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HomeMy WebLinkAbout20231101 Ver 1_More Info Received_20240426 (3)April 26, 2024 Delivered via email to: BrookeA.Davis(@.usace.army.mil Ms. Brooke Davis Regulatory Project Manager USACE Wilm ington District -Asheville Regulatory Field Office 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-5006 Re: Response to Reauest for Additional Information Joint 404/401Individual Perm it Application Duke Energy Unit 5 Inactive Ash Basin Dam Decommissioning Project, Cliffside Steam Station Cleveland and Rutherford Counties, North Carolina USACE Action ID 2015-01426 Ms. Davis: WSP USA Environm ent & Infrastructure, Inc.(WSP)and Duke Energy Carolinas, LLC(Duke Energy) are responding herein to the US Army Corps of Engineers (USACE) request for additional information (RAI)for the Duke Energy Unit 5 Inactive Ash Basin (U51AB) Dam Decommissioning (DD) project located at the Cliffside Steam Station in Cleveland and Rutherford Counties, North Carolina. Previous requestsbythe USACEforadditional information included an August 18,2023, pre -application m eeting (first RAI) and an October 24, 2023, letter via em ail (second RAI). These two RAls from the USACE were followed by responses from WSP, on behalf of Duke Energy, on Septem ber 12 and Decem ber 13, 2023. Afterthe above USACE RAlsand the respective WSP responses, conference callswere continued with you and Mr. Sean Wallace from WSP to discuss alternative design options for the construction of Channel 5 (outlet channel) to the Broad River, as well as other project design components (March 6, 2024). Email correspondence was also conducted between WSP (Mr. Wallace)and you to schedule conference call m eetingsto discussthe U51AB DD project:January 11 and March 4, 5, 18, and 20, 2024. Specifically, since the afore -mentioned December 13, 2023, WSP RAI response correspondence, WSP engineering staff hasfurther explored the construction of Channel 5 via two design alternatives: riprap arm oring or natural channel design. These two Channel 5 design options, as further developed, were presented to Duke Energy for review. A Channel 5 design (i.e.,the preferred outlet channel design —West 2 option) was selected by Duke Energy. Other project design com ponentswere also presented by WSPto Duke Energy fortheir review. It is noted herein that the afore -mentioned West 2 option wasfurther advanced by WSP engineering staff to achieve the final outlet Channel 5 design, as identified throughout this RAI response asthe West 2A design. It isthe intent of this RAI response document to further meet the purpose and need presented in the August 2023 Cliffside Steam Station U51AB DD Environmental Report —Joint Section 404/40 1 Individual Permit Application. The purpose is to breach and remove State Dam RUTHE- 070 (Main Dam) and, if required, State Dam RUTHE-072 (Saddle Dam) from the state dam inventory. The project need is to address the North Carolina CAMA-14 regulatory requirements related to ash basin closure at the U51AB DD Cliffside Steam Station and the disposal of Coal Combustion Residual (CCR) materials in a safe and timely manner. This RAI is intended to identify, compare, and contrast two design alternatives (i.e.,West 2A design and natural channel design) for the construction of the outlet Channel 5 for the U51AB DD project. The RAI document will identify and select a final design, or preferred alternative for the project action. With the above considerations, WSP herein provides the following discussion, data, tables, and graphic exhibits on the U51AB DD project for review by the USACE. The attached engineering tables include: • Table 1—Channel 5 Alternatives Sum m ary. • Table 2 —Prelim inary Construction Cost Estim atesfor Channel 5 Alternatives. • Table 3 —Wetlands and Stream Mitigation Cost Summary. The attached engineering figures include Figure 1—Alternative Channel Design —West 2A (i.e., the Plan View drawing); Figure 2 —Alternative Channel Design Profile and Details; and Figure 3 —General Seeding Notes. The North Carolina Departm ent of Environm ental Quality (NCDEQ) Division of Water Resources (DWR) and the North Carolina Wildlife Resources Commission (NCWRC) have also been provided a copy of this WSP response document. Outlet Channel 5 Design Considerations and Comparisons WSP previously developed five concept design alternatives for outlet Channel 5 that were presented asan attachment in the December 13,2023, WSP RAI response correspondence. The December 12, 2023, WSP engineering Memo (U51AB DD Plan Outlet Channel Alternatives Evaluation) discussed how each of the five alternatives differed from the original Wetlands Impact