1809-20140220INSP

A
ia
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: CATAWBA
MSWLF
PERMIT NO.: 18-09
Closed
HHW
white
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P
Tire
Industrial
X
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: 2/20/2014 and 3/7/2014 Date of Last Inspection: 6/19/2012
FACILITY NAME AND ADDRESS:
Duke Energy Carolinas, LLC - Marshall Steam Station
Flue Gas Desulfurization (FGD) Residue Landfill
8320 East NC Highway 150
Terrell, North Carolina 28682
GPS COORDINATES: N: 35.60463 W:-80.9774
IV.Ty101&VO 1 el KTIJ ser.307IW.10790[00 DoeU1u1301
George Tolbert, EHS
Duke Energy Carolinas, LLC
[phone]
George.Tolbertgduke-energy.com
FACILITY CONTACT ADDRESS:
Registered Agent: CT Corporation System
150 Fayetteville Street, Box 1011
Raleigh, NC 27601
Principal Office: Duke Energy Carolinas, LLC
526 South Church Street
Charlotte, NC 28202-1904
PARTICIPANTS:
George Tolbert, EHS - Duke Energy Carolinas, LLC
Kimberlee Hutchinson, PE — Duke Energy Environmental Services
Sherrie Christopher, Contract Resource Coordinator - Duke Energy Carolinas, LLC
Scott Parks, System Manager - Duke Energy Carolinas, LLC
Deb Aja, NCDENR Solid Waste Section
STATUS OF PERMIT:
Active.
INDUSTRIAL WASTE LANDFILL FACILITY:
PERMIT NO. 18-09
ISSUANCE DATE
Original Permit to Construct
April 12, 2006
Modification PTC: HDPE Liner and Cap System
May 22, 2006
Permit to Operate: Phase 1, Cell 1
November 21, 2006
Permit to Operate: Amendment — Five (5) Year Renewal
May 18, 2012
Permit to Operate: Modification, Chimney Drains
December 6, 2013

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 5
PURPOSE OF SITE VISIT:
Comprehensive Inspection - Inspection of operations conducted on 2/20/2014 and inspection of records conducted on
3/7/2014.
STATUS OF PAST NOTED VIOLATIONS:
None.
OBSERVED VIOLATIONS:
1. 15A NCAC 13B .0203(d) states: `By receiving solid waste at a permitted facility, the permittee(s) shall be
considered to have accepted the conditions of the permit and shall comply with the conditions of the permit."
General Permit Condition Number 6 states:
"Operation of this solid waste management facility must be in accordance with the Solid Waste Management
Rules, 15A NCAC 13B, Article 9 of the Chapter 130A of the North Carolina General Statutes (NCGS 130A-
290, et seq.), the conditions contained in this permit; and the approved plan. Should the approved plan and the
rules conflict, the Solid Waste Management Rules shall take precedence unless specifically addressed by
permit condition."
The approved Operations Plan dated November 13, 2013, Section 2.3.1 LCS Maintenance, states in part:
"LCS pipes will be cleaned out by the use of a clean -out snake or high-pressure water flushing at least once a
year, and the LCS piping will remote -camera monitored if cleaning indicates a blockage in the leachate
collection system pipes."
On March 7, 2014, leachate collection system pipes were in the process of being cleaned and remote -camera
monitored. The previous high-pressure water flushing was performed on 10/18/2012 and 10/19 2012 (no defects
were noted). The leachate collection system pipes had not been cleaned out in 2013 and thus had not been
cleaned out at least once a year. This constitutes a violation of 15A NCAC 13B .0203(d).
To correct this violation and be in compliance with 15A NCAC 13B .0203(d), ensure that leachate collection
system pipes are cleaned out in accordance with the approved Operations Plan. Please submit an
electronic version of the report for the March 7, 2014 clean -out to Deborah Aja at
deborah.aia(a,ncdenr.gov within seven (7) days of receipt of the report.
The Operations Plan also states the frequency of clean -out and camera inspections may be modified based on
consecutive inspection results and observed operating conditions. Please contact Larry Frost, Regional Permitting
Engineer, to make any modifications.
