8801_ROSCANS_1995

' '
State of North Care ,a
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
May 18, 1995
R. J. Gussman
Director, Environmental Affairs
Ecusta
Post Office Box 200
Pisgah Forest, North Carolina 28768-0200
Re: Permit Number 88-01
Mr. Gussman:
.RA
DEHNR
The Division of Solid Waste Management, Solid Waste Section (Section) has received
your request concerning the above referenced permit. A preliminary completeness review has
been undertaken and the following comments must be addressed in order to allow the Section
to proceed with a technical review.
• Revise the drawing entitled Brown No.2 Ash Landfill Topographical Plan, Drawing
Number 735, Sheet 1 {prepared by Hampton, Hintz & Associates),. to include final
contours {top of cover) for both proposed fill areas. Also include on the drawing the
location of the proposed perforated HOPE pipe, valve, and temporary sediment trap.
Proposed design plans must be signed and sealed by a Professional Engineer licensed
to practice in North Carolina.
• Plan View Schematic Of Proposed Landfill Expansion, Brown No. 2 Ash Landfill
Expansion, Ecusta Facility -Pisgah Forest, North Carolina {prepared by Law Engineering
and Environmental Services) must be signed and sealed by a Professional Engineer
licensed to practice in North Carolina.
• Section A -A' (Typical), Brown No. 2 Ash Landfill Expansion, Ecusta Facility -Pisgah
Forest, North Carolina {prepared by Law Engineering and Environmental Services) must
be signed and sealed by a Professional Engineer licensed to practice in North Carolina.
If approved, a total of three sets of the submitted information is required for distribution
by the Section. When resubmitting the above referenced drawings, provide three copies.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
Should you have any questions or if we can provide any assistance, please contact the
Section at [phone].
Thank you,
William D. Sessoms, PE
copy: James C. Coffey -DSWM
Jim Patterson -DSWM
Central File 88-01
C: \SES SOMS\PROJECTS\ECUST A \LETTER. 1
State of North Curolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
August 4, 1995
R. J. Gussman
Director, Environmental Affairs
Ecusta
Post Office Box 200
Pisgah Forest, North Carolina 28768-0200
Re: Permit Number 88-01
Additional Fill Area Request
Mr. Gussman:
~!·;~ ~---• a a
DEHNR.
The Division of Solid Waste Management, Solid Waste Section (Section) has
completed the initial technical review of your request concerning the above referenced
permit. The following items must be provided or addressed in order to continue with the
review process.
1 . A review of the permit file indicates that several subsurface (French) drains were
installed on the site within the fill and slide area. The specific location and discharge
points of these drains, and all other surf ace and subsurface drainage structures,
should be shown on the Topographical Plan, Drawing number 734.
2. The Ecusta letter of May 11, 1995 indicates the need to stabilize the ASB dike as
the justification to allow an expanded aerial limit for coal ash disposal. No
engineering data or calculations were provided with regards to existing stability
conditions of the dike or landfill slope. Nor is any information provided with regards
to stability of the dike or landfill slopes in a post fill configuration. In addition, the
proposed fill area is along only approximately one half of the length of the dike in
the area of the existing landfill property.
3. Hydrogeological comments are contained in the attached hydrogeological review
memorandum.
The Section reserves the right to request additional information during the
continuing review. If such additional information is required, you will be notified by the
Section.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
Ecusta Landfill
File Number 88-01
Page 2
Should you have any questions or if we can provide any assistance, please contact
the Section at [phone] (email: [e-mail]}.
Thank you,
William D. Sessoms, PE
enclosure
copy: James C. Coffey -DSWM
Jim Patterson -DSWM
Central File 88-01
C:\SESSOMS\PROJECTS\ECUSTA\LEITER.2
• -~-N-~-1 N-~-A-1 N-G-A N_D_E_N_V_I R_O_N _M E_N_T_A L-S E_R_V_I C-E-S ,-1-N-C .-
August 30, 1995
Ecusta Division of P.H. Glatfelter Co.
One Ecusta Road
Post Office Box 200
Pisgah Forest, North Carolina 28768
Attention: Mr. Robert J. Gussman
Director, Environmental Affairs
APPRO V E D
DIVISI ON OF SOLID WASTE MANAGEMENT
DATL ' o I z.-.., h;., BY_u_P'::7_....., __ _
Subject: Expansion of Brown No. 2 Ash Landfill
Ecusta Facility, Pisgah Forest, North Carolina
LAW Project 30100-5-0248
Gentlemen:
Law Engineering and Environmental Services, Inc. is pleased to submit the accompanying revised
Drawing No. 734 and written summary pertaining to the stability of the ASB dike and landfill
slope. This work was performed to assist Ecusta in responding to a letter from North Carolina
Department of Environmental Health and Natural Resources (NCDEHNR) dated August 4, 1995
and was authorized by your Purchase Order No. 51-11746-1 dated August 9, 1995; the scope of
work was described in our confirmation letter dated August 8, 1995.
Law Engineering appreciates the opportunity to provide our services on this project. If you have
any questions regarding the information presented in the enclosed materials, please contact us.
Sincerely,
0
Senior Engineer
Registered, N.C. 17501
(t,/1~
Clay ~ams, P.E.
ND ENVIRONMENTAL SERVICES, INC.
