20150998 Ver 1_401 Application_20151215

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Office Use Only
Corps action ID no.
DWQ project no.
Form Version 1.4 January 2009
Page 1 of 10
PCN Form — Version 1.4 January 2009
M 460
Pre -Construction <c5oVion (PCN) Form
A.
Applicant Information
1.
Processing
1 a.
Type(s) of approval sought from the Corps:
❑ Section 404 Permit ❑ Section 10 Permit
1b. Specify Nationwide Permit (NWP) number: or General Permit (GP) number:
1c.
Has the NWP or GP number been verified by the Corps?
❑ Yes ❑X No
1d.
Type(s) of approval sought from the-DWQ (check all that apply):
❑ 401 Water Quality Certification — Regular ❑X Non -404 Jurisdictional General Permit
❑ 401 Water Quality Certification — Express ❑ Riparian Buffer Authorization
1 e.
Is this notification solely for the record
because written approval is not required?
For the record only for DWQ
401 Certification:
❑ Yes ❑X No
For the record only for Corps Permit:
❑X Yes ❑ No
1f.
Is payment into a mitigation bank or in -lieu fee program proposed for
mitigation of impacts? If so, attach the acceptance letter from mitigation bank
or in -lieu fee program.
❑X Yes ❑ No
1 g.
Is the project located in any of NC's twenty coastal counties. If yes, answer 1 h
below.
0 Yes ❑ No
1 h.
Is the project located within a NC DCM Area of Environmental Concern (AEC)?
❑ Yes ❑X No
2.
Project Information
2a.
Name of project:
L.V. Sutton Steam Station - Onsite Landfill- Sutton Energy Complex
2b.
County:
New Hanover
2c.
Nearest municipality / town:
Wilmington
2d.
Subdivision name:
I'
2e.
NCDOT only, T.I.P. or state project no:
3.
Owner Information
3a.
Name(s) on Recorded Deed:
Carolina Power & Light Co..
3b.
Deed Book and Page No.
5753 2451 DEC 2 2 2015
3c.
Responsible Party (for LLC if
applicable)-
Duke Energy Progress
DENR - WATER RESOURCES
3d.
Street address:
249 Sutton Lake Road
3e.
City, state, zip:
Wilmington NC
3f.
Telephone no.:
[phone]
3g.
Fax no.:
3h.
Email address:
[e-mail]
Page 1 of 10
PCN Form — Version 1.4 January 2009

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Office Use Only:
Corps action ID no.
DWQ project no.
Form Version 1.4 January 2009
Page 1 of 10
PCN Form — Version 1.4 January 2009
Pre -Construction Notification (PCN) Form
A.
Applicant Information
1.
Processing
1 a.
Type(s) of approval sought from the Corps:
❑ Section 404 Permit ❑ Section 10 Permit
1 b.
Specify Nationwide Permit (NWP) number: or General Permit (GP) number:
1c.
Has the NWP or GP number been verified by the Corps?
❑ Yes NX No
1 d.
Type(s) of approval sought from the DWQ (check all that apply):
❑ 401 Water Quality Certification — Regular ❑X Non -404 Jurisdictional General Permit
❑ 401 Water Quality Certification — Express ❑ Riparian Buffer Authorization
1 e.
Is this notification solely for the record
because written approval is not required?
For the record only for DWQ
401 Certification:
❑ Yes X❑ No
For the record only for Corps Permit:
❑X Yes ❑ No
1f.
Is payment into a mitigation bank or in -lieu fee program proposed for
mitigation of impacts? If so, attach the acceptance letter from mitigation bankX❑
or in -lieu fee program.
Yes ❑ No
1 g.
Is the project located in any of NC's twenty coastal counties. If yes, answer 1 h
below.
❑x Yes ❑ No
1 h.
Is the project located within a NC DCM Area of Environmental Concern (AEC)?
❑ Yes ❑X No
2.
Project Information
2a.
Name of project:
L.V. Sutton Steam Station - Onsite Landfill- Sutton Energy Complex
2b.
County:
New Hanover
2c.
Nearest municipality / town:
Wilmington
2d.
Subdivision name:
2e.
NCDOT only, T.I.P. or state project no:
3.
Owner Information
3a.
Name(s) on Recorded Deed:
Carolina Power & Light Co.
3b.
Deed Book and Page No.
5753 2451
3c.
Responsible Party (for LLC if
applicable):
Duke Energy Progress
3d.
Street address:
249 Sutton Lake Road
3e.
City, state, zip:
Wilmington NC
3f.
Telephone no.:
[phone]
3g.
Fax no.:
3h.
Email address:
[e-mail]
Page 1 of 10
PCN Form — Version 1.4 January 2009

4. Applicant Information (if different from owner)
4a. Applicant is:
❑ Agent ❑ Other, specify:
4b. Name:
4c. Business name
(if applicable):
4d. Street address:
4e. City, state, zip:
4f. Telephone no.:
4g. Fax no.:
4h. Email address:
5. Agent/Consultant Information (if applicable)
5a. Name:
5b. Business name
(if applicable):
5c. Street address:
5d. City, state, zip:
5e. Telephone no.:
5f. Fax no.:
5g. Email address:
Page 2 of 10

