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HomeMy WebLinkAboutNC0001422_L.V. Sutton Excavation Plan 2016_20161201 L.V. Sutton Electric Plant Coal Ash Excavation Plan 2016 Update i Table of Contents I. Statement of Purpose ..................................................................................................... 1 II. General Facility Description ............................................................................................ 2 III. Project Charter ............................................................................................................... 3 IV. Critical Milestone Dates .................................................................................................. 5 V. Erosion and Sedimentation Control Plan ........................................................................ 6 VI. Dewatering Plan ............................................................................................................. 7 VII. Proposed Location(s) for Removed Ash ......................................................................... 7 VIII. Transportation Plan ........................................................................................................ 8 IX. Environmental and Dam Safety Permitting Plan ............................................................. 9 X. Contracting Strategy ......................................................................................................11 XI. Environmental, Health, and Safety Plan ........................................................................11 XII. Communications Plan ....................................................................................................12 XIII. Glossary ........................................................................................................................12 XIV. Reference Documents ...................................................................................................14 Exhibits Exhibit A: Excavation Soil Sampling Plan 1 I. Statement of Purpose Duke Energy Progress, LLC (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 L.V. Sutton Electric Plant (Sutton or Plant), National Pollutant Discharge Elimination System (NPDES) Permit No. NC0001422, in New Hanover County, as soon as practicable, but not later than August 1, 2019. 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 discussed in this updated Plan. This is a revision of the Coal Ash Excavation Plan dated November 13, 2015, which covers 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 Sutton. The Plan will generally be updated and submitted to NC DEQ annually. The Plan covers some of the work required by Part II, Sections 3(b) and 3(c) of the Coal Ash Act. The Act requires the closure of the ash basins as soon as practicable, but no later than August 1, 2019. However, the Act contains no requirement for the submittal of an excavation plan of the kind presented here. Thus, while the formulation, submittal, and review of this Plan will assist in Duke Energy’s work to close the ash basins, its ultimate approval is an action not specifically required by statutory, regulatory, or other applicable authority. The precise scope of work in excavating the ash basins has been determined by 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 2 consequence, neither the submittal of this Plan nor its a cknowledgement 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 Sutton is located in New Hanover County near Wilmington, NC, situated between the Cape Fear River to the west and the Northeast Cape Fear River to the east. Sutton was a three-unit, 575 megawatt (MW) coal-fired power plant. The Plant operated from 1954 until retirement of the coal-fired units in November 2013. Upon retirement of the coal-fired units, a new 625 MW gas-fired unit began operations. There are two CCR basins—the 1971 and 1984 Basins—and a large Cooling Basin. Both the 1971 and 1984 Basins contain fly ash, bottom ash, boiler slag, stormwater, ash sluice water, coal pile runoff, and low volume waste water. The Cooling Basin is accessible to the general public and is used for recreational purposes. The lake was classified as W aters of the State on November 5, 2014. One other area that contains CCR material is the Lay of Land Area (LOLA). The LOLA consists mostly of bottom ash and soil. Duke Energy’s Coal Combustion Residuals Removal Verification Procedure (Removal Verification Procedure) will be used to verify that primary source ash has been removed 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 for 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. 