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HomeMy WebLinkAbout2019-05-15 Duke Mayo Gyp Pad Assessment Work Plan_20190515DUKE ENERGY May 15, 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 Gypsum Pad 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. Pursuant to technical direction provided in the September 8, 2017 letter and additional clarification in correspondence from NCDEQ dated April 5, 2019, the gypsum pad at the Duke Energy Mayo Steam Electric Plant (Mayo) requires completion of a Comprehensive Site Assessment (CSA) submitted to NCDEQ no later than March 31, 2020. Duke Energy is submitting the attached Gypsum Pad Assessment Work Plan to assess potential groundwater and soil impacts from the gypsum pad at Mayo. Upon concurrence with this work plan, Duke Energy will pursue receipt of necessary permits for the installation of 15 proposed groundwater monitoring wells and perform associated sampling and analysis for the gypsum pad. Call or email me at 336-215-4576 or kimberlee.witt(&duke-energy com if you need additional information. Regards, '#6:, 4, 0�#— Kimberlee Witt, PE Environmental Services Attachments: Gypsum Pad Assessment Work Plan (SynTerra May 2019) cc: Coal Ash War Room — NCDEQ Mayo Gypsum Pad Page 1 of 2 Rick Bolich - NCDEQ Eric Smith - NCDEQ Steve Lanter - NCDEQ Ed Sullivan — Duke Energy Jerry Wylie - SynTerra Mayo Gypsum Pad Page 2 of 2 ,61P synTerra GYPSUM PAD ASSESSMENT WORK PLAN MAYO STEAM ELECTRIC PLANT 10660 BOSTON ROAD ROXBORO, NC 27574 MAY 2019 PREPARED FOR f ' DUKE ENERGY DUKE ENERGY PROGRESS, LLC Jer.y A. ylie,, N LG 1425 Project Manager Peggy W. Altman Project Scientist Gypsum Pad Assessment Work Plan May 2019 Mayo Steam Electric Plant SynTerra TABLE OF CONTENTS SECTION PAGE 1.0 INTRODUCTION.........................................................................................................1-1 1.1 Regulatory Background...........................................................................................1-1 1.2 Site Description.........................................................................................................1-1 2.0 GYPSUM PAD ASSESSMENT OBJECTIVES........................................................2-1 2.1 Soil Assessment......................................................................................................... 2-1 2.2 Groundwater Assessment........................................................................................ 2-1 3.0 GYPSUM PAD ASSESSMENT REPORT.................................................................3-1 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 Soil Samples and Monitoring Wells Table 3 Groundwater Analytical Methods Page i Gypsum Pad Assessment Work Plan May 2019 Mayo Steam Electric Plant SynTerra 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. Proposed groundwater and soil assessment activities for the gypsum pad is 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. Pursuant to technical direction provided in the September 8, 2017 letter, NCDEQ requested assessment of the gypsum pad at Mayo. 