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HomeMy WebLinkAboutElnitski to Skvarla - Excavation Plans for four priority sites_20141113John Elnitsky Senior Vice President Ash Basin Strategy DUKE ENERGY® November 13, 2014 John E. Skvarla, III Secretary North Carolina Department of Environment & Natural Resources Mailing: 1636 Mail Service Center 217 W. Jones Street Raleigh, NC 27699-1636 Dear Secretary Skvarla: 550 South Tryon Street DEC 22C Charlotte, NC 28202 Mailing Address: P.O. Box 1321 Charlotte, NC 28201 0:704.382.4371 Once Of the s/Dretp ry NOV 13 2014 bapamnslv 110votur01t5n lronme t`Ai asoarces As requested in the letter from the North Carolina Department of Environment and Natural Resources (NC DENR) to Duke Energy dated August 13, 2014, Duke Energy is submitting the attached Coal Ash Excavation Plans for Riverbend Steam Station, Dan River Steam Station, L.V. Sutton Electric Plant, and Asheville Steam Electric Generating Plant. In general, these Excavation Plans cover the first 12 — 18 months (Phase 1) of ash basin excavation activities, including site preparation, ash basin preparation, the initiation of basin dewatering, and ash removal from the basins. These plans will normally be updated and submitted to NC DENR annually or earlier as required by Subsequent Phase(s). These plans also represent the activities necessary to satisfy the requirements outlined in Sections 3(b) and 3(c) Subparagraph 1 &2 of the Coal Ash Management Act of 2014. Each Excavation Plan details what Duke Energy considers to be the necessary permits to begin work or facilitate subsequent phases of work. Integral to the success of the Excavation Plans is the timely receipt of permits, including industrial stormwater, National Pollutant Discharge Elimination System, landfill, structural fill and mine reclamation permits where applicable. The objective of these excavation efforts is to achieve ash basin closure in a reasonable, prudent, and cost effective manner. The initial phases of these Excavation Plans will incorporate off -site transportation and disposition options, which are generally more costly than the utilization of on -site, lined landfills. Initial use of offsite solutions is necessary for the Company to meet the deadlines prescribed in the Coal Ash Management Act of 2014 for High Priority sites. Timely receipt of landfill permits will enable the Company to expeditiously transition from more costly off -site storage locations at sites where these landfills are practical. We are prepared to implement these Excavation Plans upon receipt of NC DENR written approval of these plans and necessary permits. 7nE_InitskP'..i',.", Asheville Steam Electric Generating Plant Coal Ash Exca►►ation Plan (� DUKE �, ENERGY Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 Table of Contents I. Statement of Purpose...................................................................................................................2 II. General Facility Description.........................................................................................................3 III. Project Charter...............................................................................................................................6 IV. Critical Milestone Dates................................................................................................................8 V. Level 1 Schedule...........................................................................................................................9 VI. Erosion and Sedimentation Control Plan................................................................................10 VII. Dewatering Plan..........................................................................................................................10 Vill. Proposed Location(s) for Removed Ash..................................................................................11 IX. Transportation Plan.....................................................................................................................12 X. Environmental Permitting Plan..................................................................................................12 XI. Contracting Strategy...................................................................................................................15 XII. Environmental, Health, and Safety Plan..................................................................................15 XIII. Communications Plan.................................................................................................................16 XIV. Glossary........................................................................................................................................17 XV. Reference Documents................................................................................................................19 1 Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 I. Statement of Purpose Duke Energy (Company) is required by Section 3(b) of the Coal Ash Management Act of 2014 to close in accordance of Section 3(c) the coal combustion residuals (CCR) surface impoundments located at the Asheville Steam Electric Generating Plant Buncombe County (Asheville or Plant) as soon as practicable, but not later than August 1, 2019. This Coal Ash Excavation Plan (Plan) for Asheville documents key activities as requested by North Carolina Department of Environment and Natural Resources (NC DENR), Division of Water Resources (DWR) stated in a letter to Duke Energy dated August 13th, 2014 (NC DENR Letter). The Plan represents Phase I and subsequent phase(s) to satisfy the requirements outlined in Section 3(b) and 3(c) Subparagraphs 1 &2 of the Coal Ash Management Act of 2014. In general, Phase 1 of the Plan addresses the first 12 —18 months of ash basin excavation activities. For Subsequent Phase(s), this document will be revised for any modifications to the Plan. The Plan will be updated and submitted to NC DENR at least annually or earlier as required by Subsequent Phases. The NC DENR Letter specifically requests that the Plan includes 1) a schedule for soil and sedimentation erosion control measures, 2) dewatering, and 3) the proposed location(s) of the removed ash. These requirements are found in Section V. Level 1 Schedule, Section VI. Erosion and Sedimentation Control Plan, Section VII. Dewatering Plan, and Section VIII. Proposed Location(s) for Removed Ash. The Plan covers some of the work required by Sections 3(b) and 3(c) of the Coal Ash Management Act of 2014 (Session Law 2014-122) (Coal Ash Act, or Act). The Act requires the closure of the ash basins as soon as practicable, but no later than August 1, 2019. However, the Act contains no requirement for the submittal of an excavation plan of the kind presented here. Thus, while the formulation, submittal, and review of this Plan will assist in Duke Energy's work to close the ash basins, its ultimate approval is an action not specifically required by statutory, regulatory or other applicable authority. Additionally, it may become necessary for the Company to modify the Plan to address other legal requirements or factors that develop during ash basin excavation. Any changes will be included in annual updates to the Plan that Duke Energy will submit to NC DENR. The precise scope of work in excavating the ash basins will be determined by applicable laws, rules, permits, and approvals that control the activities to be performed under the Plan. For example, the United States Environmental Protection Agency (EPA) is considering issuing rules regarding the management of coal ash (proposed EPA Coal Ash Rules). Similarly, the water quality permit for the discharge from the basins Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 (National Pollutant Discharge Elimination System Permit No. #NC0000396 Buncombe County) or its reissuance or amendment (NPDES Permit) could contain terms that control or affect the scope of that work. DENR filed legal cases in Superior Court (DENR Cases), which could be resolved through decision or settlement. DENR also sent Duke Energy Notices of Violation (NOVs) regarding surface water and groundwater quality issues at the Plant. All of the above (Coal Ash Act, NC DENR Letter, NPDES Permit, DENR Cases, NOVs and the proposed EPA Coal Ash Rules) are illustrative of actions that could potentially affect the precise scope of the work to be performed under the Plan. As a consequence, neither the submittal of this Plan nor its approval by DENR should be taken as requiring actions different from other such applicable requirements. Thus, Duke Energy submits this Plan to DENR based on the understanding that it may be necessary to make changes in the Plan in the future to reflect any such actions and reserves the right to make such changes after DENR's approval of the Plan. II. General Facility Description The Plant is located in Arden, NC, approximately eight (8) miles south of Asheville, NC. Asheville Plant's Unit 1 was constructed in 1964 with a second coal burning unit (Unit 2) added in 1971. Current generation capacity of the plant is 376 megawatts (MW) from two (2) coal fired units. In 1999 and 2000, two (2) natural gas and oil combustion turbines (CT) with an additional output of 324 MW were added. YEAR (net MW) COMBINErP 1 Coal Fired Steam 1964 191 376 1971 185 2 3 Natural Gas and Oil 1999 162 1999 162 324 4 Combustion Total 700 The Plant has two (2) ash storage basins. The first basin was created in 1964 when the plant began operations. In 1982 a second basin was constructed and placed into operation directly adjacent to the 1964 basin's south retention dam. 1964 Ash Basin The 1964 Ash Basin Dam (Bunco-097) was constructed in 1964 to serve as a wastewater treatment facility for the treatment of ash sluice water. The surface area of the basin is approximately 45 acres. The basin does not retain a permanent pool with the exception of a three (3) acre unlined retention pond known as the "Duck Pond". In 2005, engineered and lined wetlands were constructed within the 1964 basin footprint to treat flue gas desulfurization (FGD) process wastewater. Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 Currently, production ash is sluiced to a concrete rim ditch system that is located within the footprint of the 1964 basin. The rim ditch system also receives plant stormwater drainage and low volume wastewater. Coal combustion residuals are dredged from the rim ditch, dewatered, and transported offsite to a structural fill project at the Asheville Regional Airport approximately two (2) miles from the plant. The wastewater from the rim ditch process is treated in the lined rim ditch system and then routed to the Duck Pond area within the 1964 basin for further treatment prior to discharge to a small settling pond outside of the 1964 dam. This settling pond serves as the monitoring point for Outfall 001 of the plant's NPDES permit (NC0000396). Treated water discharged from this settling pond is routed directly to the French Broad River. The 1964 Ash Basin is estimated to contain approximately 2.3 million tons of ash. 1982 Ash Basin In response to the filling of the 1964 ash basin in the late 1970s, a second basin was constructed in 1982 with the establishment of a dam (Bunco-089) in the adjacent valley of the 1964 ash basin. The 1982 ash basin reached capacity in the early 2007 timeframe. In an effort to continue plant operations an ash harvesting plan was developed to increase ash storage capacity. The 1982 basin has been dewatered and is currently being excavated in accordance with the Asheville Plant's ash reuse permit (Distribution of Residual Solids (503 Exempt) Permit Number WQ0000020). The harvested ash is transported to the Asheville Regional Airport for a structural fill project for its taxiway infrastructure. Currently, inflows into the 1982 ash basin consist of stormwater that collects naturally on the basin. Stormwater collected at the combustion turbine area of the Asheville Plant, adjacent to the coal-fired units, is also pumped into the basin. Water collected in the basin is pumped to the head of the rim ditch system where it is treated prior to discharge via Outfall 001. As of September 30, 2014, the 1982 Ash Basin contains approximately 867 thousand tons of ash remaining from an original inventory of approximately 3.7 million tons. 4 Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 Figure 1: Asheville Steam Electric Generating Plant Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 III. Project Charter As a further commitment, Duke Energy has formed an internal team, the Ash Basin Strategic Action Team (ABSAT). This team is dedicated to executing a comprehensive strategy for increased oversight and excavation of all of the Company's ash basins. Dewatering of the ash basins and the removal of ash from the site will be performed within project phases, Phase I and Subsequent Phase(s). Phase I will include the removal of remaining ash in the 1982 basin, dewatering of the rim ditch system and engineered wetlands that lie within the footprint of the 1964 ash basin, and completion of any subsequent permitted activities. During Phase I, the Company will continue to perform the pre -construction and planning activities for the Subsequent Phase(s). These activities include project planning, development of new disposal or beneficial reuse options, and completion of the required permitting for the ash removal from the ash basins. Knowledge and opportunities for program improvement obtained during Phase I of the project will be applied to the Subsequent Phase(s). Project Charter Objectives Phase I Objectives 1. Complete removal of ash in the 1982 Ash Basin 2. Identify disposition of rim ditch, lined retention pond, and engineered wetlands in the 1964 Ash Basin 3. Submit and obtain permits for Phase I activities 4. Evaluate, procure, design, construct and commission alternative waste water treatment methodologies to replace the wetlands and rim ditch system within the 1964 basin 5. Evaluate, select, design, build and commission an alternate treatment method to treat FGD process water to replace engineered wetlands process 6. Decommission, dewater, and demolish existing rim ditch system and wetlands in the 1964 Ash Basin 7. Plan activities for Subsequent Phase(s) 8. Continue developing option(s) for proposed location(s) for removed ash for the Subsequent Phase(s) 9. Validate production rates to meet project requirements 10. Gain knowledge and opportunities for program improvement that can be applied to the Subsequent Phase(s) Subsequent Phase(s) Objectives 1. Dewater the unlined retention pond (Duck Pond) 2. Remove ash from the 1964 basin 6 Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 3. Decommission, dewater, and demolish the rim ditch system in the 1982 Ash Basin 4. Perform ash basin closure activities Project Charter Scope Phase I Scope 1. Continue excavation of ash from the 1982 Ash Basin to the permitted structural fill project at the Asheville Regional Airport utilizing current contractor 2. Obtain all applicable permits for work in Phase 1 3. Determine the contents of the engineered wetlands to determine disposal options for the spoil materials 4. Engineer, build and commission a new rim ditch and primary and secondary lined retention pond in the 1982 Ash Basin 5. Engineer, build and commission an alternate treatment methodology to replace the engineered wetlands outside of the ash basins 6. Decommission, dewater and demolish rim ditch system and wetlands in the 1964 Ash Basin 7. Initiate excavation of ash in the 1964 Ash Basin 8. Finalize planning for the dewatering of the unlined retention pond 9. Continue developing beneficial reuse opportunities and placement alternatives for subsequent phase ash removal of the 1964 basin 10. Finalize decision for need of onsite landfill in 1982 ash basin 11. Submit and/ or obtain all remaining required permit applications for ash removal activities for Subsequent Phase(s) Subsequent Phase(s) Scope 1. Prepare all remaining required permit applications for next Subsequent Phase for ash removal activities (if applicable) 2. Finalize and/or develop additional location(s) for removed ash (if applicable) including obtaining all required permits 3. Excavate and transport the remaining ash from Asheville to an approved landfill or structural fill location 4. Decommission, dewater and demolish the rim ditch and primary and secondary lined retention ponds in the 1982 Ash Basin 5. Complete closure activities as outlined in in Sections 3(b) and 3(c) Subparagraphs 1 &2 of the Coal Ash Management Act of 2014 7 Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 IV. Critical Milestone Dates Critical Milestones within the Plan are summarized in the table below. These milestones have been added to the Level 1 Schedule. MILESTONES i1M. Submit Excavation Plan NO LATER THAN DATE November 15, 2014 Complete comprehensive engineering review November 30, 2014 Receive Dam Safety Permit to excavate 1982 Ash Basin dam face December 12, 2014 Receive updated DORS Permit February 28, 2015 Receive NPDES permit modification for Rim Ditch System July 2, 2015 Commission new 1982 rim ditch, primary and secondary retention ponds July 17, 2015 1964 Rim Ditch demolished and begin excavation of 1964 basin September 1, 2015 Complete removal of ash from 1982 basin (except interim storage of production ash September 15, 2015 Decommission Engineered Wetlands and Commission alternate FGD Wastewater Treatments stem November 3, 2015 Dewater and Demolish Engineered Wetlands March 2, 2016 Submit Updated Excavation Plan for Subsequent Phases Annually Convert Units 1 & 2 to "dry" fly ash handling December 31, 2018 Impoundments closed per Sections 3.(b) and 3.(c) of the Coal Ash Management Act of 2014 August 1, 2019 Convert Units 1 & 2 to "dry" bottom ash handling December 31, 2019 At facilities actively producing CCR, end storm -water discharge into impoundments December 31, 2019 9 Asheville Steam Electric Generating Plant —Coal Ash Excavation Plan November 13, 2014 V. Level 1 Schedule ASHEVILLE EXCAVATION PLAN Print Date 04-Nov-1415:25 LEVEL 1.5 SCHEDULE "AshevilleAshon n na Dur 2o1s 66 2011 o1a0zozo On D'. 02 Da qn ❑-. ❑0 Dt ci� QO4 22 q1 3 D4 O+ 02 Oa O4 q+ D2 09 O4 1 GENERALPd I- I l I i I tad DORS 0.od: Fag 15 Permn i ♦ S—Ne uodatad ORS %e 1 I _ 9a2 R'm IXlj Au 1 NPIDEt Perm1Needed (Admin Matl 19 Rlm Ditch) �m Fiplete l .FAA ructural Flll Requ rem9M j i �.. ICI - -- - i DryFtrAsh Co IPer O0tl a1-Daec�18 Y 1 - _._�.. ______.._. -... DrV Fly As. ....... . .. .... ... �2 CAMA2014) Lat u n ts/ - Nu.. OOd, v01 Au919W 1I(�Perrts Glas N.W rThan&1/19 (Par CAM A - l End Storm Water 0.O ; 31-0ec-18'. f Disoharpo lnlo Basin (mr 1y T Entl 61arm Nlater Db har9e Into Basin (per C6 CANfA 2014) Dwe9i ,o hcp plate. aw 01-Dec-t9' ( CAMA2014) I i j Dry Bo[tom Ash Comp le(per CAMA 2014) „- 1982 ASH BASIN j reezR 1 F*^ aeon- Jan-oeA 16 saris -._..- _. -is-........... 19a2B in Dam Sately _W 2&Cct-14A 12-1Dec-14 I t'_7 1962 Bas n- am Sal Pernl Revlaw SAppr�val , Revlew&Approval j H2 R Di1cM1 21 0tl 03Mar-15 02-Jul-15' 1 992 Nlm OhcM Conal/ otpn N Rim WC!, Intl Ret Pond 1 NMPOttES� 930a 3t-Mar-15 0 -JUF16 PDESP 11 Modlfical IAd Mod Rm Duty fn Motl 1 19B2ftsnDyck O.Op 1902B In Camplatbn o6d S P-15 - n ComPlelrun Pf h Removal to hR m - ExcavanoN PLAN C it E avatanP Develop 600tl rt-Aug- q 12 Nov 14 Fcava[on Plan Devela I I ; E�avallon Pbt Submit O.Od, .12-Nov-t4' av a[ion Plan-Sutxnh j E valion Plan- 90.Od 12-Nov-1 !'10-Feb-15 NCDENRR law/ E%<avetbn Plan- 6 CDENR Review/Appral 1964 ASH __ 1 ..... .......... ...... _._ __...-I....... ....--- ++ 1 WWT �ma T A1bma419 Deveb(�men[ aBASIN - i- WWT-Permhtln9 201M 14Mar-15 pOct-16 T rmitltl P1 j W ♦JFGD l ----- WWta__re.i_nllWga_ -D DOO._nn&d T lm41A.—lvevMebm.pI1— ! Wrs 10dDN6 FFF�DGGGa -'-- -- .. - .. ... ... ..... --'- ...fI1I FGD 4Yed baen&D- . __. __......... ...... _... ..-. _..... !)• ' D of 0Mr6 & Demo C k:te ^ mpRLM Wd, w&DmCo 1984 - Ewavaibn of O:Od 02-Mar-16 W etland. D k Pond 1964 - Esavalbrtli d W etlands & Duck P Itl Available f Note: This Level 1 Schedule is a living element of this Plan. Dates and durations are based on known information at the date of this Plan. Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 Vi. Erosion and Sedimentation Control Plan Current excavation is being performed under the Distribution of Residual Solids (503 Exempt) Permit (WQ0000020) issued by the NCDENR Division of Water Quality. The permit, in Section 11.7, provides "Adequate provisions shall be taken to prevent wind erosion and surface runoff from conveying ash from stockpile/storage areas onto adjacent property or into any surface waters prior to distribution and use. The Permittee shall provide to the recipient of the ash a copy of the most -recent version of the Material Safety Data Sheet (MSDS) for the ash as well as the most -recent version of the Permittee's Document No. EVC-FGDC-00101 "Ash Utilization Plan" so that the recipient of the ash is aware of guidance regarding how to take adequate provisions to prevent wind erosion and surface runoff from conveying ash from the location of use onto adjacent property or into any surface waters." Asheville Plant site conditions allow for the excavation and transport of ash on existing paved roads. No new construction is anticipated for continued ash excavation for either the 1982 or the 1964 ash basins. Should any construction be needed that disturbs more than one acre, the appropriate permits will be obtained. Vil. Dewatering Plan The 1982 Ash Basin is currently void of free-standing water. However, current water inflows into the ash basin continue as described earlier. Water is captured and pumped to the head of the rim ditch wastewater treatment system within the footprint of the 1964 Ash Basin. The focus of dewatering of the 1964 Ash Basin consists of removing the current wastewater streams in the engineered wetlands that treat FGD process water, the rim ditch system, and the unlined retention pond (Duck Pond area) that serves as the permitted wastewater treatment system for the plant's production ash. These elements must cease to treat wastewater, be decommissioned, and be demolished in order to facilitate ash excavation of the 1964 ash basin. During Phase I, an evaluation of alternatives to treat all waste water streams will inform needed permitting activities specifically related to the existing NPDES permit. Once any needed permits are obtained, the alternate treatment system must be commissioned in order to abandon the current rim ditch and engineered wetlands systems. Phase 1 will culminate in decommissioning and demolition of the rim ditch and engineered wetlands system. The unlined retention pond will then be dewatered through current operational processes. All water will be treated prior to discharge through an updated NPDES permit. 10 Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 VIII. Proposed Location(s) for Removed Ash Phase is Ash Disposition Site Phase I of ash removal from the Asheville Plant will include excavation and removal of the remaining 867 thousand tons of ash from the 1982 Ash Basin. The ash will be transported approximately two (2) miles from the Plant to the Asheville Regional Airport where it will continue to be placed into a permitted lined structural fill area developed and managed by the excavating contractor, Charah. Should the structural fill opportunity become unavailable, alternate ash disposition sites, including disposal in permitted municipal landfills, will be identified during Phase I. These sites, to date, have not been determined. Currently, a study has been commissioned to identify potential areas of ash disposal within a 25 mile radius of the Asheville Plant. This study will be finalized in November 2014. This study will also inform potential disposal locations for all, or a portion of, the 2.3 million tons of ash in the 1964 basin. Subsequent Phase(s): Ash Disposition Sites Currently, two potential beneficial reuse opportunities have been identified for ash disposition during the subsequent phase(s) of ash excavation. Duke Energy, and their vendor Charah, have identified another structural fill opportunity at the airport and are working toward finalizing details of the project. The opportunity will not provide adequate capacity for all of the ash in the 1964 Ash Basin. However, the beneficial use opportunity may be utilized as an element of the overall ash basin excavation strategy. The second opportunity, construction of a lined structural fill or landfill in the soon -to - close 1982 Ash Basin, will be evaluated with other potential placement sites that will be identified during Phase I. Asheville Regional Airport Arden, NC ±1.7M Structural Fill On -Site Structural Fill or Asheville Plant 550k — 2.25M Lined Landfill or Lined Landfill Structural Fill 11 Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 IX. Transportation Plan Phase I Ash from the 1982 basin will continue to be transported by Charah from the plant to the Asheville Regional Airport via double -axle trucks. The haul is approximately two (2) miles each way and the current tonnage equates to approximately 200 truckloads per day. At peak of excavation in spring and summer 2015, tonnage hauled would equate to approximately 280 truckloads per day. Current transportation policies and standards will remain in place through final excavation and will continue to meet Department of Transportation (DOT) and other applicable federal, state, and local regulations. All drivers will follow all DOT regulations pertaining to the trucking, including DOT bridge laws. Subsequent Phase(s) For subsequent phase(s), the transportation plan will be evaluated and reviewed to provide any improvements discovered in Phase I or the previous Subsequent Phase. These options may include continued trucking or moving ash by rail. X. Environmental Permitting Plan Phase I Phase 1 will include continued excavation and removal of ash from the 1982 ash basin to the Asheville Airport. Phase 1 will also include removal of the 1964 Basin Engineered FGD Wetlands. Implementation for Phase I will continue under the current DORS and NPDES permit. Phase I will include permitting activities for subsequent phases. Through the Excavation Plan approval process, Duke Energy is seeking to confirm that all necessary approvals have been identified for subsequent phase(s). The Excavation Plan is intended to authorize the excavation and movement of ash once the identified permits have been obtained. Excavation of ash creates potential for stormwater impacts. The facility holds an NPDES stormwater permit and a stormwater pollution prevention plan (SWPPP). Future modifications to the permit/plan will be managed as necessary. Throughout the project, all necessary Dam Safety approvals will be obtained to cover activities on or around jurisdictional dams. During Phase I, it is anticipated that ash removal along the 1982 Ash Basin dam interior face will require review by the Division of Energy, Mineral and Land Resources. Subsequent phases will assume the same review for excavation work along the 1964 Ash Basin dam face. 12 Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 There are no jurisdictional wetlands/streams associated with the removal of ash in the 1982 ash basin and the 1964 ash basin in Phase I. Future jurisdictional determinations will be managed through the US Army Corps of Engineers with particular attention paid to the difference between jurisdictional wetlands/streams under Section 404 and those arising from Section 402 waters. Subsequent Phase(s) Subsequent Phases will include dewatering (once NPDES permit modification complete) and excavation and removal of ash from the 1964 ash basins. Excavation of ash creates potential for stormwater impacts. The facility holds an NPDES Stormwater permit. The primary method to manage stormwater discharges is the use of best management practices (BMPs), which are incorporated in the NPDES permit and the stormwater pollution prevention plan (SWPPP). Future modifications to the permit/plan will be managed as necessary. Based on suggestion from NC DENR and US EPA, modification of the NPDES wastewater permit may be necessary to initiate removal of free-standing water from inactive ash basins. Removal of other water (sometimes referred to as pore water) is likely to require NPDES permit modification. Future jurisdictional determinations will be managed through the US Army Corps of Engineers with particular attention paid to the difference between jurisdictional wetlands/streams under Section 404 and those arising from Section 402 waters. Any Section 404 permitting will require Section 401 Water Quality Certification by DENR. If the Company pursues an on -site landfill solution for ash placement during subsequent phase(s), site suitability approvals (Site Suitability Report, Required Public Comment, DWM Approval of Site Suitability), Permit -to -Construct (Construction Plan Application, Receive Permit -to -Construct from DWM), and Permit -to -Operate (Construction Quality Assurance Report, Receive Permit -to -Operate) will be obtained. If the Company chooses to utilize a mine reclamation solution for ash placement during subsequent phase(s), an individual structural fill permit will need to be obtained by the mine reclamation project owner/operator. It is anticipated that the mining permit will be transferred from the existing mine owner to a mine reclamation contractor. Once the permit is transferred, the mine reclamation contractor will submit an individual structural permit application and mine reclamation plan to the Division of Mining. It is anticipated that the Division of Mining will then forward the reclamation plan to the Division of Water Resources, Division of Waste Management, and other divisions as necessary for comments. Subject to any changes from Division of Mining, the revised reclamation plan would be approved and an individual Structural Fill Permit will be issued. 13 Asheville Steam Electric Generating Plant —Coal Ash Excavation Plan November 13, 2014 If used, before shipping ash to a third -party Subtitle D landfill, waste characterization and approval will be completed. All necessary Dam Safety approvals will be obtained to cover activities on or around jurisdictional dikes. Breaching of the dikes will require Dam Safety approval. Any impacted wells or piezometers will be properly abandoned and dispositioned with NC DENR. Fugitive dust will be managed to mitigate impacts to neighboring areas. Impacts to threatened and endangered species will be avoided. Subsequent Phases Permit Matrix Media Permit Milestone/Targot Date Reasoning Excavation of ash creates potential for stormwater impacts. The facility holds an NPDES Stormwater permit. The primary method to control stormwater discharges is the use of best Industrial Stormwater Permit 5/29/2015 management practices (BMPs) which are incorporated in the NPDES permit and the stormwater pollution prevention plan (SWPPP). Future modifications to the permit/plan will be managed as necessary. DENR has indicated dewatering activities, including free water removal, Water Wastewater NPDES Permit may require NPDES wastewater permit Modification 12/31/2015 modification. Based on this, Duke is submitting proposed dewatering permit conditions in its pending NPDES permit application. Identify if project scope results in impacts to jurisdictional wetlands or streams. Obtain JD and pursue 404 Jurisdictional Wetland and Stream permit for impacts from the ACOE. Also, Impacts/404 Permitting and 401 10/30/2015 404 permits are required for working WQC below the ordinary high water mark. If Federal permitting is required, obtain 401 WQC. There are no identified jurisdictional wetland/stream impacts in Phase I. Mine Reclamation Owner/Operator to Individual Structural Fill Permit 5/29/2015 obtain a structural fill permit as set forth in Subpart 3 of Part 21 of Article 9 of the Coal Ash Management Act Hauling and excavation activities must not impact a jurisdictional dam or dike. Dam Safety Approvals 10/30/2015 Activities are initially staying 50 It away from the jurisdictional dike. Breaching Waste of dike will require Dam Safety approval. Site Suitability Report 9/30/2016 Site Suitability anticipated for offside landfill must go through public comment Must receive permit to begin Permit -to -Construct 212412017 construction and corresponding E&SC approval to cover approved Construction design Must provide Construction Quality Permit -to -Operate Fpermit 1/26/2018 Assurance Report and then receive before operation Site specific Local Nuisance/Noise/Odor/Other N/A No local nuisance requirements Ordinances Requirements including DOT and identified. FERC Requirements 14 Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 XI. Contracting Strategy Phase I Duke Energy has contracted with Charah since 2007 for excavation of ash in Asheville's 1982 Ash Basin on a firm, fixed price per ton price basis. Duke Energy will continue to manage the contract with Charah through final excavation of the 1982 Ash Basin as indicated in Phase I of the Excavation Plan. For the dewatering elements of phase 1, Duke Energy will engage multiple contractors to drive competition, system -wide innovation, and the collection of best practices. Subsequent Phases During the subsequent phase(s) of ash removal, the Company will award the excavation, transportation, and disposal of the ash to a single contractor. The contracting strategy may shift for subsequent phases as the Company recognizes enhancements that may drive costs lower, such as the use of incentives or risk sharing to drive productivity and unit cost. The Company's core values of safety and quality are non-negotiable and will not be compromised in order to increase productivity or generate cost savings. In summary, The Company's contracting strategy will provide the most effective combination of ash removal, transportation, disposition, and beneficial use options while balancing safety, scope adherence, cost and schedule. XII. Environmental, Health, and Safety Plan Protecting workers, the public, the community and the environment Duke Energy is committed to the health, safety and welfare of employees, contractors and the public; and to protecting the environment and natural resources. During all phases of the project work, Duke Energy and its contractors will follow the Duke Energy Safe Practices; the ABSAT Environmental, Health, and Safety (EHS) supplement document, and any additional requirements. Occupational health and safety expectations include oversight and continuous improvement throughout the project. The project will include comprehensive environmental, health and safety plans encompassing all aspects of the project work including at the plant, in transit and at the final destination as needed. In addition to adhering to all applicable environmental, health and safety rules and regulations, Duke Energy and contractors will focus on ensuring the safety of the public and environment during each phase of the project. 15 Asheville Steam Electric Generating Plant— Coal Ash Excavation Plan November 13, 2014 XIII. Communications Plan Many different external stakeholders including neighbors, government officials and media have an interest in this project. For example, there is the potential for facility neighbors and the general public to see or experience construction -related impacts such as truck traffic, landscape changes, or noise. The Company is committed to providing information by proactively communicating about the Project activities to potentially affected parties and responding to inquiries in a timely manner. The Project team will coordinate with Duke Energy's Corporate Communications Department to develop a comprehensive external communications plan tailored to the specific needs of each phase of the project. 16 Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 XIV. Glossary TERM DEFiNITI ABSAT Duke Energy organization acronym for Ash Basin Strategic Action Team ABSAT Project Duke Energy organization acronym for Ash Basin Strategic Action Controls Team responsible for financial reporting, scheduling and management reporting Ash Basin Synonymous with Coal Combustion Residual Impoundment. A topographic depression, excavation, or dammed area that is primarily formed from earthen materials; without a base liner approved for use by Article 9 of Chapter 130A of the General Statutes or rules adopted thereunder for a combustion products landfill or coal combustion residuals landfill, industrial landfill, or municipal solid waste landfill; and an Area that is designed to hold accumulated coal combustion residuals in the form of liquid wastes, wastes containing free liquids, or sludge, and that is not backfilled or otherwise covered during periods of deposition. Beneficial Re -use Beneficial use of coal combustion residuals, or byproducts, removed Opportunities from the site in compliance with the requirements of Section .1700 of 31 Subchapter B of Chapter 13 of Title 15A of the North Carolina 32 Administrative Code (Requirements for Beneficial Use of Coal 33 Combustion By -Products) and Section .1205 of Subchapter T of 34 Chapter 2 of Title 15A of the North Carolina Administrative Code 35 (Coal Combustion Products Management Bottom Ash The agglomerated, angular ash particles formed in pulverized coal furnaces that are too large to be carried in the flue gases and collect on the furnace walls. Bottom Ash falls through open grates to an ash hopper at the bottom of the furnace. CCR Coal Combustion Residuals. Residuals include fly ash, bottom ash, boiler slag produced by a coal fired generating unit Coal Ash Plan required by NC DENR letter dated August 13, 2014 including a Excavation Plan schedule for soil and sedimentation erosion control measures, dewatering, and the proposed location of the removed ash Coal Ash North Carolina Session Law 2014-122 Management Act of 2014 17 Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 TERM DEFINITION Decanting The act of removing water from ash Dewatering The act of removing bulk and entrapped water from the ash basin Dewatering Plan Engineered plan and the associated process steps necessary to dewater an ash basin Duke Safe Work Document detailing the Duke Energy safety guidelines Practices Engineer of Record Duke Energy or 3rd party contracted engineer responsible for final verification of specific plan actions and documents Excavation Tasks and work performed related to the planning, engineering and Activities excavation of ash from an ash basin Excavation Plan Refer to Coal Ash Excavation Plan Fly Ash Very fine, powdery material, composed mostly of silica with nearly all particles spherical in shape, which is a product of burning finely ground coal in a boiler to produce electricity and is removed from the plant exhaust gases by air emission control devices. Level 1 Schedule Schedule view that shows the main milestones to complete the project NPDES National Pollutant Discharge Elimination System NPDES Permit A permit that regulates the direct discharge of wastewater to surface waters Off -Site Facility A structural fill or mine reclamation for the long term storage of coal combustion residuals Permit Federal, state, county or local government authorizing document 1964 Ash Basin Ash pond created in 1964 for wastewater treatment of industrial wastewater produced by coal combustion for electric steam generation (#BUNCO-097) 1982 Ash Basin Ash pond created in 1982 for wastewater treatment of industrial wastewater produced by coal combustion for electric steam generation (#BUNCO-089) 18 Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan November 13, 2014 XV. Reference Documents 19 Dan River Steam Station Coal Ash Excavation Plan DUKE �, ENERGY Dan River Steam Station — Coal Ash Excavation Plan November 13, 2014 I. Statement of Purpose...................................................................................................................2 II. General Facility Description.........................................................................................................4 III. Project Charter...............................................................................................................................6 IV. Critical Milestone Dates................................................................................................................8 V. Level 1 Schedule...........................................................................................................................9 VI. Erosion and Sedimentation Control