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FINAL Combined 36-12I-20131227 & 20140113INSP Proposed Corractive Actions+ -Arias NCDENR NORTM CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section UNIT TYPE: Lined LCID YW Transfer Compost SLAS COUNTY: GASTON I MSWLF PERMIT NO.: 36-121 I Closed xllW white Incin T&P FIRM MSWLF goods _ FILE TYPE: COMPLIANCE CDLF TireT&P/ Tire Industrial X DEMO SDTF Collection Monofill Landfill Date of Site Inspection: 12/27/13 and 1/13/14 Date of Last Inspection: 10/04/12 FACILITY NAME AND ADDRESS: Duke Energy, Allen Steam Station — Retired Ash Basin (RAB) 253 Plant Allen Road Belmont, NC 28012 GPS COORDINATES: N: 35.18295' E:-81.00979' FACILITY CONTACT NAME AND PHONE NUMBER: Don Scruggs (704) 829-2423 Office (704) 400-3005 Cell don.scruggs@duke-energy.com Fax: (704) 829-2370 FACILITY CONTACT ADDRESS: Same as Above PARTICIPANTS: Don Scruggs — Duke Energy Walter Fox — Chara (Construction Subcontractor) Bill Wagner — NCDENR, Solid Waste Section STATUS OF PERMIT: Permit to Operate: Allen Steam Station / Retired Ash Basin (RAB) Phase 1, Cells 1 & 2 (DIN 14135) Issued: 6/16/2011 Expires: 12/09/14 PURPOSE OF SITE VISIT: Partial Compliance Inspections in response to two separate reported "off -liner" release of waste on 12/27/13 and on 1/13/14. STATUS OF PAST NOTED VIOLATIONS: None. OBSERVED VIOLATIONS 1. 15A NCAC 13B .0505 states, in part that, any person who maintains or operates a sanitary landfill site shall maintain and operate the site in conformance with the permit. Incorporated in the Permit to Operate — Modification, Duke Energy Allen Steam Station (DIN 14135) is the approved Operations Plan, Retired Ash Basin (RAB) (DIN12344). Section 3.1 (Storm Water Collection and Conveyance) of the Approved Operations Plan requires, in part, that "storm water runoff from the landfill be FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 3 Duke Energy Allen Steam Station 36-12I—Belmont, Gaston Co. Retired Ash Basin (RAB) Site Map of the Approximate Location of the "Off -site" Release of Waste and Silt on 12/27/13 2. Since October 2012 this is the third incidence of the release of waste off of the liner due to heavy rains. Date of Release Location of Release Comment September 2011 Northern Slope of Celll, Phase 1 Self -reported by Duke Energy Sept. 2012 10/14/13 Western Slope of Cell 1, Phase 1 Self -reported by Duke Energy 10/15/13. 12/23/13 Southern Slope of Cell 1, Phase 1 Self -reported by Duke Energy 12/23/13. 3. 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. 4. The landfill is permitted to receive combustion products / residuals consisting of fly ash, bottom ash, boiler slag, mill rejects and flue gas desulfurization (FGD) residue generated from the Allen Steam Station plant. 5. At the time of construction, the projected life of the RAB landfill was approximately 12-years. 6. The power plant was not operating at the time of the inspection due to low demand for electricity. 7. The current active area of the landfill is Cell 2, of Phase 1. (Figure 1) 8. The retired ash basin (RAB) landfill has been constructed on top of a former structural fill landfill. 9. There are three `chimney drains" in Cell 2 of Phase 1 that collect and direct storm water that contacts the coal ash to the leachate collection system. (Figure 1 and Photo # 1) 10. Both the edge of waste and the edge of liner are identified with white PVC markers. 11. While it appeared that leachate from the two "rills" was mostly held within the limits of the perimeter stormwater ditch, there was matted vegetation in the sediment basin that suggested that leachate and / or stormwater had spilled from the perimeter ditch, over the perimeter access road and into the sediment basin. (Photo # 10) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 4 4, t Duke Energy Allen Steam Station 36-12I— Belmont, Gaston Co. Retired Ash Basin (RAB) Site Map of the Approximate Location of the "Off -site" Release of Waste and Silt on 1/12/14 1. Western "rill" in the (S) slopes of the landfill under repair. (Photo taken by Duke Energy 12/23/13) Note edge -of -waste maker. 