8106_DukeRogers_INSP_20190122

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 5

UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost SLAS COUNTY: Rutherford
Closed
MSWLF HHW White
goods Incin T&P FIRM PERMIT NO.: 8106-INDUS-2009
CDLF Tire T&P /
Collection Tire
Monofill Industrial
Landfill X DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: January 22, 2019 Date of Last Inspection: April 23, 2018

FACILITY NAME AND ADDRESS:
Rogers CCP Landfill
James E Rogers Energy Complex (Formerly Cliffside Steam Station)
573 Duke Power Road
Mooresboro, N.C. 28114
[phone]

GPS COORDINATES: N: 35.20534 W: -81.76547

FACILITY CONTACT NAME AND PHONE NUMBER:
Patrick Dunn, 980-373-1164, [e-mail]
Ryan Czop, 980-373-2779, [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
David Giachini - NCDEQ, Solid Waste Section
Patrick Dunn - Duke Energy
Ryan Czop - Duke Energy
Scott Saunders - Duke Energy
Chuck Cranford – Duke Energy
Scott Nordgren – Duke Energy

STATUS OF PERMIT:
Permit to Construct, Phase I, issued 6/4/2009
Permit to Operate, Phase I, issued 9/7/2012
Permit to Construct, Phase II, issued 9/17/2012
Permit to Construct, Phase II modification, issued 3/19/2014
The Permit to Operate, Phase II, Modification issued June 13, 2016 shall expire September 7, 2020
The Permit to Construct, Phases III and IV are being prepared by Wood. The Section expects submission in
February 2019.

PURPOSE OF SITE VISIT:
Comprehensive Site 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 "Coal combustion residuals" including (but not limited to) fly ash,
bottom ash, boiler slag, mill rejects, and flue gas desulfurization residue produced by a coal-fired generating unit destined
for disposal generated by any Duke Energy Corporation facilities, as well as geotextiles used in the management of coal
combustion products, and vacuum truck waste. The Permit to Operate shall expire September 7, 2020.

1) The facility permit, site plan, and operations plan were discussed during the inspection. Routine operations
occur during daylight hours (usually from 7am – 3pm or later as needed).

2) The facility is operated by Charah, Inc. which is responsible for hauling materials to the landfill, daily
operations of the landfill, and conducting other associated activities. Charah, Inc. personnel are responsible for
daily landfill operations; certified staff are always present when the landfill is in operation. Annual Landfill
Operation Plan Training occurred on April 19, 2018.

The following Charah personnel are NC Certified Landfill Managers:

Walter Fox, NC Manager of Landfill Operations, 13-02M-00092, expires 9/20/19
Chris Emory, NC Manager of Landfill Operations, 13-02M-00079, expires 7/24/19
Charles Bridges, NC Certified Landfill Manager, 17-02M-00306, expires 6/15/20
Camron Smith, NC Certified Landfill Manager, 16-02M-00197, expires 10/14/19
Sam Byrd, NC Certified Landfill Manager, 13-02M-00093, expires 9/20/2019
Ronald Ramey, NC Certified Landfill Manager, 18-02M-00393, exp. 9/6/2021

3) The leachate collection system consists of a geocomposite drainage layer and pipe network to convey leachate to
sumps located in each landfill cell. Leachate is pumped from the landfill sumps to a lined leachate basin. From
the basin, the leachate is pumped to an existing plant NPDES permitted ash basin located to the northeast of the
landfill and is incorporated into the plant’s treatment system.

Records of the liquid levels in the leachate collection system were not available at the time of the inspection but
were subsequently electronically sent to the Solid Waste Section. Readings are currently being recorded on a
weekly basis. Given that § 130A-295.6. (h)(2) states A leachate collection system shall be designed to return the
head of the liner to 30 centimeters or less within 72 hours. The design shall be based on the precipitation that
would fall on an empty cell of the sanitary landfill as a result of a 25-year-24-hour storm event.... The Department
may require the operator to monitor the head of the liner to demonstrate that the head is being maintained in
accordance with this subdivision and any applicable rules.