Plan................................................................................10 VII. Dewatering Plan..........................................................................................................................10 VIII. Proposed Location(s) for Removed Ash..................................................................................11 IX. Transportation Plan.....................................................................................................................12 X. Environmental Permitting Plan..................................................................................................13 XI. Contracting Strategy...................................................................................................................18 XII Environmental, Health, and Safety Plan..................................................................................18 XIII. Communications Plan.................................................................................................................18 XIV. Glossary ........................................................................................................................................20 XV. Reference Documents................................................................................................................22 1 Dan River Steam Station — Coal Ash Excavation Plan November 13, 2014 I. Statement of Purpose Duke Energy Carolinas, LLC (Duke Energy or the Company) is required by Section 3(b) of the Coal Ash Management Act of 2014 to close in accordance of Section 3(c) the coal combustion residuals (CCR) surface impoundments located at the Dan River Combined Cycle Plant, National Pollutant Discharge Eliminations System Permit No. #NC0003468 Rockingham County (Dan River) as soon as practicable, but not later than August 1, 2019. Further, by letter to Duke Energy dated August 13, 2014, North Carolina Department of Environment and Natural Resources (NC DENR) requested that Duke Energy submit coal ash excavation plans for inactive coal ash impoundments at Dan River no later than November 15, 2014 (NC DENR Letter). This Coal Ash Excavation Plan (Plan) represents Phase I and other Subsequent Phase(s) activities to satisfy the requirements outlined in Sections 3(b) and 3(c) Subparagraph 1 &2 of the Coal Ash Management Act of 2014 and the requests set forth in the NC DENR Letter. In general, the Plan covers the first 12 — 18 months of ash basin excavation activities, including the initiation of basin dewatering, site preparation, ash basin preparation, and ash removal from the basins. These activities may include decanting ash within the ash basin system. For Subsequent Phase(s), this document will be revised for any modifications to the Plan for the site. The Plan will be updated and submitted to NC DENR annually or earlier as required by Subsequent Phase(s). The NC DENR Letter specifically requests that the Plan include 1) a schedule for soil and sedimentation erosion control measures, 2) dewatering, and 3) the proposed location(s) of the removed ash. These requirements are found in Section V. Level 1 Schedule, Section VI. Erosion and Sedimentation Control Plans, Section VII. Dewatering Plan, and Section VIII. Proposed Location(s) for Removed Ash. The Plan covers some of the work required by Sections 3(b) and 3(c) of the Coal Ash Management Act of 2014 (Session Law 2014-122) (Coal Ash Act, or Act). The Act requires the closure of the ash basins as soon as practicable, but no later than August 1, 2019. However, the Act contains no requirement for the submittal of an excavation plan of the kind presented here. Thus, while the formulation, submittal, and review of this Plan will assist in Duke Energy's work to close the ash basins, its ultimate approval is an action not specifically required by statutory, regulatory or other applicable authority. Additionally, it may become necessary for the Company to modify the Plan to address other legal requirements or factors that develop during the ash basin excavation. Any changes will be included in annual updates to the Plan that Duke Energy will submit to NC DENR. Dan River Steam Station — Coal Ash Excavation Plan November 13, 2014 The precise scope of work in excavating the ash basins will be determined by applicable laws, rules, permits, and approvals that control the activities to be performed under the Plan. For example, the United States Environmental Protection Agency (EPA) is considering issuing rules regarding the management of coal ash (proposed EPA Coal Ash Rules). Similarly, the water quality permit for the discharge from the Pond (National Pollutant Discharge Elimination System Permit No. #NC0003468 Rockingham County) or its reissuance or amendment (NPDES Permit) could contain terms that control or affect the scope of that work. NC DENR filed legal cases in Superior Court (NC DENR Cases), which could be resolved through decision or settlement. NC DENR also sent Duke Energy a Notices of Violation (NOVs) regarding surface water and groundwater quality issues at the Plant. All of the above (Coal Ash Act, NC DENR Letter, NPDES Permit, NC DENR Cases, NOVs, and the proposed EPA Coal Ash Rules) are illustrative of actions that could potentially affect the precise scope of the work to be performed under the Plan. As a consequence, neither the submittal of this Plan nor its approval by NC DENR should be taken as requiring actions different from other such applicable requirements. Thus, Duke Energy submits this Plan to NC DENR based on the understanding that it may be necessary to make changes in the Plan in the future to reflect any such actions and reserves the right to make such changes after NC DENR's approval of the Plan. M Dan River Steam Station — Coal Ash Excavation Plan November 13, Z014 ll. General Facility Description The Dan River coal station began operation around 1950 and is currently being decommissioned. The Primary Ash Basin was constructed in 1956, with an embankment crest elevation of 523.5 feet. In 1968, the pond embankment crests were raised to elevation 530 feet and extended in length approximately 1,200 feet east along the Dan River. An intermediate dike was constructed in 1976, resulting in two basins, with the primary basin dam crest being raised to elevation 540 feet. The Primary Ash Basin was periodically dredged and the material dry -stacked on higher terrain north of the ponds (referred to as dry ash stacks). The dam numbers for the ash basins are ROCKI-237 and ROCKI-238. The dry ash stacks have been capped. Primary Ash Basin The Primary Ash Basin at Dan River consists of a composite dam made up of local borrow materials, including silty sands and sandy silts with some clay. Portions of the dam may have been built on, or contain, ash materials. The eastern face of the embankment is armored with dumped rock up to elevation 512 feet. A rock fill berm was constructed alongside the river, up to elevation 503 feet. An intermediate bench was constructed at approximate elevation of 530 feet. The Primary Ash Basin has an approximate footprint of 39 acres with a surface water area of 18 acres. The Primary Ash Basin received sluiced ash from pipes in the southwest corner, and outlets into the Secondary Ash Basin through a decant structure in the northwest corner. Currently, the Primary Ash Basin contains approximately 957 thousand tons of CCR material. Intermediate Dike (separates the Primary Ash Basin and the Secondary Ash Basin) The intermediate dike was constructed in 1976-77, bisecting the pond into Primary and Secondary Ash Basins. The dike was constructed on existing ash deposits, with an upper crest elevation of 540 feet adjacent to the Primary Ash Basin and a lower crest elevation of 530 feet adjacent to the Secondary Ash Basin. The dike has a surface road at the 540 foot level. It has a vegetated slope adjacent to the road which extends to a 530 foot elevation shelf adjacent to the Secondary Ash Basin. A dumped rock buttress was constructed below the elevation 530 foot crest. The width of the intermediate dike is approximately 100 feet. Secondary Ash Basin The Secondary Ash Basin embankments, including the intermediate dike forming the southwest boundary, have a crest elevation of 530 feet and are constructed of the same local materials as the Primary Ash Basin. The eastern face of the embankment is armored with dumped rock up to elevation 512 feet. A rock fill berm was constructed alongside the river, up to elevation 503 feet. The pond receives decanted flow from the 4 Dan River Steam Station — Coal Ash Excavation Plan November 13, 2014 Primary Ash Basin in the western corner, and flows exit the basin through a decant structure in the northeast corner. Flow from the Secondary Ash basin is controlled by National Pollutant Discharge Elimination System (NPDES) Permit #NC 0003468. The pool level is controlled by the decant riser using concrete stop -logs and conveys to the outlet through a 36-inch diameter reinforced concrete pipe (RCP) constructed through the embankment dike. Currently, the Secondary Ash Basin contains approximately 207 thousand tons of CCR material. Ash Stacks The dry ash stacks are located to the North of the Primary and Secondary Ash Basins. These ash stacks consist of CCR material dredged from the Primary Pond. Ash Stack 1 and Ash Stack 2 contain approximately 1.1 million tons and 372 thousand tons of CCR material, respectively. For the purposes of water management, the Ash Stacks are located within the ash basin system. Stormwater run-off from the Ash Stacks is contained within the ash basin system and flows to the Primary and Secondary Ash Basins. Figure 1: Dan River Combine Cycle Plant (#NC 0003468) in Rockingham County 5 Dan River Steam Station — Coal Ash Excavation Plan Novembor 13, 2014 III. Project Charter As a further commitment, the Company has formed an internal team, the Ash Basin Strategic Action Team (ABSAT). This team is dedicated to strengthening and executing a comprehensive strategy for increased oversight and closure of all of the Company's ash basins. Dewatering of the ash basins and the removal of ash from the site will be performed within project phases, Phase I and Subsequent Phase(s). Required permits for each phase are set forth in Section X of this Plan. Phase I will include site preparation, dewatering, ash excavation to an off -site landfill location, and completing any other subsequent permitted activities. The excavation will begin with the approval of this Plan by NC DENR and the receipt of final permits. In addition, a dewatering plan for the ash basins has been drafted and, if approved by NC DENR, bulk dewatering will be expedited during the initial phase of work. Duke Energy has submitted an application to modify its NPDES wastewater permit to include controls to be implemented during dewatering activities. During Phase I, the Company will continue to perform the pre -construction and planning activities for the Subsequent Phase(s). These activities include project planning, development of new permanent disposal and sale or reuse options, and completion of additional required permitting that may be necessary for the ash removal from the ash basins. Knowledge and opportunities for program improvement obtained during Phase I of the project will be applied to the Subsequent Phase(s). The Plan will begin removing ash to an off -site location while simultaneously developing an on -site landfill in order to meet the closure requirement mandated in the Coal Ash Management Act. Permits to construct and operate the landfill must be received no later than October 24, 2015 and June 1, 2017; respectively, in order to make the on -site landfill a viable option to comply with the mandatory closure date of August 1, 2019. Project Charter Objectives Phase I Objectives 1. Initiate the removal of ash from the Dan River ash basins 2. Begin dewatering of the ash basins 3. Determine the disposition of the ash stacks 4. Obtain permit to construct on -site landfill by October 24, 2015 5. Plan activities for Subsequent Phase(s), including development of option(s) for reuse or proposed ash disposal location(s) 6. Gain knowledge and opportunities for program improvement that can be applied to Subsequent Phase(s) n Dan River Steam Station — Coal Ash Excavation Plan November 13, 2014 7. Validate production rates to meet project requirements 8. Evaluate the on -site landfill option and sale and beneficial reuse options Subsequent Phase(s) Objectives 1. Remove remaining ash from ash basins and ash stacks 2. Obtain permit to operate the on -site landfill by June 1, 2017 3. Develop, construct, and operate the on -site landfill if viable 4. Continue developing beneficial reuse opportunities and placement alternatives for subsequent phase(s) ash removal Phase I Scope 1. Finalize end location(s) for removed ash and obtain all required permits 2. Obtain all applicable permits for work in Phase 1 3. Begin site preparation activities, including mobilization 4. Install site erosion and sediment control measures 5. Install required site haul roads 6. Prepare and install rail load out spur for rail transportation 7. Prepare and install truck load out and truck wash for truck transportation 8. Perform site preparation for the basin dewatering (Primary & Secondary Ash Basins) 9. Engineer plan to stop water inputs into the ash basins 10.Initiate rerouting or elimination of inflows to the ash basins 11. Begin bulk dewatering of the Secondary Basin 12. Perform site preparation in the Primary & Secondary Ash Basins for ash excavation 13. Perform site preparation for ash stack removal 14. Develop the on -site landfill if viable 15. Excavate and transport approximately 1.2 million tons of ash from the Primary and Secondary Ash Basin & Ash Stacks to an approved landfill or structural fill location 16. Perform an engineering and constructability review for the on -site landfill 17.Obtain all required permits for subsequent phase activities 7 Dan River Steam Station — Coal Ash Excavation Plan November 13, 2014 Subsequent Phase(s) Scope 1. Identify and/or develop additional off -site ash options 2. Obtain all required permits for the added options 3. Obtain all remaining required permits for next Subsequent Phase activities 4. If viable construct and operate the on -site landfill 5. Complete basin dewatering 6. Excavate and transport the remaining ash from the Dan River Station to the on - site landfill or off -site reuse options 7. Complete closure activities as outlined in Sections 3(b) and 3(c) Subparagraphs 1 &2 of the Coal Ash Management Act of 2014 IV. Critical Milestone Dates Critical Milestones within the Plan are summarized in the table below. These milestones have been added to the Level 1 Schedule. MILESTONES■ LATER THAN DATE Elk Submit Excavation Plan November 15, 2014 Complete comprehensive engineering review November 30, 2014 Excavation Plan Approval February 17, 2015 Industrial Stormwater Permit March 18, 2015 Commence work - ash removal Final permit approval + 60 Days Receive Permit to Construct On -site Landfill October 24, 2015 Submit Updated Excavation Plan — Subsequent Phase(s) December 31, 2015 Receive Permit to Operate On -Site Landfill June 1, 2017 Eliminate stormwater discharge into impoundments December 31, 2018 Impoundments closed per Sections 3(b) and 3(c) of the Coal Ash Management Act of 2014 August 1, 2019 0 Dnn River Stearn Station - Coal Ash Excavation I -- November 13.2014 V. Level 1 Schedule Oar RrW Ash Pond Clowe Ash Rebtat. Dan River Ash Pond Closure Ash Relocation F.R%vrc 10.t8.7a 10:t3 E--tiao Fla< Schedule AM*N" Start Fnsh i 16 1 Z,'17 2DIII, . I. I = M21 1 ' OEtd[11T1;:i1NG I WasterG;•.=r iFO£SP-MMnor Madff:atorlApp—al 02-11-15 10347.15 =. O Was P-T* t M Mod* XonApp,, al Wastew NFOES PmA Mew Mad6cscn Mksu-a27:15 Was •,r Pe.* A nor Wev PK--SE i B" FREE WATER 0:• 71.15 ; ti-_3 i5 --0 c„kTER 1YastexcXer At''Dc5 Pemu Mgor Mod.4caon h'.'.tsk- , ib3615' ♦ as NI DES Moor sloftatio MFesi•+!e EXCAVATION FLAN --- —. E:,--PW-r; 11 4 1;-01:-14 I EX ii: F1N�-rR ..-a? E;;a acn �.=t r,._._. 't1.15-14' ♦ Scdas3 Fx avato.N, E•cr,at a-aa e: = c. c,p ;nr a. 11-17-14 02-17-I5 ... ...s'ca:•: or Pa::G YR'.er :!A rea- __________ _________ --- .-___ ASH REMOVAL 9—rr :. 341—ss•>•.:.--..s•'-•,:., .• .. .- '< _.--..a:,e;. s<<L,cn'...,N?L•, VlS Rtn: •a Waste Charactemadas RAocepbnce forOnposat- 10-17-14- i Vastee sv¢s" &Aa for See SA"'y RelxnMks:arc - -.. sl r 1>' `: S4e SA 4 sty Repo Mrns Obta----------------- rl kl9etrial $tarnwa:er PS•t�ES Prlyd ,K1-1S-1S' ♦OWif Vdusaial-.... --------- ---------- ---------- --------- ..(Phase 1)Ash Rmwvae- MbdrryicrtI So, Pr�on Cz-, •ib&m15 ® ( el)Ash —.1 - M bkYon t Pnprs'_. (R-9 Ash Rorwaf- Etoson CcrOn6 v S_• Reparmon C ta-SS - 05-20615 1 (P Itr„•�u-i . ,L xe: •,C a-- :a ac." (Phase1)Load IH.JYPla-Ash(ISMcrMs) Phase lj !tied; Ash( 3Ma•.tlnr 1,16.4tal sv oft al Fl Pend ... .. 05•Zo- 16` `. ♦Inti, djaISnct ral Fi FW' Oam Sa*A{paaats 1 t5' - .. -..... ---- � ....... --................_ _....... ___.__... .......... End 3orttsva aDscharL,Rrrpaas.frter'a __ I �11p•. End b Rsh, M�vla7ern�dAoi �SecGons 3.(hj.saf3{cjdflse Corti... 08.69.19° ♦ _Pt bseQ Sections Note: This Level 1 Schedule is a living element of this Plan. Dates and durations are based on known information on the date of this Plan. Dan River Stcam Station — Coal Ash Excavation Plan November 13, 2014 VI. Erosion and Sedimentation Control Plan: The Erosion and Sedimentation Control Plan (E&SC) for the excavation of the Ash Stack is being developed. The approval of this plan by NC DENR will meet the requirement outlined in the NC DENR Letter. Any deviations from the current E&SC for Subsequent Phase(s) will be submitted to and approved by NC DENR prior to installation and initiation of subsequent phases of work. The approved contractor will install the E&SC measures indicated in the plan. The Engineer of Record will review the installation prior to commencing excavation on site. All control measures will be maintained through the project in accordance with the E&SC. VIA. Dewatering Plan The Dan River ash basins will be dewatered to facilitate the removal of ash and to mitigate risk. Lowering the water level within each basin will improve safety factors of the dams by reducing the driving force on the upstream face of the dam. Similarly, dewatering will improve the physical properties of the retained ash, making it less susceptible to flow in the event of an unexpected dam failure. An Engineered Dewatering Plan for Dan River is being developed. This plan details removal of the following water: Sequence Primary Ash Basin — Removal of water 25 feet below top of ash The Primary Ash Basin contains an undetermined amount of water which will be pumped to the Secondary Ash Basin at a maximum drawdown rate of one foot over seven days. Following free water removal, vacuum well points will be installed in the ash along the dam to draw down entrapped water in the vicinity of the dam. 2. Secondary Ash Basin — Removal of water 15 feet below top of ash Based on data from April 2014, the Secondary Ash Basin contains approximately 20.7 million gallons of free water. The maximum free water drawdown rate will be one foot over seven days. Following free water removal, vacuum well points will be installed in the ash along the dam to draw down entrapped water in the vicinity of the dam. 10 Darr River Steam Station — Coal Ash ExcavaJon Plan November 13, 2014 VIII. Proposed Location(s) for Removed Ash Phase I of the Plan will include the excavation and removal of approximately 1.2 million tons of ash from Dan River. Subsequent Phase(s) will remove the remaining ash at the site. Ash removed from the site will be transported by the contractor to properly permitted facilities. The ash placement location will be properly managed and maintained to ensure environmental compliance with all applicable rules and regulations. Phase l: Ash Disposition Sites For Phase I, the Maplewood Landfill located in Jetersville, Virginia has been identified for ash placement. This primary option provides a solution for Phase I and/ or Subsequent Phase(s). Contingent Plan: Ash Disposition Sites In the event of any issues with accepting ash at the Maplewood Landfill, the Atlantic Landfill has been determined as a suitable alternative site. All necessary steps will be taken to assure that the Atlantic Landfill is ready to accept ash in the event of any issues at the Maplewood Landfill. The Atlantic Landfill is located in the city of Waverly, Virginia. 