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HomeMy WebLinkAbout2019-03-26 Duke NC Waste Management Plan 2019 Update2500 Fairfax Road Greensboro, NC 27404 336-215-4576 Page 1 of 2 March 26, 2019 North Carolina Department of Environmental Quality Division of Waste Management Solid Waste Section 1646 Mail Service Center Raleigh, North Carolina 27699 Attn: Ms. Shawn McKee (submitted electronically) Re: Duke Energy Management Plan 2019 Update Permit No. Various 526 South Church Street Charlotte, North Carolina 28202 Dear Ms. McKee, Attached you will find the Waste Management Plan for Duke Energy Coal Combustion Residual (CCR) Industrial Landfill Facilities and the McGuire Nuclear Landfill No. 2. As previously discussed with the Section, waste management at Duke Energy facilities operates as a system thereby resulting in a better representation as a combined Waste Management Plan. This Solid Waste Management Plan pertains to: •landfills at operational coal combustion facilities: o Allen Steam Station Retired Ash Basin Landfill Permit No. 3612-INDUSoBelews Creek Steam Station Craig Road Ash Landfill Permit No. 8504-INDUSoBelews Flue Gas Desulfurization Residue Landfill Permit No. 8505-INDUS o Cliffside Steam Station Coal Combustion Products Landfill Permit No. 8106-INDUSoMarshall Steam Station Industrial Landfill #1 Permit No. 1812-INDUSoMayo Steam Electric Plant Coal Combustion Product Landfill Permit No. 7305-INDUS o Roxboro Steam Electric Plant Landfill Permit No. 7302-INDUS •landfills to support closure of ash basins at retired coal combustion facilities, and;o Dan River Steam Station Landfill Permit No. 7906-INDUS o Sutton Steam Electric Plant Landfill Permit No. 6512-INDUS •the landfill at McGuire Nuclear Station.o McGuire Nuclear Station Landfill No. 2 Permit No. 6004-INDUS Page 2 of 2 This plan is being submitted as courtesy in accordance with GS 130A-309.09D. If you need additional information in regard to this submittal please do not hesitate to call or email, 336-215-4576 or kimberlee.witt@duke-energy.com. Regards, Kimberlee Witt, PE, ME Environmental Services Attachments: North Carolina CCR Landfill Waste Management Plan 2019 Update McGuire Nuclear Station Landfill No. 2 Waste Management Plan 2019 Update cc: Ed Mussler - NCDEQ Ben Jackson - NCDEQ David Giachini - NCDEQ Larry Frost - NCDEQ Evan Andrews - Duke Energy Scott Nordgren - Duke Energy Ed Sullivan – Duke Energy Courtney Murphy - Duke Energy Tyler Hardin - Duke Energy Ryan Czop - Duke Energy Melonie Martin - Duke Energy North Carolina CCR Industrial Landfills Waste Management Plan 2019 Update 526 South Church Street Charlotte, North Carolina 28202 March 26, 2019 Duke Energy NC Ten-Year Waste Management Plan 2019 Update Table of Contents 1.0 Overview ........................................................................................................................ 1 2.0 Waste Management Strategy – Plans for Waste Reduction and Disposal ...................... 1 2.1 Fly Ash and Bottom Ash ...................................................................................... 3 2.2 Flue Gas Desulphurization (FGD) Residue .......................................................... 3 3.0 Future Ash Beneficiation Projects ................................................................................... 3 List of Abbreviations & Acronyms BTU British Thermal Unit CCP Coal Combustion Products CCP TS Duke Energy Coal Combustion Products & Technical Support CCR Coal Combustion Residuals NCDEQ North Carolina Department of Environmental Quality DWM Division of Waste Management FGD Flue Gas Desulfurization PTO Permit to Operate Duke Energy NC Waste Management Plan 2019 Update Page 1 of 3 1.0 Overview In accordance with North Carolina Administrative Code Section 130A-309.09D(c); A generator of industrial solid waste that owns and operates an industrial solid waste facility for the management of industrial solid waste generated by that generator shall develop a Waste Management Plan. This plan shall be updated at least every three years and be provided to the North Carolina Department of Environmental Quality (DEQ) upon request. This Duke Energy (Duke) Solid Waste Management Plan pertains to landfills at operational coal combustion facilities: • Allen Steam Station Retired Ash Basin Landfill (RAB Landfill) Permit No. 3612 • Belews Creek Steam Station Craig Road Ash Landfill (Craig Road Landfill) Permit No. 8504 • Belews Flue Gas Desulfurization (FGD) Residue Landfill, Phase I (FGD Landfill) Permit No. 8505 • Cliffside Steam Station Coal Combustion Products (CCP) Landfill (CCP Landfill) Permit No. 8106 • Marshall Steam Station Industrial Landfill #1 (ILF 1) Permit No. 1812 • Mayo Steam Electric Plant Coal Combustion Product Landfill (Landfill) Permit No. 7305 • Roxboro Steam Electric Plant Landfill (Landfill) Permit No. 7302 And facilities that have landfills to support closure