WQ0003254_Correspondence_19940630

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
June 30, 1994
Mr. M. D. McIntosh, Vice -President
Fossil/Hydro Generation Department
Duke Power Company
Post Office Box 1006
Charlotte, North Carolina 28201-1006
RE: Duke Power Company
Ash Reuse Program
Dear Mr. McIntosh:
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IDEHNR
In accordance with several conversations between the Division and Mr. L. D. Evans, Scientist,
Environmental Protection - Waste Management, Generation Services Department, Duke Power Company,
we are forwarding clarification of the Division's position on using fly ash and bottom ash in structural
fills. Although in the existing ash reuse permits the Division did not approve this use of fly ash and
bottom ash, further clarification is necessary. The ash reuse permits previously read as follows:
a. Section H(1)(a) - Structural fills were further defined by describing them as engineered fills
constructed of fly ash and bottom ash properly placed and compacted. However, the Division
does not agree on including areas of high intense public use such as parks, golf courses, and
ball fields as examples for using structural fills. If Duke Power Company washes to pursue
these disposal alternatives, further documentation must be submitted to the Division justifying
them for using in structural fills.
The Division would like to offer the following clarification:
a. Section H(i)(a) - Structural fills were further defined by describing them as engineered fills
constructed of fly ash and bottom ash properly placed and compacted. The Division does not
agree on including cxisting areas of high intense public use such as parks, golf courses, and
ball fields as examples for using structural fills. However, during initial or preliminary
construction of such high intense public areas, fly ash and bottom ash may be used in structural
fills as long as the fly ash and bottom ash is properly placed and compacted and not used in the
top eighteen (18) inches of the final cover.
Until the Duke Power Company has requested another permit amendment or the permits are
renewed, this letter will serve as the Division's approval for the use of fly ash and bottom ash in structural
fills as explained above.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

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= June 30, 1994
Duke Power Company
If you need additional information concerning this matter, please contact Ms. Carolyn Mc{
Mr. Michael D. Allen at [phone].
Sincerely,
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©� A. Press Howard, Jr., P.E.
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cc: Asheville Regional Office, Water Quality Section
Asheville Regional Office, Groundwater Section
Mooresville Regional Office, Water Quality Section
Mooresville Regional Office, Groundwater Section
Winston-Salem Regional Office, Water Quality Section
Winston-Salem Regional Office, Groundwater Section
Jack Floyd, Groundwater Section, Central Office
Permit File WQ0000452
Permit File WQ0000563
Permit File WQ0003253
st,jFile;WaQ, W3g254­ -
Permit File WQ0003255
Permit File WQ0007210
Permit File WQ0007211
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