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) • Corrective Action Plan Part 1 —Mayo Steam Electric Plant (SynTerra, December 1, 2015) Page 1-1 Gypsum Pad Assessment Work Plan May 2019 Mayo Steam Electric Plant SynTerra • 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 gypsum pad at Mayo Plant is not discussed in detail in the documents described above. The unit is located in the central portion of the Plant south of the ash basin (Figure 1). The gypsum pad is approximately two acres and was put into operation in May 2009 to contain and temporarily store synthetic gypsum generated by the Plant's flue gas desulfurization (FGD) scrubbing process. A synthetic liner was installed in the footprint of the gypsum pad in 2016. The gypsum pad is bounded to the north and east by internal Plant access roads and buildings as well as the Plant railroad line. The pad is bounded to the west and south by the coal pile and internal Plant access roads. The gypsum pad appears to be positioned in a separate flow regime from the ash basin area. Hydrogeological interpretation based on previous Site assessment activities indicates that a groundwater divide is present roughly correlated with the ridge upon which the Plant railroad is constructed. Groundwater flows to the west and north on the west side of the ridge, and groundwater flows to the east towards Mayo Reservoir on the east side of the ridge. The gypsum pad area does not appear to be coincident to nor flow into the ash basin. However, given its historical use and the potential for CCR impacts from this unit, groundwater and soil assessment will be conducted as required by 02L. Groundwater flow will be evaluated as part of this proposed assessment work. Page 1-2 Gypsum Pad Assessment Work Plan May 2019 Mayo Steam Electric Plant SynTerra 2.0 GYPSUM PAD ASSESSMENT OBJECTIVES Objectives of the gypsum pad assessment include the following: • Characterize inorganic constituents associated with source area (gypsum pad) soils • Compare inorganic constituent concentrations in source area soils with Site background soils • Characterize inorganic constituent concentrations in groundwater underlying the source area and just beyond the source area perimeter Compare inorganic constituent concentrations in source area groundwater with Site background groundwater 2.1 Soil Assessment Gypsum pad 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 02L standards or Site provisional background threshold values (PBTV). Soil samples will be collected at proposed monitoring well locations as part of well installation activities. Soil analytical procedures are provided in Table 1. 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. Synthetic Precipitation Leaching Procedure (SPLP) samples for inorganics analysis 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). 2.2 Groundwater Assessment Groundwater conditions proximate to the area of investigation will be assessed by installing groundwater monitoring wells in and around the gypsum pad and collecting/analyzing representative groundwater samples from the wells. A maximum total of 15 gypsum pad assessment groundwater monitoring wells (GYP) is proposed to be installed to characterize groundwater conditions at their respective locations. Five well clusters, each consisting of a shallow ("S"), transition zone ("D"), and bedrock ("BR") groundwater monitoring well (GYP-1S/D/BR, GYP-2S/D/BR, GYP - Page 2-1 Gypsum Pad Assessment Work Plan May 2019 Mayo Steam Electric Plant SynTerra 3S/D/BR, GYP- 4S/D/BR, GYP-5S/D/BR), are planned to be installed at the proposed locations shown in Figure 2. Well locations may be modified from those shown on Figure 2 based on field constraints (e.g. underground utility locations, rig stability). Further, based on field conditions, it is possible that saturated conditions will not be encountered at all well locations; therefore, a lower number of wells may actually be installed. 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). 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). Page 2-2 Gypsum Pad Assessment Work Plan May 2019 Mayo Steam Electric Plant SynTerra 3.0 GYPSUM PAD ASSESSMENT REPORT An assessment report will be prepared after soil and groundwater sample analytical data is received, validated, and evaluated. 