NC0005088_CSS Excavation Plan_20150911

O: 704.382.4371
September 11, 2015
Mr. Tracy E. Davis
Director
North Carolina Department of Environment & Natural Resources
Division of Energy, Mineral and Land Resources
Land Quality Section
Mailing: 1636 Mail Service Center
217 W. Jones Street
Raleigh, NC 27699-1636
Re: Coal Ash Excavation Plan — Cliffside Steam Station at the Rogers Energy Complex
Dear Mr. Davis:
In response to the Notices of Deficiency issued by the North Carolina Department of Environment and
Natural Resources (NC DENR) to Duke Energy received on March 5, 2014, Duke Energy is submitting
and requesting review and acknowledgement of the attached Coal Ash Excavation Plan (Excavation
Plan) for Units 1-4 and Unit 5 Inactive Ash Basins at the Cliffside Steam Station at the Rogers Energy
Complex as discussed during our meeting on September 9, 2015.
This Excavation Plan covers the excavation of approximately 84,000 cubic yards of ash and material from
the Units 1-4 Inactive Basin and approximately 400,000 cubic yards from the Unit 5 Inactive Ash Basin to
increase stormwater storage capacity, increase freeboard, and validate hydrology & hydraulics analysis.
The excavation will allow the retirement of decant riser/outfall pipes in each basin and resolution of the
Notices of Deficiency.
Based on the location of the Units 1-4 Inactive Ash Basin adjacent to the Broad River and the structural
integrity analysis performed under the Disposal of the Coal Combustion Residuals from Electric Utilities
published by the U.S. Environmental Protection Agency on April 17, 2015, which indicates that insufficient
factors of safety exist in the event of an earthquake, Duke Energy also proposes to excavate the
remainder of the ash and close the Units 1-4 Basin under the Coal Ash Management Act of 2014.
Duke Energy will submit updates to this Excavation Plan and / or closure plans to address the remaining
ash excavation and dam decommissioning of the U1-4 Basin and the closure of the U5 Basin. Closure
plans will be prepared and submitted to NC DENR by October 2016.
John Elnitsky
Senior Vice President
r� DUKE
Ash Basin Strategy
ENERGY
400 South Tryon Street
ST06A
Charlotte, NC 28202
Mailing Address:
P.O. Box 1321
Charlotte, NC 28201
O: 704.382.4371
September 11, 2015
Mr. Tracy E. Davis
Director
North Carolina Department of Environment & Natural Resources
Division of Energy, Mineral and Land Resources
Land Quality Section
Mailing: 1636 Mail Service Center
217 W. Jones Street
Raleigh, NC 27699-1636
Re: Coal Ash Excavation Plan — Cliffside Steam Station at the Rogers Energy Complex
Dear Mr. Davis:
In response to the Notices of Deficiency issued by the North Carolina Department of Environment and
Natural Resources (NC DENR) to Duke Energy received on March 5, 2014, Duke Energy is submitting
and requesting review and acknowledgement of the attached Coal Ash Excavation Plan (Excavation
Plan) for Units 1-4 and Unit 5 Inactive Ash Basins at the Cliffside Steam Station at the Rogers Energy
Complex as discussed during our meeting on September 9, 2015.
This Excavation Plan covers the excavation of approximately 84,000 cubic yards of ash and material from
the Units 1-4 Inactive Basin and approximately 400,000 cubic yards from the Unit 5 Inactive Ash Basin to
increase stormwater storage capacity, increase freeboard, and validate hydrology & hydraulics analysis.
The excavation will allow the retirement of decant riser/outfall pipes in each basin and resolution of the
Notices of Deficiency.
Based on the location of the Units 1-4 Inactive Ash Basin adjacent to the Broad River and the structural
integrity analysis performed under the Disposal of the Coal Combustion Residuals from Electric Utilities
published by the U.S. Environmental Protection Agency on April 17, 2015, which indicates that insufficient
factors of safety exist in the event of an earthquake, Duke Energy also proposes to excavate the
remainder of the ash and close the Units 1-4 Basin under the Coal Ash Management Act of 2014.
Duke Energy will submit updates to this Excavation Plan and / or closure plans to address the remaining
ash excavation and dam decommissioning of the U1-4 Basin and the closure of the U5 Basin. Closure
plans will be prepared and submitted to NC DENR by October 2016.

