Cape Fear CBE - Closure Plan_20191230

veviye 1. nmoiw.n
Senior Vice President
Coat Combustion Products
tDUKE
ENERGY
December 30, 2019
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: Cape Fear Steam Station Ash Basin Closure Plan
Dear Ms. Holman:
400 South Tryon Street, ST06A
Charlotte, NC 282t12
Phone: [phone]
Email., [e-mail]
In accordance with the requirements of North Carolina General Statue § 130A-309. 214(a)(4),
Closure of Coal Combustion Residuals Surface Impoundments, Duke Energy provides the
attached plan for ash basin closure by excavation.
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,
George T. 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

DUKE ENERGY wood.
CAPE FEAR STATION
COAL COMBUSTION RESIDUALS SURFACE
IMPOUNDMENT CLOSURE PLAN
CLOSURE BY EXCAVATION
1956 Ash Basin
1963/1970 Ash Basin
1978 Ash Basin
1985 Ash Basin
Closure Plan Report
Final Submittal
Prepared for
(�. D U KE
E N E R(37
550 South Tryon Street
Charlotte, North Carolina 28202
Revision 0
Issue Date: 11 December 2019
Prepared by
Wood Environment & Infrastructure Solutions, Inc.
4021 Stirrup Creek Drive, Suite 100
Durham, North Carolina 27703
Project No. 7812180071

