NC0000396_Asheville Excavation Plan 2016_20161201

Asheville Steam Electric Generating Plant

Coal Ash Excavation Plan

2016 Update

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Table of Contents
I. Statement of Purpose ................................................................................................................... 1
II. General Facility Description ......................................................................................................... 2
III. Project Charter ............................................................................................................................... 4
IV. Critical Milestone Dates................................................................................................................ 5
V. Erosion and Sedimentation Control Plan .................................................................................. 6
VI. Dewatering Plan ............................................................................................................................ 6
VII. Proposed Location(s) for Removed Ash .................................................................................... 7
VIII. Transportation Plan ....................................................................................................................... 8
IX. Environmental and Dam Safety Permitting Plan ...................................................................... 8
X. Contracting Strategy ................................................................................................................... 10
XI. Environmental, Health, and Safety Plan .................................................................................. 10
XII. Communications Plan ................................................................................................................. 11
XIII. Glossary ........................................................................................................................................ 11
XIV. Reference Documents ................................................................................................................ 13

Exhibits
Exhibit A: Excavation Soil Sampling Plan

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I. Statement of Purpose
Duke Energy Progress, Inc. (Duke Energy or the Company) is required by Part II,
Section 3(b) of the Coal Ash Management Act of 2014 (Session Law 2014-122) (Coal
Ash Act or Act) to close in accordance with Part II, Section 3(c) the coal combustion
residuals (CCR) surface impoundments located at the Asheville Steam Electric
Generating Plant in Buncombe County (Asheville or Plant) as soon as practicable, but
not later than August 1, 2022.1
This Coal Ash Excavation Plan (Plan) represents activities to satisfy the requirements
outlined in Part II, Sections 3(b) and 3(c), Subparagraphs 1 and 2 of the Act and the
requests set forth in the North Carolina Department of Environmental Quality’s (NC
DEQ) August 13, 2014 letter titled “Request for Coal Ash Excavation Plans for Asheville
Steam Electric Generating Plant, Dan River Combined Cycle Station, Riverbend Steam
Station, L.V. Sutton Electric Plant” (NC DEQ Letter).
The NC DEQ Letter was sent by the North Carolina Department of Environment and
Natural Resources, which was renamed the North Carolina Department of
Environmental Quality by Session Bill 2015-241. The NC DEQ Letter specifically
requests that the Plan include 1) soil and sedimentation erosion control measures, 2)
dewatering, and 3) the proposed location(s) of the removed ash. These requirements
are found in this updated Plan.
This is a revision of the Coal Ash Excavation Plan updated November 13, 2015, which
covered the initial phase of ash basin excavation activities, including the initiation of
basin dewatering, site preparation, ash basin preparation, and ash removal from the
basins at Asheville. The Plan will generally be updated and submitted to NC DEQ
annually.
The Mountain Energy Act of 2015 (MEA 2015), which extends the removal of all ash to
August 1, 2022, amended the previous strategy to address the dewatering of the rim
ditch system located in the 1964 Ash Basin. Previously, the existing rim ditch system in
the 1964 Ash Basin was to be removed and relocated in a temporary configuration in
the 1982 Ash Basin. The Company plans to build a natural gas-fired plant in the
footprint of the1982 Ash Basin. The existing rim ditch system will remain in service
through plant retirement. The Company will excavate a significant portion of the ash in
the 1964 Ash Basin until plant retirement by January 31, 2020. Once the plant is
retired, and the rim ditch system is no longer operational, the rim ditch system will be

1 Revised Coal Ash Management Act of 2014 closure date from August 1, 2019. Amended by Mountain Energy Act
of 2015 (Session Law 2015-110) (June 24, 2015).

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removed and the ash directly beneath the rim ditch system will be excavated and placed
in a lined storage facility.

The Act contains no requirement for the submittal of an excavation plan of the kind
presented here. Thus, while the formulation, submittal, and review of this Plan will
assist in Duke Energy’s work to close the ash basins, its ultimate approval is an action
not specifically required by statutory, regulatory, or other applicable authority.
The scope of work in excavating the ash basins has been determined b y applicable
laws, rules, permits, and approvals that control the activities to be performed under the
Plan. There are several external and internal factors that could potentially affect the
precise scope of the work to be performed under the Plan. As a consequence, neither
the submittal of this Plan, nor its acknowledgement by NC DEQ, should be taken as
requiring actions different from such applicable requirements. Duke Energy submits this
Plan to NC DEQ based on the understanding that it may be necessary to take actions
that deviate from the Plan in the future, and the Company reserves the right to make
such changes.
II. General Facility Description
The Plant is located in Arden, NC, approximately eight miles south of Asheville, NC.
The Plant’s Unit 1 was constructed in 1964 with a second coal burning unit (Unit 2)
added in 1971. Current generation capacity of the Plant is 376 megawatts (MW ) from
two (2) coal-fired units. In 1999 and 2000, two natural gas and oil combustion turbines
with an additional output of 324 MW were added (Figure 1).
UNIT TYPE COMMERCIAL
YEAR
RATING
(net MW)
COMBINED
1 Coal-Fired Steam 1964 191 376 2 1971 185
3 Natural Gas and Oil
Combustion
1999 162 324 4 1999 162
Total 700
Figure 1: Asheville Steam Electric Generating Plant Generation Profile
The Plant has two ash basins. The first basin was created in 1964 when the plant
began operations. In 1982, a second basin was constructed directly adjacent to the
1964 Basin’s south retention dam and has been excavated and turned over for
construction of the natural gas combined cycle plant.
Duke Energy’s Coal Combustion Residuals Removal Verification Procedure (Removal
Verification Procedure) will be used to verify that primary source ash has been removed

