8505_DukeEnergy_BelewsCreek_RevisedOpsPlan_DIN25902_20160406

Operations Plan March 24, 2016 Duke Energy Carolinas, LLC—Belews Creek Steam Station
Flue Gas Desulfurization (FGD) Residue Landfill Phase 1 Page ii
Description of Revisions
The following table provides a brief description of the revisions to the Operations Plan. The Operations
Plan was originally submitted to the North Carolina Department of Environment and Natural Resources
(DEQ) on September 30, 2005. Comments from DEQ on the subsequent modification submittals were
provided in letters from Mr. Larry Frost, DEQ, to Mr. Ed Sullivan, P.E., Duke Energy Carolinas, LLC, and can be found in Appendix E.

Revision Date of Document Description of Revisions
Initial Issue January 24, 2008 Initial issuance of document.
Revision 1 August 5, 2011 Landfill Operations Plan
Section 3.0 Dust Control Plan
• Added dust control plan and two figures
Section 4.0 Chimney Drain System
• Added chimney drain system design and description and appendices
Revision 2 March 23, 2012 FGD landfill leachate system modification allowing penetrations to remain
Revision 3 March 24, 2016 Revised Section 2.1.2 Waste Acceptance, Disposal, and Screening
Requirements to include Duke Energy Carolinas, LLC
Added Sections:
2.1.6.3 Vacuum Truck waste
2.1.6.4 Geotextile Waste, and
2.1.6.5 Mining of Waste

Operations Plan March 24, 2016 Duke Energy Carolinas, LLC—Belews Creek Steam Station
Flue Gas Desulfurization (FGD) Residue Landfill Phase 1 Page iii
Table of Contents
1.0 General Facility Operations ....................................................................................................... 1
1.1 Overview ......................................................................................................................... 1
1.2 Contact Information ...................................................................................................... 1
1.3 Safety .............................................................................................................................. 1
1.4 Access and Security Requirements ............................................................................... 1
1.5 Operating Hours ............................................................................................................ 2
1.6 Signs ................................................................................................................................ 2
1.7 Training .......................................................................................................................... 2
1.8 Record Keeping .............................................................................................................. 2
1.9 Design Drawings ............................................................................................................. 3
2.0 Operations Management ............................................................................................................ 3
2.1 Waste Handling and Landfill Sequencing .................................................................... 3
2.1.1 Landfill Capacity ............................................................................................... 3
2.1.2 Waste Acceptance, Disposal, and Screening Requirements ............................ 4
2.1.3 Dust, Litter, Odor, and Vector Control ........................................................... 4
2.1.4 Fire Control ....................................................................................................... 5
2.1.5 Landfill Sequencing ........................................................................................... 5
2.1.6 Waste Placement ............................................................................................... 5
2.1.7 Compaction Requirements ............................................................................... 8
2.1.8 Cover Requirements.......................................................................................... 8
2.1.8.1 Operational Cover ............................................................................ 8
2.1.8.2 Intermediate Cover .......................................................................... 8
2.1.8.3 Final Cover ....................................................................................... 8
2.2 Leachate and Contact Stormwater Management ........................................................ 9
2.3 Leachate Collection System (LCS) ................................................................................ 9
2.3.1 LCS Maintenance .............................................................................................. 9
2.3.2 LCS Record Keeping and Sampling .............................................................. 10
2.3.3 Contingency Plan ............................................................................................ 10
2.4 Stormwater Collection and Conveyance ..................................................................... 10
2.4.1 Stormwater Discharge .................................................................................... 10
2.5 Contact and Non-Contact Water Basin Maintenance Requirements ....................... 10
2.6 Groundwater Monitoring Well Access Requirements ............................................... 11
Operations Plan March 24, 2016 Duke Energy Carolinas, LLC—Belews Creek Steam Station
Flue Gas Desulfurization (FGD) Residue Landfill Phase 1 Page iv
2.7 Landfill Gas Management ........................................................................................... 11
3.0 Erosion and Sedimentation Control ........................................................................................ 11
3.1 E&SC Measures Monitoring and Maintenance ......................................................... 11
3.2 Surface Erosion Monitoring ........................................................................................ 12
4.0 Vegetation Management ........................................................................................................... 12
4.1 Temporary Seeding ...................................................................................................... 12
4.2 Permanent Seeding ...................................................................................................... 13
5.0 Landfill Closure ........................................................................................................................ 14
6.0 Required Regulatory Submittals ............................................................................................. 14

Tables
1. List of Construction Drawings

Appendices
Appendix I Dust Control Plan
Appendix II Phasing Drawings (developed and provided by WSP Sells, dated August 2, 2006)
Appendix III Closure/Post-Closure Plan
Appendix IV Chimney Drain System
Appendix V Leachate Storage Basin Leak Detection System
Appendix VI NCDEQ Communications
• Letter from Mr. Larry Frost, DEQ to Mr. Ed Sullivan, P.E., Duke Energy Carolinas, LLC, dated July 1, 2011, Permit to Operate, Modification, Changes to the Approved Plans, Completeness
Determination and Technical Review, Belews Creek Steam Station Flue Gas Desulfurization
(FGD) Residue Landfill, Permit # 8505, Stokes County, DIN 14257
• Letter from Mr. Larry Frost, DEQ to Mr. Ed Sullivan, P.E., Duke Energy Carolinas, LLC, dated March 26, 2012, Drawing OP-5, Cell Operation – Leachate Collection and Removal System –
Revision Approval, Duke Energy of the Carolinas, Belews Creek Steam Station, FGD Residue
Landfill, Stokes County, Permit # 8505, DIN 16354

Operations Plan March 24, 2016 Duke Energy Carolinas, LLC—Belews Creek Steam Station
Flue Gas Desulfurization (FGD) Residue Landfill Phase 1 Page 1
1.0 General Facility Operations
1.1 Overview
The purpose of this Operations Plan is to provide a plan for the safe and efficient operations of the Belews Creek Steam Station (BCSS) Flue Gas Desulfurization (FGD) Residue Landfill (BCSS FGD
Landfill). This Operations Plan presents the operational requirements for: 1) General Facility
Operations, 2) Operations Management, 3) Erosion and Sedimentation Control, and 4) Vegetation
Management, along with guidance for Landfill Closure and Required Regulatory Submittals. This
Operations Plan was prepared consistent with 15A NCAC 13B .1626 Operational Requirements for MSWLF Facilities rules.
The BCSS FGD Landfill is owned and operated by Duke Energy Carolinas, LLC (Duke). The landfill is
located in Stokes County, North Carolina on Duke property, south of the Belews Creek Steam Plant,
between the east and west arms of Belews Creek Lake near Walnut Cove.
1.2 Contact Information
Correspondence and questions concerning the operation of the BCSS FGD Landfill should be directed to the appropriate entity as follows:
Owner
Duke Energy Carolinas, LLC—Belews Creek Steam Station
3195 Pine Hall Road, Belews Creek, North Carolina 27009
[phone] Facility Contact: CCP O&M Station Sponsor (Construction Specialist or System Owner or Environmental Professional
State Regulatory Agency
North Carolina Department of Environmental Quality
Division of Waste Management, Solid Waste Section Asheville Regional Office 2090 US Highway 70, Swannanoa, North Carolina 28778
[phone]
Environmental Engineer: Larry Frost
1.3 Safety
Landfill operations at the BCSS FGD Landfill were developed considering the health and safety of the
facility’s operating staff. The operating staff is provided with site-specific safety training prior to landfill operations, and on-site activities are to be conducted according to the applicable sections of
Duke’s Safe Work Practices.
1.4 Access and Security Requirements
The BCSS FGD Landfill is located entirely within Duke property. Security for the site is currently in
place, consisting of fencing, gates, berms, wooded buffers, and security check stations. Unauthorized
Operations Plan March 24, 2016 Duke Energy Carolinas, LLC—Belews Creek Steam Station
Flue Gas Desulfurization (FGD) Residue Landfill Phase 1 Page 2
vehicle access to the site is prevented around the landfill property by security check stations, woods,
fencing, gates, and stormwater conveyance features.
The access road to the site is of all-weather construction and will be maintained in good condition. Potholes, ruts, and debris on the road(s) will receive timely attention in order to avoid damage to
vehicles.
1.5 Operating Hours
The BCSS FGD Landfill is open seven days a week, as needed to support plant operations.
1.6 Signs
A sign providing the landfill permit number, and a statement reading, “NO HAZARDOUS OR LIQUID
WASTE PERMITTED,” is posted at the site entrance and shall be maintained in good condition.
Directional signs are placed along the access road to the landfill and shall be maintained in good
condition at all times.
Edge-of-waste markers are installed to delineate the edge of waste. These markers shall be maintained
in good condition and remain visible at all times.
1.7 Training
Due to the diversity and nature of job tasks required at the BCSS FGD Landfill, personnel shall be
adequately trained to handle facility operations and maintenance.
The Station Sponsor for Landfill Operations shall have a general understanding of all the tasks required
for site operations. Individuals performing the various tasks shall have adequate training for the site-
specific tasks they are assigned. Duke shall provide annual training for facility personnel.
Noteworthy operations and maintenance tasks to be addressed in training include:
• Maintaining accurate records of waste loading (quantitative and qualitative)
• Operating requirements for stormwater segregation from exposed waste areas
• Operating and maintaining the leachate collection system (LCS)
All training will be documented and training records will be kept on-site. The Station Sponsor for Landfill Operations will complete operator training courses in accordance with the permit requirements.
1.8 Record Keeping
An operating record is to be maintained on-site and include the following records:
• Leachate Collection System (LCS)—Line Cleanout and Camera Monitoring Documentation
• Stormwater Maintenance and Inspection Logs
• Erosion and Sedimentation Control Inspection Logs
• Periodic Landfill Inspection Reports
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• Maintenance and Repair Logs
• Dust Control Plan Monitoring Worksheets (included in the Dust Control Plan);
• Groundwater Monitoring (and Sampling) Documentation
• Operations Plan
The above records are to be kept in the operating record for the active life of the BCSS FGD Landfill
and the post-closure care period. Information contained in the operating record must be furnished upon request to the North Carolina Department of Environment and Natural Resources Division of Waste Management, Solid Waste Section (Division) or be made available for inspection by the Division.
Additional records kept on-site should include:
• Solid waste facility permits
• Record of the amount of solid waste received summarized on a monthly basis based on scale
records
• Regulatory agency inspection reports
• Permit-to-Construct Application
• Employee training program and records
• Landfill drawings and specifications
1.9 Design Drawings
A list of the landfill design drawings is provided in Table 1. The drawings provide the location of landfill features, landfill construction details, and technical design and construction notes.