Wood Environment & Infrastructure Solutions, Inc.
Duke Energy Coal Combustion Residuals Management Program
Cape Fear Station Basin Closure Plan
TABLE OF CONTENTS
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EXECUTIVE SUMMARY............................................................................................iv
1.0 INTRODUCTION............................................................................................................... 1
1.1 Background...................................................................................................................................1
1.2 Closure Plan Objectives............................................................................................................... 1
1.3 Report Organization...................................................................................................................... 2
2.0 GOVERNING LAWS......................................................................................................... 2
3.0 FACILITY DESCRIPTION AND EXISTING SITE FEATURES .......................................... 3
3.1 Surface Impoundment Description............................................................................................... 3
3.1.1 Site History and Operations................................................................................................ 3
3.1.2 Estimated Volume of CCR in Impoundments.....................................................................3
3.1.3 Description of Surface Impoundments Structural Integrity.................................................4
3.1.4 Sources of Discharges into Surface Impoundments...........................................................5
3.1.5 Existing Liner System.......................................................................................................... 5
3.1.6 Inspection and Monitoring Summary..................................................................................5
3.2 Site Maps...................................................................................................................................... 6
3.2.1 Summary of Existing CCR Impoundment Related Structures............................................6
3.2.2 Receptor Survey.................................................................................................................6
3.2.3 Existing On -Site Landfills.................................................................................................... 6
3.3 Monitoring and Sampling Location Plan....................................................................................... 6
4.0 RESULTS OF HYDROGEOLOGIC, GEOLOGIC, AND GEOTECHNICAL
INVESTIGATIONS............................................................................................................ 6
4.1
Background...................................................................................................................................6
4.2
Hydrogeology and Geologic Descriptions.................................................................................... 7
4.3
Stratigraphy of the Geologic Units Underlying Surface Impoundments ....................................... 7
4.4
Geotechnical Properties............................................................................................................... 7
4.4.1 CCR Within Ash Basins......................................................................................................7
4.4.2 Liner Material Properties.....................................................................................................8
4.4.3 Subsurface Soil Properties.................................................................................................8
4.5
Chemical Analysis of Impoundment Water, CCR and CCR Affected Soil .................................... 8
4.6
Historical Groundwater Sampling Results.................................................................................... 8
4.7
Groundwater Potentiometric Contour Maps................................................................................. 8
4.8
Estimated Vertical and Horizontal Extent of CCR within the Impoundments ............................... 8
5.0 GROUNDWATER MODELING ANALYSIS...................................................................... 9
5.1 Site Conceptual Model.................................................................................................................. 9
5.2 Geochemical Site Conceptual Model............................................................................................ 9
5.3 Groundwater Trend Analysis........................................................................................................ 9
6.0 BENEFICIAL USE AND FUTURE USE............................................................................ 9
6ACCR Beneficial Use...................................................................................................................... 9
6.2 Site Future Use............................................................................................................................. 9
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7.0 CLOSURE DESIGN DOCUMENTS.................................................................................. 9
7.1 Engineering Evaluations and Analyses......................................................................................
10
7.2 Closure Plan Activities................................................................................................................
10
7.3 Design Drawings.........................................................................................................................
11
7A Description of Construction Quality Assurance and Plan...........................................................
11
8.0 MANAGEMENT OF WASTEWATER AND STORMWATER...........................................12
8.1 Anticipated Changes in Wastewater and Stormwater Management ..........................................
13
6.2 Wastewater and Storm water Permitting Requirements..............................................................
14
9.0 DESCRIPTION OF FINAL DISPOSITION OF CCR.........................................................14
10.0 APPLICABLE PERMITS FOR CLOSURE.......................................................................14
11.0 DESCRIPTION OF POST -CLOSURE MONITORING AND CARE..................................14
11.1 Groundwater Monitoring Program..............................................................................................
15
12.0 PROJECT MILESTONES AND COST ESTIMATES........................................................15
12.1 Project Schedule.........................................................................................................................
15
12.2 Closure and Post -Closure Cost Estimate...................................................................................
15
13.0 REFERENCES.................................................................................................................17
Tables
Table 2-1 CAMA Closure Plan Requirements Summary and Cross Reference Table
Table 4-1 Summary of Typical Material Properties
Table 10-1 Cape Fear Plant Regulatory Permits, Approvals, or Requirements for Ash Basin
Closure by Excavation
Fi ures
Figure 1-1 Vicinity Map and Site Plan
Figure 1-2 Overall Existing Conditions Plan
Appendices
Appendix A
Estimated Volume of CCR in Impoundment
Appendix B
Geotechnical Data and Properties
Appendix C
Engineering Evaluations and Analyses
Appendix D
Closure Plan Drawings
Appendix E
Excavation Soil Sampling Plan
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Cape Fear Station Basin Closure Plan
EXECUTIVE SUMMARY
In accordance with N.C.G.S. § 130A-309.214(a)(4), Duke Energy has prepared this Closure Plan
to describe the closure of the coal combustion residuals (CCR) surface impoundments (Basins)
at the Cape Fear Station. The Cape Fear Station Basins closure will consist of closure by
excavation, whereby CCR in the Basins will be excavated, processed, and transported off -site for
beneficial re -use as a concrete amendment. The removal of CCR and closure of the Basins will
be in accordance with all applicable provisions of the North Carolina Coal Ash Management Act
of 2014, Sess. L. 2014-122, as amended (codified at N.C.G.S. § 130A-309.200, et seq.) (CAMA).
CCR processing will be done using on -site STAR' (Staged Turbulent Air Reactor) Technology, a
patented thermal beneficiation process to transform coal ash from CCR surface impoundments
into a high -quality, sustainable product for the concrete industry.
Duke Energy will periodically review the progress of the excavation and STAR' processing as it
relates to achieving full CCR removal by the required end date of October 1, 2028 for 1956, 1963
and 1970 Ash Basins and October 1, 2029 for the 1978 and 1985 Ponds. Duke Energy will
implement a concurrent excavation plan in which the remaining excavated CCR will be
transported to an approved landfill facility in order to meet the end date of October 1, 2029 for
complete removal.
The Cape Fear Station is owned and operated by Duke Energy Progress, LLC (Duke Energy).
The approximately 483-acre Cape Fear Station site is located 500 CP&L Road in Chatham
County, Moncure, North Carolina, on the eastern bank of the Cape Fear River.
The plant initially began power production operations in 1923. Additional power generating units
were added from 1924 to 1969. In the most recent operating configuration, the plant employed
two coal-fired units along with four oil -fueled combustion turbine units. Power production
operations at the plant were terminated in October 2012, and demolition activities were completed
in 2017. There are no coal-fired units currently in operation at the Cape Fear Station.
This Closure Plan covers the Basins located at the Cape Fear Plant, identified in the North
Carolina Department of Environmental Quality (NCDEQ) Dam Safety Inventory as follows:
• 1956 Ash Basin Dike (NC Dam Safety ID CHATH-075)
• 1963 Ash Basin Dike (NC Dam Safety ID CHATH-076)
• 1970 Ash Basin Dike (NC Dam Safety ID CHATH-077)
• 1978 Ash Basin Dike (NC Dam Safety ID CHATH-078)
• 1985 Ash Basin Dike (NC Dam Safety ID CHATH-079)
The Basins at the Cape Fear Plant were all constructed as raised dike basins, with excavated
soils from within the Basins to construct the dikes. During operation, fly ash, bottom ash, coal
slag, unburned coal, and stormwater from the plant were transported from the plant to the facility's
Basins by hydraulic (wet) sluicing. With the permanent retirement of the coal-fired generating
units, there are no longer any CCR disposal operations within the Basins.
The Basins are unlined and the maximum depth of CCR within these basins varies between 20
and 40 feet. Information provided by Duke Energy (with updated CCR inventory data through July
31, 2019) indicates that the current estimated volume of ash in the Basins is approximately 5.765
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million tons (4.804 million cubic yards assuming a conversion factor of 1.2 tons/cy). It should be
noted that the CCR volume/tonnage estimates are approximations since they are based on
assumed pre -basin grades.
Upon approval of the Closure Plan by NCDEQ, additional activities to complete closure of the
Basins will commence, including beginning excavation of the CCR from the Basins, establishing
final grades using soil fill where required to properly drain the Basin areas, breaching/removing
the Basin dikes following removal of CCR (soil material removed from the Basin dikes will remain
on -site and will be incorporated into the final site grading plan), and development of stormwater
features and vegetative covers.
This document also includes a description of the future Post -Closure Care Plan, which will provide
a description of the inspection, monitoring, and maintenance activities required to be performed
for the Cape Fear Station site for a minimum of 30 years.
This document provides a summary of properties of the site, as well as geotechnical properties
of CCR and natural soils to support engineering analyses of the closure design. These analyses
indicate that closure by excavation, as detailed in the Closure Plan, meets regulatory
requirements for the stability of the site, management of stormwater runoff, and access for
effective maintenance over the post -closure care period.
In a letter dated April 5, 2019, NCDEQ established submittal dates for an updated Comprehensive
Site Assessment (CSA) and updated Corrective Action Plan (CAP) for CCR surface
impoundments and other primary and secondary sources. Consistent with this direction, Duke
Energy will submit to NCDEQ the updated CSA for Cape Fear by September 1, 2020, and the
updated CAP by June 1, 2021. The CAP sets out corrective action measures for the restoration
of groundwater quality as required under CAMA and the state's groundwater quality regulations.
Although the Closure Plan contains references to the CAP, all specific relevant details to
groundwater and related actions will be contained in the CAP itself and not in this Closure Plan.
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1.0 INTRODUCTION
1.1 Background
The approximately 483-acre Cape Fear Station site is located at 500 CP&L Road in Chatham
County, Moncure, North Carolina, adjacent to the Cape Fear River and south of the confluence
of the Haw and Deep Rivers. Commercial operations of the station began power production in
1923 with two coal-fired units. Additional power generating units were added from 1924 to 1969.
Power production operations at the Cape Fear Station were terminated in October 2012, ceasing
all waste flows at that time. Demolition activities were completed in 2017.
This Closure Plan is being submitted for approval by NCDEQ and reflects closure by excavation
of the CCR from the Cape Fear Station site. Processing of the excavated CCR will be done using
STAR' Technology, a patented thermal beneficiation process to transform coal ash from CCR
surface impoundments into a high -quality, sustainable product for the concrete industry. Figure
1-1 presents a Vicinity Map and Site Plan of the Cape Fear Station.
The Cape Fear Station has five regulated impoundment structures (Figures 1-1 and 1-2). This
Closure Plan covers the Basins located at the Cape Fear Station that are identified (and regulated
by) the North Carolina Department of Environmental Quality (NCDEQ) and Dam Safety as follows:
• 1956 Ash Basin Dike (NC Dam Safety ID CHATH-075)
• 1963 Ash Basin Dike (NC Dam Safety ID CHATH-076)
• 1970 Ash Basin Dike (NC Dam Safety ID CHATH-077)
• 1978 Ash Basin Dike (NC Dam Safety ID CHATH-078)
• 1985 Ash Basin Dike (NC Dam Safety ID CHATH-079)
This Closure Plan has been prepared for the review and approval of NCDEQ.
1.2 Closure Plan Objectives
The primary objective of this Closure Plan is to address the closure by excavation of the CCR
from the Basins at the Cape Fear Station pursuant to North Carolina Coal Ash Management Act
of 2014, Session L. 2014-122, as amended (CAMA). A further objective is to obtain approval from
NCDEQ to proceed and develop the additional details (as described further within this Closure
Plan) and working documents necessary to complete the closure actions. Duke Energy is
requesting approval of this Closure Plan with the knowledge that other details will follow. This
Closure Plan describes and communicates the key actions and activities necessary to close the
Basins in accordance with the requirements for written closure plans for CCR surface
impoundments in N.C.G.S. § 130A-309.214(a)(4). Planned closure activities include:
• Removal of free water/bulk water volume via permitted outfall (i.e., decanting)
• Construction and operation of a temporary water management (WMS) system to manage
discharges in compliance with the NPDES permit during closure
• Construction of haul roads and STAR' Unit for processing of CCR for beneficial re -use
• Development of sump areas in the Basins to collect and convey waters to the water
management system
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• Dewatering the CCR to allow for safe access. CCR excavation and conditioning will be
required prior to transport to the on -site STAR° system
• Excavate CCR from the Basins, with sequencing determined for optimal progression.
Instrumentation and monitoring requirements to be developed prior to construction will be
followed to verify construction phase stability. Construction dewatering to be used as
needed to provide stable work areas and slopes
• Complete closure by excavation verification
• Breaching of the Basin dikes
• Grading the perimeter dikes into each of the basins with a grading plan that will establish
drainage to promote flow of stormwater out of the Basins in a manner protective of area
soils and water
1.3 Report Organization
This document is structured to follow the requirements of N.C.G.S. § 130A-309.214(a)(4).
2.0 GOVERNING LAWS
In August 2014, the North Carolina General Assembly enacted CAMA, which contains specific
statutory requirements applicable to CCR surface impoundments. Relative to the Cape Fear
Station, "coal combustion residuals surface impoundment," as defined in N.C.G.S. § 130A-
309.201(6), is interpreted to include the plant's Basins.
In July 2016, the North Carolina General Assembly enacted House Bill 630, which added
N.C.G.S. § 130A-309.216 requiring Duke Energy to identify three sites in North Carolina at which
to install and operate Ash Beneficiation projects capable of processing CCR to specifications
appropriate for cementitious products. The statute requires Duke Energy to use commercially
reasonable efforts to produce 300,000 tons of useable ash at each site annually. On October 5,
2016, Duke Energy selected the Cape Fear Station as one of the Ash Beneficiation sites. Pursuant
to subsection (c) of N.C.G.S. § 130A-309.216, CCR surface impoundments located at a site at
which an Ash Beneficiation project is installed and operating, shall be closed no later than August
1, 2028.
The Excavation Soil Sampling Plan for the Cape Fear Station (presented in Appendix E),
represents activities to satisfy the requirements set forth in the NCDEQ's November 4, 2016 letter
and attachment titled "CCR Surface Impoundment Closure Guidelines for Protection of
Groundwater."
In a letter dated April 5, 2019, NCDEQ established submittal dates for an updated Comprehensive
Site Assessment (CSA) and updated Corrective Action Plan (CAP) for CCR surface
impoundments and other primary and secondary sources. Consistent with this direction, Duke
Energy will submit to NCDEQ the updated CSA for the Cape Fear Station by September 1, 2020,
and the updated CAP by June 1, 2021.
In addition to the above requirements, National Pollutant Discharge Elimination System (NPDES)
permit program compliance, Special Order by Consent (which commits Duke Energy to initiate
and complete decanting of the Basins by dates certain) compliance, dam safety approvals for
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modifications to regulated CCR basin dikes, and environmental permitting requirements must be
considered as part of closure.
3.0 FACILITY DESCRIPTION AND EXISTING SITE FEATURES
3.1 Surface Impoundment Description
This section provides details on the CCR-related features at the Cape Fear Station.
3.1.1 Site History and Operations
Figure 1-1 shows locations of the Cape Fear Station and 1956 (CHATH-075), 1963 (CHATH-
076), 1970 (CHATH-077), 1978 (CHATH-078), and 1985 (CHATH-079) Basins. Figure 1-2 shows
the overall existing conditions at the Cape Fear Station.
The Cape Fear Station is located on the east bank of the Cape Fear River in Chatham County,
Moncure, North Carolina. Review of available information indicates that the property, consisting
of approximately 483 acres, is owned by Duke Energy, and is reported to have begun commercial
operation in 1923. Additional power generating units were added from 1924 to 1969. The CCR
Basins were constructed at the site between 1956 and 1985 as operational needs required
additional CCR disposal area. Sluicing of ash to the basins ceased in 2012. Process and waste
waters continued to be treated thru the 1978 and 1985 Ash Basins until 2015. In the most recent
operating configuration, the Cape Fear Station employed two coal-fired units along with four oil -
fueled combustion turbine units. A cooling water discharge channel is present in the middle
portion of the Cape Fear Station. The discharge channel extends to an unnamed tributary to the
Cape Fear River. All power generating operations were terminated at the Cape Fear Station in
October 2012 and demolition was completed in 2017.
There are no longer any CCR disposal operations within the Basins with the permanent retirement
of the coal-fired units. The Basins at the Cape Fear Station are surrounded by perimeter dikes
such that no external stormwater flows into the Basins.
3.1.2 Estimated Volume of CCR in Impoundments
Based on CCR inventory data provided by Duke Energy as of July 31, 2019 the approximate
volume of CCR in the Ash Basin is listed in the table below. To compute the estimated volume of
CCR in place an assumed density of 1.2 tons per cubic yard was used, which is the Duke Energy
fleet wide assumption. See Appendix A for the Estimated Volume of CCR Material in the
Impoundment data sheet.
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Impoundment
Estimated CCR Material Volume
(Cy)
Estimated CCR Material Weight
(tons)*
1956 Ash Basin
349,167
419,000
1963 Ash Basin
715,833
859,000
1970 Ash Basin
699,167
839,000
1978 Ash Basin
694,167
833,000
1985 Ash Basin
2,345,833
2,815,000
TOTAL
4,804,167
5,765,000
* Estimated CCR Material is based on updated CCR Inventory Data provided by Duke Energy as of July 31,
2019. To compute the estimated mass of CCR in place an assumed density of 1.2 tons per cubic yard was
used, which is the Duke Energy fleet wide assumption.
3.1.3 Description of Surface Impoundments Structural Integrity
The purpose of this section is to summarize the Basins' structural integrity evaluations based on
current existing information. This section includes brief summaries of the Geotechnical and
Hydrology and Hydraulics (H&H) capacity analyses results. Duke Energy provided Wood with
pertinent information regarding the integrity of the embankments, which had already been
compiled and analyzed. In summary, the structural integrity of the Basins and subsequent dam
inspection reports meet the regulatory requirements.
• Slope Stability:
Slope stability analysis completed for the identified critical cross sections for each of the dikes
indicate that the minimum factors of safety meet programmatic criteria under static, pseudo -
static, and post -seismic conditions.
• Liquefaction Conditions (where susceptible) and Liquefaction Potential:
Embankment and foundation soils associated with these dikes are not liquefaction -
susceptible. The predicted deformations from these analyses are negligible, less than'/2 inch.
Because the Basin dike embankments and foundation soils are not liquefaction -susceptible,
Wood expects no vertical seismically -induced settlements and negligible seismically -induced
shear at these structures during the Maximum Design Earthquake (MDE).
• Hydrology and Hydraulics (H&H) Capacity Analyses:
In April 2019, the NCDEQ promulgated new dam safety rules and, per the dam safety High
Hazard Classification, each CCR Basin is required to pass a full Probable Maximum
Precipitation (PMP). Each basin is classified as high hazard by NCDEQ due to the potential
for environmental impacts greater than $200,000, if the Basin failed. In response, Wood
performed H&H Analysis on each of the Basins at the Cape Fear site. Based upon the results
of these analyses, the 1956 Ash Basin and 1963/1970 Ash Basin both overtop during the
design storm event. Spillway designs have been developed for 1956 and 1963/1970 basins
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to address the requirements of the 2019 NCDEQ dam safety rules. The 1978 Ash Basin and
1985 Ash Basin both have the capacity to contain two times the design storm, and through
the pumping plan (currently in place) have the capability to release 80 percent of the detained
storm volume within 15 days following the design storm peak (6-hour PMP), as required by
the North Carolina dam safety rules. The results of the analyses are presented in Appendix
C.
3.1.4 Sources of Discharges into Surface Impoundments
Duke Energy has decommissioned the coal-fired power plant at this site. Since it is now
permanently retired from service, CCR is no longer sluiced into the Basins, and the Basins are
inactive. Since the Basins were constructed by raised dikes, the contributing drainage area to
each of the Basins consists only of the Basins themselves and the only discharges into the Basins
is from direct rainfall during rain events.
3.1.5 Existing Liner System
The Basins located at the Cape Fear Station do not include a geomembrane or clay liner system
and are considered to be unlined. Inspection and Monitoring Summary
Duke Energy conducts routine weekly, monthly, and annual inspections of the Basins, consistent
with North Carolina's dam safety requirements and the federal CCR rule.
Weekly Basin inspections have been on -going since 2014, and include observation of upstream
slopes and shorelines, crest, downstream slopes, toe areas, and adjacent drainage way(s),
spillway(s) and associated structure(s), and other structures and features of the dikes.
Monthly inspections of the Basins include the weekly monitoring elements with the addition of
piezometer and observation well readings; water level gauges/sensors; and visual observations
and documentation of slopes and benches of the dry ash stack in the 1985 Ash Basin.
Daily inspections of the Basins are not routinely required; however, on a case -by -case basis, the
Basins may be inspected daily beginning at such times and continued for the duration as specified
by plant management. Such daily inspections might be initiated during a repair activity on the dike
or in response to a specific imposed regulatory agency requirement.
The Basins are inspected annually by an independent third -party consultant. In a letter dated
August 13, 2014, NCDEQ requires these inspections to be conducted annually at all of Duke
Energy's CCR impoundments in North Carolina. These inspections are intended to confirm
adequacy of the design, operation, and maintenance of the surface impoundments in accordance
with accepted engineering standards. Reports are to be submitted to the NCDEQ within 30 days
of the completion of the inspection.
The results for the annual inspections are used to identify needed repairs, repair schedules, to
assess the safety and operational adequacy of the dikes, and to assess compliance activities
regarding applicable permits and environmental and dam regulations. Annual inspections are also
performed to evaluate previous repairs. The annual inspections of the dikes have been ongoing
since 2001, with 5-year inspections between 1986 and 2001.
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The 2015 through 2019 annual inspections did not identify features or conditions in the Basin
dikes or their outlet structures or spillways, that indicate an imminent threat of impending failure
hazard. Review of critical analyses indicated the designs conform to current engineering state of
practice to a degree that no immediate actions are required other than the recent and ongoing
surveillance and monitoring activities already underway.
Special inspections of the Basins may be performed during episodes of high -flow, earthquake,
emergency, or other extraordinary events. Visual inspections are performed after a heavy
precipitation event when accumulation of four inches of rainfall or greater occurs within a 24-hour
period. An internal inspection will be performed if a seismic event is felt locally or detected by the
US Geological Survey measuring greater than a Magnitude 3 and with an epicenter within 50
miles of the dikes. A special inspection would also be performed during an emergency, such as
when a potential dike breach condition might be identified or when construction activities (e.g.,
basin cleanout) are planned on or near the dikes. They are also conducted when the ongoing
surveillance program identifies a condition or a trend that warrants special evaluation.
3.2 Site Maps
3.2.1 Summary of Existing CCR Impoundment Related Structures
A site map showing property boundary, former location of the Cape Fear Station, and the Basins
with their boundaries and topographic and bathymetric contours are shown on Figure 1-2.
3.2.2 Receptor Survey
This information is included as part of the updated CAP being prepared separately by SynTerra
for Duke Energy and will be submitted to NCDEQ by June 1, 2021. The CAP is herein
incorporated by this reference, but its content is not the work product of Wood.
3.2.3 Existing On -Site Landfills
There are no known on -site landfills at the Cape Fear Station.
3.3 Monitoring and Sampling Location Plan
This information is included as part of the updated CAP being prepared separately by SynTerra
for Duke Energy and will be submitted to NCDEQ by June 1, 2021. The CAP is herein
incorporated by this reference, but its content is not the work product of Wood.
Locations of the existing groundwater monitoring wells are shown in Figure 4 of the Closure Plan
Drawings included in Appendix D, but the CAP should be consulted for details of well locations,
names, and status.
4.0 RESULTS OF HYDROGEOLOGIC, GEOLOGIC, AND GEOTECHNICAL
INVESTIGATIONS
4.1 Background
An overall boring and existing monitoring well location plan indicating the locations of recent and
historical borings, monitoring wells, piezometers, and Cone Penetration Test (CPT) sounding
locations is shown on Figure 4 included in Appendix D.
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This section summarizes the site geology and hydrogeology; site stratigraphy of the geologic units
underlying the surface impoundments; hydraulic conductivity of CCR and the soils underlying the
surface impoundment; geotechnical properties of the CCRs and the uppermost stratigraphic unit
under the surface impoundment; and the CCR and CCR-affected soils. Duke Energy provided
Wood with pertinent documentation regarding the site geology and hydrologic information, which
had already been compiled.
4.2 Hydrogeology and Geologic Descriptions
This information is included as part of the updated CSA being prepared separately by SynTerra
for Duke Energy and will be submitted to NCDEQ by September 1, 2020. The CSA is herein
incorporated by this reference, but its content is not the work product of Wood.
4.3 Stratigraphy of the Geologic Units Underlying Surface Impoundments
This information is included as part of the updated CSA being prepared separately by SynTerra
for Duke Energy and will be submitted to NCDEQ by September 1, 2020. The CSA is herein
incorporated by this reference, but its content is not the work product of Wood.
4.4 Geotechnical Properties
This section provides a summary of geotechnical conditions and properties found from
investigations performed within the Basins and Basin dike areas. The presented information was
obtained from previous geotechnical investigations at the site and recent investigation activities
conducted to support the Closure Plan development. The geotechnical conditions within the
Basins generally consist of CCR material (primarily interbedded layers of fly ash and bottom ash,
along with coal slag, unburned coal, and plant stormwater) placed in the Basins primarily by
hydraulic sluicing underlain by residual soil, saprolite, partially weathered rock (PWR), and
bedrock.
For purposes of discussion of the geotechnical properties of the materials, the saprolite material
is described as residual material. General properties of the various materials encountered within
and surrounding the Basins are described below. A range of measured material properties from
laboratory tests performed by Wood and SynTerra for the subsurface explorations completed
within the Basins is presented in Appendix B (boring locations are shown in Figure 4 of
Appendix D). A summary of typical measured properties for different material types are
presented in Table 4-1. A summary of laboratory tests data performed at the Cape Fear Station
in support of the closure design is presented in Appendix B.
4.4.1 CCR Within the Basins
The CCR within the Basins consists primarily of layers and mixtures of bottom ash and fly ash.
Other CCR materials such as slag are also typically encountered. The bottom ash generally
consists of very loose to loose, moist to wet, dark gray to gray, silty sand (SM) or silt and sandy
silt (ML). At some drilling locations, a surficial layer of CCR fill material (SP or SW or SW-SM)
was encountered that was used for boring access road construction.
The fly ash generally consists of very soft to soft, moist to wet, light to medium gray sandy silt and
silt (ML).
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Further information is included as part of the updated CSA being prepared separately by SynTerra
for Duke Energy and will be submitted to NCDEQ by September 1, 2020. The CSA is herein
incorporated by this reference, but its content is not the work product of Wood.
4.4.2 Liner Material Properties
The Basins at the Cape Fear Station are unlined, so there are no associated material properties.
4.4.3 Subsurface Soil Properties
Exploratory borings installed at the Cape Fear Station indicate the subsurface lithology generally
consists of a fining upward sequence of unconsolidated surficial alluvial deposits unconformably
atop a scoured bedrock surface comprised of sedimentary rock.
• Alluvium: Alluvium is likely present as a result of deposition of sediments from the Cape
Fear River and associated tributaries. The alluvium typically consists of 10 to 15 feet of
clay and silts that grade into a 5- to 10-foot layer of silt, clay, and sand, which in turn
grades into an approximate 5-foot layer of gravelly coarse sand directly atop weathered
bedrock.
• Bedrock: Little, if any, "transition zone" or Partially Weathered Rock (PWR) exists along
the unconformity between the alluvium and bedrock. Further, cores did not indicate a
significant zone of saprolite as indurated bedrock was typically observed less than 10 feet
below the unconformity of alluvium and bedrock. The bedrock consists of Triassic -age
sedimentary rock (mudstone and sandstone). The residuum (including saprolite) is the
next layer encountered and generally consists of soft to hard sandy lean clay (CL), silty
sand (SM), and sandy silt (ML).
4.5 Chemical Analysis of Impoundment Water, CCR and CCR Affected Soil
This information is included as part of the updated CSA being prepared separately by SynTerra
for Duke Energy and will be submitted to NCDEQ by September 1, 2020. The CSA is herein
incorporated by this reference, but its content is not the work product of Wood.
4.6 Historical Groundwater Sampling Results
This information is included as part of the updated CSA being prepared separately by SynTerra
for Duke Energy and will be submitted to NCDEQ by September 1, 2020. The CSA is herein
incorporated by this reference, but its content is not the work product of Wood.
4.7 Groundwater Potentiometric Contour Maps
This information is included as part of the updated CSA being prepared separately by SynTerra
for Duke Energy and will be submitted to NCDEQ by September 1, 2020. The CSA is herein
incorporated by this reference, but its content is not the work product of Wood.
4.8 Estimated Vertical and Horizontal Extent of CCR within the Impoundments
This information is included as part of the updated CSA being prepared separately by SynTerra
for Duke Energy and will be submitted to NCDEQ by September 1, 2020. The CSA is herein
incorporated by this reference, but its content is not the work product of Wood.
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5.0 GROUNDWATER MODELING ANALYSIS
This information is included as part of the updated CAP being prepared separately by SynTerra
for Duke Energy and will be submitted to NCDEQ by June 1, 2021. The CAP is herein
incorporated by this reference, but its content is not the work product of Wood.
5.1 Site Conceptual Model
This information is included as part of the updated CAP being prepared separately by SynTerra
for Duke Energy and will be submitted to NCDEQ by June 1, 2021. The CAP is herein
incorporated by this reference, but its content is not the work product of Wood.
5.2 Geochemical Site Conceptual Model
This information is included as part of the updated CAP being prepared separately by SynTerra
for Duke Energy and will be submitted to NCDEQ by June 1, 2021. The CAP is herein
incorporated by this reference, but its content is not the work product of Wood.
5.3 Groundwater Trend Analysis
This information is included as part of the updated CAP being prepared separately by SynTerra
for Duke Energy and will be submitted to NCDEQ by June 1, 2021. The CAP is herein
incorporated by this reference, but its content is not the work product of Wood.
6.0 BENEFICIAL USE AND FUTURE USE
6.1 CCR Beneficial Use
Duke Energy has developed plans for on -site recovery and reclamation/recycling of a significant
portion of the CCR at the Cape Fear Station, in accordance with rate established by NCGS §
130A-309.216. Duke Energy will implement a concurrent excavation plan in which the remaining
excavated CCR will be transported to an approved landfill facility in order to meet the end date of
December 31, 2029 for complete removal of the CCR.
The beneficial use activities consist of removing and transporting CCR from the Basins for
processing at a STAR' facility to be constructed on -site to the east of the 1985 Basin. The STAR'
facility will process the reclaimed CCR to a level of quality and condition suitable for future reuse
in the concrete industry.
6.2 Site Future Use
At this time, Duke Energy has not identified any future use of the land reclaimed by the excavation
and decommissioning of the Basins.
Since this Closure Plan details a closure by excavation method, no recording of a notation on the
deed to the property is required.
7.0 CLOSURE DESIGN DOCUMENTS
Closure of the Cape Fear Basins will be completed in two phases. Phase 1 is excavation and
Phase 2 will be the final decommissioning of the Basin dikes and final grading.
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7.1 Engineering Evaluations and Analyses
Engineering evaluations and analyses to support closure of the Basins at the Cape Fear Station,
as detailed in this Closure Plan, are provided in Appendix C. Based on the final post -closure
configuration of the Basins and absence of engineered fill features, no geotechnical calculations
accompany the Closure Plan presented herein. Calculations related to dike removal will be
included in the dike modification permit applications.
Safe and effective access to the Basins is critical to CCR excavation and the completion of
closure. Access road locations into or across the Basins cannot be reliably established until
detailed phasing of closure is developed, and a contractor is selected to complete the work. A
variety of mitigation techniques can be applied, such as installation of a geogrid and crushed
stone aggregate, placement and spreading of dry CCR over the basin surface to establish access
and use of low ground pressure or light weight construction equipment.
Areas for stockpiling or conditioning (drying) of CCR are generally needed. These areas will be
established within the limits of the CCR unit and require placement or stacking of CCR excavated
from other areas of the Basins. They will be established in areas where all or most of the CCR
has been removed, or on areas where a significant depth of CCR remains in place. Sluiced CCR
forming the foundation of stockpiles or conditioning (drying) areas may be subject to bearing
capacity or slope failures from the additional vertical compressive stress imparted by the stacked
CCR and hauling equipment.
During excavation of CCR, interim or temporary excavated CCR slopes are commonly created.
These slopes vary in height and the duration they will have to stand. Some slopes are subject to
potential loading from hauling or stockpiling operations. The location and geometry of such slopes
cannot be established during design. These elements depend on the means and methods
employed by the construction contractor, site conditions, schedule, and other site conditions.
Excavation in a deep valley fill creates significant safety risks that need further evaluation and will
require the means and methods inputs from a contractor to fully address before closure
excavation work commences. A detailed phasing and excavation plan will be developed after this
Closure Plan is approved by NCDEQ.
7.2 Closure Plan Activities
The primary activities associated with closure by excavation are as follows:
• Decant by using floating pumps, screened intakes, and pumping through the on -site WMS
under the existing NPDES permit
• Construct the STAR° facility and required haul roads
• Install stormwater diversion or retention controls to minimize stormwater flow impacts to
the CCR within the Basins
• Operate the on -site pumping and WMS to manage interstitial/pore water and contact
stormwater during construction
• Dewatering the CCR to allow for safe access. CCR excavation and conditioning will be
required prior to transport to the on -site STAR' system
• Start CCR excavation from the Basins, with sequencing determined for optimal
progression. Instrumentation and monitoring requirements to be developed prior to
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construction will be followed to verify construction phase stability. Construction dewatering
to be used as needed to provide stable work areas and slopes
• Maintain required hydraulic storage capacity throughout the excavation process
• Manage dusting from closure activities through the use of appropriate controls
• Complete closure by excavation verification. Grade the area to promote positive drainage
and seed for vegetative growth
• Sequence final dike breach with inflow design flood management
Additional information and details pertaining to the closure design are provided in the Closure
Plan drawings, which can be found in Appendix D.
7.3 Design Drawings
Four sets of Closure Plan drawings can be found in Appendix D. The sets of drawings provided
are for the 1956 Basin, the 1963/1970 Basin, the 1978 Basin, and the 1985 Basin. Each set
includes the following sheet for each of the Basins:
• Sheet 1 — Cover sheet
• Sheet 2 —
General project notes
• Sheet 3 —
Existing conditions overall aerial
• Sheet 4 —
Existing conditions
• Sheet 5 —
Estimated bottom of ash grades
• Sheet 6 —
Proposed final conditions
• Sheet 7 —
Cross -sections
These Closure Plan drawings will be further developed and refined to develop construction -level
drawings during subsequent stages following NCDEQ approval of the Closure Plan. In addition,
supplemental drawing sets will be prepared on an as -needed basis to support dike modification
and/or decommissioning permits, erosion, and sediment control permits, NPDES permit
modifications, and any other related permits.
Once the excavation grades shown on the Closure Plan drawings have been achieved, the
procedures described in the Duke Energy Excavation Soil Sampling Plan (Appendix E) will be
followed to confirm that closure by excavation has been achieved.
7.4 Description of Construction Quality Assurance and Plan
A Construction Quality Assurance (CQA) Plan will be developed following NCDEQ approval of the
Closure Plan for closure of the Basins located at the Cape Fear Station site. This CQA Plan
description has been prepared to address N.C.G.S. § 130A-309.214(a)(4)(g) of CAMA, and its
purpose is to provide a description of the CQA program to be adhered to in execution of the final
closure activities at the Cape Fear Station, being the construction of the dike breach and
stormwater channels. The CQA Plan will be a component of the dam decommissioning package
and will include a description of the roles and responsibilities for monitoring and testing activities
and provides guidance on the methodology to be used for evaluating whether the construction
has been performed in accordance with the approved Closure Plan. The CQA Plan will also detail
the material testing frequencies; methods for transportation, handling, and storage of materials;
test methods and verifications; manufacturer, field, and laboratory testing; field activities for
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construction monitoring and oversight; and reporting and documentation requirements. Technical
specifications to be developed as part of the construction -level design packages for contractor
bidding will present specific material properties and specifications.
The items that will be included in the CQA Plan will address materials and CQA activities
associated with the following components:
• Earthwork
• Stormwater Channels
• HDPE Piping
• As -Built Conditions
• Record Documentation Report
8.0 MANAGEMENT OF WASTEWATER AND STORMWATER
• Existing Wastewater and Stormwater Management
The Basins at the Cape Fear site are surrounded by perimeter dikes, and stormwater runoff from
adjacent areas does not enter the Basins. For the 1978 and 1985 Basins, stormwater collected
within the pond surface area is pumped to a water treatment system and subsequently released
to the Cape Fear River. The stormwater collected within the pond surface area for 1963/1970
Basin is currently discharged to the Cape Fear River through the discharge outlet pipe at the
southwest corner of the basin. The direct precipitation to the 1956 Basin historically infiltrated into
the CCR or was pumped to a water treatment system under the current pumping plan. The Cape
Fear site operates under a NPDES permit issued by the NCDEQ. Permit number NC0003433,
effective February 1, 2019 through June 30, 2023, authorizes seven discharge points (three
internal) that flow into the Cape Fear River (Outfalls 001, 005, 007, 008, 008A, 009, and S-05).
The 1956 and 1978 Basins do not have working outlet structures. A gate valve is installed in the
outlet structure of 1985 basin and dewatering is by mechanical system. The limits and
requirements stipulated for these outfalls can be found in the aforementioned permit.
In April 2019, NCDEQ promulgated new dam safety requirements and, per the dam safety High
Hazard Classification, each CCR basin is now required to pass a full PMP storm event. The Cape
Fear Basins are classified as High Hazard by NCDEQ due to the potential for environmental
impacts greater than $200,000, if the Basins failed. The PMP event will produce 29.5 inches of
rainfall (HMR-51 6-hour, 10 mi2, All -Season PMP Isopluvial Map).
Wood evaluated the site for the full PMP rainfall event and results indicated that the 1956 Basin
and 1963/1970 Basin both overtop during the design storm event. Spillway designs have been
developed for 1956 and 1963/1970 basins to address the requirements of 2019 NCDEQ Dam
Safety rules. Also, additional internal storage capacity will be obtained once excavation of the
CCR initiates. The 1978 and 1985 Ash Basin have the capacity to contain and release the full
PMP storm event.
Since the 1956, 1978 and 1985 Ash Basins do not have working outlet structures, per recent
NCDEQ guidance these ash basins would require the internal capacity to contain back-to-back
full PMP storms. The 1978 and 1985 Ash Basins are currently maintained under Pumping Plans
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by Duke Energy to assure the design storm inflow is released by pumping the stormwater to the
treatment system, followed by release to the Cape Fear River.
• Wastewater and Stormwater Management During CCR Excavation
Wastewater from the Basins will be pumped, treated (if required) and discharged meeting the
NPDES permit discharge requirements, in two phases; the Decanting Phase and the Dewatering
phase. In the Decanting phase, free water above the settled CCR layer will be removed from the
Basins without the mechanical disturbance of the CCR. In the Dewatering phase interstitial or
pore water will be removed from the CCR.
The Basin discharges will continue to be in service to meet the NPDES permit discharge
requirements as it goes through the two phases of waste water removal. Wastewater from the
Basins will be pumped, treated, and discharged through a WMS. WMS at Cape Fear consists of
a physical -chemical treatment system designed to meet the requirements of the discharge permit
including continuous monitoring for pH and Total Suspended Solids. The Cape Fear site WMS
has a designed flow rate of 400 gpm. Following the Decanting phase and as the Closure schedule
dictates, the Cape Fear site will advance into the Dewatering phase to remove interstitial water
from the Basins. During this phase, additional physical -chemical treatment processes will be
added to the wastewater treatment systems as necessary to maintain compliance with the
requirements of the discharge permit. During the Dewatering phase, the Cape Fear WMS will
have a designed flow rate of 400 gpm.
The 1956, 1978 and 1985 Basins are currently maintained under pumping plans by Duke Energy
to assure the design storm inflow is released by pumping the stormwater to the treatment system,
followed by release to the Cape Fear River.
Post -Closure Stormwater Management
The post -closure grading is anticipated to provide sheet flow to discharge points flowing to the
Cape Fear River with no detention. Up to and including the last phase of closure before the Basin
dikes are breached, the Basins will maintain the capacity to contain the required storm size/flows.
The concept plans for post -closure grading are based conservatively on 100-year storm events.
Appendix C presents the results of the post -closure stormwater management calculations.
8.1 Anticipated Changes in Wastewater and Stormwater Management
A WMS has been installed for the closure of the Basins. Afloating intake suction pump and screen
(followed by a sump upon sufficient dewatering), has been placed at the location of the lowest
elevation within the 1978 and 1985 Ash Basins. The system design, including pump capacity and
filter size, are such that the existing NPDES Outfall 008 effluent discharge limits, or other limits
as directed by the NCDEQ, will be met throughout the duration of dewatering and closure.
Erosion and Sediment Control Plans for different phases of the excavation will be developed as
part of the excavation packages for field implementation and formal Erosion and Sediment Control
Plan permit submittal. The Basins are NPDES permitted wastewater treatment units. Therefore,
only activities that can impact the areas outside the Basins will need to be addressed as part of
the Erosion and Sediment Control Plan. However, water quality of discharges from the Basins
during excavation may be impacted due to activities within the Basins, and appropriate planning
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and control measures will need to be implemented. This will be addressed during subsequent
stages of the design, and calculations to support the Erosion and Sediment Control Plans will be
developed during future stages of the design, which will follow NCDEQ approval of this Closure
Plan. In addition, erosion and sediment control measures may be installed and removed in phases
as stabilization is achieved.
8.2 Wastewater and Stormwater Permitting Requirements
Information on required permits is described in Section 10.
9.0 DESCRIPTION OF FINAL DISPOSITION OF CCR
CCR materials in the Basins at the Cape Fear Station will be excavated, processed, and
beneficially reused to achieve project goals in accordance with applicable state and federal
requirements and beneficial reuse contracts. CCR processing will be done using STAR°
Technology, a patented thermal beneficiation process to transform CCR into a high -quality,
sustainable product for the concrete industry.
An estimate of 5.7 million tons of CCR are currently stored in the Basins at the Cape Fear Station
(refer to section 3.1.2 for a detailed discussion and to Appendix Afor quantities). At full production,
the STAR° facility is designed to process 400,000 tons of CCR material per year (based on
information provided by Duke Energy). Assuming 10-years of processing (2020-2029), this would
allow approximately 4 million tons of CCR material to be processed for beneficial re -use, leaving
1.7 million tons which would potentially require handling by another process.
In order to meet the CCR removal deadline, Duke Energy will periodically review the progress of
the excavation and STAR° processing as it relates to achieving full CCR removal by the required
end date of October 1, 2028 for 1956, 1963 and 1970 Ash Basins and October 1, 2029 for the
1978 and 1985 Ponds. Duke Energy will implement a concurrent excavation plan in which the
remaining excavated CCR will be transported to an approved landfill facility in order to meet the
end date of October 1, 2029 for complete removal.
Vegetation encountered or removed during the progression of the work will be managed in
accordance with state regulations for handling and disposal.
10.0 APPLICABLE PERMITS FOR CLOSURE
Refer to Table 10-1 for detailed information on the potential and applicable permitting/approval
needed to implement this Closure Plan. Development of permitting package submittals and/or
regulatory approval requests will follow NCDEQ approval of the Closure Plan.
11.0 DESCRIPTION OF POST -CLOSURE MONITORING AND CARE
A Post -Closure Care Plan will be developed following NCDEQ approval of the Closure Plan for
closure of the CCR Basins located at the Cape Fear Station site. The purpose of the Post -Closure
Care Plan will be to provide a description of the inspection, monitoring, and maintenance activities
required to be performed throughout the 30-year post -closure care period for the closed CCR
Basins at the Cape Fear Station site. The Basins at the Cape Fear Station site are detailed in this
Closure Plan as being closed by excavation.
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The Post -Closure Care Plan will be developed to meet the requirements of N.C.G.S. § 130A-
309.214(a)(4)(k). The items that will be included in the Post -Closure Care Plan for the Cape Fear
Station include:
• Name, address, phone number, and email address of the responsible office or person
• Means and methods of managing affected groundwater and stormwater
• Maintenance of the groundwater monitoring systems
• Regular inspection and maintenance of the final cover system
• Groundwater and surface water monitoring and assessment program
• Post -closure inspection checklist to guide post -closure inspections
• Description of planned post -closure uses
• Financial assurance estimates for post -closure operations and maintenance and
remedial action
11.1 Groundwater Monitoring Program
This information is included as part of the CAP being prepared separately by SynTerra for Duke
Energy and will be submitted to NCDEQ by June 1, 2021. The CAP is herein incorporated by this
reference, but its content is not the work product of Wood.
12.0 PROJECT MILESTONES AND COST ESTIMATES
12.1 Project Schedule
On June 30, 2017, Duke Energy selected the Cape Fear Station as an ash beneficiation site as
required by N.C.G.S. § 130A-309.216. Excavation of CCR from the Cape Fear Station site for
beneficial use will occur over multiple project phases. Activities started in April 2017 and will
continue until all CCR is removed from the 1956 and 1963/1970 Basins by 2028, and the 1978
and 1985 Basins by 2029, then continuing until 2029/2030, when final site restoration is
completed.
A Closure project high-level milestone schedule has been prepared by Duke Energy and the
major activities and milestones are provided below:
Engineering, Dewatering Ongoing
STAR° Unit Construction Complete Q2-2021
STAR' Unit in Operation Q3-2021
Complete CCR Excavation Q1-2029
Site Restoration Q4-2029
12.2 Closure and Post -Closure Cost Estimate
Cost estimates for closure and post -closure care of the CCR Basins at the Cape Fear Station
were developed by Duke Energy and provided to Wood. These are Class 5 estimates as the
detailed and final design has not been developed at this stage of the closure project. Following
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approval of this Closure Plan by NCDEQ and further development of the project plans and
engineering designs, the cost estimate will be refined and updated.
The cost to complete the closure by excavation is estimated to be $502 million.
The cost to perform the 30-year post -closure activities and monitoring is estimated as $23 million.
The cost estimates include the following major activities:
• Site Infrastructure development, Site Preparation, and Mobilization
• Dewatering, Earthwork, and Subgrade Preparation
• CCR Excavation
• Stormwater Management, Erosion and Sediment Control, and Site Restoration
• Engineering Support (Design and CQA)
• Closure by Excavation Rectification and Dike Decommissioning
• Post -Closure — Groundwater Monitoring
• Post -Closure — Operations and Maintenance
• Contingency
Corrective action costs are included as part of the CAP being prepared separately by SynTerra
for Duke Energy and will be submitted to NCDEQ by June 1, 2021. The CAP is herein
incorporated by this reference, but its content is not the work product of Wood.
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13.0 REFERENCES
North Carolina General Assembly, Session Law 2014-122, Coal Ash Management Act, as
amended
North Carolina Department of Environmental Quality report, "Coal Combustion Residual
Impoundment Risk Classification" (2016)
North Carolina Department of Environmental Quality, 15A N.C.A.0 02K — North Carolina dam
safety rules
North Carolina Department of Environmental Quality, 15A N.C.A.C. 02L - North Carolina
groundwater rules
United States Environmental Protection Agency, Coal Combustion Residuals (CCR) Rule 40
C.F.R. Part 257, subpart D
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TABLES