Corporate Geotechnical Consultant
JPD:CES:JNS/am
Attachments
2801 YORKMONT ROAD • SUITE 100 • CHARLOTIE, NC 28208
P.O. BOX 11297 • CHARLOTIE, NC 28220
[phone]
@
Comment:
RESPONSE TO COMMENT NO. 2 OF NCDEHNR
LETTER DATED AUGUST 4, 1995
The Ecusta letter of May 11, 1995 indicates the need to stabilize the ASB dike as the
justification to allow an expanded areal limit for coal ash disposal. No engineering data or
calculations were provided with regards to existing stability conditions of the dike or
landfill slope. Nor is any information provided with regards to stability of the dike or
landfill slopes in a post fill configuration. In addition, the proposed fill area is along only
approximately one half of the length of the dike in the area of the existing landfill property.
Response:
AERATION STABILIZATION BASIN (ASB) DIKE
The wording regarding the stability of the dike in Ecusta's letter dated May 11, 1975 was
intended to point out that the forces on the dike due to impounded water and gravity (weight)
will be partially counterbalanced by the placement of fill on the opposite side of the dike, thereby
increasing the factor of safety against failure. The factor of safety against failure is believed to
be adequate under existing conditions, and it was not meant to imply that the dike needed to be
stabilized. The entire ASB dike has been inspected regularly since its completion nineteen years
ago. None of the inspections over this period found the dike to be unstable or in need of
emergency repairs. Concerns noted during the inspections have been limited to the need for
routine maintenance, some minor erosion repairs, and the need to prevent animals from
burrowing into the dike. Some seepage at the toe of the dike was discovered shortly after
construction was completed, however, this was promptly addressed by the construction of
pressure relief wells and inverted filters. These measures allow seepage to continue in a
controlled manner and have functioned as intended since their installation. It is our opinion that
the ASB dike as designed and constructed is stable. A brief recap of the dike's history and
observations noted in the inspection reports prepared by Law Engineering, Inc., is provided
below. Additional and more frequent inspections have been conducted on a regular basis by
Ecusta personnel. Observations made during Ecusta's inspections are not included in this
summary.
Dike Design and Construction
The ASB dike was constructed over a one-year period from June 1975 to June 1976. Design
documents for the dike were prepared by J.E. Sirrine Engineers of Greenville, South Carolina.
No stability calculations are available to us. Considering the size of the dike, normal engineering
practice would not require stability calculations, and it is likely that none were done. Such low
dikes are normally designed based on precedent and engineering judgment Construction
monitoring was continuous during all earthmoving operations to verify that fill material was
suitable and that it was placed and compacted in accordance with project specifications. Field
density compaction tests were conducted throughout the construction process for quality control
purposes.
The dike has a crest width of 15 feet, an upstream slope of 2H: 1 V, and a downstream slope of
2.5H: 1 V. The dike ranges in height from about 15 to 20 feet and impounds water to an average
depth of about 15 feet. A partially penetrating cutoff or "keyway" was constructed along the
central axis of the dike. The keyway is three feet deep and has a minimum width at the bottom
of 12 feet. Internal ladder drains, 7 feet wide, were constructed at 25-foot centers and are
connected at their upstream end with a drain parallel to the dike. The drain material consists of
an 8-inch thick coarse filter (Penrose No. 4 crushed stone) sandwiched between two 8-inch thick
sand filters. The dike has "south dike" and "north dike" segments.
Post-Construction Activities
The aeration stabilization basin was filled during the period from April 19 to May 3, 1976. An
inspection conducted shortly after filling revealed three areas of seepage. Two of these areas
were outside of the south dike and the third was outside of the north dike near the east end. The
seepage was believed to have been caused by hydrostatic loading on a subsurface sand and
gravel stratum as a result of the basin being filled. To prevent the piping of fine soil particles
and to relieve any uplift pressures due to the seepage, a system of 36 relief wells was designed
and constructed. The wells extend into the sand and gravel stratum. Six relief wells are near the
east end of the north dike. Installation of the wells was accomplished by Law Engineering
Testing Co.
ASB Dike Inspection (October 5, 1976)
The above-referenced relief wells installed earlier in 1976 were inspected. The wells located
along the south dike were reported to be functioning adequately with no observed seepage
emerging from the ground in the vicinity of the wells.
Inspection of the wells along the north dike revealed two areas where flow could still be
observed emerging to the ground surface. Recommendations were made to construct an inverted
filter in these two isolated areas of percolation to prevent piping of foundation soils. The
proposed filter consisted of a six-inch layer of sand placed on a prepared foundation. An 18-inch
gravel layer (Penrose No. 4) was proposed to overlay the sand layer. The inverted filters were
constructed as proposed. Water entering the inverted filters drains to the channel that parallels
the dike on the north side.
ASB Dike Inspection (October 29, 1976)
A few areas of minor surface erosion on the dike and beyond the toe of the dike were noted.
These areas were recommended for repair.
The pressure relief wells were inspected again on this trip. The wells along the south dike were
reported to be functioning adequately and no seepage was observed in their vicinity.
The two isolated areas of percolation along the north dike previously observed were being
controlled adequately by the inverted filter. No other areas of percolation were observed at this
location.
Two additional areas of percolation were noted at new locations near the dike. One of these was
located just west of the electrical pad on the north dike. The other new area of seepage was
located along the west dike just north of the second power pole from the south end of the dike.
These two areas of seepage were reported to be very small. Inverted filters were constructed at
these locations at the recommendation of Law Engineering Testing Co.