B.
Project Information and Prior Project History
1.
Property Identification
1a.
Property identification no. (tax PIN or parcel ID):
R02300-002-001-000
1 b.
Site coordinates (in decimal degrees):
Latitude: 342999 Longitude: -77.98638
1 c.
Property size:
1,570.55 acres
2.
Surface Waters
2a.
Name of nearest body of water to proposed project:
Cape Fear River
2b.
Water Quality Classification of nearest receiving water:
2c.
River basin:
Cape Fear
3.
Project Description
3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this
application:
The project is located on DEP's existing Sutton Steam Plant facility, north of the City of Wilmington in New Hanover County, North Carolina. The land
use of the proposed site is primarily classified as "Unused Land". Lands located along the northern boundary of Sutton are classified as
"Miscellaneous Manufacturing" . The proposed site is an area designated as zoning district 1-2, Heavy Industrial District".
3b.
List the total estimated acreage of all existing wetlands on the property: 337
3c.
List the total estimated linear feet of all existing streams (intermittent and perennial) on the property: 5,460
3d. Explain the purpose of the proposed project:
The Coal Ash Management Act (CAMA) requires Duke to close the Basins in accordance with CAMA by 1 August 2019. See Attached Narrative.
3e. Describe the overall project in detail, including the type of equipment to be used:
See Attached Narrative Summary and Construction Application Report.
4.
Jurisdictional Determinations
4a.
Have jurisdictional wetland or stream determinations by the
Corps or State been requested or obtained for this property /
project (includingall prior phases) in the past?
❑X Yes ❑ No ❑ Unknown
Comments:
4b.
If the Corps made the jurisdictional determination, what type
of determination was made?
❑ PreliminaryX❑ Final
4c.
If yes, who delineated the jurisdictional areas?
Name (if known): multipole
Agency/Consultant Company: Geosyntec / AMEC
Other:
4d. If yes, list the dates of the Corps jurisdictional determinations or State determinations and attach documentation.
Jurisdictional Determination Request Submitted to Corps on 11 November 2015.
5.
Project History
5a.
Have permits or certifications been requested or obtained for
this project (including all prior phases) in the past?
❑ Yes ❑X No ❑ Unknown
5b.
If yes, explain in detail according to "help file" instructions.
6.
Future Project Plans
6a.
Is this a phased project?
❑X Yes ❑ No
6b. If yes, explain.
The Landfill construction is planed to be conducted in phases with sequencing of landfill cell construction during the Basin closure. This PCN includes
all wetlands impact associated with all phases of the landfill construction. See Attached Narrative Summary and Construction Application Report
Page 3 of 10
PCN Form — Version 1.4 January 2009

C. Proposed Impacts Inventory
1. Impacts Summary
1 a. Which sections were completed below for your project (check all that apply):
❑X Wetlands ❑ Streams — tributaries ❑ Buffers ❑ Open Waters ❑ Pond Construction
2. Wetland Impacts
If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted.
2a.
Wetland impact
number
Permanent (P) or
Temporary T
2b.
Type of impact
2c.
Type of wetland
2d.
Forested
2e.
Type of jurisdiction
Corps (404,10) or
DWQ (401, other)
2f.
Area of
impact
(acres)
W1 P
Fill
Small -Basin Wetland
No
DWQ
0.218
W2 P
Fill
Small -Basin Wetland
No
DWQ
0.06
W3 P
Fill
Small -Basin Wetland
No
DWQ
2.247
W4 P
Fill
Small -Basin Wetland
No
DWQ
1.058
W5 P
Fill
Small -Basin Wetland
No
DWQ
2.96
W6 P
Fill
Small -Basin Wetland
No
DWQ
0.027
2g. Total Wetland Impacts:
6.57
2h. Comments:
Awaiting Approved Jurisdictional Determination for 2e.
W1 - W6 Isolated Basin Wetlands (Wetlands ID's A, B,C, D,E & F) to be filled for construction of on-site landfill.
3. Stream Impacts
If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this
question for all stream sites impacted.
3a.
Stream impact
number
Permanent (P) or
Temporary (T)
3b.
Type of impact
3c.
Stream name
3d.
Perennial (PER) or
intermittent (INT)?
3e.
Type of
jurisdiction
3f.
Average
stream
width
(feet)
3g.
Impact
length
(linear
feet)
S1 -
Choose one
-
S2 -
Choose one
-
S3 -
Choose one
-
S4 -
Choose one
-
S5 -
Choose one
-
S6 -
Choose one
-
3h. Total stream and tributary impacts
3i. Comments:
No stream impacts proposed.
Page 4 of 10
PCN Form — Version 1.4 January 2009

