Table 8-2 summarizes analyses and analytical methods for soil, PWR, and bedrock samples collected. Total inorganic results for background soil samples are presented in Table 8-3. Total inorganic results for background PWR and bedrock samples are presented in Table 8-4. Total inorganic results for soil samples are presented in Table 8-5. Total inorganic results for PWR and bedrock samples are presented in Table 8-6. Figure 8-1 depicts the total inorganic results for soil, PW R, and bedrock analysis. Cross-section transects are presented on Figure 6-2. Cross-sections presenting the vertical distribution of COIs along the transect are depicted on Figures 8-2 through 8-5. 8.3 Comparison of Soil Results to Applicable Levels Soil, PWR, and bedrock analytical results are compared to the North Carolina PSRGs for Industrial Health and Protection of Groundwater Standards and are included in Tables 8-3 through 8-6. Frequency and concentration ranges for COI exceedances of North Carolina PSRGs are listed in Table 8-7. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 8.0 SOIL AND ROCK CHARACTERIZATION 42 8.4 Comparison of Soil Results to Background In addition to comparing results to regulatory criteria, soil sample results have also been compared to background concentrations as discussed below. Refer to Figure 8-1 for soil boring locations. 8.4.1 Background Soil, PWR, and Rock Background soil locations are identified as SB-1, SB-2, SB-3, BG-1D, BG-5D, and MW -23BR. The range of concentrations of COIs in background soil samples are provided below and a summary of results is provided in Table 8-3.  Arsenic – 3.9 mg/kg to 20 mg/kg  Cobalt – 5.6 mg/kg to 42.6 mg/kg  Iron – 16,500 mg/kg to 95,900 mg/kg  Manganese – 82.7 mg/kg to 2,840 mg/kg  Selenium – Not detected above the MDL (<5.4 mg/kg to <7.2 mg/kg)  Vanadium – 16.0 mg/kg to 54.4 mg/kg 8.4.2 Soil, PWR, and Rock Beneath the Ash Basin Soil, PWR, and rock samples beneath the ash basin were obtained from AB-5D, AB-10D, AB- 15D, AB-25BR, AB-30D, AB-35BR, MW -308BR, MW -310BR, MW-311BR, and MW-314BR. The range of constituent concentrations along with a comparison to the range of reported background soil concentrations is provided in Table 8-8. Constituent concentrations of soils beneath the ash basin tend to be higher for arsenic, selenium, and vanadium compared to background soil concentrations. Concentrations for cobalt, iron, and manganese are similar to or lower than background soil concentrations. 8.4.3 Soil, PWR, and Rock Beneath the Ash Storage Areas Soil, PWR, and rock samples beneath the ash storage areas were obtained from AS-2D, AS- 4D, AS-6D, AS-8D, AS-10D, MW -303BR, MW-315BR, and MW -318D. The range of constituent concentrations along with a comparison to the range of reported background soil concentrations is provided in Table 8-9. Constituent concentrations of soils beneath the ash storage areas tend to be higher for arsenic, cobalt, and selenium compared to background soil concentrations. Concentrations for iron, manganese and vanadium are similar to or lower than background soil concentrations. 8.4.4 Soil, PWR and Rock Outside the Waste Boundary Soil, PWR, and rock samples outside the waste boundary were obtained from GWA-1D, GWA- 2D, GWA-3D, GWA-4D, GWA-6S, GWA-7S, GWA-8D, GWA-9D, GWA-10D, GWA-11D, GWA- 12S, GWA-12D, GWA-14S, GWA-15D, MW-301BR, MW-317BR, BG-1D, BG-5D, SB-1, SB-2, and SB-3. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 8.0 SOIL AND ROCK CHARACTERIZATION 43 The range of constituent concentrations along with a comparison to the range of reported background soil concentrations is provided in Table 8-10. Constituent concentrations of soils outside the waste boundary tend to be higher for arsenic, iron, and selenium compared to background soil concentrations. Concentrations for cobalt, manganese, and vanadium are similar to or lower than background soil concentrations. This page is intentionally left blank. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 9.0 SURFACE WATER AND SEDIMENT CHARACTERIZATION 44 9.0 Surface Water and Sediment Characterization The purpose of surface water and sediment characterization is to evaluate whether storage of CCR has migrated to surface waters in the vicinity of the ash basin and ash storage areas. Sampling was performed in general accordance with the procedures described in the Work Plan. Sampling methodology and variances to that methodology are described in Appendix F. Surface water and sediment sample locations are shown on Figure 9-1. NCDENR’s March 2014 sample locations are shown on Figure 9-2. 9.1 Surface Water Surface water samples were obtained from locations along the Dan River and two tributary streams that flow north to south along the eastern and western property boundaries. Surface water parameters and laboratory methods used for analysis of aqueous matrix samples are presented in Table 7-1. Surface water sample results for total and dissolved fractions are presented in Table 9-1. 9.1.1 Comparison of Exceedances to 2B Standards Surface water analytical results are compared to the 2B Standards. Concentration ranges for exceedances of COIs are listed in Table 9-2. Note that antimony, cadmium, and sulfide were not detected in surface water. 9.1.2 Comparison of Exceedances to Background 9.1.2.1 Background Surface Water Background surface water locations are identified as SW-5 and SW-8. Note that sample SW -8 was collected from the Dan River upstream of the DRSS site. Background concentrations for COIs at these two locations are provided below:  Aluminum – <5.0 micrograms per liter (µg/L) to 90 µg/L  Arsenic – <1.0 µg/L to 0.22J3 µg/L  Chromium – <1.0 µg/L to 0.59 µg/L  Cobalt – <1.0 µg/L to 0.32J µg/L  Copper – 1.3 µg/L to 4.62J+ µg/L  Lead – <1.0 µg/L to 0.64 µg/L  Thallium – <0.1 µg/L to <0.2 µg/L  Zinc – <0.005 µg/L to <0.01 µg/L 3 J = Detected, estimated concentration Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 9.0 SURFACE WATER AND SEDIMENT CHARACTERIZATION 45 9.1.2.2 Ash Basin Surface Water Ash basin surface water was obtained at locations SW -1 and SW -9. The range of constituent concentrations along with a comparison to the range of reported background surface water concentrations is provided in Table 9-3. Constituent concentrations of surface water within the ash basin tend to be higher for aluminum, arsenic, copper, and zinc compared to background surface water concentrations. Concentrations for chromium, cobalt, lead, and thallium are similar to or lower than background surface water concentrations. 9.1.2.3 Dan River Surface Water Dan River surface water locations are identified as SW -6 and SW -7. The range of constituent concentrations along with a comparison to the range of reported background surface water concentrations is provided in Table 9-4. Constituent concentrations of surface water from the Dan River tend to be higher for arsenic, chromium, cobalt, lead and zinc compared to background surface water concentrations. Concentrations for aluminum, copper, and thallium are similar to or lower than background surface water concentrations. 9.1.2.4 Tributary Stream Surface Water Tributary surface water locations are identified as SW -3 and SW -4. The range of constituent concentrations along with a comparison to the range of reported background surface water concentrations is provided in Table 9-5. Constituent concentrations of surface water from the tributary tend to be higher for aluminum, arsenic, chromium, copper, lead, thallium and zinc compared to background surface water concentrations. 9.1.3 Discussion of Results for Constituents without 2B Standards In addition to the COIs discussed above, surface water samples were also analyzed for the following constituents that do not have 2B Standards: boron, iron, manganese, mercury, selenium, and vanadium. In lieu of 2B Standards, concentrations of COIs have been compared to background concentrations in the sections below. 9.1.3.1 Background Surface Water Background surface water locations are identified as SW -5 and SW-8.  Boron – 0.057 mg/L to 0.18 mg/L  Iron – 0.412 mg/L  Manganese – 0.055 mg/L to 0.29 mg/L Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 9.0 SURFACE WATER AND SEDIMENT CHARACTERIZATION 46  Mercury – 1.2J+ nanograms per liter (ng/L) to 2.96J+ ng/L  Selenium – <0.5 µg/L to <1 µg/L  Vanadium – 0.42 µg/L to 2.5 µg/L 9.1.3.2 Ash Basin Surface Water Ash basin surface water was obtained at locations SW -1 and SW -9. The range of constituent concentrations along with a comparison to the range of reported background surface water concentrations is provided in Table 9-6. Constituent concentrations of surface water within the ash basin tend to be higher for selenium and vanadium compared to background surface water concentrations. Concentrations for boron, iron, manganese, and mercury are similar to or lower than background surface water concentrations. 9.1.3.3 Dan River Surface Water Dan River surface water locations are identified as SW -6 and SW -7. The range of constituent concentrations along with a comparison to the range of reported background surface water concentrations is provided in Table 9-7. Constituent concentrations of surface water from the Dan River tend to be higher for mercury and vanadium compared to background surface water concentrations. Concentrations for boron, manganese, and selenium are similar to or lower than background surface water concentrations. 9.1.3.4 Tributary Stream Surface Water Tributary surface water locations are identified as SW -3 and SW -4. The range of constituent concentrations along with a comparison to the range of reported background surface water concentrations is provided in Table 9-8. Constituent concentrations of surface water from the tributary tend to be higher for iron manganese and vanadium compared to background surface water concentrations. Concentrations for boron, mercury, and selenium are similar to or lower than background surface water concentrations. 9.2 Surface Water Speciation Speciation is the analysis of the composition of a particular analyte in a system. Speciation is important for understanding the fate and transport of COIs. Three locations, SW-3, SW-4, and SW -5, were sampled for chemical speciation analyses of arsenic (III), arsenic (V), chromium (VI), iron (II), iron (III), manganese (II), manganese (IV), selenium (IV), and selenium (VI). Results for chemical speciation of surface water are presented in Table 9-9. Further evaluation of chemical speciation results will be included in the CAP. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 9.0 SURFACE WATER AND SEDIMENT CHARACTERIZATION 47 9.3 Sediments Sediment samples were collected coincidentally with each of the surface water samples (SW -3 through SW -8), with the exception of ash basin surface water sample locations, and at S-1 (S-1 was dry at the time samples were collected). Sediment samples were analyzed for COIs in accordance with the constituent and parameter list used for soil and rock characterization (see Table 8-1). In the absence of NCDENR sediment criteria, the sediment sample results were compared to North Carolina PSRGs, and ranges of exceedances are presented in Table 9-2. Sediment sample locations are shown on Figure 9-1. Exceedances of soil PSRGs are summarized in Table 9-10. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 48 10.0 Groundwater Characterization The purpose of groundwater characterization is to characterize the groundwater on the site for comparison to 2L Standards or IMACs, and to inform the corrective actions identified in the CAP. Groundwater sampling methods and the rationale for sampling locations were in general accordance with the procedures described in the Work Plan. Refer to Appendix G for a detailed description of these methods. Variances from the proposed well installation locations, methods, quantities, and well designations are presented in Appendix G. 10.1 Regional Groundwater Data for Constituents of Interest Individual sampling events serve to characterize the hydrogeologic and chemical conditions at a particular monitoring location, at a particular time. When interpreting the results from a sampling event, a number of factors that affect the sample results should be taken into consideration. Among these are the geologic and hydrogeologic setting, the location of the sample points in the regional groundwater flow system, potential interactions between suspected contaminants, and the geological and biological constituents present in the formation (Barcelona 1985). As a result of these factors, it may be possible that the analytical results of a given constituent are influenced by naturally occurring conditions as opposed to conditions caused by releases from the ash basin. This section presents an overview of the regional and statewide groundwater conditions for COIs found at the DRSS ash basin system that have promulgated state or federal standards. The 2L Standards recognize that the concentrations of naturally occurring substances in groundwater may exceed the standard established in .0202(g). Rule .0202(b)(3) states that when this occurs, the Director of the DWR will determine the standard. COIs at the DRSS site, along with the associated state and federal drinking water standards, are listed in Table 10-1. North Carolina 2L Standards are established by NCDENR, whereas Primary and Secondary Maximum Contaminant Levels (PMCLs and SMCLs) are established by the USEPA. PMCLs are legally enforceable standards set to protect human health. SMCLs are non-enforceable guidelines set to account for aesthetic considerations, such as taste, color, and odor (USEPA 2014c). Regional background information on COIs at the DRSS site are provided (in alphabetical order) in Sections 10.1.1 through 10.1.14. In addition, regional background information on pH is provided in Section 10.1.15, as pH levels can affect the leachability of metal ions in groundwater. 10.1.1 Antimony Antimony is a silvery-white, brittle metal. In nature, antimony combines with other elements to form antimony compounds. Small amounts of antimony are naturally present in rocks, soils, water, and underwater sediments. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 49 Only a few ores of antimony have been encountered in North Carolina. Antimony has been found in combination with other metals, and is found most commonly in Cabarrus County and other areas of the Carolina Slate Belt (Chapman et al. 2013). In a USGS study of naturally occurring trace minerals in North Carolina, 57 private water supply wells were sampled to obtain trace mineral data. Of the wells sampled, no wells contained antimony above the USEPA PMCL (Chapman et al. 2013). Antimony is compared to IMAC since no 2L Standard has been established for this constituent by NCDENR. 10.1.2 Arsenic Natural arsenic occurs commonly and comes mainly from the soil. The USEPA estimates that the amount of natural arsenic released into the air as dust from the soil is approximately equal to the amount of arsenic released by all human activities (EPRI 2008). DRSS is located in Rockingham County, North Carolina. Data collected from 577 private wells across Rockingham County from 1998 to 2010 indicated that 0.69% of samples had arsenic concentrations exceeding the PMCL. The average arsenic concentration was reported as 1.8 µg/L (NCDHHS 2010b). Sanders et al. (2011) found strong geological patterns in groundwater arsenic concentrations across the state of North Carolina (see Figure 10-1).The DRSS site is located in an area where the average concentrations of naturally occurring arsenic in groundwater is between 2.6 and 5.0 µg/L. 10.1.3 Barium Two forms of barium, barium sulfate and barium carbonate, are often found in nature as underground ore deposits. Barium is sometimes found naturally in drinking water and food. However, since certain barium compounds (barium sulfate and barium carbonate) do not mix well with water, the amount of barium found in drinking water is typically small. Barium compounds such as barium acetate, barium chloride, barium hydroxide, barium nitrate, and barium sulfide dissolve more easily in water than barium sulfate and barium carbonate, but because they are not commonly found in nature, they do not usually occur in drinking water unless the water is contaminated by barium compounds that are released from waste sites (EPRI 2008). Barium is naturally released into the air by soils as they erode in wind and rain, and is released into the soil and water by eroding rocks. Barium released into the air by human activities comes mainly from barium mines, metal production facilities, and industrial boilers that burn coal and oil. Anthropogenic sources of barium in soil and water include copper smelters and oil-drilling waste disposal sites. Industries reporting to the USEPA released 119,646 tons of barium and barium compounds into the environment in 2005 (EPRI 2008). Regional metamorphic grade greenschist to upper amphibolite in the Piedmont’s King’s Mountain Belt contains deposits of barium sulfate (barite). Barium is especially common as Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 50 concretions and vein fillings in limestone and dolostone, which are not common geologic facies in North Carolina; however, at various times in the past century and a half, the Carolinas have been major producers of barite (USEPA 2014c). In a statistical summary of groundwater quality in North Carolina, the Superfund Research Program at the University of North Carolina (UNC) analyzed 245 private well water samples in Rockingham County. The samples were tested by the North Carolina State Laboratory of Public Health from 1998 to 2012. The study found an average barium concentration of 50 µg/L. No samples exceeded the 2,000 µg/L PMCL for barium (NCDHHS 2010b). 10.1.4 Beryllium Beryllium is a hard, gray metal that is very lightweight. In nature, it combines with other elements to form beryllium compounds. Small amounts of these compounds are naturally present in soils, rocks, and water. Emeralds and aquamarines are gem-quality examples of a mineral (beryl) that is a beryllium compound. Beryllium combines with other metals to form mixtures called alloys. Beryllium and its alloys are used to construct lightweight aircraft, missile, and satellite components. Beryllium is also used in nuclear reactors and weapons, X-ray transmission windows, heat shields for spacecraft, rocket fuel, aircraft brakes, bicycle frames, precision mirrors, ceramics, and electrical switches (EPRI 2008). Most of the beryl occurring in North Carolina is along the south and southwest sides of the Blue Ridge Mountains. The most notable mines include the Biggerstafff, Branchand, and Poteat mines in Mitchell County; the Old Black mine in Avery County; and the Ray mine in Yancey County. The beryl forms golden or pale-green well-formed prismatic crystals ranging in size from a fraction of an inch to about 3 inches in diameter. It is generally found near the cores of bodies of pegmatites of moderate size that contain considerable amounts of perthitic microcline. Production has been negligible, and no regular production appears possible. Green beryl (aquamarine and emerald) was mined commercially many years ago at the Grassy Creek emerald mine and the Grindstaff emerald mine on Crabtree Mountain in Mitchell County. The Ray mine in Yancey County has also produced some golden beryl and aquamarine (Brobst 1962). Beryllium-containing minerals are also common in granites and pegmatites throughout the Piedmont region; however, to a much lesser degree than the Blue Ridge Mountains Province (Brobst 1962). Beryllium is concentrated in silicate minerals relative to sulfides and in feldspar minerals relative to ferromagnesium minerals. The greatest known naturally occurring concentrations of beryllium are found in certain pegmatite bodies. Beryllium is not likely to be found in natural water above trace levels due to the insolubility of oxides and hydroxides at the normal pH range (Brobst 1962). Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 51 10.1.5 Boron While boron is relatively abundant on the earth’s surface, boron and boron compounds are relatively rare in all geological provinces of North Carolina. Natural sources of boron in the environment include volatilization from seawater, geothermal vents, and weathering of clay-rich sedimentary rocks. Total contributions from anthropogenic sources are less than contributions from natural sources. Anthropogenic sources of boron include agriculture, refuse, coal and oil burning power plants, by-products of glass manufacturing, and sewage and sludge disposal (EPRI 2005). Boron is usually present in water at low concentrations. Surface waters typically have concentrations of 0.001 to 5 mg/L, with an average concentration of about 0.1 mg/L. Background boron concentrations in groundwater near power plants were compiled from data presented in EPRI technical reports, and ranged from <0.01 to 0.59 mg/L with a median concentration of 0.07 mg/L (EPRI 2005). 10.1.6 Chromium Chromium is a blue-white metal found naturally only in combination with other substances. It occurs in rocks, soil, plants, and volcanic dust and gases (EPRI 2008). Background concentrations of chromium in groundwater generally follow the media in which they occur. Most chromium concentrations in groundwater are low, averaging less than 1.0 µg/L worldwide. Chromium tends to occur in higher concentrations in felsic igneous rocks (such as granite and metagranite) and ultramafic igneous rocks; however, it is not a major component of the igneous or metamorphic rocks found in the North Carolina Piedmont or the Blue Ridge (Chapman 2013). In a statistical summary of groundwater quality in North Carolina, the Superfund Research Program at UNC analyzed 245 private well water samples in Rockingham County. The samples were tested by the North Carolina State Laboratory of Public Health from 1998 to 2012. The study found an average chromium concentration of 5.2 µg/L (range: 0.5 to 40 µg/L). No samples exceeded the 100 µg/L PMCL for chromium (NCDHHS 2010b). 10.1.7 Cobalt The concentration of cobalt in surface and groundwater in the United States is generally low— between 1 and 10 parts of cobalt in 1 billion parts of water (ppb) in populated areas. The concentration may be hundreds or thousands of times higher in areas that are rich in cobalt- containing minerals or in areas near mining or smelting operations. In most drinking water, cobalt levels are less than 1 to 2 ppb (USGS 1973). 10.1.8 Iron Iron is a naturally occurring element that may be present in groundwater from the erosion of natural deposits (NCDHHS 2010a). Iron commonly exceeds state and federal regulatory standards in North Carolina groundwater. According to Harden 2009, iron exceedances occurred in over half of the state’s 10 geozones. The average concentration of iron detected in North Carolina private well water from sampling conducted in 2010 (NCDHHS 2010a) is shown Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 52 on Figure 10-2. A study by the Superfund Research program at UNC found that only 15 of the 100 counties in North Carolina had average concentrations below the SMCL of 300 µg/L. The DRSS site is in an area where the average naturally occurring iron concentrations in groundwater range from 300 to 500 µg/L. A 2015 study by NCDENR (Summary of North Carolina Surface Water Quality Standards 2007- 2014) found that while concentrations vary regionally, “iron occurs naturally at significant concentrations in the groundwaters of NC,” with a statewide average concentration of 1320 µg/L (Table 10-2). 10.1.9 Lead Lead is a heavy, bluish-gray metal that occurs naturally in the earth’s crust. It is rarely found as a pure metal, but is instead typically found with other elements to form lead compounds. Lead is soft and malleable. It combines with other metals to form mixtures called alloys and is commonly found in pipes, weights, firearm ammunition, sheets used to shield humans from radiation, pigments in paint and dye, ceramic glazes, and caulk. The largest use for lead is in vehicle storage batteries (EPRI 2008). Lead is the 34th most abundant element in the earth’s crust, averaging 15 parts per million (ppm). In igneous rocks its concentration ranges from approximately 5 ppm in gabbro to 20 ppm in granite. Typical concentrations in sedimentary rocks range from an average of 7 ppm in sandstone, 9 ppm in carbonates, 20 ppm in shale, to as much as 80 ppm in deep-sea clays (USGS 1973). A variety of lead-bearing igneous, metamorphic, and sedimentary rock units are distributed throughout North Carolina. The Kings Mountain belt once hosted a lead mine, with minerals such as galena, chalcopyrite, and pyrite present in vein quartz throughout the host rock (Horton 1991). A statistical summary of groundwater quality in North Carolina was conducted by the Superfund Research Program at UNC. The study found that four North Carolina counties had average lead concentrations which exceeded the PMCL of 15 µg/L. The North Carolina State Laboratory of Public Health tested 584 private well water samples from Rockingham County from 1998 to 2012. The county was found to have an average groundwater lead concentration of 3.6 µg/L. The PMCL of 15 µg/L was exceeded in 14 samples. 10.1.10 Manganese Manganese is a naturally occurring silvery-gray transition metal that resembles iron, but is more brittle and is not magnetic. It is found in combination with iron, oxygen, sulfur, or chlorine to form manganese compounds. Manganese occurs naturally in soils, saprolite, and bedrock and is thus a natural component of groundwater (EPRI 2008). Manganese concentrations tend to cluster by soil system and geozone throughout North Carolina, as shown on Figure 10-3. The Carolina Slate and Milton geozones have the highest proportions of manganese-exceedances, although six other geozones exceeded the state Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 53 standard as well (Gillespie 2013). Geozones with magmatic-arc rocks and low-grade metamorphic rocks, seen on Figure 10-3 tend to include abundant manganese-bearing mafic minerals and are likely to contribute manganese for subsurface water cycling (Gillespie 2013). These rock types are distributed throughout North Carolina and contribute to spatial variations of manganese concentrations throughout the state. High manganese concentrations are associated with silty soils and sedimentary, unconsolidated, or weathered lithologic units. Low concentrations are associated with non-weathered igneous bedrock and soils with high hydraulic conductivity (Gillespie 2013; Polizzoto 2014). Manganese is most readily released to the groundwater through the weathering of mafic or siliceous rocks (Gillespie 2013). When manganese-bearing minerals in saprolite, such as biotite, are exposed to acidic weathering, the metal can be liberated from the host-mineral and released to groundwater. It can then migrate through pre-existing fractures during the movement of groundwater through bedrock. If this aqueous-phase of manganese is exposed to higher pH in the groundwater system, it will precipitate out of solution. This results in preferential pathways becoming “coated” in manganese oxides and introduces a concentrated source of manganese into groundwater (Gillespie 2013). Manganese(II) in suspension with silt or clay is commonly oxidized by microorganisms present in soil, leading to the precipitation of manganese minerals (USDHHS-ATSDR 2012). Roughly 40-50% of North Carolina’s wells have manganese concentrations higher than the state drinking water standard (Gillespie 2013). Concentrations are spatially variable throughout the state, ranging from less than 0.01 mg/L to more than 2 mg/L. This range of values reflects naturally derived concentrations of the constituent and is largely dependent on the bedrock’s mineralogy and extent of weathering (Gillespie 2013). In a 2015 study by NCDENR (Summary of North Carolina Surface Water Quality Standards 2007-2014) it was found that manganese concentrations vary regionally; however, “manganese occurs naturally at significant concentrations in the groundwater of NC,” with a statewide average concentration of 102 µg/L. The study found the regional variations summarized in Table 10-3. Using the USGS National Uranium Resource Evaluation (NURE) database, all manganese groundwater test results from water supply wells within a 20-mile radius of the DRSS site are shown on Figure 10-4 and also provided in Table 10-4. These results generally represent concentrations found in deeper aquifers below the uppermost surficial aquifer. 10.1.11 Selenium Selenium is a semi-metallic gray metal that commonly occurs naturally combined with rocks and soil. It is common to find trace amounts of selenium in food, drinking water, and air-borne dust. Over geologic time, selenium has been introduced to the earth’s surface and atmosphere through volcanic emissions and igneous extrusions. Weathering and transport partition the element into residual soils, where it is available for plant uptake, or to the aqueous environment, Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 54 where it may remain dissolved, enter the aquatic food chain, or redeposit within a sedimentary rock such as shale (EPRI 2008). Groundwater containing selenium is typically the result of either natural processes or industrial operations. Naturally, selenium’s presence in groundwater is from leaching out of selenium- bearing rocks. It is most common in shale ranging from 0.6 to 103 milligrams per kilogram (mg/kg). Anthropogenically, selenium is released as a function of the discharge from petroleum and metal refineries and from ore mining and processing facilities. Ore mining may enhance the natural erosive process by loosening soil, creating concentrations in erodible tailings piles, and exposing selenium containing rock to runoff (Martens 2002; USEPA 2014). In a statistical summary of groundwater quality in North Carolina, the Superfund Research Program at UNC analyzed 245 private well water samples in Rockingham County. The samples were tested by the North Carolina State Laboratory of Public Health from 1998 to 2012. The study found an average selenium concentration of 2.7 µg/L (range: 2.5 to 26 µg/L). No samples exceeded the 50 µg/L PMCL for selenium (NCDHHS 2010b). 10.1.12 Sulfate Sulfate is a naturally occurring substance found in minerals, soil, and rocks. It is present in ambient air, groundwater, plants, and food. The principal commercial use of sulfate is in the chemical industry. Sulfate is discharged into water in industrial wastes and through atmospheric deposition (USEPA 2003). While sulfate has an SMCL, and no enforceable maximum concentration set by the USEPA, ingestion of water with high concentrations of sulfate may be associated with diarrhea, particularly in susceptible populations, such as infants and transients (USEPA 2012). In the Piedmont and Blue Ridge Aquifers chapter of the USGS Ground Water Atlas of the United States, the groundwater of this region as a whole is described as “generally suitable for drinking… but iron, manganese, and sulfate locally occur in objectionable concentrations” (USGS 1997). The Dan River-Danville, Virginia area (located approximately 22 miles downstream from DRSS) is an early Mesozoic basin, and the Atlas describes aquifers in this area as having average sulfate concentrations of 29 mg/L. However, sulfate concentrations up to 1200 mg/L have been reported from water in deep wells (USGS 1997). 10.1.13 Thallium Pure thallium is a soft, bluish white metal that is widely distributed in trace amounts in the earth's crust. In its pure form, it is odorless and tasteless. It can be found in pure form or mixed with other metals in the form of alloys. It can also be found combined with other substances such as bromine, chlorine, fluorine, and iodine to form salts (EPRI 2008). Traces of thallium naturally exist in rock and soil. As rock and soil erode, small amounts of thallium can occur in groundwater. In a USGS study of trace metals in soils, the variation in thallium concentrations in A (i.e., surface) and C (i.e., substratum) soil horizons was estimated across the United States. The overall thallium concentrations ranged from <0.1 mg/kg to 8.8 Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 55 mg/kg. North Carolina concentrations from this study are depicted on Figure 10-6. Thallium is compared to IMAC since no 2L Standard was established for this constituent by NCDENR. In a study by the Georgia Environmental Protection Division (EPD) of the Blue Ridge Mountain and Piedmont aquifers, 120 testing sites were sampled for various constituents. Thallium was not detected at any of these sites (MRL = 1 µg/L) (Donahue and Kibler 2007). 10.1.14 Vanadium Vanadium is widely distributed in the earth’s crust at an average concentration of 100 ppm (approximately 100 mg/kg), similar to that of zinc and nickel. Vanadium is the 22nd most abundant element in the earth’s crust (EPRI 2008). Occurrence of vanadium in groundwater is known to be limited to its soluble oxidation state, V(V). Vanadium presence is mostly limited to groundwater with relatively high DO concentrations and a basic pH (i.e., pH > 7) (Wright and Belitz 2010; Canadian Council of Ministers of the Environment 1999). In a study by the Georgia EPD, 120 sites in the Blue Ridge and Piedmont physiographic regions (regions shared with North Carolina) were sampled and detectible traces of vanadium were found in six samples (with a reporting limit of 10 µg/L). Only two of these samples were in basic pH groundwater while the rest were sampled in more acidic waters. Using the USGS NURE database, all vanadium groundwater test results from water supply wells within a 20-mile radius of DRSS are shown on Figure 10-7 and provided in Table 10-5. Concentrations near DRSS range from 0.10 to 1.20 µg/L. These results generally represent concentrations found in deeper aquifers below the uppermost surficial aquifer. 10.1.15 pH The pH scale is used to measure acidity or alkalinity. A pH value of 7 indicates neutral water. A value lower than the USEPA-established SMCL range (<6.5 Standard Units) is associated with bitter, metallic tasting water and corrosion. A value higher than the SMCL range (>8.5 Standard Units) is associated with a slippery feel, soda taste, and deposits in the water (USEPA 2013). In a statistical summary of groundwater quality in North Carolina, the Superfund Research Program at UNC analyzed 577 private well water samples for pH in Rockingham County. The samples were analyzed by the North Carolina State Laboratory of Public Health from 1998 to 2012. The study found an average pH of 7, with values ranging from 4.6 to 9.2. A total of 100 samples (17.3% of all samples) fell outside the USEPA’s PMCL range of 6.5-8.5 for pH (NCDHHS 2010a). Using the USGS NURE database, all pH groundwater test results from water supply wells within a 20-mile radius of DRSS are shown on Figure 10-5. These results generally represent concentrations found in deeper aquifers below the uppermost surficial aquifer. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 56 10.2 Background Wells BG boring locations were identified based on the SCM at the time the Work Plan was submitted. The BG locations were chosen in areas assumed not to be impacted by and topographically upgradient of the ash basin and ash storage areas. Based on the developed groundwater elevation contours (Figures 6-5 through 6-7) and the updated SCM, the BG locations are considered to be hydraulically upgradient of the ash basin and ash storage areas. The BG boring locations are considered to be representative of background groundwater quality conditions at the site. Background monitoring wells include one existing groundwater monitoring well (MW -23D) and four newly installed groundwater monitoring wells (MW -23BR, BG-1D, and BG-5S/D) located near the western property boundary. Background groundwater monitoring wells are depicted on Figure 10-8. Well construction details are summarized in Tables 10-6 and 10-7. A generalized well construction diagram for newly installed wells is shown on Figure 10-9. Well installation procedures are documented in Appendix G, along with variances from the Work Plan. Boring logs are provided in Appendix H. Background monitoring well MW -23D was previously installed in 2010 as a compliance monitoring well to evaluate background water quality at the site. MW -23D was installed to a depth of 20.11 feet bgs and screened from 10.11 to 20.11 feet bgs. Groundwater flow in the vicinity of MW -23D is to the west-southwest toward an unnamed tributary that flows south into the service water settling pond and ultimately to the Dan River. Historical groundwater data for MW -23D dates back to January 2011. The compliance monitoring wells are sampled three times per year (January, May, and September) and 15 sampling events have been conducted to date. This is considered sufficient data to adequately perform statistical analysis of background concentrations in well MW-23D (Appendix G). Duke Energy recognizes that the NCDENR DWR Director is responsible for establishing site-specific background levels for groundwater as stated in 15A NCAC 02L .0202(a)(3). The concentrations in the statistical report are provided as information to aid in this determination, and for comparative purposes for groundwater at the site. Newly installed background monitoring well MW -23BR was installed to evaluate background water quality within the bedrock in close proximity to MW -23D. Well MW -23BR was installed to 61.0 feet bgs and screened from 56.0 to 61.0 feet bgs. Groundwater flow in the vicinity of MW - 23BR is similar to well MW-23D, as described above. Currently, insufficient data are available to statistically evaluate background concentrations in well MW -23BR. As data become available through periodic monitoring, statistical analysis will be performed. Background monitoring wells BG-1D, BG-5D, and BG-5S were installed to evaluate background water quality in the TZ and regolith. BG-1D was installed to 14.0 feet bgs and screened from 9.0 to 14.0 feet bgs, BG-5D was installed to 33.0 feet bgs and screened from 28.0 to 33.0 feet bgs, and BG-5S was installed to 20.5 feet bgs and screened from 10.5 to 20.5 feet bgs. A shallow groundwater monitoring well could not be installed at the proposed BG-1S location because Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 57 shallow bedrock was encountered at approximately 7 feet bgs and no groundwater was encountered in the boring. Based on review of available information, additional bedrock background wells are recommended to enhance understanding of background conditions in bedrock beneath the site. The number of shallow and deep background wells located within the property boundary of the site is adequate for monitoring background groundwater quality. The background wells are located hydraulically upgradient and were strategically placed to maximize physical separation from the ash basin and ash storage areas. Time series plots, time history plots, and stacked time series plots are depicted on Figure 10-10 through Figure 10-57. 