NC0004961_Regional Office Historical File Pre 2018 (2)

4.,DUKE
ENERGY. James Weds
Vice President
Environmental,Health&Safety-
Coal Combustion Products
526 South Church Street
Mail Code EC12H
Charlotte,NC 28202
[phone]
January 26, 2017 RECEIVED/NCDENR/DWR
Corey Basinger ,JAN 2 7 2017
Mooresville Regional Supervisor
North Carolina Department of Environmental Quality w(]RG
Division of Water Resources MOORESVILLE REGIONAL OFFICE
Regional Water Quality Operations Section
601 East Center Avenue, Suite 301
Mooresville, NC 28115
Bob Sledge
North Carolina Department of Environmental Quality
Water Quality Permitting Program
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Report Under Special Order by Consent - SOC No. S16-005
Duke Energy Carolinas, LLC - Riverbend Steam Station
NPDES Permit NC0004961
Dear Mr. Basinger and Mr. Sledge:
On behalf of Duke Energy Carolinas, LLC ("DEC"), I am submitting to you the Riverbend Steam
Station Progress Report summarizing the work and activities undertaken with respect to closure
of coal ash surface impoundments as required by the Riverbend Steam Station NPDES Permit
NC0004961 Special Order by Consent ("SOC"), SOC No. S16-005 Section 2. d.
Please direct any questions concerning the Riverbend Steam Station NPDES Permit
NC0004961 SOC No. S16-005 to Brad Loveland at [phone].
Sincerely,
//
1IIT\ UU�
Jam Wells
Vice President, Environment, Health & Safety-
Coal Combustion Products
Duke Energy
CC: Richard Baker, Duke Energy
Brad Loveland, Duke Energy
Rick Massey, Duke Energy

NPDES PERMIT NC0004961
SPECIAL ORDER BY CONSENT EMC SOC WO S16-005
QUARTERLY EXCAVATION PROGRESS REPORT
RIVERBEND STEAM STATION
JANUARY 26, 2017

Riverbend Special Order by Consent
Quarterly Closure Progress Report
January 26,2016
I. Background and Summary
On November 10, 2016, Duke Energy Carolinas, LLC ("DEC") and the North Carolina
Environmental Management Commission entered into the Special Order by Consent as part of
the North Carolina NPDES Permit NC0004961 —EMC SOC WQ S 16-005 ("SOC"). This report
is submitted in accordance with paragraph 2. d of the SOC. In compliance with paragraph 2. d.
this report summarizes the work and activities undertaken with respect to closure of coal ash
surface impoundments at the Riverbend Steam Station. In an effort to provide context, the first
report will provide summaries from the past six months. The quarterly reports are due no later
than the last day of January, April, July, and October for the duration of the SOC.
A. Riverbend Steam Station Closure Summary
Riverbend is located off of Horseshoe Bend Beach Road near the town of Mt. Holly in
Gaston County, North Carolina, on the south bank of the Catawba River. The site contains two
ash basins, as well as the Dry Ash Stack and the Cinder Pit. As of April 2013, all of the coal-
fired units were retired. As of January 13, 2017, the Primary Ash Basin contains approximately
2,600,000 tons of ash that remains from the original inventory and the Secondary Ash Basin
contains approximately one million tons.
The North Carolina Coal Ash Management Act of 2014 ("CAMA") state law requires that
ash from the Riverbend Plant's ash basins be excavated and relocated to a lined facility with the
ash basins closed by August 1, 2019. As of January 13, 2017, the Riverbend site had completed
Phase I and has transported 1,600,032 tons of ash from the station,representing 30% of the total.
A total of 1,450,735 tons of ash was excavated from the Riverbend site in 2016. Ash was
primarily excavated from the Ash Stack, but initial excavation work in the Primary Ash Basin
began on September 9, 2016. Rail yard and rail load-out area improvements were also
completed in 2016 to allow transportation of ash by rail to the Brickhaven Structural Fill site.
On July 11, 2016, Duke Energy received approval of the Intermediate Dam Decommissioning
Plan from the North Carolina Department of Environmental Quality("NCDEQ"). The
decommissioning of the intermediate dam will take place in 2017 and excavation of the Ash
Stack and Ash Basins will continue, as well as continued transportation by rail.
Bulk dewatering of the Secondary Ash Basin began in January 2016, but was halted in
response to the NCDEQ letter dated July 20, 2016 adding additional requirements to its
December 17, 2015 "Decanting of Coal Ash Impoundments to Mitigate Seepage" letter. A
Waste Water Treatment facility was completed to satisfy these requirements and Duke Energy
submitted an application to modify its NPDES Wastewater Permit to include controls to be
implemented during dewatering activities. The modified permit became effective on December
1, 2016 and dewatering of the Secondary Ash Basin resumed under the permission of NCDEQ
2

Riverbend Special Order by Consent
Quarterly Closure Progress Report
January 26,2016
and the current NPDES permit. In 2017, bulk dewatering at Riverbend will be completed and
treatment/discharge of interstitial water will begin.
Within the current reporting period, there have not been any critical milestone activities
reached. The Riverbend site is on track to comply with the CAMA deadline of complete
excavation of the ash basins by August 1, 2019, with an expected completion date of March 3,
2019.
Ash Transported Off Site in Thousands of Tons I July 2016 to January 2017
Riverbend
20
18 1,600
16 1,450
1,300
14
1,150
12
1000 3
C 70 850
I t It III. 1� � f I
550
I400
2f f. 1 250
100
'1\01\..ti�\111C1' 0 \ti10\�A \1°9\1 0 4\N'*c ' \"bO lo\'tip O\'Lti o\ ,, ,*\ l\10,\'Lh.,1\1'.,1 ,\ ,\�'1\"c) , ,\'��'.,\15)
■Plan .Actual
Ash Transported Off Site in Millions of Tons
Riverbend
6,000,000
5,000,000 --..__-.-.--
4,000,000 -
-
Q
5 3,000,000 ------ - -Plan
12 2,000,000 - Actual
1,000,000
05/01/15 05/01/16 05/01/17 05/01/18
3

Riverbend Special Order by Consent
Quarterly Closure Progress Report
Ianuary 26,2016
II. Conclusion
Duke Energy will continue to provide its Quarterly Closure Progress Reports for the duration
of the Riverbend SOC summarizing the work and activities undertaken with respect to closure of
coal ash surface impoundments at Riverbend Steam Station.
4

liN DUKE
ENERGY. James Wells
Vice President
Environmental,Health&Safety-
Coal Combustion Products
526 South Church Street
Mail Code EC12H
Charlotte,NC 28202
[phone]
January 26, 2017 RECEIVED/NCDENR/DWR
Corey Basinger JAN 2 7 2017
Mooresville Regional Supervisor
North Carolina Department of Environmental Quality WQROS
Division of Water Resources MOORESVILLE REGIONAL OFFICE
Regional Water Quality Operations Section
601 East Center Avenue, Suite 301
Mooresville, NC 28115
Bob Sledge
North Carolina Department of Environmental Quality
Water Quality Permitting Program
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Report Under Special Order by Consent - SOC No. S16-005
Duke Energy Carolinas, LLC - Riverbend Steam Station
NPDES Permit NC0004961
Dear Mr. Basinger and Mr. Sledge:
On behalf of Duke Energy Carolinas, LLC ("DEC"), I am submitting to you the Semi-Annual
Report on the Status of Implementation of the Duke Energy Environmental Management
System as required by the Riverbend Steam Station NPDES Permit NC0004961 Special Order
by Consent ("SOC"), SOC No. S16-005 Section 2. h.
Please direct any questions concerning the Riverbend Steam Station NPDES Permit
NC0004961 SOC No. S16-005 to Brad Loveland at [phone].
Sincerely,attA
James Wells
Vice President, Environment, Health & Safety-
Coal Combustion Products
Duke Energy
CC: Richard Baker, Duke Energy
Brad Loveland, Duke Energy
Rick Massey, Duke Energy

NPDES PERMIT NC0004961
SPECIAL ORDER BY CONSENT EMC SOC WO S16-005
SEMI-ANNUAL REPORT OF ENVIRONMENTAL MANAGEMENT SYSTEM STATUS
JANUARY 26, 2017
RECEIVED/NCDENR/DWI
WQROS
MOORESVILLE REGIONAL OFFICE

Riverbend Special Order by Consent
Semi-Annual Status Report
January 26,2016
I. Background and Summary
On November 10, 2016, Duke Energy Carolinas, LLC ("DEC") and the North Carolina
Environmental Management Commission entered into the Special Order by Consent as part of
the North Carolina NPDES Permit NC0004961 —EMC SOC WQ S 16-005 ("SOC"). This report
is submitted in accordance with paragraph 2. h of the SOC. In compliance with paragraph 2. h,
DEC shall submit semi-annual reports due July 31St and January 31st of each year covering the
preceding first and second halves on the status of implementation of improvements to its
environmental management system. Unless otherwise stated, this report contains information for
the period of July 1, 2016 to December 31, 2016.
II. Environmental Management System Status Update
Duke Energy is in the process of revising its environmental management system that was in
place prior to this time. The re-designed system is based on the International Organization for
Standardization ("ISO") 14000 standards. Although the SOC only references an environmental
management system, Duke Energy has chosen to develop and implement an Environmental
Health and Safety ("EHS") Management System("EHSMS") designed to continually improve
EHS risk management, prevent and detect non-compliance, reduce adverse effects to the
environment, and enhance the company's reputation. The EHSMS Manual, issued in August
2016, is attached for your review. The EHSMS Manual describes our EHSMS and serves as a
reference guide for how EHS risks and obligations are managed across the company, sets
expectations, and defines the EHS management roles and responsibilities for various key
departments and positions. It has both a statement of general expectation and guidance on
implementation and captures both current state activities as well as aspirations for the future.
The model is based on the "plan-do-check-act" system and is divided into six core elements
explained in more detail below.
♦ LEADERSHIP •
-
Planning
Improvement vps Operation
`Adjust) " (Do)
*Cr
Monitoring(Check)
t SUPPORT t
2

Riverbend Special Order by Consent
Semi-Annual Status Report
January 26,2016
• Element 1- Leadership: It starts with the Duke Energy Environmental Policy
and Health and Safety(H&S) Policy which describes the company's vision
and expectations
• Element 2—Planning: It requires critical planning processes to ensure
we have a comprehensive understanding of applicable legal requirements and EHS risks
that need to be adequately controlled
• Element 3 —Operation: Operational processes are implemented to ensure ongoing
compliance with the legal requirements and effective management of risks
• Element 4—Monitoring: Monitor our operational processes and resulting performance
• Element 5 —Improvement: Take corrective actions to drive continual improvement
• Element 6—Support: Adequate human and financial resources, including qualified and
competent staff with clearly defined responsibilities, as well as internal and external
communication processes and appropriate documentation and record keeping
In parallel with launching the revised EHSMS, Duke Energy has initiated 18 projects to help
close current gaps. These projects are short-term efforts to strengthen our practices and set the
EHSMS up for long-term, sustainable success and are listed below.
• Policy Roll-out and Commitment Management
• Environmental Compliance Registers
• Environmental Awards
• Contractor EHS Management
• EHS Responsibilities and Leading Indicators
• EHS Risk Procedure and Management
• Health and Safety Regulatory Review
• Embed EHS in Skills Training
• EHS Critical Equipment
• Management of Change
• Organizational Learning
• Document Management Framework
• Corrective Action Management
• Leveraging Inspections
• Health and Safety Obligations Register
3