11 Dan River Steam Station — Coal Ash Excavation Nan November 13, 2014 Subsequent Phase(s): Ash Disposition Sites The project team will utilize lessons learned from Phase I to develop an off -site disposal strategy and/ or alternative sale or reuse site(s) that will provide the improvements below. • Provide a reliable, long-term, cost effective, solution for ash designated for removal • Develop a supplier diverse Program to drive innovation and competition • Establish performance baselines and the system to optimize pickup, transport, drop-off and reuse IX. Transportation Plan Ash will be transported from the site via rail car to the off -site facility. Transportation of the CCR will be conducted by approved transporters and meet DOT and other applicable federal, state, and local regulations. Phase 1: Transportation For Phase 1, all CCRs will be transported by rail from Dan River to the Maplewood Landfill site. Trains will consist of approximately 65 gondola cars at 100 tons per car. One train will leave the site every other day or 2.5 to 3 trains per week on average establishing a production rate of approximately 16,400 tons per week. The operation of loading rail cars will be completed with a crew working typically 10 hours per day, 5 days per week. Plans are being made to design and install a rail loading system at Dan River that would transport ash to the Maplewood Landfill. .'�anvt4le `SgT .. 0 ... . ORoxboro Figure 2: Typical Truck Route to Maplewood Landfill 12 Dan River Steam Station — Coal Ash, Excavation Plan !November 13, 2014 Contingent Plan: Transportation To support the transportation of ash for the Contingent Location, ash will be transported to the Atlantic Landfill instead of the Maplewood Landfill. In the event of rail transportation disruption, truck transportation remains a contingency option for either the Maplewood Landfill or the Atlantic Landfill. _. c by !aka Farmwna ' '360 460) Lia.rzla CRnrhy Mai nt QBfa:astena i 311 '.da 0SEuzicro i,nderswnr is 33R,a14 ' Samubr qtd � 8t Greens or.o pMstanw YIStner P4v�rsh:.iy rharn i•1—�1i 115t5n11�tir C Lat r �tj�bULbetp' 60� ��4irhdrr�E4V1,'� ��Un6arp� � �301 Nowporl r'""� i256y - QTGWS rasof � [Szn:porra �$4tybltT F—k- f1(jf[p M. wAnoks Rspcna `f`f , C158�- OAh.W. Mount Figure 3: Typical Truck Route to Atlantic Landfill Subsequent Phase(s): Transportation The transportation plan and any other options will be reviewed and could be amended in Subsequent Phase(s) to enhance the excavation process and objectives. X. Environmental Permitting Plan Phase / Phase 1 will include excavation and removal of 1.0 — 1.2 million tons of ash either from the ash stack or ash basins. Implementation for Phase I can begin once the permitting for Phase I is in place, although different permitting may be necessary prior to initiating Subsequent Phase work. Phase I will include permitting activities for subsequent phases. Through this Excavation Plan approval process, Duke Energy is seeking to confirm that all necessary approvals have been identified. The Excavation Plan is intended to authorize the excavation and movement of ash once the identified permits have been obtained. Excavation of ash creates potential for stormwater impacts. NC DENR has indicated an industrial stormwater permit may be needed. Based on this representation from NC 13 Dan River Steam Siation — Coul Ash Excavation Plan Novembor 13, 2014 DENR, Duke Energy has applied for an NPDES industrial stormwater permit to support ash removal at the site. A stormwater pollution prevention plan (SWPPP) incorporating best management practices (BMPs) will be created. Future modifications to the permit/plan will be managed as necessary. NC DENR has recently indicated that modification of the NPDES wastewater permit may be required to initiate removal of free water from inactive ash basins. Duke is submitting additional information to NC DENR for its consideration to support incorporating dewatering requirements into the pending the Company's pending NPDES permit application. The Company is working with United States Environmental Protection Agency (EPA) and NC DENR with a goal of identifying the regulatory framework that will allow the removal of free-standing water from inactive basins to move forward. There are no jurisdictional wetlands/streams associated with the removal of the Ash Stack or Primary or Secondary Ash Basins in Phase I. Future wetlands/stream impacts and jurisdictional determinations will be managed through the US Army Corps of Engineers (ACOE) with particular attention paid to the difference between jurisdictional wetlands/streams under Section 404 and those arising from Section 402 waters. Before creation of new mine reclamation structural fills, an individual structural fill permit will need to be obtained by the mine reclamation project owner/operator. It is anticipated that the mining permit will be transferred from the existing mine owner to a mine reclamation contractor: Once the permit is transferred, the mine reclamation contractor will submit an individual structural permit application and mine reclamation plan to the Division of Mining. It is anticipated that the Division of Mining will then forward the reclamation plan to the Division of Water Resources, Division of Waste Management, and other divisions as necessary for comments. Subject to any changes from Division of Mining, the revised reclamation plan would be approved and an individual Structural Fill Permit will be issued. No information currently exists to indicate that the Dan River ash should be treated as a DOT hazardous material shipped via truck or rail. Subsequent Phase(s) will include dewatering (once NPDES permit modification complete) and continued excavation and removal of ash from the Primary and Secondary Ash Basins. Subsequent Phase(s) also potentially include the construction of an offsite landfill. Future jurisdictional determinations will be managed through the US Army Corps of Engineers with particular attention paid to the difference between jurisdictional 14 Dan River Steam Station — Coa; lash Excavation Plan Noveinber 13, 2014 wetlands/streams under Section 404 and those arising from Section 402 waters. Any Section 404 permitting will require Section 401 Water Quality Certification by NC DENR. In order to facilitate adjacent -site ash monofill construction and operation, Site Suitability approvals (Site Suitability Report, Required Public Comment, DWM Approval of Site Suitability), Permit -to -Construct (Construction Plan Application, Receive Permit -to - Construct from DWM), and Permit -to -Operate (Construction Quality Assurance Report, Receive Permit -to -Operate) will be obtained. If used, before shipping ash to a third - party Subtitle D landfill, waste characterization and approval will be completed. All necessary Dam Safety approvals will be obtained to cover activities on or around jurisdictional dams. Breaching of the dams will require Dam Safety approval. Any impacted wells or piezometers will be properly abandoned and dispositioned with NC DENR. Fugitive dust will be managed to mitigate impacts to neighboring areas. Impacts to threatened and endangered species will be avoided. No additional site -specific or local requirements have been identified. 15 Dan River Steam Station — Coal Ash Excavation Plan Novembcr 13, 2014 Phase I Permit Matrix Media Permit Milestone/ Target Reasoning Date Excavation of ash creates potential for stormwater impacts. The facility will seek an approved E&SC and associated Construction Industrial Stormwater NPDES Stormwater Permit approval for Permit March 18, 2015 ash stack removal. NC DENR has indicated an industrial stormwater permit may also be needed. Duke has applied for this permit. A SWPPP incorporating BMPs will be Water created. NC DENR has indicated dewatering activities including free water removal, may require Wastewater NPDES Permit — NPDES wastewater permit Minor Modification March 27, 2015 modification. Based on this requirement, Duke Energy is submitting proposed dewatering permit conditions in its pending NPDES permit application. Jurisdictional Wetland and There are no identified Stream Impacts/ 404 Permitting N/A jurisdictional wetland/stream and 401 WQC impacts in Phase I. Hauling and excavation activities must not impact a jurisdictional dam or dike. Activities are initially staying away from the jurisdictional Dam Safety Approvals May 29, 2015 dike. Removing ash from the Primary and Secondary Ash Basins will have to be reviewed Waste with Dam Safety. Breaching of dike will require Dam Safety approval. Mine Reclamation Owner/Operator to obtain a Individual Structural Fill Permit March 27, 2015 structural fill permit as set forth in Subpart 3 of Part 2 of Article 9 of the Coal Ash Management Act. Site Specific Local Nuisance/Noise/Odor/Other N/A No local nuisance requirements Ordinances Requirements including DOT identified. and FERC Requirements 16 Dan River Steam Station — Coal Ash Excavation Plan, November 13, 2014 Subsequent Phase(s) Permit Matrix Media Permit Milestone/ Target Reasoning Date Excavation of ash creates potential for stormwater impacts. The facility will seek an approved E&SC and associated Construction Stormwater Industrial Stormwater NPDES June 26, 2015 Permit approval for ash stack Permit removal. NC DENR has indicated an industrial stormwater permit may also be needed. Duke has applied for this permit. A SWPPP incorporating BMPs will be created. NC DENR has indicated dewatering activities including free water removal, may require NPDES Water Wastewater NPDES Permit — October 30, 2015 wastewater permit modification. Major Modification Based on this requirement, Duke Energy is submitting proposed dewatering permit conditions in its pending NPDES permit application. Identify if project scope results in impacts to jurisdictional wetlands or streams. Obtain JD and pursue 404 Jurisdictional Wetland and Stream permit for impacts from ACOE. Impacts/ 404 Permitting and 401 October 30, 2015 Also, 404 permits are required for WQC working below the ordinary high watermark. If Federal individual permitting is required, obtain 401 WQC. Mine Reclamation Owner/Operator Individual Structural Fill Permit March 27, 2015 to obtain a structural fill permit as set forth in Subpart 3 of Part 2 of Article 9 of the Coal Ash Management Act. Hauling and excavation activities must not impact a jurisdictional dam Dam Safety Approvals October 30, 2015 or dike. Activities are initially staying 50 feet away from the jurisdictional dike. Breaching of dike will require Dam Safety approval. Waste Site Suitability anticipated for offsite Site Suitability Report January 30, 2015 landfill must go through public comment. Must receive permit to begin Permit -to -Construct October 24, 2015 construction and corresponding E&SC approval to cover approved Construction design. Must provide Construction Quality Permit -to -Operate June1, 2017 Assurance Report and then received permit before operation. Site Specific Local Nuisance/Noise/Odor/Other N/A No local nuisance requirements Ordinances Requirements including DOT and identified. FERC Requirements 17 Dan River Steam Station — Coal Sash Excavation Plan November 13, 2014 XI. Contracting Strategy The Ash Management Program strategy is to engage multiple contractors, to drive competition, system wide innovation and the collection of best practices. During the initial phase (Phase 1) of ash removal at Riverbend, L.V. Sutton, Dan River and Asheville, the Company will award the excavation, transportation, and disposal of the Ash to a single contractor for each site. The result may be two to three contractors, with each contractor having responsibility for one, or two sites, working on a firm fixed per ton price basis. The contracting strategy will shift for subsequent Phases, and potentially during Phase 1, as the Company and the selected contractors recognize enhancements that can increase productivity or drive unit cost lower. Duke Energy's core values of safety and quality are non-negotiable and will not be compromised in order to increase productivity or generate cost savings. In summary, the Company's contracting strategy will provide the most effective combination of ash removal, transportation, disposal, and beneficial reuse options balancing strategic intent, cost, and schedule. The health and safety of workers, the communities, and environment will not be sacrificed to achieve these goals. XJI. Environmental, Health, and Safety Plan Protecting workers, the public, the community, and the environment The Company is committed to the health, safety and welfare of employees, contractors and the public, and to protecting the environment and natural resources. During all phases of the project work, the Company and its contractors will follow the Company Safe Practices; the ABSAT Environmental, Health, and Safety (EHS) supplement document, and any additional requirements. Occupational health and safety expectations include oversight and continuous improvement throughout the project. The project will include comprehensive environmental, health and safety plans encompassing all aspects of the project work including at the plant, in transit and at the final destination as needed. The project's commitment is to minimize public and environmental impacts. MI. Communications Plan Many different external stakeholders including neighbors, government officials and media have an interest in this project. For example, there is the potential for facility neighbors and the general public to see or experience construction -related impacts such as truck traffic, landscape changes, or noise. The Company is committed to 18 Dan River Steam Station — Coal Ash Excavation Plan November 13, 2014 providing information by proactively communicating about the Project activities to potentially affected parties and responding to inquiries in a timely manner. The Project team will coordinate with Duke Energy's Corporate Communications Department to develop a comprehensive external communications plan tailored to the specific needs of each phase of the project. 19 Elan River Stem Station — Coal Ash Excavation Plan i%!overnber 13, 2014 'NIV. Glossary DefinitionTerm ABSAT Duke Energy organization acronym for Ash Basin Strategic Action Team Ash Basin Synonymous with Coal Combustion Residual Impoundment. A topographic depression, excavation, or dammed area that is primarily formed from earthen materials; without a base liner approved for use by Article 9 of Chapter 130A of the General Statutes or rules adopted thereunder for a combustion products landfill or coal combustion residuals landfill, industrial landfill, or municipal solid waste landfill; and an Area that is designed to hold accumulated coal combustion residuals in the form of liquid wastes, wastes containing free liquids, or sludge, and that is not backfilled or otherwise covered during periods of deposition. Ash Ponds Coal Combustion Residual stored in wet impoundments, or ponds Ash Stack Ash storage areas located north and west of the Primary and Secondary Ash Basins. Beneficial and Projects promoting public health and environmental protection, offering Beneficial Use equivalent success relative to other alternatives, and preserving natural resources Bottom Ash The agglomerated, angular ash particles formed in pulverized coal furnaces that are too large to be carried in the flue gases and collect on the furnace walls. Bottom Ash falls through open grates to an ash hopper at the bottom of the furnace. Bulk Water Water above the ash contained in the ash basin. Synonymous with free water Coal Ash Excavation Plan required by NC DENR letter dated August 13, 2014 including a Plan schedule for soil and sedimentation erosion control measures, dewatering, and the proposed location of the removed ash Coal Ash North Carolina Session Law 2014-122 Management Act of 2014 Coal Combustion Residuals, including fly ash, bottom ash, boiler slag, mill rejects, and flue Residuals (CCR) gas desulfurization residue produced by a coal-fired generating unit Decanting The act of removing water from ash 20 Dan River Steam Station — Coal Ash Excavation Plan November 13, 2014 DefinitionTerm A Dewatering The act of removing bulk and entrapped water from the ash basin Dewatering Plan Engineered plan and the associated process steps necessary to dewater an ash basin Duke Safe Work Document detailing the Duke Energy safety guidelines Practices Engineer of Record Duke Energy or 3rd party contracted engineer responsible for final verification of specific plan actions and documents Entrapped Water Flowable water below the ash surface which creates hydrostatic pressure on the dam Excavation Activities Tasks and work performed related to the planning, engineering and excavation of ash from an ash basin Excavation Plan Refer to Coal Ash Excavation Plan Factor of Safety In reference to dam safety, the ratio of the forces or moments resisting mass movement to the forces or moments tending to produce mass movement Free Water Water above the ash contained in the ash basin. Synonymous with bulk water Fly Ash Very fine, powdery material, composed mostly of silica with nearly all particles spherical in shape, which is a product of burning finely ground coal in a boiler to produce electricity and is removed from the plant exhaust gases by air emission control devices Grading Plan Document detailing the final elevation, drainage and lay of the excavated area Level 1 Schedule Schedule view that shows the main milestones to complete the project NPDES National Pollutant Discharge Elimination System NPDES Permit A permit that regulates the direct discharge of wastewater to surface waters Off -Site Disposal A structural fill or mine reclamation for the long term placement of coal Facility combustion residuals Permitting Federal, state, county or local government authorizing document 21 Dan River Steam Station — Coal i'--,sh Excavation Plan November 13, 2014 Reference Documents 1 Letter to Duke Energy, Request for Excavation Plans August 13, 2014 2 Coal Ash Management Act of 2014 September 20, 2014 22 I.M. Sutton Electric Plant Goal Ash Excavation Plan (� DUKE �. ENERGY L.V Suttor's Electric Plant — Coal Ash Excavation Flan November 13, 2014 Table of Conten.ts I. Statement of Purpose...................................................................................................................2 II. General Facility Description.........................................................................................................4 III. Project Charter...............................................................................................................................7 IV. Critical Milestone Dates................................................................................................................9 V. Level 1 Schedule.........................................................................................................................10 VI. Erosion and Sedimentation Control Plan................................................................................11 VII. Dewatering Plan..........................................................................................................................11 Vill. Proposed Location(s) for Removed Ash..................................................................................12 IX. Transportation Plan.....................................................................................................................13 X. Environmental Permitting Plan..................................................................................................15 XI. Contracting Strategy...................................................................................................................19 X11. Environmental, Health, and Safety Plan..................................................................................19 X1I1. Communications Plan.................................................................................................................19 XIV. Glossary ........................................................................................................................................21 