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from the basin. Subsequent to removal of the ash pursuant to the Removal Verification
Procedure, Duke Energy will implement its Excavation Soil Sampling Plan (ESSP),
which was developed for the purpose of meeting the applicable performance standard.
Although not required under CAMA, in September 2016, NC DEQ sent Coal
Combustion Residuals Surface Impoundment Closure Guidelines f or Protection of
Groundwater to Duke Energy instructing the Company to submit the ESSP to NC DEQ
as part of the site’s excavation plan. In accordance with this directive, a copy of the
ESSP is attached as Exhibit “A” to this Plan.
1964 Ash Basin
The 1964 Ash Basin Dam (BUNCO-097) was constructed in 1964 to serve as a
wastewater treatment facility for the treatment of ash sluice water. The surface area of
the basin is approximately 45 acres. The basin does not retain a permanent pool with
the exception of a three-acre unlined retention pond known as the “Duck Pond.” In
2005, engineered wetlands were constructed within the 1964 Ash Basin footprint to treat
flue gas desulfurization (FGD) process wastewater.

Production ash is sluiced to a concrete rim ditch system that is located within the
footprint of the 1964 Ash Basin. The rim ditch system also receives plant stormwater
drainage and low volume wastewater. CCR are dredged from the rim ditch, dewatered,
and transported off-site.
Historically, the wastewater from the rim ditch process was treated in the lined rim ditch
system and then routed to the Duck Pond and decanted to a settling pond outside of the
1964 Ash Basin. The settling pond serves as the monitoring point for Outfall 001 of the
Plant’s National Pollutant Discharge Elimination System (NPDES) permit (NC0000396).
Water discharge from this settling pond is routed directly to the French Broad River.
During 2016, wastewater flows and treatment were adjusted to facilitate the excavation
of the 1982 Basin. The center pond filters were constructed at the end of the rim ditch
and commissioned to replace the treatment provided by the Duck Pond. Infrastructure
was developed to dewater the Duck Pond to the head of the rim ditch, and
subsequently, the low volume waste and stormwater that flowed into the 1982 Basin
and pumped to the rim ditch was re-routed to the Duck Pond.
Since the last Plan update, the FGD engineered wetlands were excavated and
transported to an approved Resource Conservation and Recovery Act (RCRA) Subtitle
D landfill.
The estimate of ash tonnage in the 1964 Ash Basin is approximately 2.9 million tons of
ash as of December 31, 2016.

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1982 Ash Basin
Excavation of the 1982 Ash Basin was completed on September 30, 2016, and the
Basin was turned over for dam decommissioning and the construction of a natural gas
combined cycle plant.

III. Project Charter
Dewatering of the ash basins and the removal of ash from the site will be performed
within project phases. The project has substantially completed Phase I and has been
planning and implementing Phase II.
The following items in Phase I have been completed or initiated:
1. Excavation and closure of the 1982 Ash Basin
2. Design and construction of alternate treatment methods for FGD process water
to replace engineered wetlands process
3. Decommissioning and dewatering of the FGD engineered wetlands in the 1964
Ash Basin
4. Excavation and transportation of 1964 Basin FGD engineered wetlands material
to an approved RCRA Subtitle D landfill
5. Initiation of the 1982 Ash Basin dam decommissioning and grading material into
former 1982 Ash Basin footprint to facilitate the construction of the natural gas-
fired plant
6. Initiation of the 1964 Ash Basin ash excavation and transportation

Project Charter Objectives
Phase II Objectives
1. Excavate and transport ash from the 1964 Ash Basin
2. Evaluate, design, and construct water treatment system and/or water retention
for utilization after plant retirement
3. Complete decommissioning of the 1982 Ash Basin dam
4. Submit and obtain any necessary permits for Phase II activities
5. Gain knowledge and opportunities for program improvement that can be applied
to the subsequent phase(s)
6. Plan activities for Phase III.
Phase III Objectives
1. Remove remaining ash from the 1964 Ash Basin

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2. Decommission and demolish 1964 Ash Basin rim ditch system
3. Perform 1964 Ash Basin closure activities
Project Charter Scope
Phase II Scope
1. Excavate and transport approximately 2 million tons of ash from the 1964 Ash
Basin, including generation ash
2. Evaluate, design, and construct water treatment system and/or water retention
for utilization after plant and rim ditch retirement
3. Submit and obtain permits for Phase II activities
4. Maintain lowered water state of the Duck Pond
5. Complete decommissioning of the 1982 Ash Basin dam and grade for
construction of the natural gas combined cycle plant
6. Continue to validate production rates to meet project requirements and increase
efficiency

Phase III Scope
1. Prepare remaining required permit applications for subsequent phase(s) of ash
removal activities (if applicable)
2. Finalize and/or develop additional location(s) for excavated ash (if applicable),
including obtaining all required permits
3. Decommission and removal of the 1964 Ash Basin rim ditch
4. Excavate and transport the remaining ash from Asheville to an approved landfill
or structural fill location
5. Complete closure activities as outlined in Part II, Sections 3(b) and 3(c),
Subparagraphs 1 and 2 of the Act, as modified by MEA 2015

IV. Critical Milestone Dates
Critical Milestones within the Plan are summarized in the table below.
MILESTONES NO LATER THAN DATE STATUS
Submit Excavation Plan November 15, 2014 Completed
November 13, 2014
Complete Comprehensive Engineering
Review
November 30, 2014 Completed
November 30, 2014
Excavation Plan acknowledgment February 17, 2015 Received
February 2, 2015
Receive Dam Safety Permit to excavate
1982 Ash Basin dam face
December 12, 2014 Completed
Received approval on