Figure (see August 2023 Duke Energy Rogers Energy Complex —Cliffside Steam Station Environmental Report —Joint Section 404/401Individual Permit Application, Appendix B: Plan View and Cross -Section Drawings). Based on that m em o, Duke Energy/WSP identified the West- 2 alternative as the preferred alternative for the construction of the outlet channel to the Broad River. Specifically, Duke Energy/WSP identified West-2 because it would result in a reduction of USACEjurisdictional waters impacts from the originally proposed 0.9 acre for Wetland Cto 0.38 acre for this forested riparian wetland (Table 1). In March/April 2024, the West 2 design was further developed into the West 2A design alternative which reduces the proposed impact to Wetland Cfrom 0.38 acre to 0.29 acre (Table 1),In addition, as based on the West-2A design, the drainage feature within the northeastern portion of Wetland C would not be impacted by the construction of the outlet channel to the Broad River. As discussed in the afore -mentioned December 13, 2023, RAI response, Duke Energy/WSP considered the feasibility of natural channel design asan alternative forthe riprap-lined Channel 5. The RAI Memo discussed natural channel design feasibility and presented a conceptual design for natural channel design principles. Duke Energy/WSP concluded that natural channel design wasfeasible for Channel 5 considering the relatively flat channel slope with accessto the river floodplain (see Figure NSD —1 to NSD —5 in Attachment 2—Channel 5 Natural Channel Design in RAI December 13, 2023). However, in comparison, the natural channel design alternative would impact a slightly larger area of Wetland C (0.40 acre) but additionally impact the drainage feature (30 linear feet) within Wetland C (Table 1). In addition, the natural channel design alternative wasdeterm ined to be one of the costliest alternativesforthe proposed action. Duke Energy U51AB Dam Decommissioning Project, Cliffside Steam Station WSP Cleveland and Rutherford Counties, North Carolina April 2024 Duke Energy Progress, LLC For these reasons, Duke Energy and WSP excluded that natural channel design alternative because it was not the least environmentally damaging practicable alternative (LEDPA). The updated engineering design detailsfor the West 2A,the preferred alternative, are presented herein, and include discussion, data, tables, and graphic exhibits. Regarding the comparison between the West 2A preferred alternative and the natural channel design alternative, the following additional discussion is presented to facilitate the review of the U51AB DD project Individual Permit application bythe USACE. Prelim inary Construction Costs Com parison As updated herein (i.e., updates to the December 12, 2023, WSP engineering Memo), the preliminary construction cost estimate for the West 2A preferred alternative would be $206,163 (Table 2). The estimated construction cost of the natural channel design alternative would be higher at $329,842,which would includethe establishment ofastep/pool sequenceto the Broad River (Table 2). Note: The estimated construction costs are for comparison purposes and do not include construction cost items such as logistics of coordinating a specialized contractor for natural channel construction, safety planning, mobilization, demobilization, surveying, erosion and sediment control, access roads, and contingency. In addition, the estimated construction costs do not include the costs of potential compensatory mitigation. Potential compensatory mitigation costs are presented directly below. USACE Jurisdictional Waters Impacts Comparison West-2A, as the preferred alternative for the U51AB DD project outlet channel to the Broad River, would impact 0.29 acre of Wetland C (forested riparian wetland). In comparison, the natural channel design alternative would impact 0.40 acre of Wetland C and 30 linear feet of the drainage feature within Wetland C. The cost of compensatory mitigation for the West 2A preferred alternative would be $44,167 (Table 3). The cost of m itigation for the natural channel design alternative would be higher at $74,865; i.e., as based on $30,460 forthe Wetland C im pact and $44,405 forthe drainage feature im pact within the wetland (Table 3).A 2:1m itigation ratio wasapplied forthe im pact calculation for Wetland C, a riparian forested wetland, under the West 2A preferred alternative. A 1:1 m itigation ratio wasapplied forthe im pact calculation for Wetland C underthe natural channel design alternative.A 2:1 m itigation ratio was applied for the im pact calculation for the drainage feature within Wetland C. As stated in the afore-m entioned Decem ber 13, 2023, WSP