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HomeMy WebLinkAbout8504_DukeBelews_INSP_20190319FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section UNIT TYPE: Lined MSWLF LCID YW Transfer Compost SLAS COUNTY: Stokes Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 8504-INDUS- CDLF Tire T&P / Collection Tire Monofill Industrial Landfill X DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: March 19, 2019 Date of Last Inspection: October 16, 2018 FACILITY NAME AND ADDRESS: Craig Road Ash Landfill Duke Energy Carolinas, LLC Belews Creek Steam Station 3195 Pine Hall Road Belews Creek, North Carolina 27009 GPS COORDINATES: N: 36.27908 W: -80.05890 FACILITY CONTACT NAME AND PHONE NUMBER: Melonie Martin, Environmental Coordinator, O: 336-445-0610, C: 336-669-2994, melonie.martin@duke-energy.com FACILITY CONTACT ADDRESS: Duke Energy Carolinas, LLC Belews Creek Steam Station 3195 Pine Hall Road Belews Creek, North Carolina 27009 PARTICIPANTS: Shawn McKee, NCDEQ Elizabeth Werner, NCDEQ David Giachini, NCDEQ Melonie Martin, Duke Energy Evan Andrews, Duke Energy Jeff Gateley, Duke Energy Michael Cowart, Duke Energy Henry Taylor, Duke Energy STATUS OF PERMIT: Notification of Site Suitability Issued: May 12, 2006 Original Permit to Construct Issued: June 20, 2006 Original Permit to Operate, Phase 1 Issued: November 5, 2007 Permit to Operate, Phase 1 Renewal and Vertical Expansion Issued: August 5, 2011 Notification of Site Suitability, Phases 2-6 Issued: November 15, 2011 Permit to Construct, Phase 2 Issued: May 18, 2012 Permit to Operate, Phase 2 Issued January 16, 2014 Permit to Operate Issued November 28, 2017 The Permit to Operate shall expire: November 5, 2067 PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: None FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 2 OBSERVED VIOLATIONS None ADDITIONAL COMMENTS The Craig Road Landfill is permitted to receive: "Coal combustion residuals" …, including fly ash, bottom ash, boiler slag, mill rejects, and flue gas desulfurization residue produced by a coal-fired generating unit destined for disposal”. The landfill is primarily utilized for the disposal of ash generated by the Belews Creek Steam Station. Operations at the facility began in February 2008. 1. The facility is permitted to operate 24 hours a day, 7 days a week. The facility is in operation on an as needed basis. Operations occur infrequently outside of daylight hours. 2. The approved Operations Plan (listed in Section 2.1.2) allows for the disposal of coal combustion by-products, gypsum produced by the flue gas desulfurization (FGD) process, waste water treatment sludges produced by the flue gas desulfurization process, waste limestone materials, boiler slag, sand blast materials, fixated FGD waste, and other coal waste generated by the Belews Creek Steam Station. 3. 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. o Annual internal training on the Belews Creek Landfill Operations Plan was last conducted 10/3/2018. o The following Charah, Inc. personnel are NC Certified Landfill Managers:  Andrew Reising, Certification #14-02M-00116, exp. 7/23/2020  Brandon Garrison, #16-02M-00162, exp. 5/20/2019  Janet Harvey, #17-02M-00307, exp.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. 4. The facility has a current Division of Air Quality, Title V Permit. Permit #01983T32 was issued January 30, 2018 and expires January 31, 2022. 5. 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 $10,832,266 for closure, $2,657,153 for post-closure care, and $2,000,000 for potential assessment and corrective action. 6. For the period between 2/20/18 and 3/17/19, the facility landfilled 104,628 tons. For the annual reporting period July 1, 2017-June 30, 2018 the facility landfilled 98,403 tons of CCRs. 7. Coal ash density records were reviewed during the inspection. Density testing is completed on a quarterly basis. Density testing records for the last 12 months appear complete. 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 8. The facility conducts weekly internal inspections of the active landfills which were reviewed during the inspection. Any deficiencies noted during these inspections are corrected. 9. The approved Operations Plan (Section 2.7) does not require detection monitoring for methane and hydrogen sulfide gas. The facility previously monitored for these constitutes and the last monitoring event of May 2012 detected no methane or hydrogen sulfide. 