CCB0070_DukeBelewsCreek_AddtitionalAssessment_WorkPlan_20190520

�.S DUKE
�, ENERGY.
May 20, 2019
North Carolina Department of Environmental Quality
Division of Waste Management
Solid Waste Section
1646 Mail Service Center
Raleigh, North Carolina 28778
Attn: Ms. Elizabeth Werner
Re: Structural Fill Additional Assessment Work Plan
Belews Creek Steam Station BCSS .1700 Structural Fill
Permit No.: CCB0070
Belews Creek Steam Station
Stokes County
Belews Creek, North Carolina 27009
Dear Ms. Werner,
Belews Creek Steam Station
3195 Pine Hall Road
Belews Creek, NC 27009
336-445-0610
336-669-2994
Attached you will find the proposed Additional Assessment Work Plan for the Belews
Creek BCSS .1700 Structural Fill. This plan is being submitted to the Division for
approval.
Duke Energy is committed to excellent environmental stewardship and cooperation with
the Division regarding the operation, maintenance, safety, and integrity of all of its
facilities. We look forward to continuing to work with you regarding environmental
concerns.
If there are any questions regarding this request, please contact me at [phone].
Respectfully submitted,
Melonie Martin
Environmental Services
Attachments: Structural Fill Additional Assessment Work Plan

161p
synTerra
STRUCTURAL FILL ADDITIONAL
ASSESSMENT WORK PLAN
FOR
BELEWS CREEK STEAM STATION
3195 PINE HALL ROAD
BELEWS CREEK, NC 27009
MAY 20, 2019
PREPARED FOR
DUKE ENERGY CAROLINAS� LLC
& DUKE
e ENERGY,
PREPARED BY
SYNTERRA CORPORATION
- J,-J-J-
Ashley A ert, LG NC 2615
Project Manager
David Avard
Project Scientist

Structural Fill Assessment Work Plan May 20, 2019
Duke Energy Carolinas, LLC - Belews Creek Steam Station SynTerra
TABLE OF CONTENTS
SECTION
PAGE
1.0 INTRODUCTION.........................................................................................................1-1
1.1 Regulatory Background...........................................................................................1-1
1.2 Site Description.........................................................................................................1-2
2.0 STRUCTURAL FILL ASSESSMENT OBJECTIVES..............................................2-1
2.1 Soil Assessment......................................................................................................... 2-1
2.2 Groundwater Assessment....................................................................................... 2-2
3.0 REPORTING..................................................................................................................3-1
LIST OF FIGURES
Figure 1 Well Location Vetting — Proposed Monitoring Wells
LIST OF TABLES
Table 1 Proposed Structural Fill Assessment Soil Samples and Monitoring Wells
Table 2 Soil Analytical Parameters
Table 3 Groundwater Analytical Parameters
Page i

Structural Fill Assessment Work Plan May 20, 2019
Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra
1.0 INTRODUCTION
This technical memorandum provides a work plan for groundwater and soil assessment
activities proposed for the Structural Fill area at the Belews Creek Steam Station (BCSS,
Plant, or Site) owned and operated by Duke Energy Carolinas, LLC (Duke Energy). The
Plant is located in Stokes County, North Carolina and encompasses approximately 6,100
acres of company -owned property along Belews Reservoir. The Structural Fill is
located south of the ash basin (Figure 1), and south of a topographic hydrogeological
divide represented by Pine Hall Road. Conclusions from a previous Structural Fill
Groundwater Assessment Report (HDR, 2018) recommended installation of additional
monitoring wells to delineate the vertical and horizontal extent of groundwater affected
by the Structural Fill. Additional groundwater and soil assessment activities proposed
for the Structural Fill area 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 residuals (CCR) surface
impoundment to conduct detailed assessment of site groundwater within and around
the CCR surface impoundments.
The primary source of CCR-related constituents at the BCSS was identified as the ash
basin during the Comprehensive Site Assessment (CSA) (HDR, 2015) and the CSA
Update (SynTerra, 2017). Ash associated with the Structural Fill is not considered
coincident with the primary source area and was not evaluated during the CSA (HDR,
2015) or CSA Update (SynTerra, 2017). However, seep sample results from a non -
constructed seep S-9, located south of Pine Hall Road and west of the Structural Fill,
have indicated consistent constituent concentrations of boron and manganese
uncharacteristic of other seep sample results south and east of the ash basin (i.e. seeps S-
7, S-12, S-13). Boron, an inorganic constituent, is commonly used as an indicator
constituent of CCR impacts. Effects from non -constructed seep S-9 are deemed covered
by the Special Order by Consent (EMC SOC WQ S18-004).
Installation and sampling of additional groundwater monitoring wells in the area south
of Pine Hall Road and adjacent to the Structural Fill was recommended in the 2015 CSA
Report (HDR, 2015). In May and June 2017, groundwater monitoring wells SFMW-1D,
SFMW-2D, SFMW-3D, SFMW-4D, and SFMW-5D were installed around the Structural
Fill (Figure 1). Each well was installed within the deep flow layer because groundwater
was not encountered above rock within the shallow flow layer. Water levels collected
Page 1-1
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Assessment Work Plan.docx

