Duke - Mayo Coal Pile Assessment Work Plan_20190123

DUKE
ENERGY
January 23, 2019
North Carolina Department of Environmental Quality
Water Quality Regional Operations
3800 Barrett Drive
1628 Mail Service Center
Raleigh, North Carolina 27699
Attn: Mr. Eric Rice (submitted electronically)
Re: Mayo Steam Electric Plant Coal Pile
Groundwater Assessment Work Plan
Mayo Steam Electric Plant
10660 Boston Road
Roxboro, North Carolina 27574
Dear Mr. Rice:
2500 Fairfax Road
Greensboro, North Carolina 27407
336-215-4576
As indicated in a letter from the North Carolina Department of Environmental Quality (NCDEQ)
dated September 8, 2017 (Zimmerman to Sullivan), it is understood that in addition to
requirements of the Coal Ash Management Act (CAMA), Duke Energy is bound by the
requirements of the North Carolina General Statutes and North Carolina Administrative Code
02L. Therefore, Duke Energy is required to assess soil and groundwater in areas where there is a
potential for groundwater impact, identified by NCDEQ as primary and secondary sources.
Pursuant to technical direction provided in the September 8, 2017 letter and discussions at the
Duke Energy/NCDEQ Mayo Steam Electric Plant (Mayo) Conceptual Site Assessment (CSA)
Technical Review meeting on June 26, 2018, Duke Energy understands the Coal Pile area at
Mayo is identified as a potential primary source.
Since the Mayo coal pile area appears to be positioned directly upgradient and in close proximity
to the Mayo ash basin, NCDEQ requested assessment of the coal pile area to be included in the
evaluation for ash basin corrective action in the upcoming Mayo Corrective Action Plan (CAP).
Duke is submitting the attached Coal Pile Assessment Work Plan to assess potential groundwater
and soil impacts from the coal pile area at Mayo. Upon concurrence with this work plan, Duke
Energy will pursue receipt of necessary permits for the installation of 16 proposed groundwater
monitoring wells and perform associated sampling and analysis around the coal pile area.
If you need additional information in regards to this submittal please do not hesitate to call or
email, 336-215-4576 or [e-mail].
Mayo Steam Electric Plant - Page I of 2

Respectfully submitted,
:�'e; *
#—
Kimberlee Witt, PE
Environmental Services
Attachments: Coal Pile Assessment Work Plan, SynTerra January 2019
ecc: Coal Ash War Room - NCDEQ
Rick Bolich - NCDEQ
Eric Smith - NCDEQ
Steve Lanter - NCDEQ
John Toepfer - Duke Energy
Ed Sullivan — Duke Energy
Jerry Wylie - SynTerra
Mayo Steam Electric Plant - Page 2 of 2

,61p
synTerra
COAL PILE ASSESSMENT WORK PLAN
MAYO STEAM ELECTRIC PLANT
10660 BOSTON ROAD
ROXBORO, NC 27574
JANUARY 2019
PREPARED FOR
DUKE ENERGY PROGRESS,, LLC
(' DUKE
ENERGY
Jeiry A. W li , NC LG 1425
Project Manager
Peggy W. Altman
Project Scientist

Coal Pile Assessment Work Plan January 2019
Mayo Steam Electric Plant
LIST OF FIGURES
Figure 1 Site Location Map
Figure 2 Proposed Monitoring Well and Soil Boring Locations
LIST OF TABLES
Table 1 Soil Sample Analytical Methods
Table 2 Proposed Coal Pile Assessment Soil Samples and Monitoring Wells
Table 3 Groundwater Analytical Methods
Page i
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Coal Pile Assessment Work Plan January 2019
Mayo Steam Electric Plant
1.0 Introduction
Duke Energy Progress, LLC (Duke Energy) owns and operates the coal-fired Mayo
Steam Electric Plant (Mayo, Plant, or Site) located in a rural area approximately 10 miles
north of the City of Roxboro in Person County, North Carolina (Figure 1). Duke Energy
owns the site property, which is roughly bisected by US Highway 501, encompasses 460
acres, and includes the power plant, ash basin, material storage, industrial landfill and
other operational features associated with coal fired power generating facilities. Mayo
began operations in 1983 with a single 727-megawatt capacity coal-fired unit. Coal is
transported to Mayo by rail and stored on Site. Proposed groundwater and soil
assessment activities for the coal storage area (Coal Pile) are described herein.
