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HomeMy WebLinkAboutMayo_ClosureOptionsAnalysis_20181114Mayo Plant Ash Basin Closure Options Analysis Summary Report This summary report (Report) presents the Closure Options evaluation for the ash basin located at Duke Energy Progress Mayo Station, located at 10660 Boston Road, near Roxboro, Person County, North Carolina. The Closure Options Evaluation involved developing ash basin closure strategies and evaluating these options relative to one another to determine which option to advance to more detailed engineering and closure plan development. The strategies discussed in the Closure Options evaluation are representative of the range of possible approaches for basin closure, and do not constitute final closure plans as described in N.C. Gen. Stat. sec. 130A-309.214(a)(4). Final closure plans will be submitted in 2019, as required by law, supported by detailed engineering designs and any necessary updates to groundwater modeling and related analysis. Duke Energy developed programmatic guidance for the closure analysis effort in early 2016 to provide fleet -wide consistency to ash basin closure plan development. Duke Energy developed a relative weighting and scoring system with input from the National Ash Management Advisory Board. Using this system, Duke Energy evaluated and scored the alternatives using an options analysis framework designed to identify the best solution that balances environmental protection, cost, schedule and local community impacts. It is noted that internal working draft versions of these 2015-2016 Options Analyses for Allen, Belews Creek, Cliffside, Marshall, Mayo, and Roxboro were provided to NCDEQ at its request in May and June 2018. The 2016 internal working draft Options Analysis identified closure -in -place as the preferred solution for Mayo that is protective of the environment, safely closes the Ash Basin, minimizes the other associated risks, and was the least cost to customers. A permit -level design was developed for that option in 2016. The company then paused that work, pending determination that the site would meet the requirements for a low -risk impoundment classification pursuant to N.C. Coal Ash Management Act (CAMA), as amended by House Bill 630. Duke Energy has completed those requirements at the Mayo site for a low - risk classification. Stormwater management (downstream impacts) was identified as a concern for the closure -in -place option in the 2016 analysis. In 2018, the grading plan for the Closure -in -Place option has been revised to direct the majority of stormwater runoff towards Mayo Reservoir rather than down Crutchfield Branch. SITE BACKGROUND Duke Energy's Mayo Station is a single -unit, 727-megawatt coal-fired plant located near Roxboro, N.C, less than one-half mile south of the North Carolina -Virginia line. It began commercial operation in 1983, and the station is currently in active operation. Mayo operates one impoundment for storing wet - sluiced ash, which is referred to as the Active Ash Basin (Ash Basin). Historically, both bottom ash and fly ash have been sluiced to the Ash Basin, but in 2013/2014 Mayo converted to dry ash handling systems. Bottom ash and fly ash have been disposed of in the on -site lined landfill starting in 2014. Summary— Page 1 The station has two related facilities considered and regulated as dams by the North Carolina Department of Environmental Quality (DEQ): a single ash basin (NCDENR ID=PERSO-035), and two dams associated with the FGD Pond (NCDENR ID=PERSO-036, NCDENR ID=PERSO-037) which are shown in the figure below. s.1 __i i i'j FA Figure 1. Ash Basin CLOSURE OPTIONS For the Mayo Station, under the direction of Duke Energy, AECOM developed the following conceptual closure options that remain under evaluation: • Option 1: Hybrid Closure • Option 2: Closure -In -Place • Option 3: Closure -By -Removal (Existing On -Site Landfill) Option 1 consists of excavating ash materials from the proposed Closure -by -Removal Areas depicted on Figures A1A and A1B and the subsequent placement of these ash materials within the proposed consolidated Hybrid Ash Closure Area. The Hybrid Ash Closure Area reduces the Ash Basin footprint, but due to site geometry, also incorporates a lateral lined expansion into a small greenfield area outside the Summary— Page 2 current basin boundary. Following these excavation and placement activities, the Hybrid Ash Closure Area will be capped with an infiltration barrier/cover system meeting the requirements of the Federal Coal Combustion Residuals (CCR) Rule and CAMA (Figure A4). The Ash Basin dam will be breached as a final step in this option to enable release of stormwater. Option 2 consists of leaving the ash material within the Ash Basin, graded to facilitate stormwater drainage which will be capped with an infiltration barrier/cover system meeting the requirements of the Federal CCR Rule and CAMA as shown on Figures A2A, A2B, and A4. The Ash Basin dam will remain in place and stormwater is routed through a modification of the current discharge channel to Mayo Lake. Option 3 consists of excavating all ash materials from the Ash Basin, and placing these ash materials in a new, lined phase which would be permitted and constructed within the existing landfill Site Suitable area as depicted in Figure A3. This 30-acre phase would be constructed with a base liner system and an infiltration barrier/cover system meeting the requirements of the Federal CCR Rule and CAMA (Figure A4). The Ash Basin dam will be breached as a final step in this option to enable release of stormwater. Options earlier evaluated but not carried forward included Option 3B (closure -by -removal with existing and new on -site landfill) and Option 4 (closure -by -removal with off -site landfill) which were removed from consideration from the Options Analysis for reasons of availability of on -site landfill space and excessive schedule/cost. Tables 1, 2, and 3 of this report present a tabulated summary of each evaluated closure option, estimated quantities of ash and soil materials associated with each closure option, and a more detailed overview of each closure option presented. Attachment A of this report includes figures depicting conceptual -level plan drawings and cross sections/details for each closure option. The figures included in Attachment A are as follows: • Figure A1A — Option 1 Hybrid Closure Plan View • Figure A1B — Option 1 Hybrid Closure Profile and Section Views • Figure A2A—Option 2 Closure -In -Place Plan View • Figure A2B — Option 2 Closure -In -Place Profile and Section Views • Figure A3 — Option 3 Closure -By -Removal to Existing On -Site Landfill Plan View • Figure A4 — Cover and Liner System Details Attachment B includes rough order of magnitude (ROM) cost estimates for each closure option. Attachment C contains the scoring matrix which summarizes the composite scores of the various closure options, the assumptions of which are outlined in Table 3 for each particular option. METHODOLOGY A scoring matrix was prepared to provide consistent evaluation of closure options for each of the various site locations. This scoring evaluation tool can be found in Attachment C and considers the following primary criteria: Summary— Page 3 • Environmental Protection and Impacts • Cost • Schedule • Regional Factors • Constructability Rough Order of Magnitude Costs A rough order of magnitude (ROM) Class 5 cost estimate was prepared for each of the closure options, based on information and quantities developed during the conceptual design activities. The estimated costs include construction, permitting, engineering design, post -construction