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Home My WebLink AboutNC0005088_CSS Excavation Plan Rev1 RED LINE_20151007Cl ffs ire Stearn Station at the Rogers Energy Complex Coal Ash Excavation flan for Units 1-4 and Un t 5 Inactive Ash Basins • Address Not ces of Deficiency ('DUKE ENERGY October 7, 2015 C|hfaid8 St, --am ERctivn at tfig RVy*ns EOeryy [nnlp|ex Uoa|Ash Exuavatiun Man tor Units 1-4 and U,it5 InautiveAs5 Basins Uctober 7, 2015 Table of Contents iS1ateMmeni of PU[posc................. ................................................................................................. 2 |i Uenera|Fachhv Description ......... ........ ............... ............................................................. ....... 4 UiMaur .............................. ....... ....................................... ................................................ 7 |V. Milestone DateG—................ ...................................... .......... ....................... ----------8 V. Maintaininy Dam SatetvDuring ' .... ......... ............................ ......................................... 9 Vi\A/aie[ Manayerriunt .......... ............... ............................................................................................ 9 VU. | ranspurtation and Storage OfEoMLvEi1eaASM ............................. ......................................... 1O \H|i EloSt L;Dn1ru|......... .............. ............ ........................................................................................... d] |x. EnVironrnenia|PermhIinyMan .................................................................................................. 1 A LtherEnvironmental Issues .................... ............................................................................. ... 1S XiCurivautiny Strateyy ............................. ..................................................................................... 1S XURealth and Gafe/v........ ......................................................................................... ..................... 1S XxiL;Dn1rnuni:a1kno Plan ............ ..................................................................................................... LG X|\/ Gk]ssa/y..................................... .................................................................................................. 17 1 Cliffsidu Steam Station at the Rogers Eneryy Complex Uual Ash Excavation Plan for unites 1-4 and unit 5 Inactive Ash Basins October 7 2015 Statement of Purpose DaRe Energy is implementing a cumprenensive long-term ash basin strategy to close basins and safely manage asH throughout North Carolina. i he LAtiside Steam Station at the Roycrs Energy Complex (hereafter Cliffside) has the tollowing ash basins: Units 1-4 Inactive Ash Basin (U1-4 Basin), Unit 5 Inactive Ash Basin (U5 Basin), and the Active Ash Basin, which iiidodes two ash storage areas. The purpose of this Ash Excavation Plan (Plat i) is to present the approach for excavatir ig a portion of the ash from the W-4 Basin and the U5 Basin to address I9otices of Deficiency (NOD) issued by the I9orth Carolina Department of Environment al Quality (IAC IDENRDEQ). Subsequent apdates to tHis Plan and / or the closure plans will address the remaining ash excavation and dam decommissioning of the 01-4 Basin, including water re-ruate, and closure of the U5 Basin. c;lusare plans will be prepared and soDmitted to NC PE#RDE0 in Oututier 1u16 for the U1-4 Basin, U5 Basin, and Active Ash Basin. Duke nergy received a NOD from NC DEWPDEu on March 5, 2014 for the "high hazard potential" of the Cliffsidc Inactive ASH Basin 1-4 Main Dam doe to the potential for significant environmental damage to the Broad River if the coal asH shred behind the dam were to be released. On September 30, 2ui4, DaRe Energy submitted the drawing package titled inactive Ash Basin 1-4 Main L)ar11 ((LtvE - 047), High Ha4ard Flofe"Tial Storm Storage Excavarivn far Clinside Steam Station, Clevelan8 ane Hutnerford Counties, NaiTh Carolina. September 2014, to NC dRDEU to provide a basis to resolve the issues identified in the NOD. On Jai wary v6, tui 5, NC DENRDEQ issued a letter approving the drawing packayc. Based on these drawings, Dake Energy will excavate approximately 84,uuu cubic yards (or approximately i ui ,uuu tons) of ash and material from the 01-4 Basin to increase stormwater storage capacity; increase freeboard, and validate hydrology & hydraulics analysis to