Riverbend Special Order by Consent
Semi-Annual Status Report
January 26,2016
EHS is also working on the campaign to communicate the new EHSMS across all business
units. The campaign will kick off in February 2017 focusing on deployment of the new
Management System to EHS personnel. The campaign will shift focus, later in 2017, to the
business units. The overall intent of the campaign is to:
• Communicate the EHSMS and its purpose
• Tie the management system to the Operational Excellence initiative
• Educate and make connections so that employees can understand how their role impacts
EHS compliance, protecting people and the environment.
As the EHSMS is communicated, there will be engagement among the Change Management
groups within the business units to ensure the message is clear, specific to the EHS risks and
challenges of that business unit, and that the communications are not competing with other
initiatives/priorities.
Additional accomplishments from July 1, 2016 to December 31, 2016 are highlighted below.
A. Contractor EHS Management
An adjusted project scope has evolved from managing contractor environmental obligations
through supplemental contract language to creation of an Environmental Handbook that outlines
consistent expectations to employees and contractors (that could become a contractual
expectation). The handbook will be prepared in 2017.
B. EHS Risk Program
Duke Energy developed the EHS Risk Program document which establishes the general work
processes used by the Duke Energy EHS organization to identify, evaluate and work with
affected business units to address environmental, health and safety risks throughout the
corporation. Training was provided on the Risk Program to EHS leadership team and staff, and
tools were deployed for use.
C. Environmental Compliance Registers
• Duke Energy completed and implemented registers and compliance tasks for 22 coal sites
and pilot sites for 5 additional business units (Nuclear, Gas Operations, Solar, Hydro and
Transmission/Distribution).
• Compliance registers and tasks were implemented and completed for 22 hydro sites
4

Riverbend Special Order by Consent
Semi-Annual Status Report
January 26,2016
• Compliance tasks were completed for 30 combined cycle/simple cycle combustion
turbine facilities (task implementation to be completed in 1st quarter 2017).
D. Corrective Action Management
A new EHS Corrective Action Procedure was drafted for use by EHS personnel. This
procedure will outline the procedures to be utilized to assign, document and track corrective
actions associated with EHS incidents.
E. Document Management Framework
• Completed migration of EHS governance documents to final document management
system (Fusion)
• Continued migration of EHS records to final record retention system(FileNet).
III. Conclusion
As the communication campaign begins and additional work on the 18 projects is conducted
Duke Energy will continue to provide its Semi-Annual EHSMS Status Report for the duration of
the Riverbend SOC in January and July of each year.
5

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.
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--lc.'c fai DUKE
EMERY
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ENVIRONMENTAL HEALTH AND
iltt SAFETY MANAGEMENT
kSYSTEM MANUAL
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31.1
4 August 2016
CeEHS Management System
Plan. Do.Check.Adjust

TABLE OF CONTENTS
I INTRODUCTION 1
II ENVIRONMENTAL POLICY 3
III HEALTH AND SAFETY POLICY 4
IV EHS MANAGEMENT ROLES AND RESPONSIBILITIES 5
V EHSMS FRAMEWORK AND IMPLEMENTATION APPROACH 10
ELEMENT 1 — LEADERSHIP 10
1a — Leadership and Commitment
1 b— EHS Policies
1c — Roles, Responsibilities, Accountabilities, and Authorities
ELEMENT 2 — PLANNING 16
2a — EHS Aspects/Hazards and Risk Assessment
2b — Compliance Obligations
2c — EHS Objectives and Plans
ELEMENT 3 — OPERATIONS 20
3a — Operating Procedures
3b — Mechanical Integrity
3c — Management of Change
3d — Emergency Preparedness and Response
3e — Contractors
ELEMENT 4— MONITORING 27
4a — Performance Monitoring
4b — Inspections and Audits
ELEMENT 5 — IMPROVEMENT 30
5a — Corrective Action
5b— Organizational Learning
5c — Management Review
ELEMENT 6 —SUPPORT 34
6a — Resources
6b— Competency
6c — Communications and Engagement
6d — Documentation and Recordkeeping
APPENDIX I —ACRONYMS AND DEFINITIONS 39
APPPENDIX II — MAPPING TO INTERNATIONAL STANDARDS 42

August 2016 Duke Energy EHSMS Manual
I. INTRODUCTION
Duke Energy has implemented an Environmental, Health, and Safety (EHS) Management System
(EHSMS) to ensure the consistency and effectiveness of its EHS management activities, including
continually improving EHS risk management, preventing and detecting non-compliances, reducing
adverse impacts to the environment, and enhancing the company's reputation with external
stakeholders. The EHSMS is designed to be consistent with relevant international standards (e.g.,
International Organization for Standardization [ISO] 14001:2015 and American National Standards
Institute [ANSI] Z10), agency guidelines (e.g., Occupational Safety and Health Administration [OSHA],
Environmental Protection Agency [EPA], and Department of Justice [DOJ]), and industry standards, but
has been customized to apply to Duke Energy's unique operating environment, risk profile, and culture.
The elements of the Duke Energy EHSMS are illustrated below:
+ - LEADERSHIP i
Planning(Plan)
Improvement do g Operation
(Adjust) (Do)
1111
Monitoring(Check)
t SUPPORT - t
The model is based on a simple `plan-do-check-act' system. It starts with the Duke Energy
Environmental Policy and Health and Safety (H&S) Policy which describes the company's vision and
expectations, with visible support from leadership (Element 1). The EHSMS requires critical planning
processes that ensure we have a comprehensive understanding of applicable legal requirements and
EHS risks that need to be adequately controlled (Element 2: Planning). Operational processes are
then implemented to ensure ongoing compliance with the legal requirements and effective
management of risks (Element 3: Operation). We monitor our operational processes and resulting
performance (Element 4: Monitoring) and take corrective actions to drive continual improvement
(Element 5: Improvement). The process is supported by adequate human and financial resources,
including qualified and competent staff with clearly defined responsibilities, as well as internal and
external communication processes and appropriate documentation and record keeping (Element 6:
Support).
Page 1 of 46

August 2016 Duke Energy EHSMS Manual
These six elements break down into 20 sub-elements as illustrated below:
......... .. .... LEADERSHIP + A
•Corrective Action •Leadership and Commitment
•Organrational Learning •ENS Policies
•Management Review Planning(Plan) •Roles.Responsibilities.
Accountabdrbes and Authorities
•
•Performance Monitonng "
•Inspections and Audits -EHS ;Haza
Improvement � � Operation
Risk AssessmentAspects rds and
(Adjust) (Do) -Compliance Obligations
•EHS Obtectrves and Plans
•
•Resources •Operating Procedures
•Competency •Mechanical Integrity
•Communications and Engagement Monitoring(Check) •Management of Change
•Documentation and Record Keeping •Emergency Preparedness and Response
♦ SUPPORT •Contractors
This document is designed to provide an overview of Duke Energy's EHSMS and serves as a
reference guide for how EHS risks and obligations are managed across the company. Note: the
EHSMS covers all of Duke Energy's US-based operations; Duke Energy International is not subject to
the requirements of this EHSMS.
EHS management expectations and commitments are set at the highest level via the Duke Energy
Environmental Policy and H&S Policy. Key elements of both policies are included within this EHSMS
Manual, and the full policies are available on our Portal and Internet website. These policies, and this
EHSMS Manual, cover all of Duke Energy's global activities, including the work of corporate
departments and business unit operations.
Implementation of the Duke Energy EHSMS affects everyone inside our company. This EHSMS
Manual serves to define the EHS management roles and responsibilities for various key departments
and positions. The management of EHS risks and requirements requires contributions from all
departments and all organizational levels, including our employees and the contractors working on
behalf of the company. Line management and supervisors have a particularly critical role, as they are
often on the front line where the risks and regulatory requirements apply and need to be managed. The
subject matter experts within Corporate EHS are also critical to our success; however, ultimately,
accountability for EHS performance rests with each employee.
This manual establishes the minimum requirements (i.e., expectations) for each of the six elements
and 20 sub-elements of the EHSMS framework. It also describes our approach to implementing the
requirements, referencing other processes and procedures where appropriate. Duke Energy
recognizes that there are currently gaps that must be addressed and are being managed through to
closure as part of the EHSMS implementation.
Page 2 of 46

August 2016 " Duke Energy EHSMS Manual
II. ENVIRONMENTAL POLICY
The foundation of the environmental side of our EHSMS is the Duke Energy Environmental Policy, as it
defines our overall vision and expectations regarding environmental management.
Statement of Purpose and Philosophy
At Duke Energy, we are committed to the highest levels of performance in environmental compliance, practices
and stewardship. Protecting and responsibly managing natural resources are essential to a cleaner environment,
the quality of life in the communities we serve, and Duke Energy's long-term business success.
This Environmental Policy establishes principles to fulfill this commitment. Through these, Duke Energy will:
Compliance Plus Comply with applicable laws, regulations, permit obligations and
company policies and procedures while also proactively
addressing risk and building margin into our planning and
operations.
Agility Be nimble as new risks and opportunities emerge. Act with a
sense of urgency while ensuring accuracy in all our responses.
Apply lessons learned effectively across the enterprise.
Accountability Set clear expectations, provide support and training and hold
employees accountable for understanding and incorporating their
environmental responsibilities into daily work activities.Actively
engage the management of our contractors to hold them
accountable for compliance with laws, regulations and applicable
company requirements.
Managing Impacts Work to prevent environmental incidents and be prepared to
respond effectively in the event that they occur. Use natural
resources efficiently to reduce consumption, waste, discharges
and emissions. Integrate environmental considerations into
planning, design, construction and operational decisions.
Continual Improvement Set challenging goals to attain industry-leading performance and
continually assess performance to improve environmental
management systems, processes and results. Collaborate across
the enterprise to proactively address environmental issues and
explore opportunities to prevent pollution while providing
affordable and reliable energy to our customers.
Stewardship and Transparency Support community efforts in environmental education, protection
and conservation. Engage in partnerships that address common
issues and promote sound public policy. Communicate
environmental challenges and performance to maintain the trust
and confidence of our stakeholders.
Page 3 of 46

August 2016 Duke Energy EHSMS Manual
III. HEALTH & SAFETY POLICY
The foundation of the health and safety (H&S) side of our EHSMS is the Duke Energy H&S Policy, as it
defines our overall vision and expectations regarding the protection of people.
Statement of Purpose and Philosophy
Duke Energy is committed to employee, contractor and public health and safety. Protecting our people is an
essential duty that enhances the quality of life for our workforce and contributes to Duke Energy's long-term
business success. Through each person's commitment, ownership and engagement, the company will strive to
achieve an injury and illness-free workplace.
The Health & Safety Policy establishes principles to fulfill this commitment. Through them, Duke Energy will:
Compliance Plus Comply with applicable laws and company policies and procedures while
also proactively addressing risk and building margin into our planning and
operations.
Agility Be nimble as new risks and opportunities emerge. Act with a sense of
urgency while ensuring accuracy in all our responses. Apply lessons
learned effectively across the enterprise.
Accountability Set clear expectations, provide support and training and hold employees
accountable for understanding and incorporating health and safety
responsibilities into daily work activities. Actively engage the management
of our contractors to hold them accountable for compliance with laws and
applicable company requirements.
Managing Impacts Provide a safe and healthy workplace and be prepared to respond
effectively in the event that incidents occur. Empower all employees to
actively identify hazards, prevent and correct unsafe conditions and
demonstrate safe behaviors at every level. Select, manage and partner with
contractors to improve health and safety performance.
Continual Improvement Set challenging goals to attain industry-leading performance and continually
assess performance to improve health and safety management systems,
processes and results. Recognize and reward safety excellence.
Stewardship and Transparency Develop and maintain effective public safety programs to educate and
inform the public in the communities in which we operate. Interact with key
stakeholders to develop responsible laws and regulations that enhance
health and safety in the workplace and communities.
Page 4 of 46

