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HomeMy WebLinkAboutREVISED_Duke_BelewsCreek_CoalPile_Assessment_WorkPlan_20190715161p synTerra COAL PILE AREA ASSESSMENT WORK PLAN FOR BELEWS CREEK STEAM STATION 3195 PINE HALL ROAD BELEWS CREEK, NC 27009 SUBMITTED: MAY 2019 REVISED: DULY 2019 PREPARED FOR DUKE ENERGY CAROLINAS, LLC ('DUKE ENERGY PREPARED BY SYNTERRA CORPORATION Ashley A ert, NC LG 2615 Project Manager J David Avard Project Scientist Coal Pile Area Assessment Work Plan Submitted May 2019; Revised July 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 COAL PILE 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 Proposed Coal Pile Assessment Sample Locations LIST OF TABLES Table 1 Proposed Coal Pile Assessment Soil Samples and Monitoring Wells Table 2 Soil Analytical Parameters Table 3 Groundwater Analytical Parameters List of Attachments Attachment A Coal Pile Area Assessment Work Plan Comments — Belews Creek Steam Station (June 24, 2019) Page i Coal Pile Area Assessment Work Plan Submitted May 2019; Revised July 2019 Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra 1.0 INTRODUCTION This revised work plan provides a description of groundwater and soil assessment activities proposed for the Coal Pile area at the Belews Creek Steam Station (BCSS, Station, or Site), with consideration of comments received by North Carolina Department of Environmental Quality (NCDEQ) on June 24, 2019 (Attachment A). BCSS is owned and operated by Duke Energy Carolinas, LLC (Duke Energy). The Site, located in Stokes County, North Carolina, encompasses approximately 6,100 acres of company -owned property along Belews Reservoir. The Coal Pile is located east of the Structural Fill and southeast of the ash basin (Figure 1). 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). The Coal Pile is not coincident with the ash basin, as it is located approximately 1,700 feet southeast of the ash basin and a topographic hydrogeological divide represented by Pine Hall Road. The topographic hydrogeological divide was identified through Site assessment information from the CSA and CSA Update. Groundwater flow direction beneath the Coal Pile is predicted to be predominantly away from the ash basin, and toward the plant area and Belews Reservoir. Groundwater monitoring well GWA-6S/D is located approximately 1,000 feet north of the Coal Pile, and GWA-7S/D is located approximately 500 feet northwest of the Coal Pile (Figure 1). However, these wells are considered upgradient of the Coal Pile. No existing monitoring wells are located in areas predicted to be downgradient, in the direction of groundwater flow from the Coal Pile. Because no groundwater sampling results are currently available for use in assessing the area, assessment of inorganic constituents in soils and groundwater in the Coal Pile area is planned. Duke Energy understands the Coal Pile area groundwater and soils could be primary and secondary sources of inorganic constituents that are to be further assessed apart from CAMA or the CCR Rule. Page 1-1 P:\Duke Energy Carolinas\20. BELEWS CREEK\29.Structural Fill, Coal Pile and Gypsum Pad Assessment\02.Coal Pile Groundwater Assessment\Belews Creek - Coal Pile Assessment Work Plan.docx Coal Pile Area Assessment Work Plan Submitted May 2019; Revised July 2019 Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra 1.2 Site Description Detailed descriptions of the Site operational history, physical setting and features, geology/hydrogeology, and results of the findings of Site assessment -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). • 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 Coal Pile is the storage field for coal used in the Station's process for power generation. The storage field holds about 1,350,000 tons of coal covering an area of approximately 42 acres. The approximate footprint of the coal pile area is depicted on Figure 1. The Coal Pile storage field is unlined and has been maintained at the same location since Station operations began in 1974. The Coal Pile has been identified as a potential additional source of inorganic constituents in groundwater