3612_Allen_REVISED_Table10-1_FID1389562_20200206

KE
ENERGY,
February 6, 2020
HAND DELIVERY AND ELECTRONIC MAIL
Ms. Shelia Holman
Assistant Secretary
North Carolina Department of Environmental Quality
1611 Mail Service Center
Raleigh, NC 27699-1611
RE: Ash Basin Closure Plans — Revision
Allen Steam Station
Belews Creek Steam Station
Cliffside Steam Station/Rogers Energy Complex
Marshall Steam Station
Mayo Power Station
Roxboro Power Station
Dear Ms. Holman:
George T. Hamrick
Senior Vice President
Coal Combustion Products
400 South Tryon Street ST06A
Charlotte, NC 28202
Phone., 980-373-8113
Email. [e-mail]
In accordance with the requirements of North Carolina General Statues § 130A-309. 214(a)(4),
Closure of Coal Combustion Residuals Surface Impoundments, and the requirements of the
Settlement Agreement, Duke Energy provides revisions to the Basin Closure Plans submitted
on December 31, 2019 and January 30, 2020 for the subject stations. This revision consists of
an updated Appendix D, Closure Plan Drawings, for the Cliff side Steam Station and the
Roxboro Power Station and an updated Table 10-1, Regulatory Permits, Approvals, or
Requirements for Basin Closure by Excavation, for each of the subject closure plans.
Duke Energy remains committed to safely and permanently closing basins in ways that continue
to protect people and the environment and welcomes the opportunity to work constructively with
NCDEQ to move forward.
Respectfully submitted,
Georg . Hamrick
Senior Vice President
NCDEQ cc: [e-mail], [e-mail], Ed Mussler, Steven
Lanter, Toby Vinson
Duke Energy cc: Jessica Bednarcik, Dave Renner, Dan Mc Rainey, Jim Wells, Ed Sullivan,
Michael Kafka, Randy Hart

Table 10-1
Allen Steam Station Regulatory Permits, Approvals, or Requirements for Ash
Basin Closure by Excavation
Permit/Approv
al
Type of
Existing
Regulatory
Permit
Approval
General Permit
Regulating
(Mechanism
if
or
Name or Subject
Agency
applicable)
Not Required
Comments
Permit modification likely due to the
Permit
increased heavy equipment vehicle
Air Quality
NCDEQ
modification
traffic and potential dust generated
likely
during closure activities
Gaston
A local building permit is required for
Building Permit
County
New Permit
installation of construction trailers
Modification or abandonment of CAMA
CAMA
Written NCDEQ
program monitoring wells require the
Monitoring Plan
NCDEQ
DWR approval
approval of the Division of Water
Resources (DWR)
CCR
Impoundment
US EPA
Self -Regulating
Required postings to Public Record
CCR Rule
Closure
CCR
Maintain CCR GW monitoring network
Impoundment
US EPA
Self -Regulating
and requirements as stated in 257.90 -
Monitoring
CCR Rule
Network
257.98
USACE
and
NCDEQ
It is anticipated that an individual
Clean Water Act
DWR 401
Individual
permit will be required in relation to
401
Water
Permit
dam breaching and associated
Quality
downstream impacts.
Permittin
g Section
It is anticipated that an individual
Clean Water Act
Individual
permit will be required in relation to
404
USACE
Permit
dam breaching and associated
downstream impacts.
Applicable and
Erosion and sediment controls, natural
to be covered
Cutting Trees
habitat, and endangered species
as part of other
considerations.
permits

AAB Dam - Permitting is required to
Certificate of
modify or abandon wells and
Dam Safety
NCDEQ
GASTO-
Approval to
instrumentation on regulatory dams
061
Modify
through the Division of Energy, Mineral,
and Land Resources (DEMLR)
AAB Dam - Final approval after
abandoning wells and instrumentation
GASTO-
Certificate of
on regulatory dams through the
Dam Safety
NCDEQ
Final Approval
Division of Energy, Mineral, and Land
061
(COFA)
Resources (DEMLR) in accordance with
the Dam Safety Law of 1967, 15A WAS
02K.0220.
AAB Dam - Permitting is required to
modify and remove the dam in
Certificate of
accordance with the Dam Safety Law of
GASTO-
Approval to
1967, § 143-215.27 and § 143-215.27A
Dam Safety
NCDEQ
061
Modify and
(where applicable) and the Dam Safety
General Provisions, 15A WAS 02K.0201
Remove
(b)(2); an application must be filed with
the Division of Energy, Mineral, and
Land Resources (DEMLR)
AAB Dam - Final approval after
Certificate of
modifying to remove the Ash Basin
Dam Safety
NCDEQ
GASTO-
Final Approval
Dam through the Division of Energy,
061
(COFA)
Mineral, and Land Resources (DEMLR)
in accordance with the Dam Safety Law
of 1967, 15A WAS 02K.0220.
RAB Dam - Permitting is required to
Certificate of
modify or abandon wells and
Dam Safety
NCDEQ
GASTO-
Approval to
instrumentation on regulatory dams
016
Modify
through the Division of Energy, Mineral,
and Land Resources (DEMLR)
RAB Dam - Final approval after
abandoning wells and instrumentation
Certificate of
on regulatory dams through the
Dam Safety
NCDEQ
GASTO-
Final Approval
Division of Energy, Mineral, and Land
016
(COFA)
Resources (DEMLR) in accordance with
the Dam Safety Law of 1967, 15A WAS
02K.0220.
RAB Dam - Permitting is required to
Certificate of
modify and remove the dam in
GASTO-
Approval to
accordance with the Dam Safety Law of
Dam Safety
NCDEQ
016
Modify and
1967, § 143-215.27 and § 143-215.27A
(where applicable) and the Dam Safety
Remove
General Provisions, 15A WAS 02K.0201
(b)(2); an application must be filed with

