NC0005088_1-4 Basin Excavation Soil Sampling Plan_20170302

DUKE
ENERGY,.
March 2, 2017
Mr. S. Jay Zimmerman. Director
Divi!Jon of Wafer Resources
North Car—ulina Departme, it of Ei-ivirnmental Quality
o 1 1 Mail Service Center
Raleigh, NC 27699-1611
Subject: James. F. Rugars EneNy Complex
Units i -zF Inactive /Ash Basin Exceva;ion Soil Sampling Plan
Dear Mr. Zimmerman:
=u sourm MUM" street
mn9u., PC 2M
MWIMV— Address:
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Mai! Cade ECr3x
UnalWft, IVU ,?Bzai-100
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In accordance with the CCR Surface Impoanameni Ciosare Gaiaelines for Protection of
Ground..atu provided by the Diviaiun of Water Rasoarcu3 on NuvGmber 4, 2016, Duke E'nurgy
Garulinas, LLC (DEC) has prepared an Excavation Soil Sampling Plan for the Units 1-4 Inactive
HsM basin at the Rogers Energy Complex. This plan will be utilized to confirm ash removal from
the U,ita 1-41, acti-e Ash Basin and conduit soil sampling that will be incurperated into an
opdsied fate and transpoR groundwater model for Rogers Energy Complex.
If yuo have any questions an the enclosed infurmatian, please cuntact Ryan Ccup at
ryan.czop@tla><e-energy.com or at 980-373-2779.
Respectfally submitted,
D. Edwin M. Sullivan, PE
Director - Waste & Groundwater Programs
Environmental, Health & Safety
Attachment: E,,caveuiun Suii Sampling Plan
Rogers Energy Complex
Units 1-4 Inactive Ash Basin
ecc: Steve Lamar, NCDEQ
Landon Davidson, Ni✓DEu
Larry Frust, NCDEQ
Ed Mussler, NCDEu
Mickey Willuaghby, Dake Energy
Phil Mooney. Dake Energy
Scott Martin, Duku Energy
Ryan Cz-up, Dake Energy

EXCAVATION SOIL SAMPLING PLAN
ROGERS ENERGY COMPLEX
UNITS 1-4 INACTIVE ASH BASIN
FOR ASH BASIN EXCAVATION
NORTH CAROLINA ASH BASIN CLOSURE
DUKE ENERGY CAROLINAS, LLC.
526 SOUTH CHURCH STREET/ECI3K
CHARLOTTE, NORTH CAROLINA 28202
� DUKE
ENERGY,
Waste & Groundwater Programs
Revision 0
March 2017

Excavation Soil Sampling Plan March 2017
Rogers Energy Complex Units 1-4 Inactive Ash Basin Revision 0
TABLE OF CONTENTS
SECTION
PAGE
1.0 PURPOSE................................................................................................................................1
2.0 SOIL SAMPLING METHODOLOGY.............................................................................................1
2.1 Method Summary
1
2.1.1 Equipment
1
2.1.2 Sample Locations
2
2.1.3 Collection of Representative Samples
2
2.1.4 Sample Preservation, Containers, Handling and Storage
3
2.1.5 Decontamination
4
3.0 VISUAL CONFIRMATION OF ASH REMOVAL..............................................................................4
3.1 Pre -Excavation Documentation
4
3.2 Ash Removal Verification Protocol
4
3.2.1 Field Documentation
5
3.2.2 Fill Evaluation Criteria
5
3.3 Visual Removal Not Applicable
6
4.0 SOIL SAMPLING AND ANALYSIS...............................................................................................6
4.1 Soil Sampling
6
4.1.1 Scenario 1
7
4.1.2 Scenario 2
7
4.2 Fate and Transport Modeling
7
5.0 DOCUMENTATION SUMMARY.................................................................................................8
LIST OF TABLE
Table 1- Soil Parameters and Analytical Methods
LIST OF FIGURE
Figure 1 - Rogers Energy Complex Units 1-4 Inactive Ash Basin
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Excavation Soil Sampling Plan March 2017
Rogers Energy Complex Units 1-4 Inactive Ash Basin Revision 0
1.0 PURPOSE
The purpose of this Excavation Soil Sampling Plan is to provide a standardized method for collecting soil
samples at Duke Energy North Carolina ash basins that are to be closed via excavation. Soil samples are
being collected following all visible ash removal from certain ash basins or other management units
referenced in Coal Ash Excavation Plans to support closure activities.