RAI response correspondence to the USACE, the North Carolina Division of Mitigation Services (NCDMS) In -Lieu Fee (ILF) Request Form was com pleted for the proposed 0.38-acre im pact of Wetland C. The ILF Request Form was attached to the December 13, 2023, WSP correspondence. The completed form was submitted to Ms. Kelly Williams, In -Lieu Fee Program Coordinator, NCDMS, on December 13, 2023. The subsequent December 19, 2023, Acceptance Letter from Ms. Williams, NCDMS, was transmitted to Ms. Lori Tollie, Duke Energy. The expiration of the Acceptance Letter is June 19, 2024. As the proposed im pact to Wetland C will be reduced from 0.38 acre to 0.29 acre under the further advanced design for the outlet Channel 5 (i.e., the West 2A design), a new request for com pensatory m itigation, via an updated ILF Request Form, will be subm itted by WSP to Ms. William s, NCDMS. Duke Energy U51AB Dam Decommissioning Project, Cliffside Steam Station WSP Cleveland and Rutherford Counties, North Carolina April 2024 Duke Energy Progress, LLC Extent of Riprap-lined Channelswithin Project The total extent of new riprap-lined channels that will be constructed within the U51AB is approxim ately 4,190 linear feet. The proposed channels within the basin following ash removal include Channels 1,2, 3,and anew channel to be added in the southeast portion of the ash basin. Channel 4 (see RAI December 13, 2023, Proposed Final Grades —Stage 6 Figure) is no longer included in the design since the existing culvert isto be left in place.The extent of the proposed riprap-lined Channel 5 (outlet channel to the Broad River), under the West 2A preferred alternative, is approxim ately 245 linear feet or approximately 17% of the project. The majority of the proposed riprap-lined channels in the U51AB DD project area will occur outside the Broad River flood plain, i.e., approxim ately 4,190 linear feet for the afore-m entioned channelswith in the basin (-- 83%). Within the floodplain area, the extent of new riprap-lined channel will only be approximately 245 linear feet (Figure 1). Duke/WSP evaluated the cost benefit of attempting to create a m ore natural channel design for the Channel 5 outlet; however, since the m ajority of the U51AB project would be drained via 4,190 linear feet of riprap-lined channels, to spend approximately double the expenses for mitigation and construction costs, the West-2A alternative was developed to further reduce costs of the project. Duke Energy has a public obligation to evaluate project costsfor ash basins closures because these costsare evaluated in public rate caseswith the North Carolina UtilitiesCom mission. Riprap Gabion-Lined Outlet A riprap gabion-lined outlet channel is proposed at the confluence of Channel 5 and the Broad River under the West 2A design. The point of entry into the river will not be in an upstream alignment along the reach, but rather at a near 90-degree angle. Figure 2 presents the Channel/Gabion Outlet Profile (i.e., Typical Gabion Outlet Section and Typical Gabion Outlet Profile). Selection of Preferred Design Alternative for Outlet Channel 5 Construction Based on previous meetings, emailsand responsesfrom USACE, other agencies and the public, the initial preferred alternative outlet channel design (August 2023)and m ost of the five concept designs presented in the December 13, 2023 RAI, were considered ineffective except for the natural channel design which the USACE and other agencies preferred. Therefore, Duke/WSP continued to advance designs to develop a LEDPA. The selection of the preferred design alternative for the construction of the outlet Channel 5 of the U51AB DD project entailed a comparison of preliminary construction cost estimates (Table 2), constructability concerns, permanent jurisdictional waters impacts, and compensatory mitigation costs for two principal design alternatives: West 2A design and natural channel design. The West 2A design was selected asthe preferred alternative over natural channel design forthe following reasons: It isthe LEDPA: o Least impact to Wetland C. o No impact to Drainage Channel in Wetland C. More cost effective: o Construction cost estimate isthe lowest. o Mitigation cost isthe lowest. Constructability concerns: o Does not require coordinating/utilizing a specialized contractor for 17% of the channel construction of the project. Duke Energy U51AB Dam Decommissioning Project, Cliffside Steam Station WSP Cleveland and Rutherford Counties, North Carolina April 2024 Duke Energy Progress, LLC o More efficiently utilizeson site m aterialsfrom project such asexisting rip -rap and other materials vs. purchasing off site materials for natural channel