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7302_INSP_20160824FACILITY COMPLIANCE INSPECTION REPORT Department of Environmental Quality Division of Waste Management - Solid Waste Section UNIT TYPE: Lined MSWLF LCID YW Transfer Compost SLAS COUNTY: Person Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 7302-INDUS-1988 CDLF Tire T&P / Collection Tire Monofill Industrial Landfill X DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: August 24, 2016 Date of Last Inspection: August 24, 2015 FACILITY NAME AND ADDRESS: Duke Energy Progress, Inc. - Roxboro Steam Electric Plant 1700 Dunnaway Road Semora, NC 27343 GPS COORDINATES: N: 36.47843 W: -79.06312 FACILITY CONTACT NAME AND PHONE NUMBER: Robert Miller, w. 336-597-7337, c. 336-503-2875, robert.miller@duke-energy.com Kimberlee Witt, w. 980-373-2779, c. 336-215-4576, Kimberlee.Witt@duke-energy.com FACILITY CONTACT ADDRESS: Duke Energy Progress, Inc. Robert Miller 1700 Dunnaway Road Semora, NC 27343 PARTICIPANTS: Shawn McKee, NCDEQ, Solid Waste Section Elizabeth Werner, NCDEQ, Solid Waste Section Larry Frost, NCDEQ, Solid Waste Section Kim Witt, Duke Energy Evan Andrews, Duke Energy Robert Miller, Duke Energy Issa Zarzar, Duke Energy STATUS OF PERMIT: Initial Permit to Construct issued June 22, 2002 Initial Permit to Operate Phase 1 issued November 25, 2003 Permit to Construct, Phase 6 issued October 8, 2013 Permit to Operate Phase 6, February 9, 2015 PTO expires August 31, 2020 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 a lined industrial landfill permitted to accept coal combustion by-product (CCB) predominately fly ash, bottom ash, gypsum, and flue gas desulfurization (FGD) residue from Duke Energy Progress and Duke Energy Carolinas power generating facilities. It is also permitted to receive other residues as stated in the facility operations plan section 2.1.2. 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 facility permit, site plan, and operations plan were discussed during the inspection. 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. 4. a. Annual internal training on the Roxboro Steam Electric Plant Landfill Operations Plan was last conducted on 3/3/2016. b. The following Charah, Inc. personnel are NC Certified Landfill Managers:  Christopher Nowell, Certification #15-02M-00135, 4/22/18  Scott Martin, Certification #13-02M-00072, 7/24/16  Rob Long, Certified Landfill Manger, No. 11-02-00021, exp. 6/22/2017  John Johnson, Certified Landfill Operator, No. 14-020-00100, exp. 01/11/2017 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. 5. The facility has a current Division of Air Quality, Title V Permit. The permit was issued February 7, 2014. 6. The current erosion and sedimentation control plan for the facility is on file. The facility conducts erosion and sedimentation control inspections once a week and after ½ inch of rain within 24 hours. Facility inspection records were verified. 7. Leachate lines for the landfill were inspected on 12/30/2015 by Jet Clean America. No blockages were noted. Routine cleaning of the leachate systems for Phase 1-5 and Phase 6A last occurred 9/3/2014- 9/6/2014. 8. Leachate Detection System (LDS) records indicate that the LDS pump has been under repair for lengthy period of time. The facility is aware of the situation and has taken action to resolve the issue with regular scheduled maintenance of the pump. The facility has developed and accurate backup methods for determining flow from this system when the pump has been out of service. 9. Financial assurance documentation for the facility was reviewed during the inspection. The financial assurance was submitted by Duke Energy Carolina on March 22, 2016. The approved financial assurance includes $14,921,937 for closure, $7,564,247 for post-closure care, and $2,000,000 for potential assessment and corrective action. 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 10. For 2016 (1/1/16 to 8/22/16), the facility had landfilled 204,342.37 tons of waste. For the annual reporting period July 1, 2015-June 30, 2016 the facility landfilled 274,420.32 tons of waste. 11. During the inspection, the semi-annual ground water, surface water and leachate monitoring report for the sampling event conducted November 11, 2015 and April 6, 2016. Six groundwater wells and four leachate port locations were monitored. Two piezometers are also checked for groundwater levels. Groundwater well monitoring indicated the presence of boron, selenium, sulfate and barium. 12. Dust control records appear complete. These records were computer generated, well organized, and easy to review. 