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 Recommendations Page 3-1 Gypsum Pad Assessment Work Plan May 2019 Mayo Steam Electric Plant FIGURES SynTerra VIRGINIA.- _-' NORTH CAROLINA-, � u MAYO STEAM ASH BASIN COMPLIANCE •;a ! p �' ELECTRIC PLANT BOUNDARY Hwy, � PARCEL LINE ! J r if FAQ APPROXIMATE ASH BASIN . ...JJJ WASTE BOUNDARY 100' RIGHT-OF-WAY i } i/ \ I i ♦ r^ WASTE WATER -\5 G_ /I /`♦—TREATMENT BASIN SIG l I CCPMONOFILL APPROXIMATE FUTURE (SEE NOTE S r�eShrJ ]HiA ' a . , • , , NOTES:, 2017 USGS TOPOGRAPHIC MAP, QUADRANGLE NAME, CLUSTER SPRINGS, QUAD I 36078E8, QUADRANGLE, OBTAINED FROM ARCGIS ONLINE, APRIL 25, 2019. ��_ •r.J } •' r __ �� ll_ - AREA OF INVESTIGATION THAT DETERMINED SETTLED CCR MATERIAL IS NOT PRESENT IN THIS AREA OF THE ASH BASIN. A FUTURE J --, • /� j '++ � 4LJ.i __- \J `T •, � .. �- st.6' REPRESENTATIVE ASH BASIN WASTE AND COMPLIANCE BOUNDARY IS INCLUDED IN THE MAYO NPDES PERMIT NCO038377 PART I, 5.A.(18.)- 1 'r. ATTACHMENTA FIGURE 1 ANDATTACHMENT B FIGURE 1.1 DATED JULY 13, 2018. PERSON COUNTY FIGURE 1 *' SITE LOCATION MAP synTerra W/NSTON-SALEM GYPSUM PAD ASSESSMENT WORK PLAN • RALEI H MAYO STEAM ELECTRIC PLANT DUKE ENERGY PROGRESS, LLC DUKE CHARLOTTE ROXBORO, NORTH CAROLINA ENERGY DRAWN BY: A. ROBINSON DATE:4/2G/2019 1,000 0 1,000 2,000 PROGRESS PROJECT MANAGER: J. WYLIE CONTOUR INTERVAL: 201 GRAPHIC SCALE IN FEET CHECKED BY: P. ALTMAN MAP DATE: 2016 �. . GYP-4 ♦�♦ -GYP-1... ,. �... _'�,`'S-•-;�; - - �! ♦ / ` :.fir : ' GYP-5 x! GYP-2 � ram:. � is •.Y _ . -..♦� � t I it _ "ice'^• .: a ; ' �. GYP-3 ■• `�-� � -. oo -2_ �r a . �. SOURCE: AERIAL PHOTOGRAPHY OBTAINED FROM GOOGLE EARTH PRO, DATED 1011412013. J LEGEND GRAPHIC SCALE FIGURE 2 50 25 0 50 100 PROPOSED MONITORING PROPOSED MONITORING WELL �%^ IN FEET synTerra WELLS AND SOIL BORING LOCATIONS 0 GYPSUM PAD GR RIVERSTREET,SUITE GREENVILLE,SOUTHCAROLINLINA29601 GYPSUM PAD ASSESSMENT WORK PLAN 0 ASPHALT PAVEMENT PHONE864-421-9999 MAYO STEAM ELECTRIC PLANT ASPHALT SURFACING 'DUKE DRAWN BY: A.ROBI'llNSON DATE:05/10/2019 DUKE ENERGY PROGRESS, LLC APPROXIMATE ASH BASIN COMPLIANCE ENERGY CHECKED BY:PROJECT P. LTMAN LIE ROXBORO, NORTH CAROLINA BOUNDARY PROGRESS P:\Duke Ener Pro ress.1026\00 GIS BASE DATA Ma o\Ma Docs\Pro osal Sam lin 201610271G sumPile.mxd Gypsum Pad Assessment Work Plan May 2019 Mayo Steam Electric Plant Tables SynTerra TABLE 1 SOIL SAMPLE ANALYTICAL METHODS GYPSUM PAD ASSESSMENT WORK PLAN 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 I mg/kg JEPA 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 mV - Millivolts S.U. - Standard Unit Page 1 of 1 TABLE 2 PROPOSED SOIL SAMPLES AND MONITORING WELLS GYPSUM PAD ASSESSMENT WORK PLAN MAYO STEAM ELECTRIC PLANT DUKE ENERGY PROGRESS, LLC, ROXBORO, NC Monitoring Well ID Estimated Well Depth (feet bgs) Soil Sample ID (Estimated Depth Interval in feet bgs) Comments GYP-SB1 (2-3) Near -surface unsaturated soil sample (water table —20 feet bgs) GYP-SBl (Various) Continue soil sampling at 5' intervals until the bottom of unconsolidated material is reached. (i.e., 7-8', 12-13', 17-18', etc.) GYP-SBl (19-20) Saturated soil sample (may not apply) GYP-1S 30 GYP-SBl (25-26) Soil sample from shallow well screened interval GYP-1D 50 GYP-SBl (45-46) Soil sample from deep well screened interval GYP-1611 80 GYP-SBl (75-76) Rock sample from bedrock well screened interval GYP-S132 (2-3) Near -surface unsaturated soil sample (water table —20 feet bgs) GYP-S132 (Various) Continue soil sampling