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3612_DukeAllen_INSP_20190123FACILITY 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: January 23, 2019 Date of Last Inspection: April 23, 2018 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), Randall.Harris@duke-energy.com Courtney Murphy, 704-718-7570, Courtney.Murphy@duke-energy.com FACILITY CONTACT ADDRESS: Same as above PARTICIPANTS: Shawn McKee, NCDEQ, Solid Waste Section Elizabeth Werner, NCDEQ, Solid Waste Section David Giachini, NCDEQ, Solid Waste Section Courtney Murphy, Duke Energy Steve Pulley, Duke Energy R. Scott Harris, Duke Energy Scott Nordgren, 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) No units were running at the time of the inspection. Weather conditions were in the mid-30s with rain and a light breeze. 4) 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 current elevation of the working area in cell 2B is approximately 651 ft. The total tonnage disposed of in the landfill between in 2018 was 51,586 tons. 5) 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. 6) Internal inspections of the landfill are performed weekly. These reports were reviewed during the inspection. 7) 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. Expected completion of the project is by the end of 1st quarter 2019. 8) 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. The facility also uses a remote wireless system which shows current levels and will alert staff if a vault has unexpected high levels of leachate or stormwater. 9) Leachate sampleing was performed on March 6, 2018 and September 4, 2018. The leachate lines were cleaned by Jet Clean America on August 20, 2018. Gunn Co Pump & Control Inc performed an annual inspection of the leachate pumping system on April 30, 2018. 10) All required quality assurance compaction testing (Field Density) appears to be complete. These records are maintained by Charah, Inc. 11) 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. 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 12) Facility has a spill prevention control and counter measures plan in place. 13) The annual operations plan training for the facility took place on August 2, 2018. 14) 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 Ben Hildebran Landfill Manager 15-02M-00151 12/3/21 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 present when the landfill is in operation. 15) 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. 16) 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. 17) 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. Dust is also remotely monitored by using security cameras located around the steam station property. Two water trucks are onsite to provide back up in the event that maintenance issues occur. 18) The access roads for the landfill are well maintained. The truck scales were tested and inspected by Charlotte Scale Co Inc on November 2, 2018. 19) 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. Active area of the landfill (Cell 2B) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 4 20) A gate was installed 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. 21) 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. South slope – slopes are well vegetated and being well maintained 22) Both the edge of waste and the edge of liner are identified with white PVC markers. 23) The perimeter stormwater ditches are free of exceisive sediments and are being well maintained. 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: 919-707-8284 Environmental Senior Specialist Regional Representative Sent on: 2/22/19 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 Larry Frost, Engineering Project Manager, Solid Waste Section Elizabeth Werner, Permitting Hydrogeologist, Solid Waste Section David Giachini, Permitting Engineer, Solid Waste Section