design. • Effectively meetsthe purpose and need of the project. Other Project Considerations Erosion Control Mattina Erosion control matting that isfree of nylon or plastic mesh will be used as component of the Erosion & Sedim ent Control (E&SC) Plan for revegetated areas adjacent to the disturbed portion of Wetland C/floodplain area and where applicable, throughout the project. Permanent Seeding of Project Area The permanent seeding of the proposed outlet Channel 5 work area under the West 2A design (i.e., Wetland Cdisturbed area —see Figure 1)will include the use of native grasses and fortis. Non- native/invasive plant species wiII not be seeded within the Wetland C/floodplain disturbed areas. Please seethe attached Figure 3 for detailson the native plant seed specifications and seeding requirements, including the proposed plant seed specieslist. Closing Duke Energy/WSP appreciates your attention to this project. If you have any questions or comments, or need additional information, please contact James Cutler at (336) 906-3244 or jam es.cutler(a)wsp.com and/or Sean Wallace at (770) 286-7916 or sean.wallaceawsp.com . Sincerely, WSP USA Environment &Infrastructure Inc. Jam es D. Cutler, PWS Senior Scientist Attachm ents: Figures 1, 2, 3 and Tables 1, 2, 3 Sean R. Wallace, PMP, PWS Associate Scientist, Assistant Vice President Cc: Sue Homewood (NC Division of Water Resources) Joey Winston (NC Division of Water Resources) Andrea Leslie (ND Wildlife Com m ision Charlie Hiner (Duke Energy) Michael Clough (Duke Energy) Shahid Rahu (Duke Energy) Mark Taylor (WSP) Duke Energy U51AB Dam Decommissioning Project, Cliffside Steam Station WSP Cleveland and Rutherford Counties, North Carolina April 2024 Duke Energy Progress, LLC ROA _ _ Q-RIVE DRAINAGE FEATURE _�_\ _ do / GABION OUTLET y / \ CHANNEL TOE // \ \ LIMIT OF MAY 2023 TOP O i OF SLOPE // /(/ CHANNEL TOP / OF SLOPE J - \CHANNEL- -\\\\� I L\— — WEST 2A J s — — 7///< \\ \\\ = \_ BOUNDARY OF ESTIMATED I I \ \ EARTHWORK QUANTITIES I I I \ \\ \ \ \\ ✓�\\ \\\\\ \\ \� //// /// // II // ////// // v v vii 11� v vv vvA l l 11 ll� llI III /� i CHANNEL 1 ___--- .- - I 12' BUFFER - - \ o I Illlllb ESTIMATED DISTURBANCE m \ I V�\� �� WITHIN WETLAND C \ \ \ \ / / / / / / �� B o (I \ \ 29 ACRE AREA 0 EXISTING WETLAND C \ \ \\ \ = .\ \ �( \ AREA = 0.90 ACRE ,vvw���VAvw�\v vvv \vA vv��vvvv 00 \ \ \\ \\\ o vv I -- \ vvv v v ors vv v A \cos 12' BUFFER . - \ \ \ \\\\ \ \ \\\ o \ \\ \ \ \ c . . . - - - - - \\� \\ ��\ \ 1- -� r) / \ \\ \ /\i TO BE VEGETATED WITH THE SELECTED NORTH CAROLINA \ \� PIEDMONT RIPARIAN SEED MIX ONLY. MAIN DAM (RUTHE-070, SCOPE 8) AND SADDLE DAM (RUTHE-072, SCOPE 3) DECOMMISSIONING PLAN ROGERS ENERGY COMPLEX - CLIFFSIDE STEAM STATION WSP USA Environment & ALTERNATIVE CHANNEL DESIGN - WEST 2A Infrastructure Inc. 2801 YORKMONT ROAD, SUITE 100 CHARLOTTE, INC 28208 FOR F TEL:(704)357-8600 FAX: (704) 357-8638 ISSUED FOR REVIEW LICENSSEAL URE: INC ENG: F-1253 INC GEOLOGY: C-247 SCALE: AS NOTED DES: SL REFERENCES: DUKE DWG TYPE: DWG DFTR: SL 1. EXISTING TOPOGRAPHIC INFORMATION WAS PRODUCED FROM PHOTOGRAMMETRIC METHODS FROM '490'ENERGY® JOB NO: 7818220026 CHKD: BG 60 60 20 FT AERIAL PHOTOGRAPHY OBTAINED ON JULY 31, 2015 BY WSP. MAIN DAM DOWNSTREAM AREA EXISTING DATE: 4/24/2024 ENGR: BG CONDITIONS TOPOGRAPHIC SURVEY WAS DONE BY FLEMING ENGINEERING INC. (FEI) ON MAY 18, 2023. FILENAME: APPD: MT DWG SIZE DRAWING NO. REVISION ANSI 11"x17" FIGURE 1 0 1 2 3 4 5 6 7 8 9 10 I I I I I I I I I Plotted By:Lee, Seehoon Sheet Set:Cliffside Dam Decom — Alt Channel Design Layout: FIGUREI April 24, 2024 01: 26: 11 pm X:\US\USCL7500—CLT1\CAD\Duke\CliffSide\7818220026 Cliffside Closure Support\Plansheets\Dam Decommissioning Plan\Exhibit\Wetland Submittal\Altern ative Channel Design — West 2A.dwg 705 700 695 690 685 680 675 670 665 660 655 650 705 700 695 690 685 680 675 670 665 660 655 650 25+00 25+50 26+00 26+50 27+00 27+50 28+00 28+50 29+00 29+50 30+00 CHANNEL/GABION OUTLET PROFILE HORIZONTAL SCALE: 1"=100' VERTICAL SCALE: 1"=20' EXISTING GRADE 3.0' 3.0' 42' EXISTING GRADE 3:1 TIE- IN SLOPE 1.5' 3-FT. X 3-FT. X 9-FT. LONG 3.0' 3:1 TIE- IN SLOPE 1.5' GABION BASKET 18-IN. THICK GABION MATTRESS 6-IN. NCDOT NO. 57 STONE CUSHION LAYER 8 OZ/SY NONWOVEN GEOTEXTILE TYPICAL GABION OUTLET SECTION PROJECTED TOP OF GABION BASKETS FLOW LINE OF OUTLET DITCH 8 OZ/SY NONWOVEN GEOTEXTILE \ S :1V 18-IN. THICK GABION MATTRESS 6-IN. NCDOT NO. 57 STONE \ CUSHION LAYER \ 8 OZ/SY NONWOVEN GEOTEXTILE \ TYPICAL GABION OUTLET PROFILE 1 GABION OUTLET DETAIL N.T.S. BROAD RIVER WATER SURFACE AT TIME OF CONSTRUCTION � EXISTING GRADE NOTE: 1. THE GABION OUTLET DETAILS ARE FROM "MAIN DAM AND SADDLE DAM DECOMMISSIONING