1971 Ash Basin The 1971 Basin was operated from 1971 to 1985. It was opened again in 2011 for temporary use during repair work and ash removal activities. The 1971 Basin is unlined and was initially constructed with a crest elevation of 18 feet mean sea level (msl), which was raised in 1983 to 26 msl. The 1971 Basin initially contained approximately 3.8 million tons of CCR material. The southern basin dikes of the 1971 Basin contain ash and will be excavated as part of final closure. 3 1984 Ash Basin The 1984 Basin was operated from 1984 to 2013. The 1984 Basin was constructed with a 12-inch thick clay liner at the basin bottom, which extends along the side slopes where it is protected by a 2-foot thick sand layer. The 1984 Basin crest elevation is 34 feet msl. In 2006, an Interior Containment Area (ICA) was constructed within the 1984 Basin with a crest elevation of 42 feet msl. The 1984 Ash Basin initially contained approximately 2.8 million tons of CCR material. LOLA The LOLA is located between the discharge canal and the coal pile. It is believed that the presence of CCR in this area may have been due to Plant operations between approximately 1954 and 1972. A small portion adjacent to the coal pile storage area was used to locate fuel oil storage tanks. The LOLA is on the North Carolina Inactive Hazardous Waste Sites Priority List. This area contains approximately 686,000 tons of CCR and soil mixture at depths of 0 to 15 feet. Current Operating Permit Details The Cooling Basin, 1971 Basin, and 1984 Basin are operated under NPDES Permit No. NC0001422 to regulate effluents to the Cape Fear River. Additionally, the dams of the Cooling Basin, 1971 Basin, and 1984 Basin are listed under the NC DEQ Dam Safety Program. The dam identification numbers for the Cooling Basin, 1971 Basin, and 1984 Basin are NEWHA-003, NEWHA-004, and NEWHA-005, respectively. The dam inventory lists the Cooling Basin and 1971 dams as exempt. The 1984 dam is listed as impounding, hence regulated. In 2014, these dams were re-rated as high hazard by NC DEQ. The 2006 ICA constructed within the 1984 Basin was permitted and used as a “basin within a basin,” where an interior dam was constructed on top of the CCR within the basin; sluiced CCR was excavated from rim ditches, placed within the interior basin, and compacted to heights that are above the exterior basin dams. This operation was discontinued before reaching the permitted final grades when the Plant was shut down in November 2013. III. Project Charter Dewatering of the ash basins and the removal of ash from the site is being 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. Initiated the removal of ash from the Sutton site 4 2. Began dewatering of the ash basins 3. Installation of a waste water treatment system to support dewatering of the ash basins 4. Development of option(s) for proposed ash disposal or beneficial use locations 5. Complete a work scope and bid event to support ash basin closure 6. Reroute approximately two miles of the Sutton Lake public boat ramp access road 7. Validate production rates to meet project requirements 8. Develop and construct the infrastructure to remove and transport the ash 9. Initiate the development and complete the permitting of the on-site landfill 10. Obtain permit to construct on-site landfill The Sutton NPDES waste water permit was issued to Duke Energy in December 2015. The removal of the bulk free water was completed on January 28, 2016. After the required waste water treatment was installed and operational, removal and treatment of the basin interstitial water commenced in June 2016. Based on revisions to the NPDES permit, the stormwater from the fossil plant has been rerouted and no longer discharges into the basins. Therefore, rainwater is the only inflow into the basins. Basin dewatering is currently being implemented on an as-needed basis to maintain the basins’ clear water ponds as low as reasonably possible. Under this Plan, the Company began removing ash to an off-site location while simultaneously developing an on-site landfill in order to meet the closure requirement mandated in the Coal Ash Act. The Sutton on-site landfill construction permit was received on September 22, 2016. This date is significantly later than originally forecasted and combined with the impacts of Hurricane Matthew on the landfill construction and ash movement, will move the projected completion date beyond the mandatory closure date of August 1, 2019. Schedule recovery opportunities are and will continue to be evaluated. Project Charter O bjective s Phase II Objectives 1. Continue to dewater the ash basins 2. Submit