NC0000396_60 BOD comments response_20170803

*:!� DUKE
ENERGY,
Aagast 3, w I r
Mr. S. Jay Zimmerman, Director
Divisio, of Water Resoorc;es
North Carolina Department of Environmental wuality
1611 Mail Service Center
Raleigh, North Caraiil la 2 1699-1551 i
Subject: 30 Basis of Design Report Comments
Aahvvift Steam Electric Plant
Dear Mr. Zimmerman -
us Soeln cmaran stoat
Mail Coue EC i 33R
%rlarloue, Rortn Carolina zBz02
'350-3/3-3/1y
In lotions dated July in, e01 r and July et, e01 i, DF—U documented comments from their re„ iovy
of the 60% Baa;a vi Design (BOD) package fur the Asheville Interim Action Plan. Dake h orgy
vvith assistance from our consaltant, has prepared the enclosed respunses to clarify our
interpreta, ion of the comments and how ..e intend to addrus3 sauh a,vmment.
If yua have cur,iiiionts and/or questions, please direct them to me at 980-373-3719.
Sir,Lerely,
D. Edwin M. Sullivan, PE
Director – WaD,to & Groundwater Programs
Environmental, Health a Safety
Cc: Landon Davidson – ARO Regiumal Office Supervisor
Ted Campbell – ARO Regional Office Hydrogeologists
Steven IM. Santer – DW R Hydrogeologist
Jim Wella – Duke Energy
John Tuepfer – Dake Lnergy
Kevin Kirkley – Duke Energy
Enclosed, Response to Comments

Response to DEQ Comments
Bass of Design Reyo t (50% ubmittaI)
Asnevillr 5tea��, Eiect.ic Plant
August 2017
1. The Division recognizes tnat the proposed interim action is intended to
aur�nt, and not reFlace, corrective action required in LaANCAC 02L .0106.
The interim action activities (groundwat4r extraction) should, w:th;n the Dou.
be placed in the context of a corrective action or partial corrective action undor
02L.0106. The BOD should (a) state the subsection of 02L.0106 (for example:
(1)_ and (or) (m)) that is being used to address the target contamination if
ay . i ne expectation is that the proposed interim action, coupled with the
future corrective _coon, wall lead to full compliance with 02L .0106 for all
con. tituents and that adherence to an refevanr suosecdons of Ozu will be
demonstrated within the CAP.
Response: Appropriate text will be included in Section 1.1 of the BOD to clarify regulatory
context.
2. Basis of Design Report (BOD) should state wnethvr ad erse ecological impacts_
if any, are expected because of the pnj used groundwater extraction syste.., aTiu
the basis for this expectation.
iesponse: z)ecdon i.1 uesign Considerations will be revised to include discussion of
potential adverse ecotog:c.i .*...r.acts. The wetlands complex in downgradienr areas of the
Site will be the focus of discussion. Pump:..g tv.t reswus and long term predicted
hydraulic head simulations from the flow and transport model will be usal to zurporr no
adverse ecological impacts are expected from the operation of the designed system.
3. 1 ne DVu should explain whether and how the interim action will address all
constitue,.ts or u.terest �C.�x�. rather than a subset of COIs. If the proposed
groundwater extraction system is ..ot I..tei-mea to address all Cots_ a section of
the BOD should explain what additional remediation efforts are coi-acmpiated
and the conditions under which they would be implemented in any additional
corrective action. For example, Page 1-1 states that T, Cl, Co, Fe, Mn, Se, SO4,
TDs, and V have been identified as constituents occurring at levels above 2L or
iMAC. n, Cl. Suzi, and t uS impact which have the potential to migrate beyond
the compliance boundary a..0 oaf site, wid be the focus of remedial efforts."
While the Intzrim Action may focus on B, Cl, SO4, ar-.d i uS, ate DUu should
acknowledge that Co, Fe, Mn, Se, and V must also be mmediated a..d that the
CAP (not the BOD) will address these. The Division recognizes that
conservative- poorly-sorptive constituents like B, Cl, and SO4 will tend to move
off sire most rapidly- but 02L,0106 compliance is expected for all constituents.
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Response to DEQ CUL111itents
Bays un ue5ign RUFurt (60'io S.D... ittal) August 2017
AshEvI E! StEMIL Electric Plant
Response: Section 1 of the BOD will be revised to clearly explain the purpose of the interim
action and the constituents (i.e., constituenis within solution in groundwater and within
the area of influence of the systems that will be addressed by groundwater extraction.
Groundwater extraction na3 beep, aei«re l as ine interim action to provide sufficient
hydraulic control to reduce migration of source area constitueTts 1.; -.to tnc urcu of interest
and remove constituent mass from the area of highest observed concentrations.
Groundwater beyond the area of influence will be discussed in the Corrective Action Plan.
zj. The bulk auenuarion rare discussed on page 2-2 was computed using an
inapprop.:ateiy deteaa..�Tieu slope .at -e �m). instead of using boron
concentrations from monitor wells al%ng a plume io–gitudiT.ai ce..cenine to plot
and compute the slope as dlvs�ribed in the referenced EPA method (EPA1540TS-
01/500, page 10), the report plotted and used boron concentrations from monitor
wells that were side gradient and (or) screened across various, sometimes
uncontaminated flow units. The failure to properly apply and compute the bulk
attenuation rate should be corrected in the BOD. Comment 7 below discusses
the need for additio..ai i..o..:toi- -ells.