XV. Reference Documents................................................................................................................23 1 L.V. Sutton Electric Plant -- Coal Ash Excavation Plan, November 13, 2014 I. Statement of Purpose Duke Energy Progress, Inc. (Duke Energy or the Company) is required by Section 3(b) of the Coal Ash Management Act of 2014 to close in accordance of Section 3(c) the coal combustion residuals (CCR) surface impoundments located at the L.V. Sutton Electric Plant, National Pollutant Discharge Eliminations System Permit No. #NC0001422 New Hanover County (Sutton) as soon as practicable, but not later than August 1, 2019. Further, by letter to Duke Energy dated August 13, 2014, North Carolina Department of Environment and Natural Resources (NC DENR) requested that Duke Energy submit coal ash excavation plans for inactive coal ash impoundments at Sutton no later than November 15, 2014 (NC DENR Letter). This Coal Ash Excavation Plan (Plan). represents Phase I and other Subsequent Phase(s) activities to satisfy the requirements outlined in Sections 3(b) and 3(c) Sub paragraph 1 &2 of the Coal Ash Management Act of 2014 and the requests set forth in the NC DENR Letter. In general, the Plan covers the first 12 — 18 months of ash basin excavation activities, including the initiation of basin dewatering, site preparation, ash basin preparation, and ash removal from the basins. These activities may include decanting ash within the ash basin system. For Subsequent Phase(s), this document will be revised for any modifications to the Plan for the site. The Plan will be updated and submitted to NC DENR annually or earlier as required by Subsequent Phase(s). The NC DENR letter specifically requests that the Plan include 1) a schedule for soil and sedimentation erosion control measures, 2) dewatering, and 3) the proposed location(s) of the removed ash. These requirements are found in Section V. Level 1 Schedule, Section VI. Erosion and Sedimentation Control Plans, Section VII. Dewatering Plan, and Section Vill. Proposed Location(s) for Removed Ash. The Plan covers some of the work required by Sections 3(b) and 3(c) of the Coal Ash Management Act of 2014 (Session Law 2014-122) (Coal Ash Act, or Act). The Act requires the closure of the ash basins as soon as practicable, but no later than August 1, 2019. However, the Act contains no requirement for the submittal of an excavation plan of the kind presented here. Thus, while the formulation, submittal, and review of this Plan will assist in Duke Energy's work to close the ash basins, its ultimate approval is an action not specifically required by statutory, regulatory or other applicable authority. Additionally, it may become necessary for the Company to modify the Plan to address other legal requirements or factors that develop during the ash basin excavation. Any changes will be included in annual updates to the Plan that Duke Energy will submit to NC DENR. 2 L.V. Sutton Electric Plant — Coal Ash Excavation Plan November 13, 2014 The precise scope of work in excavating the ash basins will be determined by applicable laws, rules, permits, and approvals that control the activities to be performed under the Plan. For example, the United States Environmental Protection Agency (EPA) is considering issuing rules regarding the management of coal ash (proposed EPA Coal Ash Rules). Similarly, the water quality permit for the discharge from the Pond (National Pollutant Discharge Elimination System Permit No. #NC0001422 New Hanover County (Sutton) or its reissuance or amendment (NPDES Permit) could contain terms that control or affect the scope of that work. NC DENR filed legal cases in Superior Court (NC DENR Cases), which could be resolved through decision or settlement. NC DENR also sent Duke Energy a Notices of Violation (NOVs) regarding surface water and groundwater quality issues at the Plant. All of the above (Coal Ash Act, NC DENR Letter, NPDES Permit, NC DENR Cases, NOVs, and the proposed EPA Coal Ash Rules) are illustrative of actions that could potentially affect the precise scope of the work to be performed under the Plan. As a consequence, neither the submittal of this Plan nor its approval by NC DENR should be taken as requiring actions different from other such applicable requirements. Thus, Duke Energy submits this Plan to NC DENR based on the understanding that it may be necessary to make changes in the Plan in the future to reflect any such actions and reserves the right to make such changes after NC DENR's approval of the Plan. 3 L.V. Sutton Elect is Plint- — Coal Ash Excavaiion Flan November 'i 3, 2014 II. General Facility Description Sutton is located in New Hanover County near Wilmington, North Carolina, situated between the Cape Fear River to the west and the Northeast Cape Fear River to the east. Sutton was a three -unit, 575 megawatt (MW) coal-fired power plant. The Plant operated from 1954 until retirement of the coal-fired units in November 2013. Upon retirement of the coal-fired units a new 625 MW gas -fired unit began operations. There are two CCR basins, the 1971 and 1984 basins, and a large Cooling Basin. The Cooling Basin is accessible to the general public and is used for recreational purposes. Two other areas that contain CCR material are the Lay of Land Area (LOLA) and the 1971 Borrow Area. The LOLA consists mostly of bottom ash and soil, while the 1971 Borrow Area consists of fly and bottom ash. 1971 Ash Basin The 1971 Basin was operated from 1971 to 1985. It was opened again in 2011 for temporary use during repair work and ash removal activities. The 1971 Basin is unlined and was initially constructed with a crest elevation of 18 feet, which was raised in 1983 to 26 feet mean sea level (MSL). An area underneath the footprint of the 1971 Basin contains additional CCR materials and is referred to as the 1971 Borrow Area. The 1971 Basin and the Borrow Area contain approximately 3.5 million tons of CCR material. 1984 Ash Basin The 1984 Basin was operated from 1984 to 2013. Both the 1984 and 1971 Basins contain fly ash, bottom ash, boiler slag, stormwater, ash sluice water, coal pile runoff, and low volume wastewater. The 1984 Basin was constructed with a 12 inch thick clay liner at the basin bottom which extended along the side slopes where it is protected by a 2 foot thick sand layer. The 1984 Basin crest elevation is 34 feet MSL. In 2006 an Interior Containment Area was constructed within the 1984 Basin with a crest elevation of 42 feet MSL. Currently, the 1984 Ash Basin contains approximately 2.8 million tons of CCR material. WOM The LOLA is located between the discharge canal and the coal pile. It is believed that the presence of CCR in this area may have been due to the plant operations between approximately 1954 and 1972. A significant portion of this area toward the discharge canal is heavily vegetated while the portion adjacent to the coal pile storage was used to locate fuel oil storage tanks. The LOLA is on the North Carolina Inactive Hazardous 4 L.V. Sutton Electric Plant — Coal Ash E;scavation Plan November 13, 2014 Waste Sites Priority List. This area contains approximately 840 thousand tons of CCR and soil mixture at depths of 2 to 15 feet. Current Operating Permit Details The Cooling Basin, 1971 Basin and 1984 Basin are operated under the State of North Carolina National Pollutant Discharge Elimination System (NPDES) permit number NC0001422 to regulate effluents to the Cape Fear River. Additionally, the dams of the Cooling Basin, 1971 Basin and 1984 Basin, are listed under the NC DENR Dam Safety Program. The dam identification numbers for the Cooling Basin, 1971 Basin and 1984 Basin are NEWHA-003, NEWHA-004, and NEWHA-005; respectively. Furthermore, the dam inventory lists the cooling basin and 1971 dams as exempt. The 1984 dam is listed as impounding, hence regulated. These dams are rated as low hazard by NC DENR. The 2006 Interior Containment Area constructed within the 1984 Basin was permitted and used as a "basin within a basin", where an interior dam was constructed on top of the CCR within the basin; sluiced CCR was excavated from rim ditches, placed within the interior basin, and compacted to heights that are above the exterior basin dams. This operation was discontinued before reaching the permitted final grades when the Plant was shut down in November 2013. 5 L)i8uttonElectric Plant — Coal Ash Excavation Plan RQureY: LV.Sutton Electric Plant |nNew Hanover County (WC0UO1422 A L.V. Sort'Lcn Eleciric Plant - Coal Ash Excavation Plan November 13, 2014 Ill. Project Charter As a further commitment, the Company has formed an internal team, the Ash Basin Strategic Action Team (ABSAT). This team is dedicated to strengthening and executing a comprehensive strategy for increased oversight and closure of all of the Company's ash basins. Dewatering of the ash basins and the removal of ash from the site will be performed within project phases, Phase I and Subsequent Phase(s). Required permits for each phase are set forth in Section X of this Plan. Phase I will include site preparation, dewatering, ash excavation to an off -site location, and complete any other subsequent permitted activities. The excavation will begin with the approval of this Plan by NC DENR and the receipt of final permits. In addition, a dewatering plan for the ash basins has been drafted and, if approved by NC DENR, bulk dewatering will be expedited during the initial phase of work. Duke Energy has submitted an application to modify its NPDES wastewater permit to include controls to be implemented during dewatering activities. During Phase I, the Company will continue to perform the pre -construction and planning activities for the Subsequent Phase(s). These activities include project planning, development of new storage options, and completion of additional required permitting that may be necessary for the ash removal from the ash basins. Knowledge and opportunities for program improvement obtained during Phase I of the project will be applied to the Subsequent Phase(s). This Plan will begin removing ash to an off -site location while simultaneously developing an on -site landfill in order to meet the closure requirement mandated in the Coal Ash Management Act. Permits to construct and operate the landfill must be received no later than December 23, 2015 and August 1, 2016; respectively, in order to make the on -site landfill a viable option to comply with the mandatory closure date of August 1, 2019. N L.V Sutton Electric Plant — Coal Ash Excavation Plun November 13, 2014 Project Charter Objectives Phase I Objectives 1. Initiate the removal of ash from the Sutton site 2. Begin dewatering of the ash basins 3. Development of option(s) for proposed ash disposal or beneficial reuse locations 4. Gain knowledge and opportunities for program improvement that can be applied to the Subsequent Phase(s) 5. Complete a work scope and award a contract to support ash basin closure by August 2019 6. Validate production rates to meet project requirements 7. Initiate the development and permitting of the on -site landfill 8. Obtain permit to construct on -site landfill by December 23, 2015 Subsequent Phase(s) Objectives 1. Dewater the ash basins 2. Remove ash from the 1971 Basin, 1984 Basin, and the LOLA area 3. Obtain permit to operate the on -site landfill by August 1, 2016 4. Construct and operate the on -site landfill if viable Project Charter Scope Phase I Scope 1. Finalize off -site end location for ash relocation 2. Obtain all applicable permits for Phase 1 3. Install required site haul roads 4. Prepare and install rail load out spur for transportation by rail 5. Prepare and install truck load out and truck wash for transportation by truck 6. Install site erosion control and sediment control measures 7. Perform site preparation for ash basin ash removal 8. Perform site preparation for the basin dewatering (both 1971 basin & 1984 basin) 9. Begin bulk dewatering of the 1984 Basin 10. Excavate and transport approximately 2.0 million tons of ash from the 1984 Basin and the 1971 Basin to an approved landfill or structural fill location 11. Engineer plan to stop water inputs into the ash basins 12. Initiate rerouting or elimination of inflows to the ash basins 13. Start installation of the basin and lake isolation measures along Sutton Cooling Lake and the discharge canal 14. Finish the engineering for the on -site landfill 15. Modify the lease arrangement for public boat ramp access and install alternate access 16. Initiate landfill development for the on -site landfill 9 L.V. Sutton Electric Plant — Coal Ash Excavation Plan Noy; rnoer 13, 2014 17. Begin site preparation activities for Subsequent Phase(s) 18. Plan activities for Subsequent Phase(s) and submit an updated Plan Subsequent Phase(s) Scope 1. Identify and/or develop additional off -site ash storage options 2. Obtain all required permits for on -site land fill development 3. Construct and operate the on -site landfill 4. Continue to excavate and transport remaining ash from Sutton to an on -site landfill or structural fill location 5. Obtain all remaining required permits for next Subsequent Phase activities 6. Complete activities to stop basin inflows 7. Complete basin dewatering 8. Install discharge canal isolation measures around the LOLA area 9. Excavate and transport the material from the LOLA area Complete closure activities as outlined in Sections 3(b) And 3(c) Subparagraphs 1 &2 of the Coal Ash Management Act of 2014 IV. Critical Milestone Cates Critical Milestones within the Plan are summarized in the table below. These milestones have been added to the Level 1 Schedule. MILESTONES■ LATER THAN D. Submit Excavation Plan November 15, 2014 Complete comprehensive engineering review November 30, 2014 Excavation Plan Approval February 17, 2015 Industrial Stormwater Permit February 18, 2015 Commence work — ash removal Final permit approval + 60 Days Receive Permit to Construct On -site Landfill December 23, 2015 Submit Updated Excavation Plan — Subsequent Phase(s) December 31, 2015 Receive Permit to Operate On -Site Landfill August 1, 2016 Eliminate stormwater discharge into impoundments December 31, 2018 Impoundments closed per Sections 3(b) and 3(c) of the Coal Ash Management Act of 2014 August 1, 2019 M L.V- Sutton Electric Plant —Coal Ash Ex,--,,3tiun PLin Novcnib�;- 13, 2014 V. Level I Schedule Sution k0i Pond Cls Project Sutton Ash Pond Closure Project PrO DaX, 10-18-14 10:19 Excavation Plan Schedule cv,,&wtv - e�;Owv�; ; 11-24-4 WnkVOberk—MFeftrAMMMOM=WAppn,Val i1-2544 Oi�27-1.5' Wzat,kt WOW, P—,� t�, Nli¢sRf� 03-23-15 FKA—E i BULK rREE WATPR 1040-15, T pf", DO R& b- fAff—f 01,10-15, Obtan Inckseal Swirr e KVM P—d C,'h." I)Ah Remov.l - Wbkx- 0323ty 04.ID.16 S49 SUMNtyRepon JAW.Wne O331,15. 'Rru- i)Abb &vsc,, co4kA_'. sit pmfis. x 2ql2vm) 04.1305 -04-1346 Nxtdp�EWtons3(b).ndSjc)ddx Coal 1H IRIMUM111111111 IM MUM 0 M Was Pernt t M MMA AimApp� al 0 W.te "W NM.S PvTM A nor Mad * *w W; iRfim ------------ ---------- --------- ---------- ♦ Was*mu, WMS P "A "or -.beab. MWA.* I E-c 3tix +9A- TR. * Fa . .. E .......... 3 Ex ............................... R. DI NR Reva — IApp—d ---------- - ........ .......... .......... I Emsim & Sed—A tm GorM I Rm -Ast Re al 0 Waste I for I isp� * Obtm i*zVdSl w-Wi, -DESPern f . . .......... ....................... ---------- .......... ---------- ------- — - ♦ Ste 8 AkAxy Rel ort Mbsbx * (Fhm,I)AhRtmS-EmswC4,tcsiSib.Pnwtin j l)LwVIWiFW-ehshJl2W*.) EMMM ♦WN da Sow ral Fe .... .............. ------- .................... End b Note: This Level 1 Schedule is a living element of this Plan. Dates and durations are based on known information on the date of this Plan. 10 L.V. Sutton Electric Plant— Coal Ash Excavation Plan November 13, 2014 VI. Erosion and Sedimentation Control Plan The Erosion and Sedimentation Control Plan (E&SC) for the excavation of ash is being developed and planned for submittal by January 30, 2015. The approval of this plan by NC DENR will meet the requirement outlined in the NC DENR Letter. Any deviations from the current E&SC for Subsequent Phase(s) will be approved by NC DENR prior to installation and initiation of subsequent phase work. The approved contractor will install the E&SC measures indicated in the plan. The Engineer of Record will review the installation prior to commencing excavation on site. All control measures will be maintained through the project in accordance with the E&SC. V11. Dewatering pian The Sutton ash basins will be dewatered to facilitate the removal of ash and to mitigate risk. Dewatering the free water will improve the physical properties of the retained ash, making it less susceptible to flow in the event of an unexpected dam failure. Engineering analysis has shown that lowering the water below the level of ash within each basin does not improve the factor of safety (FS) against failure of the associated dam; therefore removal of entrapped water is not required. An Engineered Dewatering Plan for Sutton was developed. This plan details the removal of the following water: Sequence 1. 1971 Basin — Removal of free water Based on data from July 2014, the 1971 Basin contains approximately 362 thousand gallons of free water. The free water in the 1971 Basin will be pumped to the 1984 Basin. The maximum free water drawdown rate will be one foot over seven days. Following free water removal, accumulated stormwater will be removed at a maximum rate of 2 feet over 1 day. 2. Interior Containment Area— Removal of free water The 2006 ICA has accumulated an undetermined amount of free water during the summer of 2014. The free water in the 2006 ICA will be drained to the 1984 Basin. The maximum free water drawdown rate will be one foot over seven days. Following free water removal, the accumulated stormwater will be removed at a maximum rate of 2 feet over 1 day. 11 L.V. Sutton Electric Plant— Coal Ash Excavation Plan November 13, 2014 3. 1984 Basin — Removal of free water Based on data from July 2014, the 1984 Basin contains approximately 65 million gallons of free water. The maximum free water drawdown rate will be one foot over seven days. Following free water removal, accumulated stormwater will be removed at a maximum rate of 2 feet over 1 day. VIII. Proposed Location(s) for Removed Ash Phase I of the Plan will include the excavation and removal of approximately 2.0 million tons of ash from Sutton. Subsequent Phase(s) will remove the remaining ash at the site. Ash removed from the site will be transported by the contractor to properly permitted facilities. The ash storage placement will be properly managed and maintained to ensure environmental compliance with all applicable rules and regulations. Phase l: Ash Disposition Sites For Phase I, Brickhaven Mine located in Moncure, North Carolina has been identified for ash placement. This primary option provides a solution for Phase I and/or Subsequent Phase(s). Brickhaven Mine The mine is located near the city of Moncure in Chatham County of North Carolina. The mine resides on approximately 299 acres. Its primary mined minerals are clays. Ash will be transported to the mine as a reclamation project. The Brickhaven Mine will comply with the requirements set forth in Sections 4(b) and (c) of the Coal Ash Management Act of 2014. Contingent Plan: Ash Disposition Sites In the event of any issues with accepting ash at the Brickhaven Mine, the Sanford Mine has been determined as a suitable site. All necessary steps will be taken to assure that the Sanford Mine is ready to accept ash in the event of any issues at the Brickhaven Mine. 12 L.V. SLItton Electric Plait— coal Ash Excavation Plan Ncv4mher 13, 2014 Sanford Mine The Sanford Mine is located in Sanford, North Carolina. Ash will be transported from Sutton to the Sanford Mine as a reclamation project. Structural Fill Alternative In the event the structural fill options are not available, the Anson County Landfill, a permitted solid waste landfill, has been identified as the alternate location. The Anson County Landfill is located in Polkton, NC. Material will be transported by rail. Subsequent Phase(s): Ash Disposition Sites The project team will utilize lessons learned from Phase I to develop an off -site disposal strategy and/ or alternative beneficial reuse site(s) that will provide the improvements below. • Provide a reliable, long-term, cost effective, solution for ash designated for removal • Develop a supplier diverse Program to drive innovation and competition • Establish performance baselines and the system to optimize pickup, transport, drop-off and reuse IX. Transportation Alan Ash will be transported from the site, via rail car to the off -site facility. Transportation of the CCR will be conducted by approved transporters and meet DOT and other applicable federal, state, and local regulations. Phase 1: Transportation For Phase 1, all CCRs will be transported by rail from Sutton to Brickhaven site. Trains will consist of 110 gondola cars at 100 tons per car. One train will leave the site every other day or 3 to 3.5 trains per week on average. The operation of loading rail cars will be completed with a crew working typically 12 hours per day, 7 days per week. Plans are being made to design and install a rail loading system at Sutton that would transport ash to the Brickhaven Mine. 13 L.V. Sutton Electric Plant-- Coal Ash Excavation Plan November 13, 2014 01 rY 6� � Axbabo o S a. 4rt VU abo � p i Fig`?',ti CAR L,I N� pA L;mer ♦ y I.a , 52 � npnan• '?6? ' 06eMn;ns+roe , L4mQprron w 701 a H; br'le S 5 Wen" �Muntnx 7 i�ill%on 258� Goldsboro - 70,I.