August 2016 Duke Energy EHSMS Manual
IV. EHS ROLES AND RESPONSIBILITIES
Effective implementation of the Duke Energy Environmental Policy, H&S Policy, and this EHSMS
Manual depends on employees across organizational levels and departments taking responsibility for
various tasks. Specific roles and responsibilities for various key departments and positions are listed
below.
Chief Executive Officer
• Provides strategic direction for the overall management of EHS issues company-wide
• Provides visible leadership striving for a strong compliance-plus and incident-free culture
• Periodically reviews EHS programs and performance for appropriateness and fit with the
company's needs
• Holds senior leaders accountable for their implementation of the Environmental Policy, H&S Policy,
and the underlying EHS management system as described in this Manual, as well as for resulting
performance
Senior Leadership [Senior Management Committee/Executive Leadership Team
• Provides visible leadership and strategic direction for the EHS management system and programs
in their area of responsibility, helping to build and maintain a strong EHS culture and drive EHS
performance improvement
• Allocates adequate resources to enable implementation of EHS programs consistent with corporate
and business unit (BU) policies and standards
• Holds leaders accountable for their implementation of the EHS programs and resulting EHS
performance
Executive Environmental Governance Board (EEGB) and Health & Safety Performance Council
(HSPC)
• Reviews and approves company-wide EHS policies and standards and specific EHS initiatives to
drive performance improvement and risk management
• Guides and informs senior leadership's strategic decisions that involve potentially significant EHS
risk or opportunity
• Debates advocacy positions on current and emerging EHS issues
• Reviews and interprets company-wide EHS performance, including audit results, risk assessments,
and risk management/mitigation efforts, and guides continual improvement
• Conducts an annual management review of the company's overall EHS management system and
its underlying programs
Business Unit Management
• Is directly accountable for EHS performance at their operation/location
• Provides visible leadership towards achieving a strong compliance-plus and incident-free culture
Page 5 of 46

August 2016 Duke Energy EHSMS Manual
• Allocates resources to enable implementation of site EHS programs consistent with corporate and
BU policies and standards
• Holds subordinate managers accountable for the implementation of the EHS programs and
resulting EHS performance and ensures that EHS hazards/risks are accounted for in the planning
of work and that controls are fully implemented
• Leads site EHS management review meetings and drives continual improvement in EHS programs
and performance
• Participates in investigations of significant incidents within the scope of their management
responsibility
• Raises EHS issues or concerns to senior leaders where warranted
• Ensures operational changes and onsite contractor work are subject to appropriate EHS risk review
and oversight
• Acts as a company ambassador to local community stakeholders
Front-line Supervisor
• Provides visible leadership toward achieving a strong compliance-plus and incident-free culture;
monitors EHS behaviors and conditions and takes corrective actions as needed
• Participates in investigations of incidents within the scope of their supervisory responsibility
• Participates in routine inspections and helps promote/maintain good housekeeping
• Ensures team members understand their EHS roles and responsibilities and obtain/maintain the
required competencies to carry them out
• Raises issues or concerns to appropriate management where warranted
• Ensures EHS work management tasks are completed on time
Corporate EHS
• Chairs the Environmental Governance Board (EEGB) and Health & Safety Performance Council
(HSPC)
• Provides functional oversight and leadership to the company-wide EHS management system and
its underlying programs
• Develops and proposes EHS policies and standards for review and approval by the EEGB and
HSPC; assists individual BUs with business-specific EHS procedures/programs
• Develops and implements programs and initiatives to drive continual improvement in EHS
performance and risk management
• Maintains an understanding of the material federal and state EHS laws and regulations that apply
to the company's operations
• In collaboration with the BUs and Corporate Legal, tracks potential changes to federal and state
laws and regulations, assesses the impact of potential changes to these laws and regulations to the
company, and develops and implements a strategic approach to influencing public policy and
legislation where business impacts could be material
Page 6 of 46

