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HomeMy WebLinkAbout1117_Buncombe_GARAA_DukeResponsetoArea1_FID1891049_20240725Ar' DUKE ENERGY® PROGRESS July 25, 2024 North Carolina Department of Environmental Quality Attn: Ms. Sarah M. Moutos (Electronic Submittal Only) Environmental Program Consultant Division of Waste Management — Solid Waste Section 1646 Mail Service Center Raleigh, NC 27699-1646 410 S. Wilmington Street NCRH 3 Raleigh, NC 27601 Subject: Greater Asheville Regional Airport Authority — Area 1 Structural Fill Site Visit Report Received June 13, 2024 Dear Ms. Moutos: Duke Energy (Duke) is in receipt of the North Carolina Department of Environmental Quality (NCDEQ) Site Visit Report (enclosed — Attachment 1) provided to Duke via electronic mail on June 13, 2024. The Site Visit Report summarized the NCDEQ inspection from May 29, 2024 for the Area 1 structural fill located at the Greater Asheville Regional Airport Authority (GARAA). The Site Visit Report requested certain activities be completed by Duke and the GARAA, and this response only addresses item numbers 1— 3 as item 4 was to be addressed by GARAA. Below are the items requested by NCDEQ along with Duke's response in italic font. 1. Toe Drain Erosion caused exposure of a significant amount of geonet that should have been covered by twelve inches of aggregate. The Section requests Duke Energy conduct an evaluation of the toe drain, determine and complete any repairs. This may include evaluation of the size of the aggregate stone within the toe drain and if it is sufficient. Please provide the evaluation, any additional communication on repairs, and photos to Sarah Moutos at Sarah.Moutos@deg.nc.gov. The GARAA completed repairs to the toe drain by adding additional aggregate and provided an electronic mail (D. Nance to S. Moutos) on June 19, 2024 which summarized and included photos of the repairs completed. Separately, Duke worked with our Area 1 Cover Project vendor (Geosyntec) to complete a walkdown of the Area 1 structural fill toe drain. That walkdown was completed on July 3, 2024. Within the Geosyntec memorandum dated July 19, 2024 (enclosed —Attachment 2), Geosyntec recommended that Class A riprap be placed along a stretch of the east perimeter toe drain and along a stretch of the west perimeter swale. Duke will work with the GARAA for access and apply the Class A riprap and notify NCDEQ that the work is complete to close out this item. 2. Performance Monitoring Protocol The Section requests Duke Energy ensure the required Settlement Agreement Condition #8, Performance Monitoring Protocol, was submitted to the Section. Ms. Sarah M. Moutos July 25, 2024 Page 2 The settlement was dated October 2, 2020 and Condition #8 thereto required Duke to submit to NCDEQ within 90 days the Performance Monitoring Protocol. Duke submitted to NCDEQ on December 14, 2020 the Water Quality Monitoring and Reporting Plan (Rev. 1) and within under Section 3.2 Surface Water is the necessary text from Condition #8. NCDEQ provided to Duke later that day (12114120) the Water Quality Monitoring and Reporting Permit (1117-STRUC-2020, FID 1517115). 3. Monitoring Wells The Section requests Duke Energy ensure Area 1 monitoring well pads, tags and locks are installed and secure. Duke partnered with our vendor SynTerra to inspect all the groundwater monitoring wells and piezometers within and nearby to Area 1 structural fill and to complete repairs as necessary. On June 26, 2024, SynTerra added well tags as needed to any piezometers and wells, attached a lock to MW-7-Al, and cleared dirt and debris from well pads to inspect and make any repairs if needed. Well pads on MW- 28-A1, MW-7-Al, and MW-8-Al were found to be in good condition and did not need replacement (enclosed photo —Attachment 3). If you need any clarification regarding the information provided, feel free to contact me at 9ohn.toepfer(d)duke-energy.com or 919-546-7863 at your convenience. Respectfully submitted, John R. Toepfer, P.E. Lead Engineer Waste & Groundwater Programs enc: Attachment 1— NCDEQ Site Visit Report, June 13, 2024 Attachment 2 — Memorandum, Asheville Airport Area 1— Site Visit Follow Up, July 19, 2024, Geosyntec Attachment 3 — Groundwater Monitoring Well Pad located —Area 1 structural fill, June 26, 2024 cc: Ed Sullivan and Ronnie Goodman — Duke Energy John Coon and Daniella Lajos - GARAA Victor Damasceno — Geosyntec Consultants Kelly Ferri — SynTerra Corporation