We are prepared to commence implementation upon receipt of NC DENR acknowledgement of this
Excavation Plan.
i Elnitsky
for Vice President
cc: Harry Sideris
Richard Baker
Dan Mc Rainey
Gary Miller
Steve Struble
Henry Duperier

Cliffside Steam Station
at the Rogers Energy Complex
Coal Ash Excavation Plan for
Units 1-4 and Unit 5 Inactive Ash Basins to
Address Notices of Deficiency
('DUKE
ENERGY.

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
Table of Contents
I.
Statement of Purpose...................................................................................................................2
II.
General Facility Description.........................................................................................................4
III.
Project Charter...............................................................................................................................7
IV.
Milestone Dates.............................................................................................................................8
V.
Water Management......................................................................................................................
9
VI.
Transportation and Storage of Excavated Ash.........................................................................9
VII.
Dust Control.................................................................................................................................10
VIII.
Environmental Permitting Plan..................................................................................................10
IX.
Contracting Strategy...................................................................................................................14
X.
Health and Safety........................................................................................................................14
XI.
Communications Plan.................................................................................................................14
XII.
Glossary........................................................................................................................................15
XIII.
Reference Documents................................................................................................................17
1

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
I. Statement of Purpose
Duke Energy is implementing a comprehensive long-term ash basin strategy to close
basins and safely manage ash throughout North Carolina. The Cliffside Steam Station
at the Rogers Energy Complex (hereafter Cliffside) has the following ash basins: Units
1-4 Inactive Ash Basin (U14 Basin), Unit 5 Inactive Ash Basin (U5 Basin), and the
Active Ash Basin, which includes two ash storage areas. The purpose of this Ash
Excavation Plan (Plan) is to present the approach for excavating a portion of the ash
from the U1-4 Basin and the U5 Basin to address Notices of Deficiency (NOD) issued
by the North Carolina Department of Environment and Natural Resources (NC DENR).
Subsequent updates to this Plan and / or the closure plans will address the remaining
ash excavation and dam decommissioning of the U14 Basin, including water re-route,
and closure of the U5 Basin. Closure plans will be prepared and submitted to NC
DENR in October 2016 for the U1-4 Basin, U5 Basin, and Active Ash Basin.
Duke Energy received a NOD from NC DENR on March 5, 2014 for the "high hazard
potential" of the Cliffside Inactive Ash Basin 1-4 Main Dam due to the potential for
significant environmental damage to the Broad River if the coal ash stored behind the
dam were to be released. On September 30, 2014, Duke Energy submitted the drawing
package titled Inactive Ash Basin 1-4 Main Dam (CLEVE — 047), High Hazard Potential,
Storm Storage Excavation for Cliffside Steam Station, Cleveland and Rutherford
Counties, North Carolina, September 2014, to NC DENR to provide a basis to resolve
the issues identified in the NOD. On January 26, 2015, NC DENR issued a letter
approving the drawing package.
Based on these drawings, Duke Energy will excavate approximately 84,000 cubic yards
(or approximately 101,000 tons) of ash and material from the U14 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 NOD, the
basin's location adjacent to the Broad River, and the structural integrity analysis
performed under the Disposal of the Coal Combustion Residuals from Electric Utilities
published by the U.S. Environmental Protection Agency on April 17, 2015, which
indicates that insufficient factor of safety exists in the event of an earthquake, Duke
Energy proposes to excavate the remainder of the ash and close the U1-4 Basin under
the Coal Ash Management Act of 2014 (CAMA).
Duke Energy received another NOD from NC DENR on March 5, 2014 categorizing the
Cliffside Inactive Ash Basin #5 Main Dam as a "high hazard" dam due to the potential
for significant environmental damage to the Broad River if the coal ash stored behind
the dam were to be released.
2