PLAN, INACTIVE ASH BASIN", DRAWING CLS_C999.011.201, DATED OCTOBER 12, 2023, PREPARED BY WSP. 3H:1V � 48' M 30' 3H:1V 2 CHANNEL WEST 2A DETAIL jN.T.S. " TITLE MAIN DAM (RUTHE-070, SCOPE 8) AND SADDLE DAM (RUTHE-072, SCOPE 3) DECOMMISSIONING PLAN ROGERS ENERGY COMPLEX - CLIFFSIDE STEAM STATION ALTERNATIVE CHANNEL DESIGN PROFILE AND DETAILS WSP USA Environment & Infrastructure Inc. 2801 YORKMONT ROAD, SUITE 100 CHARLOTTE, NC 28208 TEL: 1704)357-8600 FAX: (704) 357-8638 LICENSURE: INC ENG: F-1253 INC GEOLOGY: C-247 FOR ISSUED FOR REVIEW SEAL 4115DU KE ENERGY® SCALE: AS NOTED DES: SL DWG TYPE: DWG DFTR: SL JOB NO: 7818220026 CHKD: BG DATE: 4/17/2024 ENGR: BG FILENAME: APPD: MT DWG SIZE DRAWING NO. REVISION L11ANSIC "x17" FIGURE 2 0 7 I 8 9 10 I C 0 Plotted By: Lee, Seehoon Sheet Set:Cliffside Dam Decom — Alt Channel Design Layout:FIGURE2 April 17, 2024 12:20:21pm X:\US\USCLT500—CLT1\CAD\Duke\CliffSide\7818220026 Cliffside Closure Support\Plonsheets\Dam Decommissioning Plan\Exhibit\Wetland Submittal\Alternative Channel Design — West 2A.dwg 2 7 NATIVE WETLAND SEED SPECIFICATIONS SEEDING MIXTURE COMMON NAME (SPECIES) PERCENTAGE OF MIX Riverbank wild rye 20 (Elymus riparius) Creeping bentgrass 15 (Agrostis stolonifera) Fox sedge 12 (Carex vulpinoidea) Switchgross 15 (Panicum virgatum) Fowl bluegrass 15 (Poa palustris) Deer tongue $ (Dichanthelium clandestinum) Bidens 4 (Bidens aristosa) Soft rush (Juncus effusus, INC Ecotype) 4 Calico aster 3 (Aster lateriflorus) Blackeyed Susan 2 (Rudbeckia hirta) Lanceleaf coreopsis 2 (Coreopsis lanceolata) Total 100 NOTE: THE RECOMMENDED APPLICATION RATE FOR THE WETLAND SEED MIXTURE ABOVE IS 20 TO 25—LBS PER ACRE. APPLY SEED MIXTURE TO DISTURBED WETLAND, EXTENDING 10—FEET LANDWARD. SOIL AMENDMENTS SOIL AMENDMENTS ARE NOT TO BE APPLIED IN WETLAND AREAS MULCH MULCH IS NOT TO BE APPLIED IN WETLAND AREAS MAINTENANCE RESEED/OVER SEED IF GROWTH IS NOT FULLY ADEQUATE. Companion Crops Species Common Season Mix Notes: Secale Cereal or Winter Early Spring or Fall 30 Ibs/acre Grows 3-4' tall, but not a strong cereale rye competitor. Lolium Perennial rye Early Fall or Spring 20-50% Shorter rye; lasts about 2 years, then perenne dies out. Urocloa grown Top Millet Spring, Summer 20-50% Good germination; dies off with ramose frost; does not tolerate mowing. To provide quicker establishment of groundcover, the Riparian Seed Mix specified above should also be augmented with the appropriate cover/companion species in this table. 1 GENERAL SEEDING NOTES WETLAND AREAS NITS GENERAL SEEDING REQUIREMENTS FOR WETLAND AREAS DEFINITION CONTROLLING RUNOFF AND EROSION ON DISTURBED WETLAND AREAS BY ESTABLISHING PERENNIAL VEGETATIVE COVER WITH NATIVE WETLAND SEED. TO REDUCE EROSION AND DECREASE SEDIMENT YIELD FROM DISTURBED AREAS, AND TO PERMANENTLY STABILIZE SUCH AREAS IN A MANNER THAT IS ECONOMICAL, ADAPTS TO SITE CONDITIONS, AND ALLOWS SELECTION OF THE MOST APPROPRIATE PLANT MATERIALS SEEDBED REQUIREMENTS TO MAINTAIN A GOOD STAND OF WETLAND VEGETATION, THE SOIL MUST BE WETLAND SOIL REMOVED FROM NEARBY DISTURBED AREAS AND STOCKPILED OR IMPORTED WEED -FREE TOPSOIL APPROVED BY THE ENGINEER. REUSED WETLAND SOIL AND TOP SOIL SHOULD ALSO HAVE THESE CRITERIA: • FREE FROM LARGE ROOTS, BRANCHES, STONES, LARGE CLODS OF EARTH, OR TRASH OF ANY KIND. SEEDBED PREPARATION INSTALL NECESSARY ADJACENT (NOT IN WETLAND) MECHANICAL EROSION AND SEDIMENTATION CONTROL PRACTICES BEFORE SEEDING, AND RETURN GRADES TO ORIGINAL CONTOURS AS MUCH AS PRACTICABLE. ROUGHEN WETLAND SURFACES BY DISKING, RAKING, HARROWING, OR OTHER SUITABLE METHODS PRIOR TO SEEDING. BROADCAST SEED INTO A FRESHLY LOOSENED SEEDBED THAT HAS NOT BEEN SEALED BY RAINFALL. SEEDING USE CERTIFIED SEED ONLY FOR NATIVE WETLAND SEEDING. LABELING OF NON -CERTIFIED SEED IS ALSO REQUIRED BY LAW. LABELS CONTAIN IMPORTANT INFORMATION ON SEED PURITY, GERMINATION, AND PRESENCE OF WOOD SEEDS. SEEDS MUST MEET STATE STANDARDS FOR CONTENT OF NOXIOUS WEEDS. DO NO ACCEPT SEED CONTAINING "PROHIBITED" NOXIOUS WEED SEED. APPLY SEED UNIFORMLY BY HAND OR WITH A PORTABLE BROADCAST SPREADER WHEN USING BROADCAST -SEEDING METHODS, SUBDIVIDE THE AREA INTO WORKABLE SECTIONS AND DETERMINE THE AMOUNT OF SEED NEEDED FOR EACH SECTION. APPLY ONE-HALF THE SEED WHILE MOVING BACK AND FORTH ACROSS THE AREA, MAKING A UNIFORM PATTERN: THEN APPLY THE SECOND HALF IN THE SAME WAY, BUT MOVING AT RIGHT ANGLES TO THE FIRST PASS. DO NOT APPLY MULCH IN WETLANDS. DO NOT APPLY FERTILIZER. NAA IAI-1 A INSPECT SEEDED AREAS FOR LARGE-SCALE FAILURE AND MAKE NECESSARY REPAIRS AND RESEEDINGS WITHIN THE SAME SEASON, IF POSSIBLE. IF A STAND HAS INADEQUATE COVER, RE-EVALUATE CHOICE OF PLANT MATERIALS. RE-ESTABLISH THE