This Excavation Soil Sampling Plan is applicable to the collection of representative soil samples. Analysis
of soil samples may be chemical or physical in nature and may be used to determine the following:
• Extent and magnitude of constituent occurrence
• Input concentrations for groundwater fate and transport model
The methodologies discussed in this Excavation Soil Sampling Plan are applicable to the sampling of soil
in ash basin excavation areas. For the purposes of this plan, soils are those mineral and organic
materials remaining after all visible ash has been excavated.
2.0 SOIL SAMPLING METHODOLOGY
2.1 Method Summary
This Excavation Soil Sampling Plan has been adapted from Environmental Protection Agency (EPA)
Standard Operating Procedures (SOPS) #2012 and #2006; and North Carolina Department of
Environmental Quality (DEQ) Attachment 1 Coal Combustion Residuals Surface Impoundment Closure
Guidelines for Protection of Groundwater, November 4, 2016.
Soil samples are collected directly using stainless steel or plastic trowel, spade, shovel, or scoops.
Following collection, soil is transferred from the sampling device to a stainless steel or plastic bowl to be
homogenized. Once homogenized, the soil is transferred into Duke Energy Laboratory supplied sample
bottles.
Soil samples will be submitted under chain of custody for the proper analyses dependent on two
scenarios described in Section 4.1 below. Analytical methods for total metals and SPLP metals are
described in Table 1. Ash presence is quantitatively determined by polarized light microscopy (PLM) by
RJ Lee Laboratory (or other approved vendor). PLM analysis passes visible light through a pair of
polarizing filters to create optical effects used in identifying unknown materials. This method is
commonly used in asbestos and coal ash identification.
2.1.1 Equipment
• Stainless steel or plastic trowel, scoop, spade or shovel — used for collecting soil samples
from surface locations.
• Sample containers —To be supplied by Duke Energy Laboratory with appropriate
cooler(s). Estimated that 5-8 ounce samples bottles with Teflon -lined lids will be
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Excavation Soil Sampling Plan
Rogers Energy Complex Units 1-4 Inactive Ash Basin
March 2017
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required for each sample location and sample depth. For return of cooler to the lab, ice
will be required.
• Gloves — used for personal protection and to prevent cross -contamination of samples —
nitrile, disposable, powderless.
• Field clothing and Personal Protective Equipment — used as specified in the site Health
and Safety Plan.
• Sampling flags — used for identifying soil sampling locations.
• Field notebook — a bound book used to record progress of sampling effort and record
any problems and field observations during sampling.
• Three-ring binder book — used to store necessary forms and record and track samples
collected at the site.
• Permanent marking pen — used to label sample containers, document field logbooks,
data sheets and chain of custody.
• Stainless steel or plastic spoon — used for homogenizing soil samples within a stainless
steel or plastic bowl.
• Stainless steel or plastic bowl — used for homogenizing soil samples, when applicable.
• Camera — used for photo -documentation of sample locations and samples.
• GPS — device used to obtain elevation, latitude and longitude of sample location.
• Trash bag — used to dispose of gloves and any other non -hazardous waste generated
during sampling.
• Decontamination supplies and equipment.
2.1.2 Sample Locations
General locations for soil sampling are determined by the soil scientist in the field at a rate of
one soil sample for every 1 acre of ash basin area excavated. Actual sampling locations on-site
may vary to account for site conditions and to allow collection of representative samples.
Representative samples reflect areas where all ash has been visually excavated and natural soil
is observed.
