WQ0000020_DENR Request for Information_20100512

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`� Progress Energy
May 11, 2010
North Carolina Department of Environment and Natural Resources
Attn: Mr. Jon Risgaard
Aquifer Protection Section
1636 Mai[ Service Center
Raleigh, NC 27699-1636
Subject: Coal Ash Structural Fill Projects Under Permit WQ0000020
DENR Request for Information
Dear Mr. Risgaard:
Carolina Power & Light Company d/b/a Progress Energy Carolinas, Inc. (PEC) received your letter dated
April 21, 2010 (attached) which requested information from PEC regarding coal ash structural fill
projects completed under permit WQ0000020. PEC completed two structural fill projects per this
permit. The information you requested for these two projects is included in the table below:
DENR Requested Information
Sutton Plant Fill Project
Asheville Plant Fill Project
Interstate 140 By-pass of
Asheville Regional Airport General
List of site
Wilmington, New Hanover County,
Aviation Expansion, Asheville,
North Carolina
Buncombe County, North Carolina
Sutton Plant ponded ash (fly ash and
Asheville Plant ponded ash (fly ash
Source and type of ash utilized
bottom ash)
and bottom ash)
Dates of ash distribution
November 2001 through March 2003
December 2007 through April 2010
Recipient of the ash
Triangle Grading & Paving, Inc.
Charah, Inc.
Total of 168,266 tons [46,135 tons in
Total of 732,408 tons [14,190 tons in
Amount of ash distributed
2001, 93,257 tons in 2002 and
2007, 1 tons in 2008, 487,329
28,874 tons in 2003]
tons n 2009 and 53,657 tons In
in 20
2010]
Total distribution per site
Total of 168,266 tons
Total of 732,408 tons
Anticipated fill completion date
Project completed in March 2003
Project completed with ash
placement in April 2010
Please contact John Toepfer at 919-546-7863 if you have any questions concerning this information.
Sincerely,
Brenda E. Brickhouse
Director - Environmental, Health & Safety
Attachment
BEB/jt
Progress Energy Carolinas, Inc.
P0. Box 1551
Raleigh, NC 27502
RECEIVED / DENR / DWQ
AQUIFFR'PRf1TFCTION .SFCTIQN
MAY 12 2010

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2i
NCDENR
North Carolina Department of Environment andrh o' s
Division -of Water Quality
Beverly Eaves Perdue Coleen H. Sullins APR 2 72010
Governor Director
WATER PROGRAMS
'April 21, 2009 1 UNIT
MR. JOHN S. KEENAN, VICE PRESIDENT - FOSSIL GENERATION / PEB 8
CAROLINA POWER & LIGHT COMPANY D/B/A PROGRESS ENERGY CAROLINAS, INC.
POST OFFICE BOX 1551
RALEIGH, NORTH CAROLINA 27602
Subject: Permit No. WQ0000020
Carolina Power & Light Company
d/b/a Progress Energy Carolinas, Inc.
Progress Energy Ash Distribution Program
Distribution of Residual Solids (503 Exempt)
Wake County
Dear Mr. Keenan:
This letter is intended to provide clarification on existing permit and State Administrative Code
requirements for the distribution of coal combustion products (CCP) as structural fill, and to request
additional information on structural fill activities. Non -discharge permit, WQ0000020, issued by the
Division of Water Quality on February 17, 2006 and effective until February 28, 2013, specifies the
condition under which Carolina Power & Light Company is allowed to distribute CCP. After review of
the existing- permit language, and 15A NCAC 02T requirements for the distribution of CCP, the Division
felt that further clarification was needed to assure that Progress was aware of the expectations of their
distribution program.
Permit Condition II.3.b. specifies that structural/engineered fill (i.e., engineered fill that is properly placed
and compacted) for embankments, foundations, constructionfoundations, and for bases/ sub -bases under a
structure or a footprint of a paved road, parking lot, sidewalk, walkway, or similar structure is approved
for distribution of bottom ash and fly ash: Furthermore; condition II.5.a. and II.9. provide specific
requirements for the use of. CCP as structural fill, and condition IV l .a, provides an explanation of when
use sites are considered individually permitted.' Structural fill is an allowable use for CCP as specified in
the permit; however, the permit fails to reiterate the permit application requirements for new and
expanding structural fill sites specified in 15A NCAC 02T 1204(d) and (f) as provided below:
15A NCAC 02T.1204 Application Requirements
(d) For new and expanding structural fill sites or sites where CCPs are used for bedding if the bedding
is applied at a depth greater than two feet underneath the structure:
(1) Site plans If required by G.S. 89C, a professional land surveyor shall provide location
information on boundaries and physical features not under the purview of other licensed
professions. Site plans or maps shall be provided to the Division by the applicant depicting the
location, orientation, and relationship of the CCPs use site's features including:
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604 One�1
Phone: [phone] FAX 1: 919-715-0588; FAX 2: 919-715-60481 Customer Service: 1-877-623-6748 Nol ffiCarohna
Internet: www.ncwaterpuality.orp '/N����
An Equal Opportunity 1 Affirmative Action Employer NatKy