2.0 Operations Management
The primary objective of operations management at the BCSS FGD Landfill is to dispose of waste material in compliance with permit conditions while operating in a safe manner. Landfilling operations
will generally proceed from the east toward the west and have a working face size based on the
operator’s discretion, with waste in other areas covered with intermediate cover as appropriate. In
general, landfill operations in the cell will initially proceed in 10-foot lifts with cells divided by stormwater segregation berms; and once the cell floor has been covered with the initial lift of waste, the chimney drains will be installed.
2.1 Waste Handling and Landfill Sequencing
2.1.1 Landfill Capacity
The BCSS FGD Landfill Phase I was permitted to operate on January 24, 2008. The Phase 1 footprint
consists of approximately 22.6 acres. The landfill began receiving waste in early March 2008. The total
available airspace volume of Phase 1, according to the Construction Plan Application dated April 19, 2006, is approximately 1.50 million cubic yards. This volume corresponds to 1,701,000 tons of capacity
Operations Plan March 24, 2016 Duke Energy Carolinas, LLC—Belews Creek Steam Station
Flue Gas Desulfurization (FGD) Residue Landfill Phase 1 Page 4
based on an average unit weight of 84.0 pounds per cubic foot. The expected annual quantity of waste
to be placed in the landfill is up to 300,000 tons per year. Due to gypsum sales demands combined
with the potential for limited plant production, mining of gypsum may limit the net amount of landfilled material per year. This includes the potential for a negative fill rate if sales outpaces production and material is mined from the landfill (See section 2.1.6.5 for mining operations).
2.1.2 Waste Acceptance, Disposal, and Screening Requirements
The BCSS FGD Landfill is permitted to accept the following waste types from Duke Energy Carolinas,
LLC:
• Coal combustion products (CCPs) (including fly and bottom ash, pyrites and coal mill rejects,
and boiler slag);
• Gypsum produced during the flue gas desulfurization (FGD) process;
• Waste water treatment sludge (WWTS) produced during the FGD process;
• Waste limestone material;
• Sand blast material;
• Waste coal; and
• incidental materials produced in coal facility operations
The landfill owner or operator shall notify the Division within 24 hours of attempted disposal of any
wastes the landfill is not permitted to receive.
At a minimum, hazardous waste, yard trash, liquid wastes, regulated medical waste, sharps not properly packaged, polychlorinated biphenyls (PCB) waste as defined in 40 Code of Federal Regulations (CFR)
761, and wastes banned from disposal in North Carolina by General Statute 130A-309.10(f), must not be
accepted at the landfill.
Asbestos waste will not be disposed of in the landfill. The removal of waste from the landfill is prohibited without the owner or operator approval. Waste will
be hauled and disposed of by dedicated and consistent operators from the waste source to the landfill.
Access to the interim waste storage location, haul routes, and landfill are restricted; therefore, no
screening of waste is recommended.
2.1.3 Dust, Litter, Odor, and Vector Control
Litter, odors, and vectors are not anticipated to be concerns at the BCSS FGD Landfill. The waste
placed in the landfill does not attract vectors, and windblown litter is not a problem other than some
dusting. Odors are typically not a problem at FGD residue landfills.
Dust control is addressed in the Dust Control Plan included as Appendix I. Generally, dust control measures will be implemented when necessary and will include at a minimum watering of dusty roads and exposed work areas. The gypsum surface typically generates a crust, which reduces the dust
potential for the gypsum. Additionally, intermediate cover will be vegetated as soon as is practical in
order to minimize the blowing of dust on-site.
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2.1.4 Fire Control
No open burning shall be permitted at the BCSS FGD Landfill. There are no explosive gas concerns
with gypsum, ash waste, or mill rejects; therefore, the threat of fire is considered to be minimal.
Although it is unlikely, if a fire occurs at the landfill, the Station Control Room (phone number: 336-445-0521) shall be notified and equipment and stockpiled soil shall be provided to control accidental
fires. Belews Creek Steam Station will notify the local fire department, which will be immediately
dispatched to assist with fire control. Any fire that occurs at the landfill shall be reported to the Division
within 24 hours and a written notification will be submitted within 15 days by the Station Sponsor for Landfill Operations.
2.1.5 Landfill Sequencing
The BCSS FGD Landfill will be developed in sequence from Cell 1 to Cell 4. The landfill Phasing
Diagrams (Figures OP-1 through OP-4) are included in Appendix II and they illustrate a possible
sequence of operations. The actual filling sequence, fill heights, and grades may be modified and the owner's discretion.
2.1.6 Waste Placement
Waste generated at the BCSS is transported from the interim waste storage areas to the landfill by using
dump trucks.

• Gypsum - A conveyor system transports the gypsum from the FGD facility and stockpiles it
adjacent to the BCSS FGD Landfill. The gypsum is then loaded onto dump trucks and hauled to
the landfill active face, or taken off-site for sale.
• Fly Ash - A conditioning hopper is utilized to load fly ash into dump trucks and the fly ash is then hauled to the landfill active face.
• Bottom Ash, Mill Rejects, and Waste Water Treatment Sludge – These materials are loaded into
dump trucks through the use of varying equipment and hauled to the landfill active face.
Upon reaching the active face of the landfill, the waste is dumped from the trucks. After the waste is
dumped, the dump trucks exit the landfill and pass through a wheel wash system before returning to the
interim waste storage areas. The interim waste storage areas, haul roads, and landfill are located within
the secured BCSS facility. A minimum of 3 feet of waste material will be in place as a protective
cushion over the liner system before vehicular or construction equipment is allowed on the liner.
The landfill surface shall be graded to promote surface water drainage to the contact water collection
system. No waste shall be placed in standing water.

2.1.6.1 Fly Ash, Bottom Ash, and Gypsum
Fly ash, bottom ash, and FGD Gypsum shall be compacted using compactors and dozers in approximate
1-foot lifts to achieve a vertical operational lift thickness of 10 feet.