STAND AFTER SEEDBED PREPARATION OR OVERSEED THE STAND. SEEDING SPECIFICATIONS SEE TABLE FOR WETLAND SEEDING AND RIPARIAN SPECIFICATIONS. FESCUE AND SERICEA LESPEDEZA ARE PROHIBITED IN WETLAND AREAS. NN%I) WSP USA Environment & Infrastructure Inc. 2801 YORKMONT ROAD, SUITE 100 CHARLOTTE, NC 28208 TEL:(704)357-8600 FAX: (704) 357-8638 LICENSURE: NC ENG: F-1253 NC GEOLOGY: C-247 SEAL TITLE MAIN DAM (RUTHE-070, SCOPE 8) AND SADDLE DAM (RUTHE-072, SCOPE 3) DECOMMISSIONING PLAN ROGERS ENERGY COMPLEX - CLIFFSIDE STEAM STATION GENERAL SEEDING NOTES FOR ISSUED FOR REVIEW 40)DUKE E N E nt"' SCALE: AS NOTED DES: SL DWG TYPE: DWG DFTR: SL JOB NO: 7818220026 CHKD: BG DATE: 4/17/2024 ENGR: BG FILENAME: APPD: MT DWG SIZE DRAWING NO. FIGURE 3 REVISION ANSI 11"x17" 0 8 9 10 C -n ^ U J C m W 0 Plotted By Lee, Seehoon Sheet Set Chffsde Dom Decom — Alt Channel Design Layout -FIGURES April 17, 2024 05. 33-04pm X_\US\USCLT500—CLT1\CAD\Duke\CliffSide\7818220C26 Cliffside Closure Support\Plo heets\Dam Decommissioning Plan\Exhibit\Welland Submittal\Alternative Channel Design — West 2A_dwg USIAB DDP Outlet Channel Design Alternatives Evaluation Rogers Energy Complex, Cliffside Steam Station Rutherford County, North Carolina Revision 2, 4/17/2024 filnrSQi:ST.T.T]W Channel 5 Alternative Channel Bottom Top Length Longitudinal Channel Channel Estimated Estimated Estimated Cut Fill Channel Description Pros Cons Depth (ft) Width Width (ft) Slope Capacity Lining Wetlands Wetlands Drainage Feature (CY) (CY) (ft) (ft) (ft/ft) (cfs) Disturbance Disturbance (Stream) (ac) (%) Disturbance (ft) DDP Design Rev 1 Minor grading in the U51AB exit area. Largest area of wetlands disturbance Current Design Central location divides thewetlands leaving (WSP Memo (12/13/23) - z 30 az 211.0 0.0107 416s Class B o.90 100.0% 142 o z,1ao small/isolated areas Figure 1) Riprap p p Potentially challenging subgrade conditions for construction. DDP Design Rev 1 Minor grading in the IAB exit area Slightly less area of wetlands disturbance Alternative alignment - reduced Less fill required in comparison to design channel Central location divides the wetlands leaving Channel 5 Class B bottom width/ Reduces wetlands disturbance compared to design small/isolated areas (WSP Memo (12/13/23) - 3 12 30 211.0 0.0307 420.4 Riprap 0.64 71.3% 142 0 1,850 increased depth. p channel Potentially challenging sub rade conditions for Y Bi B B Attachment 1) construction Channel starts from Lower estimated wetlands disturbance compared to Tree clearing and excavation west of the design West 1 Class Channel 5 high paint, design channel; under 0.5 acre channel (WSP Memo (12/13/23) - 3 16 34 286.0 0.0070 418.9 0.47 52.4% 0 2,088 775 alignment moved west. Conveys flow to existing U51AB primary/auxiliary Requires re -grading U51AB Channel 1 to Channel Attachment 1) Riprap outlet channel to the river West-1 transition with a down chute Channel West -1 alignment Lower estimated wetlands disturbance of the Increased tree clearing and excavation area to the upper areas moved further alternatives west ofthe proposed channel West west to avoid wetlands. Conveys flow to existing U51AB primary/auxiliary Channel 1 to Channel West-2 transition will require (WSP Memo (12/13/23) - 3 16 34 380.0 0.0079 445.0 Class B Riprap o.38 42.3% D 1,954 1,179 outlet channel to the river down chute USIAB final grades need to be revised at the U51AB Attachment 1) exit area Channel alignment moved Lowest estimated wetlands disturbance of the Increased tree clearing and excavation area to the further west to avoid alternatives west ofthe proposed channel West 2a wetlands. U pperstrea no USIAB final grades need to be revised at the U51AB (Figure 1) 3 30 48 245.0 0.0070 700.7 Class B Riprap 0.29 32.3% 0 2,722 507 channel alignments modified per the exit exit area (work in Progress) (Notes 4 and 5 ) channel (West 2a). Channel 5 alignment Shift wetlands impacts to the east and does not Major excavation area to the east ofthe channel in moved further east to avoid divide the wetlands the vicinity ofthe transmission tower East wetlands. Insignificant reduction in wetlands disturbance (WSP Memo (12/13/23) - 3 12 30 341.0 0.0117 440.0 Class B 0.59 65.7% 142 3,000 1,834 Potentially challenging subgrade conditions for Attachment 1) Riprap onstruction Natural Channel Design: Natural stream design likely replicates conditions Insignificant reduction in wetlands disturbance combination of cross vanes, before the dam and U51AB was constructed Potentially challenging subgrade conditions for Natural Channel Design Boulder, Rockand step pools, and riffles construction ((WSP Memo (12/13/23)- N/A N/A N/A 319.0 0.03 to 0.06 N/A Rock, 0.40 44.6% 30 1,300 gravel - Attachment 2) Riffles, Step Pools unknown quantity 1. Existing Wetlands C Area = 0.9 ac 2. Permit design flow rate for USIAB exit channel= 416 cfs. Channel side slopes are 3H:1V. 3. The wetlands disturbance acreages reported above are estimated based on preliminary grading. Actual acreages may change when the selected channels are graded with Main Dam footprint modification. 