2. Eastern "rill" in the (S) slopes of the landfill. (Photo taken by Duke Energy 12/23/13) Note edge -of -waste marker. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 5 3. Looking (N) across the sediment basin at the two "rills" on the (S) slope of the landfill. (Photo taken by Duke Energy 12/23/13) 5. Looking (NNE) at Cell 2, in Phase 1. (Note the "chimney drain".) Photo taken by B.Wagner 12/27/13. 7. Looking (E) down the perimeter road on the (S) side of the landfill., Cell 2, Section A, at the cap on Phase 1, Cell 1, Section B. Photo taken by B.Wagner 12/27/13. 4. Looking (N) at the (S) slopes of the landfill at the two repaired "rills" caused by stormwater runoff from the cap of Phase 1. Photo taken by B.Wagner 12/27/13. 6. Looking (W) down the sediment basin located to the (S) of the landfill. (Landfill is in the upper right background.) Photo taken by B.Wagner 12/27/13. 8. "Drop inlet" at the (W) end of the perimeter ditch on the (S) side of the landfill. Photo taken by B.Wagner 12/27/13. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 6 9. Crew vacuuming stormwater from the perimeter ditch on the (S) side of the landfill. Photo taken by B.Wagner 12/27/13. 10. Vegetation in the sediment basin compacted by runoff from the outfall of the western rill. Photo taken by B.Wagner 12/27/13. 12. There is a "drop inlet' at the western end of the perimeter stormwater ditch that channels the contents of the stormwater ditch to the sediment basin on the south side of the landfill. (Figure 1 & Photo #8) 13. There was no visual evidence that any ash or soil associated with this episode reached the sediment basin. 14. Other than the two "erosion rills" on the southern slope, the landfill does not exhibit any excessive on -site erosion. 15. The side slopes of the landfill had well sloped. Release of Waste and Silt on 1/12/14 16. On January 12, 2014 Sean DeNeale (Engineer for Duke Energy) reported the release of soil and coal ash at the Allen Steam Station Retired Ash Basin (RAB) in Belmont, Gaston County. Mr. DeNeale made the report to Larry Frost (NCDENR, Solid Waste Section) by e-mail at 12:25 AM on Sunday 1/12/14: g) The release occurred when the inlet to the "down slope drain" in the SW corner of the top of the landfill became blocked during a heavy rain event (approximately 2.5-inches) on Saturday (1/11/14) and Sunday 1/12/14. This caused stormwater run-off on the cap of Cell 1 of Phase 1, to spill over the top of the containment berm and flow down the western slope, off the liner, and to the perimeter stormwater ditch. It did not appear that any sediment or waste moved beyond the perimeter stormwater ditch in the immediate vicinity of the outfall of the "down slope drain". (Photos 1,2,3,4, & 6) h) Crews recovered the coal ash and soil that had been released beyond the edge of the landfill liner. This material was returned to the landfill. i) The inlet to the "down slope drain" was repaired. (Photo #1) j) The SW slope that was eroded due this incident was repaired. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 7 11. Inlet to the "down slope drain" in the SW corner of landfill after initial repairs. (Photo taken by Duke Energy on 1/12/14) 13. Perimeter stormwater ditch partially filled with sediment & possibly waste, at the outfall of the "down slope drain" in the SW corner of landfill. (Photo taken by Duke Energy on 12. Out fall of the "down slope drain" in the SW corner of landfill. Note the surface water runoff spilling over the silt fence into the perimeter stormwater ditch. (Photo taken by Duke Energy on 1/12/14) 14. "Down slope drain" in