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HomeMy WebLinkAbout7906_Duke_DanRiver_Area1DebrisRemoval_DIN26851_20161013Andrew Shull Duke Energy 410 S. Wilmington Street NCRH 15 Raleigh, NC 27601 o: 919.546.2104 c: 919.946.5835 October 13, 2016 Ms. Elizabeth Werner North Carolina Dept. of Environmental Quality Waste Management Division 1646 Mail Service Center Raleigh, NC 27699-1646 Subject: Duke Energy Dan River Steam Station – Debris Removal Dear Ms. Werner: Per your recent conversation with Duke Energy personnel, debris was recently encountered during coal residual removal activities within the former Ash Stack #1 at the Duke Energy Dan River Steam Station. This letter outlines our proposed approach for removal and disposal of this debris and soil. On September 22nd, debris consisting of household garbage (glass, plastic, etc) and general construction debris (metal pieces, wire, tile, shingles, etc) was discovered at the eastern edge of the former Ash Stack #1. After the discovery of fibrous tile and shingles, the material was tested and returned positive laboratory results for asbestos. Due to the presence of asbestos- containing materials (ACM), a plan was developed to safely handle and remove the materials in coordination with the North Carolina Division of Public Health – Health Hazards Control Unit. The material was also tested by TCLP methods for Volatile Organic Compounds (VOCs), Semi- volatile Organic Compounds (SVOCs), Polychlorinated Biphenyls (PCBs) and metals. The only detections in the analyses were metals, with lead at a TCLP concentration of 5.7 mg/L. We currently estimate that approximately 50 to 300 tons of debris and impacted soil exist in the Ash Stack #1 area, which we are proposing to remove. Our goal is to remove the material in the most effective way possible, given the ACM, while not changing the station’s small quantity generator (SQG) status for this one-time event. In order to achieve this, we propose to stabilize the material with Enviroblend and then transport and dispose the material to a non-hazardous waste landfill after laboratory analysis confirms favorable TCLP lead results. Additional details on our proposed Enviroblend approach are listed below:  The Enviroblend will be shipped to the site in 1 ton super sacks and will be added to the soil at a 3-5 % ratio based on a volumetric estimate (roughly 1 supersack per 18 cubic yards or 25 tons).  The Enviroblend will be incorporated into the soil via excavator bucket mixing, and would be mixed ex-situ immediately adjacent to the excavation in a temporary stockpile.  Once the material has been properly mixed/stabilized it will be loaded into roll-off containers. An additional composite TCLP sample will be collected from each roll-off container to confirm that lead has been effectively stabilized, and the TCLP concentration is below 5 mg/L.  Upon completion of the debris removal and any necessary over-excavation, confirmation samples will be collected from the sidewalls and base of the excavation. We are planning to implement this scope of work on Monday, October 17, 2016, to remain on schedule for ash removal efforts. Duke Energy appreciates your time to review and provide feedback on our proposed approach. If you have any questions or concerns regarding the project or approach, please contact me at 919-546-2104. Sincerely, Andrew W. Shull, P.E. Sr. Environmental Specialist