Anchor QEA of North Carolina, PLLC 231 Haywood Street Asheville, North Carolina 28801 828.281.3350 August 23, 2018
Tracy L. Wahl North Carolina Brownfields Program, Western District Supervisor Department of Environmental Quality Mail Service Center 1646 Raleigh, NC 27699-1646
Re: Limited Environmental Management Plan Duke Energy Craggy-Enka Switch Project Closed BASF Landfill Site Brownfields Program Site #15011-11-11
Dear Ms. Wahl,
Anchor QEA of North Carolina, PLLC (Anchor QEA) on behalf of Duke Energy Progress (Duke Energy) has prepared this limited environmental management plan (EMP) for the Craggy-Enka Switch Project. Duke Energy’s is planning to upgrade and replace certain structures located adjacent to the Closed BASF Landfill (the Site) located near Sand Hill Road in Asheville North Carolina. A Site Location Map and Site Layout Map showing proposed improvements is attached. All proposed work will be outside of the landfill waste boundary. Only a portion of the access road and associated erosion control measures will be installed on the Brownfields property boundary (see Figure 2 for property boundary location and location of improvements).
As requested in an email sent by you on May 21, 2018 to Mr. David Witte with Duke Energy, this limited EMP includes the following components:
Plan to manage groundwater should it be encountered
Notification and management plan should waste be encountered
Work schedule
The following sections include a description of the proposed work activities, a site background, and procedures for managing groundwater and waste should it be encountered.
Proposed Work Activities The planned work activity is a switch replacement project, the Craggy-Enka Switch Project (Project) to be completed by Duke Energy Progress and their contractors. The proposed Project involves pole replacement, and installation of 115kV tap lines in the utility rights-of-way adjacent to the Site property along the northeast and southeast property boundaries. The Project also includes
A:\Projects\Duke Energy\Craggy-Enka\Workplan-Brownfields\DukeCraggy-EnkaSwitch_WorkPlan-2018-08-Rev1.docx August 23, 2018 Page 2 installation of temporary gravel roads for construction access, permanent gravel roads for switch access, and associated clearing, grading, and erosion control measures. Please note that no existing monitoring wells or soil gas monitoring points will be disturbed/destroyed by construction activities.
A review of the proposed Clearing, Grading, Access, & Erosion Control Plans (attached) reveals that all proposed work activities will be performed outside of the waste boundary of the North Carolina Department of Environmental Quality (DEQ), Division of Waste Management (DWM), Solid Waste Section closed landfill (#1102-INDUS-1980). Only a small portion of the proposed Project is located within the property boundary of the DEQ, DWM, Brownfields Program Site (#15011-11-011).
Site Background The Site was used as an industrial landfill by the adjacent former American Enka Company (American Enka) and BASF Corporation (BASF) manufacturing facility, which began rayon yarn production in 1929. The facility primarily manufactured various types of yarns, including continuous filament rayon yarn, nylon textile yarn, and carpet yarn.
In 1980, American Enka received a state permit (No. 11-02) to use the Site as an industrial waste landfill. The wastes included fly ash (a coal-combustion byproduct), caprolactam (a precursor to nylon) reactor bottoms, waste activated sludge (excess biological material produced during wastewater treatment), alum sludge (material produced from treating wastewater with aluminum sulfate), viscose pit bottoms (a byproduct of the production of viscose rayon), and household and construction wastes.
On March 13, 2006, The DEQ-SWS, formerly known as the North Carolina Department of Environment and Natural Resources, issued a letter of closure for the landfill to BASF (the responsible party). The 29.88-acre Site is now owned by Enka Youth Sports Organization, Inc who is currently redeveloping the Site as a sports complex with ball fields, a concession stand, and associated parking.
Landfill waste has not been documented in the area of proposed work activities.
Groundwater Management Plan According to groundwater monitoring reports prepared for the Site by Elm Site Solutions, Inc., the nearest monitoring well to planned work activities is the background monitoring well, MW-6. Depth to water in MW-6 has historically been approximately 40 feet below the top of casing.
Replacement pole foundations are planned to be installed to approximately 20-feet, and other improvements will only disturb the top few feet of soil or less. Excavation activities for access road construction and the installation of erosion control measures are planned to be relatively superficial. As such, groundwater is unlikely to be encountered. August 23, 2018 Page 3
If groundwater is encountered at the Site, it could potentially be impacted. Impacted groundwater is defined as groundwater containing concentrations of a regulated substance in excess of the Title 15A, NCAC, Subchapter 2L groundwater quality standard (2L standard), with some exceptions. Groundwater containing concentrations of metals in excess of the 2L standard that are consistent with naturally occurring concentrations of these metals is not considered impacted.