10.3 Discussion of Redox Conditions Determination of the reduction/oxidation (redox) condition of groundwater is an important component of groundwater assessments, and helps to understand the mobility, degradation, and solubility of contaminants. By applying the framework of the Excel Workbook for Identifying Redox Processes in Ground Water (Jurgens, McMahon, Chapelle, and Eberts 2009) to the analytical results in the following sections, the predominant redox process, or category, to samples collected during the groundwater assessment was assigned. Categories include oxic, suboxic, anoxic, and mixed. Assignment of redox category was based upon concentrations of DO, nitrate as nitrogen, manganese (II), iron (II), sulfate, and sulfide as inputs. Constituent criteria appropriate for inputs to the Excel Workbook, as well as an explanation of the redox assignments, can be found in Tables 1 and 2, respectively, of the USGS Open File Report 2009-1004 (Jurgens, McMahon, Chapelle, and Eberts 2009). Redox assignment results are presented in Table 10-8. 10.4 Groundwater Analytical Results A total of 61 groundwater monitoring wells were installed at DRSS between March and June 2015 as part of the groundwater assessment program. Groundwater monitoring well locations are shown on Figure 10-8. Monitoring well information is provided in Table 10-6 and 10-7. Monitoring wells were installed in general accordance with procedures described in the Work Plan and a detailed description is provided in Appendix H. Boring logs are also provided in Appendix H. Groundwater monitoring wells were developed prior to sampling activities in general accordance with well development procedures detailed in Appendix G. Also included in Appendix G are the groundwater sampling procedures and variances from the Work Plan. Groundwater sample results are compared to 2L Standards or IMACs. Background groundwater sample field parameters and laboratory results for totals and dissolved constituents are summarized in Table 10-9. Ash basin groundwater results are provided in Table 10-10. Groundwater sample laboratory results for totals and dissolved constituents are summarized in Table 10-11. Groundwater sampling results relative to 2L Standards and IMACs are depicted on Figure 10- Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 58 63. Field and sampling quality control / quality assurance protocols are provided in Appendix E. Variances from the proposed sampling plans are presented in Appendix H. 10.4.1 Ash Basin: Primary and Secondary Cells A total of 17 groundwater monitoring wells (five shallow, four deep and eight bedrock) were installed within the footprint of the Primary and Secondary Cells and associated dams. These borings include the following: AB-5S/D, AB-10S/SL/D, AB-25S/D/BR, AB-30S/D/BR, AB-35BR, MW -308BR, MW -310BR, MW -311BR, MW -314BR and MW-22BR. These groundwater monitoring wells were installed to evaluate groundwater quality within and beneath the active ash basin. Ten existing groundwater monitoring wells located within the ash basin system and associated dams were sampled to supplement groundwater quality data for this groundwater assessment. These wells include the following: MW -9, MW -9D, MW-10, MW -10D, MW -11, MW-11D, MW- 22S/D, OW -308D, and OW-310D. 10.4.2 Ash Storage Areas A total of 12 groundwater monitoring wells (one shallow, six deep and five bedrock) were installed within the footprint of Ash Storage 1 and 2 waste boundaries. These monitoring wells include the following: AS-2D, AS-4D, AS-6D, AS-8D/BR, AS-10D, AS-12S, MW -301BR, MW- 303BR, MW -306BR, MW-315BR, and MW -318BR. The groundwater monitoring wells associated with the ash storage areas were installed to evaluate the potential impact of the ash storage areas on groundwater quality. Due to difficulties during drilling activities, the proposed AS-12D was not installed; however, a shallow groundwater monitoring well AS-12S was installed at this location as detailed in the variance table included in Appendix G. 10.4.3 Beyond the Waste Boundary A total of 24 groundwater monitoring wells (eleven shallow, eleven deep, and two bedrock) were installed outside the waste boundary of the ash basin and ash storage areas. These monitoring wells include the following: GWA-1S/D, GWA-2S/D, GWA-3S/D, GWA-4S/D, GWA-5BR, GWA- 6S/D, GWA-7S/D, GWA-8S/D, GWA-9S/D, GWA-10S/D, GWA-11S/D, GWA-12S/D, and MW- 317BR. The groundwater monitoring wells located outside the waste boundaries were installed to evaluate the potential impact of the ash basin and ash storage areas on groundwater quality. GWA-10S was dry at the time of sampling, and was unable to be sampled. A total of four existing groundwater monitoring wells are being sampled to supplement groundwater quality data for this groundwater assessment. These wells include the following: MW -20S/D and MW -21S/D. 10.4.4 Off-Site A total of three groundwater monitoring wells (one shallow and two deep) were installed off-site immediately adjacent to the eastern property boundary of the site. The groundwater monitoring wells located off-site were installed to assess potential impact from site activities on Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 59 groundwater quality on the adjacent property downgradient of the ash basin and ash storage areas. These wells include the following: GWA-14S/D and GWA-15D. A shallow groundwater monitoring well as unable to be installed at GWA-15S because groundwater was not encountered above shallow bedrock. GWA-14S was dry at time of sampling, and was unable to be sampled. 10.5 Comparison of Results to 2L Standards Groundwater results were compared to 2L Standards or IMACs and exceedances are summarized below. Table 10-12 presents groundwater results with exceedances of 2L Standards and Figure 10-63 depicts groundwater sample exceedances of 2L Standards or IMACs. 10.6 Comparison of Results to Background 10.6.1 Background With the exception of cobalt, iron, lead, manganese, thallium, TDS, and vanadium, the results for all other COIs were reported to be less than their respective 2L Standards or IMACs. The background concentration range for constituents that are considered COIs at the DRSS site are provided below:  Antimony – <0.5 µg/L to 1.21 µg/L  Arsenic – <0.5 µg/L to 6.36 µg/L  Beryllium – 0.087 µg/L to <0.2 µg/L  Boron – <50.0 µg/L  Chromium – 0.22 µg/L to 1.2 µg/L  Cobalt – 1 µg/L to 2.1 µg/L  Iron – 110 µg/L to 890 µg/L  Lead – 0.057 µg/L to 0.078 µg/L  Manganese – 110 µg/L to 910 µg/L  pH – 6.2 µg/L to 7.45 µg/L  Selenium – <0.5 µg/L  Sulfate – 29,800 µg/L to 41,300 µg/L  Thallium – < 0.1 µg/L to 0.019 µg/L  TDS – 175,000 µg/L to 252,000 µg/L  Vanadium – <1.0 µg/L to 2.6 µg/L Please refer to Section 10.1 for a comparison of the above-referenced site-specific constituent concentrations to regional groundwater constituent concentrations. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 60 10.6.2 Ash Basin: Primary and Secondary Cells With the exception of antimony, arsenic, boron, chromium, cobalt, iron, lead, manganese, pH, thallium, TDS, and vanadium, the results for all other COIs were reported less than the 2L or IMAC Standards. The range of constituent concentrations along with a comparison to the range of reported background groundwater concentrations is provided in Table 10-13. Constituent concentrations of groundwater beneath the ash basin tend to be higher for antimony, arsenic, boron, chromium, cobalt, iron, lead, manganese, thallium, TDS and vanadium compared to background groundwater concentrations. 10.6.3 Ash Storage Areas With the exception of antimony, arsenic, boron, chromium, cobalt, iron, lead, manganese, pH, thallium, TDS, and vanadium, the results for all other COIs were reported less than the 2L Standards or IMACs. The range of constituent concentrations along with a comparison to the range of reported background groundwater concentrations is provided in Table 10-14. Constituent concentrations of groundwater beneath the ash storage areas tend to be higher for antimony, boron, chromium, cobalt, iron, manganese, selenium, TDS and vanadium compared to background groundwater concentrations. 10.6.4 Beyond the Waste Boundary With the exception of antimony, beryllium, chromium, cobalt, iron, manganese, pH, sulfate, thallium, TDS, and vanadium the results for all other COIs were reported less than the 2L Standards or IMACs. The range of constituent concentrations along with a comparison to the range of reported background surface water concentrations is provided in Table 10-15. Constituent concentrations of groundwater beyond the waste boundary tend to be higher for antimony, beryllium, chromium, cobalt, sulfate, and vanadium compared to background surface water concentrations. Concentrations for iron, manganese, thallium, and TDS are similar to or lower than background groundwater concentrations. 10.6.5 Off-Site With the exception of iron, manganese, sulfate, TDS, and vanadium, the results for all other COIs were reported less than the 2L Standards or IMACs. The range of constituent concentrations along with a comparison to the range of reported background groundwater concentrations is provided in Table 10-16. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 61 Constituent concentrations of groundwater off-site tend to be higher for sulfate and TDS compared to background groundwater concentrations. Concentrations for iron, manganese, and vanadium are similar to or lower than background surface water concentrations. Groundwater isoconcentration contours with respect to each COI are depicted on Figures 10-64 through 10-102. Cross-sections are presented on Figure 6-2. Cross-sections presenting horizontal and vertical distribution of COIs along the transect are depicted on Figures 10-103 through 10-106. COIs with exceedances of 2L Standards or IMACs will be modeled in the CAP. The USEPA recommends that when possible, especially when sampling for constituents that may be biased by the presence of turbidity, the turbidity values in the stabilized well should be less than 10 Nephelometric Turbidity Units (NTUs) (USEPA 2002). 10.7 Groundwater Geochemistry There are two types of ions: cations (positively charged ions) and anions (negatively charged ions). Cations and anions are used in hydrogeological investigations to assess naturally occurring ions in groundwater. There are eight ions commonly used to evaluate groundwater: four cations (calcium, magnesium, sodium, and potassium) and four anions (chloride, sulfate, carbonate, and bicarbonate). The geochemical composition of groundwater aids in aquifer characterization, and piper diagrams are used to graphically depict geochemistry of groundwater samples collected at a particular site. Cation and anion concentrations at the DRSS site from upgradient groundwater monitoring wells and ash basin groundwater monitoring wells are compared on Figures 10-107 through 10- 113. In general, calcium, chloride, magnesium, sodium, and sulfate are elevated, but calcium and sulfate are three to four orders of magnitude higher in ash basin groundwater monitoring wells compared to the upgradient monitoring wells. Sulfate/chloride ratio in ash basin, seep, and background monitoring wells, as well as shallow, deep, and bedrock wells, are provided in Figures 10-114 through 120. Piper diagrams were generated for the DRSS site to compare the geochemistry between ash basin porewater, surface water, seeps, upgradient and downgradient groundwater monitoring wells and background groundwater monitoring wells. In general, geochemistry of groundwater and surface water at the DRSS site is predominantly rich in calcium, magnesium, and bicarbonate with the exception of downgradient groundwater monitoring wells, which trend closer to a calcium-, magnesium- and sulfate-rich geochemical composition. Piper diagrams are included as Figures 10-121 through 10-124. 10.8 Groundwater Speciation Speciation is the analysis of the composition of a particular analyte in a system. Speciation is important for understanding the fate and transport of COIs. Fourteen locations, AB-10D, AB- 25D, AB-30S/D, AB-35BR, AS-4D, AS-8D, OW-308D, OW310D, GWA-10D, MW -21S/D, MW- 22S, and MW -23D, were sampled for chemical speciation analyses of arsenic (III), arsenic (V), chromium (VI), iron (II), iron (III), manganese (II), manganese (IV), selenium (IV), and selenium Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 62 (VI). Results for chemical speciation of surface water are presented in Table 10-17. Further evaluation of chemical speciation results will be included in the CAP. 10.9 Radiological Laboratory Testing Radionuclides may exist dissolved in water from natural sources (e.g. soil or rock). The USEPA regulates various radionuclides in drinking water. For purposes of this assessment, radium-226, radium-228, natural uranium, uranium-233, uranium-234, and uranium-236 were analyzed. Three locations, AB-10D, AB-25D/BR, MW-11, MW-11D, and BG-5S/D, were sampled for the analytes listed above. Results for radiological laboratory testing are presented in Table 10-18. Further evaluation of radiological laboratory testing results will be included in the CAP. 10.10 CCR Rule Groundwater Detection and Assessment Monitoring Parameters Appendix III to Part 257 Constituents for Detection Monitoring and Appendix IV to Part 257 Constituents for Assessment Monitoring On April 17, 2015, the USEPA published its final rule “Disposal of Coal Combustion Residuals from Electric Utilities” (Final Rule) to regulate the disposal of CCR as solid waste under subtitle D of the Resource Conservation and Recovery Act (RCRA). Among other requirements, the Final Rule establishes requirements for a groundwater monitoring program consisting of detection monitoring and, if necessary, assessment monitoring and corrective action. USEPA selected constituents to be used in the groundwater detection monitoring program as indicators of groundwater contamination from CCR. USEPA selected constituents for detection monitoring that are present in CCR, would be expected to migrate rapidly, and that would provide early detection as to whether contaminants were migrating from the disposal unit (80 FR 74: 21397). As stated in the FR (80 FR 74: 21342): These detection monitoring constituents or inorganic indicator parameters are: boron, calcium, chloride, fluoride, pH, sulfate and total dissolved solids (TDS). These inorganic indicator parameters are known to be leading indicators of releases of contaminants associated with CCR and the Agency strongly recommends that State Directors add these constituents to the list of indicator parameters to be monitored during detection monitoring of groundwater if and when a MSWLF decides to accept CCR. (Emphasis added) NCDENR requested that figures be included in the CSA report that depict groundwater analytical results for the constituents in 40 CFR 257, Appendix III detection monitoring and 40 CFR 257, Appendix IV assessment monitoring. Constituents for detection monitoring listed in 40 CFR 257 Appendix III are: Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 10.0 GROUNDWATER CHARACTERIZATION 63  Boron  Calcium  Chloride  Fluoride (this constituent was not analyzed for in the CSA)  pH  Sulfate  TDS The analytical results for the detection monitoring constituents are found on Figures 10-125 through 10-127. Constituents for assessment monitoring listed in 40 CFR 257 Appendix IV include:  Antimony  Arsenic  Barium  Beryllium  Cadmium  Chromium  Cobalt  Fluoride (not analyzed for the CSA)  Lead  Lithium (not analyzed for the CSA)  Mercury  Molybdenum  Selenium  Thallium  Radium 226 and 228 combined The analytical results for the assessment monitoring constituents are found on Figures 10-128 through 10-130. Aluminum, copper, iron, manganese, and sulfide were included in the Appendix IV constituents in the draft rule; USEPA removed these constituents in the Final Rule. Therefore, these constituents are not included on the above-referenced figures. In addition, NCDENR requested that vanadium be included on these figures. Exceedances of the relevant regulatory standards of the constituents listed above including vanadium are presented in Figure 10-63. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 11.0 HYDROGEOLOGICAL INVESTIGATION 64 11.0 Hydrogeological Investigation The purpose of the hydrogeological investigation is to characterize site hydrogeological conditions including groundwater flow direction, hydraulic gradient and conductivity, groundwater and contaminant velocity, and slug and aquifer test results. The hydrogeological investigation was performed in general accordance with the procedures described in the Work Plan. Refer to Appendix H for a description of these methods. 11.1 Hydrostratigraphic Layer Development The following materials were encountered during the site exploration and are consistent with material descriptions from previous site exploration studies:  Ash – Ash was encountered in borings advanced within the ash basin and ash storage areas, as well as in some borings advanced through the pond perimeter and intermediate dam. Ash several inches thick was encountered in one location within the ash dredge area located between Ash Storage 1 and Ash Storage 2. Ash was generally described as gray to dark bluish gray with a silty to sandy texture, consistent with fly ash and bottom ash.  Fill – Fill material generally consisted of re-worked materials from the DRSS site. The base of filled areas was difficult to distinguish from in-place soil/saprolite.  Alluvium – Alluvium is unconsolidated soil and sediment that has been eroded and redeposited by streams and rivers.  Residuum (Residual Soils) – Residuum is the in-place soil that develops by weathering.  Saprolite/Weathered Rock – Saprolite is soil developed by in-place weathering of rock.  Partially Weathered/Fractured Rock – Partially weathered (slight to moderate) and/or highly fractured rock was encountered below refusal (auger, casing advancer, etc.).  Bedrock – Sound rock in boreholes, generally slightly weathered to fresh and relatively unfractured. Based on the site investigation, the groundwater system in the natural materials (alluvium, soil, soil/saprolite, and bedrock) at DRSS is consistent with the regolith-fractured rock system and is an unconfined, connected aquifer system without confining layers as discussed in Section 5.2. The Dan River groundwater system is divided into two layers referred to in this report as the shallow aquifer and bedrock aquifer to distinguish flow layers within t he connected aquifer system. The classification system of Schaeffer (2014a) was used to show that the TZ is present in the Piedmont groundwater system (discussed in Section 5.2), and was modified to define the hydrostratigraphic layers of the natural groundwater system. The classification system is based on Standard Penetration Testing values (N) and the Recovery (REC) and Rock Quality Designation (RQD) collected during the drilling and logging of the boreholes (Borehole/Well logs in Appendix H). The ash, fill, and alluvial layers are as encountered at the site. The natural system (except alluvium) includes the following layers: Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 11.0 HYDROGEOLOGICAL INVESTIGATION 65  M1 – Soil/Saprolite: N<50  M2 – Saprolite/Weathered Rock: N>50 or REC<50%  TZ – Transition Zone: REC>50% and RQD<50%  BR – Bedrock: REC>85% and RQD>50%. Rock core runs that fell between the values for TZ and BR (REC<85% and RQD>50% or REC>85% and RQD<50%) were assigned a hydrostratigraphic layer based on a review of the borehole logs, rock core photographs, and geologic judgment. The same review was performed in making the final determination of the thickness of the TZ as it could extend into a run that meets the BR criterion because of the potential 15% core loss in that run. The above layer designations (M1, M2, TZ, and BR) are used on the geologic cross-sections shown on Figure 11-1 and presented Figures 11-2 to 11-5 and in the data tables and hydrostratigraphic layer parameter tables presented in this section. The ash, fill and alluvial layers are represented by A, F, and S, respectively, on the cross-sections and tables. Groundwater analytical results are presented on Figure 11-6. 