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
On November 14, 2014, Duke Energy submitted the drawing package titled Inactive Ash
Basin #5 Main Dam (RUTHE — 070), High Hazard Potential, Storm Storage Excavation
for Cliffside Steam Station, Rutherford County, North Carolina, November 2014, to NC
DENR to provide a basis to resolve the issues identified in the NOD. On February 2,
2015, NC DENR issued a letter approving the drawing package.
Based on these drawings, Duke Energy will excavate approximately 400,000 cubic
yards (or approximately 500,000 tons) of ash and material from the U5 Basin to
increase stormwater storage capacity, increase freeboard, and validate hydrology &
hydraulics analysis in order to retire the decant riser/outfall pipe.
This Plan covers some of the work that may be required by CAMA. CAMA 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 basin and provide transparency to NC DENR, its approval is an
action not specifically required by statutory, regulatory, or other applicable authority.
Additionally, it may become necessary for Duke Energy to modify the Plan to address
other legal requirements or factors that develop during ash excavation. Significant
changes to this Plan and final closure requirements and plans will be included in annual
updates to the Plan (by December 31 of each subsequent year) and/or in the final
closure plan that Duke Energy will submit to NC DENR by October 2016.
The precise scope of work for excavating the ash will be determined by applicable laws,
rules, permits, and approvals that control the activities to be performed under the Plan.
The water quality permit for the discharge from the basins (National Pollutant Discharge
Elimination System Permit No. NC0005088) or its reissuance or amendment (NPDES
Permit) could contain terms that control or affect the scope of that work. NC DENR filed
legal cases in Superior Court (NC DENR Cases), which may be resolved through
decision or settlement. NC DENR also sent Duke Energy a Notice of Violation (NOV)
because an NPDES Stormwater Permit had not been received for the site, the
resolution of which could have an effect on the activities discussed here.
All of the above (CAMA, NC DENR Letter, NPDES Permit, NC DENR Cases, NOVs,
and the U.S. EPA CCR Rule) are illustrative of actions 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 DENR should be taken as
requiring actions different from other such applicable requirements. Thus, Duke Energy
submits this Plan to NC DENR based on the understanding that it may be necessary to
make changes in the Plan in the future to reflect any such actions and reserves the right
to make such changes after initial submittal of the Plan.
3

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
II. General Facility Description
Cliffside is located at 573 Duke 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 units. Units 1-4 were retired in
2011, and Unit 5 (commissioned in 1979) and Unit 6 (commissioned in 2012) continue
to operate with a combined capacity of approximately 1,387 megawatts.
Cliffside Ash Facilities
Cliffside has the following ash facilities (as outlined in Figure 1):
• Units 1-4 Inactive Ash Basin (U1-4 Basin)
• Unit 5 Inactive Ash Basin (U5 Basin)
• Active Ash Basin, which includes two ash storage areas
• Cliffside Landfill
As noted in Section I, this Plan presents the approach for excavating approximately
84,000 cubic yards (or approximately 101,000 tons) of ash and material from the U14
Basin and approximately 400,000 cubic yards (or approximately 500,000 tons) of ash
and material from 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-route, and closure of the U5 Basin.
Units 1-4 Inactive Ash Basm uvc w iption and History
The U1-4 Basin and dam (NC Dam ID: CLEVE-047) were constructed in 1957 to
receive ash and remained in service through 1977. The 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 reinforced concrete drainage tower with bottom 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 U14 Basin outfall discharges to the Broad River and is identified as Outfall 002A
under NPDES Permit #NC0005088.
Five (5) interconnected holding cells for stormwater and plant process water were
constructed in the west portion of the U1-4 Basin. Water from these holding cells is
pumped to the Active Ash Basin to the 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, Water Management.
4

