CCB0053_Insp_20010720

June 20, 2001
MEMORANDUM
Subject: Notes On 6/20/01 Visit to the Proposed Structural fill in Iredell County near
Mooresville,NC to be known as "Race Park USA".
References:
(1) January 23, 2001 Notification of a Proposed Coal Ash Structural Fill Near
Mooresville in Iredell County. This fill is to be named "Race Park USA". The
Notification was from Mr. Dean Johnston of Ash Basics Company (ABC) and
was addressed to W.R. Hocutt of NC DENR.
(2) February 13, 2001 Letter from James C. Coffey (NC DENR) to Mr. Dean
Johnston of ABC. This letter lists six (6) details and descriptions of construction
or drawings in the Reference (1) Notification that the Division of Waste
Management (DWM) desired to be changed or additional descriptions or
explanations furnished.
(3) June 1, 2001 letter from Mr. Dean Johnston of ABC to W.R. Hocutt
addressing the six (6) items covered in Reference Number (2). Except for the
ones specifically covered in the body of this site visit report, the requirements of
Reference (2) were satisfied.
To: The File
From: Bill Hocutt1/
Tim Jewitt and Bill Hocutt met Mr. Dean Johnston at the subject site at 11:00 AM on
6/20/01. Mr. Larry Harper, Director of Product Applications, Fuels, Purchasing, and Ash
Management for Duke Power (the ash generator for this project), was also present. We had not
been told that he would also be there. He had perhaps been invited by Mr. Johnston late on 6/19
or early on 6/20 after we had, on 06/19, canceled and then rescheduled the meeting all within a
period of 2-3 hours. This was done when it was learned that Jim Barber could not come to the
meeting. Johnston told us that his engineer had scheduled another appointment after we
cancelled the visit early in the day of 6/19 and could not change his schedule back and be there.
Johnston probably felt that he needed an engineer present and maybe asked Harper to come.
Another possibility is that Harper had planned to be there all along. I apologized for the
confusion caused by the cancelation, but explained that we were trying to avoid any further
delays in the project. Mr. Johnston had voiced displeasure over an additional week delay when
we had canceled.
Very early in the 06/20/01 discussions on the information concerning the location of
groundwater on the site, Mr. Johnston discovered that information which he received from
Ground Technical Services Incorporated (GTSI) right at the time that he was writing Reference
(3) was not included in his reply to Reference (2). The only groundwater information that the
DWM was aware of as of 06/20/01 was a copy of a 01/25/01 letter from GTSI to Dean Johnston
that was included in the O1/23/01 notification. That GTSI letter simply stated that six (6) hand
augered probes had been conducted in January in the low lying areas of the planned project.