O&M, and groundwater monitoring. A tabulated summary of the preliminary closure cost estimates is provided below: Current Estimates (October 2018) Option Closure Option Estimated Estimated O&M Construction Cost Cost (30 Years) 1 Hybrid Closure $109,290,046 $32,093,144 2 Closure -In -Place $74,626,681 $40,408,995 3 Closure -By -Removal $199,751,368 $24,637,553 (Existing On -Site Landfill) Option 2: Closure -In -Place has the lowest estimated construction cost which is primarily due to the substantial reduction in material excavation and associated dewatering activities. Detailed tabulated ROM cost estimates are included in Attachment B. Schedule Within the scoring evaluation, estimates of the length of time required to initiate closure activities and the anticipated construction duration are provided for each option. Option 1 is estimated to take 96 months or 8 years. Option 2 is estimated to take 66 months or 5.5 years. Option 3 is estimated to take 120 months, or 10 years. A major driver in the estimated construction durations is the assumed material excavation/ movement rate of 1,000,000 cubic yards/year; therefore, the Closure -By -Removal option has longer construction duration, due to the requirement to move all ash materials, compared to the Hybrid and Closure -In - Place options where material movement quantities are less. Another driver is the assumed capping rate of 50 acres/year for completing the closure system for the Hybrid and Closure -In -Place options. Summary— Page 4 Options 1 and 2 are the only options that could be completed by the CAMA deadline of 2029, assuming work could begin in 2020. Evaluation Criteria This Options Analysis was developed as a decision -making tool to assist in selection of closure options when multiple methods are allowed under applicable regulations. The intent was to develop a decision framework that used weighted scorings to balance environmental factors, cost, and the safety of workers and the public. The Options Analysis incorporates Duke Energy's obligation as a regulated utility to ensure that its closure decisions are protective of the environment and communities, while also being prudent from a cost-effectiveness perspective. The analysis considered multiple aspects in each criterion, including surface water impacts, groundwater impacts, air emissions, greenfield disturbance, construction duration, imported soil needs, transportation and noise impacts, stormwater management, long-term maintenance needs and post - closure monitoring. These elements were combined to provide a weighted sum for each criterion using the following weights: environmental considerations (30%); cost (35%); schedule (15%); regional/ community factors (15%) and constructability (5%.). Duke Energy placed primary emphasis on environmental factors and cost, which were approximately equal in weight. When considering all of the criteria and associated weightings, the environmental considerations have a slightly higher weight than cost with the inclusion of certain regional/community factors (transportation impact, noise impact, view impact) which are effectively environmental considerations. The scoring matrix provided in Attachment C, rates each option on a scale of 0 (least favorable) to 10 (most favorable) for each of the specified criteria. The scores for each option are then summed based on specified criterion weighting, resulting in an overall weighted score for each option. The results of the scoring evaluation for the Mayo closure options are summarized below: Summary— Page 5 Scoring Summary (October 2018) Criterion Option 1 2 3 Environmental Protection and Impacts 2.75 2.44 2.55 Cost 2.39 2.80 0.70 Schedule 0.74 1.50 0.00 Regional Factors 1.16 1.12 0.14 Constructability 0.15 0.40 0.30 Total Score 7.18 8.26 3.69 DISCUSSION The Options Analysis finds relatively similar rankings for environmental considerations, such as impacts to groundwater, surface water, and avoidance of greenfield disturbance. The analysis incorporates the latest groundwater modeling at Mayo that demonstrates groundwater near the basin responds similarly for several decades in all closure options evaluated. The most effective step the company can take to improve groundwater is to safely decant the free water from the ash basin, which will occur in any closure approach. In terms of duration of work and closure time, the Closure -In -Place option (#2) and Hybrid option (#1) scenarios would be expected to be completed in 5.5 years and 8 years, respectively and could be completed by the CAMA deadline of 2029, while the Closure -By -Removal option (#3) is expected to take 10 years. The excavation scenario (#3) would extend beyond the current CAMA deadline of 2029. However, it remains in our options analysis despite this for full transparency of the alternatives. Other aspects the company considered are regional impacts to the surrounding community related to traffic and noise generated by each of the options. Traffic to and from the site will occur through the duration for each option noted above. That will include workers, trucks for deliveries or movement of soil, topsoil, stone, and geosynthetics. For the Closure -In -Place option (#2) and Hybrid option (#1) traffic will be mingled with typical traffic on the main roads leading to Mayo Station and Boston Road in particular. Closure -By -Removal option (#3) requires a significant number of truck crossings per work day of Boston Road over the approximate 10-year excavation period to access the landfill. The noise generated for each the options would be similar to someone near the site, but the duration of the work and the exposure to that noise varies directly with the time required for each option and would be longer for Closure -by -Removal. Along with increased duration and truck trips comes higher levels of emissions for the Closure -by -Removal option as well. At the Mayo site, the on -site landfill is located across a public highway, which would present a degree of safety risk and road congestion issues in excavation scenarios. Summary— Page 6 The Closure -By -Removal option is at least double the estimated cost of the Closure -In -Place option and causes other unnecessary community impacts with little compelling environmental benefit. While long- term modeling indicates a quicker reduction in the boron plume within the immediate vicinity of the basin footprint for the Closure -By -Removal scenario, compared to the Closure -in -Place scenario, the modeled concentrations at downstream points are nearly identical for all the closure options at each evaluated point in time. Moreover, the quicker reduction is partially offset by the fact that the modeled improvement is delayed in the Closure -By -Removal scenario, compared to the Closure -in -Place scenario, due to the extended construction time. In any event, the minor change in modeled plume size, within the immediate vicinity of the basin footprint, is not enough to justify the cost of the Closure -by -Removal scenario - particularly when the impact and improvement do not materially affect neighbors or other potential receptors. The Hybrid Closure option ranks most closely with Closure -In -Place but does not appear to produce environmental benefits commensurate with the added cost and closure time. It also brings potential construction difficulties with development of the closure area stability slope or wall. CONCLUSION Based on the concept designs for the selected closure options and evaluation of the criteria established (environmental protection/impacts, cost, schedule, regional factors and constructability), Closure -In - Place option (#2) or the Hybrid option (#1) were