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2.1.6.2 Wastewater Treatment

Sludge, waste limestone, waste coal, and sandblast material FGD clarifier sludge, coal mill rejects, waste limestone material, boiler slag, sand blast material, ball mill rejects, coal waste, wastewater sludge, and pyrites will be spread in 6-inch lifts in the center of the operational area and shall not be
placed within 25 feet of the exterior slopes. FGD clarifier sludge shall be blended with the other waste
(i.e. ash) prior to placement of the next fill lift. FGD clarifier sludge, coal mill rejects, waste limestone
material, boiler slag, sand blast material, ball mill rejects, coal waste, and pyrites shall be compacted as densely as practical and specific monitoring. In-place density testing of these materials is not required.
2.1.6.3 Vacuum Truck Waste

Vacuum trucks are used to remove waste materials from the plant areas that consist of various permitted CCP. The origin of the vacuum truck waste materials is typically from various sumps, catch basins, wheel wash stations, and coal pile sumps located within the plant.

The moisture contents of the vacuum truck waste materials may vary considerably with the waste
varying in consistency from a relatively dry state to a wet, fluid-like state depending on the amount of liquid present in the sumps or vacuumed areas. CCP material transported via vacuum truck will occur in a vacuum truck dedicated to Duke Energy operations or documentation will be obtained to ensure that
the vacuum truck contains no human or other non-permitted waste streams. Vacuum truck waste could
also mean similar waste material transported in smaller water tight units.
Vacuum truck waste shall consist of permitted waste materials. Non-permitted waste materials inadvertently included with the vacuum truck waste including but not limited to yard trash (paper,
plastic, wood, aluminum, Styrofoam, etc.) shall be visually screened and immediately removed from the
vacuum truck waste after the waste material is dumped in the operational area by vacuum contractor.
The consistency of the vacuum truck waste may vary from a relatively dry state to a relatively wet, fluid-like state. Vacuum truck waste material shall be moisture conditioned by initial decanting excess
moisture from the waste or by mixing the waste with fly ash, bottom ash, or gypsum materials
depending on its consistency. The vacuum truck waste shall be placed and spread in maximum 6-inch
lifts near the center of the operational area. The vacuum truck waste shall not be placed within 50 feet
horizontally from exterior landfill slopes or within 50 feet of chimney drain structure locations. The vacuum truck waste material shall be thoroughly mixed with fly ash, bottom ash, or gypsum material
during waste placement using a dozer or other similar grading equipment to provide additional moisture
conditioning prior to compaction. In-place density testing of the vacuum truck waste materials is not
required.
The vacuum contractor shall coordinate vacuum truck waste placement with landfill operator personnel
and the vacuum truck waste disposal will be documented.

Dust control measures shall be provided for the vacuum truck waste in accordance with the Dust Control
Plan outlined in Appendix I.

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2.1.6.4 Geotextile Waste

General operations of coal combustion products (CCP) requires the use of porous geotextile material for dewatering, outlet protection, inlet protection, and air quality management. With this letter, Duke Energy requests approval to place incidental amounts of geotextile used in the management of CCP's
into the respective facility's operational landfill.

Geotextile material shall be porous in nature and could include but is not limited to: silt bags, bag house bags, geotubes, and geotextile fabric specifically used to manage CCP material.
The geotextile material will be broken up with field equipment to the extent possible and immediately
buried with a minimum of 6" CCP material or soil. Volumes of geotextile are intended as incidental to
that of the CCP waste stream to the respective facilities. 2.1.6.5 Mining of Waste

The FGD Landfill contains mostly gypsum meeting specifications in various re-use markets. In order to
meet industry demands, frequent mining of material occurs at the FGD landfill.
In order to protect the liner system and leachate components, mining from the FGD landfill will occur in designated areas with a minimum stand-off distance of:
• horizontal: 50'-0" from the landfill side slope or anchor trench
• vertical: 10'-0" vertical separation from the top of protective cover (drainage layer). The vertical separation layer typically consists of ash or other waste material.
Operators performing mining activities shall be oriented to specific operational tasks related to mining
including but not limited to:
• liner location;
• FGD landfill grading plans;
• anchor trench location;
• vertical and horizontal liner separation requirements;
• stormwater management, and
• environmental awareness,
The landfill operators’ mining equipment shall be equipped with horizontal and vertical tracking capabilities.

The landfill operator shall have a Mining Plan approved by Duke Energy. At a minimum, the mining
plan shall include:
• base grade mining plan
• horizontal and vertical tracking
• operator orientation
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Flue Gas Desulfurization (FGD) Residue Landfill Phase 1 Page 8