1.1 Regulatory Background
In 2014, The North Carolina General Assembly passed the Coal Ash
Management Act (CAMA). CAMA required owners of a coal combustion
residual (CCR) surface impoundment to conduct detailed assessment of Site
groundwater within and around the CCR surface impoundment.
As indicated in a letter from the North Carolina Department of Environmental
Quality (DEQ) dated September 8, 2017 (Zimmerman to Sullivan), it is
understood that in addition to CAMA requirements, Duke Energy is also bound
by the rules and requirements of the NC General Statutes and NC
Administrative Code 02L. These provide requirements for the assessment and
abatement of soil and groundwater impacts resulting from Site activities.
Therefore, Duke Energy is required to assess soil and groundwater in areas
where there is a potential for groundwater impact, identified as primary and
secondary sources.. Pursuant to technical direction provided in the September 8,
2017 letter, Duke Energy understands the Coal Pile area at Mayo to be a potential
primary source. The Mayo Coal Pile appears to be positioned directly upgradient
of the ash basin and/or some portion of groundwater originating from the coal
pile potentially flows towards the ash basin. Groundwater flow will be evaluated
as part of this proposed assessment work.
1.2 Site Description
Detailed descriptions of the Site operational history, the Site conceptual model,
physical setting and features, geology/hydrogeology, and results of the findings
of the Comprehensive Site Assessment (CSA) and other CAMA-related works
are documented in full in the following documents:
• Comprehensive Site Assessment Report —Mayo Steam Electric Plant (SynTerra,
September 2, 2015)
Page 1
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Coal Pile Assessment Work Plan January 2019
Mayo Steam Electric Plant
• Corrective Action Plan Part 1— Mayo Steam Electric Plant (SynTerra,
December 1, 2015)
• Corrective Action Plan Part 2— Mayo Steam Electric Plant (SynTerra, February
2, 2016)
• Comprehensive Site Assessment Supplement 1— Mayo Steam Electric Plant
(SynTerra, July 7, 2016)
• Comprehensive Site Assessment Update —Mayo Steam Electric Plant (SynTerra,
October 31, 2017)
The Coal Pile at the Mayo occupies approximately 20 to 30 acres and is located in
the south-central portion of the Plant (Figure 2). Surface water runoff from the
area is currently directed to the ash basin; however, a coal pile retention basin
was constructed in 2018 on the western side of the coal pile area to capture run-
off. The Coal Pile is bounded to the north and east by internal Plant access roads
and buildings as well as the Plant railroad line. The Coal Pile is bounded to the
west and south by undeveloped, mostly forested land. The land surface
surrounding the coal pile is generally flat and is at an elevation of approximately
520 feet North American Vertical Datum of 1988 (NAVD 88).
2.0 Coal Pile Assessment Objectives
Objectives of the coal pile assessment include the following:
• Characterize inorganic constituents associated with coal pile area soils;
• Compare inorganic constituent concentrations in coal pile area soils and Site
background soils;
• Characterize inorganic constituent concentrations in groundwater underlying the
coal pile area and just beyond the coal pile area perimeter; and
• Compare inorganic constituent concentrations in coal pile area groundwater and
Site background groundwater.
2.1 Soil Assessment
Coal pile area soils will be sampled and analyzed for inorganic parameters to
determine if they are a source of CCR constituents that may leach into
underlying groundwater in excess of NC 2L standards or Site provisional
background threshold values (PBTV). Soil samples will be collected at proposed
monitoring well locations (CPA-1 through CPA-6) as part of well installation
Page 2
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Coal Pile Assessment Work Plan January 2019
Mayo Steam Electric Plant
activities. The proposed locations of the monitoring wells are included in Figure
2. Proposed locations are approximate and may vary slightly based on field
observations and locations of underground utilities, which will be determined
prior to initiation of boring activities.