4. Open Water Impacts
If there are proposed impacts to lakes, ponds, estuaries, tributaries, sounds, the Atlantic Ocean, or any other open water of
the U.S. then indivi ually list all open water impacts below.
4a.
Open water
impact number
Permanent (P) or
Temporary T
4b.
Name of waterbody
(if applicable)
4c.
Type of impact
4d.
Waterbody
type
4e.
Area of impact (acres)
01 -
Choose one
Choose
02 -
Choose one
Choose
03 -
Choose one
Choose
04 -
Choose one
Choose
4f. Total open water impacts
4g. Comments: No open water impacts.
5. Pond or Lake Construction
If pond or lake construction proposed, the complete the chart below.
5a.
Pond ID number
5b.
Proposed use or
purpose of pond
5c.
Wetland Impacts (acres)
5d.
Stream Impacts (feet)
5e.
Upland
(acres)
Flooded
Filled
Excavated
Flooded
Filled
Excavated
P1
Choose one
P2
Choose one
5f. Total:
5g. Comments:
No lake or pond impacts.
5h. Is a dam high hazard permit required?
❑ Yes ❑ No If yes, permit ID no:
5i. Expected pond surface area (acres):
5j. Size of pond watershed (acres):
5k. Method of construction:
6. Buffer Impacts (for DWQ)
If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts
below. If any impacts require mitigation, then you MUST fill out Section D of this form.
6a. Project is in which protected basin?
❑ Neuse ❑ Tar -Pamlico ❑ Catawba ❑ Randleman ❑ Other:
6b.
Buffer Impact
number —
Permanent (P) or
Temporary (T)
6c.
Reason for impact
6d.
Stream name
6e.
Buffer
mitigation
required?
6f.
Zone 1
impact
(square
feet)
6g.
Zone 2
impact
(square
feet
B1
Yes/No
B2 -
Yes/No
B3 -
Yes/No
B4 -
Yes/No
B5 -
Yes/No
B6 -
Yes/No
6h. Total Buffer Impacts:
6i. Comments:
No buffer impacts.
Page 5 of 10

D. Impact Justification and Mitigation
1. Avoidance and Minimization
1a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project.
Site selection. Due to the size of the footprint needed for the management of the CCR and the location of the wetland areas, primarily in the central
part of the proposed footprint, there are no alternative design options for configuration of the landfill that would allow for complete avoidance of impacts
to these wetland areas or result in less impact to other wetland areas on the Sutton Site. Shifting the landfill footprint to the north of these wetlands
would impact other wetlands in that area and not avoid or minimize total impacts. The Sutton Site contains approximately 337 acres of wetlands.
1 b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques.
The proposed landfill would avoid effects to streams, lakes, and ponds.
The implementation of the Erosion and Sediment Control Plan will minimize effects from stormwater runoff to surface waters during landfill construction
and operation. Construction of the proposed landfill will be conducted in three phases. See Attached Narrative and Construction Application Report.
2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a. Does the project require Compensatory Mitigation for
impacts to Waters of the U.S. or Waters of the State?
Q Yes ❑ No
2b. If yes, mitigation is required by (check all that apply):
X❑ DWQ ❑ Corps
2c. If yes, which mitigation option will be used for this
project?
0 Mitigation bank
El Payment to in-lieu fee program
❑ Permittee Responsible Mitigation
3. Complete if Using a Mitigation Bank
3a. Name of Mitigation Bank: TBD - Lower Cape Fear Umbrella Bank or Towncreek Headwater Bank
3b. Credits Purchased (attach receipt and letter)
Type: Non-riparian wetland
Type: Choose one
Type: Choose one
Quantity: 5.60
Quantity:
Quantity:
u e has secured credit availability from the mitigation banks above and is negotiating inal purchase agreement.
3c. Comments:
4. Complete if Making a Payment to In-lieu Fee Program
4a. Approval letter from in-lieu fee program is attached.
❑ Yes
4b. Stream mitigation requested:
linear feet
4c. If using stream mitigation, stream temperature:
Choose one
4d. Buffer mitigation requested (DWQ only):
square feet
4e. Riparian wetland mitigation requested:
acres
4f. Non-riparian wetland mitigation requested:
acres
4g. Coastal (tidal) wetland mitigation requested:
acres
4h. Comments:
5. Complete if Using a Permittee Responsible Mitigation Plan
5a. If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan.
Page 6 of 10
PCN Form — Version 1.4 January 2009

6. Buffer Mitigation (State Regulated Riparian Buffer Rules) — required by DWQ
6a. Will the project result in an impact within a protected riparian buffer that requires
❑ Yes ❑X No
buffer mitigation?
6b. If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the
amount of mitigation required.
6c.
6d.
6e.
Zone
Reason for impact
Total impact
Multiplier
Required mitigation
(square feet)
(square feet)
Zone 1
3 (2 for Catawba)
Zone 2
1.5
6f. Total buffer mitigation required:
6g. If buffer mitigation is required, discuss what type of mitigation is proposed (e.g., payment to private mitigation bank,
permittee responsible riparian buffer restoration, payment into an approved in -lieu fee fund).
6h. Comments:
Page 7 of 10

