7906_Duke_DanRiver_ResponseProtectiveCoverLinerDemo_DIN27490_20170310

ROY COOPER
Governor

MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
State of North Carolina | Environmental Quality | Waste Management
Asheville Regional Office | 2090 US Highway 70 | Swannanoa, North Carolina 28778
828 296 4500 T

March 10, 2017

Ms. Melonie Martin, Lead Environmental Specialist
Duke Energy Corporation
3195 Pine Hall Road
Belews Creek, North Carolina 27009

Subject: Utilization of 1.06-ft of Sand as Cell 1 Protective Cover, Request for Additional
Information
Permit No. 7906-INDUS-2016, Duke Energy Dan River Steam Station
Rockingham County, DIN 27490

Dear Ms. Martin:
On March 1, 2017 the Division of Waste Management, Solid Waste Section (Section) received a
proposal from Amec Foster Wheeler entitled;
Dan River Landfill (Permit No. 7906-INDUS-2016), Utilization of 1.06-ft of Sand as Cell 1
Protective Cover, Duke Energy – Dan River Steam Station, Eden, North Carolina, Amec Foster
Wheeler Project No. 7810170870. Prepared by Amec Foster Wheeler. Prepared for Duke Energy
(Duke). DIN 27477. March 2017.
The request concerns a demonstration project for utilizing 1.06-ft of sand as protective cover for
Dan River Landfill Cell 1 at Duke Energy’s Dan River Steam Station, including proposed
methods and requirements. The purpose of this demonstration is to;
 Request a permit modification to the approved permit to construct for the replacement of
two (2) feet of CCR with one (1) foot of sand.
 And propose a method to conclusively demonstrate that Duke Energy can safely
(protective of public health and the environment) construct a landfill utilizing one (1) foot
of protective cover.
The Section has reviewed Duke Energy’s request and has determined that additional information
will be needed in order to receive Section approval. The following concerns must be addressed;
 The proposed permit modification/demonstration does not include; modeling that
indicates what the effects that the change of materials may have on the design of the
leachate collection system and an engineering evaluation/determination of adequacy of
the installed liner system with regards to the change in protective cover.
 The post-construction demonstration of liner integrity lacks substance. The demonstration
does not; rule out the possibility of damage to the liner system, identify the location of
possible damage to the liner system, address the possible causes of damage, and propose
repair to possible damage of the liner system prior to operation.

Duke Energy, Dan River
March 8, 2017
DIN 27490
Page 2 of 2
Finally, a permit to construct modification for the use of sand rather than CCR is required, with
appropriate plans and specifications prior to installation. The demonstration for reduction in
protective cover requires the application of leak detection technology as a post-construction
demonstration of liner integrity. Should you have any questions regarding this matter you may contact
me at [phone] or at [e-mail].

Sincerely,

Larry Frost, Engineering Project Manager
Permitting Branch, Solid Waste Section
Division of Waste Management, NCDEQ

ec: Ed Mussler – SWS/RCO
Shannon Aufman – SWS/RCO