2
The report prepared following this inspection noted that the ASB dikes had been designed and
constructed in accordance with good, modem geotechnical engineering practice and that the
dikes were generally in good condition and stable. The report goes on to say that representatives
of Law Engineering were present during construction of the dike and that Law is satisfied that
the construction was performed in an adequate manner. The seepage outside the basin is the
only identified geotechnical problem, however, installation of the relief wells and construction
of the inverted filters appears to be allowing seepage to occur in a controlled manner.
ASB Dike Inspection (May 6, 1986)
This inspection revealed some vegetation growing in the riprap on the upstream side of the dike,
but it was not felt to be substantial enough to threaten the dike stability or structural integrity.
Some potential for increased surface erosion was noted due to the presence of ruts on the outer
face of the dike, apparently caused by mowing equipment. It was recommended that these areas
continue to be repaired as needed and monitored for signs of advancing erosion.
The seepage at the east end of the north dike was reported to remain under control; the pressure
relief wells and inverted filters were functioning as intended.
Some muskrat holes were discovered beyond the toe of the north dike, but did not appear to
threaten the integrity of the structure. It was noted that future inspections should attempt to
locate any muskrat holes that might be present in the dike itself.
Recommendations were made to keep the drainage ditch which parallels the north dike free of
vegetation. The vegetation impedes drainage, causes the wet area to extend closer to the dike
and, ultimately, could encourage muskrats to burrow into the side of the dike.
No slumps, slides or significant eroded areas were visible on the inner face of the dike above the
water line or on the dike's outer face. No tension cracks, major depressions or other signs of
displacement were noted on the crest.
The inspection report concluded that there were no visible conditions that warranted emergency
repairs.
Replacement of Damaged Relief Wells -1989
On October 1, 1989, the adjacent Brown No. 2 ash landfill experienced a sudden downslope
movement toward the ASB north dike. Although the ash movement did not affect the dike,
subsequent activities associated with the ash clean-up resulted in five of the six 1976 relief wells
at this location being damaged. Five new wells were installed December 20-21, 1989. The relief
wells were connected to a 1-1/2 inch diameter header pipe which drains to the nearby channel.
In addition, a sand and gravel blanket was placed along the outer toe of the dike to serve as a
continuous inverted filter for additional seeps potentially reaching the ground surface. The sand
and gravel layers extend southwestward from the north dike termination point at the hillside to a
point about 50 feet beyond the relief well furthest downstream (Relief Well No. 1).
The report written in conjunction with this work concludes that the ASB north dike continues to
perform as intended.
3
ASB Dike Inspection (April 22, 1990)
The inverted filters were reported to be working satisfactorily. Clear water was observed to be
flowing from the filters and no soil deposits downstream of the filters could be seen.
The header pipe connecting the relief wells was located and inspected. No discharge from the
pipe could be seen at the time of the inspection, however, there were signs of previous discharge,
indicating that the system appears to be functioning as intended.
Some minor wheel rutting was observed on the downstream face of the dike, but did not appear
to be significant.
The inspection report concluded that the ASB dikes are in generally good condition. There were
no visible signs of conditions requiring emergency repairs.
Some recommendations were made regarding the need for periodic maintenance of the dike.
ASB Dike Inspection (December 19, 1994)
The inverted filters were inspected and found to be working satisfactorily, although vegetation in
the creek obscured the downgradient edge of the filter. Water in the creek appeared clear,
indicating that piping of fine soil materials is not occurring.
The discharge end of the header pipe connecting the pressure relief wells was inspected. There
was no flow from the pipe at the time of inspection and the pipe was not obstructed.
The sides of the dike appeared to be well maintained with some ruts still evident from the
mowing equipment.
The upper portion of the creek which parallels the north dike was reported to be heavily
vegetated. Animal burrowing in the vicinity of the dike was noted as becoming more
predominant; recommendations were made to remove the burrowing animals from the site and
to backfill the burrow holes.
The inspection report noted that the dike is in generally good condition and that there were no
visible signs of conditions requiring emergency repairs.
Conclusions -ASB Dike
No stability calculations are known to exist for the ASB dike, however, due to the low height of
this dike and the normal sideslopes used in the design, it is likely that no stability calculations
were ever done. This would be in keeping with normal practice for design of similar dikes. It is
our opinion that stability calculations for this dike are unnecessary. Based on inspection reports
for the ASB dike over the 19 years since construction was completed, there is no reason to
believe that any portion of the dike is unstable. Where seepage areas near the dike were
discovered, measures were promptly implemented to control the potential piping of fine soil
materials from the dike foundation. These control measures are inspected regularly and appear
to be functioning satisfactorily.
4
Addition of ash fill on the north side of the dike in conjunction with the landfill expansion will
partially counterbalance forces in the opposing direction due to impounded water and gravity.
The result will be an increase in the factor of safety against failure. However, the ASB dike is
believed adequately stable and the added benefit of the new ash is thus a "bonus". A secondary
benefit to be gained by expansion of the landfill will be a reduction in the potential for surface
erosion on the outside face of the north dike and the elimination of burrows in the expansion
area.
Regular inspections of the entire dike will continue in order to assess maintenance needs.
5
LANDFILL SLOPE
Geometry of Stability Section
The ash landfill slope as shown on Drawing No. 734 is presently at about 2.8 or 2.9: 1 (H:V) or
flatter. The section selected for the stability analysis is shown in plan view on Drawing No. 734
and in section view on Figure 1. The section represents the finished landfill as shown on the
referenced drawing. This section is not affected by the proposed expanded ashfill area.