of ash basins at retired coal combustion facilities: • Dan River Steam Station Landfill (Landfill) Permit No. 7906 • Sutton Electric Steam Plant Landfill (Landfill) Permit No. 6512 The initial permits to operate (PTO) for the above-listed landfills were issued by the NCDEQ, Division of Waste Management (DWM), and are subject to review every five years. This Waste Management Plan presented is developed in accordance with GS 130A-309.09D. 2.0 Waste Management Strategy – Plans for Waste Reduction and Disposal The Duke Energy operational coal combustion facilities generate electric power by combustion of coal which produces fly ash, bottom ash, FGD residue (gypsum), and other coal combustion residuals (CCR) on an operational basis. The operation of a station and the quantity of CCR produced depends on interconnected power demands of the Duke system as a whole (including renewable power sources and facilities that produce energy through nuclear, hydroelectric, and natural gas sources). The quantity of ash generated at the coal combustion facilities depends on factors such as the operation of the plant, the reuse of ash in by-products, the heat of combustion of the coal itself (measured in British Thermal Units (BTUs)), ash content of the coal, the quantity of coal burned, and closure of coal ash basins. The quantity of FGD residue (synthetic gypsum) produced depends on the sulfur content and volume of coal combusted. These factors typically vary over the course of a single year, causing fluctuations in the Duke Energy NC Waste Management Plan 2019 Update Page 2 of 3 quantity and quality of ash and gypsum. The fuel chemistry also impacts the amount of CCR produced at each station. Additionally, the rise in natural gas powered electricity generation has led to speculation that coal generation facilities may see a more limited role in fulfilling the region’s electricity demand during this planning period. This prediction, coupled with increasing strength in the ash reuse markets is expected to increase the demand for ash used in byproducts, resulting in a decrease in the quantity of material disposed in the landfills. The aforementioned factors result in difficulty estimating future disposal and reuse volumes for CCR material. This Waste Management Plan is only intended to be an estimate based on information available at the time the report was generated. Duke’s Coal Combustion Products & Technical Support (CCP TS) Group was developed to seek markets and applications for use of coal combustion byproducts. This group continuously works toward maximizing the re-use of coal combustion byproducts. Marketing of combustion byproducts is Duke's primary effort towards waste reduction. Duke reports CCR production, excavation, and reuse annually in accordance with 15A NCAC 13B .1710. Table 1, below, summarizes CCR volumes produced, disposed, used in structural fill facilities, and alternatively used as described in 15A NCAC 13B .1708 for the past 5 years. It is the goal of the CCP TS Group to increase reuse to the maximum extent possible. As shown in Table 1, recent ash basin excavation projects resulting in re-use in addition to mining synthetic gypsum from historical landfills has resulted in total annual beneficial re-use greater than 100%. Re-use volumes will vary greatly over the next few years due to regulatory requirements included in the Coal Ash Management Act of 2014. Table 1 - Historical CCR Beneficial Reuse Table 1 notes: 1. Information was obtained from Duke Energy annual reports required by 15A NCAC 13B .1710. 2. Data is provided by the NCDEQ fiscal year (July 1 - June 30) as required by 15A NCAC 13B .1710. 3. Produced ash includes estimate of CCR material sluiced to basins 4. Re-Used and disposed CCR material includes ash from basins. 5. 2013 was the first reporting period for the combined Duke Energy and Progress Energy thereby the start of this table. Total CCR Produced Re-Used Disposed Produced Re-Used Disposed % Beneficially Reused 2018 1,244,914 424,531 820,383 1,287,848 1,238,036 221,009 66% 2017 1,422,288 472,530 949,758 1,408,609 1,358,995 51,379 65% 2016 1,296,824 479,272 817,522 1,148,712 1,178,086 35,696 68% 2015 1,698,218 616,625 1,081,593 1,579,276 1,329,577 249,698 59% 2014 2,562,279 466,301 2,007,218 1,717,268 1,298,208 432,438 41% 2013 2,181,627 818,833 914,952 1,095,572 1,316,997 246,413 65% Production CCR Material Year Ash (tons)Synthetic Gypsum (tons) Duke Energy NC Waste Management Plan 2019 Update Page 3 of 3 2.1 Fly Ash and Bottom Ash Fly ash is a light airborne particulate that results from the combustion of pulverized coal. Fly ash reuse is mostly used as a replacement for other aggregates, such as Portland cement, in concrete production. Bottom ash is a heavier ash particle that falls to the bottom of the plant boilers during combustion. Bottom ash reuse mostly occurs in concrete block manufacturing. During the Duke 2018 NCDEQ fiscal year, approximately 1,244,914 tons of fly and bottom ash was produced at Duke facilities in North Carolina. Market demand was greater than Duke Energy's production of fly and bottom ash. Approximately 222% of Duke Energy fly and bottom ash, produced or excavated from basins, was beneficially used. The CCP TS Group is continuing to pursue the beneficial use of fly ash. Duke anticipates that an improving regional economy will increase the demand for beneficial use of fly ash, resulting in a decrease in the quantity of material disposed in the landfills. 