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Table 2-1: CAMA Closure Plan Requirements
Summary and Cross Reference Table
Duke Energy, Cape Fear Station
Corresponding
No.
Description
Closure Plan
Section
Part II. Provisions for Comprehensive Management of Coal Combustion
Residuals § 130A-309.212(a)(4) Closure Plans for all impoundments shall include
all of the following:
a. Facility and coal combustion residuals surface impoundment — A description
of the operation of the site that shall include, at a minimum, all of the
following:
Site history and history of site operations, including details on the
1
manner in which coal combustion residuals have been stored and
3.1.1
disposed of historically.
2
Estimated volume of material contained in the impoundment.
3.1.2
3
Analysis of the structural integrity of dikes or dams associated with
3.1.3
impoundment.
4
All sources of discharge into the impoundment, including volume and
3.1.4
characteristics of each discharge.
5
Whether the impoundment is lined, and, if so, the composition thereof.
7.1
A summary of all information available concerning the impoundment as
6
a result of inspections and monitoring conducted pursuant to this Part
3.1.6
and otherwise available.
b. Site maps, which, at a minimum, illustrate all of the following:
All structures associated with the operation of any coal combustion
1
residuals surface impoundment located on the site. For purposes of this
3.2.1
sub -subdivision, the term "site" means the land or waters within the
property boundary of the applicable electric generating station.
All current and former coal combustion residuals disposal and storage
2
areas on the site, including details concerning coal combustion residuals
3.3
produced historically by the electric generating station and disposed of
through transfer to structural fills.
3
The property boundary for the applicable site, including established
3.3
compliance boundaries within the site.