Should the need for removal of gypsum from the FGD landfill extend below the horizontal and vertical
extents described above, the owner will submit a detailed mining plan to the Division for approval.
2.1.7 Compaction Requirements
After the waste is dumped from the trucks and placed on the active face, the waste will be placed in
consecutive, approximate 1-foot thick lifts that do not exceed a 10-foot operational lift. Prior to
placement of a new lift, the existing waste surface should be scarified.
The waste shall be compacted using compactors and dozers and moisture conditioning shall be performed to meet the moisture requirements. The waste shall be compacted to an average of 95 percent
of Standard Proctor maximum dry density, and within 5 percent of the optimum moisture content.
Although not required, in-place density testing may be performed at the Owner’s discretion to verify
compaction requirements are achieved.
2.1.8 Cover Requirements
2.1.8.1 Operational Cover
Operational cover, consisting of soil, will be applied as needed for dust control and stormwater
management. The operational cover may be applied at a thickness suited to its purpose. For example,
the operational soil cover may be applied in thinner layers to provide dust control and it may be applied in thicker layers where protection from surface erosion is desired. Operational soil cover is not required, provided the Dust Control Plan included as Appendix I is followed.
2.1.8.2 Intermediate Cover
A 12-inch thick intermediate cover layer shall be placed on exterior slopes and areas where final grades
have been reached. Intermediate cover material shall be free of protruding roots, stumps, and debris. Intermediate cover may not contain more than 5 percent gravel (particle sizes larger than 0.5 inches) by
weight as determined by ASTM D422. Isolated rock fragments not exceeding 6 inches in diameter may
be placed within the intermediate cover if completely surrounded by compacted soil if approved by the
Engineer. Rock fragments shall not protrude more than 3 inches from the compacted intermediate cover
fill surface. Soil shall be placed in maximum 6-inch thick compacted lifts. Intermediate cover will be seeded within 7 days in accordance with Erosion and Sediment Control requirements. Vegetation shall
be removed and the intermediate cover soil shall be scarified or removed prior to placing any overlying
waste.
2.1.8.3 Final Cover
The final cover system for the BCSS FGD Landfill will be completed within 180 days following the beginning of closure activities unless otherwise approved by the Division.
The final cover will consist of a compacted interim soil cover (on top of the waste), a geocomposite gas
collection layer, 40-mil textured linear low density polyethylene (LLDPE) geomembrane liner, a
geocomposite drainage layer, and a minimum of 2 feet of cover soil. The upper 6-inch vegetative layer
will consist of on-site soil suitable for maintaining grass cover and controlling erosion. Surface water
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that percolates through the 6-inch vegetative layer and 18-inch thick soil layer will drain through the
geocomposite drainage layer. The final cover will be vegetated with native grasses within six months
following closure.
See Closure/Post-Closure Plan in Appendix III for final cover specifications and maintenance and operations requirements.
2.2 Leachate and Contact Stormwater Management
A leachate collection system (LCS) is in place to drain the leachate within the active cell to the down-
gradient leachate storage basin. On the cell floor area, a 12-inch thick layer of soil cover is over the
geomembrane liner and the leachate collection and removal system.
Leachate and contact stormwater are collected in the leachate storage basin and routed by way of a pump station, located adjacent to the basin, to the BCSS Ash Basin, which discharges in accordance
with the BCSS plant’s National Pollutant Discharge Elimination System (NPDES) permit.
2.3 Leachate Collection System (LCS)
The leachate collection system consists of a geonet/geotextile with a perforated collection/header piping
system that drains to the leachate storage basin. In order to better manage contact water, a chimney
drain network has been designed to route leachate through the waste and out of the landfill through the existing leachate outfalls. Refer to Appendix IV for the design and description of the Chimney Drain System. The slope on the geomembrane is positive to promote leachate transport from the collection
system to the leachate storage basin. The geonet is a polyethylene synthetic mesh that transmits leachate
to the leachate collection pipe. The leachate collection header pipes drain directly to the leachate
storage basin where a riser pipe routes leachate and contact stormwater to the BCSS Ash Basin. As waste placement proceeds, the leachate collection system will be modified as shown on the design drawings.
2.3.1 LCS Maintenance
The maintenance of the leachate management system's physical facilities (consisting of high-density
polyethylene [HDPE] piping and the contact water storage basin) and records will be performed by or under the direct supervision of Duke. Visual observations of proper LCS system performance will be made monthly by Duke staff to verify that the LCS is performing properly.
In addition to the primary geomembrane basin liner, the lined leachate storage basin is equipped with a
Leak Detection System (LDS), consisting of a secondary geomembrane liner and drainage system that
drains to a sump, located on the south end of the basin. The purpose of this system is to detect and to collect liquids that may leak through the primary liner and to pump the liquid to the pump station. Refer to Appendix V for a description of the LDS and the response plan.
Clean-out pipes are located on the LCS leachate header pipes. LCS header pipes will be cleaned out by
the use of a clean-out snake or high-pressure water flushing at least once a year and will be remote-
camera monitored at least once every 5 years. The frequency of clean-out and camera inspections may be modified based on consecutive inspection results and observed operating conditions.
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2.3.2 LCS Record Keeping and Sampling
Records will be maintained at BCSS documenting the leachate line cleanout and camera monitoring.
Leachate from the LCS will be sampled on a semi-annual basis.
2.3.3 Contingency Plan
In the unlikely event that leachate cannot be pumped to the active BCSS Ash Basin, leachate will be
temporarily stored within the landfill until such time that draining operations to the active ash basin can
be restored. In such an event, the Division shall be notified in writing, within 30 days, about the events
and corrective actions taken.
2.4 Stormwater Collection and Conveyance
Stormwater that does not come in contact with waste will be treated as non-contact water. Non-contact stormwater runoff onto the landfill is prevented by diversion ditches around the landfill.
To improve operations, surface water should be diverted from the operational area. Excessive surface
water at the working face creates difficulties for maneuvering equipment and prevents the operator from
achieving maximum compaction of waste. To divert surface water runoff away from the working face,
temporary diversion berms will be installed on the current lift, upslope of the working face and in other locations as dictated by the direction of grade. The area between the temporary berm and the working
face should be sloped to the chimney drains, when practical, and graded to prevent any accumulation of
water. The soil cover in the areas beyond the diversion berms will be uniformly graded and compacted
to prevent the formation of erosion channels. In the event that channels do form, the cover should be
promptly repaired.
Stormwater collection and conveyance measures will be checked regularly and maintained such that
necessary repairs can be made as early as practical.
2.4.1 Stormwater Discharge
The stormwater system at the landfill was designed to help prevent the discharge of pollutants. Landfill
operation shall not cause a discharge of pollutants into waters of the United States, including wetlands, that violates any requirement of the Clean Water Act, including, but not limited to NPDES requirements,
pursuant to Section 402. In addition, under the requirements of Section 404 of the Clean Water Act, the
discharge of dredged or fill material into waters of the state that would be in violation of the
requirements shall not be allowed by landfill operations.
Operations at the landfill shall not cause the discharge of a non-point source of pollution to waters of the United States, including wetlands, that violates any requirement of an area-wide or statewide water
quality management plan that has been approved under Section 208 or 319 of the Clean Water Act, as
amended.
2.5 Contact and Non-Contact Water Basin Maintenance Requirements
All stormwater features (i.e., diversion ditches, berms, risers, discharge pipes, etc.) associated with
Phase 1 until final closure will be inspected and documented monthly for signs of damage, settlement,
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clogging, silt buildup, or washouts. If necessary, repairs to stormwater control features will be made as
early as practical.
2.6 Groundwater Monitoring Well Access Requirements
Groundwater monitoring wells are located around the landfill perimeter. A readily accessible,
unobstructed, path shall be maintained so that monitoring wells may be accessed by vehicles. Care must be taken around the wells to prevent any damage to the wells.
2.7 Landfill Gas Management
Because of the nature of the waste to be placed in the FGD Residue Landfill, Duke does not anticipate
that methane or hydrogen sulfide gas will be generated or that odor will be an issue during operations.
Therefore, landfill gas monitoring and management is not proposed.
A landfill gas venting system is provided as part of the engineered cover system.

3.0 Erosion and Sedimentation Control
Erosion and sedimentation control (E&SC) during operations consist of monitoring E&SC stormwater conveyance features and surface erosion.
3.1 E&SC Measures Monitoring and Maintenance
Adequate measures are to be practiced to prevent erosion in general accordance with E&SC measures
included on Drawing No. BCM6451.00-0016.001 (FGD Residue Landfill), Drawing No. BCM6451.00-
0017.001 (Stockpile Area) and Drawing No. BCM6451.00-0018.001 (FGD Landfill Erosion Control
Details), all dated April 19, 2006 and prepared by Chas. H. Sells, Inc.
Erosion control measures include:
• Disturbing as little area as practical at any one time for landfilling operations
• Seeding/mulching of all disturbed areas commencing as soon as practically possible. Employing erosion netting or sod on steep slopes and other erosion prone areas.
• Use of earthen berms, hay bales, silt fences, riprap, or equivalent devices downgradient of
disturbed areas, stockpiles, drainage pipe inlets and outlets, and at intervals along grassed
waterways, until such time as permanent vegetation is established.
Erosion and sedimentation control structures include stormwater best management practice (BMP) systems, sediment basins, ash runoff basins, contact water conveyance zones, and channels. Stormwater
BMP’s, sediment basins, and ash runoff basins shall be checked after periods of significant rainfall.
Sediment shall be removed from each structure when sediment accumulates to one half of the design
depth. Sediment removal shall bring BMP’s to their original design depth. The BMP’s, sediment
basins, embankments, spillways and outlets shall also be observed for erosion damage. Necessary repairs shall be made immediately. Trash or debris within the riser structures or outfalls shall be
removed.
Operations Plan March 24, 2016 Duke Energy Carolinas, LLC—Belews Creek Steam Station
Flue Gas Desulfurization (FGD) Residue Landfill Phase 1 Page 12
Channels shall be observed for damage after each runoff event. Riprap-lined channels and outlet
protection aprons used to prevent damage to channel vegetation shall be observed for washouts. Riprap
shall be added to these areas, as needed, to maintain the integrity of the structure.
Embankment slopes shall be periodically observed for erosion. The embankment slopes shall be mowed at least once a year. The embankment slopes shall be refertilized in the second year unless vegetation
growth is fully adequate. Damaged areas shall be reseeded, fertilized and mulched immediately.
Seeding, fertilizing, and mulching shall be in accordance with the North Carolina Erosion and
Sedimentation Control Guidelines and in accordance with the active Erosion and Sediment Control Permit.
3.2 Surface Erosion Monitoring
Adequate erosion control measures shall be established to help prevent sediment from leaving the site.
Channels will be observed once every seven days and after any rainfall event of 0.5 inches or greater
within 24 hours.

Slopes will be periodically checked for erosion and vegetative quality, fertilized, and mowed. A slope or portion thereof shall be identified as needing maintenance if it meets any one of the following
conditions:
• Exposed waste on exterior slopes
• Areas of cracking, sliding, or sloughing
• Areas of seepage
Slopes identified as needing maintenance shall be repaired as soon as practical and as appropriate to
correct deficiencies. Repair activities may include re-dressing the slope, filling in low areas, and/or
seeding.

4.0 Vegetation Management
Within six months after final termination of disposal operations at the site, the area shall be stabilized with vegetation as required by design drawings and Closure/Post-Closure Plan (Appendix III).
Temporary seeding will be applied as required.