2.2 Flue Gas Desulphurization (FGD) Residue The FGD systems at Duke's North Carolina coal generating facilities were designed to produce wallboard-quality synthetic gypsum enabling the material to be beneficially reused. Synthetic gypsum reuse occurs mostly in the wallboard industry but is also seen in agricultural markets as a substitute for natural gypsum. During the 2018 fiscal year, approximately 1,287,848 tons of synthetic gypsum were produced at Duke facilities in North Carolina. Market demand in 2018 was greater than Duke Energy's synthetic production. Previously landfilled gypsum was excavated resulting in a reuse rate greater than production. Approximately 105% of Duke Energy synthetic gypsum was beneficially used. The CCP TS Group is continuing to pursue the beneficial use of synthetic gypsum. Duke believes that an improving regional economy will increase the demand for wall-board, resulting in a decrease in the quantity of material disposed in the landfills. 3.0 Future Ash Beneficiation Projects North Carolina General Statute 130A-309.216 Ash beneficiation projects, was ratified as part of House Bill 630 on July 1, 2016, and signed into law on July 14, 2016. NCGS 130A-309.216 requires an impoundment owner to identify at least three sites capable of processing 300,000 tons annually of ash suitable for cement processing purposes. Cape Fear, HF Lee, and Buck facilities have been identified as the three facilities capable of implementing beneficial reuse. These facilities are anticipated to increase coal combustion material available for re-use in the concrete industry. McGuire Nuclear Station Landfill No. 2 (PN 6004-INDUS) Waste Management Plan 2019 Update 526 South Church Street Charlotte, North Carolina 28202 March 26, 2019 Duke Energy McGuire Landfill Ten-Year Waste Management Plan 2019 Update Page 2 of 6 Table of Contents 1.0 Overview ............................................................................................................................................ 3 2.0 Historical Disposal ............................................................................................................................ 3 2.1 Permitted Waste Types ............................................................................................................ 4 2.2 Asbestos ................................................................................................................................... 5 2.3 Empty Container Disposal ....................................................................................................... 5 2.4 Petroleum Product Clean-Up Residue Disposal ..................................................................... 5 2.5 Conventional Wastewater Sludge ........................................................................................... 5 2.6 Fish Waste, Insulation (Non-asbestos), and Surplus Chemical Product Disposal ............... 5 3.0 Future Landfill Airspace Projection .................................................................................................. 6 4.0 Waste Management Strategy Plans for Waste Reduction and Disposal ...................................... 6 List of Abbreviations & Acronyms BTU British Thermal Unit CCP Coal Combustion Products CCP TS Duke Energy Coal Combustion Products & Technical Support CCR Coal Combustion Residuals DWM Division of Waste Management FGD Flue Gas Desulfurization MNS McGuire Nuclear Station NCDEQ North Carolina Department of Environmental Quality PTO Permit to Operate Duke Energy McGuire Landfill Ten-Year Waste Management Plan 2019 Update Page 3 of 6 1.0 Overview In accordance with North Carolina Administrative Code Section 130A-309.09D(c); A generator of industrial solid waste that owns and operates an industrial solid waste facility for the management of industrial solid waste generated by that generator shall develop a Waste Management Plan. This plan shall be updated at least every three years and be provided to the North Carolina Department of Environmental Quality (DEQ) upon request. This Duke Energy (Duke) Solid Waste Management Plan pertains to the landfill operated at: • McGuire Nuclear Station (Landfill No. 2) Permit No. 6004-INDUS The permit to operate the MNS Landfill #2, Permit # 6004, was initially issued by the North Carolina Department