HomeMy WebLinkAboutNC0001422_FPA Assessment Tech Memo Final_20180629TECHNICAL MEMORANDUM
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Work Plan\FPA\FPA Assessment Tech Memo Final.docx
Date: June 2018 File: 1026.108.49
To: John Toepfer (Duke Energy)
Cc: Kathy Webb (SynTerra)
From: Perry Waldrep
Subject: Soil and Groundwater Assessment – Former Process Area – L.V. Sutton Energy
Complex
Duke Energy Progress, LLC (Duke Energy) owns and operates the L.V. Sutton Energy
Complex (Site) located on approximately 3,300 acres near Wilmington, NC. The Site
started operations in 1954 with three coal-fired boilers that primarily used bituminous
coal as fuel to produce steam to generate electricity. Ash generated from coal
combustion was originally stored on-site in the 'former ash disposal area (FADA)', also
known as the ‘lay of land area’, then in the 1971 ash basin (old ash basin), and finally
the 1984 ash basin (new ash basin). These ash storage areas are referred to as the ash
management area. Additionally, there is an area known as the Former Process Area
(FPA) located adjacent to the southeast corner of the 1971 basin which contains CCR
and CCR-like solids. The Site ceased burning coal in November 2013 and switched to
natural gas for electricity generation, thus the facility no longer generates coal ash.
Groundwater and soil assessment activities for the FPA are described herein.
Regulatory Background
In 2014, The North Carolina General Assembly passed the Coal Ash Management Act
(CAMA). CAMA required owners of a coal combustion residuals (CCR) surface
impoundment to conduct detailed assessment of site groundwater within and around
the CCR surface impoundment. In 2015, the United States Environmental Protection
Agency (USEPA) signed a CCR rule requiring all CCR disposal facilities to establish a
groundwater detection monitoring plan.
CCR groundwater monitoring wells were installed in 2016 near the southwestern edge
of the former process area. Historical data are also available from two previously
existing, nearby downgradient monitoring wells. Boron, an inorganic constituent that is
commonly used as an indicator of CCR impacts to groundwater, has been detected
above background concentrations in these wells near the FPA. Additional assessment
of the FPA also identified vanadium as a potential constituent of concern. Further
assessment is warranted so that the FPA can be incorporated into a Corrective Action
Plan (CAP) for the Site.
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Site Description
The FPA is a small settling basin which was used when the plant was co-firing fuel oil.
The FPA measures approximately 250 feet by 150 feet with concrete-lined side walls
and a concrete divider, which was subsequently filled with solids including CCR and
solids which have chemical signatures similar to CCR. The approximate FPA boundary
is shown on Figure 1.
Former Process Area Assessment Objectives
Objectives of the FPA assessment include the following:
Characterize inorganic constituents associated with FPA soils
Characterize inorganic constituent concentrations in shallow groundwater
underlying the FPA and along the FPA perimeter
Compare inorganic constituent concentrations in FPA groundwater to
downgradient well concentrations as well as Site background concentrations.
Historical Investigations
There have been two separate assessments of the FPA, both performed by Geosyntec.
An investigation in 2014 included soil and groundwater sampling from seven locations
surrounding the perimeter of the FPA (Geosyntec, 2015). A subsequent investigation in
2015 took soil samples from six locations inside the footprint of the FPA (Geosyntec,
2016). The assessment outlined in this work plan will incorporate data reported in both
of these reports.
Soil Assessment
Eight locations will be sampled and analyzed for inorganic parameters to define the
horizontal delineation of soils in the vicinity of the FPA. Analytical results on samples
collected from borings performed during the Geosyntec assessment, both within and
along the perimeter of the FPA, indicate CCR impact. Soils will be collected at
proposed monitoring well locations (FPA-1 through FPA-4) as part of well installation
activities. Unsaturated soils will be collected at four locations (FPA-4 through FPA-8)
around the perimeter of the FPA. One proposed sample location (FPA-1) is within the
footprint of the FPA (Figure 1).
Soil samples will be collected at approximately 2-foot intervals to the top of the
groundwater table. Within the FPA, samples will be taken two feet above the basin
floor, two feet below the basin floor, and two feet above the water table. The
unsaturated soil samples will be analyzed for inorganic parameters as listed on Table 1.
Additional soil samples will be collected below the water table within the new wells
screened intervals; these samples will be analyzed for hydrous ferric oxides (HFO) and
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hydrous aluminum oxides (HAO) to support the geochemical modeling effort. Please
note, SPLP analyses were conducted during the previous Geosyntec assessments and is
therefore not included in this workplan. Additionally, uranium and radium have been
assessed at locations upgradient (TW-46, TW-132, TW-136) and downgradient of the
FPA (MW-19, MW-21C, MW-22B/C, MS-28B/C) with no detections above standards,
therefore these constituents are not included in this workplan.