Soil samples will be analyzed for inorganic parameters consistent with
assessment of areas used for coal and CCR management (Table 1). Soil samples
will be collected from the near ground surface (two to three feet) and at
approximately two to five foot intervals to the top of the groundwater table or
bedrock, whichever is encountered first. An additional soil sample will be
collected below the water table within the new well screen intervals. SPLP
samples will be collected at a frequency of two per well cluster location with one
unsaturated sample collected from near ground surface (two to three feet) and a
saturated sample collected two to three feet below the water table (Table 2).
Soil samples will also be collected from depths that coincide with the screen
intervals of newly installed wells for analysis of metal oxy-hydroxide phases of
iron and aluminum (HFO and HAO) to support optimization of the geochemical
model for the Site. HFO/HAO samples will be collected at each well. Following
the first round of groundwater sampling, wells that are geochemically significant
to the Site will be selected for analysis. HFO/HAO analysis will be used in a
geochemical modeling approach that combines an aqueous speciation model
with a sorption model under a thermochemical framework that will use the site -
specific in -situ HFO and HAO results as a proxy of constituent sorption capacity.
2.2 Groundwater Assessment
Groundwater conditions proximate to the area of investigation will be assessed
by installing groundwater monitoring wells in and around the coal pile area and
collecting/analyzing representative groundwater samples from the wells.
A total of 16 coal pile assessment (CPA) groundwater monitoring wells are
proposed to be installed to characterize coal pile area groundwater conditions.
Five shallow ("S"), four transition zone ("D"), and five bedrock ('BR")
groundwater monitoring wells (CPA-1BR, CPA-2S/D/BR, CPA-3S/D/BR, CPA-
4S/D/BR, CPA-5S/D/BR, CPA-6S/D/BR) are planned to be installed as well
clusters at the proposed locations shown in Figure 2. A previously installed
transition zone well, CPB-1 (to be renamed CPA-1D), will be included in the coal
pile area groundwater assessment. No surficial groundwater was encountered
during the drilling of CPB-1.
Page 3
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Coal Pile Assessment Work Plan January 2019
Mayo Steam Electric Plant
Well locations may be modified from those shown on Figure 2 based on field
constraints (e.g. underground utility locations, rig stability).
Well installation procedures and well construction materials and lengths will be
consistent with ongoing CAMA assessment activities in accordance with the
approved Proposed Groundwater Assessment Work Plan (Rev. 1) (SynTerra, 2014).
Shallow wells are proposed to be installed so that the top of the screened interval
is positioned approximately five feet 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.
The primary drilling technology for soil sampling, well drilling, and well
installation with either be rotary sonic drilling or a combination of air rotary and
hollow stem auger drilling.
Anticipated well depths are provided in Table 2. Groundwater samples will be
analyzed for field parameters (e.g., pH, conductivity, and turbidity) and
inorganic constituents consistent with ongoing CAMA assessment activities
(Table 3).
3.0 Coal Pile Assessment Report
A coal pile assessment report to be included as an appendix in the forthcoming CAP
update document will be prepared after soil and groundwater sample analytical data is
received, validated, and evaluated. An evaluation of the data will be presented in the
CAP that addresses the need for additional assessment or corrective action.
Components of the report will include:
1) Brief Site History
2) Description of Source Assessment Activities
3) Observations Concerning Geology and Hydrogeology in Areas of Additional
Assessment
4) Soil Analytical Results
5) Groundwater Analytical Results
6) Site Conceptual Model
7) Conclusions and Recommendation
Page 4
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Assessment 2019 \ Coal Pile Assessment Work Plan \ Mayo Coal Pile Assessment Work Plan 22Jan2019.docx

Coal Pile Assessment Work Plan January 2019
Mayo Steam Electric Plant
FIGURES
P: \ Duke Energy Progress.1026 \ 105. Mayo Ash Basin GW Assessment Plan \ Additional Assessment \ Coal Pile
Assessment 2019 \ Coal Pile Assessment Work Plan \ Mayo Coal Pile Assessment Work Plan 22Jan2019.docx

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LINED RETENTION
LOW VOLUME
BASIN AREA
J
PONDSPOWER -
• 590 / l
OM
PLANT
COAL PILE AREA
/
GYPSUPAD ARE L_
SOURCE:
2016 USGS TOPOGRAPHIC MAP, CUSTER SPRINGS & VIRGILINA
QUADRANGLE, OBTAINED FROM THE USGS STORE AT
hftps://store.usgs.gov/map-locator.