E.
Stormwater Management and Diffuse Flow Plan (required by DWQ)
1.
Diffuse Flow Plan
1a.
Does the project include or is it adjacent to protected riparian buffers identified
❑ Yes X❑ No
within one of the NC Riparian Buffer Protection Rules?
1 b.
If yes, then is a diffuse flow plan included? If no, explain why.
❑ Yes ❑ No
2.
Stormwater Management Plan
2a.
What is the overall percent imperviousness of this project?
0
2b.
Does this project require a Stormwater Management Plan?
❑X Yes ❑ No
2c.
If this project DOES NOT require a Stormwater Management Plan, explain why:
2d.
If this project DOES require a Stormwater Management Plan, then provide a brief, narrative
description of the plan:
Construction
of the proposed landfill will be conducted in three phases. During and following each phase of construction, surface water will be
managed
through a series of temporary and permanent controls. Additionally, erosion and sediment controls will be required during each phase of
construction.
Temporary erosion control measures include features used during construction and operation
to direct stormwater away from active
areas of the landfill and best management practices (BMPs) used to manage on-site erosion and prevent sediment from leaving the site.
2e.
Who will be responsible for the review of the Stormwater Management Plan?
NCDEQ
3.
Certified Local Government Stormwater Review
3a.
In which localgovernment's jurisdiction is thisproject?
❑ Phase II
❑ NSW
3b.
Which of the following locally -implemented stormwater management programs
❑ USMP
apply (check all that apply):
❑ Water Supply Watershed
❑ Other:
3c.
Has the approved Stormwater Management Plan with proof of approval been
❑ Yes ❑ No
attached?
4.
DWQ Stormwater Program Review
OCoastal counties
❑HQW
4a.
Which of the following state -implemented stormwater management programs apply
❑ORW
(check all that apply):
❑Session Law 2006-246
❑ Other:
4b.
Has the approved Stormwater Management Plan with proof of approval been
❑ Yes ❑X No
attached?
5.
DWQ 401 Unit Stormwater Review
5a.
Does the Stormwater Management Plan meet the appropriate requirements?
❑ Yes 0 No
5b.
Have all of the 401 Unit submittal requirements been met?
❑ Yes 0 No
Page 8 of 10
PCN Form — Version 1.4 January 2009

F.
Supplementary Information
1.
Environmental Documentation (DWQ Requirement)
1 a.
Does the project involve an expenditure of public (federal/state/local) funds or the
❑ Yes ❑X No
use of public (federal/state) land?
1 b.
If you answered "yes" to the above, does the project require preparation of an
environmental document pursuant to the requirements of the National or State
❑ Yes ❑ No
(North Carolina) Environmental Policy Act (NEPA/SEPA)?
1 c.
If you answered "yes" to the above, has the document review been finalized by the
State Clearing House? (If so, attach a copy of the NEPA or SEPA final approval
❑ Yes ❑ No
letter.)
Comments:
2.
Violations (DWQ Requirement)
2a.
Is the site in violation of DWQ Wetland Rules (15A NCAC 2H .0500), Isolated
Wetland Rules (15A NCAC 2H .1300), DWQ Surface Water or Wetland Standards,
❑ Yes ❑X No
or Riparian Buffer Rules (15A NCAC 2B .0200)?
2b.
Is this an after -the -fact permit application?
❑ Yes ❑X No
2c.
If you answered "yes" to one or both of the above questions, provide an explanation of the violation(s):
3.
Cumulative Impacts (DWQ Requirement)
3a.
Will this project (based on past and reasonably anticipated future impacts) result in
❑ Yes ❑X No
additional development, which could impact nearby downstream water quality?
3b.
If you answered "yes" to the above, submit a qualitative or quantitative cumulative impact analysis in accordance with the
most recent DWQ policy. If you answered "no," provide a short narrative description.
4.
Sewage Disposal (DWQ Requirement)
4a.
Clearly detail the ultimate treatment methods and disposition (non -discharge or discharge) of wastewater generated from
the proposed project, or available capacity of the subject facility.
Not
Applicable
Page 9 of 10
PCN Form — Version 1.4 January 2009

5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected species or
❑ Yes X❑ No
habitat?
5b. Have you checked with the USFWS concerning Endangered Species Act
0 Yes ❑ No
impacts?
5c. If yes, indicate the USFWS Field Office you have contacted.
Raleigh
5d. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical
Habitat?
US Fish and Wildlife Service (USFWS) ECOS-IPaC web application as well as the North Carolina Heritage Program (NCNHP) database for the project
area. On-site survey and coordination with USFWS, NCDENR, and NCWRC.
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as essential fish habitat?
❑ Yes ❑X No
6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat?
National Oceanic and Atmospheric Administration (NOAA) National Marine Fisheries Service Habitat Conservation Essential Fish Habitat Mapper
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
7a. Will this project occur in or near an area that the state, federal or tribal
governments have designated as having historic or cultural preservation
❑ Yes ❑X No
status (e.g., National Historic Trust designation or properties significant in
North Carolina history and archaeology)?
7b. What data sources did you use to determine whether your site would impact historic or archeological resources?
North Carolina State Historic Preservation Office HPOWEB GIS Service. Coordination with NCSHPO.
8. Flood Zone Designation (Corps Requirement)
8a. Will this project occur in a FEMA -designated 100 -year floodplain?
❑ Yes ❑X No
8b. If yes, explain how project meets FEMA requirements:
8c. What source(s) did you use to make the floodplain determination?
FEMA National Flood Insurance Program FIRM Mapping.
Applicant/Agent's Printed Name
Date
Applicant/Agent's Signature
(Agent's signature is valid only if an authorization
letter from the applicant is provided.
Page 10 of 10