2016 August 9 ' Duke Energy EHSMS Manual
• In collaboration with Corporate Legal, provides technical input to respond to third-party claims and
non-compliance negotiations with regulators
• Works with business leaders to clearly define EHS management roles and responsibilities across
organizational levels and departments and hold responsible individuals accountable for carrying
them out
• Facilitates the development and endorsement of corporate EHS metrics to track performance,
compiles metrics data, and publishes routine internal performance reports
• Reviews internal performance trends (e.g., audit results and incidents), benchmarks EHS programs
and performance against peers, facilitates sharing of lessons learned and best practices within and
across businesses, supports training programs at the corporate level, and, as appropriate,
endorses business strategies that will enable BUs to improve performance
Environmental Energy and Policy/Sustainability
• Provides leadership and direction in the development of environmental and energy policy for Duke
Energy, as well as in the development of the company's sustainability strategy
• Identifies and analyzes regulations and legislation that may significantly impact the corporation and,
in coordination with multiple departments across the enterprise, develops and executes strategic
action plans to effectively manage these issues and advocate for the corporation's position
• Communicates Duke Energy's sustainability progress and challenges to key internal and external
stakeholders and serves as the official source for audit-quality non-financial company data
• Builds and nurtures relationships with external stakeholders (including social responsible investor
community, key non-governmental organizations, academia, community, and customers) through
proactive engagement and dialogue
• Engages, motivates, and develops employees to promote sustainability initiatives that result in
innovative ideas, operational efficiencies, cost savings and a reduced environmental footprint
Internal Audit
• Maintains an audit program to independently review conformance with the established EHS
management system and its underlying programs
Corporate Legal
• Maintains an understanding of the material federal and state environmental laws and regulations
that apply to the company
• Tracks potential changes to federal, state, and local laws and regulations and coordinates with
Corporate EHS and the businesses in developing a strategic approach to influencing public policy
where business impacts could be material
• Represents the company's strategic response to third-party claims and non-compliance
negotiations with regulators in coordination with the relevant business area, Corporate EHS, and
others, as appropriate
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August 2016 Duke Energy EHSMS Manual
• Advises on the establishment and enforcement of contracts that address potential EHS liability and
responsibility for contractors on a risk basis [shared responsibility with Supply Chain/Procurement
and relevant business areas]
• Provides appropriate internal and external legal resources in defending corporate and BUs in
matters related to EHS litigation, as well as stakeholder negotiation of legal matters that affect
existing assets, mergers and acquisitions, divestitures, new asset development, and construction
Ethics and Compliance
• Maintains an ethics and compliance program to foster a culture of ethical behavior and compliance
with law, and to prevent, detect, and respond to potential violations of laws and regulations that
apply to Duke Energy's operations
• Provides a compliance program framework and standards which establish a comprehensive
approach for defining accountabilities and core program elements
Human Resources
• Supports individual business areas and departments in ensuring EHS roles and responsibilities are
clearly defined and understood across organizational levels and departments
• Supports individual business areas and departments in ensuring responsible individuals are held
accountable for carrying out their assigned responsibilities
• In collaboration with Corporate EHS, supports individual business areas and departments in
ensuring appropriate EHS awareness, education, and training is provided to all relevant segments
of the work force, including at hiring, promotion, job transfer, and operating process changes
• Helps ensure that any person performing actions on behalf of individual business areas and
departments that can impact EHS performance is competent on the basis of appropriate
awareness, education, training, or experience
Finance
• Works with Corporate EHS to determine required financial disclosures and reserves
• Ensures integration of EHS issues into the Enterprise Risk Management process
• Procures appropriate insurance for EHS claims and incidents
Supply Chain/Procurement
• Incorporates EHS performance, programs and requirements into the strategic sourcing process,
including the procurement of materials and equipment and the selection and management of
contractors and suppliers [shared responsibility with the BUs and other internal customers]
Corporate Communications
• Coordinates with the business area(s) concerned and Corporate EHS to respond appropriately to
inquiries and complaints from interested external parties, including ensuring approvals are secured
before communicating with external stakeholders or publishing EHS information externally
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9 Duke Energy EHSMS Manual
• Coordinates with the business area(s) concerned and Corporate EHS to respond appropriately to
emergency situations, ensuring external stakeholders are appropriately briefed
• Provides information on EHS programs, performance, and issues to internal audiences to help
maintain a high level of employee awareness [shared responsibility with the BUs and Corporate
EHS]
• Participates in developing and approving the EHS content of corporate reports [shared
responsibility with the BUs and Corporate EHS]
Contractors
• Become familiar with the Environmental Policy and H&S Policy, specific BU EHS requirements,
EHS aspects/hazards and compliance obligations that apply to their work and associated
operational controls to manage compliance and risk
• Provide staff who are competent to carry out all assigned roles and meet all job-specific EHS
requirements
• Adhere to the principles of the Duke Energy Environmental Policy and H&S Policy and contract-
specific requirements
• Proactively manage EHS issues that may arise and report them to the Duke Energy business
partner or through Duke's existing Environmental Hotline or Ethics Hotline as appropriate
All Employees
• Become familiar with the Environmental Policy and H&S Policy, specific BU EHS requirements,
EHS aspects/hazards, and compliance obligations that apply to their job responsibilities and job
site, including operational controls to manage compliance and risk
• Seek information from leadership, as needed, to assure clarity in roles and expectations related to
EHS matters and become competent to carry out all assigned roles and meet all job-specific EHS
requirements
• Adhere to the principles of the Environmental Policy and H&S Policy and specific BU requirements,
and follow appropriate procedures to comply with applicable compliance obligations and effectively
manage risk
• Proactively identify opportunities to improve EHS programs and performance and share them with
responsible management
• Report any EHS issues or concerns according to company processes, including through the
Environmental Hotline or Ethics Hotline, which are accessible 24 hours a day, every day of the year
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August 2016 1 Duke Energy EHSMS Manual
V. EHSMS FRAMEWORK AND IMPLEMENTATION APPROACH
The minimum requirements (i.e., expectations) of Duke Energy's EHSMS, and the approach used by
Duke Energy to implement those requirements, are described below.
Element 1 — Leadership
The Leadership element of the Duke EHSMS includes three sub-elements:
• la. Leadership and Commitment
• lb. EHS Policies
• lc. Roles, Responsibilities, Accountabilities, and Authorities
1a. Leadership and Commitment
Management visibly demonstrates its leadership and commitment to minimizing adverse EHS impacts
and implementing the corporate EHS policies and standards, helping to build/reinforce a strong and
proactive culture of EHS responsibility and drive effective program implementation.
• ,Expectation . a iiplementatic n Approach and Gu'do nr ;° p
1. Management visibly demonstrates • Management, from executive management to front-line
the importance of EHS supervisors, takes actions to visibly demonstrate their support of
management by being actively the principles in the Environmental and H&S Policies.
involved in EHS program • Examples include:
implementation and modeling safe
behaviors in day-to-day activities — Participating, as appropriate, in the Duke Energy EEGB and
and during visits to field HSPC;
operations.
— Participating, as appropriate, in the BU-, regional-, and
location-specific environmental and H&S councils, Event Free
committees, and other steering committees;
— Including EHS topics as standard agenda items at routine
operational review meetings (e.g., executive review meetings,
department meetings, plant/facility manager meetings, daily
production meetings, shift change meetings, etc.);
— Setting goals to improve EHS programs and performance and
holding lower levels of line management accountable for the
implementation of associated action plans and resulting
outcomes;
— Establishing and reviewing EHS metrics on a routine basis,
and including EHS metrics in business planning meetings;
— Participating in the development and implementation of EHS-
related programs and initiatives, as appropriate (e.g., kicking
off training sessions);
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r
August 2016 '� Duke Energy EHSMS Manual
F to ctat ri*leinentation Approacli'and`3uidan`
— Leading corporate, regional, BU, and site-level management
reviews (see Sub-element 5c);
— Participating in site inspections and audits (see Sub-element
4b), and discussing EHS issues during visits to field
operations;
— Reviewing and commenting on EHS audit reports and
tracking closure of key corrective actions;
— Receiving and reviewing incident reports and associated
investigation reports, as well as facilitating the implementation
of action plans to prevent recurrence; and
— Supporting employees to join the `Sustainability Corps', which
is a program for employees who have a desire to be good
stewards of the environment and care about the company's
long-term success.
2. Award and recognition processes • EHS performance is included in incentive compensation
reinforce EHS expectations and programs.
culture. Poor EHS performance is
subject to disciplinary action. • The Duke Energy Exceptional Contribution Award is available for
management and employees to recognize exceptional EHS
performance or actions.
• The James B. Duke awards are also used to recognize EHS
leadership.
• These corporate-driven award and recognition programs are
supplemented by a variety of BU-, region-, and location-specific
awards recognizing environmental and H&S achievements.
• Recognition for EHS initiatives and performance is discussed as
part of the performance evaluation process.
• Poor EHS performance is subject to disciplinary action, up to and
including termination, in accordance with Corrective Action
Policy.
• The Contractor EHS Management program includes an element
of contractor recognition.
lb. EHS Policies
EHS management expectations are clearly defined in company policies and standards and effectively
guide day-to-day operations, behaviors, planning, and decision-making.
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August 2016 Duke Energy EHSMS Manual
Expectation s Implementation Approach and Guidance:
J.'444Snda:
1. The Duke Energy Environmental • The Duke Energy Environmental Policy and H&S Policy are
Policy and H&S Policy are broadly issued and communicated to employees using a variety of
distributed and the expectations approaches:
contained in each are
communicated to employees and — Policies are communicated broadly across the organization
others working on behalf of Duke and are readily available on the Duke Energy EHS portal; and
Energy. — Policies are incorporated into new hire orientation/onboarding
(see Sub-element 6b).
• The existence and importance of Duke Energy's Environmental
Policy and H&S Policy are communicated to contractors through
the contracting process. Where practical, the essence of the
policies is reinforced in pre-job briefings. (More detail on
contractor management is found in Sub-element 3e.)
• The principles of the policies are reinforced in the course of day-
to-day actions and decision-making. Employees and other
working on Duke Energy's behalf are made aware of the
company's compliance-plus commitment, focus on risk
management, and drive towards continual improvement.
2. The Duke Energy Environmental • The Environmental Policy and H&S Policy, as well as the
Policy and H&S Policy are made EHSMS Framework, are posted on the Duke Energy internet
available to external stakeholders. site.
• Both policies are also made available to external stakeholders
upon request.
3. The Duke Energy Environmental • The policies are not expected to change often, as they establish
Policy and H&S Policy are the overall vision upon which the company's EHS programs and
reviewed on a periodic basis to decision-making are based.
ensure their ongoing • The Environmental and H&S Policies are reviewed duringeach
appropriateness and fit, and are
updated as needed. annual corporate-level management review[see Sub-element
5c].
• Changes to the policies will be subject to the change
management process and are communicated to employees and
others working on behalf of Duke Energy via targeted
communication plans. Updated versions of the policies are made
available as described in 1 b.1 and 1 b.2 above.
4. Additional EHS policies, standards, • Duke Energy has developed tools to implement and support the
procedures and guidance principles of the Environmental Policy and the H&S Policy. These
documents are developed at the tools include:
corporate, business unit, regional,
and site levels to elaborate on and — Corporate Environmental Compliance Manual: a series of
support implementation of the programs and procedures defining environmental
Duke Energy Environmental Policy requirements and implementation actions, such as regulatory
and H&S Policy. review, permit review, EHS assessments, release reporting,
etc.;
— Corporate H&S Compliance Manual: a series of programs and
procedures defining EHS requirements and implementation
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August 2016 Duke Energy EHSMS Manual
mplementation Approach and Gt dand�
actions, such as transportation safety, contractor EHS
management, etc.;
— Operating Models: these define BU/organization structure,
scope of roles and responsibilities, how responsibilities are
met, etc., for key corporate and BU functions, including an
EHS Operating Model; and
— Duke Energy Corporate performance evaluation processes
support the accountability and performance principles (see
lc.3 below).
• Additionally, BU-, regional-, and facility-level procedures and
other governing documents are developed and implemented to
support personnel in meeting corporate Duke Energy standards,
providing tools to assist with implementation, and fostering
communication. The exact form and extent of these
supplemental governing documents are at the discretion of the
BUs, adequate to guide and govern their operations consistent
with the Duke Energy Environmental and H&S Policies, with
enough flexibility to accommodate the business strategy.
• Training is also provided to support the implementation of the
Duke Energy Environmental and H&S Policies and the overall
EHS management system (see Sub-element 6b).
5. Responsible line management • Responsible line management, including Business Unit leaders,
personnel are involved in the Plant/Facility Managers, etc.:
implementation and oversight of
EHS policies, standards, and — Review EHS programs and procedures during their
procedures affecting their areas of development to ensure they are fit-for-purpose;
responsibility. — Provide visible leadership to facilitate the implementation of
the Environmental and H&S Policies and the underlying EHS
standards and procedures;
— Monitor implementation effectiveness through audits, self-
assessments, and management reviews;
— Drive corrective actions through to closure, as needed; and
— Monitor day-to day-operations and maintenance
activities/processes to ensure compliance.
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9 Duke Energy EHSMS Manual
1c. Roles, Responsibilities, Accountabilities, and Authorities
EHS responsibilities of employees and contractors are defined, documented, communicated, and
understood, and individuals are held accountable for effectively carrying out their roles.
pseud .p em eiatio 130rtiai
v„sdf,7 ttL,,i�an
1. EHS responsibilities for relevant • Section IV of this corporate EHSMS Manual defines, at a high
departments and positions are level, the key EHS-related responsibilities for relevant
clearly defined, documented, and departments and functions.
communicated.
• Job descriptions define EHS responsibilities for both
environmental/H&S professionals and specialists, as well as for
key operational positions including line management and others
that can impact EHS performance.
• Various supplemental tools are used to define and document
EHS roles and responsibilities, including:
— Facility/Business Unit Interface Agreements;
— Environmental and Health &Safety Operating Models;
— Business Unit Operating Models;
— Responsible/Accountable/Consulted/Informed charts (which
may be topic-, requirement-or project-specific);
— Operating/implementing procedures (e.g., Corporate
Environmental Compliance Manual procedures, Corporate
H&S Compliance Manual procedures, etc.); and
— Collective bargaining agreements.
• Key communication vehicles include onboarding, periodic
training, and annual performance reviews. The roles are
reinforced through a range of routine inspection, assessment,
and audit activities.
• The Duke Production System process helps define
responsibilities for specific environmental and H&S projects,
goals, or tasks.
2. Individuals with EHS-related • Facility-based EHS leaders have 'solid line' reporting to
responsibilities have appropriate Corporate EHS and 'dotted line' reporting directly to the
authority to carry out their Facility/Station Manager.
assigned duties.
• EHS function employees have support from management and
are provided the necessary tools to perform their duties.
• The organizational level of the EHS staff ensures appropriate
rank and influence.
• Stop work authority is established for all employees.
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August 2016 Duke Energy EHSMS Manual
Expectation Implementation Approach and Guidance
44 3. Individuals with EHS-related • EHS content is incorporated into individual annual goal-setting
responsibilities are held and balanced scorecard processes, especially for line managers
K;,;,,� accountable for carrying out their and others whose activities have the potential to significantly ;'"
roles and achieving the desired impact EHS performance.
results through the performance
appraisal and incentive • Those with EHS responsibilities are held accountable for
compensation processes. performance results during annual reviews, impacting ratings,
Accountability cascades down salary, and promotion decisions as appropriate. n
r.r from senior line management • The specific metrics and extent of EHS coverage in these
„ : through to front line supervisors processes are at the discretion of management, but are enough
:k and employees. to signal the importance of EHS and reinforce line management's
i' responsibility for performance results.
i.
v°yl
iir
ry f:
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August 2016 Duke Energy EHSMS Manual
Element 2 — Planning
The Planning element of the Duke EHSMS includes three sub-elements:
• 2a. EHS Aspects/Hazards and Risk Assessment
• 2b. Compliance Obligations
• 2c. EHS Objectives and Plans