«a,. 0&0 Hill 1 Sorg»a �Hnll� ilmington Figure 2: Typical Truck Route to Brickhaven Mine Contingent Plan. Transportation To support the transportation of ash for the Contingent Plan, ash will be transported to the Sanford Mine (see Figure 3) instead of the Brickhaven Mine. In the event of rail transportation disruption, truck transportation remains a contingency option for either Brickhaven or Sanford. The workforce, tonnages, and schedules would remain the same as described above. �f 255J ' t .r H an d mart. w� A R � � l(.Ooldsbaro /�{f} 70 KiMl4n etteville b7tncIDupnaur 0. Hill '.te;.rin6:rr9 I Jeckaor TJn hntlt�y:l4 t.4rnbartan �7� _ phi Horsy Rre7a ita nt: rr ", l 74 ..�..IMh7te nl& eilm78 74 +`r lington r �. " Myr!Ir ,ray; Figure 3: Typical Truck Route to Sanford Mine Subsequent Phase(s): Transportation The transportation plan and any other options will be reviewed and could be amended in Subsequent Phase(s) to enhance the excavation process and objectives. 14 L..V. Sutton Electric Plan— Coal Asti Excavation Plan November 13, 2011.4 X. Environmental Permitting Man Phase l Phase 1 will include initiating excavation and removal of ash from the 1984 ash basin and the 1971 ash basin to an offsite location. Implementation for Phase I can begin once the permitting for Phase I is in place, although different permitting may be necessary prior to initiating Subsequent Phase work. Phase I will include permitting activities for subsequent phases. Through the Excavation Plan approval process, Duke Energy is seeking to confirm that all necessary approvals have been identified. The Excavation Plan is intended to authorize the excavation and movement of ash once the identified permits have been obtained. Excavation of ash creates potential for stormwater impacts. NC DENR has indicated an industrial stormwater permit may be needed. Sutton Plant has no discharges consisting of stormwater only and has therefore not submitted Form 2F applications for industrial stormwater coverage. Stormwater is combined with wastewater and permitted under the current NPDES permit. It is not anticipated that excavation will create new separate stormwater discharges. A stormwater pollution prevention plan (SWPPP) incorporating best management practices (BMPs) will be created, if necessary. Future modifications to the permit/plan will be managed as necessary. NC DENR has recently indicated that modification of the NPDES wastewater permit may be required to initiate removal of free water from inactive ash basins. The Company is submitting additional information to NC DENR for its consideration to support incorporating dewatering requirements into the pending the Company's pending NPDES permit application. The Company is working with United States Environmental Protection Agency (EPA) and NC DENR with a goal of identifying the regulatory framework that will allow the removal of free-standing water from inactive basins to move forward. There are no jurisdictional wetlands/streams associated with the removal of ash in the 1984 ash basin and the 1971 ash basin in Phase I. Future wetland/stream impacts and jurisdictional determinations will be managed through the US Army Corps of Engineers with particular attention paid to the difference between jurisdictional wetlands/streams under Section 404 and those arising from Section 402 waters. Before creation of new mine reclamation structural fills, an individual structural fill permit will need to be obtained by the mine reclamation project owner/operator. It is anticipated that the mining permit will be transferred from the existing mine owner to a 15 L.V. Sutton Electric Plant— Coal Ash Excavation Plan November 13, 201,4 mine reclamation contractor. Once the permit is transferred, the mine reclamation contractor will submit an individual structural permit application and mine reclamation plan to the Division of Mining. It is anticipated that the Division of Mining will then forward the reclamation plan to the Division of Water Resources, Division of Waste Management, and other divisions as necessary, for comments. Subject to any changes from Division of Mining, the revised reclamation plan would be approved and an individual Structural Fill Permit will be issued. No information currently exists to indicate that the Sutton ash should be treated as a DOT hazardous material shipped via truck or rail. Subsequent Phase(s) will include dewatering (once NPDES permit modification complete) and continued excavation and removal of ash from the 1984 and 1971 ash basins and the LOLA area. Subsequent Phase(s) also potentially include(s) the construction of an on -site landfill. Future jurisdictional determinations will be managed through the US Army Corps of Engineers with particular attention paid to the difference between jurisdictional wetlands/streams under Section 404 and those arising from Section 402 waters. Any Section 404 individual permitting will require Section 401 Water Quality Certification by NC DENR. If used, before shipping ash to a third -party Subtitle D landfill, waste characterization and approval will be completed. All necessary Dam Safety approvals will be obtained to cover activities on or around jurisdictional dams. Breaching of the dams will require Dam Safety approval. Any impacted wells or piezometers will be properly abandoned and dispositioned with NC DENR. Fugitive dust will be managed to mitigate impacts to neighboring areas. Impacts to threatened and endangered species will be avoided. No additional site -specific or local requirements have been identified. 16 L,11, Sutton Electric Plant— Coal Ash Excavation Plan ilovember 13, 201.4 Phase l Permit Matrix Media Permit Milestone/ Target Reasoning Date Excavation of ash creates potential for stormwater impacts. The facility will seek an approved E&SC and associated Construction Stormwater Permit approval for ash stack removal. NC DENR Industrial Stormwater NPDES has indicated an industrial Permit February 18, 2015 stormwater permit may also be needed. Sutton Plant has no discharges consisting of stormwater only. Stormwater is combined with wastewater and permitted under the current Water NPDES permit. A SWPPP incorporating BMPs will be created, if necessary. NC DENR has indicated dewatering activities including free water removal, may require Wastewater NPDES Permit — NPDES wastewater permit Minor Modification March 27, 2015 modification. Based on this requirement, Duke Energy is submitting proposed dewatering permit conditions in its pending NPDES permit application. Jurisdictional Wetland and There are no identified Stream Impacts/ 404 Permitting N/A jurisdictional wetland/stream and 401 WQC impacts in Phase I. Hauling and excavation activities must not impact a jurisdictional dam or dike. Activities are initially staying Dam Safety Approvals May 29, 2015 away from the jurisdictional dike. Removing ash from the 1971 and 1984 Ash Basins will Waste have to be reviewed with Dam Safety. Breaching of dike will require Dam Safety approval. Mine Reclamation Owner/Operator to obtain a Individual Structural Fill Permit May 29, 2015 structural fill permit as set forth in Subpart 3 of Part 2 of Article 9 of the Coal Ash Management Act. Site Specific Local Nuisance/Noise/Odor/Other NIA No local nuisance requirements Ordinances Requirements including DOT identified. and FERC Requirements 17 L.V. Sutton Electric Plant— Coal Ash Excavation Plan November 13, 2014 Subsequent Phase(s) Permit Matrix Media Permit Milestone/ Target Reasoning Date Excavation of ash creates potential for stormwater impacts. The facility will seek an approved E&SC and associated Construction Stormwater Permit approval for ash stack removal. NC DENR has indicated an Industrial Stormwater NPDES February 18, 2015 industrial stormwater permit may also Permit be needed. Sutton Plant has no discharges consisting of stormwater only. Stormwater is combined with wastewater and permitted under the current NPDES permit. A SWPPP incorporating BMPs will be created, if necessary. Water NC DENR has indicated dewatering activities including free water removal, may require NPDES Wastewater NPDES Permit October 30, 2015 wastewater permit modification. Major Modification Based on this requirement, Duke Energy is submitting proposed dewatering permit conditions in its pendinq NPDES permit application. Identify if project scope results in impacts to jurisdictional wetlands or Jurisdictional Wetland and Stream streams. Obtain JD and pursue 404 Impacts/ 404 Permitting and 401 October 30, 2015 Permit for impacts from ALOE. Also, WQC 404 permits are required for working below the ordinary high water mark. If Federal individual permitting is required, obtain 401 WQC. Mine Reclamation Owner/Operator to Individual Structural Fill Permit May 29, 2015 obtain a structural fill permit as set forth in Subpart 3 of Part 2 of Article 9 of the Coal Ash Management Act. Hauling and excavation activities must not impact a jurisdictional dam Dam Safety Approvals October 30, 2015 or dike. Activities are initially staying 50 feet away from the jurisdictional dike. Breaching of dike will require Waste Dam Safety approval. Site Suitability anticipated for offsite Site Suitability Report March 31, 2015 landfill must go through public comment. Must receive permit to begin Permit -to -Construct December 23, 2015 construction and corresponding E&SC approval to cover approved Construction design. Must provide Construction Quality Permit -to -Operate August 1, 2016 Assurance Report and then received permit before operation. Site Specific Local Nuisance/Noise/Odor/Other N/A No local nuisance requirements Ordinances Requirements including DOT and identified. FERC Requirements 18 L.V. Sutton Electric Plant— Coal rash Excavation Plan November 13, 2014 X1. Contracting Strategy The Ash Management Program strategy is to engage multiple contractors, to drive competition, system wide innovation and the collection of best practices. During the initial phase (Phase 1) of ash removal at Riverbend, L.V. Sutton, Dan River and Asheville, the Company will award the excavation, transportation, and disposal of the Ash to a single contractor for each site. The result may be two to three contractors, with each contractor having responsibility for one, or two sites, working on a firm fixed per ton price basis. The contracting strategy will shift for Subsequent Phase(s), and potentially during Phase 1, as the Company and the selected contractors recognize enhancements that can increase productivity or drive unit cost lower. Duke Energy's core values of safety and quality are non-negotiable and will not be compromised in order to increase productivity or generate cost savings. In summary, the Company's contracting strategy will provide the most effective combination of ash removal, transportation, disposition, and beneficial reuse options balancing strategic intent, cost, and schedule. The health and safety of workers, the communities, and environment will not be sacrificed to achieve these goals. XII. Environmental, Health, and Safety Plan Protecting workers, the public, the community and the environment The Company is committed to the health, safety and welfare of employees, contractors and the public, and to protecting the environment and natural resources. During all phases of the project work, the Company and its contractors will follow the Company Safe Practices; the ABSAT Environmental, Health, and Safety (EHS) supplement document, and any additional requirements. Occupational health and safety expectations include oversight and continuous improvement throughout the project. The project will include comprehensive environmental, health and safety plans encompassing all aspects of the project work including at the plant, in transit and at the final destination as needed. The project's commitment is to minimize public and environmental impacts. X111. Communications Plan Many different external stakeholders including neighbors, government officials and media have an interest in this project. For example, there is the potential for facility neighbors and the general public to see or experience construction -related impacts such as truck traffic, landscape changes, or noise. The Company is committed to 19 L.V. Sutton Electric Plane— Coal Ash Excavation Plan November 13, 201zi providing information by proactively communicating about the Project activities to potentially affected parties and responding to inquiries in a timely manner. The Project team will coordinate with Duke Energy's Corporate Communications Department to develop a comprehensive external communications plan tailored to the specific needs of each phase of the project. 20 L.V. Sutton Electric Pl;,nt— Coal Ash Excavation Plan November 13, 2014 XIV. Glossary Term Definition ABSAT Duke Energy organization acronym for Ash Basin Strategic Action Team Ash Basin Synonymous with Coal Combustion Residual Impoundment. A topographic depression, excavation, or dammed area that is primarily formed from earthen materials; without a base liner approved for use by Article 9 of Chapter 130A of the General Statutes or rules adopted thereunder for a combustion products landfill or coal combustion residuals landfill, industrial landfill, or municipal solid waste landfill; and an Area that is designed to hold accumulated coal combustion residuals in the form of liquid wastes, wastes containing free liquids, or sludge, and that is not backfilled or otherwise covered during periods of deposition. Ash Ponds Coal Combustion Residual stored in wet impoundments, or ponds Ash Stack An ash feature external to the ash basin Beneficial and Projects promoting public health and environmental protection, offering Beneficial Use equivalent success relative to other alternatives, and preserving natural resources Bottom Ash The agglomerated, angular ash particles formed in pulverized coal furnaces that are too large to be carried in the flue gases and collect on the furnace walls. Bottom Ash falls through open grates to an ash hopper at the bottom of the furnace. Bulk Water Water above the ash contained in the ash basin. Synonymous with free water Coal Ash Plan required by NC DENR letter dated August 13, 2014 including a Excavation Plan schedule for soil and sedimentation erosion control measures, dewatering, and the proposed location of the removed ash Coal Ash North Carolina Session Law 2014-122 Management Act of 2014 Coal Combustion Residuals, including fly ash, bottom ash, boiler slag, mill rejects, and flue Residuals (CCR) gas desulfurization residue produced by a coal-fired generating unit Decanting The act of removing water from ash Dewatering The act of removing bulk and entrapped water from the ash basin 21 L.V. Sutton Electric Plant— Coal Ash Excavation Plan Novernber i3, 2014 Definition Dewatering Plan Engineered plan and the associated process steps necessary to dewater an ash basin Duke Safe Work Document detailing the Duke Energy safety guidelines Practices Engineer of Record Duke Energy or 3rd party contracted engineer responsible for final verification of specific plan actions and documents Entrapped Water Flowable water below the ash surface which creates hydrostatic pressure on the dam Excavation Tasks and work performed related to the planning, engineering and Activities excavation of ash from an ash basin Excavation Plan Refer to Coal Ash Excavation Plan Factor of Safety In reference to dam safety, the ratio of the forces or moments resisting mass movement to the forces or moments tending to produce mass movement Free Water Water above the ash contained in the ash basin. Synonymous with bulk water Fly Ash Very fine, powdery material, composed mostly of silica with nearly all particles spherical in shape, which is a product of burning finely ground coal in a boiler to produce electricity and is removed from the plant exhaust gases by air emission control devices. Grading Plan Document detailing the final elevation, drainage and lay of the excavated area Level 1 Schedule Schedule view that shows the main milestones to complete the project LOLA Lay of Land Area NPDES National Pollutant Discharge Elimination System NPDES Permit A permit that regulates the direct discharge of wastewater to surface waters 22 L.V..Sutton El--ctric Plant— Coal Ash Excavation Plan November 13, 2014 XV. Reference Documents 23 Riverbend steam station Coal Ash Excavation Plan (� DUKE ENERGY. Riverbend Steam Station — Coal Ash Excavation Plan dove nbcr 13, 2014 Table of Contents I. Statement of Purpose...................................................................................................................2 11. General Facility Description........................................................... III. Project Charter...............................................................................................................................7 IV. Critical Milestone Dates................................................................................................................9 V. Level 1 Schedule.........................................................................................................................10 VI. Erosion and Sedimentation Control Plan................................................................................11 VII. Dewatering Plan..........................................................................................................................11 Vill. Proposed Location(s) for Removed Ash..................................................................................12 IX. Transportation Plan.....................................................................................................................14 X. Environmental Permitting Plan..................................................................................................16 XI. Contracting Strategy...................................................................................................................21 XII. Environmental, Health, and Safety Plan..................................................................................21 XIII. Communications Plan.................................................................................................................21 XIV. Glossary ........................................................................................................................................23 XV. Reference Documents................................................................................................................25 1 Riverbend Steam Station — Coal Ash Excavation Plan November 13, 2014 I. Statement of Purpose Duke Energy Carolinas, LLC (Duke Energy or the Company) is required by Section 3(b) of the Coal Ash Management Act of 2014 to close in accordance of Section 3(c) the coal combustion residuals (CCR) surface impoundments located at the Riverbend Steam Station, National Pollutant Discharge Eliminations System Permit No. NC0004961 Gaston County (Riverbend) as soon as practicable, but not later than August 1, 2019. Further, by letter to Duke Energy dated August 13, 2014, North