f DUKE
ENERGY.
PROGRESS
Project Narrative Summary:
Coal Ash Management Act (CAMA) mandated CCR Basin Closure and
LV Sutton Steam Station Onsite CCR Landfill Project
Sutton Energy Complex
Wilmington, NC
Introduction
This Project Narrative Summary is provided as supplemental information for the Pre -
Construction Notification form (PCN).
A Construction Application Report (Report) was submitted to North Carolina Department of
Environmental Quality (NCDEQ) Division of Waste Management, Solid Waste Section for a
proposed Onsite Coal Combustion Residuals (CCR) landfill at the L.V. Sutton Energy Complex
(Sutton), located near Wilmington, in New Hanover County, North Carolina on 7 August 2015.
The Report consists of the application to construct, permit application drawings, and associated
calculations and plans as appendices to the Report. The Report should be the primary
reference for this Project. A response to NCDEQ Technical Review regarding the construction
application and Report was submitted on 11 December 2015. The Report and supporting
documentation has already been submitted to NCDEQ, a copy has been attached to this PCN.
Project Purpose and Need
Duke Energy Progress, LLC (Duke Energy) is required to close LV Sutton Coal Combustion
Residual (CCR) surface impoundments by 1 August 2019 in accordance with the 2014 Coal Ash
Management Act (CAMA) Sections 3(b) and 3(c). Duke Energy submitted a Coal Ash
Excavation Plan to the NCDEQ on 13 November 2014 describing CCR removal plans beginning
with transporting ash to an off-site location while simultaneously developing an on-site landfill to
meet the CAMA mandated closure date. The purpose and need of the project as proposed is
the permitting, construction and operation of an on-site CCR landfill at the L.V. Sutton Steam
Station (Sutton) for the disposal of approximately 5 million tons of CCR material resulting from
the excavation and closure of the 1971 and 1984 Basins and the Lay of Land Area (LOLA).
Proposed Location and Site Plan
Sutton is located in New Hanover County, approximately 4.5 miles north of the city of
Wilmington in North Carolina (Figure 1) and is situated between the Cape Fear River to the west
and the Northeast Cape Fear River to the east. The Sutton Plant operated as a three -unit, 575 -
megawatt coal-fired plant from 1954 until retirement in 2013. A new 625 -megawatt gas-fired
combined -cycle facility began operating upon retirement of the coal-fired station. The coal-fired
units at Sutton are currently undergoing decommissioning and demolition.
There are two CCR basins located at Sutton: (i) the 1971 Basin and (ii) the 1984 Basin (Basins).
The approximate areas of the 1971 Basin and the 1984 Basin are approximately 54 and 82

Project Narrative: LV Sutton Steam Station DUKE
Coal Ash Management Act (CAMA) mandated CCR Basin Closure t ENERGY,
and On-site Landfill Project PROGRESS
acres (ac), respectively. The Basin locations are shown on Figure 2. The 1971 Basin was
operated from 1971 to 1985 and temporarily in 2011. The 1984 Basin was operated from 1984
to 2013. Both basins contain fly ash, bottom ash, boiler slag, storm water, ash sluice water,
coal pile runoff, and low volume wastewater. Scrubbers were not installed at the Sutton Plant;
therefore, Flue Gas Desulphurization (FGD) residuals are not expected to be found in the
Basins. Other notable features at the site include: (i) LOLA, located south of the 1971 Basin (ii)
the Cooling Pond (also referred to as Lake Sutton), declared waters of the State on 7 November
2014; and (iii) a discharge canal that conveys water from the plant to the Cooling Pond. Field
investigations conducted within LOLA indicate that the area contains a mixture of CCR and soil;
therefore, Duke plans to excavate the material from LOLA and dispose of it in the proposed
onsite CCR landfill along with CCR excavated from the Basins. The proposed landfill will be
located east of the Basins and LOLA, on the existing site as depicted in Figure 2, and described
in further detail in the following section.
Project Activities Description
Anticipated landfill construction and basin closure activities include:
• Utilizing existing rail spur and constructing rail car loading facility for initial off-site
CCR transport;
• Installing erosion and sediment control measures and stormwater management
infrastructure;
• Constructing the landfill liner system including:
o Earthwork: excavation and fill to construct liner system subgrade, perimeter
berm/roadways, and storm water management infrastructure (e.g., channels
and surface water basins);
o Double liner system construction including (from top to bottom) a 24 -in thick
protective cover layer, primary geocomposite drainage layer, primary
geomembrane, secondary geocomposite drainage layer, secondary
geomembrane, geosynthetic clay liner, and a 12 -in thick compacted soil
layer;
o Leachate collection and removal system construction including connection to
on-site storage facility to allow leachate management;
o Providing power connections to operate leachate collection systems;
o Building haul roads (soil) to support liner system construction and perimeter
roads (aggregate) to support landfill operations;
• Implementing the approved Landfill Groundwater Monitoring Plan;
• Removal of CCR from the basins and filling the landfill with ash placed in compacted,
controlled, and monitored lifts;
• Earthwork excavation and fill to grade stockpile and CCR storage areas to proposed
final grades followed by stabilization by establishing permanent vegetation;
• Closing the landfill by constructing a final cover system including (from top to bottom)
a 6 -in thick vegetative cover, 18 -in thick protective layer, geocomposite drainage
layer, and geomembrane;
• Closing the basin areas including removal of some areas of the dikes, fill, grading,
and stabilization; and,
• Providing post -closure operations, maintenance, and care.
4