2.1.3 Collection of Representative Samples
For the purpose of this plan, discrete surface soil samples are considered to range from 0 to 6
inches in depth while deeper subsurface soil samples will be collected at a range of 2 to 2.5 feet
below ground surface (bgs), 7 to 7.5 feet bgs, 12 to 12.5 feet bgs and 17 to 17.5 feet bgs (unless
bedrock, refusal, or the water table are encountered). A surface soil sample and deeper
subsurface soil samples will be collected at each location for every 1 acre of ash basin excavated
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Excavation Soil Sampling Plan
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March 2017
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when following Scenario 2. A new pair of nitrile gloves is worn at each sampling location and
each depth. Each sampling location is recorded on the site map prior to collecting the sample if
location is not already noted on the map. The GPS location of each sampling location (i.e.
elevation, latitude and longitude), sample descriptions, and area photographs are also recorded.
All sampling equipment is decontaminated prior to use irrespective of depth. The following
procedure will be used to collect representative soil samples with a scoop, shovel, trowel,
geoprobe or excavator:
• Locate general sampling locations.
• Determine suitability of sampling location for a representative sample.
• If sampling location appears to reflect representative conditions that would allow
collection of a representative sample, proceed with sampling procedure. If
location is not indicative of conditions that would allow collection of a
representative sample, notify the project manager so an alternate location can
be identified.
• Using a decontaminated sampling instrument, remove the desired thickness and
volume of soil from the sampling area. The sampler must obtain enough soil to
fill five 8 -ounce sample bottles.
• Transfer the sample into an appropriate sample or homogenization bowl. Non-
dedicated containers should be adequately decontaminated. Stir for
approximately one minute until there appears to be a uniform color and
consistency.
• Transfer homogenized sample to a labeled container(s) of appropriate size and
construction for the analyses requested.
• Secure sample container tightly.
2.1.4 Sample Preservation, Containers, Handling and Storage
Chemical preservation of soils is generally not recommended. Cooling to 4°C on wet ice is
usually the best approach, supplemented by the appropriate holding time for the analyses
requested.
The Duke Energy Laboratory will supply the appropriate sample bottles for the collected soil
samples. The sample volume is a function of the analytical requirements and the Duke Energy
Laboratory will ensure the appropriate number of bottles are supplied. Ensure chain of custody
is completed for sample bottle return to the Duke Energy Laboratory.
Table 1 contains a list of parameters to be analyzed with corresponding reporting units and
analytical methods. If a parameter or group of parameters is not included in Table 1, the
laboratory performing the analysis should be contacted to determine the appropriate sample
bottles, volumes, and preservatives.
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Excavation Soil Sampling Plan March 2017
Rogers Energy Complex Units 1-4 Inactive Ash Basin
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All non -dedicated sampling devices should be decontaminated and wrapped in plastic. The
sampling device should remain in this wrapping until it is needed. Each sampling device should
be used for only one sample and then decontaminated or disposed of. Non dedicated sampling
devices should be cleaned in the field using the decontamination procedure described below.
2.1.5 Decontamination
Decontamination procedures can be time consuming; having a sufficient quantity of sampling
tools available is recommended. All non -dedicated sampling equipment must be
decontaminated prior to reuse. Equipment decontamination consists of:
Detergent wash and brush cleaning
Tap water rinse
Deionized water rinse
Air dry
Wrap sampling tools with plastic
3.0 VISUAL CONFIRMATION OF ASH REMOVAL
3.1 Pre -Excavation Documentation
Closure by removal is defined herein as removing the primary source (primary source of potential
constituents of interest) to the point that ash is not visible to the unaided eye at the ground surface.
