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HomeMy WebLinkAboutDuke Mayo Coal Pile Add Assessment Work Plan_20190924DUKE ENERGY September 24, 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 Storage Pile Area Additional 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 Duke Energy is submitting the attached Additional Assessment Work Plan for the Coal Storage Pile Area (CSPA) at the Mayo Steam Electric Plant for your review. The initial assessment Work Plan for the CSPA was submitted on January 23, 2019 (revised February 10, 2019), approved by the North Carolina Department of Environmental Quality (NCDEQ) Raleigh Regional Office (RRO) on February 14, 2019. A revised Work Plan was submitted on February 20, 2019, approved by the RRO March 6, 2019. Initial assessment efforts indicate the presence of constituents (metals, other inorganics) in groundwater proximate with the CSPA. Three specific areas require additional investigation to complete the assessment. Upon concurrence with this Work Plan, Duke Energy will pursue receipt of necessary permits for the installation of 24 proposed groundwater monitoring wells, soil investigation, and perform associated sampling and analysis. If you need additional information regarding this submittal do not hesitate to call or email, 336- 215-4576 or kimberlee.witt@duke-energy.com. Respectfully submitted, '�4C�z 0-w- Kimberlee Witt, PE Environmental Services Mayo Steam Electric Plant - Page I of 2 Attachments: Work Plan for Additional Assessment — Coal Pile Area, Mayo Steam Electric Plant, SynTerra September 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 161p synTerra WORK PLAN FOR ADDITIONAL ASSESSMENT COAL PILE AREA MAYO STEAM ELECTRIC PLANT 10660 BOSTON ROAD ROXBORO, NC 27574 SEPTEMBER 2019 PREPARED FOR DUKE ENERGY PROGRESS DUKE ENERGY PROGRESS, LLC Jerry A Wylie, LG 1425 Project Manager Peggy W. Altman Project Hydrogeologist Work Plan for Additional Assessment - Coal Pile Area September 2019 Mayo Steam Electric Plant TABLE OF CONTENTS SECTION PAGE 1.0 INTRODUCTION.........................................................................................................1-1 1.1 Regulatory Background...........................................................................................1-1 1.2 Site Description.........................................................................................................1-2 1.3 Initial Assessment Results.......................................................................................1-3 2.0 COAL PILE ASSESSMENT OBJECTIVES..............................................................2-1 2.1 Soil Assessment......................................................................................................... 2-1 2.2 Groundwater Assessment....................................................................................... 2-2 2.3 Monitoring Well Assessment Procedures............................................................. 2-3 LIST OF FIGURES Figure 1 Site Location Map Figure 2 Proposed Additional 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 Work Plan for Additional Assessment — Coal Pile Area September 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 coal-fired unit. Coal is transported to Mayo by rail and stored on Site. This work plan describes activities proposed for further assessment of groundwater and soil around the Mayo coal pile area. Duke Energy submitted a coal pile assessment Work Plan on January 23, 2019 (revised February 10, 2019) that was approved by the NCDEQ Raleigh Regional Office (RRO) on February 14, 2019. A revised Work Plan was submitted on February 20, 2019 and approved by the RRO on March 6, 2019. The initial assessment effort conducted in the first half of 2019 indicated the presence of constituents (metals, other inorganics) in groundwater proximate with the coal pile. Initial