20150041 Ver 1_Attach C Riverbend Excavation Plan_20150224

(n DUKE
ENERGY
November 13, 2014
John E. Skvarla, III
Secretary
North Carolina Department of Environment & Natural Resources
Mailing: 1636 Mail Service Center
217 W. Jones Street
Raleigh, NC 27699 -1636
Dear Secretary Skvarla:
Senior Vice President
Ash Basin Strategy
550 South Tryon Street
DEC 22C
Charlotte, NC 28202
Mailing Address:
P.O. Box 1321
Charlotte, NC 28201
0. 704.382.4371
As requested in the letter from the North Carolina Department of Environment and Natural Resources
(NC DENR) to Duke Energy dated August 13, 2014, Duke Energy is submitting the attached Coal Ash
Excavation Plans for Riverbend Steam Station, Dan River Steam Station, L.V. Sutton Electric Plant, and
Asheville Steam Electric Generating Plant.
In general, these Excavation Plans cover the first 12 —18 months (Phase 1) of ash basin excavation
activities, including site preparation, ash basin preparation, the initiation of basin dewatering, and ash
removal from the basins. These plans will normally be updated and submitted to NC DENR annually or
earlier as required by Subsequent Phase(s). These plans also represent the activities necessary to
satisfy the requirements outlined in Sections 3(b) and 3(c) Subparagraph 1 &2 of the Coal Ash
Management Act of 2014.
Each Excavation Plan details what Duke Energy considers to be the necessary permits to begin work or
facilitate subsequent phases of work. Integral to the success of the Excavation Plans is the timely receipt
of permits, including industrial stormwater, National Pollutant Discharge Elimination System, landfill,
structural fill and mine reclamation permits where applicable.
The objective of these excavation efforts is to achieve ash basin closure in a reasonable, prudent, and
cost effective manner. The initial phases of these Excavation Plans will incorporate off -site transportation
and disposition options, which are generally more costly than the utilization of on -site, lined landfills. Initial
use of offsite solutions is necessary for the Company to meet the deadlines prescribed in the Coal Ash
Management Act of 2014 for High Priority sites. Timely receipt of landfill permits will enable the Company
to expeditiously transition from more costly off -site storage locations at sites where these landfills are
practical.
We are prepared to implement these Excavation Plans upon receipt of NC DENR written approval of
these plans and necessary permits.
cer
n Elnitsk
Senior Vice President

Riverbend Steam Station
Coal Ash Excavation Plan
DUKE
... ENERGY.

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
Table of Contents
I.
Statement of Purpose ..................................................................................... ..............................2
II.
General Facility Description ........................................................................... ..............................4
III.
Project Charter ................................................................................................. ..............................7
IV.
Critical Milestone Dates .................................................................................. ..............................9
V.
Level 1 Schedule ............................................................................................ .............................10
VI.
Erosion and Sedimentation Control Plan ................................................... .............................11
VII.
Dewatering Plan ............................................................................................. .............................11
VIII.
Proposed Location(s) for Removed Ash ..................................................... .............................12
IX.
Transportation Plan ........................................................................................ .............................14
X.
Environmental Permitting Plan ..................................................................... .............................16
XI.
Contracting Strategy ...................................................................................... .............................21
XII.
Environmental, Health, and Safety Plan ..................................................... .............................21
XIII.
Communications Plan .................................................................................... .............................21
XIV.
Glossary ........................................................................................................... .............................23
XV.
Reference Documents ................................................................................... .............................25
1