Structural Fill Assessment Work Plan May 20, 2019
Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra
from wells SFMW-1D, SFMW-2D, SFMW-3D, SFMW-4D, and SFMW-5D indicated that
the groundwater flow direction is to the south, away from Pine Hall Road and towards
Belews Reservoir (HDR, 2018).
Assessment activities were documented in the Structural Fill Groundwater Assessment
Report (HDR, 2018) which was provided to North Carolina Department of
Environmental Quality (NCDEQ) Division of Waste Management (DWM) in January
2018. The report summarized that sample results from two, newly installed, deep (i.e.
transition zone) groundwater monitoring wells west (SFMW-1D) and south (SFMW-4D)
of the Structural Fill have elevated concentrations of CCR-related constituents.
Groundwater monitoring well SFMW-1D is located west of the Structural Fill and
upgradient of non -constructed seep S-9. Sample results from SFMW-1D had
concentrations of boron, cadmium, chromium, cobalt, manganese, selenium, sulfate,
and total dissolved solids (TDS) greater than one or more of the groundwater screening
criteria; (NCAC 02L standard [02L standard], Interim Maximum Allowable
Concentration [IMAC], or approved background threshold value [BTV]). Groundwater
monitoring well SFMW-4D is located south of the Structural Fill. Sample results from
SFMW-4D had concentrations of boron, cobalt, manganese, sulfate, and TDS greater
than one or more of the groundwater screening criteria.
A recommendation was made in the Structural Fill Groundwater Assessment Report
(HDR, 2018) for additional assessment of groundwater and overlying soils in the area of
the Structural Fill to further delineate the vertical and horizontal extent of constituent
concentrations greater than applicable screening criteria. For this reason, Duke Energy
understands the Structural Fill area groundwater and soils to be a potential primary
and "secondary source" of inorganic constituents that would be further assessed apart
from CAMA or the CCR Rule.
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 CAMA-
related works are documented in the following documents:
• Comprehensive Site Assessment Report — Belews Creek Steam Station Ash Basin (HDR
Engineering, Inc. of the Carolinas (HDR, 2015a).
• Corrective Action Plan Part 1— Belews Creek Steam Station Ash Basin (HDR, 2015b).
Page 1-2
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Assessment Work Plan.docx

Structural Fill Assessment Work Plan May 20, 2019
Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra
• Corrective Action Plan Part 2 (included CSA Supplement 1 as Appendix A) — Belews
Creek Steam Station Ash Basin (HDR, 2016a).
• Comprehensive Site Assessment Supplement 2 — Belews Creek Steam Station Ash Basin
(HDR, 2016b).
• Comprehensive Site Assessment Update — Belews Creek Steam Station Ash Basin
(SynTerra, 2017).
• 2018 CAMA Annual Interim Monitoring Report —Belews Creek Steam Station
(SynTerra, April 2018).
The BCSS Structural Fill was constructed between February 2004 and July 2009 using fly
ash generated from the plant's coal burning process for steam generation. The
Structural Fill footprint encompasses an area of approximately 21 acres. The unit was
constructed under structural fill rules 15A NCAC 13B .1700 and is permitted under
DWM (CCB0070). An engineered cover system was constructed over the unit in 2012.
The Structural Fill is currently used as an equipment/material staging area and
overflow parking lot.
Page 1-3
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Assessment\01.Structural Fill Groundwater Assessment\ Work Plan\Belews Creek\Belews Creek Structural Fill
Assessment Work Plan.docx