identified as the preferred options that best balance the various considerations associated with basin closure. Attachments: A —Closure Options Figures B — Closure Options Cost Estimates C — Closure Options Scoring Matrix and Groundwater Sub -Scoring Worksheet Summary— Page 7 Table 1 — Closure Options Summary Ash Basin Closure Options Evaluation Mayo Station Duke Energy Description • Install stormwater controls • Install free water decanting and water treatment system • Decant free water • Perform interstitial dewatering of ash material as needed to provide stable working surfaces • Install deep soil mixing method wall and/or stabilized soil wedge • Excavate ash, and place excavated ash material within the Hybrid ash closure area • Remove one foot of residual soil in the ash excavation areas • Install new liner system over about 4.5 acres of natural ridge that would need to be incorporated as a lateral expansion in order to facilitate a more consolidated cover geometry. • Install closure cover system • Removal of dam • Groundwater corrective action and long-term monitoring pursuant to CAMA/CCR • Install stormwater controls • Install free water decanting and water treatment system • Decant free water • Perform interstitial dewatering of ash material as needed to provide stable working surfaces • Regrade ash basin waste boundary and construct closure cover • Balance of cover material required from off -site borrow source with greenfield disturbance area of 30 acres. • Minimal dam material removed and restore disturbed areas. • Groundwater corrective action and long-term monitoring pursuant to CAMA/CCR • Install stormwater controls • Install free water decanting and water treatment system • Decant free water • Perform interstitial dewatering of ash material as needed to provide stable working surfaces • Excavate the ash and one foot of residual soil from the basin, place all 5.73 million CY in the existing landfill with new cell areas (greenfield disturbance) of 30 acres, within permitted boundary. • Remove dam, regrade closure -by -removal area, and restore disturbed areas. • Groundwater corrective action and long-term monitoring pursuant to CAMA/CCR Existing Ash Ash Basin —Ash 1-Foot Over -Excavation (Entire Footprint, including upstream dam face) Existing Ash Total Free Water Volume Option 1 (Hybrid) Hybrid Closure Area (Ash to Remain in Place) Closure -by -Removal (Includes 1-ft Over -Excavation) Liner System over Lateral Expansion Areas Option 2 (Closure -In -Place) Closure -In -Place Relocation of Ash Option 3 (Closure -by -Removal - Existing On -Site Landfill) Closure -by -Removal (Includes 1-ft Over -Excavation) Existing Soil Dam Soil Volume (total) Dam Soil Volume (partial removal for Option 2) Near -Site Soil Borrow Area Needed (Option 2 only) Item Table 2 — Quantity Summary Ash Basin Closure Options Evaluation Mayo Station Duke Energy Tons Volume (CY) 318,000 265,000 112,800 93,500 430,800 358,500 542,400 452,000 542,400 452,000 271,000 226,000 57,600 48,000 115,200 96,000 444,000 370,000 Area (Ac) 82 58 140 140 30 30 Table 3 - Option 1 Overview: Hybrid Closure Option Ash Basin Closure Options Evaluation Mayo Plant Duke Energy Description 1. Install stormwater controls 2. Install free water decanting and water treatment system 3. Decant free water 4. Perform interstitial dewatering of ash material as needed to provide stable working surfaces 5. Install deep mixing method wall and/or stabilized soil wedge as needed 6. Excavate ash, and place excavated ash material within the Hybrid ash closure area 7. Install new liner system over lateral expansion areas = 4.5 acres. The 4.5 acres of natural ridge would need to be incorporated as a lateral expansion in order to facilitate consolidated mound geometry. 8. Install closure cap system 9. Removal of dam 10. Groundwater corrective action and long-term monitoring pursuant to CAMA/CCR 1. Install stormwater run-on controls to divert stormwater from the ash basin where possible. 2. Design and install temporary water treatment system to manage decanting, interstitial dewatering, and (contact) stormwater. 3. Decanting & treatment of free water. 4. Construct the deep mixing method (DMM) wall and/or stabilized soil wedge to stabilize the cut -slope at the close -in -place / closure -by - removal interface; Approximately 1,500 LF long. 5. Removal & treatment of interstitial pore water in ash material as needed to provide stable working surfaces during construction within the closure -in -place and closure -by -removal areas. 6. Permit and construct new liner system over the lateral expansion areas; approximately 4.5 acres. The 4.5 acres of natural ridge would need to be incorporated as a lateral expansion in order to facilitate consolidated mound geometry. 7. Excavate an estimated 1,980,000 tons (1,650,000 CY) of ash material from within the closure -by -removal area, and place the excavated ash material within the Hybrid ash closure area. 8. Excavate an estimated 93,500 CY of residual soil material (1 foot below ash) from the closure -by -removal area (including the upstream dam face), and place the excavated material within the Hybrid ash closure area (Total excavation = 1,743,500 CY). 9. Remove dam down to natural grade; approximately 800,000 CY of clean fill material generated. 10. Leave in place an estimated 4,620,000 tons (3,850,000 CY) of ash material beneath the consolidated hybrid "mound" and within the ash Subject Table 3 - Option 1 Overview: Hybrid Closure Option Ash Basin Closure Options Evaluation Mayo Plant Duke Energy Description basin "fingers," and install closure cap system (approximately 82 acres) utilizing material generated by removal of the existing dam (approximately 265,000 CY needed). 11. Regrade the closure -by -removal area to direct stormwater to new permitted outfall, utilizing an estimated 93,500 CY of soils generated by removal of the existing dam. Total clean fill volume required = 358,500 CY. (The remaining dam material will be utilized to reclaim the ash basin footprint, as reflected in the cost spreadsheet.) 12. Restore areas disturbed during closure; approximately 145 acres (disturbed area). 13. Decommission temporary water treatment facility. 14. Groundwater corrective action and long-term monitoring pursuant to CAMA/CCR 1. Air emissions off -site (based on miles driven) = N/A (not driving off - site). 2. Air emissions on -site (based on gallons of fuel consumed) from closure implementation = Assumed that the highest volume of material (ash / residual soil / clean fill) excavation/movement will result in the highest fuel consumption. Material excavation/movement = 2,543,500 CY. 3. Greenfield disturbance = Approximately 4.5 acres 1. Capital costs = $109,290,046. 2. Long-term O&M and monitoring = $1,069,771 annual. 3. Avoided costs = Off -site ash hauling and costs managed through minimizing material handling. 1. Initiation time (to begin ash removal) = 36 months (includes dewatering and design/permitting and is a function of the stabilization construction). 2. Design and permitting = 12 months. 3. Construction = 60 months 4. Post -closure = 30 years. 1. Plan or potential for beneficial reuse of site = None. 2. Imported soil needs = None (everything is available from removal of existing dam). 3. Transportation impact (based on miles driven) = N/A (not driving off - site). 4. Noise impact due to on -site activity (based on proximity of neighbors) _ Slight impact during construction, but no change post construction (construction noise level approximately equivalent for each option, therefore scoring is based on construction duration). 