and obtain any necessary permits for Phase II activities 3. Excavate and transport ash from the 1971 Basin and 1984 Basin 4. Construct and operate cells for the on-site landfill 5. Gain knowledge and opportunities for program improvement that can be applied to the subsequent phase(s) Inactive Ash Areas Objectives 5 1. Submit and obtain any necessary permits for activities 2. Excavate and transport ash from the LOLA 3. Operate and close cells for the on-site landfill 4. Gain knowledge and opportunities for program improvement Project Charter Scope Phase II Scope 1. Submit and obtain applicable permits 2. Install required site haul roads 3. Continue dewatering of the 1984 and 1971 Basins 4. Commence landfill operation 5. Relocate several thousand feet of Piedmont Natural Gas gas line from the LOLA 6. Continue to excavate and transport approximately an additional 3.4 million tons of ash from the 1984 Basin and the 1971 Basin to an approved landfill, beneficial use facility, structural fill locations, or on-site landfill 7. Continue infrastructure activities that are required to support the future excavation of the LOLA 8. Continue infrastructure activities that are required to support the future excavation of the 1971 Basin southern dikes 9. Dredge and transport approximately 1.3 million tons of material from the 1971 Basin and the 1971 dikes 10. Complete closure activities for the 1971 Ash Basin and the 1984 Ash Basin as outlined in Part II, Sections 3(b) and 3(c), Subparagraphs 1 and 2 of the Coal Ash Act Inactive Ash Areas Scope 1. Excavate and transport the 686,000 tons of material from the LOLA to the on-site landfill 2. The LOLA will be closed as part of overall site closure, but is not subject to Part II, Sections 3(b) and 3(c) of the Coal Ash Act 3. Operate and close cells for the on-site landfill 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 November 30, 2014 Completed 6 MILESTONES NO LATER THAN DATE STATUS Engineering Review November 30, 2014 Excavation Plan Acknowledgement February 17, 2015 Completed February 2, 2015 Submit Updated Excavation Plan November 15, 2015 Completed November 13, 2015 Commence Work – Ash Removal Final permit approval + 14 Days Completed October 30, 2015 Receive NPDES Waste water Permit December 11, 2015 Completed December 2015 Receive Permit-to-Construct On- site Landfill February 29, 2016 Delayed due to environmental justice review; Completed September 2016 Receive Permit-to-Operate On-Site Landfill August 31, 2017 Delay due to environmental justice review; Forecasted to receive during third quater 2017 Submit Updated Excavation Plan December 31, 2016 On track Submit Updated Excavation Plan December 31, Annually On track Eliminate Stormwater Discharge into Impoundments December 31, 2018 Completed July 2016 1971 and 1984 Basins closed pursuant to Part II, Sections 3.(b) and 3.(c) of the Coal Ash Act August 1, 2019 Challenged due to permitting delay and Hurricane Matthew V. Erosion and Sedimentation Control Plan The project currently has several active Erosion and Sedimentation Control (E&SC) plans: Rail Road Extension (NEWHA-2016-023), Ash Pond Vegetation Removal (NEWHA -2016-006), Site Wide Clearing Activities (NEWHA -2016-025), Groundwater Well Installation (NEWHA -2016-020), and Boat Road Relocation (NEWHA -2016-008). Additional applications are expected to be submitted during this phase as the project planning develops. Modifications from E&SC plans for subsequent phase(s) will be approved by NC DEQ prior to installation and initiation of subsequent phase work. The approved contractor will install the E&SC measures indicated in the plan. All control measures will be maintained through the project in accordance with the E&SC plans and permits. When possible, portions of the E&SC plan will be closed out at the approval of NC DEQ as areas become stabilized. 7 VI. Dewatering Plan The Sutton ash basins will be dewatered to facilitate the removal of ash and to mitigate risk. Engineering analysis has shown that lowering the water below the level of ash within each basin does not improve the factor of safety against failure of the associated dam; therefore, removal of entrapped water is not required. An engineered Dewatering Plan for Sutton has been developed and dewatering has been in progress since October 2015. Interstitial basin dewatering will probably be required throughout the life of the project. The current 1984 Clear Water Pond water elevation is approximately one foot above the clay bottom. Pumping is managed to control the water level as low as reasonably possible. The current plan calls for the removal of ash from the 