11.2 Hydrostratigraphic Layer Properties The material properties required for the groundwater flow and transport model (total porosity, effective porosity, specific yield and specific storage) for ash, fill, alluvium, and soil/saprolite were developed from laboratory testing. Table 11-1 presents the laboratory test data (test reports in Appendix H) and published data (Domenico and Mifflin 1965). Table 11-1 has a column labeled ‘Estimated Specific Yield/Effective Porosity’ estimated from the laboratory soil data (grain size analysis) utilizing Fetter-Bear diagrams (worksheets in Appendix H), as described by Johnson (1967). This technique provides a simple method to estimate specific yield; however, there are limitations to the method that may not provide an accurate determination of the specific yield of a single sample (Robson 1993). Specific yield/effective porosity were determined for a number of samples of the A, F, S, M1, and M2 layers to provide an average and range of expected values. Hydraulic conductivity (horizontal and vertical) of all layers except TZ and BR were developed utilizing the data collected during this investigation and historic data. The hydraulic conductivity of the hydrostratigraphic layers were determined by in-situ permeability testing (falling head, constant head, and packer testing where appropriate); slug tests in completed monitoring wells; and laboratory testing of undisturbed samples (ash, fill, soil/saprolite; test results in Appendix H). The effective porosity (primarily fracture porosity) and specific storage of the TZ and bedrock were estimated from published data (Sanders 1998; Domenico and Mifflin 1965). 11.2.1 Borehole In-Situ Tests In-situ horizontal (open hole) and vertical (flush bottom) permeability tests, either falling or constant head as appropriate for field conditions, were performed in each of the hydrostratigraphic units above refusal, ash, fill, alluvium, and soil/saprolite. In-situ borehole horizontal permeability tests, either falling or constant head tests as appropriate for field Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 11.0 HYDROGEOLOGICAL INVESTIGATION 66 conditions, were performed just below refusal in the first 5 feet of a rock cored borehole (TZ if present). The flush bottom test involves advancing the borehole through the overburden with a casing advancer until the test interval is reached. The cutting tool is removed from the casing and the casing is filled with water to the top and the drop of the water level in the casing is measured over a period of 60 minutes. In the open hole test, after the top of the test interval is reached, the cutting tool (but not the casing) is advanced an additional number of feet (5 feet in the majority of tests) and drop of the water level in the casing is measured over a period of 60 minutes. The constant head test is similar except the water level is kept at a constant level in the casing and the water flow-in is measured over a period of 60 minutes. The constant head test was only used when the water level in the borehole was dropping too quickly back to the static water level such that the time interval was insufficient to calculate the hydraulic conductivity. The results from the field permeability testing are summarized in Table 11-2 and the worksheets provided in Appendix H. Packer tests (shut-in and pressure tests) were conducted in a minimum of five boreholes. The shut-in test is performed by isolating the zone between the packers (in effect, a piezometer) and measuring the resulting water level over time until the water level is stable. The shut-in test provides an estimate of the vertical gradient during the test interval. The pressure test involves forcing water under pressure into rock through the walls of the borehole providing a means of determining the apparent horizontal hydraulic conductivity of the bedrock. Each interval is tested at three pressures with three steps of 20 minutes up and two steps of 5 minutes back down. The pressure test results are summarized in Table 11-2 and the shut-in and packer tests worksheets are provided in Appendix H. Where possible, tests were conducted at borehole locations specified in the Work Plan and at test intervals based on site-specific conditions at the time of the groundwater assessment work. The U.S. Bureau of Reclamation (1995) test method and calculation procedures, as described in Chapter 10 of their Ground Water Manual (2nd Edition), were used for the field permeability and packer tests. 11.2.2 Monitoring Well and Observation Well Slug Tests Hydraulic conductivity (slug) tests were completed in monitoring wells and observation wells under the direction of the Lead Geologist/Engineer. Slug tests were performed to meet the requirements of the May 31, 2007 NCDENR Memorandum titled, Performance and Analysis of Aquifer Slug Tests and Pumping Tests Policy. Water level change during the slug tests was recorded by a data logger. The slug test was performed for no less than 10 minutes, or until such time as the water level in the test well recovered 95 percent of its original pre-test level, whichever occurred first. Slug tests were terminated after 60 minutes, even if the 95 percent pre-test level was not achieved. Slug test field data was analyzed using the Aqtesolv (or similar) software and the Bouwer and Rice method. The slug test results are presented in Table 11-3 and the Slug Test Report is provided in Appendix H. Historic slug test data is presented in Table 11-4. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 11.0 HYDROGEOLOGICAL INVESTIGATION 67 11.2.3 Laboratory Permeability Tests Laboratory permeability tests were conducted on undisturbed samples (Shelby Tubes) of ash, fill, soil, and saprolite collected during the field investigation. The tests were performed in accordance with ASTM D 5084 (ASTM 2010). The results of the laboratory permeability tests are presented in Table 11-5. 11.2.4 Hydrostratigraphic Layer Parameters The soil material parameters for the A (ash), F (fill), S (alluvium), M1 (soil/saprolite), and M2 (saprolite/weathered rock) were developed by grouping the data into their respective hydrostratigraphic units and calculating the mean, median, and standard deviation of the different parameters. Values for specific storage are based on published data (Domenico and Mifflin 1965). The values are presented in Tables 11-6 and 11-7. The hydraulic conductivity parameters were developed by grouping the data into their respective hydrostratigraphic units and calculating the geometric mean, median, and standard deviation of the different parameters. Vertical hydraulic conductivity values are not available for the TZ and BR units, but are unlikely to be equal. As an initial assumption, vertical hydraulic conductivity can be considered to be equal to the horizontal hydraulic conductivity and adjusted as necessary during flow modeling. Horizontal and vertical hydraulic conductivity parameters are presented Tables 11-8 and 11-9, respectively. The values of secondary (effective) porosity and specific retention for the TZ and BR units are based on published values (Sanders 1998; Domenico and Mifflin 1965). The values are presented in Table 11-10. Further development of the above parameters and others required for the flow and contaminant transport model will be provided in the CAP. 11.3 Vertical Hydraulic Gradients Horizontal hydraulic gradient is calculated by taking the difference in hydraulic head over the distance between two wells with similar well construction. Section 6.2.2 provides additional details for horizontal hydraulic gradients calculated for the site. Vertical hydraulic gradient was calculated by taking the difference in groundwater elevation in a deep and shallow well pair over the difference in total well depth of the deep and shallow well pair. A positive output indicates upward flow and a negative output indicates downward flow. Sixteen well pair locations, each consisting of a shallow and deep groundwater monitoring well, were used to calculate vertical hydraulic gradient across the site. Based on review of the results, vertical gradient of groundwater is generally downward across the site. Vertical gradient calculations are summarized in Table 11-11. 11.4 Groundwater Velocity Average groundwater velocity was calculated using Darcy’s Law. Darcy’s Law is a derived equation that describes the flow of fluid through a porous media. The following equation was used to calculate groundwater velocities through each hydrostratigraphic unit present at the site: Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 11.0 HYDROGEOLOGICAL INVESTIGATION 68 v = Ki n where v is velocity; K is horizontal hydraulic conductivity; i is horizontal hydraulic gradient; and n is the effective porosity Average groundwater velocities were calculated using horizontal hydraulic gradients established in Section 6.2.2, horizontal hydraulic conductivity values for each hydrostratigraphic unit established in Table 11-8, and effective porosity values established in Tables 11-9 and 11-10. Hydrostratigraphic layers are defined in Section 11.1. Average groundwater velocity results are summarized in Table 11-12. Figures 11-7 and 11-8 show groundwater velocity ranges for hydrostratigraphic units typically present at the site in the shallow aquifer. Figure 11-9 shows groundwater velocity ranges in bedrock at the site in the deep aquifer. 11.5 Contaminant Velocity Contaminant velocity will be provided in the CAP. 11.6 Plume's Physical and Chemical Characterization Plume physical and chemical characterization is detailed below for each COI detected in groundwater samples collected at the DRSS site based on review of isoconcentration maps (Figures 10-64 through 10-102) and cross sections (Figures 10-103 through 10-106). Total results were utilized in evaluation of plume physical and chemical characteristics and are based on one round of comprehensive groundwater sampling of the newly installed groundwater monitoring wells installed as part of this assessment, in which some constituents may be potentially influenced by turbidity. For the purposes of this discussion, the shallow aquifer includes the analytical results reported in the shallow (S) and deep (D) wells, and the deep aquifer includes the analytical results reported in the bedrock (BR) wells.  Antimony – Antimony was not dected in the shallow aquifer above the laboratory RL. Exceedances in D wells were restricted to areas north of Ash Storage 1 and along the downgradient extent of the ash basin. Antominy was detected above the IMAC Standard in background bedrock wells MW -23BR, MW -317BR, and AB-25BR.  Arsenic – In general, concentrations of arsenic in the shallow aquifer were localized in the ash storage areas and ash basin, and the concentration varied within those areas. The only concentration of arsenic detected above 2L Standards in the deep aquifer was isolated to AB-35BR, located within the Secondary Cell of the ash basin.  Boron – Concentrations of boron in the shallow aquif er were highest in Ash Storage 2 and decreased with groundwater flow toward the downgradient side of the Primary Cell of the ash basin. Concentrations of boron above 2L Standards in the deep aquifer were isolated to MW -306BR in Ash Storage 1 and decreased with groundwater flow direction.  Chromium – Concentrations of chromium above 2L Standards in the shallow aquifer were detected around the perimeter of Ash Storage 1. Concentrations of chromium in Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 11.0 HYDROGEOLOGICAL INVESTIGATION 69 the deep aquifer were localized in Ash Storage 2 and increased with groundwater flow toward the downgradient side of the Primary Cell of the ash basin.  Cobalt – Concentrations of cobalt above 2L Standards varied in the shallow aquifer and were widespread across the site. Concentrations of cobalt above IMAC Standards in the deep aquifer were isolated to the MW -315BR in Ash Storage 2.  Iron – Concentrations of iron above 2L Standards varied in both the shallow and deep aquifer, and were widespread across the site.  Manganese – Concentrations of manganese above 2L Standards varied in both the shallow and deep aquifer, and were widespread across the site.  Selenium – Concentrations of selenium above 2L Standards were isolated in the shallow aquifer at AS-10D.  pH – values of pH outside the 2L standards range vary in both the shallow and deep aquifer and are wide spread across the site.  Sulfate – Concentrations of sulfate above 2L standards in the shallow aquifer were isolated to GWA-8D and MW -21D, located immediately downgradient of the Secondary Cell of the ash basin. The concentrations above 2L Standards of sulfate in the deep aquifer were isolated to MW-308R and GWA-5BR, located within the Secondary Cell of the ash basin and immediately downgradient.  TDS – Concentrations of TDS above 2L Standards followed the same pattern as sulfate concentrations for the shallow aquifer. In the deep aquifer, concentrations of TDS were localized within Ash Storage 1 and the Secondary Cell of the ash basin. TDS concentrations increased in the direction of groundwater flow.  Thallium – Concentrations of thallium above IMAC Standards in the shallow aquifer were localized in Ash Storage 2 and decreased with groundwater flow direction. An isolated concentration was detected at GWA-6D, located immediately downgradient of the Primary Cell in the ash basin. Thallium concentrations above IMAC Standards in the deep aquifer were isolated to background well MW -23BR, located near the western-most property boundary.  Vanadium – Concentrations of vanadium varied in both the shallow and deep aquifer, and were widespread across the site. 11.6.1 Shallow Aquifer Arsenic and boron were the primary constituents detected in groundwater at concentrations that exceeded background concentrations and 2L Standards. Both constituents were detected above 2L Standards in a three-dimensional area beneath the ash basin and ash storage areas in the surficial aquifer. There are no known exceedances of 2L Standards for arsenic or boron beyond the DRSS property boundary. TDS and sulfate exceeded the 2L Standards in an isolated area east of the DRSS historical site property boundary. Based on the relatively low concentrations of other ash-related constituents in these wells, the presence of TDS and sulfate may not be attributable to groundwater migration from the ash basin. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 11.0 HYDROGEOLOGICAL INVESTIGATION 70 The horizontal migration of boron in the surficial aquifer best represents the dominant flow and transport system at the DRSS site. Vertical migration of constituents is generally limited by underlying bedrock. 11.6.2 Bedrock Aquifer Within the bedrock aquifer, three COIs were identified as primary constituents in the groundwater: iron, manganese, and vanadium. These constituents were identified as naturally occurring metals in the background wells. Nine other COIs were identified in the bedrock aquifer: antimony, arsenic, boron, chromium, cobalt, selenium, sulfate, TDS, and thallium. These constituents were detected in isolated locations and do not appear to have migrated extensively across the DRSS site or beyond the compliance boundary. 11.7 Groundwater / Surface Water Interaction As discussed in Section 5.2, shallow and deep groundwater flow typically follows the topographic gradient and shallow groundwater generally discharges to nearby surface water bodies (i.e., streams). Groundwater/surface water interaction is evident at the DRSS site based on review of COIs present in groundwater and surface water samples. Monitoring well MW -21S exceeded the 2L Standard for arsenic and SW-3, located downgradient of MW -21S, also exceeded the 2B Standard for arsenic. Both MW -21S and SW-3 are located downgradient of the Secondary Cell. This suggests groundwater/surface water interaction at the DRSS site, which indicates migration of COIs from the ash basin to groundwater and ultimately to surface water at the site. 11.8 Estimated Seasonal High and Seasonal Low Groundwater Elevations – Compliance and Voluntary Wells Estimated Seasonal High (ESH) and Estimated Seasonal Low (ESL) groundwater elevations were calculated using historical groundwater elevations for select compliance and voluntary wells at the site. The calculated ESH and ESH depth to water (DTW) was performed statistically by multiplying the standard deviation of the historical DTW measurements by a factor of 1.2 and then adding to the mean DTW measurement. To obtain the site modification factors for ESL and ESH conditions, the calculated ESH and ESL DTW in the historical site wells were compared to the current groundwater levels on site and the difference was calculated. The difference between ESH and ESL DTW and current conditions was then averaged for the representative site wells to create a modification factor to add to current DTW . MW -20S and MW -21S were selected as the most representative shallow wells for natural seasonal fluctuations at the DRSS site, as they are located outside of the ash basin embankments and are, therefore, less likely to be influenced by the water level in the ash basin. Appendix H summarizes calculated ESH and ESL groundwater elevations for newly installed groundwater monitoring wells. This page is intentionally left blank. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 12.0 SCREENING-LEVEL RISK ASSESSMENT 71 12.0 Screening Level Risk Assessment A screening-level evaluation of potential risks to human health and the environment to identify preliminary, media-specific Contaminants of Potential Concern (COPCs) that may adversely impact human and/or ecological receptors under site-specific exposure scenarios was performed in accordance with applicable federal and state guidance, including the Guidelines for Performing Screening Level Ecological Risk Assessments within the North Carolina Division of Waste Management (NCDENR 2003). These serve as the foundation for evaluating potential risks to human and ecological receptors. In this assessment, the maximum concentrations detected for all COIs (or other appropriate data point, such as the analytical reporting limit [RL]) in the 2015 sampling and analyses for coal ash detection and assessment monitoring analytes were compared against established and conservative human health and ecological screening toxicity reference values, likely to be protective for even the most sensitive types of receptors. These comparisons were used to determine which COIs present a potentially unacceptable risk to human and/or ecological receptors and may warrant further evaluation. Those COIs determined to pose a potential for adverse impacts were identified as preliminary COPCs. Other factors that were considered qualitatively in the evaluation of final COPCs to be incorporated into a baseline risk assessment included frequency of detection and a comparison to background. Site- and media-specific risk-based remediation standards were calculated, pending additional sample collection, if and where additional sampling and site-specific standards were deemed necessary. 