5. Visual impact (based on final height of storage facility, land uses within the viewshed) = Peak of hybrid mound anticipated at 554 feet, compared to current dam crest at 488 feet. 2 Table 3 - Option 1 Overview: Hybrid Closure Option Ash Basin Closure Options Evaluation Mayo Plant Duke Energy Description 1. High internal slopes within the basin will require stabilization. 2. Dewatering will include free water removal and treatment and (as needed to provide a stable working surface) interstitial pore water removal and treatment as part of ash excavation and cover system placement. 3. Construction of the lateral expansion liner system and its leachate collection system will be a challenge. 3 Subject Table 3 - Option 2 Overview: Closure -in -Place Ash Basin Closure Options Evaluation Mayo Plant Duke Energy Description 1. Install stormwater controls 2. Install free water decanting and water treatment system 3. Decant free water 4. Perform interstitial dewatering of ash material as needed to provide stable working surfaces 5. Regrade ash basin waste boundary and construct closure cap. 6. Partial dam material removed and restore disturbed areas. 7. Groundwater corrective action and long-term monitoring pursuant to CAMA/CCR 1. Install stormwater run-on controls to divert stormwater from the ash basin where possible. 2. Design and install temporary water treatment system to manage decanting, interstitial dewatering, and (contact) stormwater. 3. Decanting & treatment of free water. 4. Removal & treatment of interstitial pore water in ash material as needed to provide stable working surfaces during construction within the closure -in -place area. 5. Regrade the close -in -place area to direct stormwater to the existing permitted outfall. 6. Remove Dam down to elevation 474 feet approximately 50,000 CY of clean fill material generated. 7. Install closure cap system over the close -in -place area, utilizing an estimated 452,000 CY of soils from borrow source (50,000 CY comes from dam, preferably remaining 402,000 CY comes from near -site borrow source). 8. Relocate an estimated 1,200,000 tons (1,000,000 CY) of ash material from within the closure -in -place area to achieve proposed grades. 9. Restore areas disturbed during closure; approximately 140 acres (disturbed area). 10. Decommission temporary water treatment facility. 11. Groundwater corrective action and long term monitoring pursuant to CAMA/CCR. 1. Air emissions off -site (based on miles driven) = N/A (not driving off - site). 2. Air emissions on -site (based on gallons of fuel consumed) from closure implementation = Assumed that the highest volume of material (ash / residual soil / clean fill) excavation/movement will result in the highest gallons of fuel consumed. Material excavation/movement = 1,050,000 CY. 3. Greenfield disturbance = Approximately 30 acres for borrow. Subject Table 3 - Option 2 Overview: Closure -in -Place Ash Basin Closure Options Evaluation Mayo Plant Duke Energy Description 1. Capital costs = $74,626,681. 2. Long-term O&M and monitoring = $1,346,967 annual. 3. Avoided costs = Off -site ash hauling, costs managed through minimizing material handling. 1. Initiation time (to begin ash removal) = 18 months (includes design/permitting and dewatering. 2. Design and permitting = 12 months. 3. Construction = 48 months 4. Post -closure = 30 years. 1. Plan or potential for beneficial reuse of site = none. 2. Imported soil needs = 402,000 CY (from unidentified borrow source, preferably near -site). 3. Transportation impact (based on miles driven) = N/A (not driving off - site). 4. Noise impact due to on -site activity (based on proximity of neighbors) _ Slight impact during construction, but no change post construction (construction noise level approximately equivalent for each option, therefore scoring is based on construction duration). 5. Visual impact (based on final height of storage facility, land uses within the viewshed) = equivalent to current conditions. 1. Dewatering will include free water removal and treatment and (as needed to provide a stable working surface) interstitial pore water removal and treatment as part of ash excavation and cover system placement. 2. No internal ash slopes to stabilize 2 Subject Table 3 - Option 3 Overview: Closure -by -Removal / Existing On -Site Landfill Ash Basin Closure Options Evaluation Mayo Plant Duke Energy Description 1. Install stormwater controls 2. Install free water decanting and water treatment system 3. Decant free water 4. Perform interstitial dewatering of ash material as needed to provide stable working surfaces 5. Construct 30-acre phase of existing landfill. 6. Excavate the ash from the basin, place in the existing landfill. Trucks would cross Boston Road/Highway 501 to the existing landfill location numerous times per day on average for nearly 7 years. 7. Remove dam, regrade closure -by -removal area, and restore disturbed areas. 8. Groundwater corrective action and long-term monitoring pursuant to CAMA/CCR. 1. Install stormwater run-on controls to divert stormwater from the ash basin and industrial landfill areas where possible. 2. Design and install temporary water treatment system to manage decanting, interstitial dewatering, and (contact) stormwater. 3. Decanting & treatment of free water. 4. Removal & treatment of interstitial pore water in ash material as needed to provide stable working surfaces during construction within the closure -by -removal area. 5. Permit and construct a new landfill and a new 30-acre phase of liner for the industrial landfill utilizing an estimated 48,000 CY of soils from the removal of the existing dam. 6. Excavate the ash material from within the closure -by -removal area (ash basin waste boundary area), an estimated 6,600,000 tons (5,500,000 CY), and place in the existing Landfill. 7. Excavate an estimated 225,900 CY of residual soil material (1 foot below ash) from the ash basin, and place in the existing Landfill. (Total excavation = 5,725,900 CY). 8. Install landfill cap system over new phase of existing industrial landfill utilizing an estimated 96,000 CY of soil by removal of the dam. 9. Remove dam down to elevation 380 feet; approximately 800,000 CY of clean fill material generated for use in cap and reclamation. 10. Regrade the closure -by -removal area to direct stormwater to the new permitted outfall utilizing an estimated 226,000 CY of soils generated by removal of the existing dam. The remaining dam material (approximately 430,000 CY) will be left in place or utilized to reclaim the ash basin footprint and the pond area will be graded to drain. Table 3 - Option 3 Overview: Closure -by -Removal / Existing On -Site Landfill Ash Basin Closure Options Evaluation Mayo Plant Duke Energy Description 11. Restore areas disturbed during closure; approximately 140 acres (disturbed area). 12. Decommission temporary water treatment facility. 13. Groundwater corrective action and long-term monitoring pursuant to CAMA/CCR 1. Air emissions off -site (based on miles driven) = 2 miles (round trip). 2. Air emissions on -site (based on gallons of fuel consumed) from closure implementation = Assume the highest volume of material (ash / residual soil / clean fill) excavation/movement will result in the highest gallons of fuel consumed. Material excavation/movement = 6,526,000 CY 3. Greenfield disturbance = Approximately 30 acres for additional phase within permitted landfill. 1. Capital costs = $199,751,368. 2. Long-term O&M and monitoring = $821,252 annual. 1. Initiation time (to begin ash removal) = 36 months (includes dewatering and design and permitting) 2. Design and permitting = 12 months. 3. Construction = 84 months 4. Post -closure = 30 years. 