Groundwater Assessment
Eight former process area (FPA) groundwater monitoring wells are proposed to
characterize FPA groundwater. One upper surficial (“B”), and one lower surficial
(“C”),groundwater monitoring well (FPA-1B/C) will be installed within the FPA
footprint. FPA-1B/C will be located on the west side of the concrete divider. Six wells
(FPA-2B/C, FPA-3B/C & FPA-4B/C) will be installed downgradient of the FPA.
Proposed approximate FPA well installation locations are shown on Figure 1 and
proposed well details are provided as Table 2. Well installation procedures will be
consistent with ongoing CAMA assessment activities in accordance with the Revised
Groundwater Assessment Work Plan (SynTerra, December 2014). As such, shallow wells
are proposed to be installed so that the top of the screened interval is positioned
approximately 5 ft. below the water table, where practical, to avoid potential issues
such as biofouling and introduction of artificial redox conditions which are common
among monitoring wells with screened intervals that bracket the water table. This
approach for well screen intervals was outlined in a May 18, 2018 email (and
subsequent teleconference) from Duke Energy to NCDEQ. NCDEQ responded via
email on May 23, 2018 supporting the proposed technical approach and rationale
concerning these procedures.
Specific well locations may be shifted depending upon access and field conditions at the
time of installation. Groundwater samples will be analyzed for inorganic constituents
consistent with ongoing CAMA assessment activities (Table 3.)
Former Process Area Assessment Report
A former process area assessment report will be prepared once all soil and groundwater
sample analytical data is received. The report will include the following components:
1) Site History and Source Characterization
2) Site Geology and Hydrogeology
3) Evaluation and interpretation of analytical results. Existing Site data will be used in
this evaluation
4) Conclusions and Recommendations
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In addition to the FPA Report, the data collected will be included in the Corrective
Action Plan Update.
ATTACHMENTS
Table 1: Soil Analytical Methods
Table 2: Proposed Former Process Area Assessment Soil Samples and Monitoring Wells
Table 3: Groundwater Analytical Methods
Figure 1: Proposed Monitoring Well and Soil Boring Locations
Soil and Groundwater Assessment – Former Process Area June 2018
L.V. Sutton Energy Complex
P:\Duke Energy Progress.1026\108. Sutton Ash Basin GW Assessment Plan\49.Former Process Area Assessment-
Work Plan\FPA\FPA Assessment Tech Memo Final.docx
ATTACHMENTS
TABLE 1
SOIL ANALYTICAL METHODS
L.V. SUTTON ENERGY COMPLEX
DUKE ENERGY PROGRESS, LLC, WILMINGTON, NC
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Tables.xlsx Page 1 of 1
INORGANIC COMPOUNDS UNITS METHOD
Aluminum mg/kg EPA 6010D
Antimony mg/kg EPA 6020B
Arsenic mg/kg EPA 6020A
Barium mg/kg EPA 6010C
Beryllium mg/kg EPA 6020B
Boron mg/kg EPA 6010C
Cadmium mg/kg EPA 6020A
Calcium mg/kg EPA 6010C
Chloride mg/kg EPA 9056A
Chromium mg/kg EPA 6010C
Chromium (Hexavalent)mg/kg EPA 7199
Cobalt mg/kg EPA 6020A
Copper mg/kg EPA 6010C
Iron mg/kg EPA 6010C
Lead mg/kg EPA 6020A
Magnesium mg/kg EPA 6010C
Manganese mg/kg EPA 6010C
Mercury mg/kg EPA Method 7471B
Molybdenum mg/kg EPA 6010C
Nickel mg/kg EPA 6010C
Nitrate as Nitrogen mg/kg EPA 9056A
pH SU EPA 9045D
Potassium mg/kg EPA 6010C
Selenium mg/kg EPA 6020A
Sodium mg/kg EPA 6010C
Strontium mg/kg EPA 6010C
Sulfate mg/kg EPA 9056A
Synthetic Precipitation Leaching Procedue (SPLP)µg/L EPA 1312
Thallium (low level) (SPLP Extract only)mg/kg EPA 6020A
Total Organic Carbon mg/kg EPA 9060
Vanadium mg/kg EPA 6020A
Zinc mg/kg EPA 6010C
Notes:
1. Soil samples to be analyzed for Total Inorganics using USEPA Methods 6010/6020 and pH using USEPA Method 9045, as noted above.
meq/100g - millequivalents per 100 grams
mg/kg - Milligrams per kilogram
mV - Millivolts
S.U. - Standard Unit
Prepared by: RBI Checked by: PBW
2. Analytical methods and reporting limits as presented were applicable at time of CSA field implementation in 2015. Analytical methods and
reporting limits are updated periodically and applied as appropriate.