assessment data indicate three specific areas around the coal pile to be evaluated further (Figure 2). The first area, an area represented by low pH in groundwater from wells CPA-1D, CPA-1BR, and CPA-7D, is located on the northwestern side of the coal pile. The second area is east of the basin, east of the coal pile, and is represented by well cluster CPA-5. The third area is southeast of the coal pile and is represented by well CPA-4D. These areas are described in more detail in Section 1.3. Initial groundwater assessment indicates that groundwater flow, as anticipated, moves beneath the coal pile and low pH area, approximately from southeast to northwest; however, detections of constituents in seemingly upgradient locations (CPA-4; CPA-5 wells) indicate the need for additional assessment of these areas. Proposed groundwater and soil assessment activities for the coal pile 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 residual (CCR) surface impoundment to conduct detailed assessment of Site groundwater within and around the CCR surface impoundment. Page 1-1 Work Plan for Additional Assessment — Coal Pile Area September 2019 Mayo Steam Electric Plant 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. 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) • 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 Mayo occupies approximately 20 to 30 acres and is located in the south- central portion of the Plant (Figure 2). 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). Surface water runoff from the area was historically directed to the ash basin; however, a coal pile retention basin and conveyance structures were constructed in 2018 on the western side of the coal pile area to capture run-off and direct it to new wastewater treatment facilities. Page 1-2 Work Plan for Additional Assessment — Coal Pile Area September 2019 Mayo Steam Electric Plant 1.3 Initial Assessment Results Initial assessment data indicate three specific areas around the coal pile to be evaluated further (Figure 2). Low pH Area The low pH area is an area (represented by CPA-71)) where groundwater pH values are approximately 4 standard units (S.U.) or less, which is less than S.U.s at other Site areas. The area is on the northwestern side of the coal pile is represented by wells CPA-11), CPA-1BR, and CPA-71). Boron is present in concentrations just below the 02L of 700 µg/L at CPA-71). The source of low groundwater pH conditions has not been identified. However, at other Duke Energy combustion facilities, similar conditions have been noted associated with "mill rejects" or "clinkers", rocks that become mixed with coal that was not combusted as part of the power generation process. Clinkers can be rich in pyrite and can cause low pH conditions in groundwater. Low pH conditions can cause metals/inorganics to solubilize and occur at concentrations notably greater than typically measured. No clinkers or similar material was noted during well installation activities at Mayo. Other possible reasons for the presence of the low pH groundwater area continue to be considered. Groundwater concentrations greater than regulatory comparison criteria are exceeded for a number of constituents (e.g., sulfate, TDS) in this area and other metals and inorganics are present. In general - except for iron and manganese - unsaturated soil concentrations do not exceed NC Preliminary Site Remediation Goals (PSRG) for Protection of Groundwater (POG) or site -specific Background Threshold Values (BTVs). CPA-413 Area The second area is southeast of the coal pile and is represented by well CPA-41). Elevated concentrations of cobalt, manganese, sulfate, and TDS were noted. Boron was detected above the background value but well below the 02L. In general - except for iron and manganese - unsaturated soil concentrations do not exceed POGs or BTVs. CPA-5 Well Cluster Area The third area