Annual CCR Monofill Inspection - Berkshire Hathaway Energy...Energy Center Final January 18, 2016 ....

Annual CCR Monofill Inspection

MidAmerican Energy Company, Neal North

Energy Center

Final January 18, 2016

Annual CCR Monofill Inspection

Prepared for

MidAmerican Energy Company, Neal North Energy Center

Sergeant Bluff, Iowa

Final January 18, 2016

Prepared by

Burns & McDonnell Engineering Company, Inc. Kansas City, Missouri

COPYRIGHT © 2016 BURNS & McDONNELL ENGINEERING COMPANY, INC.

INDEX AND CERTIFICATION

MidAmerican Energy Company, Neal North Energy Center Annual CCR Monofill Inspection

Report Index Chapter Number Number Chapter Title of Pages

1.0 Summary of Objectives 1 2.0 Results of Inspection 4 3.0 Recommended Remedial Action 1 4.0 Limitations of Report 1 Appendix A CCR Monofill Inspection Checklist and Photo Log 8 Appendix B Survey Results 1 Appendix C Construction Drawings 9 Appendix D Excerpt from CCR Rule (§257.84) 1

Certification

I hereby certify, as a Professional Engineer in the State of Iowa, that the information in this document was assembled under my direct personal charge. This report is not intended or represented to be suitable for reuse by the MidAmerican Energy Company, Neal North Energy Center or others without specific verification or adaptation by the Engineer.

Nathan Textor, P.E.

Date: {/j[

Nathan Textor License Number 23013

My license renewal date is December 31, 2016

Pages or sheets covered by this seal: As noted above.

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Neal North – CCR Monofill Inspection Report Table of Contents

MidAmerican Energy Company TOC-1 Burns & McDonnell

TABLE OF CONTENTS

Page No.

1.0 SUMMARY OF OBJECTIVES .......................................................................... 1-1

2.0 RESULTS OF INSPECTION ............................................................................. 2-1 2.1 Description of Monofill ....................................................................................... 2-1 2.2 Review of Existing Information ........................................................................... 2-2 2.3 Visual Inspection ................................................................................................. 2-2 2.4 Approximate Volume of CCR in the Monofill .................................................... 2-3 2.5 Changes in the Monofill....................................................................................... 2-3 2.6 Signs of Structural Weakness .............................................................................. 2-3

3.0 RECOMMENDED REMEDIAL ACTION ........................................................... 3-1

4.0 LIMITATIONS OF REPORT .............................................................................. 4-1

APPENDIX A – CCR MONOFILL INSPECTION CHECKLIST AND PHOTO LOG

APPENDIX B – SURVEY RESULTS

APPENDIX C – CONSTRUCTION DRAWINGS

APPENDIX D – EXCERPT FROM CCR RULE (§257.84)

Neal North – CCR Monofill Inspection Report List of Abbreviations

MidAmerican Energy Company i Burns & McDonnell

LIST OF ABBREVIATIONS

Abbreviation Term/Phrase/Name

CCR Coal Combustion Residual

EPA Environmental Protection Agency

IDNR Iowa Department of Natural Resources

MEC MidAmerican Energy Company

RCRA Resource Conservation and Recovery Act

U.S.C. United States Code

NN Neal North Energy Center

MWH MWH Americas, Inc.

Neal North – CCR Monofill Inspection Report Summary of Objectives

MidAmerican Energy Company 1-1 Burns & McDonnell

1.0 SUMMARY OF OBJECTIVES

On April 17, 2015, the Environmental Protection Agency (EPA) issued the final version of the Federal

Coal Combustion Residual (CCR) Rule to regulate the disposal of coal combustion residual materials

generated at coal-fired units. The rule is administered as part of the Resource Conservation and Recovery

Act [RCRA, 42 United States Code (U.S.C.) §6901 et seq.], using the Subtitle D approach.