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Corresponding
No.
Description
Closure Plan
Section
4
All potential receptors within 2,640 feet from established compliance
3 2 2
boundaries.
Topographic contour intervals of the site shall be selected to enable an
5
accurate representation of site features and terrain and in most cases
3.3
should be less than 20-foot intervals.
Locations of all sanitary landfills permitted pursuant to this Article on the
6
site that are actively receiving waste or are closed, as well as the
3.2.3
established compliance boundaries and components of associated
groundwater and surface water monitoring systems.
7
All existing and proposed groundwater monitoring wells associated with
3.3
any coal combustion residuals surface impoundment on the site.
All existing and proposed surface water sample collection locations
8
associated with any coal combustion residuals surface impoundment on
3.3
the site.
c. The results of a hydrogeologic, geologic, and geotechnical investigation of
the site, including, at a minimum, all of the following:
1
A description of the hydrogeology and geology of the site.
4.1
2
A description of the stratigraphy of the geologic units underlying each
4.2
coal combustion residuals surface impoundment located on the site.
The saturated hydraulic conductivity for (i) the coal combustion residuals
3
within any coal combustion residuals surface impoundment located on
4.3
the site and (ii) the saturated hydraulic conductivity of any existing liner
installed at an impoundment, if any.
The geotechnical properties for (i) the coal combustion residuals within
any coal combustion residuals surface impoundment located on the site,
(ii) the geotechnical properties of any existing liner installed at an
4
impoundment, if any, and (iii) the uppermost identified stratigraphic unit
4.4
underlying the impoundment, including the soil classification based upon
the Unified Soil Classification System, in -place moisture content, particle
size distribution, Atterberg limits, specific gravity, effective friction angle,
maximum dry density, optimum moisture content, and permeability.
A chemical analysis of the coal combustion residuals surface
5
impoundment, including water, coal combustion residuals, and coal
4.5
combustion residuals -affected soil.