of Environment and Natural Resources (DENR) Division of Waste Management (DWM) on July 30, 1992. The Permit to Operate was re-issued on September 25, 2014. This Waste Management Plan presented is developed in accordance with GS 130A-309.09D. 2.0 Historical Disposal The McGuire Nuclear Station (MNS) is a two-unit nuclear generating facility located on Lake Norman in Catawba County, North Carolina. It is among the largest of its seven nuclear facilities in the Duke Energy fleet with a generating capacity of 2,258 megawatts. Unit 1 at MNS began commercial operation in 1981 followed by Unit 2 in 1984. Two landfills are located at the McGuire Nuclear Station, Landfill #1 (Unlined) and Landfill #2 (Synthetically Lined). Both landfills are permitted under Permit No. 6004. However, the MNS Landfill #1 was closed in 1993. The MNS Landfill #2 is actively accepting waste. The MNS Landfill #2 has a waste footprint of approximately five acres and is divided into four cells, which are referred to as and permitted by DWM as Phases 1-4. The MNS Landfill #2 was designed and constructed with a synthetic geomembrane liner and with a leachate collection system. Leachate and contact stormwater are collected in the landfill footprint and then piped to an adjacent lined leachate collection pond, located to the west of the landfill. The operation of the station depends on interconnected power demands of the Duke system as a whole (including renewable power sources and facilities that produce energy through fossil, hydroelectric, and natural gas sources). Landfill No. 2 is permitted to accept waste material from Duke Energy Corporation facilities. The quantity of waste disposed at Landfill No. 2 depends on factors such as the operation of the plant, projects at McGuire and across the Duke Energy fleet. These factors typically vary over the course of a single year, causing fluctuations in the quantity and type of waste. The aforementioned factors result in difficulty estimating future disposal volumes for Landfill No. 2. This Waste Management Plan is only intended to be an estimate based on information available at the time the report was generated. Duke Energy McGuire Landfill Ten-Year Waste Management Plan 2019 Update Page 4 of 6 Table 1 - Historical Disposal Year Amount of Material Disposed (tons) Airspace Used (cubic yards)2 2018 2,377.14 68,076 2017 3,971.41 64,824 2016 2,354.59 62,323 2015 1,816.40 60,491 2014 2,298.14 54,469 2013 5,051.13 52,760 Table 1 notes: 1. Data is provided by the NCDEQ fiscal year (July 1 - June 30) 2. Airspace Used (cubic yards) covers period between the opening date and the date of the last survey and includes any weekly, intermediate, or final cover. 3. 2013 was the first reporting period for the combined Duke Energy and Progress Energy thereby the start of this table. 2.1 Permitted Waste Types The MNS Landfill #2 is currently permitted to receive the following wastes generated by Duke Energy (the most current operation plan should be referenced for official permitted waste types): • Asbestos • Insulation (non-asbestos) • Conventional wastewater sludge • Empty containers • Petroleum product spill cleanup materials • Oil contaminated materials (filters, rags, brush, shrubs, soil) • Fish waste • Non-hazardous excess, obsolete, expired chemicals • Acid/Base Spill Cleanup Material • Activated Carbon • Desiccant • Resins • Paper Filters/Waste • Sandblast Material • Diatomaceous Earth • Mud, Grease, Clam shells • Boric Acid Waste accepted into the landfill is screened to ensure that no hazardous wastes, liquid wastes, incompatible waste, etc. are accepted into the landfill. Material Safety Data Sheets, analytical results, and other appropriate methods are used to ensure compliance. Waste streams from the list of permitted waste types are called out below with a discussion about future expected disposal. Waste stream amounts vary based on operations at both MNS and other operation centers across the North Carolina and South Carolina Duke Energy Corporation fleet. Duke Energy McGuire Landfill Ten-Year Waste Management Plan 2019 Update Page 5 of 6 2.2 Asbestos Asbestos is only accepted for disposal from MNS. Landfill No. 2 receives both friable and non-friable types of asbestos which can then be categorized as Thermal System Insulation, Gasket or Packing Material, Personal Protective Equipment, Bulk Sampling Waste, Rags, Respirator Cartridges, Coatings, HEPA Vacuum Waste, etc. The total number of bags and total quantity in cubic yards placed in the landfill is calculated. The information is used to complete the North Carolina Asbestos Waste Shipment Record which is mailed to the NCDHHS- Division of Public Health annually. As more asbestos is removed and disposed during demolition or construction activities, generally, the total amount of asbestos that goes to the landfill each year decreases and is expected to continue to decrease due to limited use of asbestos in construction and auto parts. 