1971 Basin through different methods than from the 1984 Basin and the LOLA. Heavy equipment operation directly on top of the ash in the basin has been deemed impractical due to high groundwater recharge rates. Therefore, the removal of the ash from the 1971 Basin incorporates hydraulic dredging and dewatering of the resulting dredged material. The water generated during ash removal will be directed back to the 1971 Basin. VII. Location(s) for Removed Ash Ash removed from the site will be transported by the contractor to permitted facilities. The ash storage location will be managed and maintained to ensure environmental compliance with applicable rules and regulations. Disposal Sites Brickhaven Structural Fill and the on-site landfill at Sutton have been identified as the primary disposal locations. DISPOSAL SITE LOCATION APPROXIMATE AMOUNT (TONS) CCR DISPOSAL Brickhaven Structural Fill Moncure, NC 2,000,000 Structural Fill On-Site Landfill Wilmington, NC (Sutton) 5,300,000 Landfill Brickhaven Structural Fill The Brickhaven Structural Fill is located at the Brickhaven Mine near the City of Moncure in Chatham County, NC. It resides on approximately 299 acres. Ash will be transported and will be beneficially used as fill material for a structural fill project at the reclaimed mine. 8 Sutton On-Site Landfill Ash excavated from the basins and LOLA will be disposed of in the proposed on-site CCR landfill. The project includes the installation of a liner and leachate collection system for the landfill. The proposed landfill footprint is approximately 100 acres and will provide approximately 8.3 million cubic yards (approximately 10 million tons, assuming a density of approximately 1.2 tons/cy) of disposal capacity over a period of approximately 12 years; however, construction of the cells is expected to be complete within 10 years. The maximum elevation of the proposed landfill will be approximately 112 feet North American Vertical Datum (NAVD88) with an average top-deck elevation equal to 108 feet NAVD88. Contingent Plan: Disposal Sites Colon Structural Fill The Colon Structural Fill is located at the Colon Mine in Sanford, NC. Ash would be transported from Sutton to the Colon Structural Fill to be beneficially used as fill material for a structural fill project at the reclaimed mine. The Company continues to develop and evaluate contingency storage locations in the event this scenario becomes unobtainable. Contingency plans currently being developed include assessing alternate ash disposal locations and beneficial use. Subsequent Ph ase(s): Disposal Sites The project team will utilize lessons learned from Phase I and II 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  Develop a supplier-diverse program to drive innovation and competition  Establish performance baselines and a system to optimize pickup, transport, drop-off, and beneficial use of ash VIII. Transportation Plan Ash will be transported from the site via rail car and truck to the off-site facility. Transportation of the CCR will be conducted by approved transporters and meet Department of Transportation (DOT) and other applicable federal, state, and local regulations. 9 Phase I : Transportation For Phase I, all CCR transported off-site will be transported by rail and truck from Sutton to the Brickhaven site. Rail car loading operations will be completed with a crew working typically 12 hours per day, seven days per week. Truck operations are not currently in progress at Sutton. Contingent Plan: Transportation In the event of prolonged rail transportation disruption, truck transportation remains a contingency option. Subsequent Phase(s): Transportation Transportation to the on-site landfill will be by off-road truck. IX. Environmental and Dam Safety Permitting Plan Phase I includes the excavation and removal of ash from the 1984 and 1971 Basins to an off-site location. Implementation for Phase I began once the permitting for Phase I was obtained in October 2015. Excavation of ash creates potential for stormwater impacts. Since Sutton has no point source discharges consisting solely of industrial stormwater, NC DEQ determined that an individual industrial stormwater permit is not necessary. Instead, NC DEQ has included internal stormwater outfalls and the requirement to develop a stormwater pollution prevention plan as a requirement of the NPDES waste water permit. Future modifications to the permit/plan will be managed as necessary. NC DEQ has determined that removal of dry ash from the Sutton ash basins can be regulated via the Construction Stormwater General Permit. Ash removal activities were permitted