CCB0035_DukeUniversity_NoViolationCoverLetter_20200124

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
Sent via email to: [e-mail]
John Noonan, Vice President
Facilities Management Department
Duke University
114 S. Buchanan Blvd.
Box 90144
Durham, NC 27708-0144
NORTH CAROLINA
Environmental Quality
January 24, 2020
SUBJECT: Structural Fill Inspection and Maintenance Reminder
Duke University West Campus
Coal Combustion By -Products Structural Fill CCB0035
Durham County
Dear Mr. Noonan:
On December 6, 2019, Davy Conners, representing the Solid Waste Section (Section), inspected
property containing the closed Duke University West Campus structural fill site, CCB0035, located at
308 Research Drive, Durham, NC, in Durham County. The structural fill on this property was
constructed under the rules codified in 15A NCAC 13B Section .1700. On March 16, 1992, Duke
University submitted written notice to DEQ of the use of coal combustion furnace ash from the Duke
University Steam Plant as structural fill in the foundation of the Science Research Center on the West
Campus of Duke University. In this letter, it was estimated that four to five thousand tons would be
used for this project.
During the inspections, it was observed that the site had the Science Research Center building on it.
No exposed ash was observed.
Attached is a copy of our site inspection report providing additional information.
Owners of properties containing closed structural fills are responsible for the care and maintenance
of the fill in a manner to ensure protection of the public health and environment. 15A NCAC
13B .1705(a) states in part that structural fills must be "maintained in such a manner as to minimize
the potential for harmful release of constituents of coal combustion by-products to the environment
or create a nuisance to the public."
One of the most effective ways to minimize releases and/or nuisance conditions is to maintain the
approved cap system over the fill in accordance with .1705(j), which states "all structural fills shall
D_E
NORTH CAROLINA Q
U
ileparlment of Enviranmantal aaality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Duke University West Campus
Inspection/Maintenance Letter
Page 2 of 2
January 24, 2020
be covered with a minimum of 12 inches compacted earth, and an additional surface six inches of soil
capable of supporting native plant growth." Many of these sites had alternative caps or end uses that
were approved at the time of construction. Currently the cap system at this facility consists of the
concrete foundation for the building.
Section staff may periodically conduct follow-up inspections of this property to determine continued
compliance with the applicable rules. Failure to maintain compliance with the applicable rules could
result in enforcement action. In the interim, if site conditions change due to property usage or if you
observe any changes to the physical conditions of the cap system, please notify the Section
immediately.
Thank you for your cooperation in this matter. If you have any questions, please contact meat (919)
707-8290 or e-mail [e-mail].
Sincerely,
Digitally signed by Davy Conners
DN: cn=Davy Conners, o=Division of
Waste Management, ou=Solid Waste
Section,
email=[e-mail], c=US
Date: 2020.01.2412:53:03-05'00'
Davy Conners
Environmental Specialist II
Division of Waste Management - Solid Waste Section
copies: Ed Mussler, Section Chief, Solid Waste Section
Sarah Rice, Environmental Program Consultant, Solid Waste Section
Jason Watkins, Field Operations Branch Head
e:!ar:0-f DEQWAj
NORTH CAROLINA
papar•mant 01 Environmantal quality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200