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
Statement of Purpose
Duke Energy Carolinas, LLC (Duke Energy or the Company) is required by Section 3(b)
of the Coal Ash Management Act of 2014 to close in accordance of Section 3(c) the
coal combustion residuals (CCR) surface impoundments located at the Riverbend
Steam Station, National Pollutant Discharge Eliminations System Permit No.
NC0004961 Gaston County (Riverbend) as soon as practicable, but not later than
August 1, 2019. Further, by letter to Duke Energy dated August 13, 2014, North
Carolina Department of Environment and Natural Resources (NC DENR) requested that
Duke Energy submit coal ash excavation plans for inactive coal ash impoundments at
Riverbend no later than November 15, 2014 (NC DENR Letter).
This Coal Ash Excavation Plan (Plan) represents Phase I and other Subsequent
Phase(s) activities to satisfy the closure requirements outlined in Sections 3(b) and 3(c)
sub paragraph 1 &2 of the Coal Ash Management Act of 2014 and the requests set forth
in the NC DENR Letter.
In general, the Plan covers the first 12 — 18 months of ash basin excavation activities,
including the initiation of basin dewatering, ash stack removal, and any other permitted
ash removal activities within the ash basins and /or Cinder Pit Area. These activities
may include decanting ash within the ash basin system. The areas within the Ash Basin
include the Primary Ash Basin, the Secondary Ash Basin, and the Ash Stack.
For Subsequent Phase(s), this document will be revised for any modifications to the
Plan for the site. The Plan will be updated and submitted to NC DENR annually or
earlier as required by Subsequent Phase(s).
The NC DENR letter specifically requests that the Plan include 1) a schedule for soil
and sedimentation erosion control measures, 2) dewatering, and 3) the proposed
location(s) of the removed ash. These requirements are found in Section V. Level 1
Schedule, Section VI. Erosion and Sedimentation Control Plans, Section VII.
Dewatering Plan, and Section VIII. Proposed Location(s) for Removed Ash.
The Plan covers some of the work required by Sections 3(b) and 3(c) of the Coal Ash
Management Act of 2014 (Session Law 2014 -122) (Coal Ash Act, or Act). The Act
requires the closure of the ash basins as soon as practicable, but no later than August
1, 2019. However, the Act contains no requirement for the submittal of an excavation
plan of the kind presented here. Thus, while the formulation, submittal, and review of
this Plan will assist in Duke Energy's work to close the ash basin, its ultimate approval is
an action not specifically required by statutory, regulatory or other applicable authority.
Additionally, it may become necessary for the Company to modify the Plan to address
other legal requirements or factors that develop during ash basin excavation. Any
VA

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
changes will be included in annual updates to the Plan that Duke Energy will submit to
NC DENR.
The precise scope of work in excavating the ash basins will be determined by applicable
laws, rules, permits, and approvals that control the activities to be performed under the
Plan. For example, the United States Environmental Protection Agency (EPA) is
considering issuing rules regarding the management of coal ash (proposed EPA Coal
Ash Rules). Similarly, the water quality permit for the discharge from the Pond (National
Pollutant Discharge Elimination System Permit No. #NC0004961 Gaston County) or its
reissuance or amendment ( NPDES Permit) could contain terms that control or affect the
scope of that work. NC DENR filed legal cases in Superior Court (NC DENR Cases),
which could be resolved through decision or settlement. NC DENR also sent Duke
Energy a Notices of Violation (NOVs) regarding surface water and groundwater quality
issues at the Plant.
All of the above (Coal Ash Act, NC DENR Letter, NPDES Permit, NC DENR Cases,
NOVs, and the proposed EPA Coal Ash Rules) are illustrative of actions that could
potentially affect the precise scope of the work to be performed under the Plan. As a
consequence, neither the submittal of this Plan nor its approval by NC DENR should be
taken as requiring actions different from other such applicable requirements. Thus,
Duke Energy submits this Plan to NC DENR based on the understanding that it may be
necessary to make changes in the Plan in the future to reflect any such actions and
reserves the right to make such changes after NC DENR's approval of the Plan.
3

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
General Facility Description
Riverbend is located off of Horse Shoe Beach Road near the town of Mt. Holly in
Gaston County, North Carolina, on the south bank of the Catawba River. The seven -
unit station began commercial operation in 1929 with two units and then expanded to
seven by 1954. At its peak, the generating facility had a capacity of 454 megawatts. As
of April 1, 2013, all of the coal -fired units were retired.
The CCR from Riverbend's coal combustion operations was historically processed in
the ash basin system located on the northeast of the property adjacent to the Catawba
River. The discharge from the ash basin system is permitted through Outfall #002 to
the Catawba River in the Catawba River Basin by NC DENR's Division of Water
Resources (DWR) under the National Pollutant Discharge Elimination System ( NPDES)
Permit # NC0004961. Currently, Riverbend is being decommissioned, and no active
ash placement or sluicing is occurring within the ash basin system.
Ash Basin System
The ash basin system was an integral part of the station's NPDES permitted wastewater
treatment system, which predominantly received inflows from the ash removal system,
station yard drain sump, and stormwater flows. During station operations, inflows to the
ash basin were highly variable due to the cyclical nature of station operations. The
current ash basin system consists of a Primary Ash Basin cell (west side) and a
Secondary Ash Basin cell (north side), which are separated by an intermediate dam.
For the purpose of stormwater management, the Ash Stack is also within the ash basin
system.
The ash basin system is located approximately 2,400 feet to the northeast of the power
plant, adjacent to the Catawba River, as shown on Figure 1. The Primary Ash Basin
cell is impounded by an earthen embankment dam, referred to as Primary Dam
#GASTO -97, located on the west side of the Primary Ash Basin cell. The Secondary
Ash Basin cell is impounded by an earthen embankment dam, referred to as Secondary
Dam #GASTO -98, located along the northeast side of the Secondary Ash Basin cell.
Originally, the ash basin at Riverbend consisted of a single -cell basin commissioned in
1957. It was expanded in 1979 to its current configuration. In 1979, the original single
basin was divided by constructing a divider dam (Intermediate Dam #GASTO -99) to
form two separate cells (Primary Ash Basin and Secondary Ash Basin). This
modification improved the original pond's overall ability for suspended solids removal.
The Intermediate Dam was built over sluiced ash to a crest of 730 feet. At the same
time, the Secondary Dam crest elevation remained at 720 feet. At present, the Primary
Ash Basin and the Secondary Ash Basin are estimated to contain approximately 2.1
million and 700 thousand tons of CCR, respectively.
I'I