by NCDEQ. Page 1-2 P:\Duke Energy Carolinas\20. BELEWS CREEK\29.Structural Fill, Coal Pile and Gypsum Pad Assessment\02.Coal Pile Groundwater Assessment\Belews Creek - Coal Pile Assessment Work Plan.docx Coal Pile Area Assessment Work Plan Submitted May 2019; Revised July 2019 Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra 2.0 COAL PILE ASSESSMENT OBJECTIVES Objectives of the Coal Pile assessment include the following: • Characterize unsaturated soil inorganic constituents for assessment of potential secondary sources to groundwater. • Determine groundwater flow direction. • Compare inorganic constituent concentrations in the Coal Pile area with site background concentrations evaluated during the CAMA ash basin assessment and with other applicable regulatory criteria. • Evaluate potential constituent transport. 2.1 Soil Assessment Coal Pile area soils would be sampled and analyzed for inorganic parameters to determine whether 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 2 to 3 feet below ground surface, and one saturated sample collected 2 to 3 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). After the first round of groundwater sampling, wells that are geochemically significant to the Site would be selected for analysis as necessary. Page 2-1 P:\Duke Energy Carolinas\20. BELEWS CREEK\29.Structural Fill, Coal Pile and Gypsum Pad Assessment\02.Coal Pile Groundwater Assessment\Belews Creek - Coal Pile Assessment Work Plan.docx Coal Pile Area Assessment Work Plan Submitted May 2019; Revised July 2019 Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra 2.2 Groundwater Assessment Twenty-four (24) Coal Pile area assessment groundwater monitoring wells (designated as "CP ") would be installed in shallow, deep, and bedrock groundwater zones in designated areas surrounding the Coal Pile. Proposed Coal Pile area well installation locations are shown on Figure 1, and proposed well details are provided as Table 1. The shallow zone is considered groundwater within soil and unconsolidated saprolite material. The deep zone is considered groundwater within partially weathered rock, transition zone material underlying the shallow zone, and overlying competent bedrock. The bedrock zone is considered competent rock, with potential for bedrock fractures. Eight shallow ("S"), eight deep ("D"), and eight bedrock ("BR") groundwater monitoring wells (CP-1S/D/BR through CP-8S/D/BR) would be installed as well clusters surrounding the Coal Pile. Specific well locations may be shifted depending on 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 prepacked screens. After installation, the monitoring wells would be developed in order to remove drill fluids, clay, silt, sand, and other fines, which might have been introduced into the formation or sand pack during drilling and well installation, and to establish communication of the well with the aquifer. After 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 will be analyzed for constituent parameters in Table 3. Water levels would be collected within a 24-hour time frame. Data would be used for depicting water elevation contours and determining groundwater flow directions. Slug testing would be performed for each groundwater monitoring well installed to evaluate Page 2-2 P:\Duke Energy Carolinas\20. BELEWS CREEK\29.Structural Fill, Coal Pile and Gypsum Pad Assessment\02.Coal Pile Groundwater Assessment\Belews Creek - Coal Pile Assessment Work Plan.docx Coal Pile Area Assessment Work Plan Submitted May 2019; Revised July 2019 Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra hydraulic conductivity of each flow zone. Horizontal and vertical gradients and groundwater velocity would be calculated. Page 2-3 P:\Duke Energy Carolinas\20. BELEWS CREEK\29.Structural Fill, Coal Pile and Gypsum Pad Assessment\02.Coal Pile Groundwater Assessment\Belews Creek - Coal Pile Assessment Work Plan.docx Coal Pile Area Assessment Work Plan Submitted May 2019; Revised July 2019 Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra 3.0 REPORTING The Coal Pile assessment findings would be presented in a CSA report that would be submitted