1. Plan or potential for beneficial reuse of site = None. 2. Imported soil needs = None (everything is available from removal of existing dam). 3. CCR beneficial reuse = None. 4. Transportation impact (based on miles driven) = 2 mile (round trip crossing highway). 5. Noise impact due to on -site activity (based on proximity of neighbors) _ Slight impact during construction, but no change post construction (construction noise level approximately equivalent for each option, therefore scoring is based on construction duration). 6. Visual impact (based on final height of storage facility, land uses within the viewshed) = 672 feet (Final height of the existing landfill). 1. Relatively manageable construction option. 2. Dewatering will include free water removal and treatment and (as needed to provide a stable working surface) interstitial pore water removal and treatment as part of ash excavation and cover system placement. 2 Attachment A 0 �--A �--C �--D 3 4 5 6 7 8 REV. 1 N a x Oo 00 O �� bo x � 00 womoo ` x . - x CLO URE IN LACE ♦ pV AREA 0 sr90 '500 so sr'O s'0 0 5g0 00 x x �� SS S 030 g2 p .� 00 x ri O v 00 x C� i ` O� l / r G S T L x r FLUSH x`� / OQ x C�' POND x - / = x - _ � ppx�ti 1' 41 pax 'a j � m- I _ 1 W • r td k r-lie left VA;p I - ; r._ - __ • • - - - - �1 4p y� 1. T �r J L'' "L - ' � r-'{ TITLE IL p� FOR t .. LEGEND CCR UNIT BOUNDARY CLOSURE BY REMOVAL AND CLOSURE IN PLACE AREA BOUNDARY DMM WALL LOCATION (APPROX) LATERAL EXPANSION AREA (APPROX. 4.5 AC) FGD SETTLING AND FLUSH POND TO BE DECOMMISSIONED AND CAPPED AS REQUIRED. HYBRID CLOSURE PLAN VIEW MAYO STEAM ELECTRIC PLANT ASH BASIN CLOSURE OPTIONS EVALUATION PERSON COUNTY, NORTH CAROLINA MAYO PLANT SCALE : -1 = 300' DES : CLD w DUKE DWG TYPE: 09 DWG TYPE DFTR: CLD ' JOB NO: 60432013 CHKD' DS FILENAME: - - DWG SIZE . 31 ANSI D 22.0"x 34.0" E N E RG DATE : 10/18/2018 ENGR : HYBRID REDESIGN16.6 PERCENT APPD: DRAWING NO. REVISION FIGURE A1A 1 m I I I I I I I I I I I I I I I I I I I I I I I I I I I TENTHS 10 20 30 REV. 1 575 575 CCR UNIT BOUNDARY 550 550 �//o PROPOSED FINAL COVER GRADE 525 525 500 EXSTING GRADE 500 T + 475 475 DEEP MIXING METH D WALL + + +++ + + + ++ 450 450 + + +++ +M+RtM +++ V/#L+++ +++ +++ ++ 425 _ 425 HIS ORICAL RADE 400 400 375 375 350 350 0+00 5+00 10+00 15+00 20+00 25+00 30+00 35+00 40+00 44+50 LEGEND SECTION A -A - EXISTING GROUND HISTORICAL GROUND PROPOSED FINAL COVER GRADE + + + + DAM REMOVAL CCR EXCAVATION (CLOSURE BY REMOVAL) CCR PLACEMENT (CLOSURE IN PLACE) 575 575 C R UNIT BOUNDARY -LATERAL EXPANSION AREA 550 ROPOSE FINAL C VER GR DE 550 525 E STING GFrDE 525 500 500 475 475 450 450 425 `7 425 400 400 0+00 5+00 10+00 15+00 20+00 25+0Q5+50 SECTION B-B TITLE HYBRID CLOSURE PROFILE AND SECTION VIEW MAYO STEAM ELECTRIC PLANT ASH BASIN CLOSURE OPTIONS EVALUATION PERSON COUNTY, NORTH CAROLINA FOR MAYO PLANT SCALE: DES: CLD DUKEDWG TYPE: 09 DWG TYPE DFTR: CLD ARS ENERGY® DATE: 10 18/2018 ENGR : FILENAME: HYBRID REDESIGN16.6 PERCENT APPD: DWG SIZE DRAWING NO. REVISION ANSI D 22.0"x 34.0" FIGURE Al B 1 x m 1 1 1 1 1 1 1 1 1 1 1 1 I I 0 1 2 3 2 TENTHS 10 20 30 3 3 4 5 6 7 8 REV. 0 "475•�'�/' —� I /I j I �` /� \ \ ; \\ \\ \ISO \ \ I500 475 475 ik LAKE �O p \ \ / CRUTCHFIELD BRANCH \\Z7 oftb 00 %44 �'N \ v v "A o 425- / \ \ \ � � 6 •�:��\ ` / I —^J /•450--__r--450-- I474 400',� r, LEGEND 472 470 CCR UNIT BOUNDARY CD 45� DUKE ENERGY PROPERTY BOUNDARY 00 468 CCR UNIT � \ �4 BOUNDARY(APPROXIMATE) 7 ' // -----' , EXISTING MINOR CONTOURS (5 FT) 70° / 466 / ' t \11 15 EXISTING MAJOR CONTOURS 25 FT Ox00 0 464 / / t\ \� t I I \I I i / / // / FINAL COVER MINOR CONTOURS (2 FT) / FINAL COVER MAJOR CONTOURS 10 FT \ — 21 / 0`S"00 / / ;,l' �\ \� /�',' I i / / �'o /' DITCH CENTERLINE AND FLOW DIRECTION FINAL COVER SLOPE I — 0 1 +{�F / r O� v / '' • / / —500 — — / ` 1 \ oo ` IN FIELD CCR LIMITS VERIFICATION AREA (SEE / ,��\\\\\\� 'Ox 00 ) ,� NOTE 1) 00 � 40 7' 475 — _� \ \ — r SS00cv-Oo o \ 3 > -- ---- - -- - - - ` g 500 I r 1 I Q\° 4�� 2� o �N� ° 1 / / ������. }/ -1 I REFERENCE _ ,�• � 1 ` 1. TOPOGRAPHIC DATA PRESENTED IN THIS DRAWING IS TAKEN `O V / / / / � � � FROM "AERIAL TOPOGRAPHIC SURVEY - MAYO PLANT" DATED \'500 ` � °° � N � /--f \ // / OCTOBER 31, 2015 PREPARED BY WSP FOR DUKE ENERGY. 3. ASH BASIN WASTE BOUNDARY PRESENTED IN THIS DRAWING IS PROP. DISCHARGE CHANNEL `� \ -.— \ PREPARED BY SYNTERRA FOR DUKE ENERGY. UPDATED 525 5o _ \ \ SEPTEMBER 2018 l I 4. NO UNDERGROUND UTILITIES HAVE BEEN LOCATED OR MAPPED o xo`L\ `\ / / '�� \ / FOR THIS PROJECT. THE LOCATION OF ANY AND ALL UTILITIES 1 Soo `'oo / / \ / / \ \ = SHOWN HEREON WHETHER PUBLIC/PRIVATE ARE BASED ON 2 1 PHOTOGRAMMATIC MAPPING AND ARE APPROXIMATE ONLY. 00 .00 ` 7"� \ I 11 \ \ 5. BASIS OF BEARINGS: NC GRID NAD83/2011,ELEVATIONS ARE J I \ / \ BASED ON NAVD88. 6. SEEP LOCATIONS DEPICTED ARE APPROXIMATE AND BASED ON ` l / Soo / o\ /~ I / ��o ( I I \ — \ / / \ / / "COMPREHENSIVE SITE ASSESSMENT REPORT - MAYO STEAM ELECTRIC PLANT " PREPARED BY SYNTERRA FOR DUKE ENERGY / - �► 1 / o '�'& AND SUBMITTED TO NCDEQ (NPDES PERMIT NO. NC0038377) ON — 525 -�.^ SEPTEMBER 2, 2015. \ \ 1 / / — / s \ \ \ /. 7. DEPICTED WETLANDS AND PROPERTY BOUNDARY ARE BASED ON \ /�;' �5°° / JURISDICTIONAL WATERS FIGURES PREPARED FOR DUKE oa' •- r-� Ci/ ��\��\ ENERGY BY WOOD PLC, JULY 18,2018. MAYO LAKE EXISTING RAIL LINE NOTE \ 1. FINAL COVER CAP SYSTEM IS ONLY REQUIRED WITHIN THE ASH \ i r\ BASIN BOUNDARY. LIMITS OF ASH BASIN BOUNDARY WILL NEED �soo ` TO BE REFINED THROUGH GEOTECHNICAL INVESTIGATION TO BE PERFORMED AT LATER DATE. 1 .61 0 0 300 600 900 / T \ / � . \ ` r cam_, / r / ._` �l � ✓r �` � 0 \ ` < - 5 GRAPHIC SCALE (IN FEET) Q � TITLE MAYO PLANTSTEAM ELECTRIC CLOSURE IN PLACE GRADING PLAN CIO 1 f ! / /I / / 1� COAL PILE / .. , MAYO STEAM ELECTRIC PLANT I / /�-- / ASH BASIN CLOSURE OPTIONS EVALUATION \ / / PERSON COUNTY, NORTH CAROLINA FOR MAYO PLANT 1 / ////, // ` // i ( `�'•"/ �� ,: �. {_ ,�+�' SCALE: 1=300' DES: RD ' DUKE DWG NO: 605D76646 CHKD: CP I d — ENERGY® DATE: 11-20-18 ENGR : CP FILENAME: CIP_GRADING_PLAN.DWG APPD: DC DWG SIZE DRAWING NO. REVISION 1 / //� /�\ \ \\ // O 1 • • • •• • O 1 • ANSI D FIGURE A2A 0 0 1 2 3 2 TENTHS 10 20 30 3 4 5 6 7 8 1 1 1 1 1 1 1 m 0 2 3 4 5 6 7 8 FIGURE A213 REV. O q 550 525 500 475 450 425 400 375 0+00 CCR UNIT BOUNDARY 550 525 500 475 450 425 LEGEND 400 EXISTING GROUND HISTORICAL GROUND 375 PROPOSED FINAL CAP GRADES PROPOSED GRADES EXISTING GRADES HISTORICAL GRADES 37+59 - 5+00 10+00 SECTION 15+00 A 20+00 25+00 30+00 35+00 550 B 525 500 475 450 425 400 375 HISTORICAL GRADES CCR UNI BOUN PROPOSED GRADES EXISTING GRADES C 0+00 5+00 10+00 15+00 20+00 25+00 30+00 SECTION B 550 525 500 � 475 450 425 400 CC UNIT B UNDARY PROPOSED GRADES HISTORICAL GRADES EXISTING GRADES � I/ 0+00 5+00 10+00 15+00 20+00 25+00 30+00 SECTION C 0 1 2 3 2 TENTHS 10 20 30 550 525 500 475 450 425 400 375 34+42 550 525 500 475 450 425 400 34+42 TITLE CLOSURE IN PLACE CROSS SECTIONS MAYO STEAM ELECTRIC PLANT ASH BASIN CLOSURE OPTIONS EVALUATION PERSON COUNTY, NORTH CAROLINA FOR MAYO PLANT alh, DUKE 41 ENERGY SCALE: 1" = 150' DES: RD DWG TYPE :.DWG DFTR : RD JOB DATEN0:60518/2018 ENGR: CP FILENAME: CIP GRADING PLAN.DWG APPD: DC DWG SIZE DRAWING NO. REVISION ANSI D 22.0"x 34.0" FIGURE A2B O 8 m G Q ■ C 2 3 4 5 6 7 8 REV. 2 }i 3 ■ yam•! +M1 -.• `�;�kryf ■ �]' �• ' ` •kr 4 `'�' w ,7{ + _k x, 'L: ' �_r '�` Y , ■iJ ' r -AIL +� F 1t .' Tr-•�, * i 1 Y L•`'' `. �. ti' rJ .. �' V �f =1�I +`5 •.W* r''�+• ' ~, ■ 7 •,+� 'r'r• ' 3 ! ` + ''IL f �� , �' Y "' !�' a _ ^ �' '•••"i, .'.� ■ - N T ;'^ J +I .I 1 ' 1. 7• - r'L �w 1 'y �:.,, r�� fir• #�F'� .'�- ' r+' •' '4 . } # � a _ F`'• F' - { y ] � ' 'Li■� a ,f,� I�: ip M1 •• „ti_ - J ' � �_- •"' �� � _ ! ' ' _ '. _ - � jq�� �s� ' '+� r Y� i I � Y 7 R7F' �,- dM9TF �4!4± + _'r . - !I:.