Shear Strength of Ash
The shear strength parameters of the ash were determined by triaxial shear testing on a
laboratory sample of compacted ash from the Ecusta plant. The sample was compacted to a dry
density of 64 pcf, or about 98 percent of the maximum dry density as determined by the standard
Proctor laboratory compaction test. In the Law Environmental report dated November 12, 1992,
field density of the laboratory shear test specimen. Based on the laboratory test, and allowance
for the lower dry density values, the following shear strength parameters were selected for
compacted ash:
Condition:
Cohesion, psf
Friction Angle, degrees
Total Unit Weight, pcf
Saturated Unit Weight, pcf
Consolidated, Undrained
315
17.5
80
90
Effective (Drained)
150
31
80
90
For the disturbed ash affected by the 1989 failure, but left in place by necessity during the
19891990 reconstruction of the landfill, the following parameters were selected:
Condition:
Cohesion, psf
Friction Angle, degrees
Saturated Unit Weight, pcf
Subsurface Water Level in Ash
Consolidated, Undrained
0
15
90
Effective (Drained)
0
30
90
The piezometers in the ash landfill (Drawing R-730-D-1) were last read on December 4, 1992,
and showed water elevations of 2130, 2135 and 2143 in Pl, P2 and P3, respectively. Those
water elevations were at or below the top of the disturbed ash remaining after the 1989 failure,
indicating that the internal drainage system installed within the ash landfill is functioning as
intended. For the stability analysis, the water level was assumed to be at the top of the disturbed
ash level.
6
Conclusions -Landfill Slope Stability Factors
Based on our analysis using the PCSTABL5 program, the estimated factor of safety for the
active landfill when completed is 1.10 ( end of construction, undrained conditions) and 1.65 (long
term or effective stress ( drained) conditions). Computer generated graphics are attached
(Figures 2-9) showing all the failure surfaces evaluated and then the ten most critical failure
surfaces with their safety factors.
As shown on Drawing 734, the maximum surface slope of the proposed expansion area is
3H: 1 V, approximately the same as the steepest part of the slope analyzed for existing conditions.
A drained condition is applicable to the expansion area since a subsurface stone drainage layer is
proposed at the bottom of the fill area. In addition, surface water from offsite areas will be
diverted away from the expansion area by means of the diversion ditches shown on Drawing No.
734. The proposed expansion slope is not as high as the slope already analyzed. Since the slope
angle is similar, the results obtained from the analysis for the existing landfill under drained
conditions can be used to conservatively approximate the factor of safety for the proposed
expansion area. The factor of safety is thus expected to be in excess of about 1.5.
7
ECUSTA ASH LANDFILL EXISTING CONDITIONS -SIMPLIFIED JANBU
All surfaces evaluated. C:TRIAL3.PL T By: JPD 08-28-95 11 :56am
2500r-~~~~-.--~~~~~,--~~~~-.~~~~--,,--~~~~-.-~~~~-,~~~~~-.--~~~~~
Elev.
(ft)
2400
2300
4
2200
4 -::=...------------· W1 W1
2000L--~~~~_._~~~~~~~~~---'~~~~~_._~~~~_.__~~~~___._~~~~~...._~~~~~
185 285 385 485 585 685 785 885 985
X-Axis (ft}
FIGURE 2
2500 II #
2
3
4
5
2400tt-6
Elev.
(ft)
7
8
9
10
2300
2200
2100,w,
FS
1.19
1.20
1.20
1.23
1.24
1.26
1.28
1.28
1.30
1.31
ECUSTA ASH LANDFILL EXISTING CONDITIONS -SIMPLIFIED JANBU
Ten Most Critical. C:TRIAL3.PLT By: JPD 08-28-95 11 :56am
Soil Total Saturated Cohesion Friction Pore Pressure Piez.
Label Type Unit Wt. Unit Wt. Intercept Angle Pressure Constant Surface
No. (pcf) (pcf) (psf) (deg) Param. (psfl No.
NEW ASH 1 80 90 315 17.5 0 0 W1
ROCKFILL 2 110 120 0 40 0 0 W1
OLD ASH 3 90 90 0 15 0 0 W1
NAT SOIL 4 135 135 4000 35 0 0 W1
4 ~------------· Wl W1
4
2000~~~~~--'-~~~~~L-~~~~-"-~~~~----'~~~~~-1-~~~~--1~~~~~....L~~~~_j
185 285 385 485 585 685 785 885 985
PCSTABL5M FSmin= 1.19 X-Axis (ft)
FIGURE 3
ECUSTA ASH LANDFILL EXISTING CONDITIONS -SIMPLIFIED BISHOP
All surfaces evaluated. C:TRIAL4.PLT By: JPD 08-28-95 11 :52am
2500.--~~~--.~~~~.-~~~~.-~~~-y-~~~~-i-~~~----i~~~~-y-~~~--,
2400
Elev.
(ft)
2300
2200
2100,w,
~ -~ ----------• W1 W1
2000'--~~~~-'-~~~~-'-~~~~---'~~~~~..__~~~~-'-~~~~~~~~~~~~~~~~
185 285 385 485 585
X-Axis (ft)
685 785 885 985
FIGURE 4
2500 II #
2
3
4
5
2400tt-6
2300
Elev.
(ft)
2200
7
8
9
10
2100,w,
FS
1.10
1.11
1.12
1.15
1.15
1.16
1.19
1.19
1.19
1.20
ECUSTA ASH LANDFILL EXISTING CONDITIONS -SIMPLIFIED BISHOP
Ten Most Critical. C:TRIAL4.PLT By: JPD 08-28-95 11 :52am
Soil Total Saturated Cohesion Friction Pore Pressure Piez.
