1910_Brickhaven_RiverbendPCB_RequestForInformation_DIN27751_20170320

March 20, 2017
Mr. Norman Divers
Charah LLC.
Post Office Box 287
Belmont, North Carolina 28012

RE: Report on CCP from Riverbend Steam Station, PCB notification.

Dear Mr. Divers,

This letter is the follow up to my email of March 15th, 2017. On Monday, March 13th Mr. Rob
Reynolds of Charah called me to notify the state that samples of coal ash from the excavation at
Riverbend had tested positive for polychlorinated biphenyl (PCB) albeit at levels less than 1
ppm. Charah filed, at my request, an incident report and supplied the lab results in question on
March 15, 2017.

Duke Energy is providing the sampling of the material being excavated. The lab report Charah
supplied with the incident report indicated that the samples were prepared and tested using
EPA’s SW 846 method 3546 (microwave extraction). The coal combustion products (CCP) are
shipped by rail to the Charah structural fill in Brickhaven, Chatham County. Mr. Reynolds
indicated that no previous samples had detected PCB’s. He stated that all shipments had been
temporarily suspended and that further testing was occurring out in front of the excavation.

PCB is regulated under the Toxic Substance and Control Act (TSCA). On March 14th I spoke
with Mr. Ken Feely of the US EPA, Region IV, Atlanta, GA. Mr. Feely is the EPA Team Lead
for TSCA and has experience with implementing and enforcing PCB regulations under TSCA.
Mr. Feely confirmed that the level for unrestricted use of soil from PCB remediation waste was
less than 1 ppm.

At this time is has not been determined what type of PCB material we are dealing with. It could
be a regulated waste or a remediation waste. The determination is complex and dependent on
several factors including age and origin of the PCB material. Should test results indicate possible
PCB contamination that exceeds 1 ppm, then further discussions about the appropriate
disposition of the material will need to be held.

Mr. Norman Divers
March 20, 20-17
Page 2

Any material testing higher than 1 ppm should not be sent to the structural fill project in
Brickhaven. It should be segregated and held for final determination.

After review of the incident report and accompanying testing reports I notified Charah, by email,
of our concurrence and the approval for resumption of shipment of CCP to Brickhaven. I also
provided the report and tests to Mr. Feely.
The Solid Waste Section requests additional information from Charah; Please provide:
 A description of the original testing protocol including frequency, lab method of
extraction and analysis, and total number of tests performed to date.
 A description of the revised testing protocol including frequency, lab method of
extraction, and analysis.
 An estimation of the amount of material removed to Brickhaven to date and the amount
of material remaining that is scheduled to go to Brickhaven.
 The contact information for a Duke Energy representative that can speak to the history of
the PCB’s at this facility.
Upon review of this information, it is likely we will request the appropriate parties enter into
discussions with the goal of determining what type of material this would be, waste or product,
should test levels exceed the unrestricted use levels of 1 ppm and verify the appropriate test
methods to be using, as well as specify the alternative handling scenarios, should they become
necessary.
If you have any questions, please contact me. My phone number is 919-707-8281 and my email
address is [e-mail]./ Thank you for your cooperation in this matter.

Sincerely,

Edward Mussler, Permitting Branch Supervisor
Solid Waste Section
Division of Waste Management

Cc: Rob Reynolds, Charah
Larry Frost, DWM
Shannon Aufman, DWM
Ellen Lorscheider, DWM