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
The inflows from the ash removal system and the station yard drain sump are directed
through sluice lines into the Primary Ash Basin cell. The discharge from the Primary
Ash Basin to the Secondary Ash Basin is through a concrete discharge tower located
near the divider dam. The surface area of the Primary Ash Basin is approximately 41
acres with an approximate maximum pond elevation of 724 feet above mean sea level.
The surface area of the Secondary Ash Basin is approximately 28 acres with an
approximate maximum pond elevation of 714 feet above mean sea level. The full pond
elevation of Mountain Island Lake is approximately 647 feet above mean sea level.
Although the station is retired, stormwater and wastewater effluent from other non -ash-
related station flows to the ash basin are discharged in compliance with the station's
NPDES permit to Catawba River through a concrete discharge tower located in the
Secondary Ash Basin. The concrete discharge tower drains through a 30 inch diameter
corrugated metal pipe (CMP) into a concrete -lined channel. The channel extends from
the Secondary Ash Basin to an NPDES Outfall #002 that discharges to the Catawba
River. The Secondary Ash Basin elevation is controlled by the use of concrete stop
logs.
Ash Stack
An ash fill deposit, known as the "Ash Stack ", was constructed from ash removed from
the Primary and Secondary Ash Basins during basin clean -out projects. The Ash Stack
was utilized for the ash basin cleanouts periodically to prolong the life of the ash basins.
The Ash Stack is a 29 acre area located south of the Primary Ash Basin and is
estimated to contain 1.5 million tons of CCR. The Ash Stack was constructed during
two ash basin clean -outs; the last recorded ash basin cleanout project was in 2007.
The Ash Stack area currently has a 1.5 — 2.0 ft. soil cover and vegetation that has been
maintained following the last deposition in this area. For the purpose of water
management, the stormwater run -off from the Ash Stack area is routed to the ash basin
system.
Cinder Pit And Other Identified Ash Storage Areas
Prior to construction of the ash basin, bottom ash (cinders) were deposited in a primarily
dry condition in the "Cinder Pit" and other areas near the cinder pit and coal pile. The
Cinder pit is approximately 13 acres and is located in a triangular area northeast of the
coal pile and northwest of the rail spur (See Figure 1). This area was utilized for
storage of ash material at the station prior to the installation of precipitators and a wet
sluicing system. The Cinder Pit contains predominantly dry cinders and is currently
covered with dense vegetation. The Cinder Pit is estimated to contain 300 thousand
tons of CCR.
5

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
RIVERBEND STEAM STATION 4
GASTGN COUNTY, NORTH CAROLIPIA w '•'
DUKE
ENERGY;.
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Figure 1: Riverbend Steam Station
N

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
III. Project Charter
As a further commitment, the Company has formed an internal team, the Ash Basin
Strategic Action Team (ABSAT). This team is dedicated to strengthening and executing
a comprehensive strategy for increased oversight and closure of all of the Company's
ash basins.
Dewatering of the ash basins and the removal of ash from the site will be performed
within project phases: Phase I and Subsequent Phase(s). Required permits for each
phase are set forth in Section X of this Plan. Phase I will include the initial removal of
ash from the Ash Stack, begin bulk dewatering, and complete any other subsequent
permitted activities. The excavation will begin with the approval of this Plan by NC
DENR and the receipt of final permits.
In addition, a dewatering plan for the ash basins has been drafted and, if approved by
NC DENR, bulk dewatering will be expedited during the initial phase of work. Duke
Energy has submitted an application to modify its NPDES wastewater permit to include
controls to be implemented during dewatering activities.
During Phase I, the Company will continue to perform the pre- construction and planning
activities for the Subsequent Phase(s). These activities include project planning,
development of new ash disposition options, and completion of additional required
permitting that may be necessary for the ash removal from the ash basins and Cinder
Pit. Knowledge and opportunities for program improvement obtained during Phase I of
the project will be applied to the Subsequent Phase(s).
Project Charter Objectives
Phase I Objectives
1. Initiate the removal of ash from the Riverbend site
2. Plan activities for the Subsequent Phase(s), including development of option(s)
for proposed ash disposal or beneficial reuse location(s)
3. Validate production rates to meet project requirements
4. Gain knowledge and opportunities for program improvement that can be applied
to the Subsequent Phase(s)
Subsequent Phase(s) Objectives
1. Dewater Ash Basins
2. Remove all remaining ash from the Ash Stack, Cinder Pit, Primary Ash Basin and
Secondary Ash Basin
3. Submit permit applications for next Subsequent Phase (if applicable)
7