MidAmerican Energy Company (MEC) is subject to the CCR Rule and therefore must have a

Professional Engineer conduct an annual inspection on all CCR Monofills in accordance with 40 CFR

Section 257.84. Burns & McDonnell conducted the 2015 annual inspection of the Neal North Energy

Center (NN) Monofill on October 20, 2015, on behalf of MEC. This report contains the results and

observations of the inspection, as well as any recommended remedial actions. This annual inspection is

the first annual inspection required under the CCR Rule.

Neal North – CCR Monofill Inspection Report Results of Inspection


2.0 RESULTS OF INSPECTION

The primary objective of the annual inspection as described in Section 257.84(b)(1) of the CCR Rule is to

“ensure that the design, construction, operation and maintenance of the CCR unit is consistent with

recognized and generally accepted good engineering standards.” The 2015 annual inspection included

reviewing existing information on the CCR Monofill including previous inspections performed if

available, construction drawings and a current survey. A visual inspection of the CCR Monofill was also

performed and included examining the toe and crest of all slopes, side slopes, hydraulic structures and

other features for any signs of distress or deficient operation of the CCR Monofill. The observations

made from the review of existing information and the visual inspection are provided below.

2.1 Description of Monofill

The NN CCR Monofill is located on the south side of the plant site. Construction drawings prepared by

MWH Americas, Inc. (MWH) were reviewed for a better understanding of the Monofill design and

geometry. The active Monofill includes Cells 1 and 2. Cell 1 was constructed in 2009 and Cell 2 was

constructed in 2013. The liner system is a geocomposite liner consisting of a two (2) feet thick layer of

compacted clay with a permeability of 1 x 10-7 centimeters per second or less overlain by a 60 mil high

density polyethylene geomembrane overlain by geocomposite drainage layer overlain by a two (2) feet

thick layer of leachate collection medium overlain by a geotextile fabric. Leachate is collected by

leachate collection pipes on top of the liner system. The leachate is then pumped to a CCR impoundment

to the north where it is discharged through the permitted outfall.

The final cover system is to consistent of two feet of compacted soil overlain by one foot of uncompacted

soil capable of growing vegetation. The slope of the final cover will be 4H:1V with a maximum crest

elevation for Cells 1 and 2 of 1210 feet. Note that all elevations in this report are referenced to mean sea

level.

At the time of inspection, no portions of the Monofill had temporary or final covers installed. CCR was

placed in Cells 1 and 2 in a relatively flat manner. Some CCR was placed in piles in the south portion of

Cell 2 and the CCR in the northwest portion of Cell 1 was higher than surrounding material.

The Monofill permit application and construction drawings prepared by MWH were reviewed and

accepted by the Iowa Department of Natural Resources (IDNR) in 2007. The construction drawings

reviewed appeared to be in general accordance with conventional Monofill standards.



2.2 Review of Existing Information

Section 257.84(b)(1)(i) of the CCR Rule requires that previous inspections are to be reviewed. Inspection

reports reviewed included the seven-day inspections performed on October 14, 2015 and October 21,

2015 and October 28, 2015. These inspections noted similar observations as this inspection. Since this is

the first annual inspection as required by the CCR Rule, no previous CCR Rule required annual

inspections were available for review. Construction drawings were also reviewed to better understand the

Monofill design and geometry.

2.3 Visual Inspection

Section 257.84(b)(1)(ii) of the CCR Rule requires a visual inspection of the CCR Monofill be performed.

The visual inspection of the Monofill was performed by Burns & McDonnell on October 20, 2015. The

visual inspection involved walking the perimeter of the Monofill, along the working area and along the

crest of the berms. The inspector looked for the following:

Surface cracking along crest or slopes indicating possible movement;

Misalignment of linear features of Monofill, such as the crest or ditches, indicating possible movement;

Displacements (slides, slumps, slips and sloughs) indicating slope instability;

Animal burrows in cover system that creates a preferential flow path for water;

Slope erosion along the berm, cover system or uncovered CCR material;

CCR outside of permitted limits;

Seepage of leachate from Monofill;

Issues with leachate system including no evidence of piping or inadequate flow indicating clogging of system;

Inadequate slope protection such as sparse or patchy vegetation;

Excessive and/or woody vegetation along the cover system;

Debris or mounded CCR on the Monofill that could lead to unaccounted for loading;

Settlement (or depressions) in Monofill that could indicate internal piping of CCR or karstic subsurface;

Drainage features in proper working order including appropriate drainage of surface water;

Signs of vandalism on Monofill.