Temporary erosion control measures may be required until permanent cover is established. Mulching,
until a vegetative cover is established, can stabilize areas where final grades have been reached. Soil
mulching can be achieved using materials such as: wood chips, straw, hay, asphalt emulsion, jute
matting, and synthetic fibers. Mulches allow for greater water retention; reduce the amount of runoff;
retain seeds, fertilizer, and lime in place; and improve soil moisture and temperature conditions.
4.1 Temporary Seeding
Temporary seeding will be applied as follows (source: NC Erosion and Sediment Control Planning and Design Manual [June 2006, Revised March 2009]):
Operations Plan March 24, 2016 Duke Energy Carolinas, LLC—Belews Creek Steam Station
Flue Gas Desulfurization (FGD) Residue Landfill Phase 1 Page 13

LATE WINTER TO EARLY SPRING

Seeds Pounds Per Acre Dates of Planting
Rye (grain) 120 January 1 to May 1
Annual lespedeza (kobe) 50 January 1 to May 1
Note: Omit lespedeza when duration of temporary cover is not to extend beyond June.

SUMMER
Seeds Pounds Per Acre Dates of Planting
German millet 40 May 1 to August 15

FALL

Seeds Pounds Per Acre Dates of Planting
Rye (grain) 50 August 15 to December 31

Soil Amendments Pounds Per Acre
Agricultural limestone 2,000
Fertilizer (10-10-10) 1,000
Mulch 4,000
Note: Soil amendments are for all-season temporary seeding applications.

4.2 Permanent Seeding
Permanent seeding will be applied as follows (source: NC Erosion and Sediment Control Planning and
Design Manual [June 2006, Revised March 2009]):

Seeds Pounds Per Acre Dates of Planting
Tall fescue 100 September 1 to April 15
Sericea lespedeza 15 September 1 to May 1
Kobe lespedeza 10 May 1 to September 1
Rye 40 August 15 to April 15

Operations Plan March 24, 2016 Duke Energy Carolinas, LLC—Belews Creek Steam Station
Flue Gas Desulfurization (FGD) Residue Landfill Phase 1 Page 14

Soil Amendments Pounds Per Acre
Agricultural limestone 4,000
Fertilizer (10-10-10) 1,000
Mulch 4,000
Note: Perform soil test to determine proper soil amendments; if not available, use the quantities above.

5.0 Landfill Closure
The BCSS FGD Landfill will be closed in accordance with the design drawings and Closure/Post-
Closure Plan (Appendix III). The Closure/Post-Closure Plan outlines the sequence for closing the
landfill and the post-closure maintenance activities. Closure is designed to minimize the need for long-
term maintenance and to control the post-closure release of contaminants. Closure activities may be revised as appropriate for materials, specifications, technology advancements, or changes in regulations
at the time the landfill is closed or in post-closure. In general, the landfill development is designed so
that final cover can be established as soon as possible.

6.0 Required Regulatory Submittals
Submittal Requirement
Reporting/Action
Frequency
Groundwater
Monitoring Reports
Maintain a record of all monitoring events and analytical data
in accordance with the Groundwater Monitoring Plan. Reports
of the analytical data for each water quality monitoring sampling event shall be submitted to NCDEQ Division of
Waste Management (DWM) in a timely manner.
Semi-annually
Annual Tonnage Reports
Tons of waste received and disposed of in the landfill shall be
reported to the DWM on forms prescribed by the DWM. Refer to the Permit to Operate for annual reporting requirement
information.
Annually
Must submit no later than August 1 each
year
10-Year Waste
Management Plan
Per North Carolina G.S. 130A-309.09D (c):
• A 10-year waste management plan shall be developed for this landfill and submitted to DWM.
• The plan shall be updated and submitted to DWM at
least every three years.
• A report on the implementation of the plan is required
to be submitted to DWM by August 1 of each year.
10-year plan
prepared every 10
years
10-year plan
updated every 3 years
Implementation
report annually

Appendix I

Dust Control Plan

Stokes County, NC 1 Joyce Engineering, Inc. BCSS FGD Residue Landfill 6/20/2011
P:\Duke Energy\Belews Crk Sta\Dust Control\06.11 Final Dust Control Plan.docx
INTRODUCTION AND SITE DESCRIPTION
This Dust Control Plan is for the Duke Energy’s Belew’s Creek Steam Station FGD (flue gas
desulfurization) Residue Landfill. This Plan provides dust control methods for managing dust
emissions at this site and provides a monitoring program and corrective action response to contain CCP’s (coal combustion products) to prevent dust nuisances to employees and the
public. The monitoring program will aid Duke Energy and the landfill operator in evaluating the
dust control methods, or combination of dust control methods, that prove effective with site
specific conditions.
The FGD Residue landfill has an approximate 22.6-acre footprint. Currently, this site is
permitted to accept flue gas desulfurization (FGD) residue and will create a residue generally
comprising of gypsum. This Plan will be added as an appendix to the approved Operations Plan
for the FGD Residue Landfill.
DUST CONTROL METHODS
The primary potential source of dust emissions in the landfill is the top deck area and active area
of waste placement. These areas are at a higher risk for producing dust due to vehicular and
equipment traffic and earthworks-like construction. Exterior landfill slopes are less of a dust
control concern as they have intermediate or operational soil covers which are vegetated as
required in the Operations Plan.
Dust emissions from the landfill can be controlled through a variety of dust control methods.
Possible dust control methods are identified herein. Dust control methods may be characterized
as products and/or applications, structural wind breaks and/or covers, and operational methods.
Dust control methods for the landfill area include:
• Watering;
• Establishing vegetative cover;
• Mulching;
• Structural controls consisting of:
o Wind breaks (i.e. fencing and/or berms); and o Temporary coverings (i.e. tarps);
• Spray applied dust suppressants consisting of, and not limited to:
o Anionic asphalt emulsion;
o Latex emulsion;
o Resin in water; o Polymer based emulsion; and o Mineral mortar coatings (i.e. posi-shell);
• Calcium chloride;
• Soil stabilizers (i.e. soil cements);
Stokes County, NC 2 Joyce Engineering, Inc. BCSS FGD Residue Landfill 6/20/2011
P:\Duke Energy\Belews Crk Sta\Dust Control\06.11 Final Dust Control Plan.docx
• Operational soil cover;
• Modifying the active working area; and
• Modifying operations during dry and windy conditions.
The operator may use, and is not limited to, combinations of these dust control methods or any
method that is technically sound to control dust for the specific site conditions. If the operator
intends to use a dust control method not presented above, the proposed dust control method will be evaluated on a case by case basis to assess the effectiveness with specific site conditions. For
the purposes of this Plan, operational soil cover will be defined as soil material applied at a
suitable thickness to provide dust control. The effectiveness of the dust control methods
implemented should be evaluated through a dust monitoring program outlined in Section 3.
Operational equipment generally consists of dump trucks, vibratory smooth drum roller,
bulldozer, water truck, spray trailer, track hoe, and service truck. Operational equipment will be
used to construct, install, apply, and/or repair dust control methods. The operator will make
provisions to alleviate any on-site issues that arise when primary equipment is being maintained
or is inoperable. In the event that Belew’s Creek Steam Station FGD Residue Landfill is permitted to accept additional CCP’s, the landfill operator will make provisions to have the
necessary equipment to control multiple fugitive CCP residue dusting emission events.
MONITORING AND CORRECTIVE ACTION RESPONSE
This section describes a dust monitoring program and suggests corrective action responses
should fugitive emissions be observed.
Monitoring
During landfill operations, a dust monitoring program will be implemented to evaluate
the dust control measure performance and observe the areas for dust emissions. The dust
monitoring program consists of performing visual observations of dust prone areas, dust control
measures, and monitoring existing and forecasted weather conditions.
Dust emissions can occur under many conditions. For the purposes of this Plan, dust emissions
are characterized as fugitive emissions, where FGD residue dust is located outside the limit of
landfill waste. This is most likely to occur during windy, dry, and hot weather conditions.
Therefore, the operator will monitor both existing and forecasted weather conditions and use dust control measures suited to the weather conditions. The dust control measures shall be
implemented prior to the forecasted weather conditions.