2a. EHS Aspects/Hazards and Risk Assessment
EHS aspects and hazards are identified and associated risks are assessed based on the controls in
place in order to define where additional controls or risk mitigation actions are required.
cppctatlA 301Pfemieritation,Approh#a$acdtGujdano
1. EHS aspects and hazards • The EHS Risk Management Program defines the process for
associated with operational identifying EHS aspects and hazards, including their
equipment and work activities are documentation.
inventoried and documented.
• The aspects and hazards identification process is overseen by
the EHS Risk Governance and Change Management
Department, who ensures that the process is carried out across
Duke Energy assets in a consistent and systematic manner.
• A variety of additional tools are used for this aspects and hazards
identification process (see 2a.2, below, for specific examples of
risk identification and assessment tools).
• Aspect/hazard identification and risk assessment happen at key
organizational levels, including at the corporate level BU-level,
and facility-level.
2. EHS risks are assessed based on • A standard EHS Risk Assessment Matrix is used to assess EHS
the controls in place in order to risks associated with environmental aspects and H&S-related
determine whether the residual risk hazards.
is
acceptablean. Controls r requires • A varietyof additional tools are collectivelyused to undertake risk
mitigation. are assessed
for effectiveness. assessments, including:
— Job hazard analyses;
— Process hazard analyses;
— Keys to Life (KTL) assessments and control plans; and
— Facility Risk Grids.
3. Additional risk controls and • Additional risk management actions may include new/improved
mitigation actions are identified, procedures or training, application of new technologies or
evaluated, and implemented to equipment, new inspection or audit schemes, enhanced
further reduce EHS risk levels mechanical integrity programs, or other enhancements to the
when deemed appropriate. management system.
• Appropriateness of additional risk controls and mitigation actions
is determined by the station/BU, the EEGB/HSPC, or the Senior
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August 2016 Duke Energy EHSMS Manual
;Expectation s Implementation Approach and Guidance f '
Management Committee, depending on the risk level and
required investment.
• Additional controls and mitigation actions may be managed
through the processes defined under EHS Objectives and Plans
(2c), Corrective Action (5a), or other management system
process (such as Operating Procedures, 3a).
4. Risk assessments are carried out • Local responsible management and front line personnel
by competent individuals and contribute to the risk assessment process where practical,
include the inputs of those with a including front line supervision, operators, and mechanics as
practical understanding of the risk appropriate, in addition to EHS staff.
scenarios based on day-to-day • Individuals leadingthe risk assessmentprocess have undergone
operational experience. g
training (formal or informal) and/or have sufficient experience in
conducting risk assessments to effectively lead them.
5. Risk assessments are carried out • Risk assessment is a key component of Duke Energy's
or updated per Management of Management of Change process, including for capital and non-
Change processes, including capital projects, new chemicals, and other relevant organizational
changes to the organization, and operational changes (see Sub-element 3c).
operations, equipment, business • Frequency for review of risk assessments is defined in the EHS
processes, materials and products.
Risk assessments are reviewed Risk Management Program, except for those driven by the
and updated, as needed. Management of Change process.
2b. Compliance Obligations
Relevant laws, regulations and other EHS obligations are proactively identified and managed through
compliance action tracking systems.
` li Expectatit tit Implementation Approach and Guidance;;
1. Applicable EHS statutes, • Registers of applicable environmental and H&S statutes,
regulations, ordinances, regulations, ordinances and other commitments are maintained
compliance requirements, and in eTRAC.
other commitments made to
regulators and other relevant - For H&S, this high-level register focuses on federal program-
stakeholders, as appropriate, are level requirements that are applicable across Duke Energy's
identified and documented. U.S. assets, and
- For environmental, these registers are site-specific and
include applicable federal, state, and local environmental laws
and requirements.
• As a further means of control, specific actionable and applicable
requirements identified in the relevant federal, state, and local
environmental laws, as well as requirements contained in site
environmental permits, are documented in environmental
compliance registers and maintained in eTRAC.
• A process is established for documenting other EHS
commitments made to regulators (e.g., as part of corrective
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August 2016 Duke Energy EHSMS Manual
Y {• m y ' t kt e +-Ryri v . ., � 4
e*pettatiO k • rt Implementation Approach and Guidance* {
actions related to a notice of violation or an OSHA citation) and
other external stakeholders.
• Requirements related to Process Safety Management (PSM) are
documented via a dedicated PSM system (Knowledge
Management System).
2. Actions required to fulfill the • Compliance tasks are defined and mapped to actionable and
identified compliance requirements applicable environmental legal requirements as part of the
are defined and communicated to environmental compliance registers. Environmental compliance
responsible employees or tasks are managed via eTRAC or other approved work
contractors. management systems within the BUs and tracked to ensure
tasks are implemented and closed. Overdue tasks are escalated
to higher levels of responsible management.
• H&S programs which outline key regulatory requirements as a
means for driving compliance actions (e.g., Maximo, Plant View,
etc.) are developed and communicated to relevant personnel.
3. Potential changes to compliance • EHS professionals at various organizational levels and in
obligations are monitored and new different BUs/regions/facilities track regulatory changes using a
applicable requirements are variety of tools and approaches, including:
incorporated into the compliance
management process. — Periodic review of agency websites;
— Online update services;
— Newsletters from professional service firms;
— Updates provided by utility groups (e.g., Utility Water Act
Group, Utility Air Regulatory Group, Utility Solid Waste
Activities Group, Florida Electric Power Coordinating Group,
etc.); and
— Relationships with third party lawyers and consultants.
• New environmental laws and other legal requirements (including
revised permits) are addressed via the following procedures in
the Environmental Compliance Manual:
— Environmental Regulatory Review (ENV-10-50); and
— Permit Renewal, Modification and Implementation Process
(ENV-10-140).
• New H&S laws and other legal requirements are monitored by
the H&S Department, and programs are updated to reflect new
and revised requirements.
2c. EHS Objectives and Plans
EHS objectives are established and evaluated as part of the business planning process to drive
continual improvement in EHS programs and performance.
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August 2016 Duke Energy EHSMS Manual
xpectatiort 4 entatio A ro d •
cl io pl ? pP Bch:an tii4anc � w,�� .,
1. Measurable objectives are • The EHS 2020 Vision Plan sets the five-year objectives and
developed to improve EHS goals for the company related to EHS performance and
programs and performance, programs, is reviewed on an annual basis, and is updated as
considering EHS policies, past needed to drive performance improvement.
performance, risks and
opportunities, industry • Through the Duke Production System, annual goals are set to
benchmarks, the interests of drive performance improvement, including EHS. These goals
stakeholders, and business are monitored via a series of related metrics, as documented in
realities. the A3s.
• The management review process (see Sub-element 5c) is used
to ensure understanding of past performance, risks and
opportunities, industry benchmarks, the interests of stakeholders,
and business realities. This understanding is used to inform
future objectives.
• Goals are also set and communicated via the EHS 'The Road
Ahead', as well as the Duke Energy Sustainability Report.
• Formal objectives/goals are not required for every significant
aspect or risk.
• Key involved and affected personnel, at the appropriate levels of
the company (e.g., Corporate, BU, Regional, etc.) are involved in
the objective setting process, to ensure objectives are the right
ones for the business.
2. Action plans are defined to achieve • Action plans are set via the Duke Production System (A3s) or
the objectives, including specifying other BU/department business plans. For example, the A3s
responsibilities, timeframes, and provide a status of key activities being implemented to achieve
resource requirements. objectives and are a visual method of knowing the status of key
metrics.
• A3s are data driven and revised until they tell a clear, simple
story about a gap that needs to be closed, what has been done
in the past to address it, and the plan to improve performance in
the future.
3. The objective-setting and action • EHS staff participate in the business planning process to ensure
planning processes are overall business plans do not inadvertently create unacceptable
incorporated into the business EHS risks and to enable them to productively support the
planning and performance business.
management processes to ensure • EHS staff areapart of the appropriate BU's team to,assist with
they are aligned with the overall
business objectives, endorsed by the development of the business plan.
management, and adequately • Corporate goals and action plans flow through to relevant
resourced. individuals' annual goals in order to drive delivery.
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August 2016 Duke Energy EHSMS Manual
Element 3 — Operations 1
The Operations element of the Duke EHSMS includes five sub-elements:
• 3a. Operating Procedures
• 3b. Mechanical Integrity
• 3c. Management of Change
• 3d. Emergency Preparedness and Response
• 3e. Contractors
3a. Operating Procedures
Documented procedures establish safe work practices for managing specific EHS risks.
Expectation Implementation Approach and Guidance
1. Operating procedures and • The outcomes of the aspects and hazards identification and
supporting work instructions subsequent risk assessment processes (see Sub-element 2a)
address day-to-day management are used to identify the potential need for additional or improved
of EHS aspects and hazards; the operating or other implementing procedures.
need for operating procedures is
based on risk. • Procedures may be established at the corporate, business unit,
region or site levels, as needed. Corporate-level procedures are
developed for significant hazards that are pervasive across the
company and warrant a consistent management approach.
— Refer to the Environmental Compliance Manual and the H&S
Compliance Manual for the available Corporate-level
programs and procedures; and
— BU, region, and facility procedures and other governing
documents are developed and implemented to help meet
corporate Duke Energy standards, procedures, and other
requirements. The need for these additional procedures is
based on risk, and left to the discretion of the BU, region,
and/or facility.
• EHS personnel review and provide input on facility operating
procedures in cases where those operations have the potential to
impact EHS outcomes.
• Facility operating procedures address both routine and non-
routine (e.g., startup and shutdown) operations.
2. Programs and procedures are • H&S programs have been developed for common high-risk
established to address specific activities (e.g., welding, working on energized equipment,
high-hazard work activities. confined space entries, and excavation)to provide programmatic
direction for planning and job execution.
• Risks associated with high-hazard work activities are mitigated
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August 2016 Duke Energy EHSMS Manual
a nExpectatiois r� ,,'Implementation Approach and Guidance ,,,:,,, a s,
through engineering and administrative controls (as outlined in
Corporate and BU H&S programs) and are fully integrated into
work plans.
• Prior to initiating work, Pre-Job Safety Briefs and/or Job Hazard
Analyses are used to ensure safety is integrated into task
completion.
• Work activities with the greatest potential for fatal and serious
injury are identified in BU-specific KTLs. Initiatives are
developed, approved, and implemented by the BUs to reduce
risk to acceptable levels for these activities. Oversight for
completion is provided by the HSPC, which is provided with
quarterly updates on the BUs' progress.
3. Employees are provided with • Business units are responsible for ensuring their staff are
training on relevant operating and qualified and trained on relevant procedures. Many BUs use
implementing procedures so that training matrices to define which roles require each relevant EHS
they are effectively implemented. training course (see Sub-element 6b).
Contractors are made aware of • EHS content is incorporated into standard career develop ment
relevant operating procedures. P P
training where workers get certified to conduct key tasks or
operate specific equipment.
3b. Mechanical Integrity
Plant and equipment critical to EHS are operated and maintained to sustain mechanical integrity and
reliability so as to prevent EHS incidents.
Expectation firt � Implementation Approach and Guidance
, .a.��,&, -+."�.�,,.;... m. �w�.. ik.'� x., ... ,'"t; pi max,�, .rit ''
1. Equipment critical to achieving • Site EHS work collaboratively with site leadership and
EHS commitments in company maintenance to agree on EHS-critical equipment and
policies and objectives (e.g. maintenance schedules and priorities, including those defined by
regulatory compliance, pollution relevant permits (e.g., Title V and National Pollutant Discharge
prevention, and employee and Elimination System [NPDES]).
public safety), including operating
equipment, control equipment, and • The list of equipment from the Risk Grids is used to inform
measurement devices, are decisions around EHS critical equipment.
identified, documented, and • Facilities use a formal work management system to establish the
subject to routine preventive schedule and priorities, and track status of work orders, to
maintenance to keep the ensure that preventive maintenance is executed on an ongoing
equipment running in proper basis.
operating condition.
• Maintenance staff are made aware of relevant EHS regulatory
requirements associated with EHS-critical equipment.
2. Equipment that fails or is not • Repairs classified as being related to environmental or H&S
operating properly receives performance are prioritized for repair.
appropriate repair priority so that
policy commitments, regulatory • These classifications are managed through Maximo,
Consolidated Asset Suite, or other BU-specific systems.
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August 2016
g Cif) Duke Energy EHSMS Manual
cp
14
Expectation 'Im lementation Approach and Guidance p pp
`> d': ,`:
¢s
•
requirements, and other • Responsible individuals monitor these maintenance actions to
obligations are met. ensure repairs are prioritized and completed.
3. Maintenance and equipment • Maintenance records on EHS critical equipment are reviewed
performance records are regularly as part of each maintenance department's internal
maintained and analyzed to review processes.
anticipate and address
performance issues.
3c. Management of Change
Planned and unplanned changes are identified and managed to ensure that EHS risks arising from
these changes remain at an acceptable level.
:Expectatiiortq
nplementa#ion Apprc ph and Guidanc
1. A documented Management of • A comprehensive MOC Procedure (under development) details
Change process defines the nature the process used at Duke Energy to assess proposed changes
and level of risk assessment for potential EHS impacts.
required to assess the potential • The Project Management Center of Excellence (PMCoE) utilizes
EHS impacts from both permanent g
and temporary changes to the the Project EHS Management Standard (PJM-00011-ENTSTD)
assets and/or equipment, land use, as part of the capital project review. E/H&S checklists are used
materials/chemicals, and for capital projects in order to understand if a given project
operational and business triggers EHS requirements or requires special controls or other
processes. measures.
• The Chemical Control Program (ADMP-ENV- EVS-00008)
establishes the process used to manage potential risks and
compliance issues related to new or changed
materials/chemicals at a given location.
• The Permit Renewal, Modification, and Implementation Process
(ENV-10-140) is used to assist with identifying and implementing
changes associated with newly issued or modified environmental
permits.
2. Risk assessments and reviews of • Project management process has EHS review at key design
proposed major changes are review stages or'gates', where EHS must be 'green-lighted' in
carried out by competent order for the project to progress to the next stage.
individuals at appropriate stages in
the change process (e.g. • New equipment is subject to an EHS review prior to
conceptual design, detailed commissioning.
design, capital authorization, prior • Issues raised during these reviews are documented and tracked
to construction, and pre-startup) through to resolution using the process laid out in the Proiect
and identified issues are EHS Management Standard (PJM-00011-ENTSTD).
addressed prior to implementing
the change. • Risk assessments and reviews of proposed changes specifically
address the need for modified or new permits as well as design
changes or improvements in operational controls to mitigate
risks, ensure compliance, and minimize adverse EHS impacts.
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August 2016 Duke Energy EHSMS Manual
Expectation i nplementation Approach and Guldancp
• EHS staff are involved in the appropriate projects early in the
process to ensure EHS risks and opportunities are well
understood and planned for.
• Competency for conducting such reviews is established by a
combination of skills, education, experience and training, but no
formal designation is required (see also Sub-element 6b).
3. Changes made are documented, • Changes are documented according to the documentation and
and communicated to relevant recordkeeping principles and requirements described in Sub-
personnel. element 6d.
• Procedures and work management/preventive maintenance
systems are updated, as needed.
• In most instances, communications related to the change are
handled at the BU-or site-level. However, communication plans
are established and implemented for critical changes which affect
large numbers of personnel.
4. EHS due diligence is conducted to • The due diligence process is driven through a set of standard
the extent practical prior to checklist tools, underpinned by a detailed Due Diligence
acquiring or divesting assets, and Procedure(under development)which explains the depth of due
management of identified EHS diligence as applied to lease changes vs acquisition vs
risks and liabilities are divestiture, etc.
incorporated into the transaction
terms; Duke Energy policies and • A gap analysis against Duke Energy corporate EHS
standards are applied to newly requirements is carried out for newly acquired assets, and action
acquired assets as soon as plans are developed to ensure that Duke Energy EHS
practicable. requirements are met as soon as practicable.
3d. Emergency Preparedness and Response
Plans and procedures are in place to prepare for and effectively respond to emergency situations.
expectation v Implementation Approach and Guidance
1. Emergency plans and procedures • The Duke Energy Emergency Management Program document
are developed to mitigate EHS and defines the framework, underlying requirements, and supporting