is east of the basin and represented by well cluster CPA-5. Boron is present above site background values in the surficial well but far below the 02L. Boron was detected around the analytical reporting limit in the transition zone well and was undetected in the bedrock well. Elevated cobalt, iron, and manganese concentrations were noted in wells CPA-5S and SPA-51). In general - except for iron, manganese, and sporadic chromium detections - soil concentrations do not exceed POGs or BTVs. In Page 1-3 Work Plan for Additional Assessment — Coal Pile Area September 2019 Mayo Steam Electric Plant general - except for iron and manganese - unsaturated soil concentrations do not exceed POGs or BTVs. Based on initial assessment results, unsaturated soils in/around the coal pile are unimpacted. This finding indicates that the source of groundwater impact requires additional investigation. Page 1-4 Work Plan for Additional Assessment — Coal Pile Area September 2019 Mayo Steam Electric Plant 2.0 COAL PILE ASSESSMENT OBJECTIVES Objectives of the additional coal pile assessment activities presented in this work plan include the following: • Further characterize and delineate constituent concentrations in groundwater in three areas proximate to the coal pile. • Refine the understanding of groundwater flow direction in the coal pile area. • Evaluate the potential need for corrective action for the coal pile area. 2.1 Soil Assessment Although unsaturated soils do not indicate impact from CCR material, samples will be collected during assessment activities and for inorganic parameters consistent with assessment of areas used for coal and CCR management (Table 1). Coal pile area soils will be sampled and analyzed for metals and inorganic parameters to determine if they are a source that may leach into underlying groundwater in excess of NC 02L standards or BTVs. Soil samples will be collected during well drilling and installation 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 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). Additional soil borings will be completed around the concrete pad/foundation located near monitoring well CPA-4D, and soil samples will be collected and analyzed as detailed above. Only unsaturated soil samples will be collected from these borings and the borings will terminate either at refusal or when groundwater is encountered. Exploratory borings will be completed in the area between CPA-1 well cluster and proposed well cluster CPA-8 on the northwest side of the coal pile area. The area is approximately 600 feet long and borings are proposed approximately every 50 feet. Page 2-1 Work Plan for Additional Assessment — Coal Pile Area September 2019 Mayo Steam Electric Plant Continuous soil sampling will be conducted for visual observation of encountered soil/material using direct push techniques, rotary sonic drilling, or hollow -stem auger drilling with split -spoon samplers. The objective of this effort is to attempt to visually determine the possible presence of clinkers/rejects in the high pH area noted near CPA- 7D. In addition, although previous assessment results indicate no impacts to unsaturated soils in this area, approximately three to five of the planned borings will be sampled for laboratory analysis. Sampling depths for unsaturated soil samples will be similar to those presented for other proposed borings as provided in Table 2. 