Equipment operators shall continuously observe the active face and other areas within the
landfill limit for dust emissions. In addition, preventative dust control measures should be observed and documented at least twice daily (morning and afternoon) when the landfill is in
operation to evaluate the dust control measure performance. Additional observations may be
necessary as site and weather conditions dictate. Observations will be documented on the
attached “Monitoring Worksheet,” or online database/worksheet, etc. Due to the continual
Stokes County, NC 3 Joyce Engineering, Inc. BCSS FGD Residue Landfill 6/20/2011
P:\Duke Energy\Belews Crk Sta\Dust Control\06.11 Final Dust Control Plan.docx
maintenance necessary on moisture conditioned and spray-applied areas, the operator shall pay
particular attention to these areas. Structural controls shall be observed to monitor that they are
achieving their intended purpose. Observations in the landfill area may be made with reference
to the attached cells grid systems.
Monitoring will be conducted during times when the landfill is in operations. The operator shall
continue to provide necessary dust control measures during periods when operations are inactive
(i.e. outages, weekends, holidays). Operators are to establish appropriate measures so that dust
emissions are not reasonably likely to occur during inactive operations periods when monitoring is not being conducted.
Corrective Action
If fugitive dust emissions are observed and observations indicate dust control measures
are not achieving their intended purpose, then appropriate corrective actions will be taken. Dust
control measures should be reapplied, repaired, or added, as necessary, to control dust emissions. The operator will construct, install, apply, and/or repair dust control measures prior to the end of
the work day to control dust emissions during non-operating hours. The operator will implement
dust control measures as preventative controls rather than in response to fugitive dust emissions.

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Appendix II

Phasing Drawings

Appendix III

Closure/Post-Closure Plan

Closure/Post-Closure Plan
Duke Energy Carolinas, LLC—Belews Creek Steam Station
Flue Gas Desulfurization (FGD) Residue Landfill Phase 1
1

1. INTRODUCTION 1.1 Introduction
The following Closure and Post-Closure Plan was prepared for Belews Creek Steam Station (BCSS) – Flue Gas Desulfurization (FGD) Residue Landfill. This plan was prepared in accordance with Title 15A Subchapter 13B of the North Carolina Administrative Code
(NCAC). Specifically, this plan was prepared to meet the requirements of the .0503(2) and
.0504(2) and 0.0505 and substantive requirements of Rules .1627-.1629 present requirements
for closure and post- closure of Municipal Solid Waste (MSW) Landfills. As stated, these rules apply to MSW units. The proposed unit will be a FGD Residue and coal combustion products landfill, and therefore some of the requirements of Rules .1627-.1629 do not apply.
The information contained in this plan will be used to assist Duke Energy Carolinas, LLC
(Duke Energy) in the closure of active waste units and the maintenance and monitoring
required during the post-closure care period.
1.2 Project Information The BCSS FGD Landfill is owned and operated by Duke Energy Carolinas, LLC (Duke). The
landfill is located in Stokes County, North Carolina on Duke property, south of the Belews
Creek Steam Plant, between the east and west arms of Belews Creek Lake near Walnut Cove.
The purpose of the Closure/Post-Closure Plan is to outline the sequence for closing the landfill phase and the post-closure maintenance activities for each phase. Closure is designed to minimize the need for long term maintenance and to control the post-closure release of
contaminants. Closure activities may be revised as appropriate for materials, specifications,
technology advances or changes in regulations at that time.

2. CLOSURE PLAN
The cover system has been designed to reduce infiltration into the landfill and to resist erosion.
The proposed cover system will incorporate a number of components which are described in
the following sections.
2.1 Cover System
The proposed final cover system will consist of the following from top to bottom and will be
placed over interim cover soils:

• a 6-inch thick vegetated erosion layer;
• a 18-inch thick soil barrier;
• a geocomposite drainage layer;
• a 40-mil thick double-sided textured linear low density polyethylene (LLDPE) geomembrane;
• a geocomposite gas collection layer; and
• existing intermediate soil cover.

Closure/Post-Closure Plan
Duke Energy Carolinas, LLC—Belews Creek Steam Station
Flue Gas Desulfurization (FGD) Residue Landfill Phase 1
2

2.1.1 Erosion Layer
The erosion layer will reduce erosion of the cover system, protect the soil barrier from root
penetration, and will consist of 6 inches of soil capable of sustaining native plant growth. 2.1.2 Soil Barrier
In concert with the underlying geocomposite drainage layer and geomembrane, the soil barrier will help minimize infiltration through to the waste and protect the liner. 2.1.3 Geocomposite Drainage Layer
The geocomposite drainage layer will promote cover system stability by collecting and
routing water that infiltrates the soil barrier to the perimeter surface water conveyance
measures. 2.1.4 Geomembrane
As an additional measure to prevent infiltration through the cover system and into the
waste, a geomembrane will be placed directly over the geocomposite gas collection layer.
2.1.5 Geocomposite Gas Collection Layer
The geocomposite gas collection layer will be placed directly over the interim cover of the
proposed landfill and will provide a pathway for accumulated gas to move laterally to the
gas vents.
2.1.6 Intermediate Cover
A thick layer of soil will be placed on top of the waste once final grades are reached. This
intermediate soil layer will serve as the base for the geocomposite gas collection layer.
2.2 Gas Venting System
Waste will consist of flue gas desulfurization (FGD) residue and coal combustion residuals
including fly ash, bottom ash, and mill rejects generated at the Belews Creek Steam Station.
The majority of the waste stream will consist of FGD gypsum and ash. Based on the inorganic
nature of the waste, methane will not be generated; also, it is not anticipated that hydrogen sulfide gas will be generated or that odor will be an issue. Therefore, Duke Energy does not propose monitoring for landfill gas nor providing landfill gas management measures until the
final cover is installed.
In the event that hydrogen sulfide gases are detected during landfill operations, appropriate
actions will be taken. In the event that gases are regularly detected during active landfill
operations, the final closure and post-closure plan will be developed to address the gas. A landfill passive gas venting system is provided as part of the engineered cover system. Once the landfill is capped, no monitoring for hydrogen sulfide gas will be necessary.

Closure/Post-Closure Plan
Duke Energy Carolinas, LLC—Belews Creek Steam Station Flue Gas Desulfurization (FGD) Residue Landfill Phase 1
3

2.3 Stormwater Management Systems
The proposed landfill is designed with a network of various stormwater controls and
conveyances to manage stormwater during active operations, over interim cover soils, and upon final closure. Upon landfill closure, stormwater will be collected and conveyed through a network of ditches, berms, and down-drain pipes to the perimeter surface water
management system. Plans and details illustrating the stormwater management system
are provided in the Closure Plan Drawings. 2.4 Largest Area Requiring Cover System The Phase 1 permitted area of 22.6 acres is the largest area that will need to be capped.
2.5 Estimated Maximum Waste Inventory
The proposed landfill design provides approximately 1,500,000 cubic yards of airspace
available for waste placement. Using an assumed in-place waste density of 84 lb/ft3, the available dry tonnage of waste to be placed in the landfill is estimated to be on the order of
1,701,000 tons. 2.6 Closure Schedule
Following the completion of waste placement, a final cover system will be constructed.
The primary purpose of a final cover system is to minimize infiltration of stormwater into
the waste, thus limiting generation of leachate. The proposed final cover system cross
section is presented in the Closure Plan Drawings.
Final closure of the landfill will commence when final design grades are achieved, Duke
Energy declares that no more waste will be accepted, or as directed by the North Carolina
Department of Environment and Natural Resources (NCDENR) Division of Waste
Management – Solid Waste Section (the Division). Duke Energy may elect to close the landfill incrementally during landfill operations once an area large enough to warrant cover
system construction has reached final grades. Prior to beginning closure of the proposed
landfill, the Owner or Operator shall notify the Division that a notice of intent to close the
landfill has been placed in the operating record. Closure activities for the landfill shall begin
no later than 30 days after final receipt of waste unless otherwise approved by the Division or, if the landfill has remaining capacity and there is a reasonable likelihood that the landfill will
receive additional wastes, no later than one year after the most recent receipt of wastes.
Extensions beyond the one-year deadline for beginning closure may be granted by the
Division if the Owner or Operator demonstrates that the landfill has the capacity to receive
additional wastes and the Owner or Operator has taken and will continue to take the steps necessary to prevent threats to human health and the environment from the unclosed landfill.
The final cover system will be finished within 180 days following the beginning of closure
activities unless otherwise approved by the Division. Extensions of the closure period may be
granted by the Division if the Owner or Operator demonstrates that closure will, of necessity, take longer than 180 days and they have taken and will continue to take the necessary steps to
prevent threats to human health and the environment from the unclosed landfill unit. The
final cover system for the closed phase will be certified by a professional engineer as being
completed. Duke Energy shall record a notation on the deed to the landfill property stating
Closure/Post-Closure Plan
Duke Energy Carolinas, LLC—Belews Creek Steam Station Flue Gas Desulfurization (FGD) Residue Landfill Phase 1
4