associated business impacts tools which Duke Energy utilizes to ensure it has the capability to
across a range of potential incident pro-actively mitigate potential crises and undertake effective
and emergency scenarios, crisis management and emergency response, if and when
including credible worst case. incidents occur.
• The Enterprise Preparedness Services organization is
established to further define requirements and establish
standards on emergency preparedness.
• Every operating location has an emergency plan or plans,
utilizing available business templates.
— Standard risk scenarios (spills, fires, medical emergency,
weather, etc.), including credible worst case, are addressed in
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August 2016 Duke Energy EHSMS Manual
,Expectation,4 Implementation Approach and G,uidanc r
these plans; and
— Emergency plans may include Emergency Response Plans,
Emergency Action Plans, Spill Prevention, Control, and
Countermeasure (SPCC) Plans, Facility Response Plans, etc.
2. Crisis communications plans are • Crisis Communications Plans are developed and maintained by
maintained to inform internal and Corporate Communications, who are responsible for emergency
external stakeholders in the event communications via the Joint Information Center.
of an actual emergency.
• The Enterprise Preparedness Services organization is
responsible for ensuring Program provisions, material changes,
and appropriate on-going communications are shared with
company leadership and site management.
• As appropriate, the Enterprise Preparedness Services
organization is also responsible for ensuring crisis management
information appropriate for employees enterprise-wide is
communicated.
• Communication protocols are also included in location-specific
emergency plans.
3. Local emergency response teams • Local emergency response teams are defined in the location-
are organized and trained, specific emergency plans, including provisions for coordinating
appropriate response equipment with external organizations.
deployed and maintained, and • Common trainingmodules areprovided bycorporate and
coordination with appropriate P
external response organizations customized for use at BU and site levels to drive efficiency and
established. ensure a consistent approach to emergency response across the
company.
4. Communications, emergency • Exercises are conducted annually, as defined in the Emergency
plans, and response and recovery Management Program document.
proceduresona and equipment are • Emergency drills to test communications, emergency plans, and
tested on a regular basis to ensure g y 9 Y
ongoing readiness. response and recovery procedures and equipment are
conducted as defined in the established location-specific
emergency plans.
5. Emergency plans and procedures • The Emergency Management Program document is reviewed at
are modified based on lessons least once annually; the Enterprise Crisis Operations Center
learned from tests and responses (ECOC), BU and corporate department crisis/emergency
to actual emergencies, and are management plans are also reviewed at least once annually.
communicated to relevant
personnel. • Formal emergency team debriefs are conducted after tests and
actual emergencies to identify potential improvements.
Crisis/emergency management plans and processes are also
subject to review and comment following exercise activities, post-
incident reviews and audits.
• Changes deemed critical to the adequacy of the Program,
ECOC, business unit or corporate department crisis/emergency
management programs are addressed immediately rather than
held for inclusion during the regularly scheduled annual update.
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August 2016 0 Duke Energy EHSMS Manual
3e. Contractors
EHS risks are factored into the selection and management of contractors.
' Expectation) 1 implementation Approach. and Guidance:, ` a
1. EHS performance, programs, and • Supply Chain is responsible for incorporating EHS performance,
issues are factored into the programs and requirements into the strategic sourcing process.
selection of contractors on a risk
basis, taking into account the • Duke Energy's Contractor EHS Management Program (HS-
nature of their activities or services 00048)defines how EHS is factored into the contractor selection
and previous EHS performance. process.
• Contractors are registered via a third-party system, Power
Advocate, into which they must provide EHS performance and
related data/information. This EHS information is assessed and
categorized, with certain categories requiring sign-off(e.g., if
EHS performance does not meet minimum established
requirements)to allow the contractor to be approved for hire.
2. Contracts are established and • Standard terms and conditions related to EHS are included in
enforced that address potential contracts (e.g., compliance, waste generation/disposal,
EHS liability and responsibility for oversight, reporting, etc.).
contractors, including • Additional, supplemental Terms and Conditions are available for
consequences for failing to comply pp
with contract or regulatory use to address particular high risk activities (e.g., waste vendors,
obligations. construction contractors, etc.) and include a requirement for a
project-specific EHS Plan.
• Duke Energy contract managers/administrators are provided with
training to ensure contract management/oversight requirements
are understood. Training is also provided to EHS professionals
who may be responsible for overseeing the EHS aspects of the
contract managers/administrators,
3. Contractors, including their • Contractor personnel must participate in required on-site EHS
employees and associated briefings prior to working at a Duke Energy location.
subcontractors, are made aware of • Contractors areprovided with the Duke Energy's
EHS risks and associated controls, H&S
procedures, and standards Handbook.
relevant to their work. • Contractor personnel plan their upcoming work and also
participate in pre-job briefings, specific to the project or planned
activity, to ensure EHS risks and associated controls,
procedures, etc. are known.
• More focused EHS communication may be provided in instances
where warranted based on risk (e.g., for demolition activities).
4. EHS aspects of contractor • Contractor personnel are included in the Field Observation
activities and performance are Program, where personnel are observed during their daily
monitored on a periodic basis. activities, performance is noted, and feedback is provided.
Contractors are also encouraged to conduct Field Observation
on their own personnel and provide similar feedback.
• Contractor EHS performance is formally reviewed on an annual
basis.
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August 2016 Duke Energy EHSMS Manual
g� is &S c'iAr
• Environmental and H&S Improvement Plans are used for those
contractors not meeting performance criteria.
• Contracts are written to include a provision to allow Duke Energy
the ability to conduct audits, including for compliance, on
contractors on an ad hoc basis, if needed.
• Duke Energy contract managers are trained to ensure they
understand their responsibilities as they relate to overseeing
contractor work, and are competent in the tools used to monitor
contractor performance.
5. Contractors provide information on • Contractors are prompted to identify environmental aspects and
the hazards associated with their H&S hazards associated with their activities.
equipment, products, and services
prior to delivery or commencement • Contractors are required to notify the company prior to bringing
of works, and whenever changes chemicals onto a Duke Energy location, and provide the Safety
occur. Data Sheets for Duke Energy's review and approval.
• Pre-job briefings are also used as a forum for contractors to
provide information related to relevant hazards and controls in
place to manage them, prior to work starting. In some cases,
JHAs are used to build the pre-job briefings.
• Contractors performing high-hazard work are required to develop
a specific health and safety plan related to the work activities.
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August 2016 Duke Energy EHSMS Manual
Element 4 — Monitoring
The Monitoring element of the Duke EHSMS includes two sub-elements:
• 4a. Performance Monitoring
• 4b. Inspections and Audits
4a. Performance Monitoring
EHS performance is tracked on an ongoing basis to enable corrective actions and drive performance
improvement.
#XPO stat+O pleb entat(IAn A*pro$h and Gu dan
1. Performance of operating and • Progress against key operating specifications and compliance
control equipment critical to limits is tracked and alarms or alerts are signaled when
achieving commitments in performance is trending towards, approaches, or hits those limits
company EHS policies and at power generation sites.
objectives is monitored using
established criteria in order to • EHS performance of operations is tracked and reviewed during
anticipate and prevent non daily operational and shift change meetings.
compliance and adverse impacts. • Operators are trained to respond to changes in operational
performance data in order to maintain compliance on an ongoing
basis.
2. An incident reporting process is • Duke Energy's incident reporting process is defined in the EHS
established that defines the types Event Reporting and Investigation Program (EHS-PGM-105).
of incidents that should be The program defines how incidents are classified, which require
documented and reported to investigations, and the general workflow and timing for all
management, reporting timelines, incidents.
and which incidents are subject to
formal incident investigation and • EHS incidents are recorded in the eTRAC Incident Module and, if
corrective action processes. applicable, in a BU database to facilitate tracking, trending, and
monitoring of the incidents and their corrective actions (see Sub-
element 5a).
3. Key performance indicators (KPIs) • KPIs are established for both environmental and H&S
are established to measure EHS performance, and reviewed by the EEGB and HSPC. They are
performance, and routine reports monitored formally through the Duke Production System A3s.
are provided to responsible These include standard metrics for all locations (focused on
management in a timely manner. compliance, risk management, and incidents), as well as
KPIs include leading and lagging indicators which are established to evaluate performance related
indicators. to key objectives or improvement areas.
• Leading indicator data are evaluated in order to identify potential
gaps in the management systems and/or their implementation.
• Routine EHS reports from operating assets to BU and/or regional
level line and EHS leaders, and from BU or region levels to
corporate line and EHS leaders, ensure that EHS performance is
being communicated to and evaluated at the appropriate level.
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August 2016 Duke Energy EHSMS Manual
4b. Inspections and Audits
A complementary combination of EHS inspections and audits is carried out to verify conformance with
compliance obligations and established standards and procedures, and to drive continual improvement
in EHS programs and performance.
1,144440.-Expettatio"-0,4-- k'nentatit n`Approal* `dc( uiden
1. Routine audits verify(1) • The audit process is established in the Environmental Health and
compliance with relevant internal Safety Assessment Proqram (ADMP-EHS-EHS-00007). It
and external obligations, including addresses audit scope, scheduling, staffing, reporting, and the
legal requirements and (2) corrective action process.
conformance to Duke's EHS
management system • EHS compliance audits include comprehensive assessments,
requirements. focused assessments based on risk, and unannounced
assessments.
• Some BUs also conduct focused audits which cover EHS
compliance and risk (e.g., the T&D Buildings and Grounds
Assessments).
• Self-assessments are used as an additional tool to provide
additional assurance related to EHS compliance and
conformance to the EHSMS.
• Additionally, the Duke Energy Corporate Audit group assesses
conformance with the company's EHS programs, including the
requirements of this EHSMS, as defined in the Audit Policy.
2. Local inspection programs are • Inspection programs ensure operations are reviewed on a
established to maintain good regular basis for safe working conditions, housekeeping, and
housekeeping and identify and routine compliance checks. EHS Field Operations personnel are
prevent potential non-compliance often involved in these site inspections. The exact frequency and
with obligations and unsafe staffing of inspections are a local management decision.
behaviors and conditions on a
routine basis. • Regulatory inspections (e.g., SPCC) are documented.
• Facilities develop site-specific checklists to guide the
implementation of EHS inspection programs. Records may be
kept locally, but are not required unless deemed so by a legal or
regulatory requirement.
• Identified issues are addressed and trends in inspection results
(including the work observation program) are analyzed to identify
systemic issues and drive improvement.
3. Inspections and audits cover a full • EHS compliance audits are designed to cover relevant EHS
range of relevant EHS topics and topics, based on risk. Audits carried out by the Corporate Audit
operations, are carried out by group are also designed to cover key program areas.
competent individuals, are
communicated to management, • Competency requirements for auditors are defined in the
and are subject to corrective Environmental Health and Safety Assessment Program (ADMP-
action. EHS-EHS-00007).
• Findings and corrective actions from EHS compliance audits go
into the eTRAC audit module, supplemented by BU corrective
action programs. Findings and corrective actions from the
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�
Augmst2O16 `/ Duke Energy EHSMSManual
00
ectat Inp|enmentatmnApproach and (�uidmoce'
* Corporate Audit group audits are managed via Teammate.
° Self-assessments are reviewed by Corporate EHS- if corrective
actions are identified, they are also entered into eTRAC.
* Corrective actions are managed according to Sub-element 5a.
* Format and content of inspection checklists are developed by8U
or facility staff based on risk and other factors. They are
intended to complement the audit process and help maintain
compliance and safe working conditions on aday-to'daybasis. �
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August 2016 Duke Energy EHSMS Manual
Element 5 — Improvement I
The Improvement element of the Duke EHSMS includes three sub-elements:
• 5a. Corrective Action
• 5b. Organizational Learning
• 5c. Management Review
5a. Corrective Action
Corrective actions are implemented to address non-conformances and drive performance
improvement.
1**000 ' 4601ei>kati APproa c Gia
1. Corrective actions are developed • Corrective actions are developed to address findings from EHS
from audit findings, in response to compliance audits, entered into the eTRAC audit module, and
incidents and significant near subject to spot verification, as defined in the Environmental
misses, and when performance Health and Safety Assessment Program (ADMP-EHS-EHS-
results are not trending in line with 00007).
established objectives and • The criteria related to the development of corrective actions in
expectations.
response to incidents and significant near misses are defined in
the EHS Event Reporting and Investigation Program (EHS-PGM-
105). These corrective actions are also tracked via eTRAC.
• BUs have the ability to also enter and track corrective actions in
BU-specific systems in order to better drive the action to closure.
• Corrective actions are also developed to address findings from
the Corporate Audit Services.
• Performance trends are reviewed by responsible line
management through the management review process, but more
frequently by EHS staff during the generation of routine monthly
and quarterly reports.
— Corrective actions (e.g., recovery plans)taken to improve
performance results are typically in the form of a focused
performance improvement program, and therefore not tracked
via eTRAC.
• The corrective action management process is documented in
the Corrective Action Management Standard (under
development).
2. Corrective actions consider the • The process for understanding underlying causes and the
underlying causes in order to instances where formal investigations are required are defined in
reduce the likelihood of a the EHS Event Reporting and Investigation Program (EHS-PGM-
recurrence, with more formal and 105).
rigorous investigations carried out
for the most significant findings • Formal root cause analysis is conducted for all Category 1
and incidents. events, and is conducted for Category 2 events at management
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August 2016 Duke Energy EHSMS Manual
" #h r0gcpectatkitiv ,hriptementation Approac kand Guidance �x
discretion. Human performance is considered as part of the
causal analysis.
• Line supervision associated with incidents are involved in
relevant investigations to facilitate the understanding of
underlying causes.
• Senior EHS staff from higher organizational levels are involved in
the investigations of the most serious incidents.
• Corrective actions to address audit findings are developed with
the underlying cause in mind, in addition to addressing the
immediate cause, as described in the Environmental Health and
Safety Assessment Program (ADMP-EHS-EHS-00007).
3. Corrective actions are tracked • Corrective actions are tracked via a suite of tools to ensure
through closure. ownership of action closure at the right level of the organization,
including eTRAC (at the corporate level), Plant View(within
some BUs, such as Fossil Hydro Operations), etc.
• Corrective action past due dates are escalated to higher levels of
responsible management and are covered in dashboards in
routine management reports to help raise visibility and drive
closure. Email notifications are used to remind those
responsible, and their managers, of overdue actions.
5b. Organizational Learning
Trends in EHS performance and lessons learned are analyzed across the company and corresponding
actions are taken as appropriate to further mitigate risk and improve performance at a given asset as
well as across BUs/regions.
aipectatipir , fi plementation: ►`pproactt'and idan s
1. Trends in incidents, audit findings, • Trend analysis occurs at multiple organizational levels, including
and other performance indicators site, business unit, region and company-wide.
are analyzed within and across
individual operations and • Trending is formally analyzed during the annual management
appropriate proactive measures review process (see Sub-element 5c) and future year planning;
are taken to further mitigate risk month to month trending is conducted on a less formal, more
and improve performance. localized basis.
• Proactive measures taken to improve performance results are
managed via DPS and monitored via the A3s, supplemented by
focused, short-term performance improvement programs.
2. Lessons learned and best • Formal lessons learned and best management practices are
management practices from compiled and shared to relevant internal teams (EHS, line
internal and external sources are management, maintenance, etc.) via a variety of methods,
shared across operations, and including:
corresponding actions are taken as — Through the EEGB and HSPC;
appropriate to further mitigate risk
and improve performance. — Internal written alerts, which are emailed to relevant personnel
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- '
' August2O10 Duke Energy EH3MSManual
* Implementation Approach
' and Guidance"
and available on the portal;
- During EHS department staff meetings-
Daily caUu at the 8U level- and
- During the management review process (see Sub-element
5u). �
° Duke Energy EHS programs and performance are periodically
;Kw_
benuhmarked against utility and other industry peers in order to
/
identify potential improvement opportunities. �&
41
.
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August 2016 Duke Energy EHSMS Manual
5c. Management Review
Overall EHS programs and performance are reviewed by senior management to ensure they are