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
Project Charter Scope
Phase I Scope
1. Finalize end location(s) for removed ash and obtain all required permits
2. Obtain all applicable permits for work in Phase I
3. Install site erosion and sedimentation control measures
4. Begin site preparation activities, including mobilization
5. Excavate and transport approximately 1 million tons of ash from the Ash Stack to
Roanoke Cement Company and Brickhaven Mine
6. Engineer plan to stop water inputs into the ash basins
7. Initiate rerouting of inflows to the ash basins
8. Begin dewatering the Primary and Secondary Ash Basins
9. Plan activities for Subsequent Phase(s) and submit an updated Plan
10. Begin site preparation activities for the Subsequent Phase(s)
11. Assess, including delineation, the potential remediation efforts in the Cinder Pit
12. Submit and /or obtain all remaining required permit applications for ash removal
activities for Subsequent Phase(s)
13. Identify and /or develop additional location(s) for removed ash for Subsequent
Phase (if applicable), including obtaining all required permits
Subsequent Phase(s) Scope
1. Obtain all remaining required permits for next Subsequent Phase for ash removal
activities (if applicable)
2. Finalize and /or develop additional location(s) for removed ash (if applicable) and
obtain all required permits
3. Complete activities to stop basin inflows
4. Complete basin dewatering
5. Excavate and transport the remaining ash from Riverbend to an approved landfill
or structural fill location
6. Complete closure activities as outlined in Sections 3(b) and 3(c) subparagraphs
1 &2 of the Coal Ash Management Act of 2014
E.3

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
IV. Critical Milestone Dates
Critical Milestones within the Plan are summarized in the table below. These
milestones have been added to the Level 1 Schedule.
MILESTONES
Submit Excavation Plan
• LATER THAN DATE
November 15, 2014
Complete comprehensive engineering review
November 30, 2014
Excavation Plan Approval
February 17, 2015
Industrial Stormwater Permit
March 5, 2015
Commence work — ash removal
Final permit approval + 60 Days
Submit Updated Excavation Plan — Subsequent
Phase (s)
December 31, 2015
Eliminate stormwater discharge into impoundments
December 31, 2018
Impoundments closed per Sections 3(b) and 3(c) of
the Coal Ash Management Act of 2014
August 1, 2019
M

Riverbend Steam Station — Coal Ash Excaw�'-:gi- r"--
November 13, 2014
V. Level 1 Schedule
Ash, Re;owtonn Project Riverbend Ash Relocation Project Pnnt Date 10-18-14 08:47
Excavation Plan Schedule
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PHASE I BULK FREE WArER 03.31}15
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Prepare 'Sbrrit Excavabon Plan 1144 -W
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ASH REMOV
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Waste Characamakn gAmplanot for Disposal
Obtan Indusral Ston,waft NPIDES Perrot
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Note: This Level 1 Schedule is a living element of this Plan. Dates and durations are based on known information on the
date of this Plan.
10