Primary source ash is the main body of ash that was deposited in the basin. This method is intended
solely to verify and document primary source ash removal and is not intended to validate environmental
quality standards of the subsurface (considered the secondary source of potential constituents of
interest). Pre -excavation documentation would consist of:
• Review topographic mapping, aerial photography, construction drawings, and boring logs to
estimate the pre -ash placement topography and/or ash/soil interface
• Preparation of an ash basin figure illustrating a grid spacing of 100 feet (Figure 1). Each grid
point (node) will be assigned a unique identifier. Each node of the grid spacing (grid point) will
represent a visual verification location.
3.2 Ash Removal Verification Protocol
Ash excavation will be considered complete based on visual confirmation that all ash has been removed.
Ash removal will be based on sampling of the ash/soil interface and analysis by PLM. Soil samples will
be examined utilizing methods outlined in American Society for Testing and Materials (ASTM) D2488,
Standard Practice for Description and Identification of Soils (Visual -Manual Procedure). Vertical and
horizontal excavation of ash can terminate when the remaining material can be documented using PLM
to contain less than SO% ash.
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Excavation Soil Sampling Plan
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Project will excavate ash until a visible change in color or texture confirms removal. This location shall
be referred to as the ash/soil interface. If visual evaluation is inconclusive, then request additional
evaluation to confirm ash removal.
3.2.1 Field Documentation
Evaluate the excavated surface elevation relative to the pre -ash placement topography.
Periodically check bottom elevation to evaluate if fill is present above historic bottom elevation.
Visual confirmation will be performed on a 100 foot grid system (Figure 1) unless conditions
prevent such confirmation, as described in Section 3.3. Soil sampling will be performed on an
acre grid system and will be analyzed using PLM.
• Personnel will locate each node by GPS or survey control, determine elevation and
evaluate whether that point is above or below the historic bottom elevation.
Personnel will then observe the surface area represented by the node to note if visible
ash is present at the surface. If present, the location should be documented and
excavation will need to continue. If the evaluation indicates the surface soils are
residuum or bedrock, then hand auger to two feet below surface (or refusal) and
perform visual -manual classification of the soils at the surface and depth according to
ASTM method D2488. Submit sample from surface and depth (or shallower if refusal)
for PLM analysis. The conditions shall be documented by taking photographs.
The classification indicator for fly ash will be grey to black silt -sized particles with no
plasticity. The classification indicator for bottom ash will be grey to black sand to gravel
sized particles and porous. If the material can not be positively identified as soil, submit
a sample for PLM analysis.
If the node point elevation is near the historic bottom elevation and either (1) residuum
is indicated by observation or (2) soil is confirmed by visual manual classification (ASTM
D2488) and PLM analysis is less than 50%, then personnel can conclude the primary
source is removed.
3.2.2 Fill Evaluation Criteria
The following procedure provide an approach that can be used to ascertain if the fill can remain
in place. The procedure specified is based on the fill material and depth.
• If the elevation is less than eight feet above the historic bottom elevation and residuum
is not observed, then test pits may be excavated to historic bottom elevation or until
residuum or bedrock is encountered but no more than eight feet below the surface.
o Personnel will evaluate existing information to determine if the test pits are
necessary. If necessary personnel may recommend excavating test pits at a
frequency no tighter than 100 feet by 100 feet.
o If visible ash is not discovered based on information defined above, then the
primary source removal may be confirmed.
o If visible ash is discovered, then continue excavation.
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Excavation Soil Sampling Plan
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March 2017
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• If the elevation is more than eight feet above historic bottom elevation and residuum is
not observed, discuss with CCP Closure Personnel.
o CCP Closure Personnel will confirm historic information and recommend a
drilling and sampling program at a frequency no tighter than 100 feet by 100
feet to evaluate the presence of ash below the fill in accordance with the
information defined above. If unusual features are revealed by the drilling, CCP
Closure Engineering may request/recommend additional borings. Exploration is
to be performed by continuous sampling during drilling.
o If visible ash is not discovered based on information defined above, then the
primary source removal may be confirmed.
o If visible ash is discovered, then continue excavation.