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These six probes had been to an average of 2.5 feet in depth and no groundwater had been
encountered. The information that was not included in Reference (3) was a copy of a 5/29/01
letter from GTSI to ABC stating that nine (9) additional hand auger probes had been conducted
to a depth of 3.0 feet below existing grade for groundwater measurement purposes. It should be
understood at this point that these additional borings were done after significant earth moving
was indicated to be occuring when Tim Jewitt visited the site on April 27, 2001. A copy of the
05/29/01 letter from GTSI to Dean Johnson and a copy of an accompanying GTSI drawing (no
scale) were obtained from Dean Johnson on 06/20/01. The drawing showed where the borings
had been made and they were identified as B-1 through B-9. In the letter GTSI states that
groundwater was noted in borings B-4 (14" below existing grade) and in B-8 (36" below
existing grade).
Copies of the engineering drawing numbered Sheet 1 of 2 and identified as the "Ash Fill
Plan" were submitted with the initial (01/23/01) Notification. Modifications # 2 and #3 were not
shown -Those modifications (#2 and #3) are identified as having occurred on 3/9/01 and 5/23/01
respectively on the "Ash Fill Plan " drawing submitted with Mr. Johnston's Reference (3),
06/01/01 letter. The major portion of the elevation contour lines in the second drawing (that
copy which contained revisions) appear to be identical to the initial drawing. The changes in the
contour elevation contour lines appear to be concentrated in the the lower elevation part of the
site. This same general area appears to be where GTSI made the nine , 3.0 foot hand angered
borings. Mr. Johnston has agreed to identify the locations of those nine probes on the "Ash Fill
Plan " drawing and to also shoot and show the elevations of the B-4 and B-8 probes on the
drawing. It is anticipated that these points will show that a significant amount of contour change
has occurred.
Mr. Johnston admitted to having done some excavating of the site and said that it was
necessary for two reasons: 1) the site had been used for dumping and he had removed material
because it would biodegrade making the area unsuitable to support a building which was to be
placed there, and 2) the site had to be made suitable for tricks to enter and be able to dump ash.
These statements are in agreement with Tim's observations at the site in late April and late
June.I In April, Tim went by at my request to see if any activity was going on there because no
communication had occurred from Mr. Johnston since the February 13, 2001 Reference (2)
letter. Tim found that some large earth moving equipment was involved in moving soil and
screening it. In June, Tim saw that a wide and deep trench had been dug up towards Doolie
Road becoming maybe 15 feet deep near the road and then turning 90 degrees and going along
Doolie to end abruptly. On June 20, the ditch was no longer discernable as the site had been
smoothed and probably recontured.
Mr. Johnston has agreed to use measured elevations of B-4 and B-8 to help determine
the amount of soil that will be required to ensure two (2) foot separation between the seasonal
high groundwater table and the ash. He was cautioned that the groundwater elevations being
measured at this time period are not representative of the seasonal high groundwater table
elevations. It was suggested to him that perhaps the Army Corps of Engineers or the Soil
Conservation Service might have long term data on the groundwater level fluctuations typical of

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the Mooresville area. If so, this could provide him with guidance as to how much separation he
should provide where he needs to add soil. I told him that J. Barber had shown me long term
(eight years or more) data from another part of NC which showed a six (6) foot swing in
groundwater levels comparing the low measured (dry season) points vs the seasonal high (wet
seasonal) groundwater table elevations. Johnston expressed a willingness to be conservative
and place as much extra soil as was seen needed to compensate for the difference to seasonal
high elevations.
Referring again to the February 13, 2001, Reference (2) letter; item number five (5)
asked that Cross Section "A"- Profile (Dowell & Co.) drawing submitted with the January 26,
2001 Notification letter be changed to include that the coal ash exterior slopes shall have a
maximum of 1 vertical to 3 horizontal. Larry Harper argued that the rules allowed deviation
from the 3:1 under special circumstances and I told him that was not the case. He then went and
got his copy of the rules and apologized that I was right. The original Dowell & Co. Cross
Section "A' drawing made no mention of the ash slopes and only indicated that earthen cover
was to have 1.0 vertical to 2.0 horizontal slope. The modified drawing that was received with
the June 1, 2001 Reference (3) letter has two changes. First, the earthen cover slope is changed
to say it will have a 3:1 slope, but no written comment is made in reference to the ash fill
exterior slope. Instead, the second change is that the drawing now shows the ash to be enclosed
by a berm. This changes the ash slope to no longer be an exterior slope but it is now interior
which is not regulated by the rules. However, it was pointed out to Mr. Johnston that the
drawing now showed a berm enclosing an ash face w/o any slope, ie vertical. It was stated to
Mr. Johnston that we did not believe that he could construct the fill as shown. He agreed, and
said that this was an error. He said that Dowell & Co. had shown him two versions to select
from. One was similar to Jim Barber's penciled changes (that I showed to Mr. Johnston) which
showed the earthen cover and the ash both had equal (3:1) slopes. The other was the berm
version which was used on the modified drawing. He said that he had selected the other and not
the berm and Dowell & Co. had misunderstood him. Johnston is supposed to be submitting a
revised drawing. Larry Harper agreed that the vertical interface between ash and earthen cover
could not be constructed.
cc: Jim Coffey
Tim Jewitt
Jim Barber
c:wp 6docs/notes/dukepwr06-20. wpd