-�3^ �A. r , �I _ ■� {• ,: � 4 � 4 .¢':R,�IF h _ � + � t�,• • /I\1 PERMITTED + • BOUNDARY } y, kL.q ■. , _ -1 f T;l� i y i }�+il'�..i = 5 w Nix. fix ' , } Fr ew -i 1p' ■ -d '+'J'Jr!• � ■ ° J! i RELOCATED- • M ASH BASIN a. ' �•5 .� _ i ' L �` G 11 r .�M �. J .1" 1 •' !' •� '` LL F rfiv 'A .- `.- I. 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L. *L f : , r " EXISTING LANDFILL ! �< ` rr ti _� ` - ,_ •• -' -�`' ` -�� (WITHIN PERMITTED - y 5_� r! s LANDFILL BOUNDARY) ., '� ! � a •_� � - -' i ,•7 .,l J a Z`'• - 141 I ]�j+�l - +'M 1 ''• L- �.. f.+ .�■ _ *.I�;t"'w_. 4 �- f� ''' - .•y 'ISM .+T, .I_. µ� �. •� r��) ., �L I�Ti s F �Lk '� �,h• r ' • +ar �� - . , Y ,• �rry ■ � - • �" �i "1 ' _ i •r • ".f •• •� �+ s• k� � � ■ -�� - s •_ F ' ; + � 4 - �If�.'1■ll� �' � I � ;,}-'• ~..�■ '.. - F - - �;�5 I ■ #� JJ •_ `�•� �' }• - - � -{rR r •�.y� L y �•.- _ � _ � � ~` � {?' `•� � v � _} �i•,M1� F` - , } L •� 4� � .jl f Ir K� r7il ry �i`y +i xx • �I ' Yr q f R J ' . �` u3• r y F d rr :� n i' rsr a TITLE pf i�-.lx .i ti { �!■L t.' - , ' "_ �Yc. Y- ra 1 •+a ' ,� _ # '+..J + ■; L ''i' REMOVAL ONSITE ��• .tea. ��■ �41 _ ,ter _ .•,• + i� _ L� , •�'�� s •Nr _ii!�• -r'•F ,�5'v�•�'r CLOSURE �. _ - , ,•ram -'_'Pf 'F _ i f wLP•.r ■- ■tea 1 � r 's - ' - r- M q ,}4■r n.�■h LANDFILLS Ii :L��••1 ! r­416 7. I _'1'.' s' •. �." �L .'} - -V• r v 'r - +T^. ��7i `.Y+�'` I'rl ` �� MAYO STEAM ELECTRIC PLANT ASH BASIN CLOSURE OPTIONS EVALUATION 17A r 4 ; ��'� ' h L ° t ?■ spec" 7>� PERSON COUNTY, NORTH CAROLINA M1 �_ t 6''ti - �r� +�' _ rV •L � . r� , L _ F� zff4 # sFOR L=}"`•�.. •� v Y L" s" .�.ti•'17. y �, ■ I PLANTMAYO r t'`•.�■ _ •'y■'1 3 �'� �i}�Y'+c �;1 + } .1.�t'a `,r - s .F• a• '1� ' • 1 1 1 ■- S _ Yam■ ■ .. r s iJJ L h L M'.�o-• r x �' ' r x # 1 3 •y.ti' t •. s�`� + �' ; _-.v., SCALE: V=300' G TYPE: 09 DWG TYPE a DUKE _ y,Ti 1 w ■ram ■Y ■ i I tiy'1 ~ r� ' T• f• -- ,'■� -} '■ytiF '-r- ja{_ r. •' y �+ 1 L ' f ,� ' . i604320 13 -' _'•�� s r• J•i. z; aal ' 'i �, ^r +-+r.'-■ -- - ���{ Y 4.� + tic. - 3-� y .L 1 A i■�• 1 _ i • 1��}� _ : �_ ' : f" k_ ' ��''r�r it .+,i �.�LFpy T{;• IF Y DATE: 10/18/2018 -� '�{r J y r r r �! +*i t•'+ENE •••. II LT '�1y■ I + s SC { 1 { ' ■ f l- �•��r 6w i 7- 'FJ j '�y. pp r r ��; ,. i �y- L ♦ {�i�',' _ r_ .'f+ w ■• w r... L ti i F 11{ c L ■i S a F 4FILENAME:OPTIONS • r �J� {'! {�1 .,R.�. ' �'� ■ +L - �. � � , �`, r•..��'. � • 7 -!!' 1 ] ' r.'�l� � {. yr' * ry - ■' �I_ r � s ••� y '� � � ' 1i 'L' � , d- �' - 1 r � l' ■'�Jr. r9 , ;�:i ■ � , ] ■ {� • . ,r • i v � � � ■i' y�■�rJ� 1 � � � • • •� _, } ++R 1F - �Y •F' �i Y _ �L+ L. +'}�+•• ''L'^'.M1 ��+ -w .Jf L ^� I. ' Y �- �{+�+ -` .� - 4 �' j ik Ir •� f�_. * L_`• r' • r 3 ■ =I,`'y '• `■ i, :�, 'rCr t,l L i,t+-fit''`''-ili' { r ' �: 'i. yY� nr „ s *• _ ■ ■ '' YL �'�.•'y7 _�'s!i '�'ti � ,■�. � �`�� '� � �:••• ��'' -.� �1'-r.n:.�■-�� ��..� -n 1 - J_ ;;0 m N Attachment B PROJECT: PLANT NAME: CLOSURE TYPE: SHEET: REV. NO.: AAZCO CCR IMPOUNDMENT CLOSURE ESTIMATES FOR DUKE ENERGY Mayo CCR Rule & CAMA Compliant Cost Summary 4 SUBJECT: IMPOUNDMENT NAME: CLOSURE METHOD: AECOM JOB NO.: CALCULATION SHEET Preliminary Promect Costs Sheets Ash Basin Hybrid 60432144 ACTIVITY: CLOSURE OPTION: LAST UPDATED BY: DATE LAST MODIFIED: REVIEWED BY: Cost Summary: Hybrid Cost Estimate for CCR Impoundment 1 1 Claudia Prado 11/8/2018 1 KK MAYO PLANT - OPTION 1 HYBRID CLOSURE Closure & Post Closure Cost Summary Closure Tasks Cost (2018 Dollars) Mobilization / Site Prep / Demobilization $5,638,640 Dewatering / Excavation for Closure by Removal / Convey Material $51,351,289 Dewatering / Earthwork for Close -in -Place $13,365,422 Lateral Expansion Areas $3,614 603 Closure System Construction $7,447,321 Stormwater Management / E&S Controls / Site Restoration $2,414,762 Contingency (25%) $20,958,009 Engineering Support (Design & CQA) $4,500,000 Total Closure Cost of CCR Impoundment = $109,290,046 Post -Closure Tasks Cost (2018 Dollars) Groundwater Monitoring $14,790,000 Operations & Maintenance (O&M) $8,550,468 Contingency (25%) $5,835,117 Engineering Costs (10%) $2,917,559 Total Post -Closure of CCR Impoundment = $32,093,144 Total Closure & Post -Closure of CCR Impoundment Cost = $141,383,190 Preliminary Based on Information Available as of 11/08/2018 1 of 5 PROJECT: PLANT NAME: CLOSURE TYPE: SHEET: REV. NO.: CCR IMPOUNDMENT CLOSURE ESTIMATES FOR DUKE ENERGY Mayo CCR Rule & CAMA Compliant Hybrid Costs 4 JOUCOM SUBJECT: IMPOUNDMENT NAME: CLOSURE METHOD: AECOM JOB NO.: CALCULATION SHEET PreliminarV Promect Costs Sheets Ash Basin Hybrid 60432144 ACTIVITY: CLOSURE OPTION: LAST UPDATED BY: DATE LAST MODIFIED: REVIEWED BY: Hybrid Closure Costs 1 Claudia Prado 11/08/18 JDP BASIS OF THE ESTIMATE YEAR COST BASIS 2018 TOTAL IMPOUNDMENT AREA (AC) 140 TOTAL AREA TO BE RESTORED (AC) 145 VOLUME OF FREE WATER IN IMPOUNDMENT (GAL) Not Used IMPOUNDMENT AREA TO BE CLOSED -IN -PLACE (AC) 82 IMPOUNDMENT AREA TO BE CLOSURE BY REMOVAL (AC) 58 EXISTING ASH VOLUME IN AREA TO BE CLOSED -IN -PLACE (CY) 3,850,000 TOTAL ASH VOLUME FROM CLOSURE BY REMOVAL (CY) 1,650,000 TOTAL (FINAL) ASH VOLUME TO BE CLOSED -IN -PLACE (CY) 4,877,950 ;'PTH OF CUT -SLOPE AT CLOSE -IN -PLACE / CLOSURE BY REMOVAL INTERFACE 1,100 HYBRID ESTIMATED COSTS INSTALLED IMPOUNDMENT TASK ITEM UNIT QUANTITY UNIT COST CLOSURE COST NOTES MOBILIZATION / SITE PREP / DEMOBILIZATION Mob/Demob & insurance: (1 % of Total Bid Price) includes 1 MOBILIZATION / DEMOBILIZATION LS 1 $903,462 $903,462 administration (mtgs, health & safety, trailer, MOBILIZATION/ phone/fax/electricity, temporary facilities, utilities, roll off boxes, SITE PREP/ waste disposal, and cleanup). DEMOBILIZATION 2 REMOVAL OF OUTLET STRUCTURES / PIPING LS 1 $994,112 $994,112 Assume outlet structures and piping will be excavated and removed. 3 REMOVAL & FILTRATION OF FREE WATER MONTHS 36.0 $103,919 $3,741,066 Based on Initiation time DEWATERING / EXCAVATION FOR CLOSURE BY REMOVAL / CONVEY MATERIAL 4 REMOVAL & TREATMENT OF PORE WATER WITHIN ASH MONTHS 60.0 $225,832 $13,549,937 Based on Construction time IN CLOSURE BY REMOVAL AREA Assume CCR material must be stockpiled within impoundment 5 EXCAVATE ASH FOR CLOSURE BY REMOVAL / CY 1,650,000 $8.00 $13,200,000 area to decant prior to loading. Done in conjunction with Step STOCKPILE ASH 1. Decant water collected and treated along with pore water DEWATERING / from Step 1. EXCAVATION FOR Once material has decanted, CCRs must be excavated out of CLOSURE BY 6 EXCAVATE ASH FROM STOCKPILE / LOAD / HAUL ASH TO CY 1,027,950 $8.43 $8,665,619 stockpile, loaded on trucks and hauled to close -in -place area. REMOVAL / CLOSE -IN -PLACE AREA Quantity takes into consideration reduction of volume due to CONVEY dewatering of ash down to 30% moisture content. MATERIAL OVER EXCAVATE SOIL FROM CLOSURE BY REMOVAL Assume 1 foot of additional material to be removed over total 7 AREA / LOAD / HAUL CCR-IMPACTED SOIL TO CLOSE -IN- CY 93,573 $10 $935,733 closure by removal impoundment area. PLACE AREA DEEP MIXING METHOD (DMM) WALL TO STABILIZE CUT- Assume DMM wall for large ponds that require excavating a 8 SLOPE AT CLOSE -IN -PLACE / CLOSURE BY REMOVAL L.F. 1,500 $10,000 $15,000,000 portion of the pond and stacking excavated material on INTERFACE remaining portion. 