allow the retirement of decant riser/outfall pipe. Based on the Nuu, the basin's location adjacei a to the Broad River, and the strau-taral integrity analysis performed under the Disposal at the Coal Combusf on Residuals tram tlectric Utilities published by the U.S. Environmental Protection Agency on April 17, 2015, which ii idicates that insufficient factor of safety exists in the event of an varthquaRe, DaRe Energy proposes to excavate the remainder of the ash and cluse the u 1-4 Basin under the Coal Ash Management Act of 2014 (CAMA). DaRe Energy received another NOD from NC DENRDEQ on March 5, W4 categorizing the Cliffside Inactive Ash Basin #5 Main Dam as a "higH Hazard" dam due to the potential for significant environmental damage tv the Broad Hiver if the coal ash stored buMind the dam were to be released. E Cliffsidc Steam Station at tnic Ruyers Enteryy Uornplex ( , ,r! Ash Excavation P! -an for UniTS 1-4 and Unit F I- e;,,.- n -k Ira.; - Uctobe_ r 7. 2015 On November 14, zu14, Dake Energy submitted the drawing package titled Inacrive Asn Basin ##b Main Varrn (HUI HE — 070), High Hazard Poieniial, Srorm Std -rage Excavation ror Llinside Steam Station, Rutherford County, Nurrh Carutina, I9uvember 2014, to NC PENIRDEQ to provide a basis to resuive tMe issues identified in the NOD. On February 2, 2015, NC QF=WRuEQ issued a letter approving the drawing paakaye. Based on these drawings, Duke Eneryy will excavate approximately 400,000 cubic yards (or approximately 500,000 tuns) uT asM and material from the U5 Basin Tu inurease sturmwater sturage capacity, increase freeboard, and validate hydruiugy & hydraulics analysis in order to retire the decant riser/outfall pipe. This Plan covers some of The wurk that may 6e required by CAMA. CAMA contains nu requirement fur the sa6mittal ut all excavation plan of the kind presented here. i has, while tMe Tormaiation, submittal, and review of this Plaii will assist in Dake Energy's work to close the ash basin and provide transparei icy to 19u , its approval is an action not specifically requii ed by statatury, regulatory, or other applicable authority. Additionally, it may beuurne necessary for Duke Energy to modify the Plai, Tu address uther legal requirements or factors that develop during ash Cxuavatiun. Significant cHanges to this Plan and final closure requiremums a, a plans win 6e included in annual updates to the Plan (by Deuember 31 of each so5sequent year) and/or in the final closure plan that DaRe Energy will submit to NC by October 2015. I He precise scope of work for excavating the ash will be determined by applicable laws, rules, permits, and approvals that cuntrul the activities to be performed under the Plan. The water quality permit for tMe discHarge from the basins (National Pollutant Disuharge Eliminatiun System Permit No. NC0005088) or its reissuance ur amendment (igPDES Permit) could contain terms that control or affect the scope uT tMat work. NC filed legal cases in Superiur Cuarrt (lvc.; PF= DEQ Cases), which may be resolved Thrunyh decision ur settiement. IAC PE DEQ also sent Duke EnCryy a Nutiue uT violation (Iwv) because an NPDES StormwaTer Permit had nut Been received Tor the site, the resolution of which could have an effeut on the activities discussed here. All of The abuve (CAMA, Inc; PE-WRDEQ Letter, NPDES Permit, NC Cases, NOvs, and tMe U.S. EPA CCR Rule) are illustrative of acTiuns that uuaia putentiaily affect the precise scope of the work To be performed ander the Plan. As a consequence, neither The submittai uT tMis Pian nor its acknowledgement by NC should GC taRen as requiring actions different from other such appiicabie requirements. Thus, Duke Energy submits This Play To NC based on the understanding that it may be necessary Tu make 0miges in tMe Pian in the future to reflect any such acTiuns and reserves tMe rigHt to make such changes after initial submittal of the Play i. Cl Clittside steam Station at the Royers Energy Complex Coal Ash Exp: iwitiun Pian Tor units 1-4 ana unit 5 Inautive Asn Basins Oc;tybur 7,. 