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MILESTONES NO LATER THAN DATE STATUS
June 25, 2015
Receive updated Distribution of Residual
Solids Permit
February 28, 2015 Completed
Received Final Permit
on September 2, 2015
Complete removal of ash from 1982 Ash
Basin (except interim storage of
production ash)
July 31, 2016 Completed September
30, 2016 due to
finding more ash than
planned
Decommission engineered wetlands and
commission alternate FGD wastewater
treatment system
November 3, 2015 Completed
FGD wastewater
conveyance to sewer
on October 28, 2015
Submit Updated Excavation Plan November 15, 2015 Completed
Plan submitted on
November 13, 2015
Submit Updated Excavation Plan December 31, 2016 On track
Dewater and remove engineered
wetlands
March 2, 2016 Completed on May 13,
2016 with no impact
on final completion
schedule
At facilities actively producing CCR, end
stormwater discharge into impoundments
December 31, 2019* This provision of
CAMA is not
applicable to
Asheville, pursuant to
Section 2.(b) of MEA
Cease Operation of coal-fired units at the
Asheville Plant
January 31, 2020* On track
Impoundments closed pursuant to Part II,
Sections 3(b) and 3(c) of the Act
August 1, 2022* On track
Submit Updated Excavation Plan December 31, Annually On track
*Pursuant to MEA 2015

V. Erosion and Sedimentation Control Plan
Asheville Plant permits allow for the excavation and transportation of ash on existing
paved roads and within the ash basins during excavation. Any new construction
supporting ash basin closure will be in compliance with applicable erosion and sediment
control permits.

VI. Dewatering Plan
The 1964 Ash Basin is currently void of free-standing water, except for the Duck Pond.
Stormwater and wastewater flows into the Duck Pond are captured and pumped to the

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head of the rim ditch wastewater treatment system within the footprint of the 1964 Ash
Basin.
As noted above, the settling treatment provided by the Duck Pond has been replaced by
a filtration system. The filtration system meets existing permit requirements as it relates
to the treatment ability provided by the Duck Pond system . The conveyance and
filtration system continues to flow to the permitted NPDES Outfall 001. The Duck Pond
is used for retention for the 1964 Basin and the low volume stormwater and wastewater
flows.
Subsequent to plant and rim ditch retirement, additional water management and
treatment systems will be required in accordance with the NC DEQ letter from Jeff
Poupart, Water Quality Permitting Section Chief, to Duke Energy, dated July 20, 2016,
regarding decanting of coal ash impoundments.

VII. Location(s) for Removed Ash
Phase I I : Disposal Site
Ash from the 1964 Ash Basin is currently being transported to the R&B Landfill in
Homer, GA, a permitted dedicated ash monofill.
STORAGE SITE LOCATION APPROXIMATE
AMOUNT (TONS)
CCR STORAGE
R&B Landfill Homer, GA 2.0M Monofill

Contingent Plan: Disposal Site
The on-site landfill at Cliffside remains an option for the Company if events warrant
transition to another site. The Company continues to develop and evaluate contingency
storage locations in the event this scenario becomes unobtainable. Contin gency plans
currently being developed include assessing alternate ash storage locations and
beneficial use opportunities.
Phase III: Disposal Site
The project team will utilize lessons learned from Phase I to develop an off -site disposal
strategy and/or alternative beneficial use site(s) that will provide the improvements
below:
 Provide a reliable, long-term, cost-effective, solution for ash designated for
removal

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 Support development of a diverse supplier p rogram to drive innovation and
competition
 Establish performance baselines and the system to optimize excavation,
transportation, and disposal of ash
VIII. Transportation Plan
The Company's transportation policies and standards meet Department of
Transportation (DOT) and other applicable federal, state, and local regulations. Drivers
will continue to follow DOT regulations pertaining to trucking, including DOT bridge
laws.
Phase I I : Transportation
Ash from the 1982 Ash Basin will be transported to the R&B Landfill by truck. The
route, utilizing primarily I-26 and I-85, is 120 miles each way.
Contingent Plan: Transportation
Contingent plans may include other trucking options.
Phase III: Transportation
The transportation plan will be evaluated and reviewed to provide any improvements .

IX. Environmental and Dam Safety Permitting Plan
Excavation of ash creates potential for stormwater impacts. The facility continues to
operate under an administratively extended NPDES Wastewater Permit. Additionally,
the site received its NPDES Industrial Stormwater Permit (ISW) on May 24, 2016. The
site has an active Stormwater Pollution Prevention Plan (SPPP), which was modified
and implemented in November 2016 to reflect the ISW. Additional modifications to the
NPDES Wastewater Permit will be necessary to facilitate the closure of the 1964 Ash
Basin.
If the Company constructs any treatment basins or conducts grading within the 1964
Ash Basin footprint, a Buncombe County Post-Construction Stormwater Permit may be
required. Additionally, a NPDES Construction Stormwater General Permit may be
required prior to commencing with any grading activities.
During Phase I, ash excavation along the 1982 Ash Basin dam interior face and the
1964 Ash Basin Separator Dike was initiated by issuance of Dam Safety Permit
approvals on June 25, 2015 and July 1, 2016, respectively. For subsequent phases,