Project Narrative: LV Sutton Steam Station DUKE
Coal Ash Management Act (CAMA) mandated CCR Basin Closure t ENERGY,
and On-site Landfill Project PROGRESS
A phased erosion and sediment control plan has already been prepared and submitted as
part of the landfill application package. The erosion and sediment control plan was prepared
to meet applicable local and state regulations and includes: (i) temporary erosion control
measures (sediment basins, stone filters terraces, sediment fences, etc.); (ii) permanent
erosion control measures (rip rap, energy dissipaters, ditch stabilization, pipe drain, etc.); and
(iii) seeding specifications and schedules.
Closure of the CCR surface impoundments will require design and installation of erosion and
sediment control devices to properly address potential sources of erosion and sedimentation
associated with excavation and grading activities. Protective measures may include
temporary diversion channels, sediment fencing, sediment basins, riprap slope or ditch
protection, and other applicable measures. The erosion and sediment control plan will be
prepared with consideration to staging of activities, with erosion and sediment control
devices designed specifically for the activities underway at any given time.
Alternatives Analysis
The alternatives analysis for this project identified and compared the available disposal options
for CCR from Sutton capable of meeting the project purpose and need. The following disposal
options were identified and evaluated as part of the alternatives analysis for this project:
• Beneficial Reuse
• Closure In-place
• Off-site Landfill
• On-site Landfill
An alternative of "no action" was also evaluated. The alternatives analysis of disposal
methodologies included an evaluation of the following criteria:
• Project objective — the alternative meets the project purpose and need.
• Feasibility — the alternative is technically feasible to implement.
• Sustainability — the alternative poses minimal potential impacts, including cumulative
effects, to human health and the environment.
• Regulatory requirements — the alternative is consistent with applicable regulatory
requirements.
The following sections describe each of the alternative disposal methodologies and evaluate the
alternatives using the aforementioned criteria.
3

Project Narrative: LV Sutton Steam Station DUKE
Coal Ash Management Act (CAMA) mandated CCR Basin Closure t ENERGY,
and On-site Landfill Project PROGRESS
No Action Alternative
The No Action Alternative (NAA) would result in Duke Energy maintaining the CCR in the
existing Basins and LOLA. However, Duke Energy would be in violation of CAMA for the
closure of the surface impoundments by the 1 August 2019 deadline.
The NAA does not meet the project purpose and need or regulatory requirements under CAMA.
Beneficial Reuse Alternative
The beneficial reuse alternative would include the excavation of CCR from each of the existing
Basins and LOLA, and reusing the CCR material for other purposes, such as structural fill. The
beneficial reuse of all of the CCR material is not commercially and logistically feasible within the
timeframe required for closure, as specified by CAMA. Duke has been unable to identify a
recipient or user for beneficial reuse of all CCR materials currently stored within the Basins and
LOLA. As a stand-alone solution, this alternative is not feasible and would not meet the current
regulatory requirements. Therefore, beneficial reuse of all of the CCR material would not be a
viable alternative to the proposed project. However, Duke is considering beneficial reuse of
some of the CCR material as a sub -alternative to disposal of all of the CCR material in the
proposed on-site landfill.
Closure In-place Alternative
Closure in-place would consist of the Basins and LOLA being closed in their current locations.
This alternative does not meet CAMA requirements for CCR to be disposed in lined units. CCR
in the existing Basins and LOLA would need to be excavated and temporarily stored while the
existing basins were lined and then the CCR material placed back in the basins. It is likely that
the temporary storage of the CCR material would occur in the same vicinity as the proposed on-
site landfill as this is the closest available open space to the existing basins. Additionally, the
Basin are located within a floodplain and would not meet regulatory requirements related to
landfill siting criteria. Therefore, this alternative would not meet the project objective, feasibility,
or regulatory criteria.
Off-site Landfill Alternative
The off-site landfill alternative would require the disposal of the CCR material in a newly
constructed "greenfield" landfill at an off-site location or in an existing, off-site landfill. Although
this alternative would meet the project objective, the off-site landfill alternative would result in
additional effort for siting and permitting a new landfill in New Hanover County or elsewhere in
North Carolina, or additional costs and environmental impacts resulting from the transport and
disposal of CCR to an existing off-site landfill. A new off-site "greenfield" landfill would require
Duke to identify and purchase a suitable site for the construction of the landfill for disposal of the
CCR material. The proposed, off-site landfill would then need to be permitted and constructed.
The time required to identify and select a suitable site, negotiate the site purchase, and conduct
the environmental and engineering studies required to design and permit the landfill is not
feasible to complete in accordance with the CAMA closure schedule. The potential
environmental impacts of constructing an off-site landfill would be anticipated to be similar to
4