2u15 GCncral Facility Description c;littside is legated at 5t3 DuRe Power Road in Mooresboro, North Carolina in Cleveland and Rutherford Counties. Cliffside went into initial operation in 1939 with one coal-fired unit and was subsequently expanded to 6 coal fired anus. Units 1-4 were retired i►, zul1, and Unit 5 (wmmissioned in 19ig) and Onit 6 (cummissiened in 2012) continue to operate witH a combined capacity of approximately 1,387 megawatts. Cliffside Ash Faciliries Ciftide Has tMe Tellowing ash tacnities (as outlined in t-igure 1): Units 1-4 Inactive ASF Basin (01-4 Basin) VP Unit 5 Inactive Ash Basin (U5 Basin) • Active Ash Basin, which includes two ash storage areas • c;liffside Landoll As noted in Section I, this Plan presents the approach for excavating approximately 84,000 cubic yards (er approximately l ui ,uuu tans) of asn and material trem the 0-1-4 Basin and approximately 400,uuu ca6ic yards (or approximately 500,000 tons) of ash and materiae trom the U5 Basin. Subsequent updates to this Plan and / or the closure plans will address the remaining ash excavation and dam decommissioning of the U1-4 Basin, including water re-roate, and ulusare of the U5 Basin. Milts 7-4 IfiactivO Asn bash► uescription and History The U1-4 Basin and dam (NC Dam ID: CLEVE-u4t) were wnstraated i.. 1951 to receive ash and remained in service tHrvagH ivtt. i He Basin contains approximately 424,000 tons (est.) of ash and material, including approximately two feet of cover soil. Vegetative cover has been established on the cover soil. The U1-4 Basin outfall is a reimorued concrete drainage tower witH 6ettem discharge into a 30 -inch diameter corrugated metal pipe (CMP), which extends approximately 180 feet horizontally through the base of the embankment near the east end of the dam. The U1-4 Basin oatfall disuharyes to the Broad River and is identified as Uattall OOZA a►der NPDES Permit #MCuuu5u88. Five (5) interconnected holding cells for stormwater and plant prec;ess water were coiistramed i►, the west Nvrfivn of the U1-4 Basin. water from these Fielding ceiis is pamped to tFie Active ASH Basin to tMe east witH discharge through Outfall 002 to the Broad River under NPDES Permit #NC0005088. Additional information regarding water management and re-routing is incorporated into Section V, Warer Management. 4 ClirTJiaC Steam Station at Vie Rvyers tiiieryy UUmplex Coal Ash Excavation Plan tar Univs 1-4 and Unit 5 Inactive Ash Basins October 7, 2015 Visit 5 Irraotive Asn dasin ULsoription and History The U5 Basin was created by the coy istraction uf two dams i, i 95y- tu, the Main Dam (RUTHE-utu) aid the Saddle Dam (Ru I RE-ui1). 6otn dams are earth -filled em5anF(ments. The outlet for the U5 Basin is a corrugated metal pipe riser ui ivased ii, aunarete tHat turns yu deyrees nitu a 50-inuFi diameter reinturued concrete pipe; which extends tMruagh the a5atment ut the Main Uam. The U5 Basin contains approximately 2.3 million (est.) tu� is of ash aid material, inuladiny an estimated i million pubic yards of wiistrautiun material trom Cliffside Unit b. 5turmwater tram approximately 165 acres flows into the basin and discharges through the outfall. The U5 Basin became inautive in i v5u. 5 Clitfside Steam Station i at the RvyCr5 Ei ieryy CumNICx Uual Ash Excavation Plan tor Units 1-4 and Unit 5 Inactive Ash Basins Uptuber 7, 2015 Project Charter The prujeut unaffer tur Uittside u1-4 arid 05 inactive Ash Basins Excavation Project is to: • U1-4 Basin — Ewavatc appruximately E34,uuu cal5ic yards (or approximately i ui ,uuu tuns) ut asM and materia, and retire the riser pipe (e.g., grout the basin oattail pipe). • U5 Basin: Excavate approximately 4uu,uuu eabie yards (or approximately SuU,uuu tuns) of asM and material, and retire tMe riser pipe (e.g., grout the basin oattall pipe). Subsequent updates to this Plan mid / or the elosare plans will address the remaining ash excavatio,, and dam decommissioning ut tMe 01 -4 Basin, including water re-route, and ulosare of tMe 05 Basin. Project Charter ObJectIvc5 Objectives U1-4 Basin: 1. Excavate approximately 84,000 c;abic; yards (or appruximately i Ui ,uuO to, ut ash and material frum the W-4 Basin 2. increase treel5oard and stormwater storage volume to safely contain the design storm event 3, Prepare the Basin for fatare c;lusare ander a NC approved c;lusare plan U5 Basin: 1. Excavate approximately 400,000 uabic; yards (ur approximately 5uu,uuu tuns) ut ash and material from the u5 Basin 2. increase treel5uard and stormwater storage volume to safely contain the design storm event 3. Prepare the Basin fur future closare ander a lqC - approved closure plan Project Charter Scope U1-4 Bes;n i . u5tain all applic;a5le permits for worn 2. Develop necessary plans (e.g,, storm water pollution prevention plan, work plans, readiness reviews, etc.) I Llittside Steam Station at the Rogers EFicryy t;vmpicx Coal Ash Excavation PI7iri t,,r Units 1-4 and Unit 5 Inactive Ash Basins gtut7er 7, 2015 3. Mobilize and prepare site 4. Excavate approximately 84,uuu cubic yards (or approximately 101,000 tons) of asH and material and transport to Cliffside`s on-site landfill fur placement 5. Control fugitive dust emissions 6. Perform pre- aid post-exuavatiun surveys to confirm that the required stvrmwater storage capacity (approximately 84,000 cubic yards) has been created 7. Grout basin outfall pipe U5 Bann Suvpu i . 