Response: The wells included on Figure 2-1 were based on their location within the boron
plume. The plume maps used to select the wells are Figures 1-18 through 1-20 from the
Asheville Steam Electric Plant CSA Supplement 1 (SynTerra, August 2016) and Figures 21
and z.L from
Stea... Glect..e Yll .<<r Amen, ryr, march t/, if,lir raira_ er. al. We agree ihat MW -13 cluster
should not have been included. but excluding them does a.ot aiter the conclusion. relying
on the balance of the wells is appropriate given the database and the assumptimis
necessary in preparing any groundwater transport model. The isoconcentration lines
implied within Figures 21 and 22 are concentric around the source areas and thus it is not
necessary to have wells precisely on a curve linear flow transect, although we agree that
these locations are preferable. Discussion of the bulk anenuarion rate will be removed
from the BOD and Te-evaivateu iouo..ing the addition of monitoring wells at the Site. This
analysis would be more appropriatety discussed :., ruturc CSA aucamenrs.
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Resp;unse to DEQ t�omme-,ts
Buvi3 z f DI -,sign Report (60% Submittal) August 2017
Aat,uvine Sten. Eizaric Plant
S. Page 2-3 States that "The foll-M ,, ing solutio.. to me advecrive-dispersive
equation (with a source area) provides downgradiunt concentrations aio..g me
centerline of a plume (Domenico, 1987)". The report attributed differences
between computed and observed bornn values to "differing levels of dilution
than anticipated in the model" and these were related to the variable hydraulic
conduct:7ky. ivo mention was made to the fact that the selected equaMion was
designed to predict co;-.ce«rracions in porous media and along a plume centerline,
and that the wells used to meaaur boron are eithe. beri.ock wells kand
unconnected to the centerline plume rn.�.$) or are side gradient wells not
Positioned along the plume centerline. The equation is not applicable to
concentrations observed in the monitor wells that currently exist. The BOD
should be corrected.
Response: We aMowieFige that tilt E4LJ?!tiOii is MI Fniuua mGLlia. Fate u.Z!
transt,ort mvQcI3 gcncrally use a similar parrial differential equation. We Chose an
equation that has an analytical solution, whereas the work by Falta, Et al. (2017)
uses a ttutIlEli%al tCLnn;.luz. 5ume tractm eQ rvz:K environments exhibit properties
sufficiently similar to porous media so that the solutions PrUviae ieasonable
estimates of head arta concei th ation. In et t v ii ni m ei et5 SimilBi to Amnc v llle, the
saF.wite, hin-mtinn, rima PvvR u.dts often exhibit porous media properties. As rock
becomes less fractured these tate and transport models ptoviae less ac=ate
estititates vt hCaa a��C! ei,�t�cx�t�ation. lnz Jesuits Fro,,iauE ay Fuitn auffi`kntly
Ixtcn irrrimZi c;,nd;ti-Mns so that the assumption concerning the applicability of
porous media equations appears valid — they piovi& reasmaible Cstitseates. lnus,
we cmitiiiue tv Uelicve that tn;n cyunt;Orc }.rvvZuus renaz.nable estimates of in -field
cz;ncentration. As stated in the response to Continent 4. discussion of advecrive-
dispersive flow will be removed from the BOD and ie-evuiz._r a following the addition of
monitoring wells at the Site. This analysis would be more appropriately discussed u. ruruiz
CSA documents.
6. i ne t0u does not need to discuss or address constituents such as Ba, Ca, Mg,
Zn, etc. that do iwr occur above z_L/hviAC (see the fourth bullet on page 2-5).
The BOD should fw. .-s on B, Ci, Co, re, ivin, ae, �04, i uS. and v _ and discuss the
factors that have been shown (by actual site data, F -T modelv.g, anu
geochernical modeling) to cuntrvi their downgradient occurrence. The
expectation is that these factors be well understood and that the BOD or future
corrective action plan describes these cvntrvls in detail using data from the
sozi.ce area itself and how the proposed corrective action will address them.
Response: The text will be revised to reflect this comment.
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Reespouse to DEQ Comments
Basis ut Dea;gn ReFmt (6070 5.omittai) August 2017
A5ncvilw Stemit Eizcttic Plm7t
7. Current monitor wells are insufficient to map the boron plume or other COIs
emanating from the source area and migrating to the 12 -acre offsite parcel and
beyond. A requesr for additional wells was discussed during the June 30, 2017,
meeting at me mooresville megional Office between Duke and the Division.
Agreements reached du"lig the i .eerh.£, rr-baMing the :nsrariarion of additional
wells and installation schedule should be carried out az part of ongoing
assessment, accelerated remediation, and CAP efforts at the Asheville Plant.
Response: Additional well locations were discussed during a June 30, 2017 meeting at the
iviooresv3le neg:onai Office. Additional email correspondence dated July 21 2017 from
Campbell to Toepfer summai:-es Fns ubrc�u upon aaa:rional well locations, uiscussion of
additional assessment activities will be provided in the Comprene..s:ve 5:tv A;53c3. 7 .cnr
document.
8. The BOD appendices should contain a copy of the boring logs from all wells used
to map boron in the source area.
Response: Boring logs of referenced wells will be included in 90/100% BOU
9. Boron isotope sampling was proposed (CSA Addendum, SynTerra, 2016) to help
evaluate whether boron concentrations in supply wells west of the French Broad
rdver are associated with coal ash (to date_ two wells contain unexplained
anomalous bo.o.. co..ce..tr-rioa.$). Ammowgn airemare water has been proposed for
these wells, the area west of the river is still considered a future use area roe
purposes of 2L .0106 compliance. The BOD Should include a section describing the
boron isotope sampling effort to date. This section should include a map of receptor
survey supply wells and a list of the monitoring and supply wells that have been
sampled for boron isotopes. For supply wells that were not sampled, please state
me reason for example. well owner declined_ well owner was unable to be reached_
well has been abandoned, etc.).
Response: Boron isotope sampling is beyond the scope of the Interim Action Plan and
Accelerated Remediation Basis of Design report and is more appropriately discussed
within the sire wide Comprehensive Site Assessment documents.