[Note: The North Carolina Board of Examiners for Engineers and Surveyors has determined,
<...ia )ette;dted„Dec.mber 1, 2005, that locating boundaries and physical features, not under the
of)thO licensed professions, on maps pursuant to this Paragraph constitutes practicing
surveying” under- , SJ89C.].
3 (A) a scaled map" o the site, with topographic contour intervals not exceeding 10 feet or 25
pe cent of tota ite relief and showing all site -related structures and fences within the site;
(B) the location of'all wells (including usage and construction details if available), streams
t"-• --
(ephemeral, intermittent, andperennial), springs, lakes ponds, and other surface drainage
:features within 1500 feet of the CCPs use boundary and delineation of the review and
:compliance -boundaries;
(C) setbacks as required by Rule .1206 of this Section; and
(D) site property boundaries within 500 feet of the CCPs use boundary.
(2)Information shall be provided to the Division that describes and explains site-specific
engineering or institutional controls proposed to prevent adverse impacts to public health and the
environment.
(3)Property Ownership Documentation of the site where the CCPs are to be used shall be provided
to the Division. This documentation shall consist of:
(A) legal documentation of ownership (i.e., contract, deed or article of incorporation);
(B) written notarized intent to purchase agreement signed by both parties, accompanied by a
plat or survey map; or
(C) easements specifically indicating the intended use of the property, as well as a plat or
survey map. Easements shall adhere to the requirements of 15A NCAC 02L .0107.
(f) A compliance boundary shall be established for all structural fill sites not subject to Rule .1203 of
this Section and the permittee shall comply with the provisions of 15A NCAC 02L .0107.
The original CCP distribution permit (WQ0000020) was issued prior to the adoption of the 02T .1200
rules (September 1, 2006), however it is the Division's perspective that any new structural fill site
utilizing CCP after the adoption of the 02T rules must meet the 02T permitting requirements.
At this time, the Division requests that Carolina Power & Light Company submit a list of all existing
structural fill sites that have received CCP under the authorization of permit WQ000020. At a minimum,
the list of sites shall specify the source and type of ash utilized, the dates'of ash distribution, the name of
the recipient of the ash, the amount of ash distributed, the anticipated total distribution per site, and the
anticipated fill completion date. The information shall be submitted no later than May 28`h, 2010. If the
information cannot be obtained by the 281', submit the information available and provide a recommend
date by which the remaining information can be gathered and provided to the Division.
If you have any questions regarding this request, please contact me at [phone]. Thank you in
advance for your cooperation.
Sin erel r
9
Jon isgaard
Aquifer Protection Section
cc: John Toepfer, Post Office Box 1551 Raleigh, North Carolina 27602
Asheville Regional Office - Aquifer Protection Section
Fayetteville Regional Office - Aquifer Protection Section
Mooresville Regional Office - Aquifer Protection Section
Raleigh Regional Office - Aquifer Protection Section
Washington Regional Office - Aquifer Protection Section
Wilmington Regional Office - Aquifer Protection Section
Winston-Salem Regional Office - Aquifer Protection Section
Permit File WQ0000020