NC0001422_LVSuttonSARP_Rev0_AppendixI_20161201

Appendix I
Post-Closure Care Plan

POST-CLOSURE CARE PLAN
L.V. SUTTON ENERGY COMPLEX
SITE ANALYSIS AND REMOVAL PLAN
December 2016
Revision 0
Prepared for

Duke Energy Progress, LLC
526 South Church Street
Charlotte, North Carolina 28202
Prepared by

Geosyntec Consultants of NC, PC
1300 South Mint Street, Suite 300
Charlotte, North Carolina 28203
License No. C-3500

Geosyntec Consultants of North Carolina, PC
Duke Energy Coal Combustion Residuals Management Program
Appendix I – Post-Closure Care Plan
Revision 0
December 2016

i

TABLE OF CONTENTS
1 INTRODUCTION ............................................................................................................... 1
2 PROJECT DESCRIPTION ................................................................................................ 1
3 CLOSURE SCHEDULE .................................................................................................... 1
3.1 Introduction .............................................................................................................. 1
3.2 Closure Certification ................................................................................................. 1
3.3 Record Keeping ....................................................................................................... 1
4 CLOSURE SYSTEM DESIGN .......................................................................................... 2
4.1 Closure System Materials ........................................................................................ 2
4.1.1 Vegetation ................................................................................................... 2
4.1.2 Vegetative Layers ........................................................................................ 2
5 POST-CLOSURE ACTIVITIES ......................................................................................... 2
5.1 Contact ..................................................................................................................... 2
5.2 Post-Closure Maintenance ....................................................................................... 3
5.3 Inspection Plan ......................................................................................................... 3
5.4 Closure System Integrity .......................................................................................... 3
5.5 Monitoring Plan ........................................................................................................ 4
5.6 Post-Closure Land Use ............................................................................................ 4
5.7 Completion of Post-Closure Care ............................................................................. 4
6 FINANCIAL ASSURANCE ............................................................................................... 4

Geosyntec Consultants of North Carolina, PC
Duke Energy Coal Combustion Residuals Management Program
Appendix I – Post-Closure Care Plan
Revision 0
December 2016

1

1 INTRODUCTION
This Post-Closure Care Plan (Plan) is submitted as part of the Closure Plan Report for L.V.
Sutton Energy Complex (Sutton), located in Wilmington, North Carolina. This plan has been
prepared for Duke Energy Progress, LLC. (DEP) pursuant to CAMA Regulations §130A-
309.212(a)(4) k.
2 PROJECT DESCRIPTION
The closure of Sutton consists of the total excavation of the coal combustion residuals (CCR)
present in the 1971 and 1984 Basins and the Lay of Land Area (LOLA). The CCR will be
placed in an on-site lined landfill. The 1971 Basin and LOLA will effectively become part of the
Cooling Pond while the 1984 Basin will be graded to drain to the Cooling Pond. We note that
this plan only deals with the excavation and later stabilization of the basins and LOLA; a post-
closure care plan for the on-site landfill is being submitted under a separate report.
3 CLOSURE SCHEDULE
3.1 Introduction
Following the completion of the CCR excavation and removal, the dikes at the 1971 Basin and
LOLA will be breached in order to allow the Cooling Pond to expand into these basins. The
western dike of the 1984 Basin will be removed and the rest of the dike of the 1984 Basin will be
lowered to match the existing contours. The previously inside area of the 1984 Basin will be
graded such that it drains to the Cooling Pond. The exposed areas will be vegetated. This
post-closure plan is for the closure of 1971 and 1984 Basins and LOLA.
3.2 Closure Certification
Following closure of each basin or portions of basins, the owner and operator shall notify the
Division that a Certification, signed by the certifying engineer verifying that closure has been
completed in accordance with the closure plan, has been placed in the operating record. This
Certification will state that Sutton was closed in accordance with the Closure Plan and
applicable regulations and laws.
3.3 Record Keeping
Following final closure of the basins, the owner and operator shall record a notation on the
facility property deed to this effect, or some other instrument that is normally examined during a
title search, and notify the Division that the notation has been recorded and a copy has been
placed in the operating record. The notation on the deed shall in perpetuity notify any potential
purchaser of the property that the land had been used as a CCR disposal facility and its future
use is restricted under the Closure Plan.
Geosyntec Consultants of North Carolina, PC
Duke Energy Coal Combustion Residuals Management Program
Appendix I – Post-Closure Care Plan
Revision 0
December 2016