Based on the observations made at the time of the visual inspection, there was no indication of structural

deficiencies in the Monofill such as surface cracking, misalignment, slope instability or excessive

settlement. In general, the Monofill was flat enough that many of the potential structural deficiencies

were not possible. No excessive and/or woody vegetation, debris or signs of vandalism were observed.

The leachate sumps and leachate outflow were inspected. No excessive sediment or lack of flow was

noted. Drainage features appeared to be in good working condition.

2.4 Approximate Volume of CCR in the Monofill

Section 257.84(b)(2)(ii) of the CCR Rule also requires that the approximate volume of CCR in the

Monofill be estimated as part of this annual inspection report. To determine the volume, MEC contracted

licensed land surveyors at HGM associates on October 26, 2015 to conduct a survey of the Monofill.

The survey provided general dimensions and slopes of the Monofill. The Monofill is relatively flat with

some elevated areas and piling of CCR material occurring in the northwest and south ends of Cell 2

respectively. The maximum height of these elevated areas is 1091 feet. Total CCR in the Monofill was

estimated by HGM Associates, Inc. to be 139,921 cubic yards.

2.5 Changes in the Monofill

Section 257.84(b)(2)(i) of the CCR Rule requires that any changes in geometry be noted since the

previous annual inspection and Section 257.84(b)(2)(iv) of the CCR Rule requires that any changes that

may affect the stability or operation of the CCR Monofill be discussed since the previous annual

inspection. However, since this is the first annual inspection as required by the CCR Rule, there is no

basis for a discussion regarding any possible changes. The geometry appears to be generally in

accordance with the construction drawings.

2.6 Signs of Structural Weakness

Section 257.84(b)(2)(iii) of the CCR Rule requires any appearances of actual or potential structural

weakness or conditions that could disrupt or potentially disrupt operation and safety of the CCR be noted

in the inspection report. During the inspection, there was no indication of structural deficiencies in the

Monofill such as slope instability, excessive settlement, cracking, displacements, or misalignment.

There were some deficient conditions observed. There were multiple animal burrows observed within the

east berm near the leachate collection outlet. One was also observed in the eastern portion of the north

berm. The burrows were in areas of the berm above the CCR in the Monofill. Some erosion was also

noted around utility manholes on the west and north berm crests. Along the southern edge of Cell 1, CCR

material was observed in an area with grass vegetation. This appeared to be outside of the limits of the



waste boundary. However, subsequent conversations with MEC personnel confirmed that the liner

extends beneath this area. Dormant and sparse vegetation was also observed on the outside of the east

berm.

Neal North – CCR Monofill Inspection Report Recommended Remedial Action


3.0 RECOMMENDED REMEDIAL ACTION

Based on observations made at the site during the inspection and documented in Appendix A, remediation

measures to correct sparse vegetative cover, animal burrows, spreading CCR and minor erosion will need

to be performed. The observations and recommended remediation measures were reviewed and discussed

with MEC personnel. The following remedial actions are recommended for the NN CCR Monofill:

Animal burrows along the east and north berms should be backfilled and measures should be

taken to ensure the animals do not continue digging more burrows. Per MEC, these burrows have

been repaired since the visual inspection.

CCR material along the south end of Cell 1 appeared to be outside of the waste boundary. If it is

found to be outside the boundary, the CCR material should be placed back within the Monofill.

A demarcating feature should be installed denoting the extent of the south side of Cell 1. MEC

worked with HGM Associates, Inc. to determine the extent of the Monofill’s composite liner and

temporarily staked out the perimeter boundary. Permanent markers will be installed in the spring.

