2020 Cliffside Excavation Plan_Draft_REV A_20200529

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May 29, 2020
VIA ELECTRONIC MAIL
Sheila C. Holman, Assistant Secretary
North Carolina Department of Environmental Quality (NCDEQ)
217 West Jones Street
1601 Mail Service Center
Raleigh, NC 27603
Dear Assistant Secretary Holman.
RE: (Draft) Coal Ash Excavation Plan
James E. Rogers Energy Complex (formerly Cliffside Steam Station)
S73 Duke Power Road
Mooresboro, North Carolina 28114
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References: NCDEQ Letter, "Coal Ash Impoundment Closure Plan — Determination of Compliance with General
Statute 130A309.214(a)(4) of Session Law 2026-95 of the Coal Ash Management Act — James E. Rogers
Energy Complex (Formerly Cliffside Steam Station)," dated April 29, 2020
Pursuant to NCDEQ's request in the above reference letter and subsequent email correspondence between Duke
Energy and NCDEQ Division of Waste Management (DWM), as well as being consistent with NCDEQ Guidelines,
please find the attached Draft Coal Ash Excavation Plan (Plan) for the lames E. Rogers Energy Complex.
As conveyed in the email correspondence with DWM, the draft Plan will be updated per the project scheduled and in
coordination with DWM. Also, as requested, an update to this Plan will be provided to DWM on an annual basis.
If you have any questions or need clarification regarding the information provided, feel free to contact Randy Hart at
rand .hart duke -ever .com or 980-373-5630 at your convenience.
Respectfully submitted,
OV1
George . Hamrick
Senior Vice President
W/attachments Coal Ash Excavation Plan James E. Rogers Energy Complex, Revision A, May 29, 2020
NCDEQ cc. Dam Saf n denr o de .coalash ncdenr. ov Ed Mussler, Rick Bolich, Toby Vinson,
George Eller
Duke Energy cc: ccyL%ords duke-ener-qr.com_ Paul Draovitch, Jim Wells, Ed Sullivan, Richard Baker, Dan
Mc Rainey, Jessica Bednarcik, Randy Hart, Diana Kooser

Coal Ash Excavation Plan
Rogers Energy Complex
/Cliffside Steam Station
Rutherford/Cleveland
County,
Mooresboro, NC
('DUKE
ENE RGY)
Draft Revision A
May 29, 2020
Cliffside Excavation Plan — Draft Page 1 of 12

Revision History
Revision
H
� Date of Revision
05/29/2020
Description Revision
Initial Draft
Cliffside Excavation Plan — Draft Page 2 of 12

Table of Contents
1.0
Purpose....................................................................................................................................4
2.0
Phased Excavation Plan...........................................................................................................4
3.0
Excavated CCR Transportation................................................................................................
7
4.0
Fugitive Dust Control..............................................................................................................10
5.0
Active Permits Associated with Excavation.............................................................................
11
6.0
Impounded CCR Stockpiles....................................................................................................12
7.0
Environmental Health and Safety Plan...................................................................................
12
Exhibits
Figure 1: Excavation Areas
Figure 2: Industrial Landfill (8106-INDUS-2009)
Figure 3: Existing Condition w/ Haul Roads
Figure 4: Haul Route Options Draft
Table 1: Excavation Areas by Year
Table 2: Active Permits
Cliffside Excavation Plan — Draft Page 3 of 12