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
Unit 5 Inactive Ash Basin Description and History
The U5 Basin was created by the construction of two dams in 1969-70, the Main Dam
(RUTHE-070) and the Saddle Dam (RUTHE-072). Both dams are earth -filled
embankments.
The outlet for the U5 Basin is a corrugated metal pipe riser encased in concrete that
turns 90 degrees into a 60 -inch diameter reinforced concrete pipe, which extends
through the abutment of the Main Dam.
The U5 Basin contains approximately 2.3 million (est.) tons of ash and material,
including an estimated 1 million cubic yards of construction material from Cliffside Unit
6. Stormwater from approximately 165 acres flows into the basin and discharges
through the outfall.
The U5 Basin became inactive in 1980.
5

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Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
III. Project Charter
The project charter for Cliffside U14 and U5 Inactive Ash Basins Excavation Project is
to:
• U14 Basin — Excavate approximately 84,000 cubic yards (or approximately
101,000 tons) of ash and material, and retire the riser pipe (e.g., grout the basin
outfall pipe).
• U5 Basin: Excavate approximately 400,000 cubic yards (or approximately
500,000 tons) of ash and material, and retire the riser pipe (e.g., grout the basin
outfall pipe).
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-route,
and closure of the U5 Basin.
Project Charter Objectives
Objectives
U1-4 Basin:
1. Excavate approximately 84,000 cubic yards (or approximately 101,000 tons) of
ash and material from the U1-4 Basin
2. Increase freeboard and stormwater storage volume to safely contain the design
storm event
3. Prepare the Basin for future closure under a NC DENR approved closure plan
U5 Basin:
1. Excavate approximately 400,000 cubic yards (or approximately 500,000 tons) of
ash and material from the U5 Basin
2. Increase freeboard and stormwater storage volume to safely contain the design
storm event
3. Prepare the Basin for future closure under a NC DENR approved closure plan
Project Charter Scope
U1-4 Basin
1. Obtain all applicable permits for work
2. Develop necessary plans (e.g., storm water pollution prevention plan, work plans,
readiness reviews, etc.)
3. Mobilize and prepare site
4. Excavate approximately 84,000 cubic yards (or approximately 101,000 tons) of
ash and material and transport to Cliffside's on-site landfill for placement
7

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
5. Control fugitive dust emissions
6. Perform pre- and post -excavation surveys to confirm that the required
stormwater storage capacity (approximately 84,000 cubic yards) has been
created
7. Grout basin outfall pipe
U5 Basin Scope
1. Obtain all applicable permits for work
2. Develop necessary plans (e.g., storm water pollution prevention plan, work plans,
readiness reviews, etc.)
3. Mobilize and prepare site
4. Excavate approximately 400,000 cubic yards (or approximately 500,000 tons) of
ash and material and transport to Cliffside's on-site landfill for placement
5. Control fugitive dust emissions
6. Perform pre- and post -excavation surveys to confirm that the required
stormwater storage capacity (approximately 400,000 cubic yards) has been
created
7. Grout basin outfall pipe
IV. Milestone Dates
Milestones within the Plan are summarized in the table below and are contingent on
receipt of regulatory approvals and necessary permits.
MILESTONESIM
TARGET DATE
Submit Excavation Plan
September 11, 2015
Mobilize and prepare site
September 21, 2015
Receive Excavation Plan acknowledgement
September 21, 2015
Receive Industrial Stormwater Permit
October 1, 2015
Commence U1-4 Basin ash excavation
October 12, 2015
Commence U5 Basin ash excavation
January 4, 2016
Complete U1-4 Basin ash excavation (approx. 84,000 cubic
yards)
February 2016
Grout U1-4 Basin outfall pipe
February 2016
Complete U5 Basin ash excavation (approx. 400,000 cubic
yards)
September 2016
Grout U5 Basin outfall pipe
October 2016