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Corresponding
No.
Description
Closure Plan
Section
Identification of all substances with concentrations determined to be in
excess of the groundwater quality standards for the substance
6
established by Subchapter L of Chapter 2 of Title 15A of the North
4.6
Carolina Administrative Code, including all laboratory results for these
analyses.
7
Summary tables of historical records of groundwater sampling results.
4.6
A map that illustrates the potentiometric contours and flow directions for
all identified aquifers underlying impoundments (shallow, intermediate,
8
and deep) and the horizontal extent of areas where groundwater quality
4.7
standards established by Subchapter L of Chapter 2 of Title 15A of the
North Carolina Administrative Code for a substance are exceeded.
Cross -sections that illustrate the following: the vertical and horizontal
extent of the coal combustion residuals within an impoundment;
9
stratigraphy of the geologic units underlying an impoundment; and the
4.8
vertical extent of areas where groundwater quality standards established
by Subchapter L of Chapter 2 of Title 15A of the North Carolina
Administrative Code for a substance are exceeded.
d. The results of groundwater modeling of the site that shall include, at a
minimum, all of the following:
An account of the design of the proposed Closure Plan that is
based on the site hydrogeologic conceptual model developed
and includes (i) predictions on post -closure groundwater
elevations and groundwater flow directions and velocities,
1
including the effects on and from the potential receptors and
5.1
(ii) predictions at the compliance boundary for substances with
concentrations determined to be in excess of the groundwater quality
standards for the substance established by Subchapter L of Chapter 2
of Title 15A of the North Carolina Administrative Code.
Predictions that include the effects on the groundwater chemistry and
should describe migration, concentration, mobilization, and fate for
substances with concentrations determined to be in excess of the
2
groundwater quality standards for the substance established by
5.2
Subchapter L of Chapter 2 of Title 15A of the North Carolina
Administrative Code pre- and post -closure, including the effects on and
from potential receptors.