the SW corner of landfill and the silt fence after the rain event and before being repaired. (Photo taken by Duke Energy on 1/12/14) 15. Looking (S) the NW corner of Phase 1, Cell 1, of the RAB landfill. (Photo taken by B.Wagner on 1/13/14) 16. Looking (E), from the perimeter road, at the repaired & cleaned up path of the release of sediment & coal ash. (Photo taken by B.Wagner on 1/13/14) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 8 of 8 17. Looking (N) down the perimeter ditch on the (W) side of the landfill. Outfall of the down slope drain is on the lower right. (Photo taken by B.Wagner on 1/13/14) 19. Looking (NE), from the perimeter road, at the SE corner of the landfill. Outfall of the down slope drain is on the center right. (Photo taken by B.Wagner on 1/13/14) 18. Looking (E) down the perimeter ditch on the (S) side of the landfill. Note the "drop inlet" in the center of the photo. (Photo taken by B.Wagner on 1/13/14) 20. Stormwater ditch on the (W) side of the perimeter road, directly across from the point where the outfall from the down slope drain in the SW corner of the landfill discharged. (Photo taken by B.Wagner on l/13/14) 17. On the early afternoon of Monday 1/13/14 Chara (Duke Energy's construction subcontractor) finishing up repairs to the slope, the down slope drain and to the perimeter stormwater ditch of the landfill. (Photos 16 - 19) 18. There was no evidence that any waste had migrated beyond the stormwater perimeter ditch in the immediate area of the outfall from the down slope drain in the SW corner of the landfill. (Photos 17 -20) 19. None of the other three down slope drains were adversely impacted. 20. Since October 2012 this is the fourth incidence of the release of waste off of the liner due to heavy rains. Date of Release Location of Release Comment September 2011 Northern Slope of Celll, Phase 1 Self -reported by Duke Energy Sept. 2012 10/14/13 Western Slope of Cell 1, Phase 1 Self -reported by Duke Energy 10/15/13. 12/23/13 Southern Slope of Cell 1, Phase 1 Self -reported by Duke Energy 12/23/13. 1/12/14 Western Slope of Cell 1, Phase 1 Self -reported by Duke Energy 1/12/14. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 9 of 9 SITE HISTORY: 21. 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. 22. The landfill is permitted to receive combustion products / residuals consisting of fly ash, bottom ash, boiler slag, mill rejects and flue gas desulfurization (FGD) residue generated from the Allen Steam Station plant. 23. At the time of construction, the projected life of the RAB landfill was approximately 12-years. 24. The power plant was not operating at the time of the inspection due to low demand for electricity. 25. The current active area of the landfill is Cell 2, of Phase 1. (Figure 1) 26. The retired ash basin (RAB) landfill has been constructed on top of a former structural fill landfill. 27. Both the edge of waste and the edge of liner are identified with white PVC markers. 28. There is a "drop inlet" at the western end of the perimeter stormwater ditch that channels the contents of the stormwater ditch to the sediment basin on the south side of the landfill. (Figure 1 & Photo #8) 29. There was no visual evidence that any ash or soil associated with this episode reached the sediment basin. Please contact me if you have any questions or concerns regarding this inspection report. f )j/zt�—Phone: 828-296-4705 Bill Wagner Environmental Senior Specialist Regional Representative Sent on: 1/29/14 to: Email Hand Us Certified No.: CT Corporation, Registered Agent Delivery Mail X 7012 1010 0002 1967 9880 Box 1011 Raleigh, NC 27601 ec: Don Scruggs — Duke Energy (Don. Scruggskduke-energy) Sean DeNeale - Duke Energy (Sean.DeNealekduke-energyy com) Jason Watkins, District Supervisor — Solid Waste Section Sarah Rice, Compliance Officer — Solid Waste Section