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
V. Water Management
Unit 1-4 Inactive Ash Basin
The U1-4 Basin contains a yard drainage basin (i.e., five (5) interconnected water
holding cells) that receives stormwater and process water from Cliffside, including runoff
from the coal yard. This 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 under the NPDES permit #NC0005088. Sump(s) with
pumps and temporary ditches will be constructed to facilitate the removal of any water
that accumulates within the ash 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 DENR NPDES Permitting Unit has
reviewed and authorized this approach in an email dated June 9, 2015.
The process water and stormwater currently flowing into the U1-4 Basin yard drainage
basin must be re-routed by April 17, 2017 under CCR stability demonstration
requirements. Although plans are still under development, a temporary water holding
cell will be constructed, and the water flowing into the U1-4 basin will be rerouted to that
cell and then pumped to the Active Ash Basin consistent with current operations.
Unit 5 Inactive Ash Basin
The U5 Basin receives water inflow from (1) rainwater that falls on top of the Basin, (2)
rainwater runoff from adjacent land, and (3) two small streams. The U5 Basin does 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 NPDES permit. The NC DENR
NPDES Permitting Unit has reviewed and authorized this approach in an email dated
September 9, 2015.
VI. Transportation and Storage of Excavated Ash
Excavated ash will be transported from the U1-4 Basin and U5 Basin to Cliffside's on-
site landfill via internal roads using trucks. These internal roads are owned by Duke
Energy, are secured with controlled access, and are not accessible to the public.
The trucks used to transport the ash will be inspected daily. The beds and tail gates will
be inspected and maintained in good condition to prevent loss/spillage of ash during
transport. The ash in the truck beds will be covered/tarped or sprayed with water or a
dust suppression agent to prevent dust emissions during transport.
N

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
Ash excavated from the U1-4 Basin and U5 Basin will be placed in the Cliffside on-site
landfill, which is permitted by NC DENR, Division of Waste Management, Solid Waste
Section, as an Industrial Solid Waste Landfill Facility (Permit No. 8106 -INDUS -2009).
The Cliffside landfill is currently used for storage of bottom ash, flyash, and gypsum
generated by daily operation of the existing coal fired units. Unloading, spreading, and
compaction of ash at the Cliffside on-site landfill will be performed in accordance with
the NC DENR approved operating plan for the landfill.
Expansion of the Cliffside Landfill (Landfill Phase 2) is currently under construction and
is anticipated to be in operation and available for placement of excavated ash in
February 2016.
VII. Dust Control
Appropriate measures will be used to minimize dust emissions during all portions of the
work including excavation, transportation, 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 exposed ash surfaces prior to weekends or
forecast windy conditions; use of tarps on dump trucks during transport; use of speed
limits; and application of water and/or chemical dust suppression agents on gravel
roads. Visual monitoring will be performed to evaluate the effectiveness of dust control
measures and guide implementation of additional dust controls as necessary.
VIII. Environmental Permitting Plan
Through the submittal of this Plan, Duke Energy is seeking to inform NC DENR that all
necessary permits and approvals have been identified and will be obtained for the
performance of the work.
An Industrial Stormwater Permit is needed to cover storm water management activities
during ash excavation activities at Cliffside; therefore, Duke Energy submitted an
application to NC DENR 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). The BMP measures will be installed during or prior to the
mobilization stage of the project to minimize discharge of sediment to Waters of the
United States. The ash excavation activities will be performed within an enclosed basin
that receives stormwater run-off from a portion of Cliffside, and that stormwater is
pumped to the Active Ash Basin. In addition to the BMP measures, a sediment control
device will be installed around the inlet areas of the U1-4 Basin and U5 Basin outfall
10