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
Erosion and Sedimentation Control Plan
The Erosion and Sedimentation Control Plan (E &SC) for the excavation of the Ash
Stack has been developed. This plan and schedule were submitted to NC DENR and
approved on July 3, 2014. The approval of this plan by NC DENR meets the
requirement outlined in the NC DENR Letter.
The approved contractor will install the E &SC measures indicated in the plan. The
Engineer of Record will review the installation prior to commencing excavation on site.
All control measures will be maintained through the project in accordance with the
E &SC.
The modification of the E &SC for the excavation of the ash basins and Cinder Pit Area
is currently under development and will be submitted as part of the Subsequent
Phase(s). Any deviations from the current E &SC for Subsequent Phase(s) are to be
approved by NC DENR prior to installation.
VII. Dewatering Plan
The Riverbend ash basins will be dewatered to facilitate the removal of ash and to
mitigate risk. Lowering the water level within each basin will improve safety factors of
the dams by reducing the driving force on the upstream face of the dam. Similarly,
dewatering will improve the physical properties of the retained ash, making it less
susceptible to flow in the event of an unexpected dam failure.
An Engineered Dewatering Plan for Riverbend was developed to remove the following
water from the ponds:
Sequence
1. Primary Ash Basin — Removal of free water
Based on data from June 2014, the Primary Ash Basin contains approximately
2.1 million gallons of free water. The free water in the Primary Ash Basin will be
pumped to the Secondary Ash Basin to minimize hydraulic pressure on the
intermediate dam. The maximum free water drawdown rate will be one foot over
seven days. Following free water removal, accumulated stormwater will be
removed at a maximum rate of 2 feet over 1 day.
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Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
2. Primary Ash Basin — Removal of water 10 feet below top of ash
After removal of free water, the entrapped water level within the Primary Ash
Basin will be lowered by approximately 10 feet. To achieve the desired water
level, a trench approximately 15 — 20 feet deep will be constructed in the Primary
Basin just inside the Primary Ash Basin dam to draw down entrapped water in
the vicinity of the dam.
3. Secondary Ash Basin— Removal of free water
Based on data from June 2014, the Secondary Ash Basin contains approximately
101 million gallons of free water. The maximum free water drawdown rate will be
one foot over seven days. Following free water removal, accumulated
stormwater will be removed at a maximum rate of 2 feet over 1 day.
VIII. Proposed Location(s) for Removed Ash
Phase I of the Plan will include the excavation and removal of approximately 1.0 million
tons of ash from the Ash Stack. Subsequent Phase(s) will remove the remaining ash at
the site. Ash removed from the site will be transported by the contractor to properly
permitted facilities. The ash placement location will be properly managed and
maintained to ensure environmental compliance with all applicable rules and
regulations.
Phase /: Storage Sites
For Phase I, several sites have been identified for beneficial reuse. The primary option
provides a solution for Phase I and/ or Subsequent Phase(s). These sites include the
Roanoke Cement Company in Troutville, Virginia and the Brickhaven Mine in Moncure,
North Carolina.
Disposition
Roanoke Cement Company
Troutville, VA
115,000 Cement Component
Brickhaven Mine
Moncure, NC
885,000 Structural Fill
Roanoke Cement Company
The Roanoke Cement Company (RCC) is located at 6701 Catawba Road, Troutville,
Virginia. The material hauled from Riverbend to RCC will be used primarily to produce
fly ash modified concrete. The practice of adding fly ash to concrete has been accepted
`V

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
since the 1970's and will be in accordance with ASTM standards, which provides
standards and specification for the production at the RCC facility.
Brickhaven Mine
The mine is located near the city of Moncure in Chatham County of North Carolina. The
mine resides on approximately 299 acres. Its primary mined minerals are clays. Ash
will be transported to the mine as a reclamation project. The Brickhaven Mine will
comply with the requirements set forth in Sections 4(b) and (c) of the Coal Ash
Management Act of 2014.
Contingent Plan. Ash Disposition Sites
For a Contingent Plan, the RCC facility will be utilized as described above. In the event
of any issues with accepting ash at the Brickhaven Mine, the Sanford Mine has been
determined as a suitable alternative site. All necessary steps will be taken to assure
that the Sanford Mine is ready to accept ash in the event of any issues at the
Brickhaven Mine.
..
Roanoke Cement Company
Troutville, VA 115,000
Cement Component
Sanford Mine
Sanford, NC 885,000
Structural Fill
Sanford Mine
The Sanford Mine is located in Sanford, North Carolina. Ash will be transported from
Riverbend to the Sanford Mine as a reclamation project.
Structural Fill Alternative
In the event the structural fill options are not available, the Anson County Landfill, a
permitted solid waste landfill, has been identified as the alternate location. The Anson
County Landfill is located in Polkton, NC. Material will be transported by rail.
13

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
Subsequent Phase(s): Ash Disposition Sites
The project team will utilize lessons learned from Phase I to develop an off -site disposal
strategy and /or alternative beneficial reuse site(s) that will provide the improvements
below.
• Provide a reliable, long -term, cost effective, solution for ash designated for
removal
• Develop a supplier diverse Program to drive innovation and competition
• Establish performance baselines and the system to optimize pickup, transport,
drop -off and reuse
IX. Transportation Plan
Ash will be transported from the site via rail car and /or highway trucks to the off -site
facilities. Transportation will be conducted by approved transporters. Drivers and
trucks will meet Department of Transportation (DOT) and other applicable federal, state,
and local regulations. All drivers will follow all DOT regulations pertaining to the trucking
including DOT bridge laws.
Phase 1: Transportation
For Phase I, approximately 10,000 tons per month of ash will be excavated and hauled
to the RCC facility in the first three to four months via truck (see Figure 2). This tonnage
equates to approximately 15 to 22 truckloads per day. After this start -up period,
throughput will be increased by approximately 50,000 to 55,000 tons per month, which
will be moved to the Brickhaven Mine via truck (see Figure 3). The total tonnage of
60,000 to 65,000 tons per month equates to 120 to 142 truckloads per day.
M