Carolina Department of Environment and Natural Resources (NC DENR) requested that Duke Energy submit coal ash excavation plans for inactive coal ash impoundments at Riverbend no later than November 15, 2014 (NC DENR Letter). This Coal Ash Excavation Plan (Plan) represents Phase I and other Subsequent Phase(s) activities to satisfy the closure requirements outlined in Sections 3(b) and 3(c) sub paragraph 1 &2 of the Coal Ash Management Act of 2014 and the requests set forth in the NC DENR Letter. In general, the Plan covers the first 12 —18 months of ash basin excavation activities, including the initiation of basin dewatering, ash stack removal, and any other permitted ash removal activities within the ash basins and/or Cinder Pit Area. These activities may include decanting ash within the ash basin system. The areas within the Ash Basin include the Primary Ash Basin, the Secondary Ash Basin, and the Ash Stack. For Subsequent Phase(s), this document will be revised for any modifications to the Plan for the site. The Plan will be updated and submitted to NC DENR annually or earlier as required by Subsequent Phase(s). The NC DENR letter specifically requests that the Plan include 1) a schedule for soil and sedimentation erosion control measures, 2) dewatering, and 3) the proposed location(s) of the removed ash. These requirements are found in Section V. Level 1 Schedule, Section VI. Erosion and Sedimentation Control Plans, Section VII. Dewatering Plan, and Section VIII. Proposed Location(s) for Removed Ash. The Plan covers some of the work required by Sections 3(b) and 3(c) of the Coal Ash Management Act of 2014 (Session Law 2014-122) (Coal Ash Act, or Act). The Act requires the closure of the ash basins as soon as practicable, but no later than August 1, 2019. However, the Act contains no requirement for the submittal of an excavation plan of the kind presented here. Thus, while the formulation, submittal, and review of this Plan will assist in Duke Energy's work to close the ash basin, its ultimate approval is an action not specifically required by statutory, regulatory or other applicable authority. Additionally, it may become necessary for the Company to modify the Plan to address other legal requirements or factors that develop during ash basin excavation. Any 2 Rivvrbend Steam Station — Coal Ash Excavation Plan November 13, 2014 changes will be included in annual updates to the Plan that Duke Energy will submit to NC DENR. The precise scope of work in excavating the ash basins will be determined by applicable laws, rules, permits, and approvals that control the activities to be performed under the Plan. For example, the United States Environmental Protection Agency (EPA) is considering issuing rules regarding the management of coal ash (proposed EPA Coal Ash Rules). Similarly, the water quality permit for the discharge from the Pond (National Pollutant Discharge Elimination System Permit No. #NC0004961 Gaston County) or its reissuance or amendment (NPDES Permit) could contain terms that control or affect the scope of that work. NC DENR filed legal cases in Superior Court (NC DENR Cases), which could be resolved through decision or settlement. NC DENR also sent Duke Energy a Notices of Violation (NOVs) regarding surface water and groundwater quality issues at the Plant. All of the above (Coal Ash Act, NC DENR Letter, NPDES Permit, NC DENR Cases, NOVs, and the proposed EPA Coal Ash Rules) are illustrative of actions that could potentially affect the precise scope of the work to be performed under the Plan. As a consequence, neither the submittal of this Plan nor its approval by NC DENR should be taken as requiring actions different from other such applicable requirements. Thus, Duke Energy submits this Plan to NC DENR based on the understanding that it may be necessary to make changes in the Plan in the future to reflect any such actions and reserves the right to make such changes after NC DENR's approval of the Plan. 3 Riverbend Stearn Station — Coal Ash Excavation Plan November 13, 2014 II. General Facility Description Riverbend is located off of Horse Shoe Beach Road near the town of Mt. Holly in Gaston County, North Carolina, on the south bank of the Catawba River. The seven - unit station began commercial operation in 1929 with two units and then expanded to seven by 1954. At its peak, the generating facility had a capacity of 454 megawatts. As of April 1, 2013, all of the coal-fired units were retired. The CCR from Riverbend's coal combustion operations was historically processed in the ash basin system located on the northeast of the property adjacent to the Catawba River. The discharge from the ash basin system is permitted through Outfall #002 to the Catawba River in the Catawba River Basin by NC DENR's Division of Water Resources (DWR) under the National Pollutant Discharge Elimination System (NPDES) Permit # NC0004961. Currently, Riverbend is being decommissioned, and no active ash placement or sluicing is occurring within the ash basin system. Ash Basin System The ash basin system was an integral part of the station's NPDES permitted wastewater treatment system, which predominantly received inflows from the ash removal system, station yard drain sump, and stormwater flows. During station operations, inflows to the ash basin were highly variable due to the cyclical nature of station operations. The current ash basin system consists of a Primary Ash Basin cell (west side) and a Secondary Ash Basin cell (north side), which are separated by an intermediate dam. For the purpose of stormwater management, the Ash Stack is also within the ash basin system. The ash basin system is located approximately 2,400 feet to the northeast of the power plant, adjacent to the Catawba River, as shown on Figure 1. The Primary Ash Basin cell is impounded by an earthen embankment dam, referred to as Primary Dam #GASTO-97, located on the west side of the Primary Ash Basin cell. The Secondary Ash Basin cell is impounded by an earthen embankment dam, referred to as Secondary Dam #GASTO-98, located along the northeast side of the Secondary Ash Basin cell. Originally, the ash basin at Riverbend consisted of a single -cell basin commissioned in 1957. It was expanded in 1979 to its current configuration. In 1979, the original single basin was divided by constructing a divider dam (Intermediate Dam #GASTO-99) to form two separate cells (Primary Ash Basin and Secondary Ash Basin). This modification improved the original pond's overall ability for suspended solids removal. The Intermediate Dam was built over sluiced ash to a crest of 730 feet. At the same time, the Secondary Dam crest elevation remained at 720 feet. At present, the Primary Ash Basin and the Secondary Ash Basin are estimated to contain approximately 2.1 million and 700 thousand tons of CCR, respectively. 4 Diver band Stearn Station — Coal Ash Excavation Plan November 13, 2014 The inflows from the ash removal system and the station yard drain sump are directed through sluice lines into the Primary Ash Basin cell. The discharge from the Primary Ash Basin to the Secondary Ash Basin is through a concrete discharge tower located near the divider dam. The surface area of the Primary Ash Basin is approximately 41 acres with an approximate maximum pond elevation of 724 feet above mean sea level. The surface area of the Secondary Ash Basin is approximately 28 acres with an approximate maximum pond elevation of 714 feet above mean sea level. The full pond elevation of Mountain Island Lake is approximately 647 feet above mean sea level. Although the station is retired, stormwater and wastewater effluent from other non -ash - related station flows to the ash basin are discharged in compliance with the station's NPDES permit to Catawba River through a concrete discharge tower located in the Secondary Ash Basin. The concrete discharge tower drains through a 30 inch diameter corrugated metal pipe (CMP) into a concrete -lined channel. The channel extends from the Secondary Ash Basin to an NPDES Outfall #002 that discharges to the Catawba River. The Secondary Ash Basin elevation is controlled by the use of concrete stop logs. Ash Stack An ash fill deposit, known as the "Ash Stack", was constructed from ash removed from the Primary and Secondary Ash Basins during basin clean -out projects. The Ash Stack was utilized for the ash basin cleanouts periodically to prolong the life of the ash basins. The Ash Stack is a 29 acre area located south of the Primary Ash Basin and is estimated to contain 1.5 million tons of CCR. The Ash Stack was constructed during two ash basin clean -outs; the last recorded ash basin cleanout project was in 2007. The Ash Stack area currently has a 1.5 — 2.0 ft. soil cover and vegetation that has been maintained following the last deposition in this area. For the purpose of water management, the stormwater run-off from the Ash Stack area is routed to the ash basin system. Cinder Pit And Other Identified Ash Storage Areas Prior to construction of the ash basin, bottom ash (cinders) were deposited in a primarily dry condition in the "Cinder Pit" and other areas near the cinder pit and coal pile. The Cinder pit is approximately 13 acres and is located in a triangular area northeast of the coal pile and northwest of the rail spur (See Figure 1). This area was utilized for storage of ash material at the station prior to the installation of precipitators and a wet sluicing system. The Cinder Pit contains predominantly dry cinders and is currently covered with dense vegetation. The Cinder Pit is estimated to contain 300 thousand tons of CCR. 5 Riverbend Steam Station — Coal Ash Excavation Plan November 13, 2014 Figure 1: Riverbend Steam Station Riverbend Steam Station — Coal Ash Excavation Plan November 13, 2014 III. Project Charter As a further commitment, the Company has formed an internal team, the Ash Basin Strategic Action Team (ABSAT). This team is dedicated to strengthening and executing a comprehensive strategy for increased oversight and closure of all of the Company's ash basins. Dewatering of the ash basins and the removal of ash from the site will be performed within project phases: Phase I and Subsequent Phase(s). Required permits for each phase are set forth in Section X of this Plan. Phase I will include the initial removal of ash from the Ash Stack, begin bulk dewatering, and complete any other subsequent permitted activities. The excavation will begin with the approval of this Plan by NC DENR and the receipt of final permits. In addition, a dewatering plan for the ash basins has been drafted and, if approved by NC DENR, bulk dewatering will be expedited during the initial phase of work. Duke Energy has submitted an application to modify its NPDES wastewater permit to include controls to be implemented during dewatering activities. During Phase I, the Company will continue to perform the pre -construction and planning activities for the Subsequent Phase(s). These activities include project planning, development of new ash disposition options, and completion of additional required permitting that may be necessary for the ash removal from the ash basins and Cinder Pit. Knowledge and opportunities for program improvement obtained during Phase I of the project will be applied to the Subsequent Phase(s). Project Charter Objectives Phase I Objectives 1. Initiate the removal of ash from the Riverbend site 2. Plan activities for the Subsequent Phase(s), including development of option(s) for proposed ash disposal or beneficial reuse location(s) 3. Validate production rates to meet project requirements 4. Gain knowledge and opportunities for program improvement that can be applied to the Subsequent Phase(s) Subsequent Phase(s) Objectives 1. Dewater Ash Basins 2. Remove all remaining ash from the Ash Stack, Cinder Pit, Primary Ash Basin and Secondary Ash Basin 3. Submit permit applications for next Subsequent Phase (if applicable) 7 Riverbend Stearn Staiion — Coal Ash Excavation Plan November 13, 2014 Project Charter Scope Phase I Scope 1. Finalize end location(s) for removed ash and obtain all required permits 2. Obtain all applicable permits for work in Phase 1 3. Install site erosion and sedimentation control measures 4. Begin site preparation activities, including mobilization 5. Excavate and transport approximately 1 million tons of ash from the Ash Stack to Roanoke Cement Company and Brickhaven Mine 6. Engineer plan to stop water inputs into the ash basins 7. Initiate rerouting of inflows to the ash basins 8. Begin dewatering the Primary and Secondary Ash Basins 9. Plan activities for Subsequent Phase(s) and submit an updated Plan 10. Begin site preparation activities for the Subsequent Phase(s) 11.Assess, including delineation, the potential remediation efforts in the Cinder Pit 12. Submit and/or obtain all remaining required permit applications for ash removal activities for Subsequent Phase(s) 13. Identify and/or develop additional location(s) for removed ash for Subsequent Phase (if applicable), including obtaining all required permits Subsequent Phase(s) Scope 1. Obtain all remaining required permits for next Subsequent Phase for ash removal activities (if applicable) 2. Finalize and/or develop additional location(s) for removed ash (if applicable) and obtain all required permits 3. Complete activities to stop basin inflows 4. Complete basin dewatering 5. Excavate and transport the remaining ash from Riverbend to an approved landfill or structural fill location 6. Complete closure activities as outlined in Sections 3(b) and 3(c) subparagraphs 1 &2 of the Coal Ash Management Act of 2014 N. Piverbend Steam Station _ Coal Ash Excavation Plan November 13, 2014 IV. Critical Milestone Dates Critical Milestones within the Plan are summarized in the table below. These milestones have been added to the Level 1 Schedule. MILESTONES -,ML Submit Excavation Plan NO LATER THAN DATEIJ, November 15, 2014 Complete comprehensive engineering review November 30, 2014 Excavation Plan Approval February 17, 2015 Industrial Stormwater Permit March 5, 2015 Commence work — ash removal Final permit approval + 60 Days Submit Updated Excavation Plan — Subsequent Phase(s) December 31, 2015 Eliminate stormwater discharge into impoundments December 31, 2018 Impoundments closed per Sections 3(b) and 3(c) of the Coal Ash Management Act of 2014 August 1, 2019 p7 Riverbend Stearn Station — Coal Ash Excavation Plan November 13, 2014 V. Level 1 Schedule Rivert—d Ash Relaaatw Project Rk erhend Ash Retacafan Project RW Dam W&14138.47 "=xaava;ian 2lan Schetlaie Aawly;q— Bart -. sh 'G16 2::4 2Z'7 2.t5 MI. L22M 2021 2022 •t: 1 DEWATERINa _ 2 a<a—g-]i"" t4 A ' :0-91-14 _�Er.ari^ - -^7,. ee •; az_,. ,,_.. �.-i-F+ry lA. ai9: �1 aI 4f-03'4 '3.-T5 - ;'ice .a:e-I�:=❑ Per-' --i ', irera---i, ' �sakT#p's 4Y3n9G39;Yi 5dl=:ur< g32 .5 � 4 Nay: .a:�..-� SFEr --idol : -G�Mies- . t'r3d.5E1 J1:7_K %RaOvV:SER IL3sJ'„� _.. ... 7-1 Lift � 3 .......... 0 ...._.... ik5= 1 9 ,_..._........ .. __-' - -' eL s1 _ _____ ________ _ ___. --------- Vi�aS[FYI2t£T4a_S�:-^,1I 1A3,J�h!W�:id[M 1��1ESt?"f2 'Q _.-S' �': 25:Ev\e'K -'_:a'^e. 7.4 EXCAYAT ION P IAN 11-0b14' I ti-01-14 I aa'rato, Plan -'P 4 PrepaeYSubmt ExcaatmPln i '*4 T§ H. 14 4..., a 1 Pte,�ef Ur,r. F.. ab . aia- - : ............. Subrnh�Kaava -Pi3n it-1afa. .................. __ ___________ __________ __________ __________ __________ _ _— a?.. _.>_„ .-.^;�rlsi ].. 4fi-f4 t1243-15 ASH REPOVAJ, : `.'sn ln5a^ai • �-ra�-. --'----'- o�saa�5 -Lva --------- a'c5?r --------- --------- {cTm_ - A ...a.:.ik•P ��.. 41do-15 _,�03T215 � I s I.tihvE. .al AS:; ,rr f�=.i. _-..nl :G !'il_: va�]Y�I ll 1Zi•? 2d-15 ? I R:3= ;,c-ce �YaSC'•l]3'. 33JF _:} D3271i Ij2{-.t5 3 �'� •j -:2C" .... _" >n¢u;a:al�aueaV'P pzmu � - — -- --' -- —___. ��-2 is"3 ♦ Irvis-C � 9, ..:a' PI=r:-. ❑z=s na'e-.y+ti�.--.rlye 3r2615' j •D Safety ak Erd Slamiwaler L'ucharge m mews i2 31-15'4, Erd D. arge to M poxcrrw Impwndmer.� Clrsed ' fi8-01-1g' ♦ 1 Do — Note: This Level 1 Schedule is a living element of this Plan. Dates and durations are based on known information on the date of this Plan. 10 Piverband Stearn Station — Coal Ash E=:cavation Plan Noveniber 13, 2014 VI. Erosion and Sedimentation Control Plan The Erosion and Sedimentation Control Plan (E&SC) for the excavation of the Ash Stack has been developed. This plan and schedule were submitted to NC DENR and approved on July 3, 2014. The approval of this plan by NC DENR meets the requirement outlined in the NC DENR Letter. The approved contractor will install the E&SC measures indicated in the plan. The Engineer of Record will review the installation prior to commencing excavation on site. All control measures will be maintained through the project in accordance with the E&SC. The modification of the E&SC for the excavation of the ash basins and Cinder Pit Area is currently under development and will be submitted as part of the Subsequent Phase(s). Any deviations from the current E&SC for Subsequent Phase(s) are to be approved by NC DENR prior to installation. VII. Dewatering Plan The Riverbend ash basins will be dewatered to facilitate the removal of ash and to mitigate risk. Lowering the water level within each basin will improve safety factors of the dams by reducing the driving force on the upstream face of the dam. Similarly, dewatering will improve the physical properties of the retained ash, making it less susceptible to flow in the event of an unexpected dam failure. An Engineered Dewatering Plan for Riverbend was developed to remove the following water from the ponds: rolp-r-OPPM Primary Ash Basin — Removal of free water Based on data from June 2014, the Primary Ash Basin contains approximately 2.1 million gallons of free water. The free water in the Primary Ash Basin will be pumped to the Secondary Ash Basin to minimize hydraulic pressure on the intermediate dam. The maximum free water drawdown rate will be one foot over seven days. Following free water removal, accumulated stormwater will be removed at a maximum rate of 2 feet over 1day. CONFIDENTIAL - NOT FOR DISTRIBUTION 11 Riverbend Steam Station — Coal Ash Excavation Plan November 13, 2014 2. Primary Ash Basin — Removal of water 10 feet below top of ash After removal of free water, the entrapped water level within the Primary Ash Basin will be lowered by approximately 10 feet. To achieve the desired water level, a trench approximately 15 — 20 feet deep will be constructed in the Primary Basin just inside the Primary Ash Basin dam to draw down entrapped water in the vicinity of the dam. 3. Secondary Ash Basin— Removal of free water Based on data from June 2014, the Secondary Ash Basin contains approximately 101 million gallons of free water. The maximum free water drawdown rate will be one foot over seven days. Following free water removal, accumulated stormwater will be removed at a maximum rate of 2 feet over 1 day. VIII. Proposed Location(s) for Removed Ash Phase I of the Plan will include the excavation and removal of approximately 1.0 million tons of ash from the Ash Stack. Subsequent Phase(s) will remove the remaining ash at the site. Ash removed from the site will be transported by the contractor to properly permitted facilities. The ash placement location will be properly managed and maintained to ensure environmental compliance with all applicable rules and regulations. Phase l: Storage Sites For Phase I, several sites have been identified for beneficial reuse. The primary option provides a solution for Phase I and/ or Subsequent Phase(s). These sites include the Roanoke Cement Company in Troutville, Virginia and the Brickhaven Mine in Moncure, North Carolina. Roanoke Cement Company The Roanoke Cement Company (RCC) is located at 6701 Catawba Road, Troutville, Virginia. The material hauled from Riverbend to RCC will be used primarily to produce fly ash modified concrete. The practice of adding fly ash to concrete has been accepted 12 Riverbed Steam Station — Coal Ash Excavation Plan November 13, 2314 since the 1970's and will be in accordance with ASTM standards, which provides standards and specification for the production at the RCC facility. Brickhaven Mine The mine is located near the city of Moncure in Chatham County of North Carolina. The mine resides on approximately 299 acres. Its primary mined minerals are clays. Ash will be transported to the mine as a reclamation project. The Brickhaven Mine will comply with the requirements set forth in Sections 4(b) and (c) of the Coal Ash Management Act of 2014. Contingent Plan: Ash Disposition Sites For a Contingent Plan, the RCC facility will be utilized as described above. In the event of any issues with accepting ash at the Brickhaven Mine, the Sanford Mine has been determined as a suitable alternative site. All necessary steps will be taken to assure that the Sanford Mine is ready to accept ash in the event of any issues at the Brickhaven Mine. Sanford Mine The Sanford Mine is located in Sanford, North Carolina. Ash will be transported from Riverbend to the Sanford Mine as a reclamation project. Structural Fill Alternative In the event the structural fill options are not available, the Anson County Landfill, a permitted solid waste landfill, has been identified as the alternate location. The Anson County Landfill is located in Polkton, NC. Material will be transported by rail. 13 Riverbend Steam Station - Coal Ash Excavation Plan blovemuer 13, 201 Subsequent Phase(s): Ash Disposition Sites The project team will utilize lessons learned from Phase I to develop an off -site disposal strategy and/or alternative beneficial reuse site(s) that will provide the improvements below. Provide a reliable, long-term, cost effective, solution for ash designated for removal Develop a supplier diverse Program to drive innovation and competition Establish performance baselines and the system to optimize pickup, transport, drop-off and reuse IX. Transportation Plan Ash will be transported from the site via rail car and/or highway trucks to the off -site facilities. Transportation will be conducted by approved transporters. Drivers and trucks will meet Department of Transportation (DOT) and other applicable federal, state, and local regulations. All drivers will follow all DOT regulations pertaining to the trucking including DOT bridge laws. Phase 1: Transportation For Phase i, approximately 10,000 tons per month of ash will be excavated and hauled to the RCC facility in the first three to four months via truck (see Figure 2). This tonnage equates to approximately 15 to 22 truckloads per day. After this start-up period, throughput will be increased by approximately 50,000 to 55,000 tons per month, which will be moved to the Brickhaven Mine via truck (see Figure 3). The total tonnage of 60,000 to 65,000 tons per month equates to 120 to 142 truckloads per day. 14 Riverbend Steam Station — Coal Ash Excavation Plan November 13, 2014 rnn-rr,x.w F'WA,r 'Nr:en LY,M �, h1Y r+l� R „GwHV airc&:i 1 * `•E;,Aeaiwkf - ,!' •un ;.F""'• Snhlcw. Tvrna:, , - Hw¢+sn[wn y ,. YAI ,Rat1y'J�Jrx'; d > 15a �y [+tiv� . • .. ni'.'ANrJ. `ne..ua:,%. W✓i9.'V FiMF hdeywar. ISVLu W__-,'� b] �•'"Il:r,+17 rWt� flxgr,, #'a fJap,'d3r fn, � lskL-Jc ✓'� " ccq --Mhw I.,ea• aar„.r its;.. -. Srebr lroio • � W,M .v++� FL •i ,4r• � 69 fk.a 'hil*M 911r�� � 'aRsFs Fre „wxr "J- caiEav"u7^. `ashax.a",> c cam'.. ra"h- AAA-, rwr, 4,. ." 