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
pipes. The Engineer of Record will review the installation of the BMP measures prior to
commencing excavation on site. In addition, the BMP measures will be routinely
inspected per NC DENR regulations and properly maintained to ensure functionality.
Based on correspondence with NC DENR, 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
U5 inactive ash basins. For land disturbing activities that occur outside of the
impoundment areas of the ash basins, submittal of an erosion control plan and
obtaining a storm water permit for construction activities is required.
Water that accumulates from the U1-4 and U5 excavation areas 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 NPDES permit as discussed in Section V, Water
Management.
As noted in Section I, Statement of Purpose, Duke Energy received a letter from Tracy
Davis, NC DENR Dam Safety, on January 26, 2015 approving the plans to excavate
approximately 84,000 cubic yards of ash and material from the U1-4 Basin to increase
freeboard and validate hydrologic & hydraulic (H&H) analysis. The area to be
excavated has been updated to facilitate project execution, but the total freeboard to be
achieved remains unchanged, and a permit modification is not required.
Duke Energy received another letter from Tracy Davis, NC DENR Dam Safety, on
February 2, 2015 approving the plans to excavate approximately 400,000 cubic yards of
ash and material from the U1-4 Basin to increase freeboard and validate H&H analysis.
The area to be excavated will also be updated to facilitate project execution, but the
total freeboard to be achieved remains unchanged, and a permit modification is not
required.
There are no jurisdictional wetlands/streams associated with the excavation of the U1-4
Basin. For the U5 Basin, the identification of streams and wetlands is under evaluation.
No additional county regulatory requirements have been identified.
11

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
Permit Matrix
Media
Permit
Target Date
Reasoning
Excavation of ash creates potential for
stormwater impacts. NC DENR has
indicated an industrial stormwater
permit will be needed. Duke has
Industrial Stormwater NPDES
October 2015
applied for this permit. NC DENR
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.
1-11-4 Basin: Duke Energy proposed an
approach to NC DENR for managing
water from the U1-4 Basin excavation
by pumping the water to into the U1-4
yard drainage area, which is pumped
Approved on June 9,
to the Active Ash Basin. NC DENR
2015
indicated concurrence to the proposed
changes to wastewater flow patterns
provided the facility continues to meet
the terms and conditions of the
Water
NPDES wastewater permits and water
quality standards in the receiving
Management of Wastewater under
stream are not contravened.
NPDES Permit
U5 Basin: Duke Energy issued a
proposal to NC DENR on August 7,
2015 for managing water from the Unit
5 Basin excavation by pumping to the
U1-4 yard drainage area. NC DENR
Approved on
indicated concurrence to the proposed
September 9, 2015
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.
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.
12

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
13
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,
U1-4 Basin: January
2015, approves the plan to excavate
26, 2015
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
Dam Safety Approvals
Elnitsky, Subject: "Approval to Repair
— Scopes 1 and 3, Cliffside Inactive
Waste
Ash Basin #5 Main Dam," dated
U5 Basin: February
February 2, 2015, approves the plan
2, 2015
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 1_11-4 and U5 Basins in the
Approved on
Cliffside on-site landfill (Permit No.
Landfill Permit
September 2, 2015
8106 -INDUS -2009) was received from
NC DENR Division of Waste
Management, Solid Waste Section on
September 2, 2015.
Duke Energy submitted an application
Erosion & Sedimentation Control
Setember 2015
p
for land disturbing activities occurring
Plans
outside of the impoundment areas of
the ash basins on September 9, 2015.
Other
Duke Energy will work with contractors
Air Permits — pumps / generators
September 2015
to ensure that permits (or exemptions)
are obtained.
Site specific and Local
Nuisance/Noise/Odor/Other
Requirements including DOT and
N/A
No local requirements identified.
FERC Requirements
13

