Duke_Allen_3612_INSP_20180423INSP

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost SLAS COUNTY: Gaston
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 3612-INDUS-2008
CDLF Tire T&P /
Collection Tire
Monofill Industrial
Landfill X DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: April 23, 2018 Date of Last Inspection: June 19, 2017

FACILITY NAME AND ADDRESS:
Duke Energy, Allen Steam Station – Retired Ash Basin (RAB) Landfill
253 Plant Allen Road
Belmont, NC 28012

GPS COORDINATES: N: 35.18295 W: -81.00979

FACILITY CONTACT NAME AND PHONE NUMBER:
Randall Scott (Scott) Harris, 704-829-2629 (o), [e-mail]
Courtney Murphy, 704-718-7570, [e-mail]

FACILITY CONTACT ADDRESS:
Same as above

PARTICIPANTS:
Shawn McKee, NCDEQ, Solid Waste Section
Elizabeth Werner, NCDEQ, Solid Waste Section
Larry Frost, NCDEQ, Solid Waste Section
Courtney Murphy, Duke Energy
R. Scott Harris, Duke Energy
Courtney Murphy, Duke Energy
Scott Nordgren, Duke Energy
Julie Robertson, Duke Energy
Ron Cobb, Duke Energy
Ryan Czop, Duke Energy
Jeremy Pruitt, Duke Energy
Randy Gantt, Duke Energy

STATUS OF PERMIT:
Permit to Construct: issued 9/2/2008
Original Permit to Operate: Phase 1, Cells 1, issued 12/9/2009
Permit to Operate: Amendment – 5 Year Renewal, issued 12/9/2014
Permit Expires: 12/09/19

PURPOSE OF SITE VISIT:
Comprehensive Inspection

STATUS OF PAST NOTED VIOLATIONS:
None.

OBSERVED VIOLATIONS
None.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 2

ADDITIONAL COMMENTS
The facility is an industrial landfill permitted to receive combustion products / residuals consisting of fly ash, bottom
ash, boiler slag, mill rejects and flue gas desulfurization (FGD) residue generated by Duke Energy Carolinas, LLC. The
Permit to Operate shall expire December 9, 2019. A request for permit review must be submitted to the Section no later
than June 9, 2019.

1) The facility permit, site plan, and operations plan were discussed during the inspection. The retired ash basin
(RAB) landfill is located within the footprint of an older, closed RAB for the Allen Steam Station. The older,
closed RAB has not been in use since the 1970’s.

2) The retired ash basin (RAB) landfill has been constructed on top of two engineered structural fills (identified
as CCB0020 and CCB0073 in Section records) which were built in accordance with NCAC 13B .1700.
Currently, there are not any construction or expansion plans for the landfill.

3) Ash is currently being placed in Cell 2B of Phase 1. Cells 1 and 2A have been covered and are well vegetated.
Nearly all of the ash being landfilled is fly ash. Other materials include FGD gypsum that does not meet
specifications for reuse and waste water treatment sludge. The total tonnage disposed of in the landfill between
January 1 and March 31, 2018 is 23,152.22 tons. A total of 64,224 tons were landfilled in 2017.

4) Nearly all of the FGD gypsum being produced by the Allen Steam Station is sent offsite for the manufacturing
of wallboard rather than landfilled. Only off-spec gypsum is landfilled.

5) Internal inspections of the landfill are performed weekly. These reports were reviewed during the inspection.

6) The leachate collection system records are current and complete for the last 12 months, no issues found. A new
leachate force main will be installed to move leachate to the combined sump. The facility was asked to provide
as-built drawings to the Solid Waste Section upon completion.

7) A weekly system check is performed on the leak detection alarm system. Logs from the leachate system were
reviewed during the inspection. The leak detection system records are current and complete for the last 12
months, no issues found.

8) Leachate sampleing was performed on March 8, 2017 and September 12, 2017.

9) All required quality assurance compaction testing (Field Density) appears to be complete. These records are
maintained by Charah, Inc.

10) The Emergency Response Plan was reviewed during the inspection. The contact information for the DEQ
Raleigh Central Office needs to be updated when the Operations Plan is updated during the next permit review.

11) Facility has a spill prevention control and counter measures plan in place.

12) The annual operations plan training for the facility took place on August 17, 2017.

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 3 of 3

13) The following Charah, Inc. personnel are NC Certified Landfill Managers:
Name Certification Certificate Expiration Date
Chris Emory Landfill Manager 13-02M-00079 7/24/19
Steve Faussete Landfill Manager 14-02M-00114 7/24/20
Richard Smith Landfill Manager 15-02M-00137 4/22/18
Mark Hancock Landfill Manager 17-02M-0032 6/15/20

Additional Duke Energy personnel are certified but not listed on the report. Charah personnel are responsible for
landfill operations; certified staff are always present when the landfill is in operation.

14) Financial assurance documentation for the facility was reviewed during the inspection. The financial
assurance was submitted by Duke Energy Carolina on March 26, 2018. The approved financial assurance
includes $3,537,902 for closure, $1,520,112 for post-closure care, and $2,000,000 for potential assessment
and corrective action.

15) Chimney drains have been installed on the top of Cell 2 of Phase 1 to collect and direct precipitation that
contacts the coal ash to the leachate collection system. Chimney drains are being well maintained.

16) Dust is being well controlled at the landfill. Dust control records were reviewed during the inspection and were
complete. Personnel filling out dust records should be reminded to be as consistent as possible for clarity.

17) The access roads for the landfill are well maintained.

18) An additional gate has been added on the haul road at the toe of the landfill for additional security while the
landfill is not operating. A manned gate limits unauthorized access to the facility at the main entrance to the
Allen Steam Station.

19) Both the edge of waste and the edge of liner are identified with white PVC markers.

Active area of the landfill (Cell 2B)
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 4

20) The northern, western and southern side slopes of the landfill are sloped at a 3 to 1 ratio and have an established
vegetative cover. Over seeding and fertilization occurs as needed to repair any erosion or bare spots on the side
slopes.

21) The active area of the landfill is being well maintained. Vegetated berms surround the uncovered ash to help
direct contact water into chimney drains and prevent ash from migrating down side slopes.

22) The perimeter stormwater ditches are free of exceisive sediments and are being well maintained. The ditches
at the toe of the southern slope have been reworked.

Please contact me if you have any questions or concerns regarding this inspection report. The sediment basin on the
south side of the landfill is operating as designed.

Phone: [phone]

Environmental Senior Specialist
Regional Representative

Sent on:
5/21/18
Email:
X
Hand delivery US Mail Certified No. [ _]

Copies: Ed Mussler, Section Chief, Solid Waste Section
Jason Watkins, Field Operations Branch Head, Solid Waste Section
Elizabeth Werner, Permitting Hydrogeologist, Solid Waste Section
Larry Frost, Engineering Project Manager, Solid Waste Section