Attachment 1 North Carolina Department of Environmental Quality Site Visit Report June 13, 2024 NORTH(;AROLI REQ�� OapaMnent of EnvironmenUl Ouali� SITE VISIT REPORT Division of Waste Management Solid Waste Section UNIT TYPE: Lined LCID YW Transfer Compost SLAS COUNTY: Buncombe MSW LF PERMIT NO.: 1117-STRUC-2021 Closed HHW White Incin T&P FIRM MSW goods LF TYPE: SITE VISIT CDLF Tire T&P / Tire Industrial Structural X SDTF Collection Monofill Landfill Fill DATE OF SITE VISIT: MAY 29, 2024 FACILITY NAME: Greater Asheville Regional Airport Authority (GARAA) Structural Fills — Areas 1 61 Terminal Drive # 1 Fletcher, NC FACILITY CONTACT NAME AND PHONE NUMBER: Name: Daniela Lajos, Asheville Regional Airport Authority Operations Manager Telephone: 828-654-6214 Email address: dlajos&flyavl.com Name: David Nantz, Safety Program and Special Projects Manager Telephone: 828.209.5104 Email address: dnantz3kflyavl.com PARTICIPANTS: Daniela Lajos, Asheville Regional Airport Authority David Nantz, Asheville Regional Airport Authority Sarah Moutos, DEQ Sherri Stanley, DEQ Elizabeth Werner, DEQ Connor McCloud, DEQ Eric Smith, DEQ Blake Butcher, DEQ John Toepfer, Duke Energy Kim Witt, Duke Energy Kelly Ferri, Synterra Corp PURPOSE OF SITE VISIT: Site Visit prior to Section completion of the Certificate of Closure for GARAA Phase 1. Page 1 of 3 SITE VISIT REPORT D_E Q�� NORTH CAROLINA Division of Waste Management OepeMronl of EnvironmenUl Oualiry Solid Waste Section NOTES: The Division of Waste Management — Solid Waste Section (Section) and Division of Water Resources were at the airport for a site visit of the Area 1 Site. Cap improvement construction was completed approximately Q3 2023. Site conditions were dry and sunny. Minimal standing water was observed along the access road. Standing water was not observed on the top of the Area 1 Structural fill. Erosion rills and exposed geonetting were observed along the permanent cap system toe drain around the perimeter of the fill, as shown in photo 3 below. Additionally, a monitoring well was observed without a pad. The Section would appreciate the following items addressed: 1. Toe Drain: o Erosion caused exposure of a significant amount of geonet that should have been covered by twelve inches of aggregate. The Section requests Duke Energy conduct an evaluation of the toe drain, determine and complete any repairs. This may include evaluation of the size of the aggregate stone within the toe drain and if it is sufficient. Please provide the evaluation, any additional communication on repairs, and photos to Sarah Moutos at Sarah.Moutos(adeq.nc. gov. 2. Performance Monitoring Protocol: o The Section requests Duke Energy ensure the required Settlement Agreement Condition #8, Performance Monitoring Protocol, was submitted to the Section. 3. Monitoring Wells: o The Section requests Duke Energy ensure Area 1 monitoring well pads, tags, and locks are installed and secure. 4. Inspection Protocols: o Erosion caused exposure of a significant amount of geonet that should have been covered by twelve inches of aggregate within the toe drain. The Section requests GARAA submit a revision of the approved March 2021 Operations and Management Plan (FID 1565311) stating proposals to help mitigate future problems of this nature. There were no violations observed. At this time, the Section will issue the Certificate of Closure once the above are addressed. The Section will be in touch to conduct an annual inspection in September 2024 of Areas 1, 3, and 4 and supporting documentation. Phone: 919-707-8287 Sarah Moutos Environmental Program Consultant Sarah.Moutos(&deq.nc. gov Page 2 of 3 ��A1��A��� REQ�� oeoann,emmeamman,eaui aear� /� Ar- SITE VISIT REPORT Division of Waste Management Solid Waste Section 1. Looking west towards the airstrip 2. Edge of Cap Markers 3. Toe drain with exposed geonetting Page 3 of 3 Attachment 2 Geosyntec Consultants of NC, PC Memorandum — Asheville Airport Area 1— Site Visit Follow Up July 19, 2024 Geosyntec consultants Geosyntec Consultants of NC, P.C. Memorandum Date: 19 July 2024 To: John Toepfer, Duke Energy Copies to: Ronnie Goodman, Duke Energy From: Victor M. Damasceno, Geosyntec Consultants Subject: Asheville Airport Area 1 — Site Visit Follow Up Geosyntec Consultants of NC, PC 1300 South Mint Street, Suite 300 Charlotte, North Carolina 28203 PH 704.227.0840 Engineering License C-3500 Geology License C-295 www.geosyntec.com This memorandum was prepared