1.0 Purpose
The purpose of this Excavation Plan (Plan) is to provide a vehicle for communication
and understanding of general activities associated with excavation efforts associated
with closure of the Duke Energy Rogers Energy Complex/Cliffside Steam Station
(Cliffside, Plant, Site) ash basins.
This Plan provides general information related to protection of public health, workers,
and the environment in addition to construction effort. Additional and/or more detailed
information is included in various permits, reports, Plans, contractor (TBD) safety plan,
and Duke Energy Safety Handbook and applicable supplemental.
Field conditions and documents could vary from this Plan's contents. Information in this
Plan is conceptual in nature and will be revised on an as -needed basis but not less than
annually.
2.0 Phased Excavation Plan
The Rogers Energy Complex/Cliffside Steam Station CCR conceptual excavation
phasing plan, illustrated in Table 1 and Figure 1, incorporates the following priorities:
• Excavation and clean closure of the Ash Storage Area 1 (ASA) for transmission
infrastructure relocation;
• Overburden removal from the unit 5 inactive basin to support excavation;
• Excavation and clean closure of the unit 5 inactive basin;
• Excavation and clean closure of the southern active basin to divert storm flows;
• Excavation and clean closure of the remaining active basin;
• Landfill phasing to optimize airspace.
The plan is for all excavated CCRs to be placed in the onsite lined Industrial Landfill
(8106-INDUS-2009). Ash excavated in 2020 and Q1 2021 will be place in the active
Phases I and II. Construction of Phase III is planned to be completed in Q1 2021 and
its use will be pending receipt of the Permit to Operate by March 31, 2021. Phase IV is
to follow completion of Phase III in Q2 of 2021. The Industrial Landfill is illustrated in
Figure 2.
Note: this is a conceptual plan that will be updated with additional input from the
excavation contractor (TBD).
Cliffside Excavation Plan — Draft Page 4 of 12

FVure 1: Excavation Areas I
Figure 1: Excavation Areas
Cliffside Excavation Plan — Draft Page 5 of 12

Table 1: Estimated Excavation Areas by Year (refer to Figure 1)
Volume
Figure 2: Industrial Landfill (8106-INDUS-2009)
Cliffside Excavation Plan — Draft Page 6 of 12

3.0 Excavated CCR Transportation
3.1 Off -Site hauling of excavated CCR
Hauling of excavated CCR will only occur on -site unless CCR is sent offsite for
approved beneficial reuse. Currently, there is no plan for off -site beneficial reuse
of excavated ash from Cliffside.
Hauling of wastes (e.g. vegetative material, etc.) impacted by CCR material may
be hauled to an off -site permitted disposal facility should the waste not be
permitted in the on -site landfill. Disposal facilities or transportation routes for
these materials have not been identified at this time.
3.2 On -Site hauling of excavated CCR
Excavated CCR will primarily be transported using off -road trucks to the on -site
landfill (8106-INDUS-2009) on existing and new haul roads located on -site, as
well as temporary haul roads located within the basin. The ASA, which
represents a small portion of the overall ash excavation, will utilize Duke Power
Rd to transport ash to the on -site landfill utilizing on -road trucks.
Existing and proposed future haul routes are shown on Figures 3 and 4 below.
Cliffside Excavation Plan — Draft Page 7 of 12

Fly Ash Silo Nk
*Bottom Ash Bunker{ . ', . N"
Gypsum Dewatering Bunker
CCP Haul Roads
Shared
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FWre 4: Haul Route Options Draft
Cliffside Excavation Plan — Draft Page 9 of 12

3.3 Spills and Incident Plan
The spills and incident plan for vehicles, trucks, and equipment used during
excavation will require that all spills be cleaned up as soon as practicable. Any spill,
regardless of size and/or reportability classification, will be reported to the Site CCP
Environmental Field Professional or their designee. Spill Prevention Control and
Countermeasure (SPCC) Plans for petroleum product storage and spills will be
developed, updated, and maintained for the excavation project. This plan will
include:
• Control measures such as the requirement for spill containments,
• Refueling and equipment inspection procedures,
• Location of spill response supplies,
• Training records, and
• Required inspection documentation.
4.0 Fugitive Dust Control
A Fugitive Dust Control Plan will be developed, updated, and maintained by the
contractor (TBD) to identify and describe dust control measures that will effectively
minimize material from becoming airborne at the facility, including soil and CCR fugitive
dust originating from CCR excavation areas, roads, landfills, and other CCR
management and material handling activities.
Fugitive Dust Control Measures
The following are fugitive dust suppression measures that will assist with effectively
minimizing material from becoming airborne at the facility. These techniques will be
used as needed and are not listed in order of importance or effectiveness:
1. Water — water supply and hoses, misters, foggers, cannons or tank trucks will be
made available during excavation, loading, conveyor transfer points, and
transportation and unloading of CCR and soil. The control efficiency for watering
depends on how fast the area dries after water is added. Frequent watering may
be necessary to maintain its effectiveness.
2. Polymer based dust suppressants — Polymer based dust suppressants may be
applied to exposed areas of CCR and soil material in lieu of frequent watering.
3. Reducing Fall Distances at Material Drop Points — where possible, fall distances
will be minimized to reduce the dusting potential from loading and unloading
operations.
4. Wind Barriers - may be erected in either a temporary or permanent configuration
to deflect prevailing winds over or around the operational area.
5. Compaction — moisture conditioning and compaction of CCR and soil material
Cliffside Excavation Plan — Draft Page 10 of 12