Label Type Unit Wt. Unit Wt. Intercept Angle Pressure Constant Surface
No. (pcf) (pcf) (psf) (deg) Param. (psf) No.
NEW ASH 1 80 90 315 17.5 0 0 W1
ROCK FILL 2 110 120 0 40 0 0 W1
OLD ASH 3 90 90 0 15 0 0 W1
NAT SOIL 4 135 135 4000 35 0 0 W1
4 ~------------· W1 W1
4
w1 ~vv,
2000L-~~~~__J_~~~~~'--~~~~--'-~~~~---'~~~~~....L....~~~~---'-~~~~~....L....~~~~--'
185 285 385 485 585 685 785 885 985
PCSTABL5M FSmin = 1.10 X-Axis (ft)
FIGURE 5
ECUSTA ASH LANDFILL -EXISTING CONDS. SIMPLIFIED JANBU METHOD, (DRAINED)
All surfaces evaluated. C:TRIAL5.PLT By: JPD 08-28-95 1 :40pm
2500~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
2400
2300
Elev.
(ft)
2200
2100,w,
4
~------------w, Wl
200QL--~~~~-L~~~~~L-~~~~-L-~~~~---''--~~~~_.__~~~~----'~~~~~__.__~~~~~
185 285 385 485 585
X-Axis (ft)
685 785 885 985
FIGURE 6
2500 II # FS
1.73
2 1.73
3 1.77
4 1.79
5 1.81
2400tf-6 1.82
7 1.83
8 1.85
9 1.87
10 1.89
I 2300
Elev.
(ft)
2200 I
2100~ 4
ECUSTA ASH LANDFILL -EXISTING CONDS. SIMPLIFIED JANBU METHOD, (DRAINED)
Ten Most Critical. C:TRIAL5.PL T By: JPD 08-28-95 1 :40pm
Soil Total Saturated Cohesion Friction Pore Pressure Piez.
Label Type Unit Wt. Unit Wt. Intercept Angle Pressure Constant Surface
No. (pct) (pct) (psf) (deg) Param. (psf) No.
NEW ASH 1 80 90 150 31 0 0 W1
ROCKFILL 2 110 120 0 40 0 0 W1
OLD ASH 3 90 90 0 30 0 0 W1
NAT SOIL 4 135 135 4000 35 0 0 W1
7 -/4 -4------------· W1 y.
3 Wl
4 ~ ---== ...
w4 VV1
w,
2000L-~~~~~~~~~-'-~~~~--1~~~~~.,__~~~~-'-~~~~-L~~~~~'--~~~---'
185 285 385 485 585 685 785 885 985
PCSTABL5M FSmin = 1. 73 X-Axis (ft)
FIGURE 7
ECUSTA ASH LANDFILL -EXISTING CONDS. SIMPLIFIED BISHOP (DRAINED)
All surfaces evaluated. C:TRIAL6.PL T By: JPD 08-28-95 1 :45pm
2500r-~~~~--,-~~~~-.-~~~~--,;--~~~~~~~~~---,--~~~~-,-~~~~~-.--~~~~~
Elev.
(ft)
2400
2300
2200
4 ~------------· W1 W1
285 385 885
2000~~~~-::::~~~-=-=--~~~J__~~~_L~~~--1~~~~...l_~~~--1..~~~_J
185 985 485 585
X-Axis (ft)
685 785
FIGURE 8
2500 II
# FS
1 1.65
2 1.67
3 1.70
4 1.71
5 1.73
2400ft6 1.76
7 1.76
8 1.78
9 1.78
10 1.80
I 2300
Elev.
(ft)
2200
2100,w,
ECUSTA ASH LANDFILL -EXISTING CONDS. SIMPLIFIED BISHOP (DRAINED)
Ten Most Critical. C:TRIAL6.PLT By: JPD 08-28-95 1 :45pm
Soil Total Saturated Cohesion Friction Pore Pressure Piez.
Label Type Unit Wt. Unit Wt. Intercept Angle Pressure Constant Surface
No. (pcf) (pcf) (psf) (deg) Param. (psf) No.
NEW ASH 1 80 90 150 31 0 0 W1
ROCKFILL 2 110 120 0 40 0 0 W1
OLD ASH 3 90 90 0 30 0 0 W1
NAT SOIL 4 135 135 4000 35 0 0 W1
I} 8 6 4 C:..------------· Wl Wl
3
4
2000L-~~~~J_~~~~_J_~~~~_L_~~~~_J_~~~~----1.....~~~~---'-~~~~---'~~~~~
185 285 385 485 585 685 785 885 985
PCSTABL5M FSmin = 1.65 X-Axis (ft)
FIGURE 9
Ecusta a division of P.H. GLATFELTER co.
P.O. BOX 200 • PISGAH FOREST, NORTH CAROLINA 28768-0200
TELEPHONE [phone]
R. J. GUSSMAN
Director, Environmental Affairs
Tel. [phone]
Fax [phone]
Mr. William D. Sessoms, P.E.
Division of Solid Waste Management
P. 0. Box 27687
Raleigh, North Carolina 27611-7687
Re: Permit No. 88-01
Additional Fill Area Request
Dear Bill:
September 1, 1995
AP~'ROVED
DIVISION OF SOLID WASTE MANAGEMENT
DATL ,0/ 2,~ { q :S _ BY __ IV_J::>_z: ____ _
I would like to start out by thanking both Bobby and you for the time you
spent reviewing the various submittals that we have sent to the depart-
ment. I believe it is important that all of us remember that this additional
fill area is being placed on existing ash and is well within the permitted
boundaries of our current landfill. This is not a new landfill.