PERSON COUNTY
synTerra
6�.ARLOTTE
Wle
148 RIVER STREET, SUITE 220
GREENVILLE, SOUTH CAROLINA 29601
PHONE [phone]
P:\Duke Energy Progress. 1026W0 GIS BASE DATA\Mayo\Map_Docs\CAP\FigES-01_Mayo _Sile Locafion—d
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FIGURE 1
SITE LOCATION MAP
MAYO STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS, LLC
ROXBORO, NORTH CAROLINA
DRAWN BY: A. ROBINSON DATE: 1/22/2019 ,000 0 1,000 2,00
PROJECT MANAGER: J. WYLIE CONTOUR INTERVAL:.: FT
CHECKED BY: P. ALTMAN MAP DATE: 2016
GRAPHIC SCALE IN FEET

Coal Pile Assessment Work Plan January 2019
Mayo Steam Electric Plant
TABLES
P: \ Duke Energy Progress.1026 \ 105. Mayo Ash Basin GW Assessment Plan \ Additional Assessment \ Coal Pile
Assessment 2019 \ Coal Pile Assessment Work Plan \ Mayo Coal Pile Assessment Work Plan 22Jan2019.docx

TABLE 1
SOIL SAMPLE ANALYTICAL METHODS
MAYO STEAM ELETRIC PLANT
DUKE ENERGY PROGRESS LLC, ROXBORO, NC
INORGANIC COMPOUNDS
UNITS
METHOD
Aluminum
mg/kg
EPA 6010D
Antimony
mg/kg
EPA 6020B
Arsenic
mg/kg
EPA 6020B
Barium
mg/kg
EPA 6010D
Beryllium
mg/kg
EPA 6010D
Boron
mg/kg
EPA 6010D
Cadmium
mg/kg
EPA 6020B
Calcium
mg/kg
EPA 6010D
Chloride
mg/kg
EPA 9056A
Chromium
mg/kg
EPA 6010C
Cobalt
mg/kg
EPA 6020A
Copper
mg/kg
EPA 6010C
Iron
mg/kg
EPA 6010C
Lead
mg/kg
EPA 6020B
Magnesium
mg/kg
EPA 6010D
Manganese
mg/kg
EPA 6010C
Mercury
mg/kg
EPA 7471B
Molybdenum
mg/kg
EPA 6010D
Nickel
mg/kg
EPA 6010C
Nitrate as Nitrogen
mg/kg
EPA 9056A
pH
SU
EPA 9045D
Potassium
mg/kg
EPA 6010D
Selenium
mg/kg
EPA 6020B
Sodium
mg/kg
EPA 6010D
Strontium
mg/kg
EPA 6010C
Sulfate
mg/kg
EPA 9056A
Thallium
mg/kg
EPA 6020B
Total Organic Carbon
mg/kg
EPA 9060
Vanadium
mg/kg
EPA 6020B
Zinc
mg/kgmg/kg
EPA 6010C
Prepared by: RBI Checked by: SRW/TCP/VTV
Notes:
1. Soil samples to be analyzed for Total Inorganics using USEPA Methods 6010/6020 and pH using USEPA Method 9045, as noted above.
2. Soil samples collected from near ground surface (2 to 3ft) and from just above water table (field determined) in each boring will also be
analyzed for leaching potential using SPLP Extraction Method 1312 in conjunction with USEPA Methods 6010/6020
3. Analytical methods and reporting limits as presented were developed for CSA field implementation in 2015. Analytical methods and
reporting limits are updated periodically and applied as appropriate.