12.1 Human Health Screening 12.1.1 Introduction This screening-level human health risk assessment was prepared in accordance with applicable NCDENR and USEPA guidance and the approved Work Plan. 12.1.2 Site Conceptual Model The Conceptual Site Model (CSM) is a dynamic tool for understanding site conditions and potential exposure scenarios for human receptors that may be exposed to site-related contamination. The CSM provides graphical representation of the following:  A source and mechanism of chemical release,  A retention or transport medium for COPCs,  A point of contact between the human receptor and the medium, and  A route of exposure to constituents for the potential human receptor at the contact point. An exposure pathway is considered complete only if all four “source to receptor” components are present. A CSM has been prepared illustrating potential exposure pathways from the source Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 12.0 SCREENING-LEVEL RISK ASSESSMENT 72 area to possible receptors (see Figure 12-1). Information in the CSM was used in conjunction with the analytical data collected as part of the CSA to determine COPCs for the site. Potential receptors are defined as human populations that may be subject to contaminant exposure. Both current and future land and water use conditions were considered when determining exposure scenarios. Current and future land use of the DRSS site including the ash basin system is expected to remain predominantly industrial while decommissioning of the coal- fired generating station is in progress (Duke Energy 2014b). The DRCCS natural gas generating facility will remain in active use for the foreseeable future. Lands surrounding the site include residential, agricultural and undeveloped areas, as well as the Dan River, which supplies drinking water to various municipalities (USEPA 2014a). The following potential receptors are identified in the CSM:  Current/future on-site construction worker with potential exposure to groundwater in trenches, surface and subsurface soil and surface water;  Current/future on-site outdoor worker with potential exposure to surface soil and surface water;  Current/future adult and child off-site resident with potential exposure to surface soil and groundwater; and  Current/future on-site trespasser with potential exposure to surface soil, surface water, and sediment. Other exposure pathways for all potential receptors were evaluated and it was determined that they would not have a significant impact on the risk assessment (e.g., outdoor worker inhalation of inorganics in surface water in open air). Other exposure scenarios will also serve as surrogates that will provide information about the magnitude of these potential risks. The following sections describe each receptor and potentially complete exposure pathway. 12.1.2.1 Current/Future Construction Worker It is assumed that construction activities during decommissioning and restoration of DRSS could take place on-site and that construction workers could potentially be exposed to COPCs in various media during this timeframe. The potentially complete exposure pathways include incidental ingestion, dermal contact, and particulate inhalation exposure to surface and subsurface soil. For example, construction workers in a trench could come in contact with groundwater COPCs with inhalation toxicity criteria and incidentally ingest or have dermal contact with (over limited parts of the body) groundwater. Dermal contact and incidental ingestion exposure to surface water could also be considered a potentially complete exposure pathway for this receptor. 12.1.2.2 Current/Future Outdoor Worker Outdoor workers are assumed to be involved with non-intrusive activities (e.g., landscapers that will maintain the site). This receptor reflects a longer timeframe and different exposure pathway than that of construction workers. Outdoor workers are assumed to have incidental ingestion, Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 12.0 SCREENING-LEVEL RISK ASSESSMENT 73 dermal contact, and particulate inhalation exposure to surface soil as well as dermal contact and incidental ingestion exposure to surface water. Exposure to COPCs in groundwater was not identified in the CSM because outdoor workers are assumed not to ingest untreated water. Also, any COPC aerosols or fumes are assumed to dissipate in open air, with limited opportunity for dermal contact. Construction worker exposure scenarios are considered a conservative surrogate to estimate the potential risk from groundwater to outdoor workers. 12.1.2.3 Current/Future Off-Site Resident (Adult/Child) The potential for off-site residents to be exposed to COPCs in untreated groundwater was included in the CSM, as three private water supply wells and one private water supply spring reportedly not currently in use are located within a 0.5-mile radius of the ash basin compliance boundary surrounding DRSS (reference Section 4.0, HDR 2014a, HDR 2014b, and Figure 4-1). These exposures considered all on and off-site monitoring well data, excluding the receptor survey data, which was performed separately. It is important to note, however, that all three water supply wells are located greater than 2,000 feet away from the Dan River ash basin compliance boundary and are either upgradient or across the Dan River from the ash basin system. No information gathered as part of this assessment suggests that any water supply well or spring is impacted by the Dan River ash basin system. Exposure routes include ingestion of groundwater (not incidental, but potable use) as well as dermal contact during bathing/showering and inhalation during bathing/showering for those metals in groundwater with available inhalation-based toxicity criteria. Residents are assumed to be exposed to contaminants in surface soil during non-intrusive outdoor activities (e.g., gardening); the potential exposure pathways include ingestion, dermal and inhalation of soil particulates. The Dan River is a public drinking water supply with the nearest intake at Danville, Virginia (23 miles downstream) that is treated before consumption (USEPA 2014a). Therefore, residential exposure of untreated surface water was not evaluated. 12.1.2.4 Current/Future Trespasser (Adolescent/Adult) Trespassers may come into direct contact with or incidentally ingest surface water and sediment while on-site and near the Dan River during what is assumed to be predominantly recreational activity. This will occur at different rates depending on the specific activity and setting. The exposure parameters for this scenario were determined and incorporated on- and off-site data for these media. Exposure routes include incidental ingestion, dermal contact and particulate inhalation of surface soil, as well as incidental ingestion and dermal contact with surface water and sediment. This receptor reflects greater exposure to surface water, sediment and soil COPCs compared to potential exposures of similar potential receptors (e.g., off-site recreator). Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 12.0 SCREENING-LEVEL RISK ASSESSMENT 74 12.1.3 Human Health Risk-Based Screening Levels A comparison of contaminant concentrations in various media to corresponding risk-based screening levels has been made and is presented in Tables 12-1 through 12-5. These include:  Soil: USEPA industrial soil Regional Screening Levels (RSLs) at a target cancer risk of 1E-06 and noncancer Hazard Quotient of 0.1 Groundwater: USEPA tap water RSLs and NCDENR 2L Standards; and  Surface Water: USEPA National Recommended Water Quality Criteria and NCDENR 15 NCAC.02B surface water standards, considering the surface water classification for local water bodies Sediment: USEPA residential soil RSLs. Tables 12-1 through 12-5 present a summary of the COIs that were detected at concentrations exceeding their relevant human health or other applicable criteria on a media-specific basis, in ground and surface water, sediment, and soil. Those COIs exceeding relevant screening criteria are identified as COPCs for purposes of this human health risk assessment.  In groundwater, aluminum, copper, lead, titanium, thallium, and zinc were eliminated as COPCs. With the exception of sodium, which was retained as a result of having no screening value for comparison, all other COIs exceeded their respective screening value. See Table 12-1 for maximum concentrations detected, the detailed screening results, identification of COPCs and contaminant categories.  In soil, arsenic, cobalt, iron, manganese, sodium, and thallium were detected at concentrations exceeding the industrial soil screening levels are determined to be COPCs. See Table 12-2 for the soil COI maximum concentrations, COPC and contaminant category data.  Aluminum, arsenic, cobalt and thallium maximum concentrations exceed their respective screening values and have been determined to be COPCs in surface water, as shown in Table 12-3. Beryllium, boron, total chromium, copper, iron, lead, manganese, mercury, sodium, vanadium and zinc are also retained as COPCs based on a lack of criteria for comparison.  Sediment COPCs and contaminant categories are presented in Table 12-4, which shows that aluminum, antimony, arsenic, cobalt, iron, manganese, thallium, and vanadium are determined to be COPCs based on exceedances of screening values. COIs were not screened out as COPCs based on a comparison to background concentrations, as USEPA recommends all COIs exceeding risk-based screening levels be considered in a baseline risk assessment (USEPA 2002). Statistical background concentrations have been developed as Prediction Limits (PLs), calculated for each COI using groundwater data in site background wells. PLs are a calculation of the upper limit of possible future values based on the Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities Unified Guidance (USEPA 2009). If concentrations of COI detected exceed the PL, then the groundwater concentrations are assumed to have increased above background levels. Site-specific background concentrations will be considered in the uncertainty section of the baseline risk assessment, if determined to be required. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 12.0 SCREENING-LEVEL RISK ASSESSMENT 75 NCDENR guidance requires a determination of COPC contaminant categories as a result of the data comparison to screening levels. These categories are presented in the ecological COPC tables (Tables 12-6 through 12-9) and include:  Category 1 – Contaminants whose maximum detection exceeds the media specific ecological screening value included in the COPC tables.  Category 2 – Contaminants that generated a laboratory sample quantitation limit (SQL) that exceeds the USEPA Region IV media-specific ecological screening value for that contaminant.  Category 3 – Contaminants that have no USEPA Region IV ecological screening value, but were detected above the laboratory SQLs.  Category 4 – Contaminants that were not detected above the laboratory SQLs and have no USEPA Region IV ecological screening value.  Category 5 – Contaminants whose SQL or maximum detection exceeds the North Carolina Surface Water Quality Standards. 12.1.4 Site-Specific Risk Based Remediation Standards Based on results of the comparison to risk-based screening levels, media-specific remediation standards were calculated in accordance with the Eligibility Requirements and Procedures for Risk-Based Remediation of Industrial Sites Pursuant to North Carolina General Statute 130A- 310.65 to 310.77, should additional sample collection and site-specific standards be deemed necessary. 12.1.5 NCDENR Receptor Well Investigation Although three off-site private water supply wells and one water supply spring not currently in use were identified within 0.5-mile radius of the ash basin compliance boundary, none of these were sampled and analyzed for COIs as part of NCDENR’s well testing program, as described in Section 4.0. No information on sampling results or recommendations from NCDENR on well water consumption for the DRSS site, or communities surrounding the DRSS site, is available at this time. All three water supply wells are located greater than 2,000 feet away from the Dan River ash basin compliance boundary and are either upgradient or across the Dan River from the ash basin system. No information gathered as part of this assessment suggests that water supply wells or springs located within the compliance boundary are impacted by the DRSS ash basin system. 12.1.6 Human Health Screening Summary A CSM was developed to identify potential pathways of exposure from COPC source to receptor populations, including several possible exposure scenarios. Maximum concentrations of COIs were compared to media-specific screening levels, COIs exceeding screening levels, and those having no screening levels or issues with RLs were retained as COPCs, in accordance with guidance. As a result of the screening, the majority of COIs were determined to be COPCs in groundwater and soil. Only four COIs exceeded their surface water screening values; most are Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 12.0 SCREENING-LEVEL RISK ASSESSMENT 76 retained as COPCs by default due to a lack of criteria being available for comparison. Eight COIs were determined to be COPCs based on exceedances of their screening values. 12.2 Ecological Screening 12.2.1 Introduction This screening-level ecological risk assessment (SLERA) has been prepared in accordance with the Guidelines for Conducting a Screening Level Ecological Risk Assessments within the North Carolina Division of Waste Management (NCDENR 2003). 12.2.2 Ecological Setting 12.2.2.1 Site Summary Refer to Section 2.0 for a description of the DRSS site. 12.2.2.2 Regional Ecological Setting The DRSS site is located in the Triassic Basins eco-region of North Carolina adjacent to the Dan River; this relatively small eco-region is surrounded by the Northern Inner Piedmont eco- region (Griffith et al. 2002). 12.2.2.3 Description of the Eco-Region and Expected Habitats This eco-region consists of irregular plains with low rounded hills and ridges and low to moderate gradient streams with wider valleys. It has generally lower elevations than the Inner Piedmont. The common rock types include unmetamorphosed shales, sandstones, mudstones and siltstones covered by red sandy loam to silty clay. Land cover includes mixed white oak forests, croplands and pastures; bottomland hardwood forests once existed in the wider floodplains; these have since then been covered by water supply reservoirs (Griffith et al. 2002). 12.2.2.4 Watershed in which the Site is Located The DRSS site is located in the Roanoke River Basin watershed. The North Carolina portion of the river basin encompasses approximately 3,500 square miles in all or in part of 19 counties. 12.2.2.5 Average Rainfall The average annual precipitation for Eden, North Carolina is 45.02 inches over the past 30 years. The average for the State of North Carolina is 48.87 inches (Weather DB 2015). 12.2.2.6 Average Temperature The average temperature for Eden, North Carolina is 59.85°F. The average winter temperature is 47.4°F. The average spring temperature is 55°F. The average summer temperature is 75.3°F and average fall temperature is 61.6°F (Weather DB 2015). Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 12.0 SCREENING-LEVEL RISK ASSESSMENT 77 12.2.2.7 Length of Growing Season According to the North Carolina State University Cooperative Extension, the average growing season for Rockingham County is 203 days, with a standard deviation of 15 days. 12.2.2.8 Threatened and Endangered Species that use Habitats in the Eco-Region A list of federal and state threatened and endangered species for Rockingham County is provided in Table 12-10. 12.2.2.9 Site-Specific Ecological Setting An ecological checklist has been completed for this site and is provided in Appendix I. The DRSS site is located on the Dan River in Rockingham County near the town of Eden, North Carolina. The June 2015 AMEC Natural Resources Technical Report identified 13 potential jurisdictional wetland areas on the site, measuring a total of approximately 2.53 acres. One potentially jurisdictional pond was identified. There were 16 potential jurisdictional drainage features within the study are: eight intermittent and eight perennial streams. An area next to the Dan River and Stream 3 is within the 100-year flood zone. The western boundary of the site, including Streams 9 and 14 and Wetland L, are within the 100-year flood zone (AMEC 2015). Requests for information were submitted to several federal and state agencies, in accordance with the North Carolina Guidelines for Performing Screening Level Ecological Risk Assessments (NCDENR 2003). A copy of the requests and responses are provided in Appendix I and a summary of the information is provided below. North Carolina Department of Cultural Resources In a letter dated June 18, 2015, the North Carolina Department of Cultural Resources indicated that there are no recorded archaeological sites located on-site and four archaeological sites within one-half mile of the DRSS site. These include:  31RK1(Lower Sauratown), a Native American village site containing intact subsurface features. It is located in the floodplain on the south side of the Dan River. This site is currently listed in the National Register of Historic Places.  31RK5 (Power Plant Site), a Native American village site containing intact subsurface features. It is located in the floodplain on the south side of the Dan River.  31RK33 (Sauratown Plantation), a late 18th to early 19th century domestic structure with an archaeological component. It is located on a hilltop south of the Dan River. The standing structure is currently listed in the National Register of Historic Places.  31RK61 is a Native American site located within the floodplain on the south side of the Dan River. This site is likely similar to sites 31RK1 and 31RK5. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 12.0 SCREENING-LEVEL RISK ASSESSMENT 78 North Carolina Natural Heritage Program In a letter dated June 9, 2015, the North Carolina Natural Heritage Program (NCNHP) provided information obtained from their database, both for the DRSS site and within a one-mile radius. According to the NCNHP database, the ROA/Dan River Aquatic Habitat, a Natural Area, is located within the DRSS site. There are no other Natural Areas or Managed Areas within a one- mile radius. North Carolina Wildlife Resources Commission In a letter dated June 19, 2015, the North Carolina Wildlife Resources Commission (NCWRC) reported the following:  The DRSS site drains to the Dan River in the Roanoke River basin.  There are records for the federal and state endangered Roanoke logperch (Percina rex) being present in the Dan River watershed.  There are records for the federal species of concern and state endangered green floater (Lasmigona subviridis), the federal species of concern and state significantly rare Roanoke bass (Ambloplites cavifrons), the state threatened bigeye jumprock (Moxostoma ariommum), and the state significantly rare Roanoke hogsucker (Hypentelium roanokense) and quillback (Carpoides cyprinus) in the Dan River watershed. In addition, there are historical records for the state threatened Jacob’s ladder (Polemonium reptans var. reptans), the state significantly rare coppery emerald (Somatochlora georgiana), and the state significantly rare glade wild quinine (Parthenium auriculatum) near the site.  