3.3 Visual Removal Not Applicable
If possible, excavation of ash should continue even if groundwater is encountered. Visual
documentation cannot be completed where ash is under the water table. If Duke Energy cannot
complete visual removal because of site conditions or other restricting factors, documentation shall be
presented to DEQ.
Duke Energy anticipates that in locations where visual documentation cannot be completed, additional
ash characterization along with groundwater fate and transport modeling will be completed. Ash
characterization may consist of SPLP and/or other testing with results imputed into an updated site wide
groundwater fate and transport model. Details will be provided to DEQ for review and concurrence.
4.0 SOIL SAMPLING AND ANALYSIS
4.1 Soil Sampling
Soil sampling of the remaining soils (less than 50% ash per PLM analysis) will be necessary to evaluate
the extent of potential secondary source depending on the depth of the water table and any proposed
institutional or engineering controls that may be used in the area of excavation. Soil sampling will not
be required if refusal or the top of bedrock are encountered or the remaining soils are below the water
table. Soil samples for laboratory analysis must be collected in a manner that will ensure a relatively
uniform distribution of particles throughout the six inch sample.
The systematic approach and design for soil sampling an analysis is dependent upon two scenarios:
• Scenario 1: Remaining soil (containing less than 50% ash per PLM analysis) is located above the
seasonal high water table and final constructed institutional and/or engineering controls will
restrict infiltration from the surface reaching the water table (e.g. installation of a liner system).
Scenario 2: Remaining soil (containing less than 50% ash per PLM analysis) is located above the
seasonal high water table and infiltration from the surface would continue to reach the water
table.
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Excavation Soil Sampling Plan
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4.1.1 Scenario 1
March 2017
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Confirmation sampling will include discrete surface samples collected from the first six inches of
the soil. Sampling will be performed on an acre grid system. This sample collection
methodology shall be sufficient to characterize the horizontal extent of any remaining potential
secondary source impacts for comparison with the DEQ Preliminary Soil Remediation Goals
(PSRG). The samples shall be analyzed by a North Carolina certified laboratory for total
concentrations for the following parameters: antimony, aluminum, arsenic, barium, beryllium,
boron, cadmium, calcium, chloride, chromium (total and hexavalent), cobalt, copper, iron, lead,
magnesium, manganese, mercury, molybdenum, nickel, nitrate as nitrogen, pH, potassium,
selenium, silver, sodium, strontium, sulfate, thallium, vanadium and zinc. No SPLP testing is
required.
4.1.2 Scenario 2
Confirmation sampling will include collection of both discrete surface and subsurface soil
samples performed on an acre grid system. Discrete surface samples will be collected from the
first six inches of the soil and a subsurface soil sample will be collected at 2 to 2.5 feet below
ground surface (bgs), 7 to 7.5 feet bgs, 12 to 12.5 feet bgs and 17 to 17.5 feet bgs unless refusal,
bedrock or the water table are encountered. The use of a geoprobe or excavator is anticipated.
This sample collection methodology shall be sufficient to characterize both the horizontal and
vertical extent of any remaining potential secondary source impacts for comparison with the
DEQ PSRGs and/or input into the soil leachate model. The samples shall be analyzed by a North
Carolina certified laboratory for both total concentrations and SPLP for the following
parameters: antimony, aluminum, arsenic, barium, beryllium, boron, cadmium, calcium,
chloride, chromium (total and hexavalent), cobalt, copper, iron, lead, magnesium, manganese,
mercury, molybdenum, nickel, nitrate as nitrogen, pH, potassium, selenium, silver, sodium,
strontium, sulfate, thallium, vanadium and zinc.
4.2 Fate and Transport Modeling
Contingency for stabilization of remaining amounts of potential secondary source impacts in a manner
that will meet the intent of North Carolina Groundwater 2L Rules and closure requirements shall be
considered as site conditions dictate. Provisions to develop groundwater flow and transport models to
evaluate protection of groundwater criteria if some secondary source impacts are left in place shall be
considered. In addition, the possibility of metals leaching from a potential change in pH and
geochemical conditions related to dewatering and excavation shall be considered along with plans for
groundwater models to assess resulting site conditions.