2.2 Groundwater Assessment The extent of groundwater impact in three areas identified during initial assessment activities will be assessed by installing groundwater monitoring wells and collecting/analyzing representative groundwater samples from newly completed and existing wells. Proposed Assessment Locations A total of eight monitoring well clusters are proposed for installation to further characterize coal pile area groundwater conditions at the proposed locations shown in Figure 2. One monitoring well cluster could include one, two, or three individual monitoring wells depending on Site conditions. If saturated conditions are present, a well will be installed in the surficial, transition zone, upper bedrock flow zones. Based on previous drilling operations at Mayo, it is anticipated that surficial groundwater is not typically encountered. Well locations may be modified slightly based on field constraints (e.g. underground utility locations, rig stability). CPA-1, CPA-7 Area Two monitoring well clusters are proposed for the area along the northwest side of the coal pile area (locations CPA-8 and CPA-9; Figure 2). The purpose of these proposed locations is to determine the extent of impact to the northeast (CPA-8) and southwest (CPA-9) of the low pH/high metals concentration area. In addition, additional groundwater quality data will inform the need and manner of any potential corrective action that is deemed necessary or useful in this specific area. The installation of additional monitoring wells immediately downgradient of the coal pile - on the northern side - is not possible due to Site infrastructure (haul road, railroad, leachate lines, steep slope, etc.). The two proposed additional well clusters will be installed within the current ash basin compliance boundary (CPA-8 and CPA-9). Page 2-2 Work Plan for Additional Assessment — Coal Pile Area September 2019 Mayo Steam Electric Plant Proposed Well Cluster CPA-10 One monitoring well cluster (CPA-10) is proposed to provide water level data in the suspected upgradient direction and to provide a viable background location for the coal pile area. As indicated in the following subsections, groundwater samples associated with the areas around CPA-4 and CPA-5 indicated impact in these areas. Therefore, a new background location for the coal pile area is proposed. CPA-4 Area Three well clusters (CPA-11, CPA-12, and CPA-13) are proposed to determine the extent of impact in this area on the south side of the coal pile area around well CPA-41) (Figure 2) and to verify groundwater flow direction. This area was initially assumed to be upgradient of the coal pile area. Detections of metals/inorganics in transition zone well CPA-41) indicate the need for additional assessment in this area. In addition, a concrete foundation pad from a previously existing structure is present in this area. The nature and use of the former structure will be investigated with Duke Energy personnel. In addition to proposed well CPA-13 located near the structure, three additional soil borings will be completed around the concrete pad, and unsaturated soil samples will be collected and analyzed from the borings (Table 1). During the initial assessment effort, a viable bedrock well could not be installed due to the lack of encountered water -bearing fractures. Existing location CPA-4BR is an open borehole; however, the water level in CPA-4BR has still not fully equilibrated after about five months. This installation will be properly abandoned. CPA-5 Area Two well clusters (CPA-14 and CPA-15) are proposed to determine the extent of impact in this area on the east side of the coal pile area around well cluster CPA-5 (Figure 2) and to verify groundwater flow direction. This area was initially assumed to be upgradient of the coal pile area. Detections of boron in shallow well CPA-5S and transition zone well CPA-51) indicate the presence of low concentrations of boron in this area. 2.3 Monitoring Well Assessment Procedures 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). During borehole installations, SynTerra will describe soil and rock cuttings. Those descriptions will include lithology, color, and the type of soil or rock. The proposed monitoring wells would be constructed in accordance with NCAC Title 15A, Subchapter 2C, Section .0100 Well Construction Standards. The proposed wells would consist of 2-inch diameter Page 2-3 Work Plan for Additional Assessment — Coal Pile Area September 2019 Mayo Steam Electric Plant schedule 40 polyvinyl chloride flush -joint threaded casings and prepacked well screens. 