There is recreational fishing in the Dan River. Recreational aquatic species include largemouth bass, catfish, and sunfish. It is likely the site is too industrialized to support any ecologically, recreationally or commercially important terrestrial wildlife species. However, raccoon, opossum, skunk, white-tailed deer, coyotes, and other species commonly found throughout the Northern Piedmont region may be found on the site. Recreationally important wildlife species in the vicinity of the site include, but are not limited to bear, white-tailed deer, beaver, mink, muskrat, nutria, otter, skunk, weasel, bobcat, opossum, raccoon, fox, rabbit, squirrel, various species of wild ducks and geese, quail, and wild turkey. United States Department of Agriculture Forest Service, National Forests in North Carolina In an email dated May 28, 2015, the United States Department of Agriculture Forest Service reported that there are no Designated and Proposed Federal Wilderness and Natural Areas, National Preserves and Forests, or Federal Land Designated for the Protection of Natural Ecosystems with a half-mile of the DRSS site. United States Department of the Interior, National Park Service In an email dated June 3, 2015, the United States Department of the Interior, National Park Service indicated that “the NPS has not identified any resource concerns at this time”. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 12.0 SCREENING-LEVEL RISK ASSESSMENT 79 12.2.2.10 On-Site and Off-Site Land Use On-site land use is approximately 40% heavy industrial, 20% light industrial, 30% undisturbed, and 10% water bodies, and cleared areas. Land use within a one-mile radius of the site is 30% undisturbed, 20% residential, 15% recreational, 10% light industrial, 10% urban, 10% agricultural, and 5% waterbodies (including the Dan River). There are several areas designated for recreational use (i.e., a boat launch, golf course, and park) in the local area as well. 12.2.2.11 Habitats within the Site Boundary Based on the findings of a July 7, 2015 site visit, the following habitats are present on site:  82 acres of Mixed Hardwoods  18 acres of Pine Plantation  15 acres of Bottomland Hardwoods  17 acres of Shrub/Scrub  77 acres of Open Fields  Aquatic features including ash basins, streams, and wetlands For a detailed description of habitats, refer to the Checklist for Ecological Assessments provided in Appendix I. 12.2.2.12 Description of Man-made Units that may Act as Habitat A 34-acre ash basin (Primary and Secondary Cell) is present on the site. 12.2.2.13 Site Layout and Topography The natural topography at the DRSS site ranges from an approximately 606 feet near the northern property boundary just west of Edgewood Road to an approximate low elevation of 482 feet at the interface with the Dan River. Topography generally slopes from northwest to southeast with an elevation loss of approximately 125 feet over an approximate distance of 0.7 miles. Surface water drainage generally follows site topography and flows from the northwest to the southeast across the site except where natural drainage patterns have been modified by the ash basin or other construction (HDR 2014b). 12.2.2.14 Surface Water Runoff Pathways Swales and drainage ditches were observed during the July 7, 2015 site visit. 12.2.2.15 Soil Types Based on lithological data obtained from soil borings completed by AMEC during ash basin closure assessment activities, subsurface stratigraphy consists of the following material types: fill, ash, residuum, saprolite, alluvium, PWR, and bedrock. In general, fill, residuum, saprolite, and PWR were encountered on most areas of the site. Ash was encountered within ash ponds and storage areas, while alluvium was encountered within and adjacent to historical drainage Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 12.0 SCREENING-LEVEL RISK ASSESSMENT 80 features and the Dan River. Bedrock was not encountered during AMEC’s activities but is known to underlie the PWR at depth (HDR 2014c). AMEC’s review of the National Resource Conservation Service (NRCS) Soil Survey indicated the presence of four soil map units within the study area; Ayersville gravelly loam, 15 to 45 percent slopes (AyF); Clover sandy loam, 2 to 8 percent slopes (CmB); Clover sandy loam, 8 to 15 percent slopes (CmD); Dan River loam, 0 to 2 percent slopes, frequently flooded (DaA); and Udorthents, loamy (Ud). Open water areas (W) are also mapped within the study area. The Dan River loam, 0 to 2 percent slopes, is frequently flooded (DaA) and considered to be a hydric soil by the NRCS (AMEC 2015). 12.2.2.16 Species Normally Expected to Use Site under Relatively Unaffected Conditions Terrestrial communities occur in both natural and disturbed habitats in the study area; these may support a diversity of wildlife species. Information on the species that would normally be expected to use this and similar sites in the Piedmont eco-region under relatively unaffected conditions was obtained from relevant literature, mainly the Biodiversity of the Southeastern United States, Upland Terrestrial Communities (Wiley and Sons 1993) and Biodiversity of the Southeastern United States, Aquatic Communities (Wiley and Sons 1993). Mammal species that may be present include eastern cottontail (Sylvilagus floridanus), gray squirrel (Sciurus carolinensis), various vole, rat and mice species, red (Vulpes vulpes) and gray fox (Urocyon cinereoargenteus), raccoon (Procyon lotor), Virginia opossum (Didelphis virginiana), and white-tailed deer (Odocoileus virginiana). Avian species are the most diverse. Canopy dwellers include the great crested flycatcher (Myiarchus crinitus), Carolina chickadee (Parus carolinensis), tufted titmouse (P. bicolor), white- breasted nuthatch (Sitta carolinensis), blue-gray gnatcatcher (Polioptila caerulea), red-eyed vireo (Vireo olivaceus), yellow-throated vireo (V. flavifrons), various warblers and tanagers, American redstart (Setophaga ruticilla), Subcanopy species include a variety of woodpeckers, eastern pewee (Contopus virens), Acadian flycatcher (Empidonax virescens), American crow (Corvus brachyrhynchos), blue jay (Cyanocitta cristata) and Carolina wren (Thryothorus ludovicianus). Catbirds (Dumetella carolinensis), brown thrashers (Toxostoma rufum), and mockingbirds (Mimus polyglottos) are found along adjacent brushy edges, fields and thickets. Understory species include wood thrush (Hylocichla mustelina), American robin (Turdus migratorius), white-eyed vireo (Virea griseus), Kentucky warbler (Oporornis formosus), common yellow-throat (Geothlypis trichas), and yellow breasted chat (Icteria virens). Predatory birds include several hawk and owl species and the turkey vulture (Cathartes aura), Amphibians and reptiles that tend to be associated with the terrestrial-aquatic interface in streams, rivers, and open waters may include certain turtles, e.g., the Striped Mud and Gulf Coast Spiny Softshell turtles; and frogs, snakes and amphibians such as the Three‐lined salamander. For a more detailed description, see Appendix I. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 12.0 SCREENING-LEVEL RISK ASSESSMENT 81 Streams of the southeastern piedmont support a range of aquatic benthic macroinvertebrate groups including mayflies (Ephemeroptera), stoneflies (Plecoptera), caddisflies (Trichoptera), water beetles (Coleoptera), dragonflies and damselflies (Odonata), dobsonflies and alderflies (Megaloptera), true flies (Diptera), worms (Oligochaeta), crayfish (Crustacea), and clams and snails (Mollusca). Streams, rivers, ponds, and reservoirs support populations of game fish that may include redbreast sunfish (Lepomis auritus), bluegill (Lepomis macrochirus), warmouth (Lepomis gulosus), and largemouth bass (Micropterus salmoides). The most widespread non-game fish species are American eel (Anguilla rostrata), eastern silvery minnow (Hybognathus regius), bluehead chub (Nocomis leptocephalus), golden shiner (Notemigonus crysoleucas), spottail shiner (Notropis hudsonius), whitefin shiner (N. niveus), swallowtail shiner (N. procne), creek chub (Semotilus atromaculatus), creek chubsucker (Erimyzon oblongus), silver redhourse (Moxostoma anisurum), yellow bullhead (Ictalurus natalis), flat bullhead (I. platycephalus), margined madtom (Noturus insignis), and tessellated darter (Etheostoma olmstedi). 12.2.2.17 Species of Special Concern For a detailed list of species of special concern that may be present, see Table 12-10. 12.2.2.18 Nearby Critical and/or Sensitive Habitats For a detailed description, see Section III.D of the Ecological Checklist provided in Appendix I. 12.2.3 Fate and Transport Mechanisms Potential fate and transport mechanisms at or near the DRSS site include erosion, seeps, stormwater runoff and flow of surface water bodies. An ecological CSM (Figure 12-2) has been prepared illustrating potential exposure pathways from the source area to possible ecological receptors. Information in the ecological CSM was used in conjunction with analytical data collected as part of the CSA to develop an understanding of the sources, pathways and media of exposure, as well as the receptors potentially impacted by site-related COPCs. 12.2.4 Comparison to Ecological Screening Levels The sampling and analysis program completed as part of the CSA is described earlier in this report. Media of primary concern for ecological receptors, (i.e., surface water, sediment, and soil) have been sampled extensively, in accordance with the NCDENR-approved Work Plan. The results of the comparison of COI concentrations in various media to risk-based screening levels is presented in Tables 12-6 through 12-9 and include:  USEPA Region IV Recommended Ecological Screening Values for soil, surface water and sediment, and  USEPA National Recommended Water Quality Criteria and North Carolina Freshwater Aquatic Life Standards. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 12.0 SCREENING-LEVEL RISK ASSESSMENT 82 The potential for ecological risk was also estimated by calculating screening hazard quotients (HQ) using the appropriate screening value of each contaminant and comparing that value to the USEPA Region IV Ecological Screening Values. COIs having a HQ greater than or equal to 1 were identified as COPCs. A determination of which category the COPCs fall into as a result of the data comparison to screening levels is presented in the media-specific ecological COPC tables (Tables 12-6 through 12-8). These include the categories described in Section 12.1.3. Table 12-9 presents a summary of the COIs that were detected at concentrations exceeding their relevant ecological screening media-specific criteria. Those COIs exceeding the relevant criteria are identified as ecological COPCs for purposes of the SLERA. Note that NCDENR SLERA guidance does not allow for exclusion of COIs as COPCs based on a comparison to background concentrations. In soil, all COIs except cadmium, sodium, and strontium were detected at concentrations exceeding the ecological soil screening levels. Cadmium is the sole COI that was excluded as a COPC in soil, as the other two have no ecological criteria and are thereby retained as COPCs by default. Reference Table 12-6 for detailed information, including the maximum concentrations detected. The exceedances were typically within the same order of magnitude as the screening levels, with the exceptions of aluminum, boron, total chromium, iron, manganese, molybdenum, selenium and vanadium, which were relatively higher. Based on the comparison of maximum detected concentrations to screening criteria, beryllium, cadmium, and copper were identified as ecological COPCs in surface water (freshwater). Barium, cobalt, manganese, molybdenum, strontium, and vanadium were retained by default due to the fact that there are no ecological criteria available or a comparison to RLs. Further information on the screening performed and characterization as to the contaminant category for each COPC is provided in Table 12-7. COPCs identified in sediment based on a comparison of maximum detected concentrations to available criteria include antimony, arsenic, cadmium and copper. Aluminum, barium, beryllium, boron, cobalt, iron, manganese, molybdenum, strontium and vanadium were retained due to issues related to their RL exceeding the screening value or there being no screening value available. Details of the COPC screening and contaminant category are provided in Table 12-8. COIs were not screened out as COPCs based on a comparison to background concentrations, as NCDENR SLERA guidance does not allow for screening based on background. Site-specific background concentrations, discussed above in Section 12.1.3, were considered in the uncertainty section of the baseline ecological risk assessment, if determined to be necessary. 12.2.5 Uncertainty and Data Gaps Uncertainties are inherent in any environmental investigation and risk evaluation involving natural heterogeneity of media, nature, and extent of constituents in the environment, due to their individual fate and transport characteristics and varied, site-specific conditions. These uncertainties are considered in developing the sampling and analysis plan, data quality assurance processes, and understanding of the site. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 12.0 SCREENING-LEVEL RISK ASSESSMENT 83 Screening-level assessments performed as part of the CSA were designed to be very conservative in identifying potential COPCs that would be carried forward into a baseline human health and/or ecological risk assessment. They included all on- and off-site analytical data, and used the maximum concentration detected as the comparison point to applicable screening criteria. Also, no COIs were eliminated as COPCs based on background levels; this will be evaluated in the baseline risk assessment, if they are required to be performed. These are highly unlikely to be the actual exposure concentrations, given the natural attenuation, dilution, and distances to potential receptors. There is a high level of confidence that any constituent with potential to impact human health or ecological receptors has been identified as a result of these assessments. 12.2.6 Scientific/Management Decision Point If, through the HQ analysis, it is determined that COIs were detected at maximum concentrations exceeding applicable screening criteria, it is an indication that additional assessment of potential risks is warranted. This does not mean that impacts are, in fact, occurring; only that further data collection or evaluation should be considered. This determination is known as the Scientific/Management Decision Point (SMDP) and the conclusion reached must be one of the following:  There is adequate information to conclude that the ecological risks are neglibible; or  Site has inadequate data to complete the risk characterization. Data gaps need to be filled prior to completion of the screening process; or  The information indicates a potential for adverse ecological effects and a more thorough assessment is warranted. Given that several COPCs have been identified as having an HQ of greater than 1 in soil, surface water, and sediment, there is adequate information indicating a potential for adverse effects to occur and a baseline ecological risk assessment may be warranted. The need for a separate baseline ecological risk assessment should be considered in light of the other ongoing or planned environmental impact studies for this site. 12.2.7 Ecological Risk Screening Summary The SLERA identified the potential for adverse ecological impacts to exist due to exposure to COPCs in soil, surface water and/or sediment. Cadmium is the only COI that was excluded as a COPC in soil and several COPCs exceeded their respective screening criteria by one or two orders of magnitude. Notably fewer COPCs were identified in surface water and sediment, and several of those were retained by default for having no criteria or due to RL issues, and not due to maximum concentrations actually exceeding screening criteria. Impacts from limited ecological receptor groundwater exposure are minimal and have not been evaluated. For DRSS, identification of potential data gaps and overall coordination of further ecological risk assessment efforts, specifically for surface water and sediment impacts, should consider other activities that are ongoing related to ash basin closure activities to avoid duplication of effort. This page is intentionally left blank. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 13.0 GROUNDWATER MODELING 84 13.0 Groundwater Modeling Groundwater modeling will be performed and submitted in the CAP in accordance with NCDENR’s Conditional Approval letter for the Work Plan. The groundwater modeling will consist of groundwater flow and fate and transport modeling, performed with MODLFOW and MT3DMS, and batch geochemical modeling, performed with PHREEQC. The following section presents an overview of the fate and transport modeling, the batch geochemical modeling, and the site geochemical conceptual model. The CAP will also include a discussion of the geochemical properties of the COIs and how these properties relate to the retention and mobility of these constituents. 13.1 Fate and Transport Groundwater Modeling A three-dimensional groundwater flow and contaminant fate and transport model (MODFLOW/MT3DMS Model) will be developed for the DRSS ash basin. The objective of the modeling will be to predict the following in support of the CAP:  Predict concentrations of the COIs at the compliance boundary or other locations of interest over time,  Estimate the groundwater flow and constituent loading to surface water discharge areas, and  Predict approximate groundwater elevations in the ash for the proposed corrective action. The model and model report will be developed in general accordance with the guidelines found in the memorandum Groundwater Modeling Policy, NCDENR DWQ, May 31, 2007 (NCDENR modeling guidelines). The groundwater model will be developed from the hydrogeologic conceptual model presented in the CSA, from existing wells and boring information provided by Duke Energy, and from information developed during the groundwater site investigation. The model will also be supplemented with additional information developed by HDR from other Piedmont sites, as applicable. The CSM is a conceptual interpretation of the processes and characteristics of a site with respect to the groundwater flow, boundary conditions, and other hydrologic processes at the site. Although the site is anticipated to conform generally to the LeGrand conceptual groundwater model, due to the configuration of the ash basin, the additional possible sources (dry ash storage area, cinder storage area), and the boundary conditions present at the site, a three- dimensional groundwater model is warranted. Groundwater modeling will be performed under the direction of Dr. William Langley, P.E., Department of Civil and Environmental Engineering, University of North Carolina at Charlotte (UNCC). Groundwater flow and constituent fate and transport will be modeled using Visual MODFLOW 2011.1 (flow engine USGS MODFLOW 2005) and MT3DMS. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 13.0 GROUNDWATER MODELING 85 The modeling process, the development of the model, the development of the hydrostratigraphic layers, the model extent (or domain), and the proposed model boundary conditions were described in Section 7.0 of the Work Plan. To date, no changes to the proposed model development are warranted based on data collected during the site investigation. The MT3DMS model will use site specific Kd values developed from samples collected along the major flow transects. The testing to develop the Kd terms is underway, but is not complete at this time; therefore, the results of that testing will be presented in the CAP. The methods used to develop the Kd terms were presented in Section 7.7.2 of the W ork Plan. 13.2 Batch Geochemical Modeling As described in the W ork Plan, batch geochemical simulations using PHREEQC will be used to estimate sensitivity of the proposed sorption constants used with MT3DMS and to assist in understanding the mechanisms involved in attenuation of selected constituents. Geochemical modeling using PHREEQC can be used to indicate the extent to which a COI is subject to solubility constraints, a variable Kd, or other processes. PHREEQC can also identify postulated solid phases calculation of their respective saturation indices. The specific locations where the batch geochemical modeling will be performed will be determined after development of the Kd terms and a review of site analytical data. 13.3 Geochemical Site Conceptual Model SCMs are developed to be a representation of what is known or suspected about a site with respect to contamination sources, release mechanisms, transport, and fate of those contaminants.4 SCMs can be a written and/or graphic presentation of site conditions to reflect the current understanding of the site, identify data gaps, and be updated as new information is collected throughout the project. SCMs can be utilized to develop understanding of the different aspects of site conditions, such as a hydrogeologic site conceptual model, to help understand the site hydrogeologic condition affecting groundwater. SCMs can also be used in a risk assessment to understand contaminant migration and pathways to receptors. On June 25, 2015, NCDENR made the following request in their Clarification of Attachment 1 Groundwater Assessment Plan Conditional Letters of Approval Items Related to Speciation – May 22, 2015 e-mail: Since speciation of groundwater and surface water samples is a critical component of both the site assessments and corrective action, the Division expects a geochemical site site conceptual model (SCM) developed as a subsection in the Comprehensive Site Assessment (CSA) Reports. The geochemical SCM should provide a summary of the geochemical interactions between the solution and solid phases along the groundwater flowpath that impact the mobility of metal constituents. At a minimum, the geochemical SCM will describe the adsorption/desorption and mineral precipitation/dissolution 4 EPA MNA Volume 1 Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 13.0 GROUNDWATER MODELING 86 processes that are believed to impact dissolved concentrations along the aquifer flowpaths away from the ash basin sources. The model descriptions should include the data upon which the conceptual model is based and any calculations (such as mineral saturation indices) that are made to develop the site-specific model. Metal speciation analyses cover a broad aspect of metals’ geochemistry, including solution complexation with other dissolved species and specific association with aquifer solids, such as a metal adsorbed onto HFO or precipitated as a sulfate mineral. A comprehensive speciation analysis that requires a relatively complete groundwater analysis is expected that includes use of an ion speciation computer code (such as PHREEQC) capable of calculating solution complexes, surface complexation onto HFO, and mineral saturation indices. This type of speciation calculation is necessary for the development of a geochemical SCM and understanding metal mobility in an aquifer. In previous correspondence, NCDENR agreed that the proposed geochemical modeling described in the Work Plan, to be performed using PHREEQC, will be included in the CAP. Specifically, the model descriptions and calculations, such as mineral saturation indices, will be provided in the CAP. This approach will allow completion of the testing to develop the site- specific Kd terms and site mineralogy, and will allow the geochemical modeling to be coordinated with the groundwater flow and transport model. Elements of the geochemical site conceptual model (GSCM) described below will be incorporated into the fate and transport and the geochemical modeling performed for the CAP. The GSCM will be updated as additional data and information associated with contaminants, site conditions, or processes such as migration of contaminants is developed. The GSCM will be useful in understanding the transport and attenuation factors that affect the mobility of contaminants at the site and the long-term capacity of the site for attenuation and stability of immobilized contaminants. The GSCM will describe the geochemical aspects of the site sources that influence contaminant transport. Site sources at Dan River consist of the dry ash storage areas (Ash Storage 1 and Ash Storage 2) and the Primary and Secondary Cells; these source areas are subject to different processes that generate leachate migrating into the underlying soil layers and into the groundwater. For example, the dry ash storage areas would generate leachate as a result of infiltration of precipitation, while the ash basin would generate leachate based on the pond elevation in the basin. General factors affecting the geochemistry of the site are as follows: Factors Affecting Ash Formation (Primary Source):  Chemical and mineralogical composition of coal  Thermodynamics of coal combustion process Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 13.0 GROUNDWATER MODELING 87 Factors Affecting Leaching in Ash Basin (Primary Source Release Mechanism):  Chemical composition of ash  Mineral phase of ash  Physical characteristics of ash  Inflow of water into/out of basin  Period of time ash has been in basin  Geochemical conditions in ash basin  Precipitation-dissolution reactions  Sorptive properties of materials in ash Factors Affecting Leaching in Dry Ash Storage Area (Primary Source Release Mechanism):  Chemical composition of ash in storage area  Mineral phase of ash in storage area  Physical characteristics of ash in storage area  Inflow of precipitation in to ash storage area  Period of time ash has been in storage  Geochemical conditions in ash storage area  Precipitation-dissolution reactions  Sorptive properties of materials in ash Factors Affecting Sorption and Precipitation of Constituents onto Soil/Aquifer Materials Beneath Ash (Secondary Source Release Mechanism):  Chemical composition of soil  Physical composition of soil  Rate of infiltration/percolation of porewater  Chemical composition of leachate infiltrating into soil  Sorption capacity of soil  Geochemistry of groundwater flowing beneath unit Factors Affecting Desorption and Dissolution of Constituents From Soil/Aquifer Materials Beneath Ash (Secondary Source Release Mechanism):  Chemical composition of soil  Physical composition of soil  Rate of infiltration/percolation of porewater  Attenuation capacity of soil  Chemical composition of leachate or precipitation infiltrating into soil  Geochemistry of groundwater flowing beneath unit The results of the Kd testing, site mineralogy testing, and geochemical modeling developed in the CAP will be used to refine the GSCM. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 14.0 DATA GAPS – CONCEPTUAL SITE MODEL UNCERTAINTIES 88 14.0 Data Gaps – Site Conceptual Model Uncertainties 14.1 Data Gaps Through completion of groundwater assessment field activities and evaluation of data collected during those activities, Duke Energy has identified data gaps that will require further evaluation to refine the SCM. The data gaps have been separated into two groups: 1) data gaps resulting from temporal constraints and 2) data gaps resulting from evaluation of data collected during the CSA. 14.1.1 Data Gaps Resulting from Temporal Constraints Data gaps identified in this category are generally present due to insufficient time to collect, analyze, or evaluate data collected during the CSA activities. It is expected that the majority of these data gaps will be remedied in a CSA Supplement to be submitted in consultation with NCDENR.  Mineralogical Characterization of Soil and Rock: A total of 15 soil, six TZ, and eight bedrock samples were submitted to three third-party mineralogical testing laboratories for analysis of soil and rock composition. As of the date of this report, Duke Energy ha s not received results of this testing; however, results should be available for inclusion in the CSA Supplement.  Horizontal Delineation of Groundwater Contamination: As part of W ork Plan development prior to field mobilization, Duke Energy reviewed existing groundwater quality data from compliance monitoring wells to evaluate the potential for off-site migration of COIs and the potential need for installation of off-site wells. This evaluation prompted the need to install groundwater monitoring wells GWA-14S/D and GWA-15D on the adjacent Duke Energy-owned property east/northeast of the Secondary Cell. Review of newly obtained groundwater quality data from wells installed east and north of Ash Storage 1 indicates a need to refine the understanding of horizontal distribution of constituents in these two areas. This evaluation will conclude prior to submittal of the CSA Supplement.  Additional Speciation of Monitoring Wells: In order to meet the NORR requirements, Duke Energy conducted speciation of groundwater samples for arsenic, chromium, iron, manganese, and selenium from selected wells along inferred groundwater flow transects. Additional speciation sampling may be performed at the following potential locations: along flow transects, at ash basin surface water sample locations, and at wells with exceedances of 2L Standards for speciation constituents in consultation with NCDENR. Adjustments to the speciation sampling from that presented herein are proposed in Section 15.0, the results of which will be presented in the CSA Supplement. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 14.0 DATA GAPS – CONCEPTUAL SITE MODEL UNCERTAINTIES 89 14.1.2 Data Gaps Resulting from Review of Data Obtained During CSA Activities  Bedrock Background Wells: Review of laboratory data indicates that well MW -23BR serves as the only background monitoring well screened within bedrock. The need for additional background bedrock monitoring wells will be evaulated and discussed with NCDENR.  Background Surface Water Data: Background surface water samples were collected from one location within a tributary water body (SW -5) and one location in the Dan River (SW -8) during one sampling event. Additional sampling locations within upstream reaches of the two tributary streams, as well as additional sampling events within the Dan River will be considered to refine the background surface water constituent concentrations.  Surface Water Impacts at SW-3: Results of analyses of surface water and sediment samples at the SW -3 location in the tributary stream along the eastern property boundary indicate potential impact by ash. Duke Energy re-sampled the SW-3 location on August 11, 2015. The results of this sampling event will be discussed in the CSA Supplement.  Seep Samples: Seep sample locations S-2, S-3, and S-4 were dry during several attempted sampling events. Collection of water from these seeps is essential to determine whether groundwater is discharging to surface water.  Review of Non-Ash Contamination Information: Review of information regarding areas of non-ash contamination (i.e., petroleum-contaminated areas) to evaluate potential interference with remedial methods is needed, if applicable. 14.2 Site Heterogeneities Site heterogeneities regarding groundwater flow were not identified during completion of the CSA. In general, groundwater within the surficial aquifer, TZ material, and fractured bedrock flows south/southeast toward the Dan River, with the exception of the area north of Ash Storage 1. In this area, groundwater elevation data suggest the presence of a groundwater divide extending from MW -12 east to GWA-1 where localized groundwater within the surficial aquifer and TZ north of Ash Storage 1 flows north, away from the DRSS site. Site heterogeneities regarding COI concentrations were not identified during completion of this CSA. However, heterogeneities may be identified following completion of the groundwater model for the DRSS site. 14.3 Impact of Data Gaps and Site Heterogeneities Certain data gaps may be addressed with additional groundwater sampling at existing wells. As discussed in Section 15.0, a second comprehensive groundwater sampling event is currently under discussion in consultation with NCDENR. A plan for interim groundwater sampling between submittal of the CSA and implementation of the anticipated CAP is proposed in Section 16.0 and will further supplement the existing data. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 15.0 PLANNED SAMPLING FOR CSA SUPPLEMENT 90 15.0 Planned Sampling for CSA Supplement In accordance with CAMA, a second comprehensive groundwater sampling event at the DRSS site is currently under discussion in consultation with NCDENR and Duke Energy. The second sampling event will be conducted to:  Supplement data obtained during the initial sampling event;  Evaluate seasonal variation in groundwater results; and  Collect additional samples for chemical speciation of arsenic, chromium, iron, manganese, and selenium. 15.1 Sampling Plan for Inorganic Constituents The second sampling event for inorganic constituents will consist of sampling all locations (monitoring wells, seeps, surface water, and sediment) that were sampled during the initial sampling event. Locations that were previously dry will be re-evaluated and sampled if sufficient water is present. All samples collected will be analyzed for total inorganic compounds. Samples with exceedances of 2L Standards during the initial sampling event will also be analyzed for dissolved-fraction inorganics. In addition, surface water samples will be collected upstream and downstream of location SW-3 to refine surface water/groundwater interaction within the tributary stream east of the ash basin. 15.2 Sampling Plan for Speciation Constituents Speciation sampling will be performed at the following potential locations: along flow transects, at ash basin surface water sample locations, and at wells with exceedances of 2L Standards for speciation constituents. A summary of the proposed sampling program for the second comprehensive sampling event is included on Table 15-1 and potential sampling locations are shown on Figure 6-2. This page is intentionally left blank. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 16.0 INTERIM GROUNDWATER MONITORING PLAN 91 16.0 Interim Groundwater Monitoring Plan CAMA requires a schedule for continued / interim groundwater monitoring. Given that Duke Energy has committed to excavating the existing ash basin and ash storage areas to a lined landfill, certain groundwater monitoring wells in these areas will be abandoned. As such, Duke Energy plans to conduct interim groundwater monitoring of select wells, as identified in Section 16.3, to bridge the gap between completion of CSA activities and implementation of the proposed CAP. 16.1 Sampling Frequency One additional interim groundwater sampling will occur during 2015 and the results will be submitted in coordination with NCDENR. Interim groundwater sampling on a quarterly basis is proposed until the CAP is approved by NCDENR. This sampling frequency will allow for evaluation of seasonal fluctuations in COI concentrations, as well as provide additional data for statistical analysis of site-specific background concentrations. 16.2 Constituent and Parameter List The proposed constituents and parameters for analysis are presented in Table 16-1. 16.3 Proposed Sampling Locations The proposed sampling locations are presented in Table 16-2 and shown on Figure 6-2. 16.4 Proposed Background Wells The proposed background wells are GWA-1S/D, GWA-9S/D, MW-23D, MW-23BR, and BG- 5S/D. Note that outside of this Interim Groundwater Monitoring Plan, background wells are planned to be sampled during the interim groundwater sampling event in 2015 (assuming timing will be such that the samples are not auto-correlated). This page is intentionally left blank. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 17.0 DISCUSSION 92 17.0 Discussion 17.1 Summary of Completed and Ongoing Work To date, the following activities have been completed in support of this CSA:  Installation of 61 groundwater monitoring wells within the ash basin and ash storage areas, beyond the waste boundary, in background locations, and on an adjacent off-site property;  Completion of 2 temporary groundwater monitoring wells within the Primary Cell of the ash basin;  Completion of 3 soil borings in background areas of the site;  Completion of topographic and well/boring location surveys;  Collection of ash samples from borings completed within the waste boundary and analysis for total inorganics, TOC, anions/cations, SPLP, and physical properties;  Collection of soil samples from borings completed within the waste boundary, beyond the waste boundary, off-site, and background locations and analysis for total inorganics, TOC, anions/cations, and physical properties;  Collection of PWR and bedrock samples from borings completed within the waste boundary, beyond the waste boundary, and background locations and analysis for total inorganics, TOC, and anions/cations;  Collection of soil samples for analysis of chemistry and mineralogy;  Collection of rock samples for chemical analysis;  Collection of rock samples for petrographic analysis (thin-sections);  Performance of in-situ horizontal (open hole) and vertical (flush bottom) permeability tests;  Completion of packer tests in 11 bedrock borings;  Completion of rising- and falling-head slug tests in 57 newly installed monitoring wells;  Collection of groundwater samples from 74 newly installed, compliance, voluntary, and previously installed monitoring wells, and analysis of samples for total and dissolved inorganics and anions/cations;  Speciation of groundwater samples for arsenic, chromium, iron, manganese, and selenium in groundwater samples collected from 18 monitoring wells installed along anticipated groundwater flow transects;  Collection of 8 surface water samples, 4 groundwater seep samples, and 9 sediment samples, and analysis for total inorganics and anions/cations;  Speciation of 7 surface water and groundwater seep samples for arsenic, chromium, iron, manganese, and selenium;  Evaluation of solid and aqueous matrix laboratory data;  Completion of an updated Receptor Survey;  Completion of fracture trace analysis; and  Preparation of this CSA report. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 17.0 DISCUSSION 93 The following activities are ongoing (as described in Section 14.1.1) and will be provided in the CSA Supplement:  Analysis of soil samples for chemistry and mineralogy and rock samples for chemistry and petrography;  Evaluation of the need for additional groundwater monitoring wells to better define the horizontal delineation of groundwater beyond Duke Energy property boundaries; and  Additional speciation of constituents found to be in excess of their respective 2L Standards. 17.2 Nature and Extent of Contamination Soil and groundwater beneath the ash basin and ash storage areas (within the compliance boundary) have been impacted by ash handling and storage at the DRSS site as described below. Concentrations of several constituents exceed their respective 2L Standards or IMACs in groundwater beyond the Compliance Boundary. However, the presence and magnitude of exceedances for certain constituents may be attributed to naturally occurring conditions and not necessarily attributed to ash handling at the DRSS site. The extent of the contamination is noted in the following sections. 