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the Company assumes that a Dam Safety Permit will be required prior to excavation
work along the 1964 Ash Basin dam face.
There are no jurisdictional wetlands/streams associated with the removal of ash in the
1964 Ash Basin in Phase II.
If the Company chooses to utilize a structural fill during subsequent phase(s), an
individual structural fill permit will need to be obtained by the project owner/operator.
All necessary Dam Safety approvals will be obtained to cover activities on or around
jurisdictional dikes. Breaching of the dikes will require Dam Safety approval. Any
impacted wells or piezometers will be abandoned in accordance with NC DEQ
requirements. Fugitive dust will be managed to mitigate impacts to neighboring areas.
Impacts to threatened and endangered species will be avoided.
Also during Phase I, the Company received an Industrial User Permit on June 13, 2015
to discharge the FGD wastewater into the Metropolitan Sewerage District (MSD)
system. As noted above, this activity has been completed and dewatering of the FGD
engineered wetlands has been completed.
Permit Matrix
MEDIA PERMIT RECEIVED DATE (R)
/ TARGET DATE (T)
COMMENTS
Water

NPDES Industrial
Stormwater Permit May 24, 2016 (R)
The facility continues to operate
under an administratively
extended NPDES wastewater
permit to include stormwater
coverage. The site has an
active SPPP.
NPDES Wastewater
Permit – Major
Modification
First quarter 2017 (T)
The Company continues to work
with regulatory entities to secure
approvals.
Jurisdictional
Wetland and Stream
Impacts / 404
Permitting and 401
WQC
N/A
No impacts to jurisdictional
wetlands and streams have
been identified at this time.
NPDES
Construction
Stormwater General
Permit
April 1, 2020 (T), if
needed
Permit may be required for
grading activities
Buncombe County
Post-Construction
Stormwater Permit
April 1,2020 (T), if
needed
Permit may be required for any
basin construction or grading
activities.

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MEDIA PERMIT RECEIVED DATE (R)
/ TARGET DATE (T)
COMMENTS
Dam Safety Dam
Decommissioning
Request Approval
Complete
June 25, 2015 (R) and
July 1, 2016 (R)
Dam Safety permits to excavate
ash from the interior face of the
1982 Ash Basin dam and the
1964 Separator Dike were
received on June 25, 2015 and
July 1, 2016, respectively.

A permit for ash excavation from
the 1964 Ash Basin dam interior
face will be required in Phase II.
Other
Requirements
Site-specific
Nuisance/Noise/
Odor/Other
Requirements,
including DOT
October 28, 2015 (R)
During Phase I, the Company
received an Industrial User
Permit on June 13, 2015 to
discharge the FGD wastewater
into the MSD system. As noted
above, this activity was
completed on October 28, 2015.
September 2, 2015
(R)
An updated Distribution of
Residual Solids (503 Exempt)
Permit (WQ0000020) was
received on September 2, 2015
for the completed structural fills
at the Airport. The permit
expires on August 31, 2020.
X. Contracting Strategy
The Ash Management Program strategy is to engage multiple contractors, drive
competition, create system-wide innovation, and develop a collection of best practices.
Duke Energy has engaged contractor(s), who are experienced in coal ash excavation,
transportation, and disposal, and continues to evaluate other potential contractors. The
Company provides in-depth oversight, coordination, and monitoring of the contracto rs to
ensure the work is performed appropriately. Duke Energy’s core values include safety,
quality, and protection of the environment which are incorporated into our contracts.
The Company continues to evaluate alternate approaches, methods, and contracting
solutions and will adjust its strategy, as necessary.
XI. Environmental, Health, and Safety Plan
Protecting workers, the public, the community and the environment
Duke Energy is committed to the health, safety, and welfare of employees, contractors,
and the public, and to protecting the environment and natural resources. During all

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phases of the project work, Duke Energy and its contractors will follow the Duke Energy
Safe Work Practices Manual, the Environmental, Health, and Safety supplement
document, and any additional requirements. Occupational health and safety
expectations include oversight and continuous improvement throughout the project.
The project will include comprehensive environmental, health, and safety plans
encompassing all aspects of the project work, including at the plant, in transit, and at the
final destination, as needed.
In addition to adhering to all applicable environmental, health, and safety rules and
regulations, Duke Energy and its contractors will focus on ensuring the safety of the
public and protection of the environment during each phase of the project.
XII. Communications Plan
Many different external stakeholders, including neighbors, government officials, and
media have an interest in this project. For example, there is the potential for facility
neighbors and the general public to see or experience construction-related impacts,
such as truck traffic, landscape changes, or noise. The Company is committed to
providing information by proactively communicating about the project activities to
potentially affected parties and responding to inquiries in a timely manner. The project
team has coordinated with Duke Energy’s Corporate Communications Department to
develop and implement a comprehensive external communications plan tailored to the
specific needs of each phase of the project.
XIII. Glossary
TERM DEFINITION
Ash Basin Synonymous with Coal Combustion Residuals Impoundment. A
topographic depression, excavation, or dammed area that is primarily
formed from earthen materials; without a base liner approved for use
by Article 9 of Chapter 130A of the North Carolina General Statutes or
rules adopted thereunder for a combustion products landfill or coal
combustion residuals landfill, industrial landfill, or municipal solid waste
landfill; and an area that is designed to hold accumulated coal
combustion residuals in the form of liquid wastes, wastes containing
free liquids, or sludge, and that is not backfilled or otherwise covered
during periods of deposition.