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4 CLOSURE SYSTEM DESIGN
4.1 Closure System Materials
4.1.1 Vegetation
The surface of the closure system will be vegetated either by seeding or sodding. The grass
seed will have a high tolerance to drought. The sod will be of firm texture, having a compacted
growth and good root development. The minimum requirements of the grass seed and sod are
presented in the Technical Specifications presented as part of the Closure Plan.
4.1.2 Vegetative Layers
The upper 6 inches of the final cover system will consist of loosely placed vegetative layer and
will be vegetated to minimize erosion. The minimum requirements of vegetative soil layer are
presented in the Technical Specifications presented as part of the Closure Plan.
5 POST-CLOSURE ACTIVITIES
Post-closure activities will be conducted at the facility in accordance with CAMA Regulations
§130A-309.212(a)(4) k for a period of 30 years following final closure of the facility. The
Division may decrease the length of the post-closure period if the owner or operator
demonstrates that the reduced period is sufficient to protect human health and the environment,
and the Division approves this demonstration. The period might be increased by the Division if
the Division determines that the lengthened period is necessary to protect human health and the
environment.
The end of the post-closure period must be certified by a registered professional engineer. To
accomplish certification over the required 30-year duration, a registered professional engineer
will prepare annual certifications. The annual certifications will document that the closure
system has been monitored and maintained in accordance with the Post-Closure Plan. The
annual certifications shall be based on observations and results documented on regular post-
closure monitoring reports, maintenance records, and compliance monitoring reports maintained
in the Operating Record.
5.1 Contact
The person responsible for the facility during the post-closure care period is:
On-Site Environmental Professional
Duke Energy Progress, LLC
L.V. Sutton Energy Complex
801 Sutton Steam Road
Wilmington, North Carolina
[phone]
Geosyntec Consultants of North Carolina, PC
Duke Energy Coal Combustion Residuals Management Program
Appendix I – Post-Closure Care Plan
Revision 0
December 2016

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5.2 Post-Closure Maintenance
Post-closure maintenance will be conducted at Sutton for a period of 30 years after final closure.
Maintenance activities will be required for the closure system to remain functional. The
vegetative cover shall be mowed as necessary. The vegetative cover shall be amended and
fertilized as needed to maintain healthy vegetation. Depressions in the cover that pond water or
otherwise impair the function of the cover will be filled and/or regraded. Areas subject to
regrading will be revegetated. Animal burrows and eroded areas should be filled in with
compacted soil and reseeded. If vegetative cover is not adequate in a particular area, fertilizer
or other soil amendments should be applied and the area reseeded in order to re-establish
vegetation. Insecticides may be used to eliminate insect populations that are detrimental to the
vegetation. In addition to maintenance of the vegetative cover, any items noted as requiring
maintenance in Section 5.3 Inspection Plan would also require maintenance.
Maintenance will include mowing at least two times per year as well as needs identified through
the monitoring program will be initiated no later than 60 days after the discovery or within 24
hours if a danger or imminent threat to human health or the environment is indicated.
5.3 Inspection Plan
Routine inspections will be conducted throughout the post-closure care period and documented
accordingly. These inspections will be carried out quarterly unless issues are detected that
indicate that more frequent visits are required. Potential impacts to the public and environment
will be considered in determining the inspection frequency. Items to be included in the quarterly
inspection will be as follows:
• Access and security control such as fences, gates, locks, and other measures that
control site and facility access
• Closure system for signs of erosion, settlement, or subsidence
• Condition and/or presence of vegetation (for distressed or dying vegetation or woody
vegetation with potential to penetrate the low permeability barrier)
• Storm water management
• Erosion and sediment control
• Groundwater monitoring system
• Integrity of site benchmarks
• Vector control
5.4 Closure System Integrity
DEP shall maintain the integrity and effectiveness of the closure system including repairing the
cover as necessary to correct the effects of settlement, subsidence, erosion, or other events,
and preventing run-on and run-off from eroding or otherwise damaging the closure system.
Geosyntec Consultants of North Carolina, PC
Duke Energy Coal Combustion Residuals Management Program
Appendix I – Post-Closure Care Plan
Revision 0
December 2016

4

5.5 Monitoring Plan
Post-closure monitoring will be conducted at Sutton for a period of 30 years after final closure.
Monitoring will include: (i) sampling of groundwater three times per year; and (ii) monthly
inspection of the final closure systems for the first year and quarterly inspections thereafter. A
monitoring plan which addresses groundwater monitoring has been prepared and is included in
the Closure Report. Groundwater monitoring shall continue throughout the post-closure care
period in accordance with the Plan.
5.6 Post-Closure Land Use
The primary land use for Sutton after closure will be open dormant green space and open water.
Post-closure use of the property shall not affect the integrity of the closure system, or the
function of the monitoring systems. The Division may approve disturbance if the owner or
operator demonstrated that disturbance of the closure system will not increase the potential
threat to human health or the environment.
5.7 Completion of Post-Closure Care
The Division shall be notified following certification of completion of the post-closure care period
for the facility and that a certification signed by a registered professional engineer licensed in
the state of North Carolina, verifying that post-closure care has been completed in accordance
with the post-closure plan has been placed in the operating record.
6 FINANCIAL ASSURANCE
In accordance with the North Carolina Solid Waste Management Rules (15A NCAC 13B.1628)
and North Carolina Session Law S.L. 2011-262, financial assurance will be provided by DEP in
the form of the Corporate Financial Test (40 C.F.R. §258.74(e)). Documentation as required by
40 C.F.R. §258.74(e)(2) shall be placed in the facility operating record before the initial receipt
of waste. The Director will be notified when the documentation of financial assurance has been
placed in the operating record.
After the initial placement of documentation of financial assurance as required by 40 C.F.R.
§258.74(e)(2) in the facility operating record, DEP will annually update the information and place
updated information in the operating record within 90 days following the close of their fiscal
year. The Director may provide up to an additional 45 days if DEP can demonstrate that 90
days is insufficient time to acquire audited financial statements.