10. Section 8. 1, System Performance Meti-:cs, page 8-l. 1 nu tsOU states rnar r- r
simulations indicate "noticeable" concentration reductions in the vicinity of EA1-0r
within 5 years of system start up. To help assess the groundwater extraction
system (and F -T model) performance, the BOD should provide a set of stacked
concenrradon-tithe plots of boron for each modeled layer at the following
locations: CCm-i01. CCrc-ruz-_ MW -9_ CB -8_ EXT -01_ MW -16_ MW -17_ A-1 (seep)_
B -.t (seep, and at cei-aei-, c.sr,.m cage of iz acre parcel. The x-axis (rime) should
extend out to the time it takes for concei-Aiatto..s to drop oeio.. the LL stannaru of
700 u at each location.
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Response to DEQ Commenis
Basis rif Design Repot t (60% SubL1Littal)
Asheville Steam FleCtriC Plaits
August 2017
._..,.�
response: Stacked concentrafion-time plots can be provided as requested in the final BOD
us:.,., varpwt u..tw from the current tfviarch Alu) flow and transport model. Updated
stacked concentration -time plots can be evaiz; .tcti u..a ,,.coy pvra1eC1 :n10 the Corrective
Action Plan after future revisions to the groundwater model. JI
11. Page 8-1 includes a list of wells that are proposed to be sampled quarterly. This �
list should also include new well MW-170BR, MW -17A, CCR-IOI BR, CCR -1025,
CCR-1'uz-0, CClt-0ou'CCA.-1UMA, and areas of wetness B-01_ MH -17_ I'W-F-
and C-01. IfMW-170BR does not co..tau. detcctaole concentrations of boron
after 2 sample rounds, Duke may contact the Regional Office for a reduced
samvline freauencv for that well.
response: These locations are currently (or will be) part of IMP to be monitored quarterly.
1 nu fc--C . Ar ne revised to include listed wells (if applicable for new wells following
installation).
12. On Page 8-1, daily water level measurements throughout the first quarter Uf
operation are proposed for a list of 5 bedrock wells (MW-8BR, MW-9BR, CCR-
IOI BR_ MW-16BR_ and MW -18BR) and the French Broad River. To assess the
:ntturconnecdvity of wells and flow units in this area this list should also include
MW -17A, Tie.. 1-1 cu rvrvv-li0tsr, new well ivtvv-1 Su dor, if ivivv-i5u is dry. MW -
16A), CCR -102D, CCR-103BR, and MW -9D.
Response: The Eext will be revised to include listed locations.
Response: A meeting has been requested by the Asheville Regional Office to discuss the
model domain and boundary conditions prior to additional revisions or updates to the
rto.. ...o transport model.
"The Rrs;onal Office requests a rneering wire uuKe ana ire modelers ro discuss rhe model
domain and model boundary conditions. Th;3 m.trn&; Zhould occur before the remainin-
rnmmenis below are addressed or tncorpora'ed into a revi3rd model report Tnot expected in the
BOD)...
Comments regarding Appendix C will be discussed during the request(A meeting
(scncZl_teU on august z__ 24/) and appropriate revisions to the model can be incorporated
into the final Corrective Actio.. ria...
Response: A meeting has been scheduled with the Asheville Regional Office to discuss
Appendix D comments. Select comments relevant to the startup and operation of the
groundwater extraction system will be addressed in the final BOD as indicated below.
Remaining comments will be addressed within a revised geochemical modeling report
within the Corrective Action Plan.
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Response zo DEQ ComuieiIts
Basis of Dez igt, RCp�-,rt (60% Suiii.itt:vt) August 2017
Asheville 5tecutt Electric Plant
1. The report would benefit from the development of conceptual geochemical
models for the two Northwest and West Transects that start in the ash basin and
exrena downgradient from the source. The geochemical models should explain
the inte.act;ons bvrween ute groundwater and the solid phases in the aquifer that
produce changes in pH, Eh, and g.oana. aver concentrations.
These processes could then be incorporated into PHREEQC geochemical models
to demonstrate the ability to simulate current site conditions along flowpaths.
The validated models could then be used to esti,JLtate how conditions might
cnange :n response to the proposed accelerated remedial alternatives. This would
provide support roe the qu-nitariv. a conclusions developed in the report from
evaluations of Asheville site data and data rroa.. outer similar facilities.
Response: In Section 2 of the report we have provided a description of the ion
concentrations in water as a function of pH for all measurements at the site as well as a
r1:;5cwss;on of pr -i, r ri' and ion concentradons along the two transects. In revised
documents, we wiu uuu aaa.*tional discussions with an explicit conceptual model of the
geochemistry along these transects. Our.a.viiet aevelopment for PHREEQC modeling
which includes sorption, redox, complexation, and precipitat:o...eucr;ons for all input
constituents is discussed in an accompanying appendix. Due to the numerous
assumptions made in the PHREEQC model including an assumption of equilibrium rather
than kinetic control of rhe system and the fact that ferrihydrite and gibbsite have been used
as pm--ics vrpr:on reactions, it is unlikely that we will have quantitative agreement
between our model simulations ai-A me measured groundwater concentrations. Thus, our
goal is to simulate trends in the data rather than enpl:cit coa.centradons.
2. Page 1-1_ first paragraph. 'Boron, chloride, cobalt, iron, manganese, selenium,
sulfate. total dissolved solids (TDS), and vanadium are the primary focus within
the focuseu area of interest. This report highlights five select constituents from
that list: bc;run, chloride, :roa., manganese, and sulfate. These select constituents
were chomn because of their elevated ...omi;ty anti concenrrarions in the area of
interest at the Asheville Plant." Given their elevated levers .. ny .. ere covalt,
splenium, and TDS not also evaluated!
nesponse: While r t.,S is a useful measure of the total concentration of all ions in the
system, our efforts rot inesc geochemical models focus on rhe geochemistry of specific
constituents, and as such we have limited our El;:3cu:;s;on of overall TDS. Cobalt and
selenium will be incorporated into the revised site -wide Gevcnem;cal modeling iwport to
accompany the CAP.