by Geosyntec Consultants of NC, P.C. (Geosyntec) pursuant to a request from Duke Energy Progress, LLC (Duke Energy) in response to a letter from the North Carolina Department of Environmental Quality (NCDEQ) dated 13 June 2024 (Attachment A). NCDEQ conducted a site visit on 29 May 2024, prior to Section completion of Closure for the Greater Asheville Regional Airport Authority (GARAA) Phase 1, and noted concerns associated with the toe drain along the perimeter swales, as described below. • Item 1. Toe Drain: "Erosion caused exposure of a significant amount of geonet that should have been covered by twelve inches of aggregate. The Section requests Duke Energy conduct an evaluation of the toe drain, determine and complete any repairs. This may include evaluation of the size of the aggregate stone within the toe drain and if it is sufficient." • Item 4. Inspection Protocols: "Erosion caused exposure of a significant amount of geonet that should have been covered by twelve inches of aggregate within the toe drain. The Section requests GARAA submit a revision of the approved March 2021 Operations and Management Plan (FID 1565311) stating proposals to help mitigate future problems of this nature." Note that items 1 and 4 (above) indicate a minimum 12-in thick aggregate is required within the toe drain/perimeter Swale. However, as noted on Drawing 12, Detail 11/3 of the Permit Drawings Area 1 Proposed Cap Design, dated December 2020 (referred to hereafter as Permit Drawings — Attachment B), the required thickness of AASHTO No. 57 Stone (aggregate) within the bottom of the swale, covering the geocomposite drainage layer is 6 inches (minimum). Relatedly, geosynthetic layers and aggregate is not required beyond the bottom of the Swale (e.g., not required on outside perimeter Swale slopes). Duke Energy and Geosyntec conducted a site visit at the Asheville Airport Area 1 on 3 July 2024. Messrs. Victor M. Damasceno, Ph.D., PE(Nq (Geosyntec) and Ronnie L. Goodman (Duke Memo - NCDEQ Site Visit.docx engineers I Scientists I innovators Mr. John Toepfer 19 July 2024 Page 2 Energy) visually inspected the perimeter swales and toe area of the Asheville Regional Airport Area 1 footprint. We understand GARAA Maintenance group inspected the areas of concern on 30 May 2024 and subsequently added gravel to the areas identified by NCDEQ. As such, the areas of concern identified by NCDEQ had been corrected and we could not readily visually assess the extent of the areas of concern. During the 3 July 2024 site visit, the Area 1 East Fill perimeter Swale comprised more than 6 inches of aggregate. Relatedly, the aggregate and geosynthetics exceeded the design requirements, extending beyond the bottom of the Swale on to the outside perimeter Swale slopes. However, based on conversations with Duke Energy, we recommend that the East Channel 2 (Drawing 6 and Detail 11/12 of the Permit Drawings — Attachment C) be supplemented with a minimum 6-in thick layer of Class A riprap. Specifically, Class A riprap should be placed between RD-1/RD-3 Outlet Stabilization Structure and RD 4 Outlet Stabilization Structure as outlined in Attachment C. Duke Energy and Geosyntec encountered exposed geosynthetics within the Swale. However, upon further inspection, the exposed geosynthetics were identified as scrap pieces, and not components of the cover system (Photos 1, 2, and 3). The scraps were removed from the swale and set aside for later removal from the site. Duke Energy and Geosyntec also visually inspected the Area 1 West Fill perimeter Swale. During the inspection, we notice (i) scrap geosynthetics within the Swale (Photo 04) and (ii) an area along the outside Swale slopes with exposed geosynthetics (i.e., South Channel 2, Drawing 7 of the Permit Drawings — Attachment D). However, as previously noted, the geosynthetic layers and AASHTO No. 57 Stone are only required within the bottom of the Swale. As shown on Photo 5, the exposed geosynthetics are beyond the bottom of the perimeter Swale. However, after conversations with Duke Energy, Geosyntec recommends that the exposed geosynthetics be covered with Class A riprap as outlined in Attachment D. During the visual inspection, Duke Energy and Geosyntec also noted that some of the limit of liner markers had been impacted by equipment/vehicle. Relatedly, adjacent perimeter swales and toe drains showed signs of traffic. Note that the perimeter swales and toe drains are not designed to