06tain all applicable permits for work 2. Develop necessary plans (e.g., storm water pullatiun prevention plan, work plans, readiness reviews, ctu.) 3. Mobilize and prepare site 4. Excavate approximately 400,000 cubic yards (or approximately 500,00u tens) at ash and material and transport to Cliffside°s on-site lanatiii for placement 5. Control fugitive dust emissions 5. Perfurm pre- and pont-excavation surveys to confirm that the regairea sturmwater storage capacity (approximately 400,00u uatiic; yards) has been created 7. Grout basin outfall pipe IV. Milestone Dates Milestones within the Plan are summarized in the table below and are uuntingent on receipt of regulatory approvals and necessary permits. Submit Excavation Plan September 11, 2015 Mobilize and pre are site _September 21, 2015 September 21, 2615 October 1, 2015 Receive Excavation Plan acknowledgement Receive Industrial Stormwater Permit _ Commence U1-4 Basin ash excavationOctober 12, 2015 Commence U5 Basin ash excavation _ January 4, 2016 Complete U1-4 Basin ash excavation (approx. 84,000 cubic yards) Grout 1.11-4 Basin outfall pipe February 2016 February 2016 Complete U5 Basin ash excavation (approx. 400,000 cubic yards) September 2016 Grout U5 Basin outfall pipe October 2016 C Clittside Steam Station at the Rogers Energy Complex Cual Ash Exuavatid-,n PEan TOO Units 1-4 arse? unit 5 Inactive Asn Basins QLAUDer 7, 2u15 V. Maintaining Dam Safety During Prviect I he basin darns are not being excavated during_this phase of the project as described in Section 1 Statement of Purpose, and the excavation will be uyndaged in a manner to ensure that the dam material is avoided. witH regard to the u1-4 Basin dam, an application was submitted to Dam Safetyr on July 29, 2015 to remove the corrugated metal pipes (CMP tog drains). The CMP toe drains are Ioiated at the buttom of tMe downstream dam slope, extend only 15 feet into the dans, ana are not near the excavation area. I he I9NDES permitted gattall uv2A will also be avoided during excavation and will be closed by grouting once the 84,000 cubic yards of ash and material have been excavated. The outfall in the U5 Basin will also be closed by grocaing once the 40u,uuu pu5ig yards of ash and material Have been excavated. In order to ensure dam safety, the CMP toe drain remuval and oattall closure will 6e conducted in a manner to ensure that the dam is nut compromised during excavation. Additionally, the impoundment's downstream face will be monitored weekly during excavation activities to ensure no other drainage pathways are activated daring excavation. Water Management Urns 7-4 litaUTivP ASn tfaShi The U1-4 Basin contains a yard drainage basin (i.e_. five (5) intereni,eated water hgldi, y gulls) that receives sturmwater and process water tram caittside, inclading ranott tram the coal yard, I His yard drainage basin has three (3) pumps in Cell 1, which pump this water to the Active Ash Basin. The water in the Active Ash Basin is discharged to the Broad River via Outfall 002 ander the NPDES permit ;FNCuuu5u88. Samp(s) witH pumps and tempurdry dituMes will lye cunstracted to tacilitate the remuval of any water tHat accumulates witHin the asn excavation area. This water will be pumped into the U1-4 yard drainage basin or the piping system that transmits the water to the Active Ash Basin consistent with the current process. The NC WENMDEQ NPDES Permitting U, it has reviewed and aotHuriced tHis apprvacH in an email dated dune 9; 2015. The process water and stormwater currently flowing into the U1-4 Basin yard drainage basin must be re -roared by April 1 t, zOi t ander uuR stability damunstration requirements. AltHuagH plans are still ander development; a tempurary water holding ;ell will be cunstructed, and the waterflowing into the U1-4 basin will be rerouted to that cell and then pumped to the Active Ash Basin consistent with current operations. 