the Division of Energy, Mineral, and
Land Resources (DEMLR)
RAB Dam - Final approval after
Certificate of
modifying to remove the Ash Basin
Dam Safety
NCDEQ
GASTO-
Final Approval
Dam through the Division of Energy,
016
(COFA)
Mineral, and Land Resources (DEMLR)
in accordance with the Dam Safety Law
of 1967, 15A NCAS 02K.0220.
Utilization of or modification to state or
DOT - General
Not anticipated
federal highways to transport CCR will
at this time
require consultation or notification to
relevant DOT agency
Driveway Permit
NCDOT
Potential
Temporary access or driveway permits
as needed
Land disturbance activities outside of
the ash basin will exceed one acre,
therefore in conformance with 15A
Erosion and
NCAC 04, an E&SC Permit is required
Sediment Control
NCDEQ
New Permit
from Land Quality prior to
(E&SC)
commencement of construction in
those areas. Note that land
disturbance includes tree clearing and
grubbing and vehicular wheel or
tracking as disturbance.
Removal from or import of material
Restriction not
could be restricted dependent on the
Fire Ants
likely
potential for fire ants and geographic
regions involved
Gaston County Floodplain Development
Regulations Section 16.3.3 require a
Floodplain
Gaston
Floodplain Development Permit prior to
Development
County
New Permit
the start of construction within FEMA-
mapped Special Flood Hazard Areas
indicated on Flood Insurance Rate
Maps.
Permits are required to construct any
Large Capacity
water supply well or water well system
Water Supply
NCDEQ
New Permit
with a design capacity equal to or
Well
possible
greater than 100,00 gallons per day -
for dewatering outside of the ash basin
Multi -State
If movement of CCR will cross state
Not required
lines, multi -state regulations might
Agreement
apply

NPDES (National
Pollution
Permit
Modification of NPDES may be
Discharge
NCDEQ
NC0004
modification
necessary if new source or outfall is
Elimination
979
likely
created.
System)
NPDES (National
Pollution
Discharge
to existing sitewide permit or
Elimination
NCDEQ
NCSRevision
Permit revision
new permit may be required for access
System)
046
546
likely
roads, staging areas, etc.
Industrial
Stormwater
NPDES (National
Pollution
Discharge
New Permit
Permit required for temporary and
Elimination
NCDEQ
possible
permanent stormwater rerouting.
System)
Stormwater
Removal from or import of vegetated
Noxious Weeds
Not anticipated
material could be restricted dependent
at this time
on the vegetation and geographic
regions involved
Railroad
Not
Construction activities adjacent to
Easement,
anticipated at
tracks/ballast or a new railroad crossing
Access, or
this time
require an agreement or permit
Crossing Permit
SPCC (Spill
In accordance with the Federal Water
Prevention
Modification of
Pollution Control Act (Clean Water Act)
Control and
EPA
existing plan
of 1974, Title 40, Code of Federal
Countermeasure)
Plan
Regulations, Part 112.
Threatened or
Endangered
Species:
Candidate
Conservation
Federal and/or state regulations may
Agreement
apply including agency consultation and
Avian Protection
It will be done
performing site -specific surveys within
Plan(s)
NCDEQ
as part of
the proper survey period (e.g.,
Bird and Bat
and EPA
401/404
flowering period for listed plant) to
Conservation
process
determine if Threatened or Endangered
Strategies
Species or their habitat exist within the
Eagle
limits of disturbance
Conservation
Plan
Eagle Take
Permit

Solid Waste Site
Suitability
NCDEQ
Approval by
Letter
New CCR Landfill
Solid Waste
Permit to
NCDEQ
Permit
New CCR Landfill
Construct
Solid Waste
Permit to
NCDEQ
Permit
New CCR Landfill
Operate