9 EXCAVATE / LOAD / HAUL CCR MATERIAL (OFF -SITE) CY 0 $60 $0 include if applicable 10 EXCAVATE / LOAD / HAUL CCR-IMPACTED SOIL (OFF- CY 0 $57 $0 include if applicable SITE) Preliminary Based on Information Available as of 11/08/2018 2 of 5 PROJECT: PLANT NAME: CLOSURE TYPE: SHEET: REV. NO.: CCR IMPOUNDMENT CLOSURE ESTIMATES FOR DUKE ENERGY Mayo CCR Rule & CAMA Compliant Hybrid Costs 4 JOUCOM SUBJECT: IMPOUNDMENT NAME: CLOSURE METHOD: AECOM JOB NO.: CALCULATION SHEET PreliminarV Promect Costs Sheets Ash Basin Hybrid 60432144 ACTIVITY: CLOSURE OPTION: LAST UPDATED BY: DATE LAST MODIFIED: REVIEWED BY: Hybrid Closure Costs 1 Claudia Prado 11/08/18 JDP BASIS OF THE ESTIMATE YEAR COST BASIS 2018 TOTAL IMPOUNDMENT AREA (AC) 140 TOTAL AREA TO BE RESTORED (AC) 145 VOLUME OF FREE WATER IN IMPOUNDMENT (GAL) Not Used IMPOUNDMENT AREA TO BE CLOSED -IN -PLACE (AC) 82 IMPOUNDMENT AREA TO BE CLOSURE BY REMOVAL (AC) 58 EXISTING ASH VOLUME IN AREA TO BE CLOSED -IN -PLACE (CY) 3,850,000 TOTAL ASH VOLUME FROM CLOSURE BY REMOVAL (CY) 1,650,000 TOTAL (FINAL) ASH VOLUME TO BE CLOSED -IN -PLACE (CY) 4,877,950 ;'PTH OF CUT -SLOPE AT CLOSE -IN -PLACE / CLOSURE BY REMOVAL INTERFACE 1,100 HYBRID ESTIMATED COSTS INSTALLED IMPOUNDMENT TASK ITEM UNIT QUANTITY UNIT COST CLOSURE COST NOTES DEWATERING / EARTHWORK FOR CLOSE -IN -PLACE 11 REMOVAL & TREATMENT OF PORE WATER WITHIN ASH MONTHS 0.0 $225,832 $0 Accounted for in closure by removal time frame. Spread dewatered ash excavated from CLOSURE BY 12 SPREAD AND COMPACT MATERIAL FROM CLOSURE BY CY 1,027,950 $7.56 $7,771,302 REMOVAL area in thin lifts over close -in -place area. Quantity DEWATERING / REMOVAL AREA takes into consideration reduction of volume due to dewatering EARTHWORK FOR of ash down to 30% moisture content. CLOSE -IN -PLACE ASH REGRADING TO ESTABLISH CROWN AND Quantity of earthwork (cut -to -fill) using existing ash to achieve 13 CY 500,000 $9.24 $4,620,000 min. 3% slope prior to installation of closure system. Quantity SURROUNDING POSITIVE DRAINAGE calculated using AutoCAD. 14 RING DRAIN INSTALLATION L.F. 14,000 $58 $806,120 Linear feet around the close -in -place area 15 PERIMETER DITCH / TEMP. DIVERSION BERM GRADING L.F. 14,000 $12 $168,000 Linear feet around the perimeter of impoundment. LATERAL EXPANSION AREAS LATERAL In areas where ash will be placed outside of the existing ash EXPANSION basin waste boundary, this will be considered a Lateral AREAS 16 LATERAL EXPANSION AREAS AC 4.5 $803,245 $3,614,603 Expansion per the CCR regulations and will require a composite liner system with Ieachate collection. CLOSURE SYSTEM CONSTRUCTION 17 FLEXIBLE MEMBRANE LINER (FML) SQ. FT. 3,929,112 $0.42 $1,650,227 Flexible membrane liner placed over close -in -place area. Assume quantity needed is 10% more than close -in -place area. 18 GEOCOMPOSITE DRAINAGE LAYER SQ. FT. 3,929,112 $0.60 $2,357,467 Geocomposite drainage layer placed over close -in -place area. Assume quantity needed is 10% more than close -in -place area. CLOSURE SYSTEM CONSTRUCTION 19 GEOSYNTHETIC CLAY LINER (GCL) SQ. FT. 0 $0.72 $0 not used 20 18" PROTECTIVE COVER SOIL CY 198,440 $13 $2,579,720 18 inches of common soil placed over closure by in place area 21 6" TOPSOIL CY 66,147 $13 $859,907 6 inches of topsoil placed over closure in place area. 22 COMPACTED LOW PERM. SOILS (Kv<1x10^-5 cm/sec) CY 0 $12 $0 not used: Preliminary Based on Information Available as of 11/08/2018 3 of 5 PROJECT: PLANT NAME: CLOSURE TYPE: SHEET: REV. NO.: CCR IMPOUNDMENT CLOSURE ESTIMATES FOR DUKE ENERGY Mayo CCR Rule & CAMA Compliant Hybrid Costs 4 JOUCOM SUBJECT: IMPOUNDMENT NAME: CLOSURE METHOD: AECOM JOB NO.: CALCULATION SHEET PreliminarV Promect Costs Sheets Ash Basin Hybrid 60432144 ACTIVITY: CLOSURE OPTION: LAST UPDATED BY: DATE LAST MODIFIED: REVIEWED BY: Hybrid Closure Costs 1 Claudia Prado 11/08/18 JDP BASIS OF THE ESTIMATE YEAR COST BASIS 2018 TOTAL IMPOUNDMENT AREA (AC) 140 TOTAL AREA TO BE RESTORED (AC) 145 VOLUME OF FREE WATER IN IMPOUNDMENT (GAL) Not Used IMPOUNDMENT AREA TO BE CLOSED -IN -PLACE (AC) 82 IMPOUNDMENT AREA TO BE CLOSURE BY REMOVAL (AC) 58 EXISTING ASH VOLUME IN AREA TO BE CLOSED -IN -PLACE (CY) 3,850,000 TOTAL ASH VOLUME FROM CLOSURE BY REMOVAL (CY) 1,650,000 TOTAL (FINAL) ASH VOLUME TO BE CLOSED -IN -PLACE (CY) 4,877,950 ;'PTH OF CUT -SLOPE AT CLOSE -IN -PLACE / CLOSURE BY REMOVAL INTERFACE 1,100 HYBRID ESTIMATED COSTS INSTALLED IMPOUNDMENT TASK ITEM UNIT QUANTITY UNIT COST CLOSURE COST NOTES STORMWATER MANAGEMENT / E&S CONTROLS / SITE RESTORATION 23 PERMANENT RIPRAP STORMWATER CHANNELS TON 7,250 $50 $362,500 Assume 10,000 If x 10 ft. wide x 1 ft. thick, 145 pcf riprap lined stormwater channels. STORMWATER 24 SITE EROSION AND SEDIMENT CONTROL ACRE 145 $2,000 $289,000 Assume total area to be restored will require site erosion and MANAGEMENT / sediment control. E&S CONTROLS / Assume 12-inches of additional soil material graded over total SITE 25 BACKFILL AND REGRADING OF CLOSURE BY REMOVAL CY 93,767 $13 $1,218,967 closure by removal area, to account for material removed by 1 RESTORATION AREA foot overexcavation of CCR impacted soils. 26 TOPSOIL CY 0 $13 $0 Assume 6-inches of top soil needed to establish vegetative stabilization over total closure by removal area. 27 SEED / FERTILIZE / MULCH ACRE 145 $3,767 $544,295 Assume total area of disturbance will be mulched, fertilized, and seeded. CONTINGENCY / ENGINEERING SUPPORT CONTINGENCY / ENGINEERING 28 CONTINGENCY (25%) LS 1 $20,958,009 $20,958,009 SUPPORT 29 ENGINEERING SUPPORT (DESIGN & CQA) LS 1 $4,500,000 $4,500,000 POST -CLOSURE POST -CLOSURE 30 GROUNDWATER MONITORING ANNUAL 30 $493,000 $14,790,000 Annual groundwater monitoring costs for each CCR impoundment are based on current groundwater monitoring system 31 OPERATIONS & MAINTENANCE (O&M) ANNUAL 30 $285,016 $8,550,468 Annual O&M costs are 3475.80/ac/yr. Based on Q3 2018 Post Closure Maintenance data CONTINGENCY / ENGINEERING COST CONTINGENCY / ENGINEERING CONTINGENCY (25%) LS 1 $5,835,117 $5,835,117 COST ENGINEERING COST (10%) LS 1 $2,917,559 $2,917,559 TOTAL $141,383,190 Preliminary Based on Information Available as of 11/08/2018 4 of 5 PROJECT PLANT NAME: CLOSURE TYPE: SHEET REV. NO. CCR IMPOUNDMENT CLOSURE ESTIMATES FOR DUKE ENERGY Mayo CCR Rule & CAMA Compliant Hybrid Assumptions 4 JAZCOM SUBJECT IMPOUNDMENT NAME: CLOSURE METHOD: CLOSURE YEAR: AECOM JOB NO. CALCULATION SHEET PreliminarV Promect Costs Sheets Ash Basin Hybrid 0 60432144 ACTIVITY CLOSURE OPTION: LAST UPDATED BY: DATE LAST MODIFIED: REVIEWED BY: Hybid Closure Assumptions 1 Claudia Prado 11/08/18 JDP KEY ASSUMPTIONS The following key assumptions and limitations are associated with the project design, implementation and performance: 1 The cost estimates were prepared using 2018 dollars and do not include any escalation. 2 A 25% contingency has been included for this cost estimate. 3 The cost for Engineering Support (Design & CQA) for the Hybrid option assumes $3M for design and $1.5M for CQA (assuming CQA cost is $25K/month for 5 years) 4 The unit rate costs are based on AECOM & Duke experience. 5 Pore water to be partially removed from ash in closure by removal area using combination of open pit dewatering and rim-ditch/wet stack methods until material can be excavated and stockpiled. Assume saturated ash must be dewatered down to 30% moisture content to haul and place in close -in -place area. Assume treatment for TSS, pH, Arsenic & Selenium. Costs based on AECOM's estimates from Duke's dewatering projects. 6 Assume pore water removal and treatment is accounted for within close -in -place area time frame. Surface area to be regraded and limited surficial dewatering will be necessary prior to receipt of ash from closure -by -removal area. 7 Removal of existing structures/piping includes the excavation and disposal of existing structures within the limits of waste and the bulkheading or grouting of existing outlet pipes that extend beyond the limits of waste. This will be performed during the closure by removal of an impoundment. 8 Assumed all CCR material excavated must be stockpiled in close proximity to the impoundment to be decanted. After decanting, the material will be excavated, loaded, and hauled to an on -site impoundment to be closed -in -place. 