9 ulittside Steam Station at the Rogers Energy Complex Coal Asn Ext aavatiun PI�:m t,,r units 1-4 ana unit 5 Inaotive Ash Basins ,,;tuber 7, 2u15 Unit 5 Inactive Ash Basin The U5 Basin receives water intlow tram (1) rainwater that falls on top of the Basin, (2) rainwater runoff from adjacent land, and (3) two small streams. The U5 Basin dues not receive any process water from Cliffside. Rainfall and stream water tHat accumulates in the excavated area of the U5 Basin will be pumped to the U1-4 yard drainage basin where the water is currently pumped to the Active Ash Basin, which discharges under the existing NPuES perr—nit. i He IAC &E4RDEQ NPDES Permitting unit has reviewed and aatHorized this approach in an email dated September % lug 5. "1� I"' i ransportation and Storage of Excavated Ash Excavated ash will be transported from the U1-4 Basin and U5 Basin to ulittside's on- site landfill via internal roads using tracks. i hese internal roads are owned by Duke Encryy, are secorea with controlled access, and are not accessible to the public. The trucks used to transport the ash will be inspected daily. Thu beds and tail gates will be inspected and maintained in youd condition to prevent luss/spillage of ash during Transport. The ash in the traaR beds will be covered/tarped or sprayed with water or a dust sappression agent to prevent dust emissions during transport. Ash excavated from the U1-4 Basin and U5 Basin will be placed in the Cliffside on-site landfill. which is permitted by ISL Division of Waste Management, Solid waste 5ectiun, as an Industrial Solid Waste Landfill Facility (Permit No. 8106 -INDUS - 2009). The Cliffside landfill is currently used for storage of buttum ash, flyash, and gypsum generated by daily uperatiun of the existing goal tired units. Unloading, spreading, and cumpactiun ut asH at the Cliffside on-site landfill will be performed in accordance witH the 19C approved operating plan for the landfill. Expansion of the Cliffside Landfill (Landfill Phase 1) is currently ander construction and is antic;ipatcd to be in uperatiun and available Tor placement of excavated ash in r-ebraary 108. V41 -Willi. Dust Control Appropriate measures will be used to minimize dust umissiuns daring all pufflons ut the work including Cxuavatiun, transpurffation, and unloading of the ash. Dust control measures that may be used include; but are not limited to, spraying water on dry ash during excavation or on stockpiled ash that is staged for loading trucks; applying water or chemical dust suppressions/fixatives to cxpused ash surfaces prior to weeRends or forecast windy cunditiuns; use of tarps on damp trac;Rs during transport; use of speed iu Llittside Steam Station at the Rogers Energy Complex foal Ash Exuavation i -17m, re -x Om;t . 1-4 ; nrl Finit 5 Ire-...,,,,., n.,-. Outu6er 7, 2u15 limits; and application of water and/ur chemical dint suppression agents on gravel roads. Visual r„unituring will be performed to evaluate the effectiveness of dust control measures and guide implementation of additional dust controls as necessary. Environmental Permitting Plan Through the submittal of this Plan, Duke Energy is seaRing to interm I9C that all necessary permits and approvals have been identified and will be obtained for the performance ut tMe wurR. An Industrial Stormwater Permit is needed to cover storm water management activities during ash eAuavatiun activities at Lliffside: tnereture, DaRe Energy submitted an applivatiun to I4L 5EWRQtQ for an Industrial Stormwater Permit in August 2014, As part of the Industrial Stormwater Permit requirements, Duke Energy will prepare and implement a Stormwater Pollution Prevention Plan (SwPPP), including Best Management Practices (BMPs). i He EMP measures will be installed during or prior to the mobilization stage et the project to minimize discharge of sediment to Waters of the United States. The ash excavation activities will be perfurrnud within an enclosed basin that receives stormwater run-off frum a pufTiun of L "side, and that stormwater is pumped to the Active Ash Basin. In addition to the BLIP measures, a sediment control daviue will 6e installed around the inlet areas of the U1-4 Basin and U5 Basin untfall pipes. The Engineer of Record will review the installation of the BMP measures prig to commencing excavation un site, lir addition, the EMP measures will be routinely inspected per NC regulations and properly maintained to ensure functionality. Based on correspondence with NC &E DEQ, an erosion control plan submittal and obtaining a storm water general permit for construction activities is not required for ash excavation activities that are conducted within the impoundment areas of the U1-4 and Basins. The U1-4 Basin is an active wastewater treatments stem that is used to pump the stormwater and wastewater it receives to the Active Ash Basin which has a NPDES permitted untfall 002. 