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
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Figure 2: Typical Truck Route to Roanoke Cement Company Facility
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Norwood Southern Dines.
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Figure 3: Typical Truck Route to Brickhaven Mine
Plans are being made to design and install a rail loading system at Riverbend that
would transport ash to the Brickhaven Mine. Once rail loading /unloading systems have
been installed and established at Riverbend and at the Brickhaven Mine, a combination
of rail and truck or all rail can be utilized to transport ash to the two locations. By
utilizing a combination of truck and rail or all rail, an estimated total of 160,000 to
165,000 tons of ash can be transported per month. The schedule estimates that ash
can start being hauled by rail during the seventh month.
15

Riverbend Steam Station — Coal Ash Excav-�finn Plan
November 13, 2014
For Phase I excavation and hauling, a typical 9 -hour work shift with two shifts per day
for five days per week will be employed. This typical schedule may be utilized or
modified in Subsequent Phase(s) to meet the August 1, 2019 compliance date.
b u: ria•:
1 �
Durham
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Figure 4: Typical Truck Route to Sanford Mine
Increase Rail Opportunity
CJJ
If the opportunity of transporting more ash by rail occurs, the amount sent to the RCC
facility may be reduced and the amount sent to the structural fill options may be
increased.
Subsequent Phase(s): Transportation
The transportation plan and any other options will be reviewed and could be amended
in Subsequent Phase(s) to enhance the excavation process and objectives.
X. Environmental Permitting Plan
Phase 1
Phase 1 will include initiating excavation and removal of ash from the Ash Stack.
Implementation for Phase I can begin once the permitting for Phase I is in place,
although different permitting may be necessary prior to initiating Subsequent Phase
work. Permitting activities for Subsequent Phase(s) will be included in Phase I.
Through this Excavation Plan approval process, Duke Energy is seeking to confirm that
all necessary approvals have been identified. The Excavation Plan is intended to
authorize the excavation and movement of ash once the identified permits have been
obtained.
16

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
Excavation of ash creates potential for stormwater impacts. The facility holds an
approved Erosion & Sedimentation Control Plan and associated Construction
Stormwater Permit approval for ash stack removal. NC DENR has indicated an
industrial stormwater permit may also be needed. Based on this representation from
NC DENR, Duke Energy has applied for an NPDES industrial stormwater permit to
support ash removal at the site. A stormwater pollution prevention plan (SWPPP)
incorporating best management practices (BMPs) will be created. Future modifications
to the permit /plan will be managed as necessary.
NC DENR has recently indicated that modification of the NPDES wastewater permit
may be required to initiate removal of free water from inactive ash basins. Duke is
submitting additional information to NC DENR for its consideration to support
incorporating dewatering requirements into the Company's pending NPDES permit
application. The Company is working with the United States Environmental Protection
Agency (EPA) and NC DENR with a goal of identifying the regulatory framework that will
allow the removal of free - standing water from inactive basins to move forward.
There are no jurisdictional wetlands /streams associated with the removal of the Ash
Stack or Primary or Secondary Ash basins in Phase I. Future wetland /stream impacts
and jurisdictional determinations will be managed through the US Army Corps of
Engineers (ACOE) with particular attention paid to the difference between jurisdictional
wetlands /streams under Section 404 and those arising from Section 402 waters.
Before creation of new mine reclamation structural fills, an individual structural fill permit
will need to be obtained by the mine reclamation project owner /operator. It is
anticipated that the mining permit will be transferred from the existing mine owner to a
mine reclamation contractor. Once the permit is transferred, the mine reclamation
contractor will submit an individual structural permit application and mine reclamation
plan to the Division of Mining. It is anticipated that the Division of Mining will then
forward the reclamation plan to the Division of Water Resources, Division of Waste
Management, and other divisions as necessary for comments. Subject to any changes
from Division of Mining, the revised reclamation plan would be approved and an
individual Structural Fill Permit will be issued.
No information currently exists to indicate that the Riverbend ash should be treated as a
DOT hazardous material shipped via truck or rail.
Subsequent Phase(s) will include dewatering (once NPDES permit modification is
complete), and continued excavation and removal of ash from the Ash Stack, Primary
and Secondary Ash Basins and the Cinder Pit area.
1i VA

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
Future jurisdictional determinations will be managed through the US Army Corps of
Engineers with particular attention paid to the difference between jurisdictional
wetlands /streams under Section 404 and those arising from Section 402 waters. Any
Section 404 individual permitting will require Section 401 Water Quality Certification by
NC DENR.
If used, before shipping ash to a third -party Subtitle D landfill, waste characterization
and approval will be completed. All necessary Dam Safety approvals will be obtained to
cover activities on or around jurisdictional dams. Breaching of the dams will require
Dam Safety approval. Any impacted wells or piezometers will be properly abandoned
and dispositioned with NC DENR. Fugitive dust will be managed to mitigate impacts to
neighboring areas. Impacts to threatened and endangered species will be avoided.
No additional site - specific or local requirements have been identified.
M;