TABLE 2
PROPOSED FORMER PROCESS AREA ASSESSMENT SOIL SAMPLES AND MONITORING WELLS
L.V. SUTTON ENERGY COMPLEX
DUKE ENERGY PROGRESS, LLC, WILMINGTON, NC
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Tables.xlsx Page 1 of 1
Monitoring
Well ID
Estimated
Well Depth
(feet bgs)
Soil Sample ID
(Estimated Depth
Interval in feet bgs)*
Comments
----FPA-1SB (X-X)Unsaturated soil sample 2 feet above bottom of basin
----FPA-1SB (X-X)Unsaturated soil sample 2 feet below the bottom of basin
----FPA-1SB (X-X)Unsaturated soil sample 2 feet above water table
FPA-1B 25 FPA-1SB (23-24)**Soil sample from upper surficial well screened interval
FPA-1C 50 FPA-1SB (47-48)**Soil sample from lower surfiical well screened interval
----FPA-2SB (1-2)Near-surface unsaturated soil sample (water table ~~6 feet bgs)
----FPA-2SB (2-4)Unsaturated soil sample
----FPA-2SB (4-6)Unsaturated soil sample 2 feet above water table
FPA-2B 25 FPA-2SB (23-24)**Soil sample from upper surficial well screened interval
FPA-2C 50 FPA-2SB (47-48)**Soil sample from lower surfiical well screened interval
----FPA-3SB (1-2)Near-surface unsaturated soil sample (water table ~~6 feet bgs)
----FPA-3SB (2-4)Unsaturated soil sample
----FPA-3SB (4-6)Unsaturated soil sample 2 feet above water table
FPA-3B 25 FPA-3SB (23-24)**Soil sample from upper surfiical well screened interval
FPA-3C 50 FPA-3SB (47-48)**Soil sample from lower surficial well screened interval
----FPA-4SB (1-2)Near-surface unsaturated soil sample (water table ~~6 feet bgs)
----FPA-4SB (2-4)Unsaturated soil sample
----FPA-4SB (4-6)Unsaturated soil sample 2 feet above water table
FPA-4B 25 FPA-4SB (23-24)**Soil sample from upper surfiical well screened interval
FPA-4C 50 FPA-4SB (47-48)**Soil sample from lower surficial well screened interval
----FPA-5SB (4-6)Unsaturated soil sample
----FPA-6SB (1-2)Near-surface unsaturated soil sample (water table ~~6 feet bgs)
----FPA-6SB (2-4)Unsaturated soil sample
----FPA-6SB (4-6)Unsaturated soil sample
----FPA-7SB (1-2)Near-surface unsaturated soil sample (water table ~~6 feet bgs)
----FPA-7SB (2-4)Unsaturated soil sample
----FPA-7SB (4-6)Unsaturated soil sample
----FPA-8SB (1-2)Near-surface unsaturated soil sample (water table ~~6 feet bgs)
----FPA-8SB (2-4)Unsaturated soil sample
----FPA-8SB (4-6)Unsaturated soil sample
Notes:
bgs = below ground surface
~ = Approximately
* Unsaturated thickness based on original site grade and does not include recently placed fill
** HFO Analyses Only
SynTerra recommends rotosonic drilling methods for boring and well installation.
Continuous cores from sonic drilling provide sufficient material for soil sampling and lithologic description.
Estimated well and soil sample depths based on data from the CCR-102 cluster and available Geosyntec boring logs.