to the NCDEQ Division of Water Resources (DWR) on March 31, 2020, as requested in an April 5, 2019, letter to Duke Energy. The report will include the following components: 1) Site History and Source Characterization 2) Site Geology and Hydrogeology 3) Sampling Results 4) Site Conceptual Model 5) Conclusions and Recommendations Page 3-1 P:\Duke Energy Carolinas\20. BELEWS CREEK\29.Structural Fill, Coal Pile and Gypsum Pad Assessment\02.Coal Pile Groundwater Assessment\Belews Creek - Coal Pile Assessment Work Plan.docx Coal Pile Area Assessment Work Plan Submitted May 2019; Revised July 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\02.Coal Pile Groundwater Assessment\Belews Creek - Coal Pile Assessment Work Plan.docx K( LAYDOWN AREA (NO DISTURBANCE ANTICIPATED) ti ------------ �' • INSET SCALE. 1'=125" F -- BELEWS RESERVOIR LEGEND la > d 6 1 o e e • �: lll�E __ � ' arm• ��� �.—.� { lQ'1 GRAPHIC SCALE C DUKE ENERGY® CAROLINAS 150 0 150 300 (IN FEET( FIGURE 1 PROPOSED COAL PILE ASSESSMENT SAMPLE LOCATIONS BELEWS CREEK STEAM STATION DRAWN BY: B.YOUNG DATE:05/09/2019 REVISED BY: B. YOUNG DATE: 07/12/2019 o Terra synwww.synterracorp.com CHECKED BY: A. ALBERT DATE: 07/12/2019 APPROVED BY: A. ALBERT DATE: 07/12/2019 PROJECT MANAGER: A. ALBERT BELEWS CREEK, NORTH CAROLINA Coal Pile Area Assessment Work Plan Submitted May 2019; Revised July 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\02.Coal Pile Groundwater Assessment\Belews Creek - Coal Pile Assessment Work Plan.docx TABLE 1 PROPOSED COAL PILE AREA 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)l Soil Sample ID (Estimated Depth Interval in feet bgs)Z Preferred Drilling Method 3 Comments° CP-1SB (2-4) Near -surface unsaturated soil sample, water table —10 feet bgs CP-1SB (5-7) Unsaturated soil sample, water table —10 feet bgs CP-1SB (8-10) Unsaturated to partially saturated soil sample, water table —10 feet bgs CP-1S 30 CP-1SB (20-30) Hollow -Stem Auger Soil sample from shallow well screened interval and HAO/HFO sample CP-1D 60 CP-1SB 50-60 Hollow -Stem Auger/Air Rotary or Sonic Soil/partially weathered rock sample from deep well screened interval and HAO/HFO sample CP-113R 100 CP-1SB (90-100) Hollow -Stem Auger/Air Rotary or Sonic Rock sample from bedrock well screened interval and HAO/HFO sample CP-2SB (2-4) Near -surface unsaturated soil sample, water table —10 feet bgs CP-2SB (5-7) Unsaturated soil sample, water table —10 feet bgs CP-2SB (8-10) Unsaturated to partially saturated soil sample, water table —10 feet bgs CP-2S 30 CP-2SB (20-30) Hollow -Stem Auger Soil sample from shallow well screened interval and HAO/HFO sample CP-21) 60 CP-2SB (50-60) Hollow -Stem Auger/Air Rotary or Sonic Soil/partially weathered rock sample from deep well screened interval and HAO/HFO sample CP-2BR 100 CP-2SB 90-100 Hollow -Stem Auger/Air Rotary or Sonic Rock sample from bedrock well screened interval and HAO/HFO sample CP-3SB (2-4) Near -surface unsaturated soil sample, water table —10 feet bgs CP-3SB (5-7) Unsaturated soil sample, water table —10 feet bgs CP-3SB (8-10) Unsaturated to partially saturated soil sample, water table —10 feet bgs CP-3S 30 CP-3SB (20-30) Hollow -Stem Auger Soil sample from shallow well screened interval and HAO/HFO sample CP-3D 60 CP-3SB 50-60 Hollow -Stem Auqer/Air Rotary or Sonic Soil/partially weathered rock sample from deep well screened interval and HAO/HFO sample CP-3BR 100 CP-3SB 90-100 Hollow -Stem Auger/Air Rotary or Sonic Rock sample from bedrock well screened interval and HAO/HFO sample CP-4SB 2-4 Near -surface unsaturated soil sample, water table —10 feet bgs CP-4SB (5-7) Unsaturated soil sample, water table —10 feet bgs CP-4SB (8-10) Unsaturated to partially saturated soil sample, water table —10 feet bgs CP-4S 30 CP-4SB 20-30 Hollow -Stem Auger Soil sample from shallow well screened interval and HAO/HFO sample CP-4D 60 CP-4SB 50-60 Hollow -Stem Auqer/Air Rotary or Sonic Soil/partially weathered rock sample from deep well screened interval and HAO/HFO sample CP-4BR 100 CP-4SB 90-100 Hollow -Stem Auger/Air Rotary or Sonic Rock sample from bedrock well screened interval and HAO/HFO sample