Should impacted groundwater be encountered and need to be removed during construction activities, it will be containerized, characterized, and disposed of in accordance with federal, state, and local laws. Non-impacted groundwater may be spread on-Site in the area from which it originated. Groundwater will be characterized by laboratory analysis including:
Volatile organic compounds (VOCs) by EPA Method 8260
Semi-volatile organic compounds (SVOCs) by EPA Method 8270
Resource Conservation and Recovery Act (RCRA) metals by various methods
Soil Management Plan Excess soil may be produced during work activities. Excess soil will be managed as follows:
With the permission of the property owner, spread onsite and appropriately seeded (i.e. seeded with a mix consisting of 1 pound/1,000 square feet of Kentucky bluegrass, 5 pounds/1,000 square feet of tall fescue, and 1 pound/1,000 square feet of fine fescue)
Sampled, characterized, and disposed of at a permitted facility, specifically, either Republic’s landfill in Enoree, South Carolina, or Lenoir, North Carolina.
Please note that soil produced during activities performed outside of the Brownfields Site property boundary may be managed using alternative methods.
If fill material is brought to the Site (to areas within the property boundary), DEQ will be contacted beforehand to approve the fill source location.
Waste Management and Notification Plan Because work will be performed outside of the waste boundary, it is unlikely that landfill waste (as described in the Site Background section of this document) will be encountered.
During construction activities, Site workers should be aware of the potential of encountering landfill waste. If field observations indicate the exposure of landfill waste, the owner of the property and/or the Site environmental professional will be notified within 24 hours and DEQ will be notified within 48 hours. If landfill waste is encountered, the following measures will be implemented: August 23, 2018 Page 4
Immediately stop the activity that exposed the landfill waste
Notify the Site owner and/or Site environmental professional, DWM’s Solid Waste Section and the Brownfields Program
Don applicable personal protective equipment (PPE), such as gloves (nitrile gloves, work gloves, or a combination)
Relocate the exposed landfill waste to where it originated from or containerize waste in a drum or properly constructed stockpile
If waste is replaced in the location where it originated, re-establish cover soils over the area of landfill waste exposure.
If waste is to be properly disposed of off-Site in a permitted facility, waste characterization samples will be collected.
Assess work methods in that area to minimize or prevent the potential for re-exposure of landfill waste
Ensure a minimum of 2 feet of cover soils exist when work is completed to final grade
Completion Report Following the completion of work activities, a summary report will be prepared and submitted to DEQ. The report will include at a minimum a description of waste encountered (if any) and associated management as well as the quantity and final disposition of any excess soil and groundwater exposed during construction activities.
Work Schedule Site work is planned to begin in October 2018 and will be completed in approximately 2 months. The completion summary report will be submitted within 90 days of the conclusion of work activities.
August 23, 2018 Page 5
Please do not hesitate to contact the undersigned should you have any questions.
Sincerely,
Adam M. Tripp, PG Senior Geologist
Attachments
Figure 1 – Site Location Map
Figure 2 – Site Layout Map
Clearing, Grading, Access & Erosion Control Plan
LEGEND: DATA SOURCES: 1. Approximate Waste Boundary - Based on drawing by ELM Site Approximate Waste Boundary Solutions from July 2015 titled "Semi-Annual Groundwater Monitoring Report" Permitted Facility Boundary 2. Basemap - USGS Topographic Maps, Enka Quadrangle, 2015 [ NOTE: 0 2,000 Permitted Facility Boundary is approximate.
Feet
Publish Date: 2018/07/26, 12:33 PM | User: alesueur Filepath: \\Asheville1\Asheville\GIS_Projects\Duke_Energy\Craggy_Enka\Maps\2018_07\AQ_Fig01_SiteLocationMap.mxd
Figure 1
Anchor QEA of North Carolina, PLLC Site Location Map Duke Energy Craggy-Enka Project Former BASF Landfill, Asheville, North Carolina 2040 2060
2040 2040
Existing 2060 Structure #59 2100 2080
2080
2060 2060 %2 2100
2040 2120
Existing Structure #58
%2 Proposed Switch Pad 2060
2120 Proposed Structure %2
Existing Structure %2 to be Removed 2100 %2%2
Proposed Structure
%2 Existing Enka BASF Tap Structure #2 (To Remain)
2120
LEGEND: NOTE: 1. Site feature locations are approximate. Proposed Sports Complex Construction Approximate Waste Boundary SOURCES: Proposed Access Road for Construction Enka BASF 115kV Tap Line 1. Basemap: NC OneMap 2015 [ Property Boundary Topographic Contours (4-Foot Interval) 2. Topographic Contours: NCDOT Lidar, 2007 0 400 3. Property Boundary: Drawn from survey completed by Ed Holmes & Associates Land Surveyors, PA
Feet
Publish Date: 2018/07/26, 12:48 PM | User: alesueur Filepath: \\Asheville1\Asheville\GIS_Projects\Duke_Energy\Craggy_Enka\Maps\2018_07\AQ_Fig02_SiteFeaturesMap.mxd
Figure 2 Site Layout Map Duke Energy Craggy-Enka Project Former BASF Landfill, Asheville, North Carolina 5/24/2018 7:07:16 AM PDT 5/24/2018 7:07:16 AM PDT 5/24/2018 7:07:16 AM PDT 5/24/2018 7:07:16 AM PDT 5/24/2018 7:07:16 AM PDT