Structural Fill Assessment Work Plan May 20, 2019
Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra
2.0 STRUCTURAL FILL ASSESSMENT OBJECTIVES
Objectives of the Structural Fill assessment include the following:
• Characterize inorganic constituents associated with Structural Fill area
unsaturated soils as potential secondary source to groundwater
• Delineate vertical extent of inorganic constituent concentrations in groundwater
• Delineate horizontal extent of inorganic constituent concentrations in
groundwater
• Compare inorganic constituent concentrations in Structural Fill area to Site
background concentrations
2.1 Soil Assessment
Structural Fill area soils would be sampled and analyzed for inorganic parameters to
determine if they are a secondary source of inorganic constituents that can leach into
underlying groundwater. Soil samples would be collected at prescribed depths, as
described on Table 1, from proposed monitoring well locations (Figure 1) as part of
well installation activities. Soil samples would be collected at approximately 2-foot
intervals to the top of the groundwater table. An additional soil sample would be
collected below the water table within the new well screen interval. Soil samples would
be analyzed for inorganic parameters listed on Table 2, with adjusted reporting limits
appropriate for comparison of soil analytical results to the Primary Soil Remediation
Goals Protection of Groundwater (PSRG POG).
Soil samples would also be analyzed using a synthetic precipitation leaching procedure
(SPLP) to understand potential leaching effects from the solid media. Soil SPLP samples
would be collected at a frequency of two per well cluster location with one unsaturated
sample collected from two to three feet below ground surface, and one saturated
sample collected two to three feet below the water table. Soil SPLP samples would be
analyzed for inorganic parameters listed on Table 2.
Soil or rock samples would be collected from depths that coincide with the screen
intervals of newly installed wells for potential analysis of metal oxy-hydroxide phases
of iron and aluminum (HFO and HAO). Following the first round of groundwater
sampling, wells that are geochemically significant to the Site would be selected for
analysis as necessary.
Page 2-1
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Assessment Work Plan.docx

Structural Fill Assessment Work Plan May 20, 2019
Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra
2.2 Groundwater Assessment
Eight Structural Fill assessment groundwater monitoring wells (designated as "SFMW-
" or "GWA-") would be installed in shallow, deep and bedrock groundwater zones in
designated areas of the Structural Fill. For vertical delineation, one bedrock well
(SFMW-2BR) is recommended upgradient of the Structural fill, paired with existing
well SFMW-2D, and two bedrock wells (SFMW-1BR and SFMW-4BR) are recommended
downgradient of the Structural fill, paired with existing wells SFMW-1D and SFMW-
4D. For horizontal delineation, two additional well pairs (SFMW-6S/SFMW-6D and
SFMW-7S/SFMW-7D) are recommended downgradient of existing wells SFWM-3D and
SFMW-4D. One additional bedrock well (GWA-23BR), adjacent to existing shallow and
deep monitoring well pair GWA-23S/D, is recommended to determine vertical extent of
affected groundwater west of the Structural Fill. Proposed well installation locations are
shown on Figure 1 and proposed well details are provided as Table 1. Specific well
locations may be shifted depending upon access and field conditions at the time of
installation.
Well installation procedures and well construction materials and lengths would be
consistent with ongoing CAMA assessment activities in accordance with the approved
Proposed Groundwater Assessment Work Plan (Rev. 1) (SynTerra, 2014). During boring
installation, soil/rock cuttings would be described for lithologic information including
color and soil/ rock type. Each well would be constructed in accordance with NCAC
Title 15A, Subchapter 2C, Section .0100 Well Construction Standards and consist of 2-
inch diameter NSF schedule 40 PVC flush -joint threaded casings and pre -packed
screens.
Following installation, the monitoring wells would be developed in order to remove
drill fluids, clay, silt, sand, and other fines, which may have been introduced into the
formation or sand pack during drilling and well installation, and to establish
communication of the well with the aquifer. Following well completion, the newly
installed wells would be surveyed for location and elevation.
Groundwater samples would be collected using low flow sampling techniques per the
groundwater sampling procedures provided in the Low Flow Sampling Plan, Duke Energy
Facilities, Ash Basin Groundwater Assessment Program, North Carolina, June 10, 2015 (Low
Flow Sampling Plan). Groundwater samples would be analyzed for constituent
parameters in Table 3.
Page 2-2
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Assessment\01.Structural Fill Groundwater Assessment\ Work Plan\Belews Creek\Belews Creek Structural Fill
Assessment Work Plan.docx