CP-5SB (2-4) Near -surface unsaturated soil sample, water table —10 feet bgs CP-5SB (5-7) Unsaturated soil sample, water table —10 feet bgs CP-5SB 8-10 Unsaturated to partially saturated soil sample, water table —10 feet bgs CP-5S 30 CP-5SB 20-30 Hollow -Stem Auger Soil sample from shallow well screened interval and HAO/HFO sample CP-5D 60 CP-5SB 50-60 Hollow -Stem Auqer/Air Rotary or Sonic Soil/partially weathered rock sample from deep well screened interval and HAO/HFO sample CP-513R 100 CP-5SB (90-100) Hollow -Stem Auger/Air Rotary or Sonic Rock sample from bedrock well screened interval and HAO/HFO sample P:\Duke Energy Progress. 1026\_ADMINISTRATIVE\Financial Management\Project Change Requests (PCRs)\Belews Creek\Proposal 14235 - Structural Fill, Coal Pile and Gypsum Pad Assessment Page 1 of 2 TABLE 1 PROPOSED COAL PILE AREA 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)l Soil Sample ID (Estimated Depth Interval in feet bgs)Z Preferred Drilling Method' Comments° CP-6SB (2-4) Near -surface unsaturated soil sample, water table —10 feet bgs CP-6SB 5-7 Unsaturated soil sample, water table —10 feet bgs CP-6SB 8-10 Unsaturated to partially saturated soil sample, water table —10 feet bgs CP-6S 30 CP-6SB 20-30 Hollow -Stem Auger Soil sample from shallow well screened interval and HAO/HFO sample CP-6D 60 CP-6SB (50-60) Hollow -Stem Auger/Air Rotary or Sonic Soil/partially weathered rock sample from deep well screened interval and HAO/HFO sample CP-6BR 100 CP-6SB (90-100) Hollow -Stem Auger/Air Rotary or Sonic Rock sample from bedrock well screened interval and HAO/HFO sample CP-7SB (2-4) Near -surface unsaturated soil sample, water table —10 feet bgs CP-7SB (5-7) Unsaturated soil sample, water table —10 feet bgs CP-7SB (8-10) Unsaturated to partially saturated soil sample, water table —10 feet bgs CP-7S 30 CP-7SB (20-30) Hollow -Stem Auger Soil sample from shallow well screened interval and HAO/HFO sample CP-7D 60 CP-7SB (50-60) Hollow -Stem Auger/Air Rotary or Sonic Soil/partially weathered rock sample from deep well screened interval and HAO/HFO sample CP-7BR 100 CP-7SB (90-100) Hollow -Stem Auger/Air Rotary or Sonic Rock sample from bedrock well screened interval and HAO/HFO sample CP-8SB (2-4) Near -surface unsaturated soil sample, water table —10 feet bgs CP-8SB (5-7) Unsaturated soil sample, water table —10 feet bgs CP-8SB (8-10) Unsaturated to partially saturated soil sample, water table —10 feet bgs CP-8S 30 CP-8SB (20-30) Hollow -Stem Auger Soil sample from shallow well screened interval and HAO/HFO sample CP-8D 60 CP-8SB (50-60) Hollow -Stem Auger/Air Rotary or Sonic Soil/partially weathered rock sample from deep well screened interval and HAO/HFO sample CP-8BR 100 CP-8SB (90-100) Hollow -Stem Auger/Air Rotary or Sonic Rock sample from bedrock well screened interval and HAO/HFO sample Prepared by: ALA Checked by: COE 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 INC Licensed Geologist. SynTerra recommends each well screen be submerged beneath the water table and have a length of at least 10 feet 2Number 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 P:\Duke Energy Progress. 1026\_ADMINISTRATIVE\Financial Management\Project Change Requests (PCRs)\Belews Creek\Proposal 14235 - Structural Fill, Coal Pile and Gypsum Pad Assessment Page 2 of 2 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/kq EPA 6020B Total Organic Carbon* NE mg/kg EPA 9060A Vanadium 350 mg/kg EPA 6020B Zinc 1200 mg/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 P:\Duke Energy Carolinas\20. BELEWS CREEK\29.Structural Fill, Coal Pile and Gypsum Pad Assessment\02.Coal Pile Groundwater Assessment\Tables\Table 2 - Soil Analytical Parameters Page 1 of 1 TABLE 3 GROUNDWATER ANALYTICAL PARAMETERS BELEWS CREEK STEAM STATION DUKE ENERGY CAROLINAS, LLC, BELEWS CREEK, NC PARAMETER RL UNITS METHOD FIELD PARAMETERS pH 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 mg/L Field Water Quality Meter Turbidity NA NTU Field Water Quality Meter INORGANICS (total and dissolved) Aluminum 5 pg/L EPA 200.7 Antimony 1 µ /L EPA 200.8 Arsenic 1 ug/L EPA 200.8 Barium 5 /L EPA 200.7 Beryllium 1 µg/L