Wood Environment & Infrastructure Solutions, Inc. wood
Duke Energy Coal Combustion Residuals Management Program
Cape Fear Station Basin Closure Plan
Corresponding
No.
Description
Closure Plan
Section
A description of the groundwater trend analysis methods used to
demonstrate compliance with groundwater quality standards for the
substance established by Subchapter L of Chapter 2 of Title 15A of the
3
North Carolina Administrative
5.3
Code and requirements for corrective action of groundwater
contamination established by Subchapter L of Chapter 2 of Title 15A of
the North Carolina Administrative Code.
e. A description of any plans for beneficial use of the coal combustion residuals
in compliance with the requirements of Section .1700 of Subchapter B of
Chapter 13 of Title 15A of the North Carolina Administrative Code
6.1
(Requirements for Beneficial Use of Coal Combustion By -Products) and
Section .1205 of Subchapter T of Chapter 2 of Title 15A of the North Carolina
Administrative Code (Coal Combustion Products Management).
f. All engineering drawings, schematics, and specifications for the proposed
Closure Plan. If required by Chapter 89C of the General Statutes, engineering
7 1 7 2
design documents should be prepared, signed, and sealed by a professional
engineer.
g. A description of the construction quality assurance and quality control
program to be implemented in conjunction with the Closure Plan, including the
7.3
responsibilities and authorities for monitoring and testing activities, sampling
strategies, and reporting requirements.
h. A description of the provisions for disposal of wastewater and management of
8
stormwater and the plan for obtaining all required permits.
i. A description of the provisions for the final disposition of the coal combustion
residuals. If the coal combustion residuals are to be removed, the owner must
identify (i) the location and permit number for the coal combustion residuals
landfills, industrial landfills, or municipal solid waste landfills in which the coal
combustion residuals will be disposed and (ii) in the case where the coal
combustion residuals are planned for beneficial use, the location and manner
in which the residuals will be temporarily stored. If the coal combustion
residuals are to be left in the impoundment, the owner must (i) in the case of
closure pursuant to sub -subdivision (a)(1)a. of this section, provide a
9
description of how the ash will be stabilized prior to completion of closure in
accordance with closure and post -closure requirements established by
Section .1627 of Subchapter B of Chapter 13 of Title 15A of the North
Carolina Administrative Code and (ii) in the case of closure pursuant to sub -
subdivision (a)(1)b. of this section, provide a description of how the ash will be
stabilized pre- and post -closure. If the coal combustion residuals are to be left
in the impoundment, the owner must provide an estimate of the volume of
coal combustion residuals remaining.