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
Phase l Permit Matrix
19
Milestone /Target
Media
Permit
Date
Reasoning
Excavation of ash creates potential for
stormwater impacts. The facility holds
an approved Erosion & Sedimentation
Control Plan and associated
Industrial Stormwater NPDES
Construction Stormwater Permit
Permit
March 5, 2015
approval for ash stack removal. NC
DENR has indicated an industrial
stormwater permit may also be
needed. Duke has applied for this
permit. A SWPPP incorporating BMPs
will be created.
Water
NC DENR has indicated dewatering
activities, including free water removal,
Wastewater NPDES Permit —
may require NPDES wastewater
Minor Modification
March 27, 2015
permit modification. Based on this,
Duke is submitting proposed
dewatering permit conditions in its
pending NPDES permit application.
Jurisdictional Wetland and Stream
There are no identified jurisdictional
Impacts /404 Permitting and 401
N/A
wetland /stream impacts in Phase I.
WQC
Hauling and excavation activities must
not impact a jurisdictional dam or dike.
Activities are initially staying 50 feet
away from the jurisdictional dike.
Dam Safety Approvals
May 29, 2015
Removing ash from the Primary and
Secondary Ash Basins will have to be
reviewed with Dam Safety. Breaching
Waste
of dike will require Dam Safety
approval.
Mine Reclamation Owner /Operator to
Individual Structural Fill Permit
March 27, 2015
obtain a structural fill permit as set
forth in Subpart 3 of Part 21 of Article 9
of the Coal Ash Management Act
Site specific
Local
Nuisance /Noise /Odor /Other
N/A
No local nuisance requirements
Ordinances
Requirements including DOT and
identified.
FERC Requirements
19

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
Subsequent Phase(s) Permit Matrix
20
Milestone /Target
Media
Permit
Date
Reasoning
Excavation of ash creates potential for
stormwater impacts. The facility holds
an approved Erosion & Sedimentation
Control Plan and associated
Industrial Stormwater NPDES
Construction Stormwater Permit
Permit
March 5, 2015
approval for ash stack removal. NC
DENR has indicated an industrial
stormwater permit may also be
needed. Duke has applied for this
permit. A SWPPP incorporating BMPs
will be created.
NC DENR has indicated dewatering
activities, including free water removal,
Water
may require NPDES wastewater permit
Wastewater NPDES Permit —
August 28, 2015
modification. Based on this, Duke is
Major Modification
submitting proposed dewatering permit
conditions in its pending NPDES
permit application.
Identify if project scope results in
impacts to jurisdictional wetlands or
Jurisdictional Wetland and Stream
streams. Obtain JD and pursue 404
Impacts /404 Permitting and 401
August 28, 2015
permit for impacts from the ACOE.
WQC
Also, 404 permits are required for
working below the ordinary high water
mark. If Federal individual permitting is
required, obtain 401 WQC.
Mine Reclamation Owner /Operator to
Individual Structural Fill Permit
March 27, 2015
obtain a structural fill permit as set
forth in Subpart 3 of Part 21 of Article 9
of the Coal Ash Management Act
Waste
Hauling and excavation activities must
not impact a jurisdictional dam or dike.
Dam Safety Approvals
August 28, 2015
Activities are initially staying 50 feet
away from the jurisdictional dike.
Breaching of dike will require Dam
Safety approval.
Site specific
Local
Nuisance /Noise /Odor /Other
N/A
No local nuisance requirements
Ordinances
Requirements including DOT and
identified.
FERC Requirements
20

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
XI. Contracting Strategy
The Ash Management Program strategy is to engage multiple contractors, to drive
competition, system wide innovation and the collection of best practices. During the
initial phase (Phase 1) of ash removal at Riverbend, L.V. Sutton, Dan River and
Asheville, the Company will award the excavation, transportation, and disposal of the
Ash to a single contractor for each site. The result may be two to three contractors, with
each contractor having responsibility for one, or more sites, working on a firm fixed per
ton price basis. The contracting strategy will shift for Subsequent Phase(s), and
potentially during Phase 1, as the Company and the selected contractors recognize
enhancements that can increase productivity or drive unit cost lower. Duke Energy's
core values of safety and quality are non - negotiable and will not be compromised in
order to increase productivity or generate cost savings.
In summary, the Company's contracting strategy will provide the most effective
combination of ash removal, transportation, disposition, and beneficial reuse options
balancing strategic intent, cost, and schedule. The health and safety of workers, the
communities, and environment will not be sacrificed to achieve these goals.
XII. Environmental, Health, and Safety Plan
Protecting workers, the public, the community, and the environment
Duke Energy is committed to the health, safety and welfare of employees, contractors
and the public; and to protecting the environment and natural resources. During all
phases of the project work, Duke Energy and its contractors will follow the Duke Energy
Safe Practices; the ABSAT Environmental, Health, and Safety (EHS) supplement
document, and any additional requirements. Occupational health and safety
expectations include oversight and continuous improvement throughout the project.
The project will include comprehensive environmental, health and safety plans
encompassing all aspects of the project work including at the plant, in transit and at the
final destination as needed. The project is committed to minimizing public and
environmental impacts.
XIII. Communications Plan
Many different external stakeholders including neighbors, government officials and
media have an interest in this project. For example, there is the potential for facility
neighbors and the general public to see or experience construction - related impacts
such as truck traffic, landscape changes, or noise. The Company is committed to
21