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TERM DEFINITION
Beneficial Use Beneficial use of coal combustion residuals, or byproducts, removed
from the site in compliance with the requirements of Section .1700 of
31 Subchapter B of Chapter 13 of Title 15A of the North Carolina
Administrative Code (Requirements for Beneficial Use of Coal
Combustion By-Products) and Section .1205 of Subchapter T of
Chapter 2 of Title 15A of the North Carolina Administrative Code (Coal
Combustion Products Management)
Bottom Ash The agglomerated, angular ash particles formed in pulverized coal
furnaces that are too large to be carried in the flue gases and collect
on the furnace walls. Bottom ash falls through open grates to an ash
hopper at the bottom of the furnace.
Coal Ash Excavation
Plan
Plan required by NC DEQ letter dated August 13, 2014, including a
schedule for soil and sedimentation erosion control measures,
dewatering, and the proposed location of the removed ash
Coal Ash
Management Act of
2014
North Carolina Session Law 2014-122
Coal Combustion
Residuals (CCR)
Coal Combustion Residuals. Residuals include fly ash, bottom ash,
and boiler slag produced by a coal-fired generating unit
Dewatering The act of removing bulk and entrapped water from the ash basin
Dewatering Plan Engineered plan and the associated process steps necessary to
dewater an ash basin
Duke Energy Safe
Work Practices
Manual
Document detailing the Duke Energy safety guidelines
Excavation Activities Tasks and work performed related to the planning, engineering, and
excavation of ash from an ash basin
Excavation Plan Refer to Coal Ash Excavation Plan
Fly Ash Very fine, powdery material, composed mostly of silica with nearly all
particles spherical in shape, which is a product of burning finely ground
coal in a boiler to produce electricity and is removed from the plant
exhaust gases by air emission control devices
Mountain Energy Act North Carolina Session Law 2015-110

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TERM DEFINITION
of 2016
NPDES National Pollutant Discharge Elimination System
NPDES Permit A permit that regulates the direct discharge of wastewater to surface
waters
Permit Federal, state, county, or local government authorizing document
1964 Ash Basin Ash pond created in 1964 for wastewater treatment of industrial
wastewater produced by coal combustion for electric steam generation
(#BUNCO-097)
1982 Ash Basin Ash pond created in 1982 for wastewater treatment of industrial
wastewater produced by coal combustion for electric steam generation
(#BUNCO-089)
XIV. Reference Documents

REF DOCUMENT DATE
1 Letter to Duke Energy, request for excavation plans August 13, 2014
2 Coal Ash Management Act of 2014 September 20, 2014
3 Mountain Energy Act of 2015 June 24, 2015

Excavation Soil Sampling Plan December 2016
Asheville Plant 1964 Ash Basin Revision 0
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EXHIBIT A
EXCAVATION SOIL SAMPLING PLAN
ASHEVILLE STEAM ELECTRIC PLANT
1964 ASH BASIN
FOR ASH BASIN EXCAVATION
NORTH CAROLINA ASH BASIN CLOSURE

DUKE ENERGY PROGRESS, LLC.
526 SOUTH CHURCH STREET/EC13K
CHARLOTTE, NORTH CAROLINA 28202

Waste & Groundwater Programs
Revision 0
December 2016
Excavation Soil Sampling Plan December 2016
Asheville Plant 1964 Ash Basin Revision 0
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TABLE OF CONTENTS
SECTION PAGE
1.0 Purpose ............................................................................................................................................ 1
2.0 Soil Sampling methodology ............................................................................................................. 1
2.1 Method Summary 1
2.1.1 Equipment 1
2.1.2 Sample Locations 2
2.1.3 Collection of Representative Samples 2
2.1.4 Sample Preservation, Containers, Handling and Storage 3
2.1.5 Decontamination 4
3.0 Visual Confirmation of Ash Removal ............................................................................................... 4
3.1 Pre-Excavation Documentation 4
3.2 Ash Removal Verification Protocol 4
3.2.1 Field Documentation 5
3.2.2 Fill Evaluation Criteria 5
3.3 Visual Removal Not Applicable 6
4.0 Soil Sampling and Analysis ............................................................................................................... 6
4.1 Soil Sampling 6
4.1.1 Scenario 1 7
4.1.2 Scenario 2 7
4.2 Fate and Transport Modeling 7
5.0 Documentation Summary ................................................................................................................ 8

LIST OF TABLE
Table 1 - Soil Parameters and Analytical Methods

LIST OF FIGURE
Figure 1 - Asheville Plant 1964 Ash Basin Grid Map

Excavation Soil Sampling Plan December 2016
Asheville Plant 1964 Ash Basin Revision 0
Page 1
1.0 Purpose
The purpose of this Excavation Soil Sampling Plan is to provide a standardized method for collecting soil
samples at Duke Energy North Carolina ash basins that are to be closed via excavation. Soil samples are
being collected following all visible ash removal from certain ash basins or other ash management units
referenced in Coal Ash Excavation Plans to support closure activities.
This Excavation Soil Sampling Plan is applicable to the collection of representative soil samples. Analysis
of soil samples may be chemical or physical in nature and may be used to determine the following:
 Extent and magnitude of constituent occurrence
 Input concentrations for groundwater fate and transport model
The methodologies discussed in this Excavation Soil Sampling Plan are applicable to the sampling of soil
in ash basin excavation areas. For the purposes of this plan, soils are those mineral and organic
materials remaining after all visible ash has been excavated.
2.0 Soil Sampling Methodology
2.1 Method Summary
This Excavation Soil Sampling Plan has been adapted from Environmental Protection Agency (EPA)
Standard Operating Procedures (SOPs) #2012 and #2006; and North Carolina Department of
Environmental Quality (DEQ) Attachment 1 Coal Combustion Residuals Surface Impoundment Closure
Guidelines for Protection of Groundwater, November 4, 2016.