meq/100g - millequivalents per 100 grams
mg/kg - Milligrams per kilogram
my - Millivolts
S.U. - Standard Unit
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Assessment Work Plan\Tables\Table 1 Soil Sample Analytical Methods Page 1 of 1

TABLE 2
PROPOSED COAL PILE ASSESSMENT SOIL SAMPLES AND MONITORING WELLS
MAYO STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESSS, LLC, ROXBORO, NC
Monitoring
Well ID
Estimated
Well Depth
feet b s)
Soil Sample ID
(Estimated Depth
Interval in feet b s
Comments
--
--
CPA-SB1 2-3
Near -surface unsaturated soil sample (water table
—20 feet b s
--
--
CPA-S131 19-20
Near -top of water table unsaturated soil sample
estimated depth, will be determined in the field
CPA-1D*
30
CPA-SB1 25-26
Soil sample from deep well screened interval
CPA-113R
80
CPA-SB1 (75-76)
Soil sample from bedrock well screened interval
--
--
CPA-SB2 2-3
Near -surface unsaturated soil sample (water table
—20 feet b s
--
--
CPA-SB2 19-20
Near -top of water table unsaturated soil sample
estimated depth, will be determined in the field
CPA-2S
30
CPA-SB2 25-26
Unsaturated soil sample
CPA-2D
50
CPA-SB2 45-46
Soil sample from shallow well screened interval
CPA-213R
80
CPA-SB2 (75-76)
Soil sample from deep well screened interval
--
--
CPA-SB3 (2-3)
Near -surface unsaturated soil sample (water table
—20 feet bgs)
--
--
CPA-SB3 (19-20)
Near -top of water table unsaturated soil sample
(estimated depth, will be determined in the field)
CPA-3S
30
CPA-SB3 (25-26)
Unsaturated soil sample
CPA-3D
50
CPA-S133 45-46
Soil sample from shallow well screened interval
CPA-3BR
80
CPA-SB3 (75-76)
Soil sample from deep well screened interval
--
--
CPA-SB4 2-3
Near -surface unsaturated soil sample (water table
—20 feet b s
--
--
CPA-S134 19-20
Near -top of water table unsaturated soil sample
estimated depth, will be determined in the field
CPA-4S
30
CPA-SB4 25-26
Unsaturated soil sample
CPA-4D
50
CPA-SB4 45-46
Soil sample from shallow well screened interval
CPA-413R
80
CPA-S134 (75-76)
Soil sample from deep well screened interval
--
--
CPA-SB5 2-3
Near -surface unsaturated soil sample (water table
—20 feet b s
--
--
CPA-SB5 19-20
Near -top of water table unsaturated soil sample
estimated depth, will be determined in the field
CPA-5S
30
CPA-SB5 25-26
Unsaturated soil sample
CPA-5D
50
CPA-SB5 45-46
Soil sample from shallow well screened interval
CPA-513R
80
CPA-SB5 (75-76)
Soil sample from deep well screened interval
--
--
CPA-S136 2-3
Near -surface unsaturated soil sample (water table
—20 feet b s
--
--
CPA-SB6 19-20
Near -top of water table unsaturated soil sample
estimated depth, will be determined in the field
CPA-6S
30
CPA-S136 25-26
Unsaturated soil sample
CPA-6D
50
CPA-SB6 45-46
Soil sample from shallow well screened interval
CPA-613R
80
CPA-SB6 (75-76)
Soil sample from deep well screened interval
--
--
CPA-S137 2-3
Near -surface unsaturated soil sample (water table
—20 feet b s
--
--
CPA-SB7 19-20
Near -top of water table unsaturated soil sample
estimated depth, will be determined in the field
CPA-7S
30
CPA-S137 25-26
Unsaturated soil sample
CPA-7D
50
CPA-SB7 45-46
Soil sample from shallow well screened interval
CPA-713R
80
CPA-SB7 (75-76)
Soil sample from deep well screened interval
--
--
CPA-SB8 2-3
Near -surface unsaturated soil sample (water table
—20 feet b s
--
--
CPA-SB8 19-20
Near -top of water table unsaturated soil sample
estimated depth, will be determined in the field
CPA-8S
30
CPA-SB8 25-26
Unsaturated soil sample
CPA-8D
50
CPA-SB8 45-46
Soil sample from shallow well screened interval
CPA-813R
80
CPA-SB8 75-76
Soil sample from deep well screened interval
Prepared by: PWA Checked by: JAW
Notes:
*CPA-1D is a previously installed well (CPB-1) in the coal pile assessment area and will be renamed for consistency. No surficial groundwater was
encountered during the drilling of this well.
bgs = below ground surface
— = Approximately
Estimated well and soil sample depths based on data from the CCR-101S-BG, CCR-101D-BG, and CPA-1 wells.