10. During the inspection, the semi-annual ground water, surface water and leachate monitoring reports for the sampling events conducted January 15, 2018 and July 23, 2018 were reviewed. Sixteen ground water wells and six surface water locations were monitored. 11. Unit 1 was operating at the time of the inspection but Unit 2 was offline. No ash was being disposed of during the inspection in the landfill. 12. The following concerns were noted for the monitoring wells observed during this inspection:  2R - Needs new sign  3R - Needs new sign  7R - Needs new sign  8RA - Needs new sign & well tag  9R - Needs new sign  10R - Needs new sign  11R - Needs new sign  12R - Needs new sign & well tag  17R - Needs new sign & well tag *Wells with an “R” designation were replaced in July 2017 due to historic high turbidity. 13. Leachate and contact water generated by the facility is collected as per approved Operations Plan (Sections 2.2 and 2.3) and discharged into the Lined Retention Basin (LRB). The LRB is currently discharging to the Belews Creek Steam Station Ash Basin while an NPDES permit is pending. 14. The leachate force main over the bridge between the landfill and power plant has been modified such that now has dual containment with heat tracing. 15. Leachate lines for the landfill were inspected on 11/30/18 by Jet Clean America. No blockages were noted. Routine cleaning of the leachate systems helps maintain proper flow. 16. Facility access roads are of all-weather construction and are well maintained. 17. Water trucks are utilized to control road dust, as needed. Water trucks were operating at the time of the inspection. Dust control checks occur daily at 9am and 2pm. Records from the previous 12 months were reviewed during the inspection. Craig Road Landfill dust control records are well maintained and appear complete, no unaddressed issues noted. 18. Operational cover is being maintained as approved in the facility Operations Plan (Section 2.1.8.1 and Appendix I, Dust Control Plan). Minimal soil is utilized for cover; landfilled materials are moistened and allowed to crust over to prevent windblown material. EcoGreen is used as needed to aid in the process of crusting. 19. Chimney drains have been installed to facilitate leachate drainage into the collection system. They appeared well maintained at the time of the inspection. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 4 Active area of landfill. Tack-on benches under construction on Phase 1. 20. The Solid Waste Section was notified on October 15, 2018, that a small area of the northern slope of Phase 1 of the landfill had failed on October 14, 2018 due to rains from Tropical Storm Michael. Investigation into the failure revealed that a slope drain had decoupled allowing storm water to create a void on the slope. During the Sunday, October 14 post-storm inspection, coal combustion residual material was found in the perimeter ditch and some ash migrated under the haul road to non-contact storm water basin. Clean up and repairs were completed on October 16. The tack-on benches currently being constructed are designed to reduce future erosion and slope failure problems in Phase 1. 21. Side slopes and inactive areas have soil cover and established vegetation. Side slopes were well vegetated and are being well maintained. Vegetative growth on side slopes and facility property are mowed regularly every 4 to six weeks or as needed during the growing season. No on-site or off-site erosion observed. 22. Cotton rat populations at the landfill have been controlled. Cotton rats had infested the slopes of the landfill and were a food source for coyotes which were digging into the slopes to excavate rat nests. 23. No windblown dust from landfill operations or roadways was noted during the inspection. Weather conditions during the inspection sunny and dry. Please contact me if you have any questions or concerns regarding this inspection report. _ Phone: 919-707-8284____ Environmental Senior Specialist Sent on: March 26, 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 Larry Frost, Engineering Project Manager, Solid Waste Section Elizabeth Werner, Solid Waste Section Ben Jackson, Solid Waste Section David Giachini, Solid Waste Section