HomeMy WebLinkAbout1910_Brickhaven_PCBIncidentReport_DIN27754_20170306
Environmental Report
Date:
03‐06‐2017 Time: 1300
Facility Name:
Riverbend Ash Basin to Brickhaven Structural Fill
Facility Location (Address/Lat-
Long/Section Township Range) Gaston / Chatham County, NC
Name of reporting individual:
Norman Divers Telephone #:
502‐475‐0725
Type of material involved Coal Combustion
Products (CCPs)
Estimated total quantity
released: 0
Units (Gallons, Tons, etc.)
17,103 tons
Source of Material Involved: Riverbend Steam Station
Primary Ash Basin
Media affected: Soil
Water (specify)
Other (specify)
CCPs
Description: On Monday, 3/6/17, Duke Environmental informed Charah of a specific CCP sample
taken on 2/14/17 indicating a PCB level of 0.079 mg/kg (.079 ppm). In addition, Duke
shared that sampling had been conducted since May 2015 with no previous samples
indicating detectable PCBs. Charah discussed potential implications with Duke to
ensure they understood permit conditions related to PCB containing materials. Rail
loading and shipments were initially halted while Charah evaluated the information
provided.
On Thursday, 3/9/17, a second Duke sample taken on 3/2/17 indicated a PCB level of
0.48 mg/kg (0.48 ppm). Confirmation of the presence of PCBs in two train loads were
confirmed.
Charah determined the CCPs associated with these two sampling events were loaded
and transported to Brickhaven on Train RB194 that departed Riverbend on 2/14
containing 8,197.85 tons and Train RB206 that departed on 3/5 containing 8,905.15
tons:
State and Federal regulations provide the following:
1. PCB Contaminated Materials defined by 40 CFR 761 mean a non‐liquid
material containing PCBs at concentrations ≥50 ppm but <500 ppm; a liquid
material containing PCBs at concentrations ≥50 ppm but <500 ppm or where
insufficient liquid material is available for analysis, a non‐porous surface
having a surface concentration >10 µg/100 cm 2 but <100 µg/100 cm 2,
measured by a standard wipe test as defined in § 761.123.
2. Under the NC Solid Waste Rules as identified in 15A NCAC 13B .1626 (1) (b)
(ii) Polychlorinated biphenyls (PCB) wastes as defined in 40 CFR 761.
3. Under the Coal Ash Management Act of 2014 (CAMA), § 130A‐309.201. (4)
Coal Combustion Products (CCPs) means fly ash, bottom ash, boiler slag, or
flue gas desulfurization materials that are beneficially used, including use for
structural fill.
4. Under TSCA, soils containing PCBs less than 1 ppm are unregulated and can
be placed as clean fill, left in place without notice. To be completely
unregulated for disposal off‐site without an approval from EPA, waste must
contain <1 ppm, and that concentration must not be the result of dilution
during remediation.
Notification to the State was attempted on Friday, 3/10 but did not actually occur until
Monday, 3/13. The following was discussed on that call:
1. Charah was recently informed that two samples of ash from Duke’s
Riverbend facility exhibited PCBs below one part per million.
2. Under the EPA’s PCB cleanup policy, the ash exhibiting less than one part per
million of PCBs is treated as clean soil. (Ref.: 40 CFR 761.125.)
3. Charah has elected to treat this material as clean and place it as structural fill
in accordance with our structural fill permit, unless otherwise directed by the
State.
4. Moving forward, Charah will require Duke to verify all ash from Riverbend
contains less than one PPM of PCBs prior to shipping to Brickhaven.
Operations currently on hold waiting for the State to make their determination of our
findings.
Actions taken: 1. Ceased shipments of CCPS from Riverbend to Brickhaven until stockpiled ash
could be confirmed to be PCB free through additional laboratory testing.
2. Documented the laboratory test results and findings.
3. Notified the State to discuss the findings and means of moving forward.
4. Established a proactive CCP sampling protocol with Duke to ensure future
CCPs transported to Brickhaven would not have a PCB concentration greater
than 1 ppm.
Damage or injuries:
No Yes (specify)
None
Evacuation needed?
No Yes (specify)
None
Organizations and individuals
contacted: National Response Center 800-424-8802 Time
Cleanup contractor (Specify) Time
Facility personnel (Specify) Time: Riverbend and Brickhaven teams were notified
on 3/7 at 0941.
State Agency (Specify) Time: Contact attempted on Friday, 3/10 at 1630.
Notification was achieved on Monday, 3/13 at approximately 1000.
Other (Specify) Time
*No pictures taken. Laboratory test results attached for review.
Signature: Date: 3/14/2017