Project Narrative: LV Sutton Steam StationDUKE
Coal Ash Management Act (CAMA) mandated CCR Basin Closure fen ENERGY,
and On-site Landfill Project PROGRESS
constructing a new landfill at the Sutton site. However, the alternative for off-site transport and
disposal would increase the likelihood for environmental impacts associated with the off-site
transport of CCR material.
On -Site Landfill Alternative (Preferred Alternative
The preferred alternative is to permit and construct an on-site landfill within the Sutton property
boundary for the disposal of CCR currently stored in the Basins and LOLA.
The on-site landfill alternative meets the project objective and is the most technically feasible
alternative for managing all of the CCR material within the mandated CAMA deadline. The
proposed landfill would be located on the existing industrial facility property near the existing
Basins and LOLA. The use of the selected location on the existing industrial site and transport
of CCR from the ash basins to the landfill is consistent with current site use. The on-site landfill
alternative represents the shortest distance that the CCR material would need to be transported
from the existing Basins. CCR transport would occur within the Sutton property boundaries and
without the requirement to use public roadways, minimizing the potential for environmental
impacts associated with the transport and disposal of CCR material.
The proposed landfill will be located adjacent and parallel to the existing, on-site CCR basins, to
the east of the 1971 and 1984 basins as illustrated in Figure 2, and is of sufficient size to meet
the project purpose and need. The on-site landfill alternative provides the best approach to
meet the regulatory criteria and represents the Least Environmentally Damaging Practicable
Alternative to facilitate the project purpose and need.
Based on the above considerations, Duke concluded that no other location could offer an
environmentally preferable alternative to the proposed landfill location, comply with siting
requirements, and allow for the contiguous land area needed for the landfill footprint.
Project Compatibility with Laws and Regulations
A Site Suitability Report has been prepared and submitted to NCDENR as part of the proposed
onsite CCR landfill application. Site suitability was approved on 2 July 2015. The proposed
landfill project is compatible with local, state, and federal laws and regulations. The proposed
landfill will be permitted through the NCDEQ Solid Waste Section in accordance with the
applicable landfill requirements under Title 15A, Chapter 13, Subchapter B, Sections .0500 and
.1600. Furthermore the proposed landfill will be compatible with location restrictions and design
criteria defined by the 2014 CAMA and Federal CCR Rules published 17 April 2015.
Permitting
The Solid Waste Section is the lead permitting agency and permits include:
• Letter of Site Suitability (received on 2 July 2015)
• Permit to Construct (application currently under review by NCDEQ)
• Permit to Operate
5

Project Narrative: LV Sutton Steam Station DUKE
Coal Ash Management Act (CAMA) mandated CCR Basin Closure t ENERGY,
and On-site Landfill Project PROGRESS
Other permits will be required for basin closure and landfill construction and operations
including:
• Local Zoning Consistency (received on 22 June 2015)
• Modification of station industrial stormwater NPDES permits
• Erosion and sediment control permits
• Dam decommissioning
Erosion and Sediment Control
Erosion control is necessary to maintain the integrity of the landfill and associated structures
and to prevent off-site discharge of sediments. An Erosion and Sediment Control Plan (ESCP)
has been developed to meet the requirements of the North Carolina Administrative Code for
permit applications for sanitary landfills (specifically, 15A NCAC 138.0504) and describes both
the temporary and permanent proposed erosion and sediment control measures. Erosion and
sediment control features have been designed in accordance with the North Carolina Erosion
and Sediment Control Planning and Design Manual (NCESC Design Manual), and the
requirements of the NCDEQ Waste Management division. The ESCP was submitted as part of
the L.V. Sutton Plant Onsite Landfill Construction Application Report.
Construction of the proposed landfill will be conducted in three phases. During and following
each phase of construction, surface water will be managed through a series of temporary and
permanent controls. Additionally, erosion and sediment controls will be required during each
phase of construction. Temporary erosion control measures include features used during
construction and operation to direct stormwater away from active areas of the landfill and best
management practices (BMPs) used to manage on-site erosion and prevent sediment from
leaving the site.
List of Figures:
Figure 1
Site Topographic Map
Figure 2
Site Vicinity Map
Figure 3
National Wetlands Inventory Map
Figure 4
FEMA Floodplain Map
Figure 5
Soils Map
Figure 6
Wetlands Features Map

i 6 A 4 n Y LeWL
;•,Ants
I
:IJ
Legend
Existing Basins
Property Boundary
Cooling Pond
Proposed Landfill Area
Notes
1 Basemap Source: Copyright:© 2013 National Geographic Society,
i -cubed
SITE TOPOGRAPHIC MAP
L.V. SUTTON CCR LANDFILL
L.V. Sutton Energy Complex
Wilmington, North Carolina
GeOS lteC NRGY Figure
consLtkants PROGRESS
1
Charlotte, NC December 2015
r•
Y•
�•
l
.�•
f_•
I Y
0.75 0.375 0
0.75
1.5 Miles
Legend
Existing Basins
Property Boundary
Cooling Pond
Proposed Landfill Area
Notes
1 Basemap Source: Copyright:© 2013 National Geographic Society,
i -cubed
SITE TOPOGRAPHIC MAP
L.V. SUTTON CCR LANDFILL
L.V. Sutton Energy Complex
Wilmington, North Carolina
GeOS lteC NRGY Figure
consLtkants PROGRESS
1
Charlotte, NC December 2015

;,i
Legena
Existing Basins
Property Boundary
Cooling Pond
World Transportation
Proposed Landfill Area
_ AM
Notes
1 Basemap Source: Source: Esri, DigitalGlobe, GeoEye, i -cubed,
USDA, USGS
04 N
0 0.25 05 0.75 1 Miles
SITE VICINITY MAP
L.V. SUTTON CCR LANDFILL
L.V. Sutton Energy Complex
Wilmington, North Carolina
Geosyniec` 't ENERGY Figure
C0tISLttLajIL,S PROGRESS
2
Charlotte, NC December 2015