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Excavation Soil Sampling Plan March 2017
Rogers Energy Complex Units 1-4 Inactive Ash Basin Revision 0
5.0 DOCUMENTATION SUMMARY
100'x 100' Grid Node (Figure 1) Visually confirm primary source removal and document with
photographs
Soil Sample Collection at a Grid Node (1 Per Acre)
Depth/Test
PLM
Total Metals (Table 1)
SPLP (Table 1)
0— 6 inches
X
X
X
2' — 2.5'
X
X
X
7' — 7.5'
N/A
X
X
12'— 12.5'
N/A
X
X
17'— 17.5'
N/A
X
X
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Excavation Soil Sampling Plan
Rogers Energy Complex Units 1-4 Inactive Ash Basin
Table
March 2017
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Excavation Soil Sampling Plan
Rogers Energy Complex Units 1-4 Inactive Ash Basin
TABLE 1
SOIL PARAMETERS AND ANALYTICAL METHODS
TOTALS AND SPLP ANALYSIS
NORTH CAROLINA ASH BASINS TO BE CLOSED
VIA EXCAVATION
March 2017
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INORGANIC COMPOUNDS
UNITS
METHODI
Aluminum
mg/kg or µg/I
EPA 6010D
Antimony
mg/kg or µg/I
EPA 6020B
Arsenic
mg/kg or µg/I
EPA 6020B
Barium
mg/kg or µg/I
EPA 6010D
Beryllium
mg/kg or µg/I
EPA 6020B
Boron
mg/kg or µg/I
EPA 6010D
Cadmium
mg/kg or µg/I
EPA 6020B
Calcium
mg/kg or µg/I
EPA 6010D
Chloride
mg/kg or µg/I
EPA 9056A
Chromium
mg/kg or µg/I
EPA 6010D
Cobalt
mg/kg or µg/I
EPA 6020B
Copper
mg/kg or µg/I
EPA 6010D
Hexavalent Chromium
mg/kg or µg/I
EPA Method
7199/218.7
Iron
mg/kg or µg/I
EPA 6010D
Lead
mg/kg or µg/I
EPA 6020B
Magnesium
mg/kg or µg/I
EPA 6010D
Manganese
mg/kg or µg/I
EPA 6010D
Mercury
mg/kg or µg/I
EPA Method
7470A/7471B
Molybdenum
mg/kg or µg/I
EPA 6010D
Nickel
mg/kg or µg/I
EPA 6010D
Nitrate as Nitrogen
mg/kg or µg/I
EPA 9056A
pH
SU
EPA 9045D
Potassium
mg/kg or µg/I
EPA 6010D
Selenium
mg/kg or µg/I
EPA 6020B
Silver
mg/kg or µg/I
EPA 6020B
Sodium
mg/kg or µg/I
EPA 6010D
Strontium
mg/kg or µg/I
EPA 6010D
Sulfate
mg/kg or µg/I
EPA 9056A
Thallium (low level) (SPLP Extract only)
mg/kg or µg/I
EPA 6020B
Vanadium
mg/kg or µg/I
EPA 6020B
Zinc
mg/kg or µg/I
EPA 6010D
Notes:
1. Soil samples to be analyzed for Total Inorganics using USEPA Methods 6010/6020 and pH
using USEPA Method 9045, as noted above (or similar approved methods). Soil samples will
also be analyzed for leaching potential using SPLP Extraction Method 1312 in conjunction with
USEPA Methods 6010/6020 (or similar approved methods).

Excavation Soil Sampling Plan
Rogers Energy Complex Units 1-4 Inactive Ash Basin
Figure
March 2017
Revision 0

Excavation Soil Sampling Plan
Rogers Energy Complex Units 1-4 Inactive Ash Basin
Figure 1— Rogers Energy Complex Units 1-4 Inactive Ash Basin
March 2017
Revision 0
FIGURE 1 1
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