achieving the desired outcomes.
1. A formal review of the adequacy • Management reviews drive local management teams, led by line
and effectiveness of the EHSMS, leadership, to conduct formal and focused reviews of their EHS
its underlying programs, and management system on a periodic basis. The intent is to help
overall EHS performance is carried ensure the ongoing appropriateness and effectiveness of the
out for major operations and overall EHS program.
assets involvement t least annually the with theo • Management reviews include discussions around the key
of senior g
line manager responsible for those performance indicators and associated trends, results of
operations and assets. inspections and audits, the nature and severity of EHS incidents,
effectiveness of existing programs, emerging issues, and
relevant views from stakeholders.
• The management review process looks at whether site-level
programs are delivering what is needed, and then cascades up
to regional/BU, and then then enterprise-wide level.
• The management review process is documented in the
Management Review Standard (under development).
2. Improvement actions are defined • Actions resulting from the management review process are
and taken based the results of the treated as corrective actions, and handled as described in Sub-
management reviews, are tracked element 5a.
through to closure, and monitored
effectiveness effectiveness in driving EHS • Improvement actions are also an input to the process of setting
performance improvement. annual objectives, consistent with the requirements under Sub-
element 2c.
3. The results of EHS management • Site level management review results are documented and feed
reviews are rolled up to higher the management review process at the business unit and/or
organizational levels, enabling region.
similar reviews at higher
organizational levels, including • Business unit/region management reviews are documented and
regional, business unit, and feed the management review process at the
corporate levels. corporate/enterprise-wide level.
•
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August 2016 Duke Energy EHSMS Manual
I Element 6 - Support
The Support element of the Duke EHSMS includes four sub-elements:
• 6a. Resources
• 6b. Competency
• 6c. Communications and Engagement
• 6d. Documentation and Recordkeeping
6a. Resources
Sufficient resources are provided across the organization to support implementation of the EHS
management system and to achieve the desired level of performance.
Pa�itici. o t n r'oi oi
t uwtlae.3-
s.,w
1. The organization determines and • Resource needs are largely identified through the annual
provides the resources needed for planning process, including management review(see Sub-
the establishment, implementation, element 5c), and secured via the annual budgeting process.
maintenance, and continual
improvement of the EHSMS. • Resources include human resources (number of staff as well as
competency, see Sub-element 6b), financial resources (capital
and operating budgets), and technological resources (IT
systems, control technologies, etc.).
• A process is established to ensure that EHS needs at the facility,
regional, and BU levels are considered in the planning and
budgeting process.
• Best available technologies reasonably achievable are
considered and implemented where practical.
6b. Competency
Processes are in place,to ensure that employees and contractors are competent to carry out their roles
in a safe and responsible manner.
�',` ', y �7 yy }may
v s4a+
1. EHS-related competencies are • EHS competencies are built into job qualifications and position
established and factored in to the descriptions for EHS professional staff, key line management,
hiring, promotion, and performance and others providing critical EHS support services (see Sub-
evaluation processes for those element 1c).
positions which can significantly
affect EHS performance. • Competencies include EHS technical skills related to regulations,
technologies, and best practices, as well as leadership skills to
effectively drive program implementation.
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August 2016 Duke Energy EHSMS Manual
• EHS competencies are included as evaluation criteria in the
annual performance review process for EHS professional staff,
key line management and others providing critical EHS support
services. Individual development plans are used to address key
gaps.
2. Training needs for key job • Training matrices are used to define the EHS training modules
classifications, including necessary, by role, for EHS staff as well as other key job
contractors (where relevant) and classifications.
new and transferring staff, are
defined and documented. • Skills qualification programs (e.g., the Employee Development
and Qualification Program [EDQP]) incorporate EHS content,
where relevant.
• As noted above, managers are involved in determining the
training of needs of their teams, identifying training gaps, and
development plans, as part of the annual performance evaluation
process.
• Training needs consider applicable legal requirements, general
EHS awareness, and specialized skills specific to the aspects,
hazards, and controls associated with each job.
• Contracts include a provision that contractors must provide staff
competent to perform the contracted services. If site-specific
hazards exist, those are communicated to the contractor as part
of contract start up process.
• Enterprise wide EHS awareness training is provided to all new
employees upon hire.
3. Training programs consistent with • EHS training is built in to the onboarding process for employee
the defined training needs are and contingent staff, as well as delivered via standalone modules
implemented and tracked, as needed.
ensuring staff are competent to • The development, delivery, and evaluation of enterprise EHS
effectively carry out assigned training programs are overseen by the EHS Training group.
responsibilities. Training on BU-specific EHS topics or procedures is the
responsibility of business unit training teams, with support as
needed from EHS Training.
• My Training is used to track completed training. Gaps in training
completed versus requirements are escalated to responsible
management.
• All active EHS computer-based training modules are made
available via My Training, which gives 24-7 accessibility.
6c. Communications and Engagement
Ongoing communications and engagement activities ensure critical information is shared, a high level
EHS awareness is maintained, and a strong, inclusive EHS culture is built and continually improved.
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August 2016 Duke Energy EHSMS Manual
Expectations x ntplementatign Approach and Guidance „
1. Affected employees are engaged • Opportunities for employees to get engaged in EHS programs
in the development, include:
implementation, and improvement
of EHS programs in order to build — Facility-based safety and environmental committees or
awareness and ownership. councils;
— Behavior-based safety programs (e.g., field observation
program);
— Local housekeeping and inspection programs and 'green'
initiatives; and
— EHS training.
• The EHS Program Development Procedure (under development)
further defines the standards around EHS program development,
including engaging with employees during the development
process.
2. Internal communication programs, • Communications plans are established to ensure consistency
for employees and key contractors, and adequacy in communications, including:
help maintain a high level of EHS
awareness, communicate — The annual EHS Communications Plan, which governs
performance accomplishments and communication amongst EHS staff across business and
opportunities for improvement, organization levels as well as communications from EHS to
share lessons learned and best the broader employee population; and
practices, and reinforce a strong — The EHS 2020 Vision Plan includes a communication
EHS culture. component to ensure that personnel are aware of EHS
objectives, initiatives, and programs.
• In addition to routine communications, targeted
communications are developed and rolled out for key company
EHS initiatives, activities, and projects (e.g., when a new EHS
policy is issued).
• BUs, regions, and facilities develop additional EHS
communication programs based on local need, including
regular emails, group calls/meetings, and other bulletins.
• EHS orientation and onboarding programs are developed and
delivered to new employees.
• Sustainability employee engagement programs and tools
reinforce a strong EHS culture including an online module, the
• Sustainability, and a portal site.
• Contractor engagement activities, such as regular meetings
with contractor EHS representatives, are defined in the Duke
Energy's Contractor EHS Management Program (HSF-00048).
3. A mechanism is in place that • An Ethics Hotline is available as a method for employees to
allows employees, contractors, report concerns, including EHS.
and thec general nc public go reponon- • An Environmental Concerns Hotline is available as a method for
EHS concerns, including non-
compliance and unsafe conditions, employees, contractors, and the general public to report
anonymously and without fear of environmental concerns.
reprisal. • Employees and contractors can also report EHS concerns as
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August 2016 Duke Energy EHSMS Manual
S ttpec#ati � ` implementation Approach and-'Guidan
part of the Job Observation Program.
• Stop work authority is given to all employees, and allows them to
stop work and report unsafe acts, unsafe conditions, and
potential non-compliances without fear of reprisal.
4. Processes are in place to • The EHS function works closely with Corporate Communications
proactively communicate on EHS to facilitate EHS communications outside of the organization. An
programs and performance to External EHS Communications Plan is established, overseen by
external stakeholders. Corporate Communications, to direct communications from Duke
Energy EHS to external stakeholders.
• In addition to targeted programs and communications throughout
the year, the Duke Energy Sustainability Report is used as a
means for formally communicating the company's EHS
performance and programs, and other non-financial information,
annually to external stakeholders.
• Some sites and businesses have local external communication
programs specific to their locations or stakeholders (including
open houses, local education initiatives with schools and the
business community, etc.).
5. A process for receiving, • Inquiries received via the Environmental Hotline are documented
documenting and responding to and tracked through to resolution.
external inquiries regarding EHS • Other formal mechanisms for receiving, documenting, and
issues, including from regulators, responding to external inquiries include:
neighbors, customers, investors,
business partners and others, is — I Can Help—a system where a Duke Energy employee can
established. elevate a particular customer issue; and
— 800-POWER-ON—the customer contact center, which can
route EHS inquires to the appropriate EHS contact for further
action.
• Local sites receiving inquiries will route the issue to local EHS
teams who coordinate with local management and business unit
or region staff to develop an appropriate response.
• Inquiries received from state agencies and other regulators are
documented and communicated to relevant management so that
necessary actions can be captured and a response developed,
as needed.
• Inquiries that come to the 'Sustainability Inbox'from the external
Sustainability page on Duke-Energy.com are managed by the
Sustainability team.
6d. Documentation and Recordkeeping
An effective EHS document control and record management system is in place.
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August 2016 Duke Energy EHSMS Manual
s p anti•. ' ",," p1 a► or to r A P` r 1, U �
1. The core elements of the EHS • This EHSMS Manual addresses this requirement at the
management system are enterprise level; individual BUs and/or sites have supplemental
documented, including indexes or documentation for local programs, etc.
maps that provide direction to • The elements of the EHSMS are also documented on the
related procedures, tools, and
other documents. company portal, where links to relevant policies, standards,
procedures, and other tools are provided.
2. Document management • EHS documentation requirements are established in the EHS
procedures are maintained to Program Development Procedure (under development).
ensure current versions of
information and data are readily • The EHS Program Development Procedure further defines the
available, obsolete versions are standards around EHS program development, including
removed, and to control documentation associated with such programs.
confidential information. • Current versions of engineering design and specification
documentation are maintained and accessible.
3. Records that demonstrate • Documentation and recordkeeping is governed by the Duke
regulatory compliance and Energy Records and Information Management Compliance
conformance to the requirements Policy and related Standard.
of the EHSMSm damageare maintained, • As a supplement to the corporate policyand standard, EHS
protected from and readily pp p
available. recordkeeping requirements are summarized in the Records
Retention File Plan.
•
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August 2016 Duke Energy EHSMS Manual
APPENDIX I - ACRONYMS AND DEFINITIONS
A3 An A3 is a working document used for multiple purposes, such as strategy,
status or problem solving. A3s communicate data and facts using
drawings, charts and graphs and focuses on one True North component.
The term comes from the size of the paper, 11 X 17. The A3 process
ultimately results in an action plan for EHS. This action plan should help
EHS close its gaps and meet its targets, by helping to move from the
current state to an ideal future state.
ANSI American National Standards Institute, the primary US organization
BU Business Unit refers to the high-level, parent organization within Duke
Energy that includes multiple departments aligned around a single function,
such as: Fossil-Hydro Operations, Transmission, Nuclear, Delivery
Operations, Commercial Portfolio, and Corporate Functions (e.g. Finance,
HR, etc.), or it may refer to the more granular child BUs within each parent
BU.
Category 1 event Category 1 events are reportable environmental events (REE) resulting in
a significant impact, a fatality, a life-altering injury or a potential significant
injury or fatality (PSIF). Category 1 events require a root cause
investigation as defined in the EHS Event Reporting and Investigation Program
(EHS-PGM-1 05).
Category 2 event Category 2 events are any other reportable environmental events (REE) or
OSHA-recordable injuries or illness that do not meet Category 1 criteria.
Category 2 events require an apparent cause analysis and may require a
root cause investigation at management discretion as defined in the EHS
Event Reporting and Investigation Program (EHS-PGM-105).
Contingent worker Contingent worker refers generally to a non-employee who performs work
for Duke Energy; they are employed by an outside third party employer and
assigned by that employer to Duke Energy. Also referred to as Staff
Augmentation Contractor.
• Contractor Contractors performs specific work activities, functions or services that •
have been outsourced for strategic and/or economic reasons. Duke
Energy provides limited oversight of contractors (pay for outcome), but
does not assign daily work activities. Also referred to as Turnkey
Contractor.
DOJ United States Department of Justice
DPS Duke Production System is an iterative process of continual planning,
learning, and adjusting activities to meet strategic objectives. Critical
elements include leveraging ideas and input from employees closest to the
work, and utilizing visual tools to ensure the status of activities and
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August 2016 Duke Energy EHSMS Manual
transparent. The A3 process in EHS is used as a framework to structure
DPS activities as follows: Define True North, Goals, Targets, "Plan", "Do",
"Check", and "Act/Adjust".
ECOC Enterprise Crisis Operations Center is located in Charlotte at South Tryon
building where emergency personnel assemble in the event where an
Enterprise crisis has been declared and where crisis management would
be coordinated to maintain business function.
Executive Environmental Governance Board (EEGB) serves in an advisory
EEGB and governance capacity for internal environmental policy development,
and provides a forum to identify, review and discuss environmental risks,
anticipated and emerging laws and regulations, environmental risk
mitigation strategies, industry trends, company metrics and trends,
significant compliance issues, environmental initiatives and lessons
learned.
Employee Development and Qualification Program is a common platform
EDQP for employee training and development which uses a performance based
qualification system which includes knowledge acquisition and actual skills
demonstration.
EHS Environmental, Health, and Safety
EHSMS Environmental, Health, and Safety Management System
Employee Duke Energy defines an employee as a regular full-time employee, regular
part-time employee, temporary full-time employee, temporary part-time
employee, intern and college co-op as identified in the Duke Energy
Employment policy, but excluding contingent workers and other non-
employees of Duke Energy.
EPA US Environmental Protection Agency
H&S Health and Safety
HSPC Duke Energy's Health & Safety Performance Council provides governance
and oversight for internal health and safety policy development, and
provides a forum to identify, review and discuss health and safety risks,
anticipated and emerging regulations, hazard mitigation strategies, industry
trends, significant compliance issues, health and safety initiatives and
lessons learned.
ISO The International Organization for Standardization (ISO) sets international
consensus standards on a number of topics, including environmental
management systems (ISO 14001), using a defined, internationally-
accepted process.
KPI Key Performance Indicator is a type of performance measurement used to
track performance, evaluate the success of an organization in achieving its
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1
August 2016 Duke Energy EHSMS Manual
`'' initiatives, and drive corrective action where needed.
' KTL Keys to Life is a fatality and serious injury prevention strategy based on the
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identification, evaluation, and control of high risk hazards known to cause v.
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OHSAS Occupational Health and Safety Assessment Series is a British Standards
Institute initiative that includes the publication of the well-regarded OHSAS k,e.
-;: 18001 standard on occupational health and safety management systems. €;r'
,, * OSHA US Occupational Safety and Health Administration
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1, PSM Process Safety Management
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Senior Leadership The members of the Senior Management Committee and the Executive
Leadership Team
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`z. SPCC Spill Prevention, Control, and Countermeasure
Sustainability Sustainability at Duke Energy means doing business in a way that is good ,.
for people, planet and profits.
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Page 41 of 46
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. APPENDIX II - MAPPING TO INTERNATIONAL STANDARDS q..A,
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x The Duke Energy EHSMS Manual requirements have been mapped to several consensus standards:
ISO 14001:2015, OHSAS 18001:2007, and ANSI/AIHA Z10-2005. The results can be found in the Wi
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.` attached tables. This high-level mapping shows that the Duke EHSMS touches on every general
`. requirement outlined in each of these standards. E
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:r'.'„�jx 4J XE* �_.' c '_. a'E,r" 7,F isk