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
providing information by proactively communicating about the Project activities to
potentially affected parties and responding to inquiries in a timely manner.
The Project team will coordinate with Duke Energy's Corporate Communications
Department to develop a comprehensive external communications plan tailored to the
specific needs of each phase of the project.
22

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
XIV. Glossary
Term
Definition
ABSAT
Duke Energy organization acronym for Ash Basin Strategic
Action Team
Ash Basin
Synonymous with Coal Combustion Residual Impoundment. A
topographic depression, excavation, or dammed area that is
primarily formed from earthen materials; without a base liner
approved for use by Article 9 of Chapter 130A of the General
Statutes or rules adopted thereunder for a combustion products
landfill or coal combustion residuals landfill, industrial landfill, or
municipal solid waste landfill; and an Area that is designed to
hold accumulated coal combustion residuals in the form of liquid
wastes, wastes containing free liquids, or sludge, and that is not
backfilled or otherwise covered during periods of deposition.
Ash Ponds
Coal Combustion Residual stored in wet impoundments or ponds
Ash Stack
Ash storage area located at the south end of the Primary Ash
Basin
Beneficial and
Projects promoting public health and environmental protection,
Beneficial Use
offering equivalent success relative to other alternatives, and
preserving natural resources
Bottom Ash
The agglomerated, angular ash particles formed in pulverized
coal furnaces that are too large to be carried in the flue gases
and collect on the furnace walls. Bottom Ash falls through open
grates to an ash hopper at the bottom of the furnace.
Bulk Water
Water above the ash contained in the ash basin. Synonymous
with free water
Cinder Pit
Area located northeast of the Riverbend Coal Pile containing
predominately dry cinders
Coal Ash Excavation
Plan required by NC DENR letter dated August 13, 2014
Plan
including a schedule for soil and sedimentation erosion control
measures, dewatering, and the proposed location of the removed
ash
Coal Ash Management
North Carolina Session Law 2014 -122
Act of 2014
23

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
Term
Definition
Coal Combustion
Residuals, including fly ash, bottom ash, boiler slag, mill rejects,
Residuals (CCR)
and flue gas desulfurization residue produced by a coal -fired
generating unit
Decanting
The act of removing water from ash
Dewatering
The act of removing bulk and entrapped water from the ash
basin
Dewatering Plan
Engineered plan and the associated process steps necessary to
dewater an ash basin
Duke Safe Work
Document detailing the Duke Energy safety guidelines
Practices
Engineer of Record
Duke Energy or 3rd party contracted engineer responsible for
final verification of specific plan actions and documents
Entrapped Water
Flowable water below the ash surface which creates hydrostatic
pressure on the dam
Excavation Activities
Tasks and work performed related to the planning, engineering
and excavation of ash from an ash basin
Excavation Plan
Refer to Coal Ash Excavation Plan
Factor of Safety
In reference to dam safety, the ratio of the forces or moments
resisting mass movement to the forces or moments tending to
produce mass movement
Free Water
Water above the ash contained in the ash basin. Synonymous
with bulk water
Fly Ash
Very fine, powdery material, composed mostly of silica with
nearly all particles spherical in shape, which is a product of
burning finely ground coal in a boiler to produce electricity and is
removed from the plant exhaust gases by air emission control
devices.
Grading Plan
Document detailing the final elevation, drainage and lay of the
excavated area
24

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
Term
Definition
Level 1 Schedule
Schedule view that shows the main milestones to complete the
project
NPDES
National Pollutant Discharge Elimination System
NPDES Permit
A permit that regulates the direct discharge of wastewater to
surface waters
Off -Site Facility
A structural fill or mine reclamation for the long term storage of
coal combustion residuals
Permitting
Federal, state, county or local government authorizing document
Primary Ash Basin
Western cell of the Ash Basin system located at Riverbend on the
northeast side of the property (Primary Dam # GASTO -97)
Secondary Ash Basin
Northern cell of the Ash Basin system located at Riverbend on the
northeast side of the property (Secondary Dam # GASTO -98)
Work Plan
Document detailing activities to accomplish a specific task or
scope of work
XV. Reference Documents
25