Based on this work, it was determined that CCR material was fully within the liner boundary.

MEC did note that removal of cemented CCR near the boundary markers on the south side of the

Monofill will be performed in the near future.

For areas of erosion around the utility manholes along the north and west berms, measures should

be taken to limit the erosion in this area. Minor re-grading of the erosion rills will also be

required. Per MEC, this repair will be performed as weather allows.

Vegetation along the outside of the east berm was observed to be dormant and sparse at the time

of inspection and was a different type of vegetation than was seen along the other berms. No

erosion was noted in this area. Additional observation of this area should be made over this

winter and through the spring. If the vegetation does not grow back sufficiently next spring or

erosion is noted, vegetation similar to what is planted on the other berms should be planted next

spring.

Continual monitoring of the leachate system should be performed to confirm there is consistent

flow volume and no clogging of the leachate system is occurring. This monitoring is a part of the

current Leachate Control System Plan and is being performed by MEC. Consistent flow has been

observed from the leachate system.

Neal North – CCR Monofill Inspection Report Limitations of Report


4.0 LIMITATIONS OF REPORT

This report is based on observations made of features that could be visually inspected at the time of the

inspection, construction drawings and survey information provided by MEC. Features not visible at the

surface including liner, leachate collection system, final cover, etc. could not be observed or assessed.

Construction drawings prepared by MWH and accepted by the IDNR were reviewed to gain an

understanding of the Monofill design and geometry. No assessment or confirmation of the design was

performed as part of this inspection. No subsurface information, construction quality assurance

documents or operational placement records were reviewed as part of this inspection. An assessment of

the adequacy and state of any groundwater monitoring wells, gradients or water quality was not a part of

this inspection.

Any recommended remedial action or further monitoring noted in this report is assumed to be performed

by MEC in a timely fashion and monitored by MEC on the required seven-day inspection schedule

currently being performed.

APPENDIX A – CCR MONOFILL INSPECTION CHECKLIST AND PHOTO LOG

EPA - Disposal of Coal Combustion Residuals (CCR) from Electric Utilities Final Rule Regulatory Compliance Inspection - 40 CFR § 257.84 CCR Monofill Annual Inspection Checklist Form

Facility Name MidAmerican Energy Company - Neal North Energy Center

CCR Landfill Name Monofill

Date of Annual Inspection 10/20/2015

Date of Prior Annual Inspection n/a

Name of Qualified Inspector (performing inspection) (print) Nathan Textor, P.E.

(signature)

Weather Conditions r

Sunny, 70 degrees

Inspector Observations

Were Any Issues

Observed in Current

Inspection?

Status as Compared to Last Inspection

Condition Items (Identify location of observation on attached site plan and approximate dimensions of any issues noted. Additional comments should be included at bottom of inspection, as needed.)

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Erosion Limited areas around utility manholes, dead vegetation along east berm X

Woody Vegetation X 03 i— 13

Trees X O =3 s_

Berm Slide/Slough X -t—• CO

Animal Burrows Multiple burrows found near leachate pipe outlet on east side of site and one on east side of north berm

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Cracks X

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Waste Material Outside Unit Footprint

CCR was found to appear to be outside of the waste boundary along the south side of Cell 1 X

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Monitoring Wells (Managed or Operating Improperly)

X

Page 1 of 2

EPA - Disposal of Coal Combustion Residuals (CCR) from Electric Utilities Final Rule Regulatory Compliance Inspection – 40 CFR § 257.84 CCR Monofill Annual Inspection Checklist Form

Page 2 of 2

Leachate Collection System (Managed or Operating Improperly)

X

Place a checkmark here if photographic log and photos are attached to this inspection form. Comments:

Multiple animal burrows were observed within the east berm of the monofill near the leachate pipe outlet.