01-4 Basin also has an active NPD_ES permitted uattall (nom5er UU2A) Tor emergency overflow situations. Dake Energy plans to meet with IAC DEQ to determine whether an erosion control elan and the associated construction stormwater permit are regaired for the 05 Basin. no work in the Unit 5 Basin will be performed until NC DEQ uuntirms that no erosion control Ian is re uired or Duke Eneigy receives approval at an erosion control plan. As described in this auuament, this wurR is scHeduled to begin on or before January 2016. 11 Ulittside Steam Station at the Rogers E, icryy Cumplex ( nA ? 7h Exuavativn Plan tur Units 1-4 and Unit 5 Inactive Ash r uutu6er 7, 1015 For land disturbing activities that occur outside UT the impoundment areas of the ash basins, submittal of an urvsion control plan and obtaining a storm water permit for constromiun activities is required. Water that accumulates from the U1-4 and 0-5 excavation areas will be pumped to the U1-4 yard drainage basin, where tMe water is currently pumped to the Active Ash Basin, which discharges under tMe existing NPDES permit as discussed in Semion V. Waref Ma►tagemetir. As noted in Section I, Srarematir of Patpo58, uuRe Energy received a letter from Tracy Davis, NC RF DEu Dam 5atety; on January 26, 2015 approviny the plans to excavate approximately 84,000 cubic yards of ash and material trvm tFie 01-4 Basin to increase freeboard and validate hydrulegiu & hydraulic (FIKR) analysis. The area to be excavated has been updated to facilitate project execution, but the total freeboard to be achieved remains uuncManged, and a permit modification is not required. Duke Energy received another letter frum Tracy uavis, ISL DE-4RDEO Dam Safety, on February 2, 2015 appruviny the plans to excavate approximately 400,000 cubic yal ds of ash and material from tMe u1-4 Basin to increase freeboard and validate H&H analysis. i he area to 6e excavated will also be updated to fac,ilitaie pruieut execution, but the total freeboard to be achieved remains unchanged, and a permit modification is not required. I here are no jurisdictional wetlands/streams associated with the excavation of tMe U1-4 Basin. For the U5 Basin. the identification of streams and wetlands is ander evaluation. No additional county reguulatury requirements have been identified 12 Glittside Steam Station at the Ruyers Encryy Lumpicx l-;ual Asn Exuavatiun Plan for Units 1-4 and Unit 5 Inactive Ash Basins Uutober 7 2015 Permir Mai,iA Media Permit Target Date Reasoning Excavation of ash creates potential for stormwater impacts. NC DE-WRDEQ has indicated an industrial stormwater permit will be needed. Duke has Industrial Stormwater NPDES October 2015 applied for this permit. NC BENRDEQ Permit issued a draft industrial stormwater permit on July 31, 2015 and a public hearing took place on September 10, 2015. A SWPPP incorporating BMPs will be created. U1-4 Basin: Duke Energy proposed an approach to NC DENRDEQ for managing water from the U1-4 Basin excavation by pumping the water to into the U1-4 yard drainage area, which is pumped to the Active Ash Approved on June 9, Basin. NC DE-NRDEO indicated 2015 concurrence to the proposed changes to wastewater flow patterns provided the facility continues to meet the terms Water and conditions of the NPDES wastewater permits and water quality Manayement of Wastewater ander standards in the receiving stream are NPDES Permit _ not contravened. U5 Basin: Duke Energy issued a proposal to NC BEE-4RDEQ on August 7, 2015 for managing water from the Unit 5 Basin excavation by pumping to the U1-4 yard drainage area. NC Approved on PE-WRDEQ indicated concurrence to September 9, zOi5 the proposed changes to wastewater flow patterns provided the facility continues to meet the terms and conditions of the NPDES wastewater permits and water quality standards in the receiving stream are not _ contravened. 4 _ There are no identified jurisdictional Jurisdictional Wetland and Stream wetland/stream impacts for the U1-4 Impacts/404 Permitting and 401 September 2015 Basin. For the U5 Basin, the WQC identification of streams and wetlands is under evaluation. 