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Home My WebLink About1910-Charah_Brickhaven_20160418INSP.pdfFACILITY COMPLIANCE INSPECTION REPORT Department of Environmental Quality Division of Waste Management - Solid Waste Section UNIT TYPE: Lined MSWLF LCID YW Transfer Compost SLAS COUNTY: Chatham Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 1910-STRUC-2015 CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: April 18, 2016 Date of Last Inspection: January 11, 2016 FACILITY NAME AND ADDRESS: Brickhaven No. 2 1473 Moncure-Flatwood Road Moncure, NC GPS COORDINATES: N: 35.596 W: -79.010 FACILITY CONTACT NAME AND PHONE NUMBER: Glenn Amey, PG, Engineering Manager, Direct: 704-731-2202, gamey@charah.com FACILITY CONTACT ADDRESS: Green Meadow, LLC 352 Brickyard Road Sanford, NC 27330 (877) 314-7724 PARTICIPANTS: Shawn McKee, NCDEQ, Solid Waste Section Elizabeth Werner, NCDEQ, Solid Waste Section Shannon Aufman, NCDEQ, Solid Waste Section Glenn Amey, Charah, Inc. Jacob Buda, Charah, Inc. STATUS OF PERMIT: Permit to Construct and Operate issued June 5, 2015 This permit shall expire June 5, 2025 PURPOSE OF SITE VISIT: Comprehensive inspection. STATUS OF PAST NOTED VIOLATIONS: None. OBSERVED VIOLATIONS None. 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 also 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. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 5 ADDITIONAL COMMENTS The site is a lined coal combustion products structural fill permitted for mine reclamation in conjunction with NCDEQ DEMLR Mine Permit 19-25. 1. The structural fill permit, site plan, and operations plan were discussed during the inspection. The Permit to Construct and Operate was issued on June 5, 2015 and approves the operation of Cells 1 through Cell 5. The permit is subject to review by June 5, 2020. 2. According to the approved site operations plan, operations can occur 24 hours a day, 7 days per week. Solid Waste Section approval is needed if there is a change in operating hours. 3. A sign providing the facility name, permit number, operating hours, and emergency contact numbers is posted at the site entrance. 4. A responsible individual trained in operations must be on-site at all times during all operating hours. Training records were reviewed during the inspection. Leachate training occurred on September 4, 2015. Spill Prevention Control and Countermeasure (SPCC) Plan training and Waste Management training are required for all staff annually. 5. Financial assurance must be continuously maintained for the duration of the site operations and post closure care in accordance with §130A-309.221. The owner and operator must annually adjust cost estimates for inflation. Financial assurance documentation for the structural fill was reviewed during the inspection. The approved financial assurance includes $5,992,590 for closure, $2,208,000 for post-closure care, $2,000,000 for potential assessment and corrective action, and $65,000 for Departmental Costs to Respond to an Incident. 6. On or before August 1 annually, the Permittee must submit an annual facility report to the Section. Reporting shall be for the time period between July 1 and June 30. Records of the amount of CCPs received at the structural fill, are being compiled on a monthly basis and must be reported on the form specified by the Section. Scales are being used routinely to weigh the amount of coal combustion products received. 7. Independent background samples from each of the compliance groundwater monitoring wells and surface water sampling locations have been obtained and analyzed for constituents listed in Appendix III and IV in accordance with 40 CFR 257.94(b). Results have been submitted to the Solid Waste Section. Addition, during the first year of operation eight (8) independent samples from each of the compliance groundwater monitoring wells and surface water sampling locations are being sampled and analyzed for the Appendix III and IV constituents. The next sampling event is scheduled for May 17, 2016. 8. The structural fill began placing coal combustion products on October 23, 2015. At the time of the inspection, the structural fill was receiving approximately one train per day of coal combustion products (CCPs); approximately half coming each from the Duke Energy facilities of Sutton Steam Plant and Riverbend Steam Station (approximately 13 per month from Sutton and approximately 14 per month from Riverbend). 9. As of the date of the inspection, 450,968 tons of CCPs have been placed within the structural fill. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 5 10. At the time of the inspection, ash was being place in Subcells 1A and 1B. Construction had been completed on Subcell 1C. Approval to commence operations in Subcell 1C was issued by the Section on April 27, 2016. Subcell 1D is under construction. Ash being placed in Cell 1A & 1B Subcell 1C – Construction complete FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 5 11. Compliance groundwater monitoring wells, surface water locations and leachate monitoring ports shall be sampled semi-annually and analyzed for constituents listed in the approved Water Quality Monitoring Plan. A readily accessible unobstructed path shall be cleared and maintained so that four-wheel vehicles may access monitoring locations, at all times. Groundwater monitoring wells are well marked and protected from vehicular traffic by yellow bollards and flags. All groundwater monitoring wells are secured with locks. 12. The structural fill has an approved dust control plan. Water trucks are utilized to control road dust, as needed. Water trucks were not operating at the time of the inspection because intermittent rain was providing sufficient dust control. Dust control check occur daily at 9am and 2pm. Records from 1/1/16 to 3/31/16 were reviewed during the inspection. 13. Roadways are of all-weather construction. Where practicable, roadways are one-way to reduce vehicular conflicts. A wheel washing station has been installed to reduce migration of coal combustion products from truck traffic. 14. A rail-spur has been constructed to bring coal combustion products to the site by rail. Each train has up to 85 cars; each train will have the capacity to carry up to 8,500 tons of CCPs. Ash is conditioned to 18-20% moisture content prior to transportation. 15. Since March 9, 2016, all ash arriving at the site has been by rail. Rail unloading 16. No windblown dust from operations or roadways was noted during the inspection. 17. Coal combustion products must not be placed in standing water. Surface water must be diverted away from the operational area and must not be impounded over or in coal combustion products. Water that comes into contact with coal combustion products shall be handled as leachate. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 5 18. Two 500,000 gallon tanks have been installed onsite to hold leachate prior to offsite treatment. The leachate tanks were observed during the inspection. Tank levels are checked by onsite staff on a daily basis. During March 2016, a total of 613,698 gallons of leachate were pumped from the tanks. Leachate is taken offsite for treatment or used within the footprint of the lined cells for dust control. 19. Storm water from the rail unloading yard is sloped to drain into an approximately 400,000-gallon underground storage tank. The tank has the capacity to hold the run-off from a 25 year/24 hour storm event. This water will be used for dust control on the lined area of the structural fill. Please contact me if you have any questions or concerns regarding this inspection report. Phone: 919-707-8284 Environmental Senior Specialist Regional Representative Sent on: April 29, 2016 Email: X Hand delivery US Mail Certified No. [ _] Copies: Ellen Lorscheider, Section Chief, Solid Waste Section Ed Mussler, Permitting Branch Head, Solid Waste Section Jason Watkins, Field Operations Branch Head, Solid Waste Section Jessica Montie, Compliance Officer, Solid Waste Section