The following is submitted in response to your letter of August 4:
1. Attached is an updated topographical plan, drawing No. 734, which
shows all subsurface and surface drainage structures.
2. The attached report from Law Engineering and Environmental Services
addresses the stabilization concerns.
3. I will try to answer Mr. Lutefy's concerns in the order they are listed in
his memo to you. dated July 17, 1995.
a)
. ..
The purpose, location, design and fl oer ·bf subsurface relief wells
were described in detail in the applic~ i'orJ; fo rebuild the landfill
after the slide incident in 1989. These are "contained in "Technical
Specifications of Reconstruction of Brown No. 2 Ash Landfill" by
Law Environmental and are part of Attachment 2 of our current
permit. As part of the original application, mention is made of
o'\' '213 74 e:, ~ ,s,.
l\'o ~ '87
(0 T :.>
I.I) ~ ;; ~£~ 1~ts i
c; Received ~
\ So\id \>,faste ~
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c' 6'.> ;f ,; >
4 aza,91..0..., .::..::;::...--
Mr. William D. Sessoms, P.E.
Division of Solid Waste Management
September l, 1995
Page 2
piping any spring discharges to the drainage ditch leading to the
Davidson River. At least two springs were located and piped to
this drainage ditch during the construction phase. After the
proposed change, these springs will be connected into the erosion
control pond and will eventually discharge into the same drainage
ditch leading to the Davidson River.
Analysis of a composite of the discharges of these springs was
conducted in late 1979 before ash was placed in the landfill with
the following results:
Chemical Name
Arsenic, mg/1
Barium, mgjl
Cadmium, mgjl
Chromium, mg/1
Fluoride, mg/1
Turbidity, NTU
Lead, mgjl
Mercury, mg/1
Nitrate, mgjl
Selenium, mgjl
Silver, mg/1
Results
<0.01
<0.1
<0.005
<0.01
0.02
0.91
<0.01
<0.0005
0.61
<0.005
<0.01
After placement of the ash, regular testing of these springs was
conducted for a number of years. The following is representative:
1981 1983 1985 1988
Arsenic, mg/1 <0.01 <0.05 <0.01 <0.005
Barium, mg/1 <0.10 <0.08 <0.10 <0.20
Cadmium, mg/1 <0.005 <0.004 <0.005 <0.01
Chromium, mgjl <0.01 <0.01 <0.01 <0.03
Fluoride, mgjl <0.05 0.12 0.18
Lead, mg/1 <0.01 0.01 <0.01 0.007
Mercury, mgjl 0.0003 <0.001 <0.0005 <0.0005
Nitrate, mg/1 • <0.02 <0.05 <0.02
Selenium, mgjl <0.005 <0.005 <0.005 <0.005
Silver, mgjl <0.01 <0.01 <0.01 <0.05
Turbidity, NTU 0.41
BOD5, mgjl 3.14
COD, mg/1 3.5
Total Solids, mg/1 39.0
TSS, mg/1 5.3
Mr. William D. Sessoms, P.E.
Division of Solid Waste Management
September 6, 1995
Page 3
Because of our program of conducting annual analysis of the coal
ash (EP and later TCLP tests), analysis of the springs was
discontinued after 1991. Copies of the former analyses were sent
to Gary Ahlberg in 1990.
b) All of the information requested in this paragraph has previously
been submitted to the State. None of it has changed. As we have
discussed, the City of Brevard is installing public water supply
lines to all homes in the Deaver Road area west of the existing
landfill and will require them to connect to city water when this is
completed. All installation costs and connection fees are being
paid by the State of North Carolina.
c) Both the P.H. Glatfelter Company and our consulting engineers,
Law Engineering and Environmental, are aware that ash cannot be
placed within four feet of the seasonal water table. Section A-A of
the Brown No. 2 ash landfill indicates a minimum bottom ash
elevation of 2100. Water table level measurements have been
taken for a number of years at our groundwater monitoring well,
Q88v5, which is located at a surface elevation of 2098 and is
approximately 300 feet from the proposed fill area. These
measurements indicate that the seasonal high water table is at an
elevation of 2095.6. Therefore, we have selected a minimum
bottom ash elevation of 2100.
d) Past data does indicate an elevated level of sulfate in one
downgradient well. It does not appear in any of our other
downgradient wells in the area. As I have discussed with Bobby
and Jim Patterson, both recently and in the past, these high
sulfate. levels are a concern to us.
As described in paragraph (b), the City of Brevard is connecting all
the homes in the Deaver Road area to city water. Because of this,
we propose that, as part of the approved operating permit for this
landfill, we will submit a program for departmental approval to not
only identify the location and design of any potable water supply
Mr. William D. Sessoms, P.E.
Division of Solid Waste Management
September 6, 1995
Page 4
wells downgradient of this monitoring well, but also to look at the
need for additional monitoring and/ or sampling for additional
parameters that may be necessary in order to assess the source
and extent of the sulfates.
If further information is needed, please call me at (704) 877-234 7.
RJG
jh
Attachments
cc: C. N. Carter
L. W. Nelson J. f1r iTEtSOtJ) qshivide
Sincerely,
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
October 23, 1995
R. J. Gussman
Director, Environmental Affairs
Ecusta
Post Office Box 200
Pisgah Forest, North Carolina 28768-0200
Re: Permit Number 88-01
Additional Fifi Area Request
Mr. Gussman:
The Division of Solid Waste Management, Solid Waste Section (Section) has
completed the review of Ecusta 's request for additional fill area at the Ecusta Ash Monofill.