Wood Environment & Infrastructure Solutions, Inc. wood
Duke Energy Coal Combustion Residuals Management Program
Cape Fear Station Basin Closure Plan
Corresponding
No.
Description
Closure Plan
Section
j. A list of all permits that will need to be acquired or modified to complete
10
closure activities.
k. A description of the plan for post -closure monitoring and care for an
impoundment for a minimum of 30 years. The length of the post -closure care
period may be (i) proposed to be decreased or the frequency and parameter
list modified if the owner demonstrates that the reduced period or
modifications are sufficient to protect public health, safety, and welfare; the
environment; and natural resources and (ii) increased by the Department at
the end of the post -closure monitoring and care period if there are statistically
significant increasing groundwater quality trends or if contaminant
concentrations have not decreased to a level protective of public health,
11
safety, and welfare; the environment; and natural resources. If the owner
determines that the post -closure care monitoring and care period is no longer
needed and the Department agrees, the owner shall provide a certification,
signed, and sealed by a professional engineer, verifying that post -closure
monitoring and care has been completed in accordance with the post -closure
plan. If required by Chapter 89C of the General Statutes, the proposed plan
for post -closure monitoring and care should be signed and sealed by a
professional engineer. The plan shall include, at a minimum, all of the
following:
1
A demonstration of the long-term control of all Ieachate, affected
11.1
groundwater, and stormwater.
A description of a groundwater monitoring program that includes (i) post -
closure groundwater monitoring, including parameters to be sampled
2
and sampling schedules; (ii) any additional monitoring well installations,
11.2
including a map with the proposed locations and well construction
details; and (iii) the actions proposed to mitigate statistically significant
increasing groundwater quality trends.
I. An estimate of the milestone dates for all activities related to closure and
12.1
post -closure.
m. Projected costs of assessment, corrective action, closure, and post -closure
12.2
care for each coal combustion residuals surface impoundment.
n. A description of the anticipated future use of the site and the necessity for the
implementation of institutional controls following closure, including property
6.2
use restrictions, and requirements for recordation of notices documenting the
presence of contamination, if applicable, or historical site use.

Wood Environment & Infrastructure Solutions, Inc. wood
Duke Energy Coal Combustion Residuals Management Program
Cape Fear Station Basin Closure Plan
Corresponding
No. Description Closure Plan
Section
§ 130A-309.212(b)(3) No later than 60 days after receipt of a proposed Closure Plan, the Department
shall conduct a public meeting in the county or counties proposed Closure Plan and alternatives to the
public.
§ 130A-309.212(d) Within 30 days of its approval of a Coal Combustion Residuals Surface
Impoundment Closure Plan, the Department shall submit the Closure Plan to the Coal Ash Management
Commission.

Wood Environment & Infrastructure Solutions, Inc. wood
Duke Energy Coal Combustion Residuals Management Program
Cape Fear Station Basin Closure Plan
Table 4-1: Summary of Typical Material Properties
Duke Energy, Cape Fear Station
Properties
CCR within the Basins
Foundation Soil (Residual) below
the CCR Basins
Fill Soil within the Embankment
Dikes
Foundation Soil (Residual) below
the Embankment Dikes
Partially Weathered Rock
(PWR)
Soil Type
Sand with silt (SP) to Silty Sand (SM)
Predominantly Bottom Ash,
Silt/Sandy Silt (ML) - Predominantly
Fly Ash
USCS Classification- CH, CL, ML, SC,
SM, SP, GC, and GW
USCS Classification- CH, CL, ML,
SC, SM, and GW
USCS Classification- CL, ML, SC, SM,
SP, SW and GP
Sampled as ML and CL with
gravel and rock fragments
Color
Light Gray to Dark Gray and Black
Brown, Red -Brown, Tan, and Gray
Tan, Orange, Gray and Black
Brown, Gray, and Tan
Red, brown, black, and gray
Plasticity
Predominantly Non Plastic
Non Plastic to Plastic
Non Plastic to Plastic
Non Plastic to Slightly Plastic
**
Liquid Limit
Predominantly Non Plastic
NP - 83
NP - 68
20 - 47
40*
Plasticity Index
Predominantly Non Plastic
NP-50
NP - 42
2 - 25
21*
Representative
Range
Geometric
Mean
Representative
Range
Geometric
Mean
Representative Range
Natural Moisture Content (%)
2% - 62%
33%
14% - 59%
28%
14% - 25%
11% - 78%
11%*
Fines Content
22% - 76%
52%
7% - 79%
39%
40% - 88%
6%- 95%
78%*
Clay Content
1% - 10%
4%
4% - 56%
16%
12% - 55%
4%- 48%
29%*
Blow Count - Uncorrected N Value (bpf)
WOR - 27
4
WOH - 50
12
3 - 34
1- 70
>50/0.5*
Moist Unit Weight
89 - 105 pcf
95 pcf
111- 139 pcf
126 pcf
116 - 138 pcf
111- 118 pcf
**
Dry Unit Weight
55 - 75 pcf
66 pcf
92 - 114 pcf
103 pcf
103 - 123 pcf
92 - 135 pcf
**
Specific Gravity
2.2 - 2.4
2.3
2.7
*
**
**
**
Horizontal Hydraulic Conductivity (cm/sec)
3.0E-06 - 7.9E-03
3.10E-04
** **
**
**
**
Vertical Hydraulic Conductivity (cm/sec)
1.4E-04
I *
8.4E-07 - 5.2E-05 4.50E-06
I 9.4E-04 - 3.5E-04
**
**
Notes:
No boring or laboratory information obtained prior to 2006 was included in the table above. For additional information, see attached Appendix
Outlier values were not included in the table above. For additional laboratory testing information, see attached Appendix
NP: Non Plastic
pcf: Pounds per cubic foot (Ib/ft)
bpf: blows per foot
WOR: Weight of rod
WOH: Weight of hammer
*Only one lab test available
**No lab testing data was available