The Section recommends the following updates to the recordkeeping:

 LCS records are hand written; recording them electronically would improve legibility. The facility should
create a comprehensive electronic spreadsheet for the data collected in the last 12 months, for the landfill
operation Phases 1, 2, leachate basic and any other pertinent leachate information. The presentation of
data should be easily understandable or explained in a comments section. The spreadsheet currently being
used at Mayo, which includes levels, flows, etc., would be a good template.

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

 Records should clearly indicate the leachate level on the liner in addition to the total depth of liquid
recorded in the sumps.

 Time between recorded readings should be no more than 72-hours to demonstrate that the head on the
liner is being maintained below statutory requirements.

4) The camera inspection of the LCS was completed 7/26/2018, issues were noted.

5) Weekly logs of rainfall events and landfill inspections for erosion & sediment problems were reviewed during
the inspection. Permit dated 3/16/2009.

6) Dust control records were reviewed during the inspection. They were well organized and appeared to be
complete.

7) The facility has an active stormwater permit which expires on 9/30/2020. Self-inspections are up to date.

8) Monthly density records were reviewed during the inspection. They were well organized and appeared to be
complete.

9) Vacuum Truck records were reviewed during the inspection. They were well organized and appeared to be
complete. No issues were noted.

10) Between January 1, 2018 and December 31, 2018, a total of 45,309.37 tons were landfilled in Phase I and
267,275.08 tons were landfilled in Phase II. The top of Phase 1 is currently being used for FGD storage (per
Section approval). A net of 7,640.28 tons were added to Phase I during 2018 and 36,777.72 tons were
reclaimed to be used in wallboard manufacturing. Phases 3 and 4 are have a tentative construction date in 2019
pending a Permit to Construct.

11) No ash was being received from other facilities at the time of the inspection. Unit 5 was not operating at the
time of the inspection. Unit 6, which is duel fuel unit next fall (gas and coal), was operating using coal.

12) Basin 1-4 – excavation is complete and wastewater treatment and retention basin system is nearing completion
where the basins were previously located.

13) 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
$4,847,922 for closure, $1,995,161 for post-closure care, and $2,000,000 for potential assessment and
corrective action.

14) Samples from groundwater monitoring wells MW-1S, MW-1D, MW-2S, MW-2D, MW-3S, MW-3D, TW-1S,
TW-1D and TW-2 are collected semi-annually and analyzed for the Appendix I constituent list. Surface water
samples are collected from two locations (SW-1 and SW-2) from Suck Creek which is south of the landfill.
Sampling was last performed on October 16, 2017 and April 24-25, 2018.

15) The edge of waste is identified with permanent markers which are yellow and are being well maintained. The edge
of liner markers on the outside perimeter of the landfill are on the top of the perimeter berm, 6.5-ft. outside of the
actual edge of waste. Edge of waste markers are placed on top of the interior berms that separate each of the cells.

16) The perimeter stormwater ditches are free of exceisive sediments and are well maintained.

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

18) There was no evidence observed during the inspection of any leachate seeps or breakouts on the landfill.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 4

Vegetation on the side slopes of the landfill was well established and was being well maintained.

19) The top of Phase 1 (gypsum storage) appears to have had no attention since the last rain event. Regular inspection
of Phase I, repairs to erosion riles, chimney drain surroundings, dust control, should be done routinely.

20) Phase 2 (active ash area) appears to be well maintained. Dust is being well controlled in the active areas of the
landfill. Water trucks not in use at the time of the inspection because it was actively raining.

Active waste placement in Phase II. Bottom ash berms surrounding chimney drain.

21) Trucks leaving the landfill wash exit through a wheel wash manned by staff using powerwashers to remove ash
from the sides of the trucks.

22) There was no evidence of significant ponded water on the landfill though recent rain was still evident. Grading
in all active areas appeared to be sloped towards the chimney drains and into the leachate collection system.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 5

Please contact me if you have any questions or concerns regarding this inspection report.

_ Phone: [phone]
Shawn McKee
Environmental Senior Specialist
Regional Representative

Sent on: February 11, 2019 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
David Giachini, Engineering Project Manager, Solid Waste Section