serves to limit irregular surfaces prone to dusting as well as consolidating loose
or fine particles into a more cohesive layer.
6. Vegetative Covers or Daily Covers — once excavation or material placement has
reached a final grade or will remain inactive for an extended period; the material
can be covered with a soil layer (CCR areas) and vegetated to remove the
exposure and dusting potential.
7. Establishing and Enforcing Speed Limits —Speed limits will be established on
unpaved, untreated roads to limit dust generation.
8. Restricted Operations — excavation activities are discouraged during high winds
or when other dust control techniques are ineffective. If necessary, reducing or
halting operations will occur temporarily.
5.0 Active Permits Associated with Excavation
Regulatory permits associated with CCR excavation at Rogers Energy Complex /
Cliffside Steam Station are summarized in Table 2. The actual current regulatory
document should be consulted for obligations and requirements related to
excavation.
In addition to the list below various permits will be needed as the project
progresses. The updated permit matrix will be included in future Excavation Plan
revisions.
Table 2: Active Permits
Regulatory
Identification
Issuance Date
Expiration Date
Document
Number or
Document
Reference
E&SC - Construction
RUTHE-2009-005
3/16/2009
SW Rule 5
Industrial Storm Water
NCS000571
10/1/2015
9/30/2020
NPDES — Waste Water
NC0005088
9/1/2018
8/31/2023
E&SC - Construction
CLEVE-2017-018
3/22/2017
SW Rule 5
E&SC - Construction
CLEVE-2013-025
6/27/2013
SW Rule 5
Rutherford Co
ZONE-11-19-2399
11/15/2019
Watershed Landfill
Permits
E&SC - Construction
CLEVE-2020-014
2/28/2020
SW Rule 5
E&SC - Construction
CLEVE-2020-016
3/31/2020
SW Rule 5
E&SC - Construction
CLEVE-2020-006
10/11/2019
SW Rule 5
CCP Landfill Permit to
8106-INDUS-2009
6/13/2016
9/7/2020
Operate Phases I and II
Cliffside Excavation Plan — Draft Page 11 of 12

CCP Landfill Permit to
8106-INDUS-2009
1/22/2020
Construct Phases III
and IV
Title V Air Permit
04044T43
1/8/2019
12/31/2023
Dam Safety
CLEVE-049
1972
CLEVE-050
1972
RUTH E-070
1972
RUTH E-072
1972
6.0 Impounded CCR Stockpiles
The excavation of dry ash may be temporarily stockpiled within the basin area at
manageable height and side slopes prior to transporting to the on -site landfill.
Typically, excavated ash that is acceptable to be placed in the on -site landfill will
be excavated and transported directly to the landfill.
The excavation of saturated ash will be stockpiled and/or wind -rowed to reduce
the moisture content in the basin area prior to transporting to the on -site landfill.
The stockpile will be of manageable height and side slopes.
Stockpiling plans will be developed, updated, and maintained for the excavation
project by the contractor (TBD). The plan will include locations of stockpiles within
the basin and engineering controls, as applicable.
7.0 Environmental Health and Safety Plan
The Company is committed to the health, safety, and welfare of employees, contractors,
and the public, and to protecting the environment and natural resources. The project
team will ensure that all work performed is compliant with corporate and site -specific
safety requirements. Duke Energy contractors (TBD) shall provide site specific
environmental, health, and safety plans as part of the submittal process for review and
approval by Duke Energy.
Excavation Planning and Permitting
Basin access and excavation activities are controlled by Procedure: CCP-PRC-NA-PMI-
021, CCR Excavation, Planning and Permitting, CCR Excavation within Basins,
Impoundments, Ponds or Stacks. This procedure governs ash excavation and
dewatering to ensure ash stability is evaluated and access is controlled to prevent
personnel from entering or creating unsafe conditions.
Cliffside Excavation Plan — Draft Page 12 of 12