withstand traffic (e.g., mower). Geosyntec recommends that the limit of liner markers be repaired and that traffic within the swales be minimized/eliminated. Memo - NCDEQ Site Visit.docx engineers I SCierlTISMS I Ir1t1UVaTUr5 Photos �66W,-P w/\�l�����\ - 6r/»` \:4 Photo O £ Scrap 2Coc mpo 4e g og i removed from East Channel 2 Photo 0.Scrap g o ompoi! g ogi embedded in the East Channl2 No. 57Stone. ;d ithetics Photo 05. Exposed geosynthetic layers along outside slope of the South Channel 2. Attachment A NOFTIi CAPOLINAD_E Q�/�� o.p—tm e.m --1 0.1 SITE VISIT REPORT Division of Waste Management Solid Waste Section UNIT TYPE: Lined LCID YW Transfer Compost SLAS COUNTY: Buncombe MSW LF PERMIT NO.: 1117-STRUC-2021 Closed HHW White Incin T&P FIRM MSW goods LF TYPE: SITE VISIT CDLF Tire T&P / Tire Industrial Structural X SDTF Collection Monofill Landfill Fill DATE OF SITE VISIT: MAY 29, 2024 FACILITY NAME: Greater Asheville Regional Airport Authority (GARAA) Structural Fills — Areas 1 61 Terminal Drive # 1 Fletcher, NC FACILITY CONTACT NAME AND PHONE NUMBER: Name: Daniela Lajos, Asheville Regional Airport Authority Operations Manager Telephone: 828-654-6214 Email address: dlajosAflyavl.com Name: David Nantz, Safety Program and Special Projects Manager Telephone: 828.209.5104 Email address: dnantz3(&flyavl.com PARTICIPANTS: Daniela Lajos, Asheville Regional Airport Authority David Nantz, Asheville Regional Airport Authority Sarah Moutos, DEQ Sherri Stanley, DEQ Elizabeth Werner, DEQ Connor McCloud, DEQ Eric Smith, DEQ Blake Butcher, DEQ John Toepfer, Duke Energy Kim Witt, Duke Energy Kelly Ferri, Synterra Corp PURPOSE OF SITE VISIT: Site Visit prior to Section completion of the Certificate of Closure for GARAA Phase 1. Pagel of 3 —� SITE VISIT REPORT DEQ Division of Waste Management D,,p�°0of E. NA _ °w°""Im°m°°"'°"°"fir Solid Waste Section NOTES: The Division of Waste Management — Solid Waste Section (Section) and Division of Water Resources were at the airport for a site visit of the Area 1 Site. Cap improvement construction was completed approximately Q3 2023. Site conditions were dry and sunny. Minimal standing water was observed along the access road. Standing water was not observed on the top of the Area 1 Structural fill. Erosion rills and exposed geonetting were observed along the permanent cap system toe drain around the perimeter of the fill, as shown in photo 3 below. Additionally, a monitoring well was observed without a pad. The Section would appreciate the following items addressed: 1. Toe Drain: o Erosion caused exposure of a significant amount of geonet that should have been covered by twelve inches of aggregate. The Section requests Duke Energy conduct an evaluation of the toe drain, determine and complete any repairs. This may include evaluation of the size of the aggregate stone within the toe drain and if it is sufficient. Please provide the evaluation, any additional communication on repairs, and photos to Sarah Moutos at Sarah.Moutos(adeq.nc. gov. 2. Performance Monitoring Protocol: o The Section requests Duke Energy ensure the required Settlement Agreement Condition #8, Performance Monitoring Protocol, was submitted to the Section. 3. Monitoring Wells: o The Section requests Duke Energy ensure Area 1 monitoring well pads, tags, and locks are installed and secure. 4. Inspection Protocols: o Erosion caused exposure of a significant amount of geonet that should have been covered by twelve inches of aggregate within the toe drain. The Section requests GARAA submit a revision of the approved March 2021 Operations and Management Plan (FID 1565311) stating proposals to help mitigate future problems of this nature. There were no violations observed. At this time, the Section will issue the Certificate of Closure once the above are addressed. The Section will be in touch to conduct an annual inspection in September 2024 of Areas 1, 3, and 4 and supporting documentation. Digitally signed by Sarah Moutos DN:cn=Sarahf EaA...= 1 Qality, Waste SeRion. ou=NC Department of Environmental Quality, Date: 20ar .06.13 tos 6.41 .0cgov, -US Phone: 919-707-8287 ...il=S.'.h. 1314:36:41 -04'°°' Sarah Moutos Environmental Program Consultant Sarah.Moutos(d),deq.nc. gov Page 2 of 3 NOFTIi CAPOLINAD_E Q�/�� D.p—t m e.m --1 Q..1 SITE VISIT REPORT Division of Waste Management Solid Waste Section 1. Looking west towards the airstrip 2. Edge of Cap Markers 3. 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