2.3 Empty Container Disposal All containers must be emptied as much as possible prior to disposal in the landfill. 55 gallon drums that are still in good condition will be collected and shipped to a drum re-conditioner, this reduces the number of drums disposed in the landfill. Any drums that cannot be recycled or disposed as scrap metal, must be labeled "empty" before being transporting to Landfill No. 2. Once the drums are at the Landfill No. 2 waiting for final disposal, each drum is crushed prior to placing in the active cell. The crushed drum is buried as a part of normal operations. 2.4 Petroleum Product Clean-Up Residue Disposal Oil contaminated materials, such as oil contaminated soil, oil pads and booms, and oil absorbent material, materials contaminated with oil and diesel fuel (which do not contain any free liquids), are approved for disposal in Landfill No. 2. Petroleum product spill clean-up residues is placed in the working cell as loose materials which is used to fill voids between other wastes. Oil contaminated soil has been approved for use as alternate daily cover (ADC), this helps prolong the life of the MNS Landfill No. 2. 2.5 Conventional Wastewater Sludge Dewatered sludge is approved for disposed in Landfill No. 2. Annual disposal volume of conventional wastewater sludge is dependent on MNS operations. 2.6 Fish Waste, Insulation (Non-asbestos), and Surplus Chemical Product Disposal Fish waste, insulation (non-asbestos), and surplus chemical product is approved for disposal in the MNS Landfill No. 2. Fish waste disposal must be covered the same day. All non-hazardous, non-asbestos insulation, and non-hazardous, obsolete, or expired chemicals, are permitted for disposal in Landfill No. 2 with approval from the MNS Manager of Landfill Operations and/or Corporate Environmental Services. Annually, disposal amounts of these materials fluctuate slightly based on operations at MNS and the Duke Energy Corporation energy production fleet. Duke Energy McGuire Landfill Ten-Year Waste Management Plan 2019 Update Page 6 of 6 3.0 Future Landfill Airspace Projection MNS Landfill No. 2 has an average disposal rate of 2,978 tons per year (average of 2013 through 2018). This equates to 65% of the 4,600 tons per year designed annual disposal rate. Landfill No. 2 has a solid waste disposal capacity of 202,600 cubic yards (measured from the upper surface of operational protective cover above the bottom liner to the uppermost surface of waste). As of the latest survey, May 15, 2018, Landfill No. 2 has 132,709 cubic yards of solid waste disposal capacity remaining. The average 2,978 tons per year converts to an annual volumetric consumption rate of 3,722 cubic yards per year (0.80 tons/cubic yard). As of May 15, 2018, the MNS Landfill No. 2 has a remaining life of approximately 35.6 years. 106,167 Tons Remaining Waste Capacity 2,978 Tons/Year Expected Annual Quantity = 35.6 Years of Disposal Capacity Remaining Duke Energy and MNS review demand for waste placement against available airspace annually. Should Landfill No. 2 life expectancy reach 5 years or less, future corporate need for waste placement is reviewed in detail so that Duke Energy and MNS can determine if additional Industrial Landfill Phases should be constructed at MNS or an alternate Duke Energy facility. 4.0 Waste Management Strategy Plans for Waste Reduction and Disposal Options for management and reduction of wastes placed in Landfill No. 2 are limited due to the sources and quantities of waste streams associated with the energy production and operation. Duke Energy strives to reduce the volume of petroleum product spill cleanup material through corporate efforts to reduce the number of petroleum spills, thereby reducing the volume of this type of material placed in the landfill. MNS has reduced the volume of expired or obsolete chemical disposed in the landfill by participating in corporate programs designed to identify alternative uses for those chemicals. Duke Energy partners with schools, colleges, waste brokerages, and small industries to utilize no longer needed chemicals, when possible, to avoid disposal. Regardless of re-use efforts, disposal volume will continue to fluctuate in the MNS Landfill No. 2 based on general operations/maintenance and energy production across the Duke Energy Corporate fleet.. All Duke Energy Corporation facilities and business units, adhere to waste reduction initiatives including reduction at the source and maximizing recycling. The goals of the Duke Energy Recycling Programs is to promote recycling, to provide guidance, to capture programs, and to recognize recycling efforts throughout the enterprise. Waste reduction goals are established and tracked annually, separate from corporate solid waste landfills, through the Duke Energy Stakeholder Strategy and Sustainability team.