Structural Fill Assessment Work Plan May 20, 2019
Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra
3.0 REPORTING
The Structural Fill assessment findings would be presented in a CSA report that would
be submitted to the NCDEQ DWM and Division of Water Resources (DWR) on March
31, 2020 as requested in an April 5, 2019 letter to Duke Energy.
Page 3-1
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Assessment Work Plan.docx

Structural Fill Assessment Work Plan May 20, 2019
Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra
Figures
P:\Duke Energy Carolinas \ 20. BELEWS CREEK \ 29.Structural Fill, Coal Pile and Gypsum Pad
Assessment\01.Structural Fill Groundwater Assessment\ Work Plan\Belews Creek\Belews Creek Structural Fill
Assessment Work Plan.docx

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DRAWN BY: B. YOUNG DATE: 05/10/2019
PROJECT MANAGER: C. EADY
CHECKED BY: A. ALBERT
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FIGURE 1
WELL LOCATION VETTING
PROPOSED MONITORING WELLS
STRUCTURAL FILL AREA
BELEWS CREEK STEAM STATION
DUKE ENERGY CAROLINAS, LLC
BELEWS CREEK, NORTH CAROLINA

Structural Fill Assessment Work Plan May 20, 2019
Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra
Tables
P:\Duke Energy Carolinas \ 20. BELEWS CREEK \ 29.Structural Fill, Coal Pile and Gypsum Pad
Assessment\01.Structural Fill Groundwater Assessment\ Work Plan\Belews Creek\Belews Creek Structural Fill
Assessment Work Plan.docx