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Response to DEQ Comments
Basis �,t Dusign Re},r,.t (bu 0 SULI.Atell) August 2017
Asheville 5tuam EluctLic Plant
3. Page 2-1, last paragraph. In the general observations of pH/EhluO, it would be
useful to point- out that some of the highest pH values and lowest EhwO values
are associated with samples of the ash pore water. This represents the source
area or potential groundwater contaminants and needs to be considered in
developing the conte tuui ,amem:cal model for this ash basin.
Response: We agree additional discussion would be informative to the conceptual
geochemical model for this ash basin. While the transect figures (Figure 2-6 and 2-7) are
Intended to illustrate the pH and Eh trends along each transect, a statement regarding the
pH1r,t,7uO t.e.xin In the ash pore water and its relation to rhe conceptual geochemical
model for this ash basin wilt be ;..etuuca :n the rinal Geochemical Model in the CAP. This
will include explicit modeling along transects wn;,n vzir I.—le :n me ash basin and thus
will incorporate the pHlEh trends in the pore water measurements into the rrn -,trQC
model.
4. rage to the discussion of groundwater concentrations of select constituents, -S
would be be..er;d;at to .elate concentrations not only to pH_ but also to locarions
relative to the ash basin tbackgrou.-Ld, asn poae..arer, aowngradienr near and far
from a basin).
nesponse: We agree that it would be beneficial to relate concentrations of constituents to
toc.rons relative to the ash basin. Section 2.1 will be revised to incorporate this comment
within the Focused GvoU-.em;cal report i-4orth and West of 1964 Basin in the Final BOD
Report.
5. Page 2-3, third bullet.
u. 'i.nror:ue and sulfate concentrations are highly variable but generally
increa=with prn trigure Lz4j."The increasing trend with pH is not apparent in
the figure, especially for sulfate, wn;cn n -s ;ts n;gnest concentrations at the
lowest pH values.
a. With a majority of the B and Mn species forming anionic complexes " In the
prn range shown in Figure 2 -a -the dominant boron species is B(OH)3, which is
a neutral spec;es, and the dominant manganese species is likely Mn2f-which is
a cation, not an anion. Note tnat the lust nutter on tris page states that ivin is
dominantly Mn(II) present as a cation. The B and Mn Pou.ba;-^ a;uga-ms
shown later in the report does not show anions as the dominant species in the
H range of interest.
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Response -to DEQ Comments
Basis of ue5ign Repot (60"No Submittw) Aµbuat 2017
Abheville Steam Elects r! Platt
Response:
a. A ext will be revised ro incorporate this comment within the Focused Geochemical
Report North and We.t ur i9f&l Dasin :n the rinal DOD Report.
b. Text will be revised to incorporate this comment within the Focused GCeencm-Cai
Report North and West of 1964 Basin in the Final BOD Report.
6. rage z --j_ fourth bullet. 'Below pH 5, sorption of the neuually charged H3B03 or
a.uo.,:c ricD03 complexes likely reduces the aqueous concentration (Figure 2-5)."
This figure shows that at pH a..d be;o.., !—Imsr of the dissolved boron
concentrations are similar to those at higher pH values (neap t, OOO ug/L). it is not
apparent that boron adsorption is having an effect on dissolved concentration.
The pKal for H3B03 is 9.2 meaning that at a pH of 5 the concentration of H21303 is
about 10.500 times less than that of H31303. Consequently, anion adsorption is
provaDly nor an im orrant attenuation process for boron at acidic j2H values.
Response: As the reviewer points out the anionic complex is prese..t ut a io.� concentration
at low pH values. We added this discussion of the anionic deprotonated species H2BO3-
primarily because that is the sorbing species predicted by the surface complexation model.
However_ the sorbed species still represents only a small fraction of the total boron and the
ma;ority remains in the aqueous phase. We will modify this statement accordingly in the
Focused Geoenv,..ic_i rceporr worth and West of 1564 Basin in the Final BOD Report,
7. Page 2-5. How do groundwater flow directions compare to the two chosen
transects? In other wordb, is a flowpath being followed from the ash basin to
downgradient locations? If nut, then comparing two locations along a transect is
nor useful in identifying eochexnical reaMons in theaquifer.
Response: As stated in the first sentence on page z-5, --(In.) two rivw transects were chosen
to investigate the 1964 ash basin's influence on the subsurface environment along
hydraulically significant flow paths (Figure 1-1)." The hydraulic gradient in the area of
concern (AOC), downgradient of the 1964 ash basin, is predominantly west and northwest
in the direction of the French Broad River. The two chosen transects begin at the ABMW-
0c wcu ctwsrer (within and beneath the source area) and continue to the west and
northwest along potential rfo.. turn.. in tnis scenario the riDMW-01- well cluster
represents the groundwater chemistry and subsurface geocnc.a,:z;r.y for entire 01M ash
basin.
We will update the Focused Geochemical Report North and West of 1964 Basin in the Final
BOD Report to explicitly state these flowpaths begin in the ash basin and move
downgradient, vvarer level maps will be provided to further illustrate groundwater flow.
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Response -Eo DEQ Comments
Basis of Design Reps► t (607o Sul) «aittal) August 2017
Asheville 5teaut EI[CtLiL Plant
8. Page 2-6. first paragraph. 'In general, along transects at the Asheville Plant, pH
and Eh increases slightly (Figure 2-6 and Figure 2-7). "The observation that the pH
increase along the Transects is apparently based on comparing pH values in the
saprolite beneath the usn basin with those downgradient. The opposite: conclusion
would be reached comparing ash po.e ..arca Yn wI.M aowngradienr prt values. In
these cases, the pH decreases away from the basin. Bucause the asn poa,u w.rer
better represents the contaminant source than the saprolite, comparisons to ash
ore water characterisics better represent contaminant flow paths.