when NC DEMLR approved erosion control plan NEWHA-2016-023. NC DEQ determined that dewatering activities, including free water removal, required a NPDES waste water permit modification. Based on this requirement, the Company applied for a permit modification to specifically allow decanting of free water and dewatering of interstitial water. Application was made in January 2015. The Company received the modified NPDES permit in October 2016. There are no jurisdictional wetlands/streams associated with the removal of ash from the 1984 and 1971 Basins during Phase I and II. The current and future wetland/stream impacts and jurisdictional determinations will be managed through the United States Army Corps of Engineers with particular attention paid to the difference between 10 jurisdictional wetlands/streams under Section 404 and those arising from Section 401 waters. Any Section 404 individual permitting will require Section 401 Water Quality Certification by NC DEQ. Sutton ash is not classified as a DOT hazardous material. Subsequent phase(s) will include dewatering and continued excavation and removal of ash from the 1984 and 1971 Basins and the LOLA. Subsequent phase(s) also include(s) the continued construction of the on-site landfill. Before shipping ash to a third-party RCRA Subtitle D landfill, waste characterization and approval will be completed. All necessary Dam Safety approvals will be obtained to cover activities on or around jurisdictional dams. Breaching of the dams will require Dam Safety approval. Any impacted wells or piezometers will be properly abandoned in accordance with NC DEQ requirements. Fugitive dust will be managed to mitigate impacts to neighboring areas. Permit Matrix MEDIA PERMIT RECEIVED DATE (R) / TARGET DATE (T) COMMENTS Water NPDES Waste water Permit – Major Modification October 2015 (R) None Jurisdictional Wetland and Stream Impacts/ 404 Permitting and 401 WQC September 2016 (R) Four cells in the new Sutton landfill have identified jurisdictional wetland/stream impacts in Phase I. Wetland permits have been received. Dam Safety Dam Decommissioning Request Approval March 30, 2017 (T) Initial transporting and excavation activities will not impact a jurisdictional dam or dike. Breaching of any dike will require Dam Safety approval. Waste Individual Structural Fill Permit to Operate October 15, 2015 (R) Mine reclamation Owner/Operator obtained a structural fill permit as set forth in Part II, § 130A-309.219 of the Coal Ash Act. Site Suitability Report July 2, 2015 (R) Site Suitability obtained for Sutton landfill and the Brickhaven Mine off- site structural landfill. Previous date was March 31, 2015. Change was related to additional requirements to complete the report prior to submittal. 11 MEDIA PERMIT RECEIVED DATE (R) / TARGET DATE (T) COMMENTS Permit-to-Construct Landfill September 2016 (R) The permit to begin construction and corresponding E&SC have been received. Previous Target Date was February 23, 2016. Construction is in progress. Permit-to-Operate Landfill August 31, 2017 (T) Previous Target Date was November 23, 2016. Must provide Construction Quality Assurance Report and then receive the permit before operation. Delay is due to environmental justice review. Other Requirements Site Site-Specific Nuisance/Noise/Odor /Other Requirements, including DOT and FERC Requirements N/A None identified. 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 contractors 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 The Company is committed to the health, safety, and welfare of employees, contractors, and the public, and to protecting the environment and natural resources. During all phases of the project work, the Company 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. 12 The project includes 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 The project team is coordinating with Duke Energy’s Corporate Communications Department to develop a comprehensive external communications plan tailored to the specific needs of each phase of the project. Many different external stakeholders, including neighbors, government officials, and media have an interest in this project. 