The request is hereby approved subject to the conditions contained in this letter.
This additional fill area approval is in addition to, and hereby made a part of, the
permit referenced above.
The following approved documents are in addition to, and hereby made a part of,
the permit referenced above:
1. Plans entitled Brown No. 2 Ash Landfill
Topographical Plan, drawing number 734, latest
revision, dated 4/17 /05.
2. Response to comments letter, from R. J.
Gussman, Ecusta, to William D. Sessoms, Solid
Waste Section, dated September 1, 1995.
3. Response to comments prepared by Law
Engineering, dated August 30, 1995, including
accompanying drawings, calculations, and
exhibits.
4. Law Engineering letter to Ecusta, dated
September 23, 1995.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
5. Plan entitled Plan View Schematic Of Proposed
Landfill Expansion, prepared by Law Engineering,
Figure 1.
6. Plan entitled Section A-A' (Typical), prepared by
Law Engineering, Figure 2.
Ecusta Landfill
File Number 88-01
Page 2
The additional fill area is limited to the proposed grading lines and as shown on the
Brown No. 2 Ash Landfill Topographic Plan, drawing number 734.
This landfill and facility is subject to the requirements of all applicable sections of
the most recent version of the North Carolina Solid Waste Management Rules, 1 5A NCAC
138.
Additional conditions and revisions of the approved documents or changes during
construction of the landfill require prior approval by the North Carolina Solid Waste Section.
This project and facility may be subject to the sedimentation and erosion control
requirements of the Department of Environmental Management, Land Quality Section. You
are advised to contact the Land Quality Section to determine if an approved sedimentation
and erosion control plan is required.
Ground water quality at this facility is subject to the "Classifications and Water
Quality Standards Applicable To The Groundwaters of North Carolina", 15A NCAC 2L. This
includes, but is not limited to, the provisions for detection monitoring, assessment, and
corrective action.
An additional surface water monitoring location shall be established in the drainage
feature immediately below the spring discharges.
The four detection monitoring wells and three surface water monitoring locations
shall be sampled for the following parameters: Arsenic, Cadmium, Chromium, Iron, Lead,
Manganese, Mercury, Selenium, Sulfates, pH, and a Volatile Organic Analyses equivalent to
the Appendix I list Volatile scan using EPA Method 8240 or 8260. All metals and inorganic
parameters are to be analyzed for total content.
Within 90 days, updated information shall be provided regarding the location of
homes, wells, septic fields, underground utilities, public water supply lines, etc. for the
properties adjacent to or in the vicinity of the landfill facility. This should include the wells
for homes that have been recently connected to, and those that will be connected to, the
public water supply.
Within 90 days, the wells immediately downgradient of the monitoring well
designated Q88v5 (which is showing high levels of sulfates) shall be sampled and analyzed
for Total Sulfates, TDS, Turbidity, pH, Temperature, and Specific Conductivity.
,·
Ecusta Landfill
File Number 88-01
Page 3
Should you have any questions concerning this approval or if we can provide any
other assistance, please do not hesitate to contact the Section at [phone] (email:
[e-mail]).
Thank you,
William D. Sessoms, PE
Approved:
enclosures
copy: Jim Patterson -DSWM
Central File 88-01
C:\SESSOMS\PROJECTS\ECUSTA\LETIER.3
Ecusta a division of P.H. GLATFELTER c~.
P.O. BOX 200 • PISGAH FOREST, NORTH CAROLINA 28768 • TELEPHONE [phone]
R. J. GUSSMAN
Director, Environmental Affairs
Te1. 704/877-2347
Fax [phone]
Mr. William D. Sessoms, P.E.
Division of Solid Waste Management
P. o. Box 27687
Raleigh, North Carolina 27611-7687
Re: Permit No. 88-01
Additional Fill Area Reguest
Dear Bill:
)
November 9, 1995
The P.H. Glatfelter Company ("Glatfelter'') has reviewed
your approval of the additional fill area of the Brown #2
Ash Monofill dated October 23, 1995. As we have discussed,
Glatfelter has some concerns with the interpretation of the
last two paragraphs on page 2 of your October 23 letter.
I write to confirm Glatfelter's understanding of those
conditions and to assure that it is consistent with the
Division's intent.
The first of these two paragraphs provides:
Within 90 days, updated information shall be
provided regarding the location of homes, wells,
septic fields, underground utilities, public water
supply lines, etc. for the properties adjacent to
or in the vicinity of the landfill facility. This
should include the wells for homes that have been
recently connected to, and those that will be
connected to, the public water supply.
Glatfelter understands this condition to require Glatfelter
to collect all records from the Transylvania County's
Health and Planning Departments, the City of Brevard's
Planning and Utilities Departments, and other agencies as
we may be directed which those agencies will make available
before January 19, 1996, regarding the location of homes,
Mr. William D. Sessoms, P.E.
Divisign of Solid waste Management
November 9, 1995
Page 2
wells, septic fields, underground utilities, and public
water supply lines for the properties within 1500 feet of
monitoring well Q88v5 and to submit that information to the
Division by January 22, 1996.
The second of the two paragraphs provides:
Within 90 days, the wells immediately downgradient
of the monitoring well designated Q88v5 (which is
showing high levels of sulfates) shall be sampled
and analyzed for total sulfates, TDS, turbidity, pH,
temperature, and specific conductivity.