Response: The cites tc--r ..:u ae revised to incorporate this comment within the Focused
Geochemical Report North and West of 19b4 in me rinal nvu iwporr.
9. Page 3-2, first paragraph, last sentence. "...conditions that could contribute to
susrained concentrations include dispersion and a lack of sorption or precipitation
onto mineral surfaces." How does dispersion conr.ribute to sustained
concentr-dunsr uispersion along a flowpath usually results in lower
concentrations.
Response: Cited text will be revised within the Focused Geochemical Report North and
West of 1964 Basin in the Final BOD Report. Our intent was to indicate that diffusion of
boron into pore spaces followed by a slow release after bulk pore water concentrations
have decreusca could result in a sustained concentration or a typical "diffusion Lail".
10. Page 3-2, second paragraph, second sentence. ''While boron :s a., a.uo.. _J3 YYIAt
be more attracted to mineral surfaces at lower pH values..."As shown in Figure 3-
.i -boron exists in groundwater at this site primarily as the neutral species H3B03.
i he anionic species of boron is not important from an adsorption standpoint
be�a—ase of its low concentration in groundwater.
Response: Similar to comment 7 above, we added this discuss:o1i or tn,-- an:on:c
deprotonated species H2BO3- primarily because that is the sorbing species predicted by
the surface complexation model. However, the sorbed species still represents only a small
fraction of the total boron and the majoriiy remains in the aqueous phase. We will modify
tn.s z;rurvment accordingly in the Focused Geochemical Report North and West of 1964
Basin in the Final BOD
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Rest,unse to DEQ cuutiueuts
Buis or Du3ig. R�rort (66"No 5.. r)uaittul) August 2017
Anne v ilio 5temi, Elerti is Piant
11. Page 3-6, Figure 3-6. This figure plots boron adsorption onto HFO and HAO
versus the aqueous anionic boron species H2B03. Why wasn't the dominant
aqueous boron species H3B03 used in this figure? Was total aqueous boron used
to calculate boron Kds or'ust the H21303 s ecies?
Response: The total boron concentration was used to determine the Kd values. S:,..11-1 to
what was described in our responses to comments 7 and 11, above, we were attempting to
highlight the sorbing species of boron. We will revise Figure 3-6 in the Focused
Geochemical Report North and West of 1964 Basin in the Final BOD Report to indicate the
dominant aqueous boron species and clearly describe the minor amount of sorption
occurring from the rerariveiy row abundance anionic surface complex.
12. Page 4-1, second paragraph. The mineral ferrihydrite is incorrectly spelled au
ferrihydrate. Also hematite rarely, if ever, precipitates from groundwater, thus,
it does not control theaqueous iron concenuadon.
response: i nc ie..t 11.11 D= a�.;;5CZ1 to incorporate tnis comment within the rocused
Geochemical Report North and West of 1964 tsas:n in the r:.,ui DOu Kut. opt.
13. Pages 4-1, last paragraph and 4-3, first paragraph. 'The higher Fe concentration
(in CB -06) can be attributed to the more acidic conditions (pH 3.6) present during
the January_ 2016 sampling event. 'The groundwater fluctuations in the alluvial
floodplain around the time of pri decrease were significant enough to cause soil
aeration resulting in sulfide ox:datio—." Wneae :s..olr t D-uttr oval
groundwater extraction associated with remediation likely lower the water table
a similar amount, also potentially resulting in the production of acidic conditions
in theaquifer?
icespvnse: vve have examined other wells which were impacted by the basin dewatering
.acrir;tic� to :f :,..:rua rr�.m...c.c vD.crvcu. in weir M345 an increase :n
dissolved sulfate and iron was also observed along with the decrease in pH. Thus, we
attributed this to sulfide oxidation. However, if the decrease in pH was due to some other
phenomena (we are currently evaluating alternatives) then the increase in iron and sulfate
could be due to mineral dissolution or ion desorption that is not linked to redox processes.
Thus_ we attempted to find similar trends in other wells including CB -1_ CB -9_ GW -1, CB -2_
Cn-sic'Co-4 '
Co -4, M3=4D, CD -o, Cn-o but these wells all maintained relatively stable pH and Eh
values compared with well CB -6. Therefore, we believe this behavior '.., wen CD -S:.
anomalous and are discussing potential reasons for the anomaly. It is potentially
noteworthy that this area lies along the French Broad River and has been significantly
impacted by cycles of inundation and drying due to repeated attempts to control beaver
activity.
i'u of III
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Rebl,vllbe to DEQ Cv111u1c11t5
Bzms ur Deign Rz:,,z;rt (50% 5ubmittal) August 2017
Asn -lc vAIE 5tEa111 ElEr.tric P[e.,t
14. Page 4-2, Figure 4-1. Comparing the locations of the global Eh valuta %n this
figure with the locations on Figure 3-1 (page 3-1) for boron, it appears that the Eh
values for the iron figure are significantly lower than 5h-vwn un the boron figure.
For example_ Figure 4-1 shows one Eh value near the lower wafer stability
po�.naar . nereas ri re j-1 does nor show any values near this boundary.
Response: The figure will be revised to incorporate this comment within the Focused
Geochemical Report North and West of 1964 Basin in the Final BOD Report.
io. rage xi -o_ second paragraph. 1-iowever_ if cobalt concentrations are not
sutra:�..riy n:gn, nemante ka - re/47o) is expected to be the dominant phase
(Figure 4 - 4). "Aa mentioned in co.....�e��t 10, nematire ..:u not typxcatly form in
aquifers. Ferrihydrite is the more common prG-.ipitate that limits dissoivea :row..
Hematite should not be included as a potential iron -forming mineral on the
P-vurbaix diagrams, including Figures 4-4 and 4-5.