Wood Environment & Infrastructure Solutions, Inc. wood
Duke Energy Coal Combustion Residuals Management Program
Cape Fear Station Basin Closure Plan
Table 10-1: Regulatory Permits, Approvals, or Requirements for
Basin Closure by Excavation
Duke Energy, Cape Fear Station
Permit/Approval
Existing
Type of Regulatory
General Permit
Regulating
Permit No.
Approval
Comments
Name or Subject
Agency
(if
Mechanism or Not
applicable)
Required
Air Quality
NCDEQ
Not Anticipated
Chatham
Building Permit
Not Anticipated
County
Modification or
abandonment of
CAMA program
CAMA Monitoring
Written NCDEQ DWR
monitoring wells
NCDEQ
Plan
approval
require the
approval of the
Division of Water
Resources (DWR)
CCR Impoundment
US EPA CCR
Required postings
Self -Regulating
Closure
Rule
to Public Record
Maintain CCR GW
monitoring
CCR Impoundment
US EPA CCR
network and
Self -Regulating
Monitoring Network
Rule
requirements as
stated in 257.90 -
257.98
Clean Water Act 401
Not Anticipated
Clean Water Act 404
Not Anticipated
Cutting Trees
Not Anticipated

Wood Environment & Infrastructure Solutions, Inc. wood
Duke Energy Coal Combustion Residuals Management Program
Cape Fear Station Basin Closure Plan
Permitting is
required to modify
CHATH-075
or abandon wells
CHATH-076
and
Certificate of
instrumentation on
Dam Safety
NCDEQ
CHATH-077
Approval to Modify
regulatory dams
CHATH-078
through the
CHATH-079
Division of Energy,
Mineral, and Land
Resources (DEMLR)
Ash Basin Dam -
Permitting is
required to modify
the dam in
CHATH-075
accordance with
CHATH-076
the Dam Safety
Certificate of
Law of 1967, 15A
Dam Safety
NCDEQ
CHATH-077
Approval to Modify
NCAS 02K.0201
CHATH-078
(b)(2); an
CHATH-079
application must
be filed with the
Division of Energy,
Mineral, and Land
Resources (DEMLR)
DOT - General
Not Anticipated
Driveway Permit
NCDOT
Not Anticipated

Wood Environment & Infrastructure Solutions, Inc. wood
Duke Energy Coal Combustion Residuals Management Program
Cape Fear Station Basin Closure Plan
No land
disturbance
activities outside of
the ash basin are
NCDEQ and
anticipated. In
Erosion and Sediment
Chatham
Not Anticipated
conformance with
Control (E&SC)
County
15A NCAC 04, no
E&SC Permit is
anticipated to be
required from Land
Quality.
Removal from or
import of material
could be restricted
dependent on the
Fire Ants
Restriction not likely
potential for fire
ants and
geographic regions
involved
No development
activities are
anticipated within
FEMA mapped
Floodplain
Chatham
Not Anticipated
Special Flood
Development
County
Hazard Areas for
the Flood
Insurance Rate
Maps
Multi -State
Not Anticipated
Agreement
NPDES (National
Pollution Discharge
NCDEQ
NC0003433
Not Anticipated
Elimination System)

Wood Environment & Infrastructure Solutions, Inc. wood
Duke Energy Coal Combustion Residuals Management Program
Cape Fear Station Basin Closure Plan
Removal from or
import of
vegetated material
could be restricted
Noxious Weeds
Not Anticipated
dependent on the
vegetation and
geographic regions
involved
Construction
activities adjacent
Railroad Easement,
to tracks/ballast or
Access, or Crossing
Not Anticipated
a new railroad
Permit
crossing require an
agreement or
permit
In accordance with
the federal Water
SPCC (Spill Prevention
Pollution Control
Control and
Act (Clean Water
NCDEQ
Not Anticipated
Countermeasure)
Act) of 1974, Title
Plan
40, Code of Federal
Regulations, Part
112.

Wood Environment & Infrastructure Solutions, Inc. wood
Duke Energy Coal Combustion Residuals Management Program
Cape Fear Station Basin Closure Plan
Federal and/or
state regulations
may apply
including agency
Threatened or
consultation and
Endangered Species:
performing site -
Candidate
specific surveys
Conservation
within the proper
Agreement Avian
survey period (e.g.,
Protection Plan(s)
NCDEQ And EPA
Not Anticipated
flowering period
Bird and Bat
for listed plant) to
Conservation
determine if
Strategies Eagle
Threatened or
Conservation Plan
Endangered
Eagle Take Permit
Species or their
habitat exist within
the limits of
disturbance
Solid Waste Site
No new CCR
NCDEQ
Not Anticipated
Suitability
Landfill planned
Solid Waste Permit to
No new CCR
NCDEQ
Not Anticipated
Construct
Landfill planned
Solid Waste Permit to
No new CCR
NCDEQ
Not Anticipated
Operate
Landfill planned
County Approval -
Chatham
No new CCR
Not Anticipated
zoning
County
Landfill planned

Wood Environment & Infrastructure Solutions, Inc. wood
Duke Energy Coal Combustion Residuals Management Program
Cape Fear Station Basin Closure Plan
FIGURES

101
..:sills;
low
rlk'-
`V
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Y
- . CHATH-075 APPROXIMATE
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FIGURE 1-2
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EXISTING MAJOR CONTOURS (D CP&L BORINGS - TYPE IV
\ \ ° \� \100YR FP
EXISTING MINOR CONTOURS CP&L PIEZOMETERS
WOOD LINE AMEC BORINGS
xxxxx—x—x— FENCE LINE GEOSYNTEC BORINGS
\sd b 0 0
i \\ \ // F, ///
o
— WATER SURFACE GEOSYNTEC CPTS & SCPTS
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UNPAVED PATH WITHERS & RA VENAL BORINGS
-�' I�
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APPROXIMATE LIMIT OF WASTEBASIN
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9 EXITING MONITORING WELL
CP&L BORINGS - TYPE 111
�
13
/ II
// J \ /// \�\ / / \
NOTES:
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/ 11
/ / 1 •\ // 11\ \ ( (�
1. WELL AND BORING IDENTIFICATION IS SHOWN ON CLOSURE PLAN DRAWINGS
IN APPENDIX D.
00, f
�� ` ' \I
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, ����H . _
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TITLE
COAL COMBUSTION RESIDUALS SURFACE
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IMPOUNDMENT CLOSURE PLAN
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CAPE FEAR STEAM STATION
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Environment &Infrastructure Solutions
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4021 STIRRUP CREEK DRIVE, SUITE 100
DURHAM NC27703 OVERALL EXISTING CONDITIONS PLAN
/ / \ / \ \ � I I11111111�I I�I\\\\
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TEL: [phone]
F�ICENSURE:901 FOR
NC EEG: URE:
ISSUED FOR REVIEW
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NC 3EOLOGY:C-247
SEAL SCALE: AS SHOWN DES: JL
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DUKE DWG TYPE: DWG DFTR VD
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JOB NO: 7810181088 CHKD: AP
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APPD:
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FILENAME: CFR_005C.DWG CRK
NOT FOR DWG SIZE DRAWING NO. REVISION
ONSTRUCTIO
ANSID 22"x34" FIGURE 1-2
REV DATE I JOB NO. PROJECT TYPE DES DFTR CHKD ENGR APPD
DESCRIPTION
TENTHS 10 20 30 4 5 6 7
8 9 10
INCHES 1 2 3