Soil samples are collected directly using stainless steel or plastic trowel, spade, shovel, or scoops.
Following collection, soil is transferred from the sampling device to a stainless steel or plastic bowl to be
homogenized. Once homogenized, the soil is transferred into Duke Energy Laboratory supplied sample
bottles.
Soil samples will be submitted under chain of custody for the following analyses: total metals and
Synthetic Precipitation Leaching Procedure (SPLP) metals. Analytical methods for total metals and SPLP
metals are described in Table 1. Ash presence is quantitatively determined by polarized light
microscopy (PLM) by RJ Lee Laboratory (or other approved vendor). PLM analysis passes visible light
through a pair of polarizing filters to create optical effects used in identifying unknown materials. This
method is commonly used in asbestos and coal ash identification.
2.1.1 Equipment
 Stainless steel or plastic trowel, scoop, spade or shovel – used for collecting soil samples
from surface locations.
 Sample containers – To be supplied by Duke Energy Laboratory with appropriate
cooler(s). Estimated that 5-8 ounce samples bottles with Teflon-lined lids will be
Excavation Soil Sampling Plan December 2016
Asheville Plant 1964 Ash Basin Revision 0
Page 2
required for each sample location and sample depth. For return of cooler to the lab, ice
will be required.
 Gloves – used for personal protection and to prevent cross-contamination of samples –
nitrile, disposable, powderless.
 Field clothing and Personal Protective Equipment – used as specified in the site Health
and Safety Plan.
 Sampling flags – used for identifying soil sampling locations.
 Field notebook – a bound book used to record progress of sampling effort and record
any problems and field observations during sampling.
 Three-ring binder book – used to store necessary forms and record and track samples
collected at the site.
 Permanent marking pen – used to label sample containers, document field logbooks,
data sheets and chain of custody.
 Stainless steel or plastic spoon – used for homogenizing soil samples within a stainless
steel or plastic bowl.
 Stainless steel or plastic bowl – used for homogenizing soil samples, when applicable.
 Camera – used for photo-documentation of sample locations and samples.
 GPS – device used to obtain elevation, latitude and longitude of sample location.
 Trash bag – used to dispose of gloves and any other non-hazardous waste generated
during sampling.
 Decontamination supplies and equipment.
2.1.2 Sample Locations
General locations for soil sampling are determined by the soil scientist in the field at a rate of
one soil sample for every 1 acre of ash basin area excavated. Actual sampling locations on-site
may vary to account for site conditions and to allow collection of representative samples.
Representative samples reflect areas where all ash has been visually excavated and natural soil
is observed.
2.1.3 Collection of Representative Samples
For the purpose of this plan, surface soil is considered to range from 0 to 6 inches in depth while
deeper samples will be collected at a range of 2 to 2.5 feet below ground surface (bgs), 7 to 7.5
feet bgs, 12 to 12.5 feet bgs and 17 to 17.5 feet bgs (unless bedrock, refusal, or the water table
are encountered). A surface soil sample and deeper samples will be collected at each location
for every 1 acre of ash basin excavated. A new pair of nitrile gloves is worn at each sampling
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location and each depth. Each sampling location is recorded on the site map prior to collecting
the sample if location is not already noted on the map. The GPS location of each sampling
location (i.e. elevation, latitude and longitude), sample descriptions, and area photographs are
also recorded. All sampling equipment is decontaminated prior to use irrespective of depth. The
following procedure will be used to collect representative soil samples with a scoop, shovel,
trowel, geoprobe or excavator:
 Locate general sampling locations.
 Determine suitability of sampling location for a representative sample.
 If sampling location appears to reflect representative conditions that would allow
collection of a representative sample, proceed with sampling procedure. If
location is not indicative of conditions that would allow collection of a
representative sample, notify the project manager so an alternate location can
be identified.
 Using a decontaminated sampling instrument, remove the desired thickness and
volume of soil from the sampling area. The sampler must obtain enough soil to
fill five 8-ounce sample bottles.
 Transfer the sample into an appropriate sample or homogenization bowl. Non-
dedicated containers should be adequately decontaminated. Stir for
approximately one minute until there appears to be a uniform color and
consistency.
 Transfer homogenized sample to a labeled container(s) of appropriate size and
construction for the analyses requested.
 Secure sample container tightly.
2.1.4 Sample Preservation, Containers, Handling and Storage
Chemical preservation of soils is generally not recommended. Cooling to 4oC on wet ice is
usually the best approach, supplemented by the appropriate holding time for the analyses
requested.
The Duke Energy Laboratory will supply the appropriate sample bottles for the collected soil
samples. The sample volume is a function of the analytical requirements and the Duke Energy
Laboratory will ensure the appropriate number of bottles are supplied. Ensure chain of custody
is completed for sample bottle return to the Duke Energy Laboratory.
Table 1 contains a list of parameters to be analyzed with corresponding reporting units and
analytical methods. If a parameter or group of parameters is not included in Table 1, the
laboratory performing the analysis should be contacted to determine the appropriate sample
bottles, volumes, and preservatives.
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All non-dedicated sampling devices should be decontaminated and wrapped in plastic. The
sampling device should remain in this wrapping until it is needed. Each sampling device should
be used for only one sample and then decontaminated or disposed of. Non dedicated sampling
devices should be cleaned in the field using the decontamination procedure described below.
2.1.5 Decontamination
Decontamination procedures can be time consuming; having a sufficient quantity of sampling
tools available is recommended. All non-dedicated sampling equipment must be
decontaminated prior to reuse. Equipment decontamination consists of:
1. Detergent wash and brush cleaning
2. Tap water rinse
3. Deionized water rinse
4. Air dry
5. Wrap sampling tools with plastic
3.0 Visual Confirmation of Ash Removal
3.1 Pre-Excavation Documentation
Closure by removal is defined herein as removing the primary source (primary source of potential
constituents of interest) to the point that ash is not visible to the unaided eye at the ground surface.
Primary source ash is the main body of ash that was deposited in the basin. This method is intended
solely to verify and document primary source ash removal and is not intended to validate environmental
quality standards of the subsurface (considered the secondary source of potential constituents of
interest). Pre-excavation documentation would consist of:

 Review topographic mapping, aerial photography, construction drawings, and boring logs to
estimate the pre-ash placement topography and/or ash/soil interface

 Preparation of an ash basin figure illustrating a grid spacing of 100 feet (Figure 1). Each grid
point (node) will be assigned a unique identifier. Each node of the grid spacing (grid point) will
represent a visual verification location.