13. Stormwater and E&SC records appear complete and up to date. 14. The facility has been contact with Solid Waste Section Permitting Branch staff regarding the construction of a perimeter berm and ditch need for the continued operation of the facility. Permitting will keep the Field Operations Branch apprised of any design changes made and timing. 15. Monitoring wells and surface sampling points with noted deficiencies during the last inspection were observed during this inspection. The following observations were noted: 7302-INDUS-1988 Monitoring Well ID Well Tag Concrete Pad Comments Groundwater Monitoring Wells GMW-9 Yes Yes locking cap and hinge have been repaired Piezometers for groundwater levels only PZ-12 Yes Yes PZ-14 No Yes permanent well tag has been affixed Leachate Collection Ports LP-1 NA NA A permanent flag locator, permanent label/tag at port sample location would be beneficial and is recommended for clarity; access to the sample location receives regular mowing LP-2 NA NA A permanent flag locator, permanent label/tag at port sample location would be beneficial and is recommended for clarity; access to the sample location receives regular mowing LP-3 NA NA A permanent flag locator, permanent label/tag at port sample location would be beneficial and is recommended for clarity; access to the sample location receives regular mowing LP-4 NA NA A permanent flag locator, permanent label/tag at port sample location would be beneficial and is recommended for clarity; access to the sample location receives regular mowing LP-5 NA NA A permanent flag locator, permanent label/tag at port sample location would be beneficial and is recommended for clarity; access to the sample location receives regular mowing LP-6 NA NA A permanent flag locator, permanent label/tag at port sample location would be beneficial and is recommended for clarity; access to the sample location receives regular mowing FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 4 16. 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 West Ash Pond for treatment and is released in accordance with the National Pollutant Discharge Elimination System (NPDES) permit for the facility. The NPDES permit #NC00003425 was issued on 4/9/07. 17. Facility access roads are of all-weather construction and are well maintained. Water trucks are utilized to control road dust, as needed. Water trucks were operating at the time of the inspection in accordance with the approved Dust Control Plan. 18. Side slopes and inactive areas have soil cover and established vegetation. Side slopes were well vegetated. Vegetative growth on side slopes and facility property are mowed regularly every two to three weeks during the growing season, or as needed. No on-site or off-site erosion observed. Reseeding is done as needed. 19. No windblown dust from landfill operations or roadways was noted during the inspection. Weather conditions during the inspection were sunny, and dry. 20. The facility permit to operate is for the operation of Phases 1 through 6. Phase 1 through Phase 5 is ~ 71 acres. The facility is currently placing material in Phase 6. Phase 6 is 22 acres and has a double liner with leak detection system. 21. 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. Additionally, Gorilla-Snot is used when needed to aid in the process of crusting. The Steam Station was in operation at the time of the site visit and ash was being placed in the working face. Active disposal area – Phase 6 22. A chimney drain will be installed in Phase to aid in leachate collection. 23. Edge of waste markers have been installed and are being maintained. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 5 24. Ceffo Volunteer Fire Department will respond to an emergency at the facility. 25. The facility is secured by a locked gate. Personnel are on site during operating hours. The facility has all required information on signs. 26. The Coal Combustion By-products Structural Fill constructed per 15A NCAC 13B .1700 Solid Waste Rules designated as “CCB0076 - Progress Energy Roxboro Plant - Phase 6 Expansion of LF” functions as the base grade for this land fill. Final closure of the fill was completed with the installation of the synthetic liner system associated with the construction of Phase 6. Please contact me if you have any questions or concerns regarding this inspection report. _ Phone: 919-707-8284 Environmental Senior Specialist Regional Representative Sent on: September 8, 2016 Email: X Hand delivery US Mail Certified No. [ _] Copies: Ellen Lorscheider, Section Chief, Solid Waste Section Ed Mussler, Permitting Branch Head, 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