Glatfelter understands this condition to require Glatfelter
to obtain from the Transylvania County Health Department,
the North Carolina Department of Environment, Health, and
Natural Resources -Division of Environmental Management,
and other agencies as we may be directed, all records
concerning sampling and analyses of the potable wells
downgradient and within 1500 feet of monitoring well Q88v5
made available by December 1, 1995, and to make reasonable
efforts to obtain additional samples and analyses if the
available records do not provide the required data.
Glatfelter further understands that it must submit the
information obtained from the public records and any new
sampling and analyses to the Division by January 22, 1996.
If you do not agree with this interpretation of these two
paragraphs, please advise us within 30 days. If you feel
that a meeting with you, Jim, and Bobby would be
beneficial, please call either me at [phone] or
c. N. Carter at [phone].
RJG
jh
cc: c. N. Carter
R. S. Lawrenc1.
J. Patterson
Sincerely,
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
NA
DEHNR
November 16, 1995
Mr. Bob Gussman
Director of Environmental Affairs
Ecusta, P.O. Box 200
Pisgah Forest, North Carolina 28768
RE: Your November 9, 1995 Letter Regarding The Conditions Of The
Approval For Additional Fill Area At The Ecusta Ash Landfill
(Permit# 88-01)
Dear Mr. Gussman,
There does appear to be some differences in Glatfelter's
understanding of the two paragraphs referenced in your letter and
the intent of the Solid Waste Section. Please note the following
comments:
The purpose of the first paragraph in question is to update the
existing conditions in the vicinity of the landfill. Typically the
Section is looking for this updated "Local Area Study" information
to include current conditions for the area within 2000 feet of the
landfill facility boundary. While, generally, checking City and
County records provides much of the requested information, some
field reconnaissance is usually necessary to verify the records and
ensure that the information accurately reflects the current
conditions.
Since the Solid Waste Section does not currently know the number or
location of the nearby houses and water supply wells, it is
somewhat difficult to specifically address Glatfelter's
understanding of the second paragraph in question. While any
historic records of sampling of these wells would certainly be
useful, I would be surprised if there was any recent data for the
parameters . in question. It is the intent of the Solid Waste
Section that the closest four to six water supply wells within 700
to 1000 feet of well 088v5 be sampled for the parameters
referenced. It would also be good to sample well Q88v5 for these
parameters at the same time. Glatfelter may wish to request the
assistance of the County Health Department if there is any
resistance on the part of the property owners to allowing access to
sample the private wells.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
Mr. Bob Gussman
Ecusta
Page 2
I hope this letter clarifies the intent of the Solid Waste Section
in requesting the information referenced in the two paragraphs in
question. If you have any questions about this letter, you may
contact me a [phone], extension 258.
Sincerely,
Bobby Lutfy
Hydrogeologist
Solid Waste Section
cc : Bill Sessoms, Solid Waste Section
Jim Patterson, SWS -Asheville
TO:
State of North Ca, olina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
Bill Sessoms
July 17, 1995
~!·i~A ---~_. a an
DEHNR
FROM: Bobby Lutfy
RE: Ecusta Landfill Expansion Plan (Permit# 88-01)
In the letter of September 23, 1994, from Law Environmental to
Ecusta, references are made to "subsurface relief wells". What is
the number, location, design, and purpose for these wells? The
statement is also made that "The channel carries stormwater runoff
and spring discharges from a nearby hillside to the Davidson
River". What is the current location of the "spring discharges"?
How will this discharge be managed in the proposed landfill
expansion? Have the spring discharges been sampled and analyzed
for water quality?
The plans should show the location of subsurface and surface
drainage features and the location of ground-water monitoring
wells and other wells at the facility. Updated information should
also be provided regarding homes, structures, wells, septic fields,
underground utilities, public water supply lines, etc. for the
properties adjacent to or in the vicinity of the landfill facility.
The plan states that "All ash will be placed a minimum of four feet
above the seasonal high water table". Some data and discussion
need to be provided that demonstrate that the proposed design will
maintain the required four foot vertical separation between the
waste and the long-term seasonal high water table. The management
of the spring discharges could affect this determination.
Past sampling data indicates sulfate levels in one of the
monitoring wells that exceed the N.C. Groundwater Standards. High
levels of TDS, specific conductivity, and TOC have also been
reported for this monitoring well in some of the past sampling
events. It is especially important to identify the location and
design of any water supply wells downgradient of this monitoring
well. Additional monitoring wells and sampling for additional
parameters will be necessary in order to assess the nature and
extent of ground-water contamination in this area.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
·-,. ----..
Ecusta Landfill
File Number 88-01
Page 2
Should you have any questions or if we can provide any assistance, please contact
the Section at [phone] (email: [e-mail]).
Thank you,
William D. Sessoms, PE
enclosure
copy: James C. Coffey -DSWM
Jim Patterson -DSWM
Central File 88-01
C:\SESSOMS\PROJECTS\ECUST A \LEITER. 2
OJ -
350
300
250
200
150
100 ....,.1----FINAL SURFACE (COMPLETED AS OF APRIL 1995) ---•
2250
2200
2150
2100 --
0 50 100 150
(D MATERIAL DESIGNATION USED IN
STABILITY PROGRAM PCSTABL5
ASH SURFACE AFTER\ 1989 FAILURE
FINAL SURF ACE
(D -----(3) ---· --------®
200 250 300 350 400 ~