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 will either be rotary sonic drilling or a combination of air rotary and hollow stem auger drilling. Anticipated well depths are provided in Table 2. After well installation is complete, monitoring wells will be developed to remove drilling fluids and solids that might have been introduced into the surrounding formation and sand pack during well installation. Well development helps establish interaction of the well with surrounding groundwater. The location and elevation of each newly installed well will be determined by survey. The newly installed wells will also be slug tested to evaluate hydraulic properties of the groundwater flow system at each location. 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). Groundwater samples will be collected using low -flow sampling techniques and following procedures outlined in the Low Flow Sampling Plan, Duke Energy Facilities, Ash Basin Groundwater Assessment Program, North Carolina, June 10, 2015. To have at least two sampling events and analytical data sets available for evaluation in the coal pile site assessment report, samples would be collected at a frequency no less than 60 days between sampling events. Page 2-4 Work Plan for Additional Assessment — Coal Pile Area September 2019 Mayo Steam Electric Plant FIGURES �� r U •�� -r �� ��� ���V� m Ell ' Jul 1 w plow - oil�J ��!. •. SETTLING BASIN �►� lr� 1,�-,FGD r. : .AREA REA BASIN IIII�/ PONDS MA YO RESERVOIR :. . • �f ii �,��/��� ►i j• ��� _ F t �1I1i�/ � 1% �i kul jam`= {(i� t) • �- - �JJ ^ ' � � ��� A 7 J•, IN ����,,,,��''�� � � ���� �'��� •�� 1►_ t-fie �w1� �► SOURCE: ► '� . TOPOGRAPHIC QUADRANGLE, OBTAINED FROM THE USGS STORE AT -..FIGURE 1 COAL PILE AREA ADDITIONAL ASSESSMENT MAYO STEAM ELECTRIC PLANT DUKE ENERGY PROGRESS, LLC synTerra PERSON COUNTY . :.-. .- -. 148 RIVER • .. ROBINSON•.• , . • ` G APPROXIMATE FUTURE ASH BASIN WASTE BOUNDARY .!� (SEE NOTE 2) 1' ti +■ • r • fie. •i 1 j� GYPSUM PADAREA 1' synTerra (' DUKE ENERGY PROGRESS - .rt v LEGEND ASH BASIN WASTE BOUNDARY — - — - — ASH BASIN COMPLIANCE BOUNDARY k PROPOSED SOIL BORING LOCATION (APPROXIMATE) PROPOSED MONITORING WELL LOCATION (APPROXIMATE) EXISTING MONITORING WELL AND SOIL BORING LOCATION COAL PILE AREA • NOTES: 1. COAL PILE DRAINAGE SYSTEM CONSTRUCTION FEATURES PROVIDED BY DUKE ENERGY PROGRESS. 2. AREA OF INVESTIGATION THAT DETERMINED SETTLED CCR MATERIAL IS NOT PRESENT IN THIS AREA OF THE ASH BASIN. A FUTURE REPRESENTATIVE ASH BASIN - WASTE AND COMPLIANCE BOUNDARY IS INCLUDED IN THE MAYO NPDES PERMIT NCO038377 PART I, 5.A.(18.) ATTACHMENT FIGURE 1 AND ATTACHMENT B FIGURE 1.1 • DATED JULY 13, 2018. ■ - • 3. NATURAL RESOURCES TECHNICAL REPORT (NRTR) PREPARED BYAMEC FOSTER • 1 • —• •• WHEELER INC., JUNE 17, 2015. • r =v • '-r - - 4. WSP SURVEY CONDUCTED APRIL 17, 2014. • _+ 5. FLOOD INSURANCE BOUNDARIES PROVIDED BY FEMA, PERSON COUNTY FLOOD • e e INSURANCE STUDY, EFFECTIVE NOVEMBER 17, 2017 ( https://msc.fema.gov/portal). f � •ii—. _ ' r ' 6. AERIAL PHOTOGRAPHY OBTAINED FROM PERSON COUNTY GIS ON SEPTEMBER 13, 2019. IMAGE COLLECTED IN 2019. . r —d 1- 7. DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE PLANE 100 50 0 100 zoo FIGURE 2 GRAPHIC SCALE IN FEET COAL PILE AREA ADDITIONAL ASSESSMENT MAYO STEAM ELECTRIC PLANT 148 RIVER STREET, SUITE 220 CAROLINA 29601 PHONE DUKE ENERGY PROGRESS LLC PHONE 864-421-9999 864-421- 9 � www.suterracoro.com PERSON COUNTY ROXBORO NORTH CAROLINA DRAWNBr.A. ROBINSON DATE09/23/2019 REVISED BY: C. DAVIS DATE: 09/23/2019 CHECKED BY: P. ALTMAN DATE: 09/23/2019 ' Work Plan for Additional Assessment — Coal Pile Area September 2019 Mayo Steam Electric Plant TABLES TABLE 1 SOIL SAMPLE ANALYTICAL METHODS WORK PLAN FOR ADDITIONAL ASSESSMENT COAL PILE AREA MAYO STEAM ELECTRIC 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 S.U. 