TABLE 1
PROPOSED STRUCTURAL FILL ASSESSMENT SOIL SAMPLES AND MONITORING WELLS
BELEWS CREEK STEAM STATION
DUKE ENERGY CAROLINAS, LLC, BELEWS CREEK NC
Monitoring
Well ID
Estimated
Well Depth
(feet bgs)'
Soil Sample ID
(Estimated Depth
Interval in feet bgs)Z
Preferred Drilling Method 3
Comments°
GWA-23BR
100
NA
Hollow -Stem Auger/Air Rotary or Sonic
Rock sample from bedrock well screened interval and HAO/HFO sample
SFMW-1BR
100
NA
Hollow -Stem Auger/Air Rotary or Sonic
Rock sample from bedrock well screened interval and HAO/HFO sample
SFMW-2BR
100
NA
Hollow -Stem Auger/Air Rotary or Sonic
Rock sample from bedrock well screened interval and HAO/HFO sample
SFMW-4BR
100
NA
Hollow -Stem Auger/Air Rotary or Sonic
Rock sample from bedrock well screened interval and HAO/HFO sample
SFMW-6SB (2-4)
Near -surface unsaturated soil sample, water table —10 feet bgs
SFMW-6SB (5-7)
Unsaturated soil sample, water table —10 feet bgs
SFMW-6SB 8-10
Unsaturated to partially saturated soil sample, water table —10 feet bgs
SFMW-6S
30
SFMW-6SB 20-30
Hollow -Stem Auger
Soil sample from shallow well screened interval and HAO/HFO sample
SFMW-6D
60
SFMW-6SB 50-60
Hollow -Stem Auger/Air Rotary or Sonic
Soil/partially weathered rock sample from deep well screened interval and HAO/HFO sample
SFMW-7SB (2-4)
Near -surface unsaturated soil sample, water table —10 feet bgs
SFMW-7SB 5-7
Unsaturated soil sample, water table —10 feet bgs
SFMW-7SB 8-10
Unsaturated to partially saturated soil sample, water table —10 feet bgs
SFMW-7S
30
SFMW-7SB 20-30
Hollow -Stem Auger
Soil sample from shallow well screened interval and HAO/HFO sample
SFMW-7D
60
SFMW-7SB (50-60
Hollow -Stem Auger/Air Rotary or Sonic
Soil/partially weathered rock sample from deep well screened interval and HAO/HFO sample
Prepared by: ALA Checked by: CDE
Notes:
bgs = below ground surface
— = Approximately
HAO = Hydrous aluminum Oxide
HFO = Hydrous ferric oxides
'Proposed boring depths and screened intervals are estimates based on well construction information from nearest spatitally existing wells; actual screened intervals and total boring depths will be determined based on field
observations and approved by a NC Licensed Geologist. SynTerra recommends each well screen be submerged beneath the water table and have a length of at least 10 feet
ZNumber of soil samples shown is approximate. A shallower water table will result in fewer samples, and a deeper water table will result in additional samples.
'SynTerra recommends a combination of hollow stem auger and air rotary or sonic drilling methods for boring and well installation
°Soil sample for inorganic analysis and HAO/HFO sample collection by means of split spoon techniques within the open borehole provide sufficient material for soil sampling and lithologic description. 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 2
SOIL ANALYTICAL PARAMETERS
BELEWS CREEK STEAM STATION
DUKE ENERGY CAROLINAS, LLC, BELEWS CREEK, NC
INORGANIC COMPOUNDS
PSRG POG
UNITS
METHOD
Aluminum
110000
mg/kg
EPA 6010D
Antimony
0.9
mg/kg
EPA 6020B
Arsenic
5.8
mg/kg
EPA 6020B
Barium
580
mg/kg
EPA 6010D
Beryllium
63
mg/kg
EPA 6020B
Boron
45
mg/kg
EPA 6010D
Cadmium
3
mg/kg
EPA 6020B
Calcium
NE
mg/kg
EPA 6010D
Chloride*
NE
mg/kg
EPA 9056A
Chromium
3.8
mg/kg
EPA 6010D
Cobalt
0.9
mg/kg
EPA 6020B
Copper
700
mg/kg
EPA 6010D
Iron
150
mg/kg
EPA 6010D
Lead
270
mg/kg
EPA 6020B
Magnesium
NE
mg/kg
EPA 6010D