Kesponse: i nanx y oz; for this commenC. vve were identifying only the most saturated
phases but will inco.porate tnis co...T..u..t :n inc -.C-..sed sire -wide iaeochemical modeling
Report to accompany the CAP.
16. Page 4-3, last paragraph. "For ferrous iron minerals, Ferroselite is predicted
using the components in Table A - 12 with the addition of 1 x 10 - 6 mol/L total
re (rigure 4 - 4)." rrovide the formula for the mineral ferroselite (FeSe2) to Show
that it is an iron-seie� LAuT.-L ai-L .e; ai.
Response: We appreciate that recommendation and will include the ferroselite formula in
the Focused Geochemical Report North and West of 1964 Basin in the Final BOD Report.
I i. rage zi-o, oruy paragraph. 'r or both transects associated with the 1964 ash basin
at Asheville (Figure 4-6), iron exhibits a decrease «, concentration wah distance
from the ash basin. "Discuss the possible geochemicai reaso..s roa this dccrc-se in
concentrations. What processes are occurring! Can they be related to pH/Eh
changes and mineral control on dissolved iron! What iron minerals have
saturation indices close to zero for the water samples'? Why are the transition
zone samples so high in iron at the down radient end of the West TranaCct?
Response: These are all excellent questions and observations which will b� una.C.3V17.n
the revised site -wide Geochemical Modeling Report to accompany the CAP. We note that
our revised geochemical model explicitly considers iron saturation as a control on the
abundance of sorbing HFO surfaces, which is germane to the comment above.
,1 of JL8
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to Commentsk'60�IDEQ.130CX

Rebpanbe to DEQ C ommentb
Basin of Dva;g�, ReF ,.t (507o 5uamittai) August 2017
Astlevillu Stuma, Ejeezt, is Plztnt
18. Page 5-1, second paragraph.
a. 'Under the Eh and pH conditions of the groundwater at seven sites
evaluated for global consideration_ Mn(II) is the dominant oxidation state
(rlgure o-.L)."rigure a -r does not show any global data.
b. The titles for Figures 5-1 and 5-1 -ppea. to ve reversed.
Response: The text will be revised to incorporate these comments within the Focused
Geochemical Report North and West of 1964 Basin in the Final BOD Report to reflect
conditions ar rhe Asheville Plant. Specifically the text will state "Under the Eh and pH
ce..7;r1%7T­ or me groundwater at the tksheville Plana Mn(II) is the dominant oxidation
state (Figure 5-1). "
19. Page 5-1, last paragraph. "It is noteworthy that the Pourbaix diagrams ieadu.g to mese
conclusions are based on a system with a total manganese concentration of 0.5 ppm k9
x 10-6 mol/L)." Why weren't actual groundwater Mn concentrations used to create the
rourbaix diagrams for manganese? The Figure 5-2 plot of monitoring well locations
.-Ould be .,tore useful If actual well data were used for all the sampling arameters.
Response: These Pourbaix diagrams were tart of our --global" modeling c toi-c done to
identify the extremes in pH and EH where changes in constituent speciation may occu..
Since many of the constiMents do not form complexes with background ions, the changes
in speciation will be minimal and the effects of changes in pH and Eh are more important.
t ne<<rore, w,_- felt'.[ was appropriate to use the average global data. For the Final BOD
report we will select or average site-speelilc Clara to calibrate new Pourbaix diagrams to
represent site-specific geochemical conditions.
20. Page 5-3. Transect Model Analysis. Suggest calculating manganese mineral
saturation indices with PHREEQC using a=al groundwater data for each
sampi.ng Location to determine if any Mn minerals might be in equilibrium with
the groundwater and potei-ai.n., rm`dng aissolved concentrations a some
locations.
Response: This is an excellent suggestion. We will include graphs plotting PHREEQC
predicted saturation indices for various Fe and Mn -oxides along each transect and the
associated discussion in the revised site -wide Geochemical Modeling Report to accompany
the CAP.
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Response i0 DEQ Cummen><s
Basis ut Design Report (6U% Submittal) August At/
Asheville Steam Electric Plant
21. Page 6-1- last paragraph. "It is noteworthy that the Na+ and Cl- concenrrarions were
fixed ar mmal/L each when generating The rourbaix diagrams �rigure S-1)...", now
does this chloi-ide co..ce..tratioTi co...pare with actual groundwater levels Why
weren't actual levels used in the plotse
Response: The concentration of Na+ and Cl- must be fixed when generating the Pourbaix
diagrams. To cover a range of concentrations would require generating multiple diagrams
that are nor particularly informative due to the low complexarion affinity of Cl- ki.e._ the
spec:anon tTv,--s nor ��b..:r�u..tly �P[u,.be r.:rn Ci- in. 1-4u+ a..d
Cl- concentrations used are comparable to those in many regions along the Northwest and
West transects except in downgradient transition zone and bedrock wells where Cl -
concentrations can reach several times higher.
22. Page 6-2_ first paragraph. "Chloride concentrations at rhe Asheville sire may be
relarea to the recentl,, a ccommissioi7ma. -o�.structel rretia;-.ds syste.�.s u, the
northwest portion of the 1964 basin formerly u5 -.d to treat FGD water." Why would
decommis3ioning of the wetlands systems cause chloride levels to increase in
groundwater? Are there any data showing elevated chloride in these wetlands?
Response: Elevared levels of chloride are associated with the constructed wetlands used to
treat r�;u blowdown. Additional discussion of the wetlands removal, ash stacking, anti
aynamic site conditions will be incorporated into the Focused Geochemical Report North
and West of 1964 Basin in the Final BOD Report to address this comment.
23. Page 7-1, second paragraph. 'Thus is can be expected that Se(VI) will be present in
the site groundwater under high reducing conditions." Se(VI) will be present under
highly oixidizing conditions, nor reducing conditions.