13 Waste Other ulittside Steam Station at the Rogers Eneryy Co ipleA Coal Ash Exuavatiun Flan tur ui its 1-4 and Unit 5 Inactive Ash Basins Dam Safety Approvals Landfill Permit Erosion & Sedimentation Cuntrul Plans U1-4 Basin: January z5, zul5 u5 Basin: Fu5ruaiy 2, 2015 Approved on September 2, 2015 September 2015 Letter from Tracy E. Davis to John Elnitsky, Subject: "Approval to Repair — Scope 2, Cliffside Inactive Ash Basin 1-4 Main Dam," dated January 26, 2015, approves the plan to excavate approximately 84,000 cubic yards of ash and material from the U1-4 Basin to increase freeboard and validate H&H analysis to support decant riser retirement. Letter from Tracy E. Davis to John Elnitsky, Subject: "Approval to Repair — Scopes 1 and 3, Cliffside Inactive Ash Basin #5 Main Dam," dated February 2, 2015, approves the plan to excavate approximately 400,000 cubic yards of ash and material from the Unit 5 Basin to increase freeboard and validate H&H analysis to support decant riser retirement. Concurrence with plan to place ash from U1-4 and U5 Basins in the Cliffside on-site landfill (Permit No. 8106 -INDUS -2009) was received from NC DENRDEQ Division of Waste Management, Solid Waste Section on September 2, 2015. Duke Energy submitted an application for land disturbing activities, including tree clearing, occurring outside of the impoundment areas of the U1-4 ask► bBasins, which was approved on September 911, 2015. The infrastructure for hauling to the on-site landfill is in place. If any additional land disturbing activities are needed (such as such as breaching or altering the embankment to access the coal ash, staging areas, haul roads, and any expansion of the landfill) other than what has been approved for the Unit 1-4 ash excavation project, Duke Energy will obtain the required erosion control plan approval and the associated construction stormwater permit. Approval of an erosion control plan associated with the U1-4 Basin CMP toe drains removal and dam face tree removal was also received on August 14 Other Clittside Steam Stdtiun at the Ruyers Eneryy Complex Uual Asn Exuavatiun Plan for Units 1-4 and Unit 5 InautivC Asn Basins Ucto5er 7. 2015 Air Permits — pumps / generators Site specific and Local Nuisance/Noise/Odor/Other Requirements including DOT and FERC Requirements September 2015 N/A TtDuke Energy will work with contractors o ensure that permits (or exemptions) are obtained. No local requirements identified. X. Other Environmental Issues Prior to the excavation of material within 2 feet of the groandwater levels observed at the site (except for installing the nquessa sam s to support excavation),Duke Ener personnel will work with the MR wQROS Asheville Office to develop and implement an agreed to supplemental monitoring schedule for those monitoring wells ut interest that will not require removal for the exCavatiun.. This ettorff will 5e conducted in a manner to evaluate any potential for ahan es in gruundwater chemist (e.g., increased dissolved u,&ygen) that may attest the mobility of metals in groundwater or ifulDaut guandwater elevations in the area. lXAl. Contracting Straw9y Dake will use specialized c ontractor(s), who are experienced in coal ash excavation, transpuffatiun, and storage. Duke will provide in-depth uversight, coordination, and monitoring of the contractors to ensure the worn is performed properly and compliantly. Duke Energy's cure values ut safety, quality, and protection of the environment are nun -negotiable and will not be compromised in urde, to increase productivity or generate cost savings. azul. Health and Safety Protecring wovkvis, The Nnatic, the cammnnity, and the environment DuRe Energy is committed to performing work safely; protecting the health, satety and welfare of employees, contractors and the public; and protecting the environment and natural resources. During all the project wurR, Duke Energy and its contractors will follow the Dake Energy Sate work Practices; the ABSAT Envirunmuntal, Hualth, and 15 Ulittside Steam Statim at the Rogers Energy Complex Coal Ash FY,,R 7ti„n Py r? f„r t,nit= 1-4 7nri i init r; Ir-mv-tiv- Ash R— in, Safety (EHS) supplemental document, and any additional requirements. Uccupatiunal health and safety expematiuns include oversigHt and continuous improvement throughout the project. I Fie project will include comprehensive health and safety plans, jus Hazard analyses, training of personnel, behavior based observation ut wurK activities and personnel, feedback and input from worRers Tor improvement of safe work practices for all aspects of the piuject worn. DaRe Energy is committed