3.2 Ash Removal Verification Protocol
Ash excavation will be considered complete based on visual confirmation that all ash has been removed.
Ash removal will be based on sampling of the ash/soil interface and analysis by PLM. Soil samples will
be examined utilizing methods outlined in American Society for Testing and Materials (ASTM) D2488,
Standard Practice for Description and Identification of Soils (Visual-Manual Procedure). Vertical and
horizontal excavation of ash can terminate when the remaining material can be documented using PLM
to contain less than 50% ash.

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Project will excavate ash until a visible change in color or texture confirms removal. This location shall
be referred to as the ash/soil interface. If visual evaluation is inconclusive, then request additional
evaluation to confirm ash removal.

3.2.1 Field Documentation
Evaluate the excavated surface elevation relative to the pre-ash placement topography.
Periodically check bottom elevation to evaluate if fill is present above historic bottom elevation.
Visual confirmation will be performed on a 100 foot grid system (Figure 1) unless conditions
prevent such confirmation, as described in Section 3.3. Soil sampling will be performed on an
acre grid system and will be analyzed using PLM.

 Personnel will locate each node by GPS or survey control, determine elevation and
evaluate whether that point is above or below the historic bottom elevation.

 Personnel will then observe the surface area represented by the node to note if visible
ash is present at the surface. If present, the location should be documented and
excavation will need to continue. If the evaluation indicates the surface soils are
residuum or bedrock, then hand auger to two feet below surface (or refusal) and
perform visual-manual classification of the soils at the surface and depth according to
ASTM method D2488. Submit sample from surface and depth (or shallower if refusal)
for PLM analysis. The conditions shall be documented by taking photographs.

 The classification indicator for fly ash will be grey to black silt-sized particles with no
plasticity. The classification indicator for bottom ash will be grey to black sand to gravel
sized particles and porous. If the material cannot be positively identified as soil, submit
a sample for PLM analysis.

 If the node point elevation is near the historic bottom elevation and either (1) residuum
is indicated by observation or (2) soil is confirmed by visual manual classification (ASTM
D2488) and PLM analysis is less than 50%, then personnel can conclude the primary
source is removed.

3.2.2 Fill Evaluation Criteria
The following procedure provides an approach that can be used to ascertain if the fill can remain
in place. The procedure specified is based on the fill material and depth.

 If the elevation is less than eight feet above the historic bottom elevation and residuum
is not observed, then test pits may be excavated to historic bottom elevation or until
residuum or bedrock is encountered but no more than eight feet below the surface.
o Personnel will evaluate existing information to determine if the test pits are
necessary. If necessary personnel may recommend excavating test pits at a
frequency no tighter than 100 feet by 100 feet.
o If visible ash is not discovered based on information defined above, then the
primary source removal may be confirmed.
o If visible ash is discovered, then continue excavation.

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 If the elevation is more than eight feet above historic bottom elevation and residuum is
not observed, discuss with CCP Closure Personnel.
o CCP Closure Personnel will confirm historic information and recommend a
drilling and sampling program at a frequency no tighter than 100 feet by 100
feet to evaluate the presence of ash below the fill in accordance with the
information defined above. If unusual features are revealed by the drilling, CCP
Closure Engineering may request/recommend additional borings. Exploration is
to be performed by continuous sampling during drilling.
o If visible ash is not discovered based on information defined above, then the
primary source removal may be confirmed.
o If visible ash is discovered, then continue excavation.

3.3 Visual Removal Not Applicable
If possible, excavation of ash should continue even if groundwater is encountered. Visual
documentation cannot be completed where ash is under the water table. If Duke Energy cannot
complete visual removal because of site conditions or other restricting factors, documentation shall be
presented to DEQ.

Duke Energy anticipates that in locations where visual documentation cannot be completed, additional
ash characterization along with groundwater fate and transport modeling will be completed. Ash
characterization may consist of SPLP and/or other testing with results imputed into an updated site wide
groundwater fate and transport model. Details will be provided to DEQ for review and concurrence.

4.0 Soil Sampling and Analysis
4.1 Soil Sampling
Soil sampling of the remaining soils (less than 50% ash per PLM analysis) will be necessary to evaluate
the extent of potential secondary source depending on the depth of the water table and any proposed
institutional or engineering controls that may be used in the area of excavation. Soil sampling will not
be required if refusal or the top of bedrock are encountered or the remaining soils are below the water
table. Soil samples for laboratory analysis must be collected in a manner that will ensure a relatively
uniform distribution of particles throughout the six inch sample.
The systematic approach and design for soil sampling an analysis is dependent upon two scenarios:
 Scenario 1: Remaining soil (containing less than 50% ash per PLM analysis) is located above the
seasonal high water table and final constructed institutional and/or engineering controls will
restrict infiltration from the surface reaching the water table (e.g. installation of a liner system).

