NCS000574_Cape Fear Coal Pile Cleanup Info_20150311

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DUKE
ENERGY®
PROGRESS
March 11, 2015
Mr. Bradley Bennett
Stormwater Permitting Program
Division of Energy, Mineral, and Land Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
Cape Fear Steam Electric Plant
500CP&LRoad
Moncure, NC 27559
Subject: Additional Information to Support NPDES Stormwater Permit Application
Cape Fear Plant
Chatham County
Dear Mr. Bennett,
Duke Energy Progress, Inc. (Duke Energy) is pleased to submit this correspondence which presents the
process utilized to remove coal from the former coal yard storage area at the Cape Fear Station located
near Moncure, North Carolina. This correspondence presents a brief history of the coal yard storage
area, the process Duke Energy staff utilized to determine residual coal removal was complete, and
conclusions.
Background
The Cape Fear Station began commercial operation in 1923. At its peak operational capacity, the Station
operated six coal fired units which generated approximately 316 megawatts. Duke Energy retired the
Station in 2012. As part of the retirement and decommissioning process, usable (combustible) coal was
recovered from the coal yard area and burned at an operating unit on site. Coal has not been burned at
the site since retirement. Non -usable (non-combustible) coal comingled with soil was excavated,
transported and disposed of at an off -site permitted Subtitle D Municipal Solid Waste (MSW) landfill.
Erosion & Sediment Control Plan Coal Removal and Site Restoration Final Grading
In January 2012, Duke Energy commissioned a subsurface exploration of the coal yard area to define the
thickness of deposited coal and to determine the depth and location of native/natural soil. Nine soil
borings were drilled to depths of 2 to 14 feet below grade. The resulting information was used to
estimate the specific locations and volumes of coal to be removed from the storage area. Duke Energy
then developed an Erosion and Sedimentation Control Plan (E&SC Plan) detailing the removal of coal
based on the study findings. The plan also detailed the breach of an area berm and the construction of a
temporary sedimentation basin, both implemented in a later phase to facilitate drainage once coal was
removed, with an outfall to Shaddock's Creek. This plan was submitted for NCDENR review on February
16, 2012. The E&SC Plan was approved by rule on March 20, 2012.
An E&SC Plan revision was submitted for NCDENR review on June 7, 2013 which provided specifications
for an access road to allow for truck transport of coal and comingled coal/soil mixtures off site. NCDENR

Additional Information to Support NPDES Stormwater Permit Application
Cape Fear Plant
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had previously concurred that this activity could be covered under the Construction General Storm
Water Permit (NCG500000) and any identified outfalls protected by erosion control measures. The
revised E&SC Plan was approved by rule on July 25, 2013.
A second E&SC Plan revision was submitted to NCDENR for review on March 24, 2014. That revision
included the balance of the site demolition activities and was approved by rule on April 8, 2014.
Coal and comingled coal/soil mixture were removed from the site from late July 2013 through August
2013 in accordance with the approved E&SC Plan and subsequent revisions. Specific procedures that
were implemented include:
• Prior to retiring the coal fired units, the usable coal inventory was managed to reduce the
amount of coal on site. Burnable coal was burned in the coal combustion process. Measures
were implemented to control fugitive dust emissions during excavation, loading and transport.
• Unburnable coal (coal/soil mixture) was removed from the yard and profiled into a permitted
Subtitle D (MSW) disposal facility. Measures were implemented to control fugitive dust
emissions during excavation, loading and transport.
• Excavation and disposal of the coal/soil mixture continued until substantially all of the coal had
been removed based on visual observations (i.e., visual evaluation of the ground surface and the
exposed near -surface soils did not reveal significant discoloration or a recoverable volume of
coal or coal/soil mixture) and the grading plan.
• A determination by the Duke Energy staff that removal and disposal activities had been
completed in accordance with these procedures and that the E&SC Plan control measures
functioned as designed.
• Grading of the former coal yard area to final ground surface contours while minimizing surface
erosion and incorporating necessary storm water controls.
• Application of topsoil and seed to the former coal yard area to promote suitable cover growth.
Conclusions
Based on the actions outlined above, Duke Energy believes that we have completed the coal removal
activity thoroughly, effectively and with appropriate due diligence. As a result, all former industrial
materials (coal) have been substantially and sufficiently removed from the former coal yard drainage
area. Therefore the existing temporary stormwater outfall from the sedimentation pond to Shaddox
Creek is appropriately covered by the Construction General Permit requirements, rather than an
individual industrial stormwater permit. The temporary outfall from the sedimentation basin is
expected to remain until final site grading is complete (expected completion in 2016).
Duke Energy appreciates the opportunity to respond to NCDENR's request for additional information.
Should you have any questions regarding this submittal or require additional information, please contact
LeToya Ogallo at [phone] or email [e-mail].
/ certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or

Additional Information to Support NPDES Stormwater Permit Application
Cape Fear Plant
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persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. i am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations.
Sincerely,
Issa J. Zarzar
Director Demolition and Plant Retirement
Cc: Mike Randall, NCDEMLR
John Stamas, Duke Energy, Cape Fear Plant
LeToya Ogallo, Duke Energy