EPA 200.8 Boron 50 /L EPA 200.7 Cadmium 0.1 ug/L EPA 200.8 Chromium 1 /L EPA 200.8 Chromium (VI) 0.025 ug/L EPA 218.7 Cobalt 1 /L EPA 200.8 Copper 1 ug/L EPA 200.8 Iron 10 /L EPA 200.7 Lead 1 ug/L EPA 200.8 Lithium 2.5 /L EPA 200.8 Manganese 5 µg/L EPA 200.7 Mercury 0.00005 m /L EPA 245.1 or 7470A Molybdenum 1 µg/L EPA 200.8 Nickel 1 /L EPA 200.8 Phosphorus 0.0005 Ug/L EPA 365.1 Selenium 1 /L EPA 200.8 Silver 0.3 Ug/L EPA 200.8 Strontium 5 /L EPA 200.7 Thallium (low level) 0.2 Ug/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 pCi/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 mg/L SM 2320B Bicarbonate 5 mg/L SM 2320E Calcium 0.01 mg/L EPA 200.7 Carbonate 5 mg/L SM 2320E Chloride 0.1 mg/L EPA 300.0 Fluoride 0.1 mg/L EPA 300.0 Magnesium 0.005 mg/L EPA 200.7 Nitrate + Nitrite 0.01 m -N/L EPA 353.2 Potassium 0.1 mg/L EPA 200.7 Sodium 0.05 m /L EPA 200.7 Sulfate 0.1 mg/L EPA 300.0 Sulfide 0.1 m /L SM 4500-S2D Total Dissolved Solids 25 mg/L SM 2540C Total Organic Carbon 0.1 m /L SM53106/EPA9060A Total Suspended Solids 2.5 m L SM 2540D Prepared by: REB Checked by: KHG Notes: OC - Degrees Celsius VS/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 NA - not applicable NTU - Nephelometric turbidity unit pCi/L - Picocuries per liter S.U. - Standard Unit PADuke Energy Carolinas\20. BELEWS CREEK\29.Structural Fill, Coal Pile and Gypsum Pad Assessment\02.Coal Pile Groundwater Assessment\Tables\Table 3 - Groundwater Analytical Parameters Page 1 of 1 Coal Pile Area Assessment Work Plan Submitted May 2019; Revised July 2019 Duke Energy Carolinas, LLC — Belews Creek Steam Station SynTerra Attachment A P:\Duke Energy Carolinas\20. BELEWS CREEK\29.Structural Fill, Coal Pile and Gypsum Pad Assessment\02.Coal Pile Groundwater Assessment\Belews Creek - Coal Pile Assessment Work Plan.docx ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Paul Draovitch Senior Vice President Environmental, Health & Safety Duke Energy 526 South Church Street Mail Code EC3XP Charlotte, North Carolina 28202 NORTH CAROLINA Envfronmenta! Qualtty June 24, 2019 Subject: Coal Pile Area Assessment Work Plan Comments — Belews Creek Steam Station Dear Mr. Draovitch: On May 24, 2019, the North Carolina Department of Environmental Quality Division of Water Resources (Division) received the proposed Coal Pile Area Assessment Work Plan for the Belews Creek Steam Station. The Division has reviewed and hereby approves the proposed assessment activities under the condition that the following items are addressed as part of the plan implementation and the results reported in the comprehensive site assessment concerning the subject area. • Add a well cluster (shallow/deep/bedrock) immediately adjacent to and downgradient of the coal pile to assess potential impacts within the footprint of the storage field. • Please update Table 2 to reflect the additional wells requested. • Please add a line outlining the footprint of the coal pile on Figure 1 and clearly label any related features. • Surface water samples should be collected in Belews Reservoir east of proposed well cluster CP-4S/D/BR. • In addition to further characterizing groundwater flow regimes in the vicinity of the coal pile storage field, data should be collected from each proposed well to evaluate hydraulic parameters such as hydraulic conductivity and flow velocity in the area. If applicable, the results should also be incorporated into the updated CAP's revised geochemical and groundwater fate and transport models. If the results of the modeling show current or future impacts to groundwater and/or surface water from this area, then appropriate remedial strategies shall be proposed in the CAP. North Carolina Department of Environmental Quality I Division of Water Resources 0 I 512 North Salisbury Street 1 1636 Mail Service Center I Raleigh, North Carolina 27699-1636 919.707.9000 If you have any questions, please contact Shuying Wang (Winston-Salem Regional Office) at (336) 776-9702 or Steve Lanter (Central Office) at (919) 707-3667. Sincere Jon Risga Chief Animal Feeding Operations and Groundwater Section cc: WSRO WQROS Regional Office WQROS Central File Copy