to minimizing public and environmental impacts. Communications Plan Many different external staReHolders including neighbors, government officials and media have an interest in this project. For example, there is the potential fur facility neighbors and the general public to see ur eAperienuu construction -related impacts such as truck traffic, landscape changes, or noise. I He Company is committed to pruviding information 6y pruactively communicating about the Project activities to potentially attested parties and responding to inquiries in a timely manner. The Project team will coordinate with DaRe Energy's Curpurate Communications Deparffment to develop a comprehensive external communications plan tailored to the specitic needs at each phase of the project. 16 Clittside Steam Station at tMe Huycrs Enteryy uumplex Leal Ash Exuavatiun Plan tur Units 1-4 and Unit 5 Inautive Asia Basins Uctvber 7, 2015 XIV. Glossary ABSAT Duke Energy organization acronym for Ash Basin Strategic Action Team Ash Basin ISynonymous with Ceal 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. Bottom Ash The agglemerated, 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 Combustion Residuals, including fly ash, bottom ash, boiler slag, mill rejects, Residuals (CCR) I and flue gas desulfurization residue produced by a coal-fired generating unit. Engineer of Record Duke Energy or 3rd party contracted engineer responsible for final verification of specific plan actions and documents Excavation Activities Tasks and work performed related to the planning, engineering and excavation of ash from an ash basin 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. 17 Llittside Steam Station aI the Rvgers Encryy LumpleA Coal Ash Exuavativn Plan tur Units 1-4 and Unit 5 Inactive Ash Basins NPDES PermitI A permit that regulates the direct discharge of treated wastewater to surface waters Permitting Federal, state, county or local government authorizing decument Work Plan Document detailing activities to accomplish a specific task er scope of work 1$ Clittside Steam Statiol at the Ruyt:m E� �cryy CumNICx Uual Ash Exuavatiun Pian tor Units 1-4 and Unit 5 Inactive Ash Basins Uctu6er 7, 2015 X- .Xy. Reterence Documents Ret Documtvnt Matt - I Letter frem Zahid S. Kahn to Duke Energy Corporation, M—aruh 5, 2014 Subject: Notice of Deficiency, Cliffside Inactive Ash Basin 1-4 Main Dam, CLEVE-847 — High Hazard Potential, Broad River Basin, Cleveland County Drawing package titled Inactive Ash Basin 1-4 Main Dam September 38, 2814 2 (CLEVE — 047), High Hazard Potential, Storm Storage Excavation for Cliffside Steam Station, Cleveland and Rutherford_ Counties, North Carolina Letter from Tracy E. Davis to John Elnitsky, subject "Approval January 26, 2015 3 to Repair — Scope 1, Cliffside Inactive Ash Basin 1 — 4 Dam, Cleveland County, State Dam ID: CLEVE-047" _ Letter from Zahid S. Kahn to Duke Energy Corporation, f�la�ch 5, 2u14 4 Subject: Notice of Deficiency, Cliffside Inactive Ash Basin #5 p Main Dam, RUTHE-070 — High Hazard Potential, Broad River Basin, Cleveland Count Inactive Ash Basin #5 Main Dam (RUTHE — 070), High Hazard November 14, 2014 5 Potential, Storm Storage Excavation for Cliffside Steam Station, Rutherford County, North Carolina 6 Letter from Tracy E. Davis to John Elnitsky, Subject: "Approval February 2, 2015 to Repair — Scopes 1 and 3, Cliffside Inactive Ash Basin #5 Main Dam" 7 40 Code of Federal Regulations (CFR) Parts 257 and 261, April 17, 2615 Hazardous and Solid Waste Management System; Disposal of Coal Combustion Residuals frem Electric Utilities; Final Rule 8 Coal Ash Management Act of 2614 September 26, 2_614 June 9, 2615 9 Email from Sergei Chernikov, NCDEQ NPDES� Permitting Unit approving the U1-4 Basin water management an 10 Email from Jeff Poupart, NCFJEPjRDEQ NPDES Permitting Unit September 9, 2015 a rovin the U5 Basin water management plan 11 Letter from Larry Frost, NC r'�DEQ Division of Waste SuptCmper z, 2U1 5 Management, Solid Waste Division, Permitting Branch to Sean DeNeale, subject "Response to Correspondence — Permit No. 8166 -INDUS -2009, Duke Power Cliffside Steam Station CCP Landfill Rutherford County, DIN 24932 approving the placement of ponded ash in the Cliffside on-site landfill lz Emails from Tamera Eplin, NCDEQ Land Quality Unit August 14, 2015 clarifying that an erosion control plan submittal and approval is October 1, 2015 net required for ash excavation activities within the inactive ash basins impoundment areas 19