Manganese
65
mg/kg
EPA 6010D
Mercury
1
mg/kg
EPA 7471B or 7470A
Molybdenum
7.1
mg/kg
EPA 6010D
Nickel
130
mg/kg
EPA 6010D
Nitrate as Nitrogen*
NE
mg/kg
EPA 9056A
pH*
NE
S.U.
EPA 9045D
Potassium
NE
mg/kg
EPA 6010D
Selenium
2.1
mg/kg
EPA 6020B
Sodium
NE
mg/kg
EPA 6010D
Strontium
1500
mg/kg
EPA 6010D
Sulfate*
NE
mg/kg
EPA 9056A
Thallium (low level)
0.28
mg/kg
EPA 6020B
Total Organic Carbon*
NE
mg/kg
EPA 9060A
Vanadium
350
mg/kg
EPA 6020B
Zinc
1200
mg/kgmg/kg
EPA 6010D
Prepared by: RBI Checked by: CJS
Notes:
1. Soil samples to be analyzed for Total Inorganics using USEPA Methods 6010/6020 and pH using USEPA Method 9045, as noted above.
Select soil samples will also be analyzed for leaching potential using SPLP Extraction Method 1312 in conjunction with USEPA Methods
6010/6020.
2. Analytical methods and reporting limits as presented were applicable as of May 6, 2019. Analytical methods and reporting limits are
updated periodically and applied as appropriate.
*Select constituents are not analyzed for leaching potential.
PSRG POG - Primary Soil Remediation Goals Protection of Groundwater
mg/kg - Milligrams per kilogram
S.U. - Standard Unit
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TABLE 3
GROUNDWATER ANALYTICAL PARAMETERS
BELEWS CREEK STEAM STATION
DUKE ENERGY CAROLINAS, LLC, BELEWS CREEK, NC
PARAMETER
RL
I UNITS
METHOD
FIELD PARAMETERS
H
NA
SU
Field Water Quality Meter
Specific Conductance
NA
PS/Cm
Field Water Quality Meter
Oxidation/Reduction Potential
NA
mV
Field Water Quality Meter
Temperature
NA
oC
Field Water Quality Meter
Eh
NA
mV
Field Water Quality Meter and Calculation
Dissolved Oxygen
NA
m /L
Field Water Quality Meter
Turbidity
NA
NTU
Field Water Quality Meter
INORGANICS (total and dissolved)
Aluminum
5
L
EPA 200.7
Antimony
1
L
EPA 200.8
Arsenic
1
L
EPA 200.8
Barium
5
L
EPA 200.7
Beryllium
1
L
EPA 200.8
Boron
50
L
EPA 200.7
Cadmium
0.1
L
EPA 200.8
Chromium
1
L
EPA 200.8
Chromium VI
0.025
L
EPA 218.7
Cobalt
1
L
EPA 200.8
Copper
1
L
EPA 200.8
Iron
10
L
EPA 200.7
Lead
1
L
EPA 200.8
Lithium
2.5
L
EPA 200.8
Manganese
5
L
EPA 200.7
Mercury
0.00005
m L
EPA 245.1 or 7470A
Molybdenum
1
L
EPA 200.8
Nickel
1
L
EPA 200.8
Phosphorus
0.0005
L
EPA 365.1
Selenium
1
L
EPA 200.8
Silver
0.3
L
EPA 200.8
Strontium
5
L
EPA 200.7
Thallium low level
0.2
L
EPA 200.8
Vanadium low level
0.3
/L
EPA 200.8
Zinc
5
L
EPA 200.7
RADIONUCLIDES
Radium 226
1
Ci/L
EPA 903.1 Modified
Radium 228
1
Ci/L
EPA 904.0/SW846 9320 Modified
Uranium 233 234 236 238
Varies by isotope
mL
SW846 3010A 6020A
ANIONS/CATIONS/OTHER
Alkalinity (as CaCO3)
5
m L
SM 2320E
Bicarbonate
5
m L
SM 2320E
Calcium
0.01
m L
EPA 200.7
Carbonate
5
m L
SM 2320E
Chloride
0.1
m L
EPA 300.0
Fluoride
0.1
m L
EPA 300.0
Magnesium
0.005
m L
EPA 200.7
Nitrate + Nitrite
0.01
m -N L
EPA 353.2
Potassium
0.1
m L
EPA 200.7
Sodium
0.05
m L
EPA 200.7
Sulfate
0.1
m L
EPA 300.0
Sulfide
0.1
m L
SM 4500-S2D
Total Dissolved Solids
25
m L
SM 2540C
Total Organic Carbon
0.1
m L
SM5310B EPA9060A
Total Sus ended Solids
2.5
m L
SM 2540D
Prepared by: REB Checked by: KHG
Notes:
°C - Degrees Celsius
µS/cm - micro -Siemens per centimeter
µg/L - Micrograms per liter
µg/mL - Micrograms per milliliter
RL - Reporting limit
mg - N/L - Milligrams nitrogen per liter
mg/L - Milligrams per liter
mV - Millivolts
NTU - Nephelometric turbidity unit
pCi/L - Picocuries per liter
S.U. - Standard Unit
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