at 5' intervals until the bottom of unconsolidated material is reached. (i.e., 7-8', 12-13', 17-18', etc.) GYP-SB2 (19-20) Saturated soil sample (may not apply) GYP-2S 30 GYP-S132 (25-26) Unsaturated soil sample GYP-2D 50 GYP-S132 (45-46) Soil sample from shallow well screened interval GYP-2611 80 GYP-SB2 (75-76) Rock sample from bedrock well screened interval GYP-S133 (2-3) Near -surface unsaturated soil sample (water table —20 feet bgs) GYP-S133 (Various) Continue soil sampling at 5' intervals until the bottom of unconsolidated material is reached. (i.e., 7-8', 12-13', 17-18', etc.) GYP-S133 (19-20) Saturated soil sample (may not apply) GYP-3S 30 GYP-S133 (25-26) Unsaturated soil sample GYP-3D 50 GYP-S133 (45-46) Soil sample from shallow well screened interval GYP-3BR 80 GYP-S133 (75-76) Rock sample from bedrock well screened interval GYP-SB4 (2-3) Near -surface unsaturated soil sample (water table —20 feet bgs) GYP-S134 (Various) Continue soil sampling at 5' intervals until the bottom of unconsolidated material is reached. (i.e., 7-8', 12-13', 17-18', etc.) GYP-S134 (19-20) Saturated soil sample (may not apply) GYP-4S 30 GYP-S134 (25-26) Unsaturated soil sample GYP-4D 50 GYP-S134 (45-46) Soil sample from shallow well screened interval GYP-4BR 80 GYP-SB4 (75-76) Rock sample from bedrock well screened interval GYP-S135 (2-3) Near -surface unsaturated soil sample (water table —20 feet bgs) GYP-S135 (Various) Continue soil sampling at 5' intervals until the bottom of unconsolidated material is reached. (i.e., 7-8', 12-13', 17-18', etc.) GYP-SB5 (19-20) Saturated soil sample (may not apply) GYP-5S 30 GYP-S135 (25-26) Unsaturated soil sample GYP-5D 50 GYP-S135 (45-46) ISoil sample from shallow well screened interval GYP-56R 80 GYP-SB5 (75-76) 1 Rock sample from bedrock well screened interval Notes: bgs - below ground surface - Approximately Estimated well and soil sample depths based on data from the CCR-101S-BG, CCR-101D-13G, 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. Prepared by: PWA Checked by: JAW Page 1 of 1 TABLE 3 GROUNDWATER ANALYTICAL METHODS GYPSUM PAD ASSESSMENT WORK PLAN MAYO STEAM ELECTRIC PLANT DUKE ENERGY PROGRESS LLC, ROXBORO, NC PARAMETER RL I UNITS METHOD FIELD PARAMETERS pH 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 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 INORGANICS 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 6020A Barium 0.005 mg/L EPA 200.7 or 6010C Beryllium 0.001 mg/L EPA 200.8 or 6020A Boron 0.05 mg/L EPA 200.7 or 6010C Cadmium 0.001 mg/L EPA 200.8 or 6020A Chromium 0.001 mg/L EPA 200.8 or 6010C Cobalt 0.001 mg/L EPA 200.8 or 6020A 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 6010C Lead 0.001 mg/L EPA 200.8 or 6020A Manganese 0.005 mg/L EPA 200.7 or 6010C Mercury 0.000 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 6020A Strontium 0.005 mg/L EPA 200.7 or 6010C Thallium (low level) 0.0002 mg/L EPA 200.8 or 6020A Vanadium (low level) 0.0003 mg/L EPA 200.8 or 6020A Zinc 0.005 mg/L EPA 200.7 or 6010C RADIONUCLIDES Radium 226 1 pCi/L EPA 903.1 Modified Radium 228 1 pCi/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 mg/L SM 2320B Bicarbonate 5 mg/L SM 2320 Calcium 0.01 mg/L EPA 200.7 Carbonate 5 mg/L SM 2320 Chloride 0.1 mg/L EPA 300.0 or 9056A Magnesium 0.005 mg/L EPA 200.7 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 SM4500S2-D Total Dissolved Solids 25 mg/L SM 2540C Total Organic Carbon 0.1 mg/L SM 5310C/EPA9060A Total Suspended Solids 2.5 m L SM 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 VS/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 Page 1 of 1