Another animal burrow was also observed on the east side of the north berm. Along the southern edge of

Cell 1, there is some spreading of CCR that appears to be outside of the landfill boundary. Around the

outside of the berm on the west and north sides, there was erosion noted in areas of utility manholes.

The vegetation along the east berm was dead. .

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Animal burrows

CCR outside boundaries

Minor erosion

Patchy/dead vegetation

IMG 449

IMG 450

IMG 453

IMG 466

IMG 469

IMG 483

IMG 490 - north ~1500 feet

IMG 468

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Neal North Energy Center CCR Monofill Inspection Areas of Concern BMcD Project No. 86609

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Prepared by: Nathan Textor, P.E. Date: 11/20/2015

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EPA - Disposal of Coal Combustion Residuals (CCR) from Electric Utilities Final Rule Regulatory Compliance Inspection – 40 CFR § 257.84 CCR Monofill Photographic Log

Photograph Number: IMG-0449

Description of Photograph: Looking across landfill from the northeast corner, facing southwest

Facility Name MidAmerican Energy Company - Neal North Energy Center

CCR Landfill Name Monofill

Date of Inspection 10/20/2015

Date of Last Prior Inspection n/a

Name of Qualified Inspector (performing inspection)

(print) Nathan Textor, P.E. (signature)

Weather Conditions Sunny, 70 degrees



Description of Photograph: Looking along east berm, facing south


Description of Photograph: Animal burrow near leachate pipe outlet in east berm



Description of Photograph: Ash spread outside of waste boundary from south side of Cell 1, facing south


Description of Photograph: Erosion around utility manhole near leachate pipe outlet on west berm, facing south



Description of Photograph: Minor erosion on outside of north berm, facing south


Description of Photograph: Leachate outflow into Pond 3A (clear)



Description of Photograph: Looking along west berm, facing north


Description of Photograph: Looking along outside of north berm, facing west

APPENDIX B - SURVEY RESULTS

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APPENDIX C - CONSTRUCTION DRAWINGS

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APPENDIX D - EXCERPT FROM CCR RULE (§257.84)

21482 Federal Register / Vol. 80, No. 74 / Friday, April 17, 2015 / Rules and Regulations

following the date of initial receipt of CCR in the CCR unit.

(4) Frequency of inspections. (i) Except as provided for in paragraph (b)(4)(ii) of this section, the owner or operator of the CCR unit must conduct the inspection required by paragraphs (b)(1) and (2) of this section on an annual basis. The date of completing the initial inspection report is the basis for establishing the deadline to complete the first subsequent inspection. Any required inspection may be conducted prior to the required deadline provided the owner or operator places the completed inspection report into the facility’s operating record within a reasonable amount of time. In all cases, the deadline for completing subsequent inspection reports is based on the date of completing the previous inspection report. For purposes of this section, the owner or operator has completed an inspection when the inspection report has been placed in the facility’s operating record as required by § 257.105(g)(6).

(ii) In any calendar year in which both the periodic inspection by a qualified professional engineer and the quinquennial (occurring every five years) structural stability assessment by a qualified professional engineer required by §§ 257.73(d) and 257.74(d) are required to be completed, the annual inspection is not required, provided the structural stability assessment is completed during the calendar year. If the annual inspection is not conducted in a year as provided by this paragraph (b)(4)(ii), the deadline for completing the next annual inspection is one year from the date of completing the quinquennial structural stability assessment.

(5) If a deficiency or release is identified during an inspection, the owner or operator must remedy the deficiency or release as soon as feasible and prepare documentation detailing the corrective measures taken.

(c) The owner or operator of the CCR unit must comply with the recordkeeping requirements specified in § 257.105(g), the notification requirements specified in § 257.106(g), and the internet requirements specified in § 257.107(g).

§ 257.84 Inspection requirements for CCR landfills.

(a) Inspections by a qualified person. (1) All CCR landfills and any lateral expansion of a CCR landfill must be examined by a qualified person as follows:

(i) At intervals not exceeding seven days, inspect for any appearances of actual or potential structural weakness

and other conditions which are disrupting or have the potential to disrupt the operation or safety of the CCR unit; and

(ii) The results of the inspection by a qualified person must be recorded in the facility’s operating record as required by § 257.105(g)(8).