Response: The text will be revised to incorporate this comment within the Focused
Geochemical Report North and West of 1964 Basin in the Final BOD Report. Specifically
the text will state "Thus, it can be expected that Se(VI) will be present in the site
groundwater at highly oxidizing conditions (high Eh)."
14. rage r-2, Figure 7-1. The first note for this figure needs to be corrected to specify
the appropriate diagrams.
Response: The text will be revised to incorporate this comment within the Focused
Geochemical Reporr North and West: of 1964 Basin in the Final BOD Report.
25. Page 8-1, third paragraph. 'When precipitation of mineral phases is allowed in the
GWB simulations, the mineral barite (BaSO4(s)) is predicted to be a dominant
mineral phase under oxidizing conditions. "It is highly unlikely that barite would
limit dissolved sulfate concentrations. Its presence on the Pourbaix diagram is an
artifact of the choice of an artificially high barium concentration (05 mg/L) in the
groundwater.
is or 15
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Response to DEQ COiuiiiCitts
Bmi3 vt Deaign REt,u. t (60% 5ugmittal) August 2017
Astievinu 5team Ewctiic Pett
Response: The concentration of barium in groundwater is inversely ietutea to the
concentration of sulfate in groundwater along the flow transect at the Asheville site. Th:s
is an observation that has been made at ocher sites as well, where the flow and transport
...oavicr. were having trouble with their sensitivity analysis when modeling sulfate in
areas associated with h:gn our:z... concentrations. We can include diagrams in revised
site -wide Geochemical Modeling Report to accompa..y [ne CHr which are generated with
lower total Ba+2 concentrations to demonstrate this influence.
co. Page 8-3. last bullet. 'Thus, in groundwaLers with sufficiently high concentrations
OF tna+c, formation of barite could limit the aqueous #,:oncemration of sulfate (Figure
8-5). 'Because the ba.—.um source to groundwater is almost always much less that
the sulfate source, barite formation. usuurty i:m:cs the barium dissolved
concentration, not the sulfate concentration. GypsuT.. Is tn= moa a common mineral
that limits dissolved sulfate.
response: Thank you for this helpful comment. We will clarify that both barite and
gypsu..i iffitua�,ce a'ssoived sulfate concentrations in the revised site -wide Geochemical
Modeling Report to accompany the CAr. in' - wall include a comment that gypsum
primarily controls the sulfate concentration but that we ave a clear inverse relationship
between barium and sulfate concentrations.
z-/. rage a -n_ only paragraph. "Similar to chloride, sulfate concentrations in GW -3
:..ci-eusca r.om the January tan mg/L) to the April (310 mg/L) 2016 sampling events."
Provide reasonable sce..a-:os for rnis increase in sulfate concentration.
Response: Additional discussion of concentration trends and dynamic site cui7ialdans wilt
be incorporated into the Focused Geochemical Report North and West of 1964 Basin in the
Final BOD Report to address [his comment.
]:;of ]8
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Reap—Unau to DEV Comments
Basis tit Design ReNort (60% Submittal) August 2017
Asheville Steam Electric Mani
z8. rage 9-1, first paragraph. "As discussed above for both the flow transect models
and the global model, the pH and Eh of the system are the p.:mury factors which
could increase or decrease the mobility of a constituent. Removal of ash from the
basin has the pote..tiui to increase the redox potential of the system through the
introduction of oxygen. It is unclear how ash removal could influence the pH.
However_ based on observations in wells surrounding the 1982 ash basin
before, during and artei- i3ewarering and ash removal efforts_ the pH is not
expected to have any significant change post remedial activities and the Eh its
expected to fluctuate with only a slight increase overall." Comments on these
assumptions:
a. Figure 2-6 shows that the measured ash pore water pH (7 to 8) is much
more alkaline than that of groundwater in the underlying saprolite (pH
about zi). rt is likely that the ash pore water is neutralizing the
groundwater i.. me aquifer immediately beneath the ash_ thereby
producing the more neut.ai tri -� -mas io to 5) in transition zones
downgradient from the ash basin (Figure 2-6). Removing the asn ...ay
reduce this neutralizing effect and lower the pH in the aquifer to
significantly more acidic conditions beneath and downgrad ient of the ash
basin. This possibility should be considered in predicting the mobility of
aq-:fer constituents of interest that may be mobilized by removing the
ash.
b. Page 4-1 d6cussed the occurrence of acidic g.ou..dwute. �pn i./)
measured in CB -06 and attributed the low pH values to exposure of soil
sulfide minerals to molecular oxygen that oxidized the sulfide to sulfuric
acid. If sulfide minerals are present beneath the ash basins because of low
nh conditions caused by the ash_ wouldn't removal of the ash expose those
suirdr- T.-ii..�.ats to molecular oxygen producing sulfuric acid and low pH
conditions!
c. The presence of low Eh conditions (50 to 100 mV) in the a -3h po.ewate.
was shown in Figure 2-7 It is possible that removing the ash will have a
significant effect on Eh in the aquifer immediately beneath the ash basin
and should be considered in estimating future geochemical conditions
ana consdruent mobility.
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Rcaj,vr[3c tas DEW Cz;..ux[ts
Basis of Design Report (60% Submitral) August 2017
Asheville Steam Electric Plant
iwspor se: We appreciate thc.0 act..'Aca ea.,.m=nr anu considerations of the data. We
have proposed sulfide oxidation as a potential explanation of the incaeasc :., tn. o<«<<.se
in pH, and increase in dissolved iron and sulfate in well CB -06 as discussed in our reply to
comment 14 above. However, we have noted that we believe this to be an anomaly that
needs further consideration. The changes in pH and Eh are certainly the primary controls
on constituent mobility in these systems. Therefore_ we have performed a "global"
ii-mact:..T, c;;crc,9a cons:tier:ng me prx and uh ranges from multiple sites as a means of
understanding how changes in pH and Eh will influence tn� ...oD:l:ry of consr:ruents. This
modeling effort has allowed us to generate qualitative conceptual models describing the
influence of changes in pH and Eh that could be the result of the ash removal discussed in
the comment above. Using this conceptual model to interpret the site-specific transect
models is the basis for these comments. Addressing this comment will add a level of detail
to the conceptual and/or quantitative geochemical model that we were not targeting at this
pn.se. Wn:ie it win :..pTo7c o-.c.an mouciing efforrs'we do nor feel it is a critical
addition at this time prior to starting remedial activities. Thereto.e, wc .. ali r.roT..Ile a
detailed response to this comment and an appropriate modification to the revised site -wide
Geochemical Modeling Report to accompany the CAP.