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/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. mg/kg - Milligrams per kilogram mV - Millivolts S.U. - Standard Unit Page 1 of 1 TABLE 2 PROPOSED COAL PILE ASSESSMENT SOIL SAMPLES AND MONITORING WELLS WORK PLAN FOR ADDITIONAL ASSESSMENT COAL PILE AREA MAYO STEAM ELECTRIC PLANT DUKE ENERGY PROGRESSS, LLC, ROXBORO, NC Monitoring Well ID Estimated Well Depth (feet bgs) Soil Sample ID (Estimated Depth Interval in feet bgs) Comments CPA-S68 2-3 Near -surface unsaturated soil sample (water table —20 feet bgs) CPA-SBS Various Continue soil at 5' intervals until the bottom of unconsolidated material is reached (i.e. 7-8', 12-13', 17-18' etc) CPA-SBS 19-20 Saturated soil sample (may not apply) CPA-8S 30 CPA-SBS 25-26 Soil sample from shallow well screened interval CPA-813 50 CPA-SBS 45-46 Soil sample from deep well screened interval CPA-81311 80 CPA-SB8 75-76 Soil sample from bedrock screened interval CPA-SB9 2-3 Near -surface unsaturated soil sample (water table —20 feet bgs) CPA-SB9 Various Continue soil at 5' intervals until the bottom of unconsolidated material is reached (i.e. 7-8', 12-13', 17-18' etc) CPA-SB9 19-20 Saturated soil sample (may not apply) CPA-9S 30 CPA-SB9 25-26 Soil sample from shallow well screened interval CPA-913 50 CPA-SB9 45-46 Soil sample from deep well screened interval CPA-91311 80 CPA-SB9 75-76 Soil sample from bedrock screened interval CPA-S10 2-3 Near -surface unsaturated soil sample (water table —20 feet bgs) CPA-SB10 Various Continue soil at 5' intervals until the bottom of unconsolidated material is reached (i.e. 7-8', 12-13', 17-18' etc) CPA-SB10 19-20 Saturated soil sample (may not apply) CPA-10S 30 CPA-SB10 25-26 Soil sample from shallow well screened interval CPA-lOD 50 CPA-SB10 45-46 Soil sample from deep well screened interval CPA-lOBR 80 CPA-SB10 75-76 Soil sample from bedrock screened interval CPA-SB11 2-3 Near -surface unsaturated soil sample (water table —20 feet bgs) CPA-SB11 Various Continue soil at 5' intervals until the bottom of unconsolidated material is reached (i.e. 7-8', 12-13', 17-18' etc) CPA-SB11 19-20 Saturated soil sample (may not apply) CPA-11S 30 CPA-SB11 25-26 Soil sample from shallow well screened interval CPA-11D 50 CPA-SB11 45-46 Soil sample from deep well screened interval CPA-11BR 80 CPA-SB11 75-76 Soil sample from bedrock screened interval CPA-SB12 2-3 Near -surface unsaturated soil sample (water table —20 feet bgs) CPA-SB12 Various Continue soil at 5' intervals until the bottom of unconsolidated material is reached (i.e. 7-8', 12-13', 17-18' etc) CPA-SB12 19-20 Saturated soil sample (may not apply) CPA-12S 30 CPA-SB12 25-26 Soil sample from shallow well screened interval CPA-12D 50 CPA-SB12 45-46 Soil sample from deep well screened interval CPA-12BR 80 CPA-SB12 75-76 Soil sample from bedrock screened interval CPA-SB13 2-3 Near -surface unsaturated soil sample (water table —20 feet bgs) CPA-SB13 Various Continue soil at 5' intervals until the bottom of unconsolidated material is reached (i.e. 7-8', 12-13', 17-18' etc) CPA-SB13 19-20 Saturated soil sample (may not apply) CPA-13S 30 CPA-SB13 25-26 Soil sample from shallow well screened interval CPA-13D 50 CPA-SB13 45-46 Soil sample from deep well screened interval CPA-13BR 80 CPA-SB13 75-76 Soil sample from bedrock screened interval CPA-SB14 2-3 Near -surface unsaturated soil sample (water table —20 feet bgs) CPA-SB14 Various Continue soil at 5' intervals until the bottom of unconsolidated material is reached (i.e. 7-8', 12-13', 17-18' etc) CPA-SB14 19-20 Saturated soil sample (may not apply) CPA-14S 30 CPA-SB14 25-26 Soil sample from shallow well screened interval CPA-14D 50 CPA-SB14 45-46 Soil