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�. Proposed Landfill Area
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Cooling Pond �.qi� =&,
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Wetlands � � '� , �!. ' � �°' PEM1 Pfd
WETLANDS
t
0, F
Estuarine and Marine Deepwater
❑Estuarine and Marine Wetland
❑ Freshwater Emergent Wetland
0.75 0.375 0 0.75 1.5 Mile
❑ Freshwater Forested/Shrub Wetland
❑ Freshwater Pond NATIONAL WETLAND INVENTORY MAP
Lake L.V. SUTTON CCP LANDFILL
L.V. Sutton Energy Complex
Other Wilmington, North Carolina
Riverine G( DUKE
eOSYClteC 'C ' ENERGY, Figure
Notes
1. Basemap Source: World Imagery Consultants PROGRESS
Esri - — 3
2. USFWS National Wetland Inventory Map Charlotte, NC December 2015

mm -
Legend
Proposed Landfill Area
Notes
1. Basemap Source: FEMA FIRM Panels
FIRM FLOODPLAIN MAP
L.V. SUTTON CCR LANDFILL
L.V. Sutton Energy Complex
Wilmington, North Carolina
GeosyTitec clDUKE
ENERGY,
consLittants PROGRESS
Charlotte, NC I December 2015
Figure
4

Custom Soil Resource Report N
3 Soil Map
324300 zbkw 2X'= 75'f'f9a `lU 3351[10 2261CO
35'N 8'35'N
�, i!1 I #. u�i 34°10'35'N
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m ..Meters "'
N 0 150 300 600 900 F
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0 500 1000 2000 300[!
Map projection: Web Mercator Comer000rdinabe : WCS%4 Edge tics: UTM Zone 18N WGS84
Legend SOILS MAP
L.V. SUTTON CCR LANDFILL
L.V. Sutton Energy Complex
Wilmington, North Carolina
Geos tec �� DUKE Figure
`*' ENERGY
Notes consultants PROGRESS
1. Basemap Source: Web Soil Survey, USGS.
Charlotte, NC December 2015 rj
New Hanover Counly, North Carolina (NC129)
ltap Unittiyntttal Map Unit Name Acres In AOI Percent of AOI
Kr 1SureL samd..$btl ptrpra 342 360%
slopes
La (Lakeland sand, 1 to B percent 90.3 64.0%
cloves
ruara For area ounterest idC.4 100.0%

r
i _434.306704
77.991586
i - I
• _ f
[Wetland C
Isolated Basin
2.247 Acres j
Wetland E
Isolated Basin
2.96 Acres
Wetland D
Isolated Basin
1.058 Acres
Wetland F
Isolated Basin
0.027 Acre
Wetland B
tt Isolated basin
0.060 Acre
Wetland A
•''- Isolated Basin
- _ 0.218 Acre
34.288360 34.289244
-77.983123 `77.979652
Legend
Existing Basins
Property Boundary
Cooling Pond
Study Area - 150 Acres
Notes
1. Basemap Source: Source: Esri, DigitalGlobe, GeoEye, i -cubed,
USDA,USGS
2. USFWS National Wetland Inventory Map
Miles
0 0.25 0.5
WETLAND FEATURES MAP
L.V. SUTTON CCR LANDFILL
L.V. Sutton Energy Complex
Wilmington, North Carolina
Geosyntec 't- N RGY� DUKE Figure
consultants PROGRESS
6
Charlotte, NC December 2015

LOWER CAPE FEAR UMBRELLA MITIGATION BANK
STATEMENT OF CREDIT AVAILABILITY
December 17, 2015
TO: Resource Environmental Solutions FROM: Lower Cape Fear Umbrella Mitigation Bank
Attn. Cara Conder c/o Land Management Group, Inc.
302 Jefferson Street, Suite 110 3805 Wrightsville Avenue, Suite 15
Raleigh, NC 27605 Wilmington, NC 28403
Applicant: Duke Energy Progress
Project: L.V. Sutton Steam Plant — Onsite Landfill Sutton Energy Complex
Dear Ms. Conder:
Pursuant to your recent credit inquiry, the Lower Cape Fear Umbrella Mitigation Bank (LCFUMB) is
providing confirmation of the availability of 5.57 non -riparian wetland credits to offset the
proposed wetland impacts associated with the Onsite Landfill Sutton Energy Complex at the L.V.
Sutton Steam Plant in New Hanover County, North Carolina. The mitigation credits for this project
are available at the following fee schedule and corresponding fee discount:
Mitigation Type
Stream
Non- Riparian Wetland
Riparian Wetland
Credits Reserved Fee Per Unit
Fee
0 $390.00 $0.00
5.6 $51,370.00 $287,672.00
0.0 $71,201.00 $0.00
Fee $287,672.00
35% Discount'
Total Fee
135% discount if payment received on or before March 31, 2016.
($100,685.20)
$186,986.80
LCFUMB will intend to reserve the 5.6 non -riparian wetland credits through March 31, 2016.
Reservation of credits will be confirmed through written notice from LCFUMB upon request from
Duke Energy and/or its authorized agents. In the interim, LCFUMB will provide Duke Energy the
first right of refusal for credit purchase of this quantity and type of credits.
The transfer of mitigation credits is contingent upon payment in full according to the fee schedule
above. Upon receipt of payment, LCFUMB will provide an executed Transfer of Credit Certificate. It
is the applicant's responsibility to ensure that the credit types and amounts requested are
consistent with the compensatory mitigation requirements of the permit(s) issued. If you have any
Lower Cape Fear Umbrella Mitigation Bank
Statement of Credit Availability

questions or need additional information, please contact me by phone at [phone] or by
email at coreziosi@a Imgroup.net.
Sincerely,
Land Management Group, Inc. (agent for LCFUMB)
rVr
Christian Preziosi
Section Manager
Lower Cape Fear Umbrella Mitigation Bank
Statement of Credit Availability