Duke Energy EHSMS Alignment with ISO 14001:2015
ISO 14001:2015 Requirement Duke Energy EHSMS E
Est Manual Section
4 Context of the Organization
4.1 Understanding the organization and its context II, 2a, 2b
4.2 Understanding the needs and expectations of interested parties 2a, 2b, 2c, 6c
4.3 Determining the scope of the environmental management
system
4.4 Environmental management system I, II, IV, V
5 Leadership
5.1 Leadership and commitment IV, la, 1c, 5c
5.2 Environmental policy II, 1 b
5.3 Organizational roles, responsibilities and authorities IV, lc
6 Planning
6.1.1 Actions to address risks and opportunities (General) I, II, IV, V
6.1.2 Environmental aspects 2a
6.1.3 Compliance obligations 2b
6.1.4 Planning action 2a, 2b, 2c, 4b, 5a, 5b, 5c
6.2.1 Environmental objectives 2c
6.2.2 Planning actions to achieve environmental objectives 2c
7 Support
7.1 Resources 6a
7.2 Competence 6b
7.3 Awareness lb, 3a, 3e, 6b, 6c
7.4.1 Communication (general) 6c
7.4.2 Internal communication 6c
7.4.3 External communication 6c
7.5.1 Documented information (general) 6d
7.5.2 Creating and updating 6d
7.5.3 Control of documented information 6d
8 Operation
8.1 Operational planning and control 3a, 3b, 3c, 3e
8.2 Emergency preparedness and response 3d
9 Performance Evaluation
9.1.1 Monitoring, measurement, analysis and evaluation (general) 3b, 4a, 4b
9.1.2 Evaluation of compliance 4a, 4b
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Duke Energy EHSMS Alignment with ISO 14001:2015 ,,,;'i
ISO 14001 2015 Requirement ,,� �I � Duke Energy EHSMS • 71
.)..434 t, rAr ' Manual Section
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9.2.1 Internal audit(general) 4b
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10 Improvement 1 a
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10.1 Improvement (general) 5b, 5c
10.2 Nonconformity and corrective action 4a, 4b, 5a, 5b • ,,
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Duke Energy EHSMS Alignment with OHSAS 18001:2007
OHSAS 18001:2007 Requirement Duke Energy EHSMS;,-
. • &�A 'K Manual Section ,
4.2 OH&S Policy
4.2 OH&S policy III, la, lb
4.3 Planning
4.3.1 Hazard identification, risk assessment and determining 2a
controls
4.3.2 Legal and other requirements 2b
4.3.3 Objectives and programs 2c, 4a, 5c
4.4 Implementation and Operation
4.4.1 Resources, roles, responsibility, accountability and authority IV, 1c, 6a
4.4.2 Competence, training and awareness 6b, 6c
4.4.3.1 Communication 3e, 6c
4.4.3.2 Participation and consultation 3e, 6c
4.4.4 Documentation 6d
4.4.5 Control of documents 6d
4.4.6 Operational control 3a, 3b, 3c, 3e
4.4.7 Emergency preparedness and response 3d
4.5 Checking
4.5.1 Performance measurement and monitoring 3b, 4a
4.5.2 Evaluation of compliance 4a, 4b
4.5.3.1 Incident investigation 4a
4.5.3.2 Nonconformity, corrective and preventative action 4a, 4b, 5a, 5b
4.5.4 Control of records 6d
4.5.5 Internal audit 4b
4.6 Management Review
4.6 Management review 5c
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Duke Energy EHSMS Alignment with ANSI/AIHA Z10-2005
ANSI/AIHA Z10-2005 Requirement '- ; Duke Energy EHSMS
2
Manual Section
3 Management Leadership and Employee Participation
3.1.1 OH&S management system I, Ill, IV V
3.1.2 Policy III, 1 b
3.1.3 Responsibility and authority IV, 1c
3.2 Employee participation 6c
4 Planning
4.1.1 Initial review 4b
4.1.2 Ongoing review 4a, 4b, 5b, 5c
4.2 Assessment and prioritization 2a, 5a
4.3 Objectives 2c
4.4 Implementation plans and allocation of resources 2c, 6a
5 Implementation and Operation
5.1.1 Hierarchy of controls 2a, 3a
5.1.2 Design review and management of change 3c
5.1.3 Procurement 3c
5.1.4 Contractors 3e
5.1.5 Emergency preparedness 3d
5.2 Education, training and awareness 3e, 6b
5.3 Communication 6c
5.4 Document and record control process 6d
6 Evaluation and Corrective Action
6.1 Monitoring and measurement 4a, 4b
6.2 Incident investigation 5a. 5b
6.3 Audits 4b
6.4 Corrective and preventive actions 5a
6.5 Feedback to the planning process 2b, 5b, 5c
7 Management Review
7.1 Management review process 5c
7.2 Management review outcomes and follow up 5c
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