4. The U51AB final grades and U51AB channels are currently being revised based on actual U51AB bottom of ash grades. Based on this update, Channel West 2a geometry may be revised. If West 2a geomery is revised, the reported total wetlands disturbance (0.29 acres) will not be exceeded. 5. To be comparable to the other alternative channel options, the reported earthwork quantities do not include the gabion outlet area. U51AB DDP Outlet Channel Design Alternatives Evaluation Rogers Energy Complex, Cliffside Steam Station Rutherford County, North Carolina Revision 2, 4/17/2024 Table 2. Preliminary Construction Cost Estimates for Channel 5 Alternatives CHANNEL ID ITEM NO. DESCRIPTION ENGINEER'S ESTIMATED QUANTITIY UNITS ESTIMATED UNIT PRICE ESTIMATED PRICE COMMENTS 1-1 Clearing and Grubbing 0.90 AC $13,000 $11,671 Wetlands C disturbed area 1-2 Cut from Western/Eastern Slopes) 0 CY $5.0 $0 See Table 1, earthworks based on AutoCAD volume anal se Current Design 1-3 1-4 Fill (for Channel Construction) Rip,. -Channel 2,180 528 CY CY $5.0 $102.0 $10,900 $53,805 See Table 1, earthworks based on AutoCAD volume analyses =(Top Width+3ft'Ch. Len h"1.5 ft'(1/27), [rip,.p thlcknes-1.5ft (WSP Memo 1-5 8 oz/sy Geotextile-Channel 1,055 5Y $2.5 $2,638 =(Top Width+3 ft)'Ch. Len th'(1/9) (12/13/23)- 1) 1-6 Erosion Control Matting -Cut Slo es 4,900 SF $3.5 $17,150 Channel side slope area Figure 1-7 Temporary Seeding -Cut/Fill Slopes 0.11 AC $3,000 $337 Channel side slope area 1-8 Permanent Seeding-Cut/Fill Slopes 0.11 AC $4,000 $450 Channel side slope area 1-9 Total Miti ation Cost 1 IS $346,913 $346,913 See Table 3 Channel 5- Current Design Total $443,864 2-1 Clearing and Grubbing 0.64 AC $13,000 $8,320 Wetlands C disturbed area 2-2 Cut from Western/Eastern Slopes) 0 CY $5.0 $0 See Table 1, earthworks calculated based on length x width x depth Alternative 2-3 Fill (for Channel Construction) 1,850 CY $5.0 $9,250 See Table 1, earthworks calculated based on length x width x depth Channel 2-4 Ri ra -Channel 387 CY $102.0 $39,457 =(Top Width+aft"Ch. Len h"1.5 ft'(1/27), [,ip,.p thickness=1.5 ftl (WSP Memo 2-5 8 oz/sy Geotextile - Channel 774 5Y $2.5 $1,934 =(Top Width+3 ft)'Ch. Length'(1/9) (12/13/23) - 2-6 Erosion Control Matting -Cut/Fill Slopes 4,900 SF $3.5 $17,150 Assume same as Item No. 1-6 Attachment 1) 2-7 Temporary Seeding -Cut/Fill Slopes 0.11 AC $3,000 $337 Assume same as Item No. 1-7 2-8 Permanent Seeding -Cut/Fill Slopes 0.11 AC $346,913 $39,024 Assume same as Item No. 1-8 2-9 Total Mitigation Cost 1 IS $307,658 $307,658 See Table 3 Alternative Channel S Total $423,130 3-1 Clearing and Grubbing 0.74 AC $13,000 $9,584 Wetlands C disturbed area+ Disturbed area outside Wetland 3-2 Cut (from Western/Eastern Slopes) 2,088 CY $5.0 $10,440 See Table 1, earthworks based on AutoCAD volume analyses 1 3-3 Fill for Channel Construction 775 CY $5.0 $3,875 See Table 1, earthworks based on AutoCAD volume analyses West 3-4 Ripra -Channel 588 CY $102.0 $59,965 1 =(Top Width+3 ft)'Ch. Len h'1.5ft'(1/27),[riprap thickness=1.5 ftl (WSP Memo 3-5 8 oz/sy Geotextile- Channel 1,176 SY $2.5 $2,939 =To Wid[h+3ft"Ch. Lenth'1/9 (12/13/23)- Attachment 1) 3-6 Erosion Control Matting -Cut/Fill Slopes 9,682 SF $3.5 $33,887 Total cut/fill areas from Figure 3 3-7 Tem o Seeding -Cut/Fill Slopes 0.22 AC $3,000 $667 Total cut/fill areas from Figure 3 3-8 Permanent Seeding -Cut/Fill Slopes 0.22 AC $346,913 $77,108 Total cut/fill areas from Figure 3 3-9 Total Mitigation Cost 1 LS $71,581 $71,581 See Table 3 Alternative Channel - West 1Total $270,046 4-1 Clearing and Grubbing 0.64 AC $13,000 $8,343 Wetlands C disturbed area+ Disturbed area outside Wetland 4-2 Cut from Western/Eastern Slopes) 1,954 CY $5.0 $9,770 See Table 1, earthworks based on AutoCAD volume anal se West 4-3 Fil I(for Chan nel Construction) 1,179 CY $5.0 $5,895 See Table 1,earthworks based on AutoCAD volume a n alyses 4-4 Ri ra -Channel 781 CY $102.0 $79,673 =(Top Width+3ft'Ch. Len h"1.5 ft'1/27, [riprap thickness 1.5ft (WSP Memo 4-5 8oz/sy Geotextile- Channel 1,562 5Y $2.5 $3,906 =(Top Width+3 ft)'Ch. Len th'(1/9) (12/13/23)- 1) 4-6 Erasion Control Matting - Cut/Fill Slopes 10,644 SF $3.5 $37,254 Total cut/fill areas from Figure 4 Attachment 4-7 Temporary Seeding - Cut/Fill Slopes 0.24 AC $3,000 $733 Total