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
IX. Contracting Strategy
Duke will use specialized contractor(s), who are experienced in coal ash excavation,
transportation, and storage. Duke will provide in-depth oversight, coordination, and
monitoring of the contractors to ensure the work is performed properly and
compliantly. Duke Energy's core values of safety, quality, and protection of the
environment are non-negotiable and will not be compromised in order to increase
productivity or generate cost savings.
X. Health and Safety
Protecting workers, the public, the community, and the environment
Duke Energy is committed to performing work safely; protecting the health, safety and
welfare of employees, contractors and the public; and protecting the environment and
natural resources. During all the project work, Duke Energy and its contractors will
follow the Duke Energy Safe Work Practices. the ABSAT Environmental, Health, and
Safety (EHS) supplemental document, and any additional requirements. Occupational
health and safety expectations include oversight and continuous improvement
throughout the project.
The project will include comprehensive health and safety plans, job hazard analyses,
training of personnel, behavior based observation of work activities and personnel,
feedback and input from workers for improvement of safe work practices for all aspects
of the project work. Duke Energy is committed to minimizing public and environmental
impacts.
XI. 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 will coordinate 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.
14

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
XII. Glossary
Term
Definition
ABSAT
Duke Energy organization acronym for Ash Basin Strategic
Action Team
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.
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 Combustion
Residuals, including fly ash, bottom ash, boiler slag, mill rejects,
Residuals (CCR)
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.
15

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for 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 I Federal, state, county or local government authorizing document
Work Plan Document detailing activities to accomplish a specific task or
scope of work
16

Cliffside Steam Station at the Rogers Energy Complex
Coal Ash Excavation Plan for Units 1-4 and Unit 5 Inactive Ash Basins
XIII. Reference Documents
Ref
Document
_ -
Date
1
1
Letter from Zahid S. Kahn to Duke Energy Corporation,
March 5, 2014
Subject: Notice of Deficiency, Cliffside Inactive Ash Basin 1-4
Main Dam, CLEVE-047 — High Hazard Potential, Broad River
Basin, Cleveland Count
2
Drawing package titled Inactive Ash Basin 1-4 Main Dam
September 30, 2014
(CLEVE — 047), High Hazard Potential, Storm Storage
Excavation for Cliffside Steam Station, Cleveland and
Rutherford Counties, North Carolina
3
Letter from Tracy E. Davis to John Elnitsky, subject "Approval
January 26, 2015
to Repair— Scope 1, Cliffside Inactive Ash Basin 1 — 4 Dam,
Cleveland County, State Dam ID: CLEVE-047"
4
Letter from Zahid S. Kahn to Duke Energy Corporation,
March 5, 2014
Subject: Notice of Deficiency, Cliffside Inactive Ash Basin #5
Main Dam, RUTHE-070 — High Hazard Potential, Broad River
Basin, Cleveland Count
5
Inactive Ash Basin #5 Main Dam (RUTHE— 070), High Hazard
November 14, 2014
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, 2015
Hazardous and Solid Waste Management System; Disposal of
Coal Combustion Residuals from Electric Utilities; Final Rule
8
Coal Ash Management Act of 2014
September 20, 2014
9
Email from Sergei Chernikov, NCDENR NPDES Permitting
June 9, 2015
Unit approving the 1-11-4 Basin water management plan
10
Email from Jeff Poupart, NCDENR NPDES Permitting Unit
September 9, 2015
approving the U5 Basin water management plan
11
Letter from Larry Frost, NC DENR Division of Waste
September 2, 2015
Management, Solid Waste Division, Permitting Branch to Sean
DeNeale, subject "Response to Correspondence — Permit No.
8106 -INDUS -2009, Duke Power Cliffside Steam Station CCP
Landfill Rutherford County, DIN 24932 approving the
placement of poncled ash in the Cliffside on-site landfill
12
Email from Tamera Eplin, NCDENR Land Quality Unit clarifying
August 14, 2015
that an erosion control plan submittal and approval is not
required for ash excavation activities within the impoundment
area of the retired ash basins
17