 Scenario 2: Remaining soil (containing less than 50% ash per PLM analysis) is located above the
seasonal high water table and infiltration from the surface would continue to reach the water
table.

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4.1.1 Scenario 1
Confirmation sampling will include discrete surface samples collected from the first six inches of
the soil. Sampling will be performed on an acre grid system. This sample collection
methodology shall be sufficient to characterize the horizontal extent of any remaining potential
secondary source impacts for comparison with the DEQ Preliminary Soil Remediation Goals
(PSRG). The samples shall be analyzed by a North Carolina certified laboratory for total
concentrations for the following parameters: antimony, aluminum, arsenic, barium, beryllium,
boron, cadmium, calcium, chloride, chromium (total and hexavalent), cobalt, copper, iron, lead,
magnesium, manganese, mercury, molybdenum, nickel, nitrate as nitrogen, pH, potassium,
selenium, silver, sodium, strontium, sulfate, thallium, vanadium and zinc. No SPLP testing is
required.

4.1.2 Scenario 2
Confirmation sampling will include collection of both discrete surface and subsurface soil
samples performed on an acre grid system. Discrete surface samples will be collected from the
first six inches of the soil and a subsurface soil sample will be collected at 2 to 2.5 feet below
ground surface (bgs), 7 to 7.5 feet bgs, 12 to 12.5 feet bgs and 17 to 17.5 feet bgs unless refusal,
bedrock or the water table are encountered. The use of a geoprobe or excavator is anticipated.
This sample collection methodology shall be sufficient to characterize both the horizontal and
vertical extent of any remaining potential secondary source impacts for comparison with the
DEQ PSRGs and/or input into the soil leachate model. The samples shall be analyzed by a North
Carolina certified laboratory for both total concentrations and SPLP for the following
parameters: antimony, aluminum, arsenic, barium, beryllium, boron, cadmium, calcium,
chloride, chromium (total and hexavalent), cobalt, copper, iron, lead, magnesium, manganese,
mercury, molybdenum, nickel, nitrate as nitrogen, pH, potassium, selenium, silver, sodium,
strontium, sulfate, thallium, vanadium and zinc.

4.2 Fate and Transport Modeling
Contingency for stabilization of remaining amounts of potential secondary source impacts in a manner
that will meet the intent of North Carolina Groundwater 2L Rules and closure requirements shall be
considered as site conditions dictate. Provisions to develop groundwater flow and transport models to
evaluate protection of groundwater criteria if some secondary source impacts are left in place shall be
considered. In addition, the possibility of metals leaching from a potential change in pH and
geochemical conditions related to dewatering and excavation shall be considered along with plans for
groundwater models to assess resulting site conditions.

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5.0 Documentation Summary
100’ x 100’ Grid Node (Figure 1) Visually confirm primary source removal and document with
photographs

Soil Sample Collection at a Grid Node (1 per Acre)
Depth/Test PLM Total Metals (Table 1) SPLP (Table 1)
0 – 6 inches X X X
2’ – 2.5’ X X X
7’ – 7.5’ N/A X X
12’ – 12.5’ N/A X X
17’ – 17.5’ N/A X X

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Table
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TABLE 1
SOIL PARAMETERS AND ANALYTICAL METHODS
TOTALS AND SPLP ANALYSIS
NORTH CAROLINA ASH BASINS TO BE CLOSED
VIA EXCAVATION

INORGANIC COMPOUNDS UNITS METHOD1
Aluminum mg/kg or µg/l EPA 6010D
Antimony mg/kg or µg/l EPA 6020B
Arsenic mg/kg or µg/l EPA 6020B
Barium mg/kg or µg/l EPA 6010D
Beryllium mg/kg or µg/l EPA 6020B
Boron mg/kg or µg/l EPA 6010D
Cadmium mg/kg or µg/l EPA 6020B
Calcium mg/kg or µg/l EPA 6010D
Chloride mg/kg or µg/l EPA 9056A
Chromium mg/kg or µg/l EPA 6010D
Cobalt mg/kg or µg/l EPA 6020B
Copper mg/kg or µg/l EPA 6010D
Hexavalent Chromium mg/kg or µg/l EPA Method
7199/218.7
Iron mg/kg or µg/l EPA 6010D
Lead mg/kg or µg/l EPA 6020B
Magnesium mg/kg or µg/l EPA 6010D
Manganese mg/kg or µg/l EPA 6010D
Mercury mg/kg or µg/l EPA Method
7470A/7471B
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Molybdenum mg/kg or µg/l EPA 6010D
Nickel mg/kg or µg/l EPA 6010D
Nitrate as Nitrogen mg/kg or µg/l EPA 9056A
pH SU EPA 9045D
Potassium mg/kg or µg/l EPA 6010D
Selenium mg/kg or µg/l EPA 6020B
Silver mg/kg or µg/l EPA 6020B
Sodium mg/kg or µg/l EPA 6010D
Strontium mg/kg or µg/l EPA 6010D
Sulfate mg/kg or µg/l EPA 9056A
Thallium (low level) (SPLP Extract only) mg/kg or µg/l EPA 6020B
Vanadium mg/kg or µg/l EPA 6020B
Zinc mg/kg or µg/l EPA 6010D
Notes:

1. Soil samples to be analyzed for Total Inorganics using USEPA Methods 6010/6020 and pH
using USEPA Method 9045, as noted above (or similar approved methods). Soil samples will
also be analyzed for leaching potential using SPLP Extraction Method 1312 in conjunction with
USEPA Methods 6010/6020 (or similar approved methods).

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Figure

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Figure 1 – Asheville Plant 1964 Ash Basin Grid Map
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