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Home My WebLink AboutPresentation - RogersCOAL COMB USTION RESID UAL IMPO UNDMENT RISK CLASSIFICATIONS March 2016 Collaboration between: Division of Water Resources Division of Waste Management Division of Energy, Mineral and Land Resources Department of Environmental Quality COAL COMB USTION RESID UAL IMPO UNDMENT RISK CLASSIFICATIONS Background: • Under the historic Coal Ash Management Act (CAMA) of 2014, all coal ash impoundments in North Carolina are required to be closed. • The deadlines for closure depend on the classification of each impoundment as either low, intermediate, or high. • CAMA required the Department of Environmental Quality (DEQ) to make available to the public a summary of the initial draft proposed classifications in December 2015, and a full report in January 2016. • These draft proposed classifications are based on the information available to the department as of January 2016 and are posted on the departments website, local library, and health department. • The draft proposed risk classification for the James E. Rogers Energy Complex is Low to Intermediate for the Active Basin and Low for the 2 Inactive Basins. • Following completion of the public meetings and the submission of comments, the Department will consider the comments and develop final proposed classifications. Department of Environmental Quality 2 COAL COMB USTION RESID UAL IMPO UNDMENT RISK CLASSIFICATIONS After the release of the summary of the initial draft proposed classifications, CAMA requires the following process: • DEQ must make available a written declaration that is a detailed report explaining the methodology and technical approach used to evaluate the available data and subsequently develop the resulting proposed draft risk classification for each impoundment • Publish a summary of the detailed report in the local newspapers. • Make the report available to the local health director and accessible at the local library • A public meeting in each county with a coal ash facility. • Consider all public comments and develop final proposed classifications Department of Environmental Quality 3 COAL COMB USTION RESID UAL IMPO UNDMENT RISK CLA SSIFI CA TIONS Closure Deadlines • High risk impoundments: Dec. 31, 2019 • Closure plan due by Dec.31, 2016 • Intermediate risk impoundments: Dec. 31, 2024 • Closure plan due by Dec. 31, 2017 • Low risk impoundments: Dec. 31, 2029 • Closure plan due by Dec. 31, 2018 COAL COMB USTION RESID UAL IMPO UNDMENT RISK CLASSIFICATIONS Four of Duke's 14 facilities are designated as high-risk by the coal ash law. Under CAMA, the department is required to consider the following factors, at a minimum, in proposing classifications for the remaining 10 facilities: 1. Any hazards to public health, safety, or welfare resulting from the impoundment 2. Structural condition and hazard potential of the impoundment 3. Consideration of the proximity of surface waters and whether surface waters are contaminated or threatened by contamination 4. Consideration of the extent of soil and groundwater contamination 5. The location and nature of all receptors and significant exposure pathways 6. All factors influencing the movement and the chemical/physical characteristics of contaminants 7. Consideration of coal combustion residuals in the impoundment 8. Position the impoundment with respect to the 100 -year flood plain 9. Any other factor the Department deems relevant to the establishment of risk COAL COMBUSTION RESIDUAL IMPOUNDMENT RISK CLASSIFICATIONS The department incorporated all of the preceding criteria into three primary categories that were used to evaluate each impoundment: • Structural Integrity • Impact to Surface Water • Impact to Groundwater The draft classification process was iterative and took months to complete. Recommendations regarding the impoundments were amended and updated as additional technical information was received, reviewed, and verified. Department of Environmental Quality I JAMES E. ROGERS ENERGY COMPLEX (FORMERLY CLIFFSIDE STEAM STATION) RISK CLASSIFICATION Department of Environmental Quality JAMES E. ROGERS ENERGY COMPLEX RISK CLASSIFICATION Overall Risk Classification DEQ has proposed the risk classification for the Active Ash Basin as LOW TO INTERMEDIATE. DEQ has proposed the risk classification for the 2 Inactive Ash Basins as LOW Groundwater Key Factor: • Based on the information received to date, there appears to be no downgradient receptors located 1,500 feet downgradient of the impoundment compliance boundary Other Factors and Considerations: • There are data gaps and uncertainty concerning site conditions at the facility related to groundwater • These data gaps are currently being addressed by Duke Energy and their findings will be provided to DEQ as supplemental reports T'1 Department of Environmental Quality I JAMES E. ROGERS ENERGY COMPLEX RISK CLASSIFICATION Surface Water Key Factor: The coal ash impoundments are not located within the 100 -year floodplain. • Active Ash Basin, including adjacent ash storage areas. LOW RISK. The footprint of the CCR impoundment is sited along the Broad River, but is not located within the 100 year floodplain. • Retired Unit 1-4 Basin. LOW RISK. The footprint of the CCR impoundment is sited along the Broad River, but is not located within the 100 year floodplain. • Retired Unit 5 Basin. LOW RISK. The footprint of the CCR impoundment is sited along the Broad River, but is not located within the 100 year floodplain. *This figure depicts landscape positions in regards to the 100 -year flood level and river valley floodplain for the Active Ash Basin, including adjacent ash storage areas, Retired Unit 1-4 Basin and Retired Unit 5 Basin at J s F. Rogers Ste lec ric Plant (Cliffside). Department o7rnvironmenta�Juality K`C� I JAMES E. ROGERS ENERGY COMPLEX RISK CLASSIFICATION Dam Safety Key Factor: The impoundments received a low to high risk ranking before any repairs are made and a low risk rating once repairs are made State of Structural Stability and Maintenance: • Active Ash Basin (CLEVE-049 & CLEVE-050). High risk before repairs are made. Low risk after repairs are made. (2 repair plans have been approved and 2 repair plans are under review by DEQ and of those 1 repair plan has been completed by Duke) • Retired Unit 1-4 Basin (CLEVE-047). Low risk. (4 repair plans have been approved by DEQ and of those 1 repair plan has been completed by Duke) • Retired Unit 5 Basin (RUTHE-070 & RUTHE-072). High risk before repairs are made. Low risk after repairs are made. (4 repair plans have been approved and 3 repair plans are under review by DEQ and of those 2 repair plans have been completed by Duke) Department of Environmental Quality a JAMES E. ROGERS ENERGY COMPLEX RISK CLASSIFICATION We will now receive public comments To view additional information please visit www.deg.nc.gov The public comment period will close on April 18, 2016 You may submit comments three ways, all weighted equally: • Here orally and/or in writing • Email to rogerscomments@ncdenr.gov • Postal mail to: N.C. Department of Environmental Quality, Attn: Zahid Khan, 610 East Center Ave, Suite 301, Mooresville, NC, 28115 Department of Environmental Quality