Number of soil samples is approximate. A shallower water table will result in fewer samples, and a deeper water table will result in additional samples.
SynTerra recommends each well screen be submerged beneath the water table and have a length of at least 10 feet.
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TABLE 3
GROUNDWATER ANALYTICAL METHODS
MAYO STEAM ELECTRIC PLANT
DUKE ENERGY PROGRESS LLC, ROXBORO, NC
PARAMETER
RL
UNITS
METHOD
FIELD PARAMETERS
H
NA
SU
Field Water Quality Meter
Specific Conductance
NA
µS/cm
Field Water Quality Meter
Temperature
NA
0C
Field Water Quality Meter
Dissolved Oxygen
NA
m 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
INORGANICS
Aluminum
0.005
m L
EPA 200.7 or 6010D
Antimony
0.001
m L
EPA 200.8 or 6020B
Arsenic
0.001
m L
EPA 200.8 or 6020A
Barium
0.005
m L
EPA 200.7 or 6010C
Beryllium
0.001
m L
EPA 200.8 or 6020A
Boron
0.05
m L
EPA 200.7 or 6010C
Cadmium
0.001
m L
EPA 200.8 or 6020A
Chromium
0.001
m L
EPA 200.8 or 6010C
Cobalt
0.001
m L
EPA 200.8 or 6020A
Copper
0.001
m /L
EPA 200.8 or 6020B
Hexavalent Chromium
0.000025
m /L
EPA 218.7
Iron
0.01
m /L
EPA 200.7 or 6010C
Lead
0.001
m L
EPA 200.8 or 6020A
Manganese
0.005
m /L
EPA 200.7 or 6010C
Mercury
0.000
m /L
EPA 245.1 or 7470A
Molybdenum
0.001
m /L
EPA 200.8 or 6020B
Nickel
0.001
m /L
EPA 200.8 or 6020B
Selenium
0.001
m /L
EPA 200.8 or 6020A
Strontium
0.005
m /L
EPA 200.7 or 6010C
Thallium low level
0.0002
m /L
EPA 200.8 or 6020A
Vanadium low level
0.0003
m L
EPA 200.8 or 6020A
Zinc
0.005
mg/L
EPA 200.7 or 6010C
RADIONUCLIDES
Radium 226
1
Ci/L
EPA 903.1 Modified
Radium 228
1
Ci/L
EPA 904.0/SW846 9320 Modified
Uranium 223, 234, 236, 238
Varies by Isotope
µg/mL
SW846 3010A/6020B
Total Uranium
NA
µg/mL
Calculated
ANIONS/CATIONS
Alkalinity as CaCO3
5
m /L
SM 2320B
Bicarbonate
5
m /L
SM 2320
Calcium
0.01
m /L
EPA 200.7
Carbonate
5
m /L
SM 2320
Chloride
0.1
m /L
EPA 300.0 or 9056A
Magnesium
0.005
m /L
EPA 200.7
Potassium
0.1
m /L
EPA 200.7
Sodium
0.05
m /L
EPA 200.7
Sulfate
0.1
m /L
EPA 300.0 or 9056A
Sulfide
0.1
mg/L
SM4500S2 D
Total Dissolved Solids
25
m /L
SM 2540C
Total Organic Carbon
0.1
mg/L
SM 5310C/EPA9060A
Total Suspended Solids
1 2.5
1 m L
ISM 2450D
Prepared by: RBI Checked by: SRW/TCP
Notes:
1. Select constituents will be analyzed for total and dissolved concentrations.
2. Analytical methods and reporting limits as presented were developed for CSA field implementation in 2015. Analytical methods and reporting limits are updated periodically and applied
as appropriate.
OC - Degrees Celsius
µS/cm = micro -Siemens per centimeter
mg/L - Milligrams per liter
mg - N/L - Milligrams nitrogen per liter
my - Millivolts
NA - Not analyzed
NTU - Nephelometric turbidity unit
pCi/L - picocuries per liter
RL = reporting limit
S.U. - Standard Unit
ug/mL - micrograms per milliliter
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