SynTerra recommends each well screen be submerged beneath the water table and have a length of at least 10 feet
TABLE 3
GROUNDWATER ANALYTICAL METHODS
L.V. SUTTON ENERGY COMPLEX
DUKE ENERGY PROGRESS, LLC, WILMINGTON, NC
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Tables.xlsx Page 1 of 1
PARAMETER RL UNITS METHOD
pH NA SU Field Water Quality Meter
Specific Conductance NA µS/cm Field Water Quality Meter
Temperature NA ºC Field Water Quality Meter
Dissolved Oxygen NA mg/L Field Water Quality Meter
Oxidation Reduction Potential NA mV Field Water Quality Meter
Eh NA mV Field Water Quality Meter
Turbidity NA NTU Field Water Quality Meter
Aluminum 0.005 mg/L EPA 200.7 or 6010D
Antimony 0.001 mg/L EPA 200.8 or 6020B
Arsenic 0.001 mg/L EPA 200.8 or 6020B
Barium 0.005 mg/L EPA 200.7 or 6010D
Beryllium 0.001 mg/L EPA 200.8 or 6020B
Boron 0.05 mg/L EPA 200.7 or 6010D
Cadmium 0.001 mg/L EPA 200.8 or 6020B
Chromium 0.001 mg/L EPA 200.8 or 6020B
Cobalt 0.001 mg/L EPA 200.8 or 6020B
Copper 0.001 mg/L EPA 200.8 or 6020B
Hexavalent Chromium 0.000025 mg/L EPA 218.7
Iron 0.01 mg/L EPA 200.7 or 6010D
Lithium 1 mg/L EPA 200.7 or 6010D
Lead 0.001 mg/L EPA 200.8 or 6020B
Manganese 0.005 mg/L EPA 200.7 or 6010D
Mercury 0.00005 mg/L EPA 245.1 or 7470A
Molybdenum 0.001 mg/L EPA 200.8 or 6020B
Nickel 0.001 mg/L EPA 200.8 or 6020B
Selenium 0.001 mg/L EPA 200.8 or 6020B
Strontium 0.005 mg/L EPA 200.7 or 6010D
Thallium (low level)0.0002 mg/L EPA 200.8 or 6020B
Vanadium (low level)0.0003 mg/L EPA 200.8 or 6020B
Zinc 0.005 mg/L EPA 200.7 or 6010D
Radium 226 1 pCi/L EPA 903.1 Modified
Radium 228 1 pCi/L EPA 904.0/SW846 9320 Modified
Uranium (233, 234, 236, 238)Varies by isotope µg/mL SW846 3010A/6020B
Total Uranium NA µg/mL Calculated
Alkalinity (as CaCO3)5 mg/L SM 2320B
Bicarbonate 5 mg/L SM 2320B
Calcium 0.01 mg/L EPA 200.7
Carbonate 5 mg/L SM 2320B
Chloride 0.1 mg/L EPA 300.0 or 9056A
Fluoride 0.1 mg/L EPA 300.0 or 9056A
Magnesium 0.005 mg/L EPA 200.7 or 6010D
Potassium 0.1 mg/L EPA 200.7
Sodium 0.05 mg/L EPA 200.7
Sulfate 0.1 mg/L EPA 300.0 or 9056A
Sulfide 0.1 mg/L SM 4500 S2 D
Total Dissolved Solids 25 mg/L SM 2540C
Total Phosphorus 0.05 mg/L EPA 365.1
Total Organic Carbon 0.1 mg/L SM5310C/EPA9060A
Total Suspended Solids 5 mg/L SM 2450D
Prepared by: HHS Checked by: RHJ
Notes:
NA indicates not applicable.
°C - Degrees Celsius
mg/L - Milligrams per liter
mV - Millivolts
NTU - Nephelometric turbidity unit
pCi/L - picocuries per liter
RL = reporting limit
S.U. - Standard Unit
ug/mL - micrograms per milliliter
µS/cm = micro-Siemens per centimeter
Dissolved and total metals analysis
FIELD PARAMETERS
INORGANICS
RADIONUCLIDES
ANIONS/CATIONS/OTHER
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HA-3
HA-6
FPA-4B/C
198 3 EXTENSION
FPA-7SB
FPA-1B/C FPA-8SB
FPA-5SB
FPA-3B/C
FPA-6SB
FPA-2B/C
HA-1HA-2
HA-4
HA-5
MW-17
MW-18
V-DPT-1
V-DPT-2
V-DPT-3
V-DPT-4
V-DPT-5
V-DPT-6
V-DPT-7
CCR-102C
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DRAWN BY: A . ROBINSONCHECK BY: B. WYLIEPROJECT M ANAGER: P. WALDREP
DATE: 3/26/2018
148 RIVER STREE T, SUITE 220GREENVILLE, SO UTH CAROLINA 29601PHONE 864-421-9999www.synterracorp.com
P:\Duke Energy Progress.1026\00 GIS BASE DATA\Sutton\Map_Docs\CSA_Supplement_2\Proposed Monitoring W ell and Soil Boring.mxd
FIG URE 1PROPOSED M ONITORING WELL AND SOILBORING LOCATIONSL.V. SUTTON ENERGY COM PLEXDUKE ENERGY PROGRESS, LLCWILMINGTON, NORTH CAROLINA
30 0 30 6015
IN FEET
LEGEND
&>HAND AUGERED SAMPLING LOCATION
&>DPT SAMPLING LOCATION
&<MONITORING WELL (ABANDONED)
?PROPOSED MONITORING W ELL
&>PROPOSED SOIL BORING
WASTE BOUNDARY
FORMER PROCESS AREA BOUNDARY
FADA BOUNDARY
COM PLIANCE BOUNDARY
NOTES:
HAND AUGERED LOCATIONS ARE APPROXIMATE.
SITE AERIAL ORTHOPHOTOGRAPHY OBTAINED FROM W SP, DATED 2014.
DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE PLANECOORDINATE SYSTEM FIPS 3200 (NAD83/2011).