cut/fill areas from Figure 4-8 Permanent Seeding -Cut/Fill Slopes 0.24 AC $346,913 $84,769 Total cut/fill areas from Figure 4 4-9 Total Mitigation Cost 1 IS $57,874 $57,874 See Table 3 Alternative Channel - West 2Total $288,217 4a-1 Clearing and Grubbing 0.58 AC $13,000 $7,540 Wetlands C disturbed area+ Disturbed area outside Wetland 4a-2 Cut (from Western/Eastern Slopes) 2,722 CY $5.0 $13,610 See Table 1, earthworks based on AutoCAD volume analyses 4a-3 Fill for Channel Construction 507 CY $5.0 $2,535 See Table 1, earthworks based on AutoCAD volume analyses West 2a 4a-4 Ri ra -Channel 694 CY $102.0 $70,805 =(Top Width+3 ft)'Ch. Length - 1.5 ft'(1/27),[ri rap thickness=l.5 ftl (Figure l) 4a-5 8 oz/sy Geotextile - Channel 1,388 SY $2.5 $3,471 =(Top Width+3ft'Ch. Lenth"1/9 (Note 4) 4a-6 Erosion Control Matting -Cut/Fill Slopes 9,382 SF $3.5 $32,837 Total cut/fill areas from Figure 1 4a-7 TemporaryTemponary Seeding -Cut/Fill Slopes 0.22 AC $3,000 $646 Total cut/fill areas from Figure I 4a-8 Permanent Seeding - Cut/Fill Slopes 0.22 AC $346,913 $74,719 Total cut/fill areas from Figure 1 4a-9 Total Mitigation Cost 1 LS $44,167 $44,167 See Table 3 Alternative Channel - West 2a Total $250,330 5-1 Clearing and Grubbing 0.95 AC $13,000 $12,312 Wetlands C disturbed area + Disturbed area outside Wetland C 5-2 Cut from Western/Eastern Slo es 3,000 CY $5.0 $15,000 See Table 1, earthworks based on AutoCAD volume anal ses East 5-3 Fill (for Channel Construction) 1,834 CY $5.0 $9,170 See Table 1, earthworks based on AutoCAD volume analyses 5-4 Ri ra -Channel 625 CY $102.0 $63,767 =(Top Width+3ft'Ch. Len h"1.5 ft'1/27, [rip,. thlcknes-1.5ft (WSP Memo 5-5 8oz/sy Geotextile- Channel 1,250 5Y $2.5 $3,126 =(Top Width+3 ft)'Ch. Lcngth'(1/9) (12/13/23)- 1) 5-6 Erosion Control Matting -Cut/Fill Slopes 22,262 SF $3.5 $77,917 Total cut/fill areas from Figure 5 Attachment 5-7 Temporary Seeding -Cut/Fill Slopes 0.51 AC $3,000 $1,533 Total cut/fill areas from Figure 5-8 Permanent Seeding -Cut/Fill Slopes 0.51 AC $346,913 $177,295 Total cut/fill areas from Figure 5 5-9 Total Mitigation Cost 1 IS $300,043 $300,043 See Table 3 Alternative Channel - East l Total $660,163 Natural Channel 5-1 n and Grubbin Clearin! 0.76 AC $13,000 $9,842 Wetlands C disturbed area+ Disturbed area outside Wetland Design 5-2 Natural Channel Construction 1 IS $320,000.0 $320,000 Cost based on 1/26/2024 KBS Earthworks CourtesyQuote ((WSP Memo 5-3 Total Mitigation Cost 1 1 1 LS $74,865 $74,865 See Table 3 Alternative Channel- Natural Channel Design Total $404,707 1. This preliminary cost estimate is prepared for comparison of the proposed alternatives and does not include construction cost items such as safety planning, mobilization, demobilization, surveying, erosion and sediment control, access roads, and contingency. 2. Unit price estimates are based on Sequoia's December 6, 2023 dated email to WSP. 3. Riprap unit cost: $85/ton from Sequoia. Assume 1.2 tons/CY and $102/Cy. 4. To be comparable to the other alternative channel options, the reported earthwork quantities do not include the gabion outlet area. U51AB DDP Outlet Channel Design Alternatives Evaluation Rogers Energy Complex, Cliffside Steam Station Rutherford County, North Carolina Revision 2, 4/17/2024 Table 3. Wetlands and Stream Mitigation Cost Summary Wetland C Impact Wetland Mitigation Wetland Mitigation New Drainage Stream Mitigation Stream Channel 5 Design Alternative Feature Impact Total Mitigation Cost (acre) Ratio X:1 Cost Ratio X:1 Mitigation Cost (linear feet) Current Design (WSP Memo (12/13/23) - 0.90 2 $136,728 142 2 $210,186 $346,913 Figure 1) Alternative Channe15 0.64 2 $97,472 142 2 $210,186 $307,658 (WSP Memo (12/13/23) - t1 West 1 (WSP Memo (12/13/23) - 0.47 2 $71,581 0 2 $0 $71,581 Attachment 1) West 2 (WSP Memo (12/13/23) - 0.38 2 $57,874 0 2 $0 $57,874 Attachment 1) West 2a (Figure 1) 0.29 2 $44,167 0 2 $0 $44,167 (Note 5) East (WSP Memo (12/13/23) - 0.59 2 $89,857 142 2 $210,186 $300,043 Attachment 1) Natural Channel Design ((WSP Memo (12/13/23) - 0.40 1 $30,460 30 2 $44,405 $74,865 Attachment 2) 1. Potential mitigation costs based on NC Division of Mitigation Services (NCDMS) In -Lieu Fee Program rates for Standard Service Areas. Current NCDMS rates are effective through June 30, 2024. 2. Wetland cost per credit = $76,150.13; Stream cost per credit = $740.09. 3. Natural Channel Design Wetland C Impact estimated to be 0.32 acres. Rounded up to 0.40 acres for contingency. 4. Natural Channel Design New Drainage Feature Impact estimated to be 26 ft. Rounded up to 30 ft for contingency. 5. If West 2a geomery is revised, the reported total wetlands disturbance (0.29 acres) will not be exceeded.