41.., x. we «ivM fe3t rtr 9WWy �Ga3 . • Cl}(IClotte %f}K.Ltk,b' `}nn . >T'[_ str �lrs+rual 4'prhe'r fees, :.''r Figure 2: Typical Truck Route to Roanoke Cement Company Facility t�oios Mal6erry Shrals �g 52okesdale �r -Busby Fork if4(tfiStoft-$$lentCa Moravian Falls' - .,�-GF$er1517oF0 E- le Mills •Farmington Hi Lenoir ] �; j Chapel Hil 'Lo - it 1501 Statesville Tyro, ., � . . CAry e� Hickory �y ilbury. �� s IILFEevvtan ¢ '. [ Gai `y mapoiis Prim An ll, }San! yid @ r a RConcord Aibemade ��.. Cacti -age. Eieltry castAty, ndClO tE .i M lohnsormlle z�•' - 'horwood 5ixuthern Pmes', ; Matthews Zin Fayetteville gYodc Mrarrroe , Falkton _. r9 Rock Hill , Rockuig h'+m ,Saratt ~q °LL iiape:'&lills MCI Figure 3: Typical Truck Route to Brickhaven Mine Plans are being made to design and install a rail loading system at Riverbend that would transport ash to the Brickhaven Mine. Once rail loading/unloading systems have been installed and established at Riverbend and at the Brickhaven Mine, a combination of rail and truck or all rail can be utilized to transport ash to the two locations. By utilizing a combination of truck and rail or all rail, an estimated total of 160,000 to 165,000 tons of ash can be transported per month. The schedule estimates that ash can start being hauled by rail during the seventh month. 15 Riverbend Steam Station — Coal Ash Excavation Plan November 13, 2014 For Phase I excavation and hauling, a typical 9-hour work shift with two shifts per day for five days per week will be employed. This typical schedule may be utilized or modified in Subsequent Phase(s) to meet the August 1, 2019 compliance date. Gtnar - rharn Figure 4: Typical Truck Route to Sanford Mine Increase Rail Opportunity 1, If the opportunity of transporting more ash by rail occurs, the amount sent to the RCC facility may be reduced and the amount sent to the structural fill options may be increased. Subsequent Phase(s): Transportation The transportation plan and any other options will be reviewed and could be amended in Subsequent Phase(s) to enhance the excavation process and objectives. X. Environmental Permitting Plan Phase I Phase 1 will include initiating excavation and removal of ash from the Ash Stack. Implementation for Phase I can begin once the permitting for Phase I is in place, although different permitting may be necessary prior to initiating Subsequent Phase work. Permitting activities for Subsequent Phase(s) will be included in Phase I. Through this Excavation Plan approval process, Duke Energy is seeking to confirm that all necessary approvals have been identified. The Excavation Plan is intended to authorize the excavation and movement of ash once the identified permits have been obtained. 16 Riverbend Steam Station -- Coal Ash Excavation Plan Noaernber 131, 2014 Excavation of ash creates potential for stormwater impacts. The facility holds an approved Erosion & Sedimentation Control Plan and associated Construction Stormwater Permit approval for ash stack removal. NC DENR has indicated an industrial stormwater permit may also be needed. Based on this representation from NC DENR, Duke Energy has applied for an NPDES industrial stormwater permit to support ash removal at the site. A stormwater pollution prevention plan (SWPPP) incorporating best management practices (BMPs) will be created. Future modifications to the permit/plan will be managed as necessary. NC DENR has recently indicated that modification of the NPDES wastewater permit may be required to initiate removal of free water from inactive ash basins. Duke is submitting additional information to NC DENR for its consideration to support incorporating dewatering requirements into the Company's pending NPDES permit application. The Company is working with the United States Environmental Protection Agency (EPA) and NC DENR with a goal of identifying the regulatory framework that will allow the removal of free-standing water from inactive basins to move forward. There are no jurisdictional wetlands/streams associated with the removal of the Ash Stack or Primary or Secondary Ash basins in Phase I. Future wetland/stream impacts and jurisdictional determinations will be managed through the US Army Corps of Engineers (ACOE) with particular attention paid to the difference between jurisdictional wetlands/streams under Section 404 and those arising from Section 402 waters. Before creation of new mine reclamation structural fills, an individual structural fill permit will need to be obtained by the mine reclamation project owner/operator. It is anticipated that the mining permit will be transferred from the existing mine owner to a mine reclamation contractor. Once the permit is transferred, the mine reclamation contractor will submit an individual structural permit application and mine reclamation plan to the Division of Mining. It is anticipated that the Division of Mining will then forward the reclamation plan to the Division of Water Resources, Division of Waste Management, and other divisions as necessary for comments. Subject to any changes from Division of Mining, the revised reclamation plan would be approved and an individual Structural Fill Permit will be issued. No information currently exists to indicate that the Riverbend ash should be treated as a DOT hazardous material shipped via truck or rail. Subsequent Phase(s) will include dewatering (once NPDES permit modification is complete), and continued excavation and removal of ash from the Ash Stack, Primary and Secondary Ash Basins and the Cinder Pit area. 17 Piverbend Stearn Station — Coal Ash Excavation Plan November 13, 20,14 Future jurisdictional determinations will be managed through the US Army Corps of Engineers with particular attention paid to the difference between jurisdictional wetlands/streams under Section 404 and those arising from Section 402 waters. Any Section 404 individual permitting will require Section 401 Water Quality Certification by NC DENR. If used, before shipping ash to a third -party Subtitle D landfill, waste characterization and approval will be completed. All necessary Dam Safety approvals will be obtained to cover activities on or around jurisdictional dams. Breaching of the dams will require Dam Safety approval. Any impacted wells or piezometers will be properly abandoned and dispositioned with NC DENR. Fugitive dust will be managed to mitigate impacts to neighboring areas. Impacts to threatened and endangered species will be avoided. No additional site -specific or local requirements have been identified. 18 Riverband Steam Station — Coal Ash Excavation Plan Novarnber 13, 2014 Phase I Permit Matrix Milestone/Target Media Permit Date Reasoning Excavation of ash creates potential for stormwater impacts. The facility holds an approved Erosion & Sedimentation Control Plan and associated Industrial Stormwater NPDES Construction Stormwater Permit Permit March 5, 2015 approval for ash stack removal. NC DENR has indicated an industrial stormwater permit may also be needed. Duke has applied for this permit. A SWPPP incorporating BMPs will be created. Water NC DENR has indicated dewatering activities, including free water removal, Wastewater NPDES Permit — may require NPDES wastewater Minor Modification March 27, 2015 permit modification. Based on this, Duke is submitting proposed dewatering permit conditions in its pending NPDES permit application. Jurisdictional Wetland and Stream Impacts/404 Permitting and 401 N/A There are no identified jurisdictional WQC wetland/stream impacts in Phase I. Hauling and excavation activities must not impact a jurisdictional dam or dike. Activities are initially staying 50 feet away from the jurisdictional dike. Dam Safety Approvals May 29, 2015 Removing ash from the Primary and Secondary Ash Basins will have to be reviewed with Dam Safety. Breaching Waste of dike will require Dam Safety approval. Mine Reclamation Owner/Operator to Individual Structural Fill Permit March 27, 2015 obtain a structural fill permit as set forth in Subpart 3 of Part 21 of Article 9 of the Coal Ash Management Act Site specific Local Nuisance/Noise/Odor/Other N/A No local nuisance requirements Ordinances Requirements including DOT and identified. FERC Requirements 19 Riverbend Stean-) Station — Coa! Ash Excavation Plan November 13, 2014 Subsequent Phase(s) Permit Matrix Milestone/Target Media Permit Date Reasoning Excavation of ash creates potential for stormwater impacts. The facility holds an approved Erosion & Sedimentation Control Plan and associated Industrial Stormwater NPDES Construction Stormwater Permit Permit March 5, 2015 approval for ash stack removal. NC DENR has indicated an industrial stormwater permit may also be needed. Duke has applied for this permit. A SWPPP incorporating BMPs will be created. NC DENR has indicated dewatering activities, including free water removal, Water Wastewater NPDES Permit — may require NPDES wastewater permit Major Modification August 28, 2015 modification. Based on this, Duke is submitting proposed dewatering permit conditions in its pending NPDES permit application. Identify if project scope results in impacts to jurisdictional wetlands or Jurisdictional Wetland and Stream streams. Obtain JD and pursue 404 Impacts/404 Permitting and 401 August 28, 2015 permit for impacts from the ACOE. WQC Also, 404 permits are required for working below the ordinary- high water mark. If Federal individual permitting is I required, obtain 401 WQC. Mine Reclamation Owner/Operator to Individual Structural Fill Permit March 27, 2015 obtain a structural fill permit as set forth in Subpart 3 of Part 21 of Article 9 of the Coal Ash Management Act Waste Hauling and excavation activities must not impact a jurisdictional dam or dike. Dam Safety Approvals August 28, 2015 Activities are initially staying 50 feet away from the jurisdictional dike. Breaching of dike will require Dam Safety approval. Site specific Local Nuisance/Noise/Odor/Other N/A No local nuisance requirements Ordinances Requirements including DOT and identified. FERC Requirements 20 Riverbend Siea,n Station - Coal Ash Excavation Plan Novemt jer 13, 2014 XI. Contracting Strategy The Ash Management Program strategy is to engage multiple contractors, to drive competition, system wide innovation and the collection of best practices. During the initial phase (Phase 1) of ash removal at Riverbend, L.V. Sutton, Dan River and Asheville, the Company will award the excavation, transportation, and disposal of the Ash to a single contractor for each site. The result may be two to three contractors, with each contractor having responsibility for one, or more sites, working on a firm fixed per ton price basis. The contracting strategy will shift for Subsequent Phase(s), and potentially during Phase 1, as the Company and the selected contractors recognize enhancements that can increase productivity or drive unit cost lower. Duke Energy's core values of safety and quality are non-negotiable and will not be compromised in order to increase productivity or generate cost savings. In summary, the Company's contracting strategy will provide the most effective combination of ash removal, transportation, disposition, and beneficial reuse options balancing strategic intent, cost, and schedule. The health and safety of workers, the communities, and environment will not be sacrificed to achieve these goals. XII. Environmental, Health, and Safety Plan Protecting workers, the public, the community, and the environment Duke Energy is committed to the health, safety and welfare of employees, contractors and the public; and to protecting the environment and natural resources. During all phases of the project work, Duke Energy and its contractors will follow the Duke Energy Safe Practices; the ABSAT Environmental, Health, and Safety (EHS) supplement document, and any additional requirements. Occupational health and safety expectations include oversight and continuous improvement throughout the project. The project will include comprehensive environmental, health and safety plans encompassing all aspects of the project work including at the plant, in transit and at the final destination as needed. The project is committed to minimizing public and environmental impacts. XIII. Communications Plan Many different external stakeholders including neighbors, government officials and media have an interest in this project. For example, there is the potential for facility neighbors and the general public to see or experience construction -related impacts such as truck traffic, landscape changes, or noise. The Company is committed to 21 Riverbend Steam Station -- Coal Ash Excavation Plan November 13, 2014 providing information by proactively communicating about the Project activities to potentially affected parties and responding to inquiries in a timely manner. The Project team will coordinate with Duke Energy's Corporate Communications Department to develop a comprehensive external communications plan tailored to the specific needs of each phase of the project. 22 Riverbend Steam Station — Coa! Ash Excavation Plan November 13, 2014 XIV. Glossary Term Definition ABSAT Duke Energy organization acronym for Ash Basin Strategic Action Team Ash Basin Synonymous with Coal Combustion Residual Impoundment. A topographic depression, excavation, or dammed area that is primarily formed from earthen materials; without a base liner approved for use by Article 9 of Chapter 130A of the General Statutes or rules adopted thereunder for a combustion products landfill or coal combustion residuals landfill, industrial landfill, or municipal solid waste landfill; and an Area that is designed to hold accumulated coal combustion residuals in the form of liquid wastes, wastes containing free liquids, or sludge, and that is not backfilled or otherwise covered during periods of deposition. Ash Ponds Coal Combustion Residual stored in wet impoundments or ponds Ash Stack Ash storage area located at the south end of the Primary Ash Basin Beneficial and Projects promoting public health and environmental protection, Beneficial Use offering equivalent success relative to other alternatives, and preserving natural resources Bottom Ash The agglomerated, angular ash particles formed in pulverized coal furnaces that are too large to be carried in the flue gases and collect on the furnace walls. Bottom Ash falls through open grates to an ash hopper at the bottom of the furnace. Bulk Water Water above the ash contained in the ash basin. Synonymous with free water Cinder Pit Area located northeast of the Riverbend Coal Pile containing predominately dry cinders Coal Ash Excavation Plan required by NC DENR letter dated August 13, 2014 Plan including a schedule for soil and sedimentation erosion control measures, dewatering, and the proposed location of the removed ash Coal Ash Management North Carolina Session Law 2014-122 Act of 2014 23 Riverbend Steam Station -- Coal Ash Excavation Plan November 13, 2014 Term Definition '4w" Coal Combustion Residuals, including fly ash, bottom ash, boiler slag, mill rejects, Residuals (CCR) and flue gas desulfurization residue produced by a coal-fired generating unit Decanting The act of removing water from ash Dewatering The act of removing bulk and entrapped water from the ash basin Dewatering Plan Engineered plan and the associated process steps necessary to dewater an ash basin Duke Safe Work Document detailing the Duke Energy safety guidelines Practices Engineer of Record Duke Energy or 3rd party contracted engineer responsible for final verification of specific plan actions and documents Entrapped Water Flowable water below the ash surface which creates hydrostatic pressure on the dam Excavation Activities Tasks and work performed related to the planning, engineering and excavation of ash from an ash basin Excavation Plan Refer to Coal Ash Excavation Plan Factor of Safety In reference to dam safety, the ratio of the forces or moments resisting mass movement to the forces or moments tending to produce mass movement Free Water Water above the ash contained in the ash basin. Synonymous with bulk water Fly Ash Very fine, powdery material, composed mostly of silica with nearly all particles spherical in shape, which is a product of burning finely ground coal in a boiler to produce electricity and is removed from the plant exhaust gases by air emission control devices. Grading Plan Document detailing the final elevation, drainage and lay of the excavated area 24 Riverbend Steam Station -- Coal Ash Excavation Plan November 13, 2014 DefinitionTerm Level 1 Schedule Schedule view that shows the main milestones to complete the project NPDES National Pollutant Discharge Elimination System NPDES Permit A permit that regulates the direct discharge of wastewater to surface waters Off -Site Facility A structural fill or mine reclamation for the long term storage of coal combustion residuals Permitting Federal, state, county or local government authorizing document Primary Ash Basin Western cell of the Ash Basin system located at Riverbend on the northeast side of the property (Primary Dam # GASTO-97) Secondary Ash Basin Northern cell of the Ash Basin system located at Riverbend on the northeast side of the property (Secondary Dam # GASTO-98) Work Plan Document detailing activities to accomplish a specific task or scope of work XV. Reference Documents 25