that the property has been used as a landfill and its use is restricted under the Closure/Post-
Closure Plan approved by the Division. The Division will be notified by Duke Energy of the
closure completion, certification, deed notation, and placement of these records into the
landfill’s operating record.
Following cover system construction, the landfill will be vegetated with grass and
maintained. A final cover will be established over the landfill unit being closed. The
maximum waste-filled area of the proposed landfill that would require closure operations at
any one time is approximately 22.6 acres. If the landfill is closed prior to reaching capacity, revised closure drawings will be submitted to the Division for approval. 3. POST-CLOSURE PLAN The Post-Closure Plan outlines the monitoring and maintenance activities intended to maintain
cover system integrity during the post-closure period, which is proposed to be 30 years. During the post-closure period the landfill cover system and related facilities must be monitored and
maintained. 3.1 Maintenance Activities
Maintenance activities will be required for the final cover system to remain functional. The vegetative cover shall be mowed a minimum of once a year. The vegetative cover shall be amended and fertilized as needed to maintain healthy vegetation. Depressions in the cover
that pond water or otherwise impair the function of the final cover will be filled and/or
regraded. Areas subject to regrading will be revegetated. Animal burrows and eroded areas
should be filled in with compacted soil and reseeded. If vegetative cover is not adequate in a particular area, fertilizer should be applied and the area reseeded in order to re-establish vegetation. Insecticides may be used to eliminate insect populations that are detrimental to
the vegetation. Any deep-rooted or woody vegetation that may have established itself on the
cover soil will be removed. In addition to maintenance of the vegetative cover, any items
noted as requiring maintenance in Section 3.2 Monitoring Activities would also require maintenance. 3.2 Monitoring Activities
Post-closure monitoring will be conducted quarterly for the first two years and semi-
annually thereafter for the remainder of the post-closure period. The following cover
system and landfill components will be monitored:
• security measures such as fences, gates, locks, and other measures that control site
and facility access;
• surface water management systems for signs of erosion, sedimentation, and
condition; • cover system for signs of erosion;
• cover system for evidence of settlement or subsidence;
• condition and/or presence of vegetation (for distressed or dying vegetation or
woody vegetation with potential to penetrate the low permeability barrier); • condition of the groundwater monitoring wells and gas venting system

Closure/Post-Closure Plan
Duke Energy Carolinas, LLC—Belews Creek Steam Station Flue Gas Desulfurization (FGD) Residue Landfill Phase 1
5

Post-closure monitoring will be documented on post-closure monitoring forms. Post-
Closure Monitoring Form sheets are provided in Appendix I. Completed post-closure
monitoring forms will be maintained in the facility operating record.
3.2.1 Groundwater Monitoring
The Groundwater Monitoring Plan will be continued semi-annually (or as required) after final
closure. The results of the analytical testing will be submitted to NCDENR as directed in the
Groundwater Monitoring Plan. 3.2.2 Surface Water Monitoring
Surface water monitoring of the downgradient tributaries to Belews Lake will be continued after closure as required by the NCDENR Division of Waste Management. Surface water discharged from the sediment basins will be sampled and analyzed if required by the NPDES
stormwater permit. 3.3 Facility Contact
The post-closure maintenance of the landfill will be the responsibility of Duke Energy. Correspondence should be directed to:
On-Site Environmental Professional
Duke Energy Carolinas, LLC – Belews Creek Steam Station
3195 Pine Hall Road, Belews Creek, North Carolina 27009
[phone] Facility Contact: Station Sponsor for Landfill Operations or Environmental
Professional
The landfill physical address and office information are the same as above. 3.4 Post-Closure Planned Use
Following closure operations, the landfill will be closed and vegetation will be planted and
maintained. Duke Energy will maintain control of, and limit access to the facility. No post-closure use is proposed at this time. In the event the post-closure planned use is changed,
Duke Energy shall obtain prior approval from NCDENR. 3.5 Certification
Consistent with regulations, the end of the closure-post closure period must be certified by a registered professional engineer. To accomplish certification over the required 30-year duration, a registered professional engineer will prepare annual certifications. The annual
certifications will document that the cover system has been monitored and maintained in
accordance with the Post-Closure Plan. The annual certifications shall be based on
observations and results documented on regular post-closure monitoring reports, maintenance records, and compliance monitoring reports maintained in the Operating Record.

QUARTERLY INSPECTION LOG Duke Energy FGD Residue Landfill Belews Creek, North Carolina
Inspector:______________________________________________
Date:__________________________________________________
Component Location Description Repair/ Cleanup? Type of Corrective Action Date to be completed

Opinion of Closure Cost:
FGD Residue Landfill
Belews Creek Steam Station
Duke Energy Carolinas, LLC
7/17/2012
ITEM UNIT QUANTITY UNIT COST COST $
FINAL CAP SYSTEM- 22.6 ACRES (PHASE 1)
Intermediate Cover (demo and fine grading)acre 23 $4,500.00 $103,500
Geocomposite Gas Collection Layer sf 984,456 $0.50 $492,228
Geomembrane (40 mil )sf 984,456 $0.63 $620,207
Geonet Composite (Drainage Layer)sf 984,456 $0.98 $964,767
Protective cover (18")cy 54,692 $4.00 $218,768
Topsoil (6")cy 18,231 $4.50 $82,040
Subtotal $2,481,510
SEDIMENTATION AND EROSION CONTROLS
Diversion Berms
Construction and lining lf 6,800 $13.00 $88,400
Slope Drains
Pipe and Installation lf 1,200 $43.12 $51,744
Drainage Bench Inlet each 3 $300.0 $900
Conveyance Channels
Riprap Channels lf 0 $57.50 $0
Grass-lined Channels lf 0 $25.00 $0
Drainage Pipe lf 0 $40.00 $0
Miscellaneous
Outlet Protection (RipRap)each 3 $10,000.00 $30,000
Silt Fence lf 500 $3.60 $1,800
Subtotal $172,844
GAS CONTROLS (Vents)each 6 $5,000.00 $30,000
VEGETATIVE COVER acre 23 $2,000.00 $46,000
TOTAL OF ABOVE ITEMS $2,730,354
MOBILIZATION / DEMOBILIZATION (construction only)5%$136,518
ENGINEERING FEE --2%$54,607
CQA (cap only)-6%$148,891
CONTINGENCY --10%$273,035
ADMINISTRATION lump sum --$2,500
CLOSURE CERTIFICATION lump sum --$2,500
SURVEY AND DEED acre 23 $1,400.00 $32,200
TOTAL CLOSURE COST (IN 2012 DOLLARS)$3,380,605
Cost per acre (for 22.6 acres)$149,584.29
Notes:
1. Costs are based on conceptual design and should be considered approximate.
Opinion of Post-Closure Care Costs:
FGD Residue Landfill
Belews Creek Steam Station
Duke Energy Carolinas, LLC
7/17/2012
ITEM UNIT QUANTITY UNIT COST ANNUAL COST
INSPECTIONS/ RECORD KEEPING per trip 4 $1,000 $4,000
ROUTINE MAINTENANCE
Mowing acre 22.6 $100 $2,260
Stormwater Structures lump sum 1 $5,000 $5,000
Roads, Fencing, Gates, Signs, Etc.lump sum 1 $3,000 $3,000
Leachate Collection and Storage lump sum 1 $1,000 $1,000
Subtotal $11,260
WELL MAINTENANCE
Groundwater Wells lump sum 1 $1,000 $1,000
Subtotal $1,000
CAP REPAIR lump sum 1 $7,500 $7,500
TOTAL OF ABOVE ITEMS $23,760
ENGINEERING --5%$1,188
CONTINGENCY --15%$3,564
TOTAL ANNUAL POST-CLOSURE COST (IN 2012 DOLLARS)$28,512
Cost Per Year Per Acre (for 22.6 acres)$1,262TOTAL 30-YEAR POST-CLOSURE COST (IN 2012 DOLLARS)$855,360
Notes:
1. All costs include labor by a third party.
2. Cap repair assumes that five acres will require repair during the period.
3. Maintenance cost for groundwater wells assumes replacement of 10 wells during the period.
Opinion of Potential Assessment Corrective Action Costs:
FGD Residue Landfill
Belews Creek Steam Station
Duke Energy Carolinas, LLC
7/17/2012
ITEM UNIT QUANTITY UNIT COST ANNUAL COST
MONITORING
Groundwater/Surfacewater (semi-annually)
Sampling per trip 2 $4,000 $8,000
Analysis per trip 2 $2,500 $5,000
Reporting per trip 2 $2,500 $5,000
Surface Water (semi-annually)per trip 2 $2,100 $4,200
Subtotal $22,200
LEACHATE MONITORING allowance 1 $3,600 $3,600
CORRECTIVE ACTION PLAN ACTIVITIES per year 1 $36,000 $36,000
TOTAL OF ABOVE ITEMS $61,800
ENGINEERING --3%$1,854
CONTINGENCY --5%$3,090
TOTAL ANNUAL PACA COST (IN 2012 DOLLARS)$66,744
TOTAL 30-YEAR PACA COST (IN 2012 DOLLARS)$2,002,320
Notes:
1. All costs include labor by a third party.
2. Water quality monitoring and leachate management costs are estimated.
3. It is assumed that gas monitoring will not be necessary for this site.

