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��
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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
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-
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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. Toe drain with exposed geonetting
Page 3 of 3
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Attachment 3
Photo Documentation
Asheville Airport — Area 1 Structural Fill
Well MW-213-A1 pad uncovered on June 26, 2024