17.2.1 Groundwater – Surficial Aquifer Arsenic and boron were the primary constituents detected in groundwater at concentrations that exceeded the background concentrations and 2L Standards. Both constituents were detected above the 2L Standards in a three-dimensional area beneath the ash basin and ash storage areas in the surficial aquifer. There are no known exceedances of 2L Standards for arsenic or boron beyond the DRSS property boundary. TDS and sulfate exceeded the 2L Standards in an isolated area east of the DRSS historical site property boundary. Based on the relatively low concentrations of other ash-related constituents in these wells, the presence of TDS and sulfate may not be attributable to groundwater migration from the ash basin. The horizontal migration of boron in the surficial aquifer best represents the dominant flow and transport system. Vertical migration of constituents is generally limited by underlying bedrock. 17.2.2 Groundwater - Bedrock Aquifer Within the bedrock aquifer, three COIs were identified as primary constituents in groundwater: iron, manganese, and vanadium. These COIs were identified as naturally occurring metals in the background wells. Nine other COIs were identified in the bedrock aquifer: antimony, arsenic, boron, chromium, cobalt, selenium, sulfate, TDS, and thallium. These COIs appear in isolated locations and do not appear to have migrated extensively across the site or beyond the compliance boundary. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 17.0 DISCUSSION 94 17.2.3 Groundwater - East of the Ash Basin Based on review of laboratory data obtained from surface water sample SW -3, collected from the unnamed tributary located east of the Secondary Cell, it appears that impacted groundwater has migrated beyond the compliance boundary to the tributary stream east of the ash basin. Aluminum, arsenic, chromium, cobalt, copper, lead, and zinc exceeded 2B Standards in the surface water sample (SW-3). However, the results of analyses of sample SW -6, collected from the Dan River near the confluence with the tributary stream, indicate that the Dan River has not been adversely affected by the water quality at sample location SW -3. A review of constituent data from adjacent well MW -21S is inconclusive as to the correlation of the groundwater chemistry, background well data and the SW -3 results. Within the shallow aquifer, three COIs were identified as primary indicator COIs in shallow groundwater: boron, sulfate, and TDS. Boron, sulfate, and TDS rarely exceeded their respective 2L Standards, but are highly mobile constituents and were observed at higher concentrations within and in the vicinity of the ash basin and ash storage areas than in background and other areas of the site likely not influenced by the ash basin or ash storage areas. Five COPCs were identified as primary risk assessment COPCs due to their widespread presence above associated 2L Standards or IMACs: arsenic, cobalt, iron, manganese, and vanadium. Arsenic rarely exceeded its 2L Standard and did indicate significant migration, but it was found at significantly higher concentrations within certain portions of the ash basin and ash storage areas. Although exceedances of associated 2L Standards or IMACs for cobalt, iron, manganese, and vanadium were detected across the site, concentrations of these parameters were generally similar between areas likely to be impacted and background or other areas of the site likely not influenced by the ash basin or ash storage areas. Four other COIs identified in the shallow aquifer were isolated in specific locations and do not appear to be transported across the site: antimony, chromium, selenium, and thallium. Within the bedrock aquifer, three COPCs were identified as primary risk assessment COPCs due to their widespread presence above associated 2L Standards or IMACs: iron, manganese, and vanadium. Although exceedances of associated 2L Standards or IMACs for iron, manganese, and vanadium were detected across the site, concentrations of these parameters were generally similar between areas likely to be impacted and background or other areas of the site likely not influenced by the ash basin or ash storage areas. Nine other COPCs identified in the deep aquifer were isolated in specific locations and do not appear to be transported across the site: antimony, arsenic, boron, chromium, cobalt, selenium, sulfate, TDS, and thallium. 17.3 Maximum Contaminant Concentrations Maximum contaminant concentrations were determined for ash, soil, groundwater, and surface water based on the results of sample analyses for each medium. These concentrations were used to perform screening-level ecological risk assessments based on the North Carolina Division of Waste Management guidelines (NCDENR 2003). Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 17.0 DISCUSSION 95 COIs evaluated for maximum contaminant concentrations for groundwater included antimony, arsenic, boron, chromium, cobalt, iron, manganese, selenium, sulfate, thallium, TDS, and vanadium. COIs evaluated for maximum contaminant concentrations for porewater included antimony, arsenic, barium, boron, chromium, cobalt, iron, lead, manganese, thallium, TDS, and vanadium. Maximum constituent concentrations are shown on Figure 10-61 and Table10-11. For the COIs identified on the basis of ash basin porewater concentrations, boron is the most prevalent in groundwater with the highest concentration being detected in the surficial aquifer between the ash storage areas at the AS-12S well location. While boron is prevalent at the site, it is limited in area and depth (reference Figures 10-73 through 10-75 and Table10-11). Groundwater affected by boron discharges to the Dan River via groundwater flow and via the unnamed tributary at the SW -3 location. The maximum concentration of boron in soil was detected in a sample collected 34-35.5 feet below Ash Storage 2. The highest concentration of arsenic in groundwater occurs beneath the Ash Storage 1 (reference Figures 10-67 through 10-69 and Table 10-11). The CSA data indicate that arsenic has not migrated in the direction of public or private water supply wells. The highest concentration of cobalt in groundwater was detected in a shallow well (MW -11) within the downgradient dam of the Secondary Cell. Cobalt was also detected in samples from multiple background well locations (reference Figures 10-79 through 10-81 and Table 10-11). 17.4 Contaminant Migration and Potentially Affected Receptors In general, groundwater flows from north to south toward the Dan River. Surface water and sediment sample results from samples collected within the Dan River stream channel did not identify COIs in excess of applicable regulatory criteria. However, laboratory results for surface water and sediment samples collected at the SW -3 location in the unnamed tributary east of and adjacent to the Secondary Cell identified the following COIs above applicable regulatory criteria: arsenic, chromium, cobalt, copper, lead, manganese, thallium, vanadium, and zinc. The presence and magnitude of these COIs indicate potential impact from ash. The human health and ecological SCMs, provided on Figures 12-1 and 12-2, illustrate potentially affected receptors; these receptors will be reviewed and revised as necessary based on the information indicated above. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 18.0 CONCLUSIONS 96 18.0 Conclusions 18.1 Source and Cause of Contamination The CSA found that the source and cause of the contamination for certain parameters in some areas of the DRSS site is the coal ash contained in the ash basin and ash storage areas. The cause of this contamination is leaching of constituents from the coal ash into the underlying soil and groundwater. However, some groundwater, surface water, and soil standards were also exceeded due to naturally occurring elements found in the subsurface. 18.2 Imminent Hazards to Public Health and Safety and Actions Taken to Mitigate them in Accordance to 15A NCAC 02L .0106(f) 15A NCAC 02L .0106(g)(2) requires the site assessment to identify any imminent hazards to public health and safety and the actions taken to mitigate them in accordance with Paragraph (f) of .0106(g). The CSA found no imminent hazards to public health and safety; therefore, no actions to mitigate imminent hazards are required. However, corrective action at the DRSS site is required to address soil and groundwater contamination. 18.3 Receptors and Significant Exposure Pathways The NORR and CAMA requirements concerning receptors were completed and results are provided in Section 4.0. A screening-level human health risk assessment and screening level ecological risk assessment was performed with the results provided in Section 12.0. The identified receptors and significant exposure pathways are identified in the human health and ecological SCMs (Figures 12-1 and 12-2). 18.4 Horizontal and Vertical Extent of Soil and Groundwater Contamination and Significant Factors Affecting Contaminant Transport The CSA identified the horizontal and vertical extent of groundwater contamination within the compliance boundary, and found that the source and cause of the groundwater exceedances within that boundary is the coal ash contained in the ash basin and ash storage areas. The cause of contamination is leaching of constituents from the coal ash into the underlying soil and groundwater. The approximate horizontal and vertical extent of soil contamination is shown on Figures 8-1 through 8-5. Soil contamination is considered to be present where soil analytical results were in excess of the site soil background concentrations or in excess of the soil screening levels protective of groundwater. The assessment found the soil contaminants are composed of iron, manganese, arsenic, chromium, and selenium. The CSA identified the horizontal and vertical Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 18.0 CONCLUSIONS 97 extent of soil contamination, with the exception of off-site areas east and north of Ash Storage 1 (as described in Section 14.1.1). Background monitoring wells contain naturally occurring metals and other constituents at concentrations that exceeded their respective 2L Standards or IMACs. Examples of naturally occurring metals and constituents include cobalt, iron, lead, manganese, thallium, TDS, and vanadium. These naturally occurring metals and constituents were detected in background groundwater samples at concentrations greater than 2L Standards or IMACs. The horizontal and vertical extent of groundwater contamination is shown, with the exception of areas associated with data gaps identified in Section 14.1.1, on Figures 10-64 through 10-102. Groundwater contamination is considered to be present where the analytical results were in excess of the site background concentrations and in excess of the 2L Standards or IMACs. The approximate extent of groundwater contamination is shown on these figures and is limited to an area within the compliance boundary, between the ash storage areas and the Dan River, with the exception of areas associated with the data gaps identified in Section 14.1.1. The CSA found the groundwater COIs to be antimony, arsenic, boron, chromium, cobalt, iron, manganese, sulfate, thallium, TDS, and vanadium. Iron and manganese are constituents that may be naturally occurring in regional groundwater as previously discussed in Sections 10.1.8 and 10.1.10, respectively. No imminent hazards to human health or the environment were identified as a result of the CSA. The significant factors affecting contaminant transport are those factors that determine how the contaminant reacts with the soil or aquifer material, resulting in retention to the soil or aquifer material and removal of the contaminant from groundwater. The interaction between the contaminant and the soil or aquifer material are affected by the chemical and physical characteristics of the soil, the geochemical conditions present in the aquifer (if present), the aquifer materials, and the chemical characteristics of the contaminant. Movement of each contaminant is related to the groundwater flow direction, the groundwater flow velocity, and the rate at which a particular contaminant reacts with materials in the aquifer. The data indicates that geologic conditions present beneath the ash basins impedes the vertical migration of contaminants. The CSA found that the direction of mobile contaminant transport is generally in a southeasterly direction towards the Dan River, as anticipated, and not towards other off-site receptors. North of Ash Storage 1 there is evidence of a northerly flow of groundwater into an unnamed tributary of the Dan River. No information gathered as part of this CSA suggests that water supply wells or springs within the 0.5-mile radius of the compliance boundary are impacted by the DRSS ash basin system. The two primary mechanisms that immobilize metals (iron and manganese) and semi-metals (arsenic, boron, and selenium) and prevent their movement in groundwater are sorption and precipitation (NCDENR 2007a). The major attenuation mechanism for sulfate, a non-metal, is sorption (EPRI 2004). In these processes, the contaminant is in effect removed from groundwater and partitions onto the surface of the soil or aquifer matrix (adsorption) or Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 18.0 CONCLUSIONS 98 precipitates into a solid phase, in both cases, removing the contaminant from groundwater. Many factors specific to the constituent and to site conditions are involved in determining which of these mechanisms occur and how much of the contaminant partitions out of the groundwater. Sections 7.0, 8.0, 9.0, and 10.0 present the results of testing performed to determine the chemical, physical, and mineralogical characteristics of the soil and aquifer materials and the site groundwater. As described above, determination of the mechanism and the amount of contaminant removed from the groundwater depends on several site-specific factors. The adsorptive capacity of the site soils and aquifer materials to the specific groundwater contaminants by development of site-specific partition coefficient Kd terms, as described in Section 13.0. The Kd testing will provide site-specific values for the ability and capacity of site soils to remove contaminants from groundwater and will assist in understanding the mechanisms affecting contaminant transport at the site. The Kd tests and the associated groundwater modeling will also allow for evaluation of the long-term contaminant loading and the capacity of the site soil and aquifer material to attenuate this loading. The results of this testing, the groundwater modeling, and the evaluation of the long term groundwater conditions at the site will be presented in the CAP. 18.5 Geological and Hydrogeological Features influencing the Movement, Chemical, and Physical Character of the Contaminants As anticipated in the initial site conceptual hydrogeologic model presented in the Work Plan, geological and hydrogeological features influencing the movement, chemical, and physical characteristics of contaminants are related to the Piedmont hydrogeologic system present at the DRSS site. Movement of the contaminants is related to the groundwater flow direction, the groundwater flow velocity, and the rate at which a particular contaminant reacts with materials in the aquifer. The CSA found that the direction of the contaminants’ movement is towards the Dan River, as anticipated. The rate of groundwater movement varies with the hydraulic conductivity and porosity of the site soil ranges from approximately 2.5 (saprolite) feet/year to 137.9 (fill) feet/year. These ranges for rock material are from 7.28 X 104 feet/year to 1.02 X 105 feet/year. The geological and hydrogeological features of the site influence the movement of the contaminants by removal of constituents through sorption or precipitation of contaminants. The degree and rate at which these processes occur depend on many factors associated with the solution containing the contaminant and the potentially sorbing soil or aquifer material. These factors include redox conditions, concentration of the solution, chemical composition of the solution and the contaminant, and mineralogy of the soil or rock matrix. The influence of these factors as determined by the chemical, physical, hydrologic, and mineralogical characterization of the ash, ash basin porewater, groundwater, and site soil and rock will be incorporated into the groundwater modeling discussed in Section 13.0. Geological and hydrogeological features at the site do not influence the physical character of the constituents other than through the process of sorption and precipitation. The Kd term development and Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 18.0 CONCLUSIONS 99 leaching tests results, which will be presented in the CAP, will be key to understanding the influences of the site soils and rock on the constituents. The groundwater model will provide information useful to evaluating the capacity of the site soil and aquifer material to attenuate the loading imposed by the conditions modeled for the proposed corrective action. 18.6 Proposed Continued Monitoring A plan for continued monitoring of select monitoring wells and parameters/constituents is presented in Section 16.0 and will be implemented following approval of this CSA report. 18.7 Preliminary Evaluation of Corrective Action Alternatives Duke Energy previously committed to removing the ash in the ash basin and ash storage areas via excavation. Approximately 1.2 million tons of ash will be transported to a lined landfill, as described in Section 2.12. It is anticipated he remainder of ash will be placed into a lined landfill to be constructed in the vicinity of Ash Storage 1. The initial phase of ash removal is scheduled to commence 60 days after all necessary permits and approvals are obtained. Closure of the ash impoundment is anticipated to be completed by August 2019. The soil dams will be removed and the unimpacted material will be used in site re-grading. The depression left in the ash basin after ash removal will be filled with on-site and imported fill material, re-graded, and appropriate vegetation planted to establish a long-term stable, erosion resistant site condition. Based on the results of soil samples and groundwater samples collected beneath the ash basin and the ash storage areas, residual contamination will remain after excavation; however, the degree and persistence of this contamination over time cannot yet be determined. In the subsequent CAP, Duke Energy will pursue corrective action under 15A NCAC 02L .0106 (k) or (l) depending on results of the groundwater modeling and evaluation of the site’s suitability to use MNA. This would potentially require evaluation of MNA using the approach found in Monitored Natural Attenuation of Inorganic Contaminants in Groundwater, Volumes 1 and 2 (USEPA 2007) and the potential modeling of groundwater surface water interaction. If these approaches are found to be unsatisfactory, additional measures such as active remediation by hydraulic capture and treatment, among others, will be evaluated. When properly applied, alternatives such as these can provide effective long-term management of sites requiring corrective action. Duke Energy Carolinas, LLC | Comprehensive Site Assessment Report Dan River Steam Station Ash Basin 19.0 REFERENCS 100 19.0 References AMEC. 2015. Natural Resources Technical Report, Dan River Steam Station, Rockingham County, North Carolina. June 24. American Society of Testing and Materials. 2014. E1689-95, “Developing Site conceptual models for Contaminated Sites,” ASTM International, West Conshohocken, PA, DOI: 10.1520/E1689. 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Ground Water 48.4 (2010): 515-25. Web.) This page is intentionally left blank. Figures This page is intentionally left blank. Tables