Appendix IV

Chimney Drain System

Stokes County, NC 1 Joyce Engineering, Inc.
BCSS FGD Residue Landfill Revised 5/8/2012
P:\Duke Energy\Belews Crk Sta\FGD Permit Renewal\Chimney Drain Ops Plan - Rev.docx

CHIMNEY DRAIN SYSTEM

The Flue Gas Desulfurization (FGD) landfill at the Belews Creek Steam Station receives
primarily FGD materials as a byproduct of air quality emissions measures. This predominant
waste stream presents a problem when managing leachate from this facility. A traditional
landfill that accepts a wide array of wastes typically allows leachate to move through the waste
mass to the floor of the cell for collection and removal from the landfill. In contrast, leachate
does not flow through the FGD material, but is absorbed into the waste or flows across the
surface to a perimeter collection system. This sheet flow, directed at the exterior slopes of the
landfill, is difficult to control. Multiple interior drains will help contain the flow within the waste
boundary and avoid contaminating traditional stormwater management facilities.
In order to better manage contact water, a chimney drain network has been designed to
route leachate through the waste and out of the landfill through the existing leachate outfalls.
Chimney Drain Design
The intent of the chimney drain design is to produce an operationally manageable
solution to safely handle contact water. The design uses readily available materials that can
successfully be implemented by the landfill operator following an initial construction event to
fabricate and install the trunk line systems.
The design utilizes the cell 3 and 4 sump outlets to remove leachate from the system via a
30 inch SDR 26 HDPE pipe. Material properties used in the design of this system are consistent
with those used elsewhere in the design of the facility.
The 25 year storm event was used to estimate overall capacity for the system. As the
landfill cells 1, 2 and 3 are already filled to approximately the 800 ft amsl elevation at the time of
system installation, an appropriate runoff area was used to estimate overland flow to the system
inlets.
Chimney Drain Construction
To install the trunkline pipes to the existing sump structures, an adequate sized hole will
be cut in the existing perforated riser at or above the flowline of the outlet. The pipe will be
extrusion welded around the diameter of the pipe on the interior and exterior of the riser with
gussets on the exterior for strength. The pipe will be supported with #57 stone material or
bottom ash until such time that the pipe can be laid upon the existing protective cover / FGD
waste layer in the cell. The 30 inch pipe will be continuously welded to conform to the bottom
Stokes County, NC 2 Joyce Engineering, Inc.
BCSS FGD Residue Landfill Revised 5/8/2012
P:\Duke Energy\Belews Crk Sta\FGD Permit Renewal\Chimney Drain Ops Plan - Rev.docx

layer of the cell providing a minimum 1% grade to the system outlet. Three feet of cover soil or
FGD material will be required to be placed over the pipe before traffic can cross the trunkline.
Six 24-inch ‘tee’ sections will be installed at approximate locations as shown on the design
drawings. Drain inlets 1, 2, 5 and 6 will transition from the SDR 26 HDPE immediately to a
perforated, double wall corrugated HDPE pipe (ADS N-12 or equivalent). Inlets 3 and 4 will use
SDR 26 HDPE vertical extensions until approximately 35 feet below the final grade surface
before transitioning to the perforated pipe section.
Chimney Drain Operations
The initial section of N-12 pipe will be 5 feet long with perforations as shown on the
design drawings. If the design year storm event occurs during this initial condition, the operator
can expect the water to overtop the structure. Therefore, local depressions of up to 5 feet will be
left around the drain inlets to prevent widespread ponding on the landfill. The pipe will be
encased with a minimum of one foot of #57 drainage stone or bottom ash in order to maintain
flow to pipe perforations. A grated inlet on top of the chimney drain will remain in place at all
times at each drain to prevent large objects from entering the system.
The fill will be graded to serve up to 5 acres at each of 4 active drains. Once the fill
progresses to the top of the grate inlet at any given drain, a perforated riser will be added in
maximum 10 foot sections and a stone or bottom ash column maintained as fill is placed around
the inlet pipe. Waste shall be graded such that there is always positive flow to the chimney drain
system.
Chimney Drain Termination
The waste filling and drain extension operations will continue until either the drain
reaches the extent of the fill at an exterior slope, or the final landfill grades have been reached.
Once the final elevation of the drain has been verified, the drain will be filled with #57 stone or
bottom ash and a permanent cap affixed to the top of the inlet pipe. This cap will be installed
approximately 5 feet below the final landfill elevation at that location.

Appendix V

Leak Detection System

Leak Detection System
Duke Energy Carolinas, LLC—Belews Creek Steam Station
Flue Gas Desulfurization (FGD) Residue Landfill Phase 1
Page 1 of 1

Leachate Storage Basin – Leak Detection System During the operational phase of the landfill, the Leachate Storage Basin, located on
the west side of the landfill, will collect stormwater that has contacted waste and
leachate from cells that contain waste. After operation ceases within a cell, only
leachate will drain to the lined storage basin. The liquid collected in this lined basin
gravity drains to a pump station, where it is pumped to the station
wastewater treatment system.
In addition to the primary geomembrane basin liner, the lined leachate storage basin is
equipped with a Leak Detection System, consisting of a secondary geomembrane liner and drainage system that drains to a sump, located on the south end of the basin. The purpose of this system is to detect and to collect liquids that may leak
through the primary liner and to pump the liquid to the pump station.
Located inside the 14 inch diameter side slope riser pipe is an electric powered
pump and level sensor. The discharge from the pump is piped to the pump station
sump. The control panel for the pump and level sensor is equipped with a dome mounted
flashing alarm light that will activate on a high level setting of 2 feet of head. The
control panel is equipped with an hour meter, indicating run time for the pump, and
a flow totalizer, indicating the quantity of liquid that has been pumped. The readings
for the hour meter and for the flow totalizer are to be recorded weekly. Leak Detection System - Action Leakage Rate Response Plan
The Action Leakage Rate is set at a rate of 50 gallons-per-day collected over a 30 day
period. The Action Leakage Rate (ALR) Response Plan for the Leachate Storage
Basin Leak Detection System is as follows:
• The NCDENR Solid Waste Regional Office in Winston-Salem is notified.
• Samples of the collected liquid are analyzed for specific conductivity, pH,
sulfates, chlorides, and boron. Analytical methods are to be the same as
described in the Groundwater Sampling and Analysis Plan.
• Samples of the liquid are collected from within the basin.
These samples are subjected to the same analyses.
• The results of these analyses are compared to determine if the source of the
collected liquid is the basin.
• The results of the analyses and a summary of the comparison will be sent to
the NCDENR Solid Waste Regional Office in Winston-Salem.
• Further actions will be determined based on the results of the comparison of
analytical results.

Appendix VI

NCDENR Communications