1-y. rage 7-t_ paragraph /-. "t% groundwater extraction well system will result in
enn—ccd grout..u.. -ter remo. at YY n:cn w1f generate a hydraulic gradient and
bring in waters from further up the flow path at a raster rate." i ne graCllent
generated by groundwater removal will be the result of lowering the water table
at the extraction wells. How much will the water table be lowered! Exposing the
aquifer in the drawdown area to soil gas with molecular oxygen may result in a
significant increase in Eh. What will be the effect on constituent concenuadons of
ae.� aterine a vordon of the aquifer beneath and adiacent to the ash basin?
Re,punse: As noted in our response to comment 29, we are considering these changes fr-.
Eh as part of a global modeling effort to understand the potential changes in contaminant
mobility that this comment is addressing. As noted in our reply to comment 14, we have
data from several wells influenced by dewatering activities which have introduced
dissolved oxygen in a similar manner to that described above and the pH and Eh of those
syste...s rea..a:., reiutivoiy MtuDic. vvc urs currenriy examining these data to determine if
this is due to a natural buffering of the system or due to tnc iucx or a vign:ficanr amount of
sulfide minerals to facilitate the decrease in pH upon sulfide oxidation to sulfate. A
detailed discussion of this analysis will be provided in the revised site -wide Geochemical
Modeling Report to accompany the CAP.
A of -t8
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RGap:,nau tz; DEV Comments
Basis of Design Report (ba%. Submitral) Augµat 251
Asheville Seam Electric rIant
30. rage 10-1, first bullet. 'Boron, chloride, manganese, and sulfate are relatively non-
reactive species under the Eh and pH conditio,w, in the area proposed for
accelerated remediation. "Sulfate may not be non-reactive in the area of
accelerated remediation if the ash basin has created subsurface reducing conditions
that have allowed for the formation of sulfide minerals. if sulfide minerals are
present in the remediarion area and those minerals arc oxidizva by towering the
water ravle or bringing in o-.yg�T_ted gaoundwater from upgradient, then the
sulfate concentration may increase considerably and the pH may become highly
acidic. If acidic conditions are generated, manganese and iron minerals will
become more soluble resulting in higher Mn and Fe groundwater concentrations.
Response: This is an excellent comment that highlights exactly me ry,,Cv of 3cc..ai-ios we
are considering in o -r Z;pz1utc!7 r,tov.t ...o21ci. Again, this model is aimed at developing a
qualitative understanding of contaminant mobility, such as the increase in dissolved Mn
concentrations due to lowering the pH of a system as noted in the comment above.
Addressing this comment will add a level of detail to the conceptual and/or quantitative
geochemical model that we were not targeitng at this phase. Therefore_ we will provide a
detailed response to this comment and an appropriate modification to the finat
geochemical model in the revised sire -wide Ccocnc...:cai iviodeling Report to accompany
Enc CRr.
31. Page 10-2, second bullet. "TDS at the Asheville site is dominated by sulfate along the
west transet't and chloride along the northwest transect." It is not clear why TDS is
mentioned in the Summary section. TDS is mentioned in the introduction kpage i -i)
as a component of primary focus_ but is not discusser :n the ..•«a.. body of the report.
Marify me im o-raTicc or i uS to tn:s discussion.
Response: While TDS is a useful measure of the total concentration of all ions in the
system, our efforts in this BOD report have focused on the geochemistry of several key
constituents. Since our focus has been on rhese specific constituents_ we have limited our
discussion of overall TDS. It is mentioned in this case to norc me aO...1T;ai-.ce of one ion in
particmar.it noun n Cali vut of context. We will remove this comment from the
rlTial BOD report and keep our focus on the behavior of specific ions.
17 of 18
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Real,-Unse to DE—W t-umments
Basis of Design Report (6U% Submittal) A,.�Tu5t 2017
Asheville Steam Electric Planr
32. Page iO-..� rrst paragraph. 'The two primary remedial alternatives in the area of
interest at the Asheville site are coal ash re...ovui From the lyM basin and
installation of a groundwater extraction system northwest of the 1964 basin.
�.,i en these proposed alternatives, pH is not expected to have any significant
change post remedial acti-�itir-s -n:re Eh is expected to show a slight increase
overall." Comments on these conclusions:
a. Add a caveat that, it suiflae minerals are present in the remediation zone,
oxidation may have a large impact on pH.
b. What is meant by Eh is expecrea ro show a slighr increase? How big an
increase might be expected! What is the basis for estii-.-.atu.g oruy a
sliizhr Eh increase?
Response: Thank you for this helpful comment. We will add the cu.,--ar noted above and
also include our discussion regarding the observations of the changes u. rn rrom multiple
wells including C13-1_ CB -9, GW -1, C13-2, CB -3R, CB -4, CB -413, CB -5, C13-8 which were
influenced by dewatering activities. In the Focused Geochemical Report North and West of
1964 the r:nal nOu rceporr we will rake the average Eh before and after the
dewatering activities and provlau - quanritadve estimate of the range of Eh values
expected. This will allow us to evaluate how the put,...Eai changes in Eh values will
influence constituent mobility as discussed above regarding our 6ir Dai model.
-1 is or 115
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