sample from deep well screened interval CPA-14BR 80 CPA-SB14 75-76 Soil sample from bedrock screened interval CPA-SB15 2-3 Near -surface unsaturated soil sample (water table —20 feet bgs) CPA-SB15 Various Continue soil at 5' intervals until the bottom of unconsolidated material is reached (i.e. 7-8', 12-13', 17-18' etc) CPA-SB15 19-20 Saturated soil sample (may not apply) CPA-15S 30 CPA-SB15 25-26 Soil sample from shallow well screened interval CPA-151) 50 CPA-SB15 45-46 Soil sample from deep well screened interval CPA-15BR 80 CPA-SB15 75-76 Soil sample from bedrock screened interval CPA-SB100 2-3 Near -surface unsaturated soil sample (water table —20 feet bgs) CPA-SB100 Various Continue soil at 5' intervals until the bottom of unconsolidated material is reached (i.e. 7-8', 12-13', 17-18' etc) CPA-SB100 19-20 Saturated soil sample (may not apply) CPA-SB100 25-26 Soil sample at top of transition zone CPA-SB101 2-3 Near -surface unsaturated soil sample (water table —20 feet bgs) CPA-SB101 Various Continue soil at 5' intervals until the bottom of unconsolidated material is reached (i.e. 7-8', 12-13', 17-18' etc) CPA-SB101 19-20 Saturated soil sample (may not apply) CPA-SB101 25-26 Soil sample at top of transition zone CPA-SB102 2-3 Near -surface unsaturated soil sample (water table —20 feet bgs) CPA-SB102 Various Continue soil at 5' intervals until the bottom of unconsolidated material is reached (i.e. 7-8', 12-13', 17-18' etc) CPA-56102 19-20 Saturated soil sample (may not apply) CPA-SB102 25-26 Soil sample at top of transition zone Prepared by: PWA Checked by: JAW Notes: -- : Not applicable bgs - below ground surface - Approximately Estimated well and soil sample depths based on data from the previously installed coal pile assessment 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. Saturated soil samples may be conincident with the screened interval of shallow wells. Collect an SPLP sample at the shallow screened interval if this is the case Page 1 of 1 TABLE 3 GROUNDWATER ANALYTICAL METHODS WORK PLAN FOR ADDITIONAL ASSESSMENT COAL PILE AREA MAYO STEAM ELECTRIC PLANT DUKE ENERGY PROGRESS LLC, ROXBORO, NC Parameter RL Units Method Field Parameters pH NA SU Field Water Quality Meter Specific Conductance NA PS/CM Field Water Quality Meter Temperature NA oC Field Water Quality Meter Dissolved Oxyqen NA mq/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 mq/L EPA 200.7 or 6010D Antimony 0.001 mq/L EPA 200.8 or 602OB Arsenic 0.001 mq/L EPA 200.8 or 602OA Barium 0.005 mq/L EPA 200.7 or 6010C Beryllium 0.001 mq/L EPA 200.8 or 6020A Boron 0.05 mq/L EPA 200.7 or 6010C Cadmium 0.001 mq/L EPA 200.8 or 602OA Chromium 0.001 mq/L EPA 200.8 or 6010C Cobalt 0.001 mq/L EPA 200.8 or 6020A Copper 0.001 mq/L EPA 200.8 or 6020E Hexavalent Chromium 0.000025 mq/L EPA 218.7 Iron 0.01 mq/L EPA 200.7 or 6010C Lead 0.001 mq/L EPA 200.8 or 602OA Manqanese 0.005 mq/L EPA 200.7 or 6010C Mercury 0.000 mq/L EPA 245.1 or 7470A Molybdenum 0.001 mq/L EPA 200.8 or 6020E Nickel 0.001 mq/L EPA 200.8 or 6020E Selenium 0.001 mq/L EPA 200.8 or 6020A Strontium 0.005 1 mq/L I EPA 200.7 or 6010C Thallium (low level) 0.0002 mq/L EPA 200.8 or 602OA Vanadium (low level) 0.0003 mq/L EPA 200.8 or 602OA Zinc 0.005 mq/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_ µ /mL SW846 3010A/6020B Total Uranium NA µg/mL Calculated Anions/Cations Alkalinity (as CaCO3) 5 mq/L SM 2320B Bicarbonate 5 mq/L SM 2320 Calcium 0.01 mq/L EPA 200.7 Carbonate 5 mq/L SM 2320 Chloride 0.1 mq/L EPA 300.0 or 9056A Maqnesium 0.005 mq/L EPA 200.7 Potassium 0.1 mq/L EPA 200.7 Sodium 0.05 mq/L EPA 200.7 Sulfate 0.1 mq/L EPA 300.0 or 9056A Sulfide 0.1 mg/L SM4500S2D Total Dissolved Solids 25 mq/L SM 2540C Total Orqanic Carbon 0.1 mq/L SM 5310C/EPA9060A Total Suspended Solids 2.5 m L I 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 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 Page 1 of 1