The item(s) listed above were observed by Section staff and require action on behalf of the facility in order to come into or maintain compliance
with the Statutes, Rules, and/or other regulatory requirements applicable to this facility. Be advised that pursuant to N.C. G.S. 130A-22, an
administrative penalty of up to $15,000 per day may be assessed for each violation of the Solid Waste Laws, Regulations, Conditions of a Permit,
or Order under Article 9 of Chapter 130A of the N.C. General Statutes. Further, the facility and/or all responsible parties may be subject to
enforcement actions including penalties, injunction from operation of a solid waste management facility or a solid waste collection service and
any such further relief as may be necessary to achieve compliance with the North Carolina Solid Waste Management Act and Rules.
ADDITIONAL COMMENTS
1. The facility is permitted to receive the following waste generated at the facility: gypsum, clarifier sludge, fly
ash, bottom ash, construction and demolition debris, mill rejects (pyrites), limestone material, land clearing
and inert debris, boiler slag, ball mill rejects, sand blast material, and coal waste. The facility is also
permitted to receive Duke Energy Carolinas -generated asbestos, Allen Steam Station (Allen) -generated
gypsum and clarifier sludge, and, Cliffside Steam Station -generated gypsum and clarifier sludge.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 5
2. The facility has contracted with Charah, Inc. to conduct landfilling operations.
3. Signage was posted at the entrance to the facility in accordance with the approved operations plan.
4. The access road to the site was of all-weather construction and maintained in good condition. Since the
previous inspection a truck wash station had been installed to clean trucks exiting the site.
5. Edge -of -waste markers delineating the permitted disposal area were visible and maintained in good condition.
The markers are offset from the edge of the landfill liner. It was stated that the markers will be re -labeled to
indicate the distance from the liner.
6. Landfill operations are currently ongoing in Phase I, Cell 1.
7. While landfilling operations at the Industrial Landfill No. 1, Permit 18-12 are temporarily ceased, those
wastes are being placed in the FGD landfill. The landfills are permitted to receive the same waste types.
8. Asbestos waste was placed in a designated area away from the working face with signage clearly marking the
disposal area with a statement "Asbestos Waste Only". The disposal area was covered by earthen material
(soil) and compacted as required; no asbestos waste was visible. The asbestos area was maintained at a
distance greater than 25 feet from exterior slopes.
9. Gypsum, ash, and mill rejects are placed at the active working face. Wastes at the working face appeared to
be landfilled as required: in ten foot layers, spread in lifts no greater than 12 inches, working from upgradient
to downgradient areas or as otherwise specified in the Operations Plan.
10. Clarifier sludge may also be placed at the active face and allowed to dry, mixed with ash or gypsum, and
spread in thin lifts. High moisture content clarifier sludge is required to be placed no closer than 50 from the
active face and spread in -place. At the time of the inspection all landfilled wastes appeared to be spread and
compacted as required.
11. All wastes were placed in the smallest working face practicable in the center of the operational area in
accordance with the approved Operations Plan. No wastes were placed within 25 feet of the exterior slopes.
12. Field and laboratory testing data of in -place density and moisture content was requested and provided post
inspection [March 18, 2014 and March 20, 2014]. Monthly field tests and laboratory tests were performed by
ESP Associates, P.A. to monitor the compaction and moisture conditioning during waste placement of
gypsum and fly ash. Test reports reviewed for the period of September, 2013, October, 2013 and December,
2013 through February, 2014. Four to eight field tests were performed during each monthly testing event at
existing elevations at varied locations throughout the landfill. The gypsum and fly ash was reported to be
compacted at the test locations equaling or exceeding a minimum 95 percent of its maximum dry density.
Monthly reports summarizing testing and waste placement activities were provided to the facility by Charah,
Inc. and reviewed for the period of September, 2013 through February, 2014. Those reports each month and
stated that waste placement was in compliance with moisture and compaction requirements. Currently
tonnages are provided in monthly activity reporting which must then be converted to cubic yards. The
conversion of tonnages to cubic yards confirmed that the frequency of testing was conducted as required.
13. There was a small pile of construction waste present within the landfill. This waste was recently generated
from the construction of new chimney drains within the landfill footprint during the week of the inspection.
There were no other C&D wastes observed.