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. XIII. Glossary TERM DEFINITION Ash Basin Synonymous with Coal Combustion Residual Impoundment. A topographic depression, excavation, or dammed area that is primarily formed from earthen materials; without a base liner approved for use by Article 9 of Chapter 130A of the General Statutes or rules adopted thereunder for a combustion products landfill or coal combustion residuals landfill, industrial landfill, or municipal solid waste landfill; and an area that is designed to hold accumulated coal combustion residuals in the form of liquid wastes, wastes containing free liquids, or sludge, and that is not backfilled or otherwise covered during periods of deposition. Ash Stack A dry ash storage feature external to the ash basin Beneficial and Beneficial Use Projects promoting public health and environmental protection, offering equivalent success relative to other alternatives, and preserving natural resources Bottom Ash The agglomerated, angular ash particles formed in pulverized coal furnaces that are too large to be carried in the flue gases and collect on the furnace walls. Bottom Ash falls through open grates to an ash hopper at the bottom of the furnace. 13 TERM DEFINITION Bulk Water Water above the ash contained in the ash basin; synonymous with free water 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) Residuals, including fly ash, bottom ash, boiler slag, mill rejects, and flue gas desulfurization residue 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 Engineer of Record Duke Energy or third-party contracted engineer responsible for final verification of specific plan actions and documents Entrapped Water Water below the ash surface, which creates hydrostatic pressure on the dam Excavation Activities Tasks and work performed related to the planning, engineering, and excavation of ash from an ash basin Excavation Plan Refer to Coal Ash Excavation Plan Factor of Safety In reference to dam safety, the ratio of the forces or moments resisting mass movement to the forces or moments tending to produce mass movement Free Water Water above the ash contained in the ash basin; synonymous with bulk 14 TERM DEFINITION water Fly Ash Very fine, powdery material, composed mostly of silica with nearly all particles spherical in shape, which is a product of burning finely ground coal in a boiler to produce electricity and is removed from the plant exhaust gases by air emission control devices. LOLA Lay of Land Area NPDES National Pollutant Discharge Elimination System NPDES Permit A permit that regulates the direct discharge of waste water to surface waters Off-Site Facility A structural fill or mine reclamation for the long-term storage of coal combustion residuals Permitting Federal, state, county, or local government authorizing document 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 Excavation Soil Sampling Plan December 2016 L.V. Sutton Plant 1971 & 1984 Ash Basins Revision 0 EXHIBIT A EXCAVATION SOIL SAMPLING PLAN L.V. SUTTON ENERGY COMPLEX 1971 & 1984 ASH BASINS 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 L.V. Sutton Plant 1971 & 1984 Ash Basins Revision 0 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 - L.V. Sutton Plant Ash Basin Sampling Plan Excavation Soil Sampling Plan December 2016 L.V. Sutton Plant 1971 & 1984 Ash Basins 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 L.V. Sutton Plant 1971 & 1984 Ash Basins 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 Excavation Soil Sampling Plan December 2016 L.V. Sutton Plant 1971 & 1984 Ash Basins Revision 0 Page 3 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. Excavation Soil Sampling Plan December 2016 L.V. Sutton Plant 1971 & 1984 Ash Basins Revision 0 Page 4 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. Excavation Soil Sampling Plan December 2016 L.V. Sutton Plant 1971 & 1984 Ash Basins Revision 0 Page 5 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. Excavation Soil Sampling Plan December 2016 L.V. Sutton Plant 1971 & 1984 Ash Basins Revision 0 Page 6  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. Excavation Soil Sampling Plan December 2016 L.V. Sutton Plant 1971 & 1984 Ash Basins Revision 0 Page 7 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. Excavation Soil Sampling Plan December 2016 L.V. Sutton Plant 1971 & 1984 Ash Basins Revision 0 Page 8 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 Excavation Soil Sampling Plan December 2016 L.V. Sutton Plant 1971 & 1984 Ash Basins Revision 0 Table Excavation Soil Sampling Plan December 2016 L.V. Sutton Plant 1971 & 1984 Ash Basins Revision 0 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 Excavation Soil Sampling Plan December 2016 L.V. Sutton Plant 1971 & 1984 Ash Basins Revision 0 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). Excavation Soil Sampling Plan December 2016 L.V. Sutton Plant 1971 & 1984 Ash Basins Revision 0 Figure Excavation Soil Sampling Plan December 2016 L.V. Sutton Plant 1971 & 1984 Ash Basins Revision 0 Figure 1 – L.V. Sutton Plant Ash Basin Sampling Plan