(2) Timeframes for inspections by a qualified person—(i) Existing CCR landfills. The owner or operator of the CCR unit must initiate the inspections required under paragraph (a) of this section no later than October 19, 2015.

(ii) New CCR landfills and any lateral expansion of a CCR landfill. The owner or operator of the CCR unit must initiate the inspections required under paragraph (a) of this section upon initial receipt of CCR by the CCR unit.

(b) Annual inspections by a qualified professional engineer. (1) Existing and new CCR landfills and any lateral expansion of a CCR landfill must be inspected on a periodic basis by a qualified professional engineer to ensure that the design, construction, operation, and maintenance of the CCR unit is consistent with recognized and generally accepted good engineering standards. The inspection must, at a minimum, include:

(i) A review of available information regarding the status and condition of the CCR unit, including, but not limited to, files available in the operating record (e.g., the results of inspections by a qualified person, and results of previous annual inspections); and

(ii) A visual inspection of the CCR unit to identify signs of distress or malfunction of the CCR unit.

(2) Inspection report. The qualified professional engineer must prepare a report following each inspection that addresses the following:

(i) Any changes in geometry of the structure since the previous annual inspection;

(ii) The approximate volume of CCR contained in the unit at the time of the inspection;

(iii) Any appearances of an actual or potential structural weakness of the CCR unit, in addition to any existing conditions that are disrupting or have the potential to disrupt the operation and safety of the CCR unit; and

(iv) Any other change(s) which may have affected the stability or operation of the CCR unit since the previous annual inspection.

(3) Timeframes for conducting the initial inspection—(i) Existing CCR landfills. The owner or operator of the CCR unit must complete the initial inspection required by paragraphs (b)(1) and (2) of this section no later than January 18, 2016.

(ii) New CCR landfills and any lateral expansion of a CCR landfill. The owner or operator of the CCR unit must complete the initial annual inspection required by paragraphs (b)(1) and (2) of this section no later than 14 months following the date of initial receipt of CCR in the CCR unit.

(4) Frequency of inspections. The owner or operator of the CCR unit must conduct the inspection required by paragraphs (b)(1) and (2) of this section on an annual basis. The date of completing the initial inspection report is the basis for establishing the deadline to complete the first subsequent inspection. Any required inspection may be conducted prior to the required deadline provided the owner or operator places the completed inspection report into the facility’s operating record within a reasonable amount of time. In all cases, the deadline for completing subsequent inspection reports is based on the date of completing the previous inspection report. For purposes of this section, the owner or operator has completed an inspection when the inspection report has been placed in the facility’s operating record as required by § 257.105(g)(9).

(5) If a deficiency or release is identified during an inspection, the owner or operator must remedy the deficiency or release as soon as feasible and prepare documentation detailing the corrective measures taken.

(c) The owner or operator of the CCR unit must comply with the recordkeeping requirements specified in § 257.105(g), the notification requirements specified in § 257.106(g), and the internet requirements specified in § 257.107(g).

Groundwater Monitoring and Corrective Action

§ 257.90 Applicability. (a) Except as provided for in § 257.100

for inactive CCR surface impoundments, all CCR landfills, CCR surface impoundments, and lateral expansions of CCR units are subject to the groundwater monitoring and corrective action requirements under §§ 257.90 through 257.98.

(b) Initial timeframes—(1) Existing CCR landfills and existing CCR surface impoundments. No later than October 17, 2017, the owner or operator of the CCR unit must be in compliance with the following groundwater monitoring requirements:

(i) Install the groundwater monitoring system as required by § 257.91;

(ii) Develop the groundwater sampling and analysis program to include selection of the statistical

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Annual CCR Monofill Inspection - Berkshire Hathaway Energy...Energy Center Final January 18, 2016 ....

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