14. No wastes were placed in areas of accumulated water and no water was observed ponded over waste.
15. Leachate Management: Leachate is transmitted via the collection system to the lined stormwater storage basin
located within the permitted landfill footprint. Leachate and stormwater are routed to the Marshall Ash Basin
(wet). Three new chimney drains had been recently installed in the center of the landfill to convey leachate to
the sump in the stormwater storage basin. At the time of the inspection the drains were connected to the sump
and the capping of the connection at the riser at the sump was not yet completed. The silt fence installed
around the sump. The need to continue maintenance of the silt fence during construction was discussed with
facility staff.
16. The lined stormwater storage basin within the footprint of the landfill appeared to be maintained below the
level limit of the basin. There were some rills on operational lifts slopes located at the interior side of the
basin. Please ensure that waste cleaned out of the basin during maintenance and construction is allowed to
dry to meet compaction and moisture content requirements prior to placement at the active working face and
continue to work to divert surface water from the working face by means of berms or other measures.
17. Leachate collection system pipes were in the process of being cleaned out with camera monitoring on
3/7/2014. The previous clean -out and camera work was performed on 10/18/2012 and 10/19 2012 (no defects

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 5
were noted). Cleaning and camera work was not performed in 2013. The Operations Plan states that' LCS
pipes will be cleaned out by the use of a clean -out snake or high-pressure water flushing at least once a year,
and the LCS piping will remote -camera monitored if cleaning indicates a blockage in the leachate collection
system pipes." Please forward copy of report of clean -out and camera work. See Observed Violations section
of this report.
18. Dust was well controlled at the time of the inspection. Dust control monitoring logs were reviewed on
3/7/2014 for compliance with the approved Dust Control Plan. Daily dust control logs were maintained and
documented measures taken to control dust as required. Dust control log forms were recently updated to
provide additional detailed reporting.
19. Exterior landfill slopes were vegetated except that the northern slopes on the northwestern were recently
graded in preparation for scheduled re -seeding. There was no erosion observed on exterior landfill slopes.
20. Weekly logs (reviewed 3/7/2014) were maintained documenting monitoring and maintenance of stormwater
conveyance systems and erosion and sedimentation controls.
21. Environmental monitoring records were reviewed on 3/7/2014. Semi-annual sampling of groundwater,
surface water, and leachate was conducted in March, 2013 and September [Monitoring wells MS-8, MS-9,
MS-10, MS-11, MS-12, MS-13, MS-14, MS-15, MS-16, Surface Water sampling point SW-1, and Leachate
sampling point Cl]. An inspection of all monitoring points was conducted on June 19, 2014 and summarized
is summarized in a report of the inspection.
22. The Permit and Operations Plan were maintained on -site as required.
23. Training records were documented and maintained on -site. The following facility staff completed operator
and/or manager training as required by Permit Condition Number 13:
Buddy Mayberry, expires 4/26/2015
George Tolbert, expires 5/19/2016
Scott Parks, expires 5/19/2016
Sherrie Christopher, expires 5/19/2016
Chris Lewis — Charah, Inc., expires 7/23/2016
Jenson Shults — Charah, Inc., expires 7/23/2016
Chris Emory— Charah, Inc., expires 7/23/2016
Steven Faussete— Charah, Inc., 10/24/2014.
24. The facility annual report was received on July 26, 2013. A total of 39,329.82 tons of waste were placed in
the landfill during FY 2012-2013.
25. An annual volume survey was conducted on 5/7/2013. A total of 336,001.56 tons of capacity was reported
used as of the survey date.
Please contact me if you have any questions or concerns regarding this inspection report.
Deborah
Environmental Senior Specialist
Regional Representative
deborah. aj akncdenr. gov
Phone: [phone]
Asheville Regional Office
2090 US Hwy 70
Swannanoa, NC 28778
Sent on March 24, 2014, to:
X
Email
Hand delivery
US Mail
Certified No.
George Tolbert, Duke Energy
Carolinas, LLC
by;
EC: Jason Watkins, Western District Supervisor
Sarah Rice, Compliance Officer
Larry Frost, Regional Permitting Engineer
Kimberlee Hutchinson, PE — Duke Energy Environmental Services