9 Assume all material excavated from areas to be closed by removal will be used for crown construction/soil regrading for closed -in -place areas. 10 Assume an over -excavation of 1 foot is necessary to achieve closure by removal conditions. 11 Cap cross section for the CCR impoundment will consist of (from bottom to top): ash / geomembrane / geocomposite drainage layer / 24" protective cover soil. The top 6-inches will be topsoil, or soil ammended to enable vegetative growth. 12 Common soil for embankment and protective cover soil construction are available near -site and topsoil would come from offsite 13 Groundwater monitoring costs for CCR impoundment is based on current groundwater monitoring system, as provided by Duke. 14 O&M costs provided by Duke. 15 Statements of Probable Construction Cost prepared by AECOM represent AECOM's judgment as a design professional familiar with the construction industry. It is recognized, however, that neither AECOM nor the Owner has control over the cost of labor, materials or equipment nor over the contractor's methods of determining the bid price or other competitive bidding, market, or negotiating conditions. Accordingly, AECOM cannot and does not warrant or represent that proposals, bids or actual construction costs will not vary from any statement of Probable Construction Cost or other estimates or evaluations prepared by AECOM. Preliminary Based on Information Available as of 11/08/2018 5 of 5 PROJECT: PLANT NAME: CLOSURE TYPE: SHEET: REV. NO.: d �COM CCR IMPOUNDMENT CLOSURE ESTIMATES FOR DUKE ENERGY Mayo CCR Rule & CAMA Compliant Cost Summary 4 SUBJECT: IMPOUNDMENT NAME: CLOSURE METHOD: AECOM JOB NO.: ►� CALCULATION SHEET PreliminarV Promect Costs Sheets Ash Basin Close -in -Place 60432144 ACTIVITY: CLOSURE OPTION: LAST UPDATED BY: DATE LAST MODIFIED: REVIEWED BY: Cost Summary: Close -in -Place Cost Estimate for CCR Surface Impoundment 2 1 Claudia Prado 1 11/8/2018 1 KK MAYO PLANT - OPTION 2 CLOSURE -IN -PLACE Closure & Post Closure Cost Summary Close -in -Place Tasks Cost (2018 Dollars) Mobilization / Site Prep $3,497,862 Dewatering / Earthwork / Subgrade Prep. $21,819,450 Closure System Construction $12,714,938 Stormwater Management / E&S Controls / Site Restoration $19,349,095 Contingency (25%) $14,345,336 Engineering Support (Design and CQA) $2,900,000 Total Closure Cost of CCR Impoundment = $74,626,681 Post -Closure Tasks Cost (2018 Dollars) Groundwater Monitoring $14,790,000 Operations & Maintenance (O&M) $14,598,360 Contingency (25%) $7,347,090 Engineering Costs (10%) $3,673,545 Total Post -Closure of CCR Impoundment = $40,408,995 Total Closure & Post -Closure of CCR Impoundment Cost = $115,035,676 Preliminary Based on Information Available as of 11/08/2018 1 of 4 PROJECT: PLANT NAME: CLOSURE TYPE: SHEET: REV. NO.: AECOM CCR IMPOUNDMENT CLOSURE ESTIMATES FOR DUKE ENERGY Mayo CCR Rule & CAMA Compliant Cost Summary 4 SUBJECT: IMPOUNDMENT NAME: CLOSURE METHOD: AECOM JOB NO.: CALCULATION SHEET PreliminarV Promect Costs Sheets Ash Basin Close -in -Place 60432144 ACTIVITY: CLOSURE OPTION: LAST UPDATED BY: DATE LAST MODIFIED: REVIEWED BY: Close -in -Place Costs 1 2 1 Claudia Prado 11/08/18 JDP BASIS OF THE ESTIMATE YEAR COST BASIS 2018 AREA OF OPEN FREE WATER IN IMPOUNDMENT (AC) Not Used TOTAL AREA TO BE RESTORED (AC) 140 AVG. DEPTH OF FREE WATER (FT) Not Used TOTAL IMPOUNDMENT AREA (AC) 140 VOLUME OF FREE WATER IN IMPOUNDMENT (GAL) Not Used VOLUME OF ASH IN IMPOUNDMENT (CY) 5,500,000 CLOSE -IN -PLACE ESTIMATED COSTS INSTALLED IMPOUNDMENT TASK ITEM UNIT QUANTITY UNIT COST CLOSURE COST NOTES MOBILIZATION / SITE PREP Mob/Demob & insurance: (1% of closure tasks) 1 MOBILIZATION LS 1 $633,217 $633,217 includes administration (mtgs, health & safety, trailer, MOBILIZATION/ phone/fax/electricity, temporary facilities, utilities, roll off SITE PREP boxes, waste disposal, and cleanup). 2 ABANDON OUTLET STRUCTURES / PIPING LS 1 $994,112 $994,112 Abandon existing outlet structures and piping. 3 REMOVAL & FILTRATION OF FREE WATER MONTHS 18.0 $103,919 $1,870,533 Initiation time DEWATERING / EARTHWORK / SUBGRADE PREP 4 REMOVAL & TREATMENT OF PORE WATER WITHIN ASH MONTHS 48.0 $225,832 $10,839,950 Construction Time DEWATERING / EARTHWORK / 5 RING DRAIN INSTALLATION L.F. 25,000 $58 $1,439,500 Linear feet around the proposed cap. SUBGRADE PREP Quantity of earthwory (cut -to -fill) using existing ash to 6 ASH REGRADING TO ESTABLISH CROWN CY 1,000,000 $9.24 $9,240,000 achieve min. 1.5% valley profile prior to installation of closure system. Quantity calculated using AutoCAD. 7 PERIMETER DITCH / TEMP. DIVERSION BERM GRADING L.F. 25,000 $12 $300,000 Linear feet around the perimeter of impoundment. CLOSURE SYSTEM CONSTRUCTION Flexible membrane liner placed over close -in -place area. 8 FLEXIBLE MEMBRANE LINER (FML) SQ. FT. 6,708,240 $0.42 $2,817,461 Assume quantity needed is 10% more than close -in -place area. Geocomposite drainage layer placed over close -in -place 9 GEOCOMPOSITE DRAINAGE LAYER SQ. FT. 6,708,240 $0.60 $4,024,944 area. Assume quantity needed is 10% more than close -in - place area. CLOSURE SYSTEM CONSTRUCTION 10 GEOSYNTHETIC CLAY LINER (GCL) SQ. FT. 0 $0.72 $0 not used 11 18" PROTECTIVE COVER SOIL CY 338,800 $13 $4,404,400 18 inches of common soil placed over closure by removal area 12 6" TOPSOIL CY 112,933 $13 $1,468,133 6 inches of topsoil placed over total impoundment area. 13 COMPACTED LOW PERM. SOILS (Kv<1x10^-5 cm/sec) CY 0 $12 $0 not used: Preliminary Based on Information Available as of 11/08/2018 2 of 4 PROJECT: PLANT NAME: CLOSURE TYPE: SHEET: REV. NO.: /ECOM CCR IMPOUNDMENT CLOSURE ESTIMATES FOR DUKE ENERGY Mayo CCR Rule & CAMA Compliant Cost Summary 4 SUBJECT: IMPOUNDMENT NAME: CLOSURE METHOD: AECOM JOB NO.: CALCULATION SHEET PreliminarV Promect Costs Sheets Ash Basin Close -in -Place 60432144 ACTIVITY: CLOSURE OPTION: LAST UPDATED BY: DATE LAST MODIFIED: REVIEWED BY: Close -in -Place Costs 1 2 1 Claudia Prado 11/08/18 JDP BASIS OF THE ESTIMATE YEAR COST BASIS 2018 AREA OF OPEN FREE WATER IN IMPOUNDMENT (AC) Not Used TOTAL AREA TO BE RESTORED (AC) 140 AVG. DEPTH OF FREE WATER (FT) Not Used TOTAL IMPOUNDMENT AREA (AC) 140 VOLUME OF FREE WATER IN IMPOUNDMENT (GAL) Not Used VOLUME OF ASH IN IMPOUNDMENT (CY) 5,500,000 CLOSE -IN -PLACE ESTIMATED COSTS INSTALLED IMPOUNDMENT TASK ITEM UNIT QUANTITY UNIT COST CLOSURE COST NOTES STORMWATER MANAGEMENT / E&S CONTROLS / SITE RESTORATION STORMWATER 14 EROSION AND SEDIMENT CONTROL ACRE 140 $2,000 $280,000 Assume total area to be restored will require site erosion MANAGEMENT / and sediment control. E&S CONTROLS / Assume rip -rap lined stormwater conveyance channels SITE 15 STORMWATER MANAGEMENT / CHANNELS / LET -DOWNS L.F. 25,000 $742 $18,541,750 and rip -rap lined let -downs off of cap. Quantity assumed at RESTORATION 3 times perimeter 16 SEED / FERTILIZE / MULCH ACRE 140 $3,767 $527,345 Assume total area to be restored will be mulched, fertilized, and seeded. CONTINGENCY / ENGINEERING SUPPORT CONTINGENCY / ENGINEERING CONTINGENCY (25%) LS 1 $14,345,336 $14,345,336 SUPPORT ENGINEERING SUPPORT (DESIGN & CQA) LS 1 $2,900,000 $2,900,000 POST -CLOSURE Annual groundwater monitoring costs for each CCR POST -CLOSURE 17 GROUNDWATER MONITORING ANNUAL 30 $493,000 $14,790,000 impoundment are based on current groundwater monitoring system 18 OPERATIONS & MAINTENANCE (O&M) ANNUAL 30 $486,612 $14,598,360 Annual O&M costs are 3475.80/ac/yr. Based on Q3 2018 Post Closure Maintenance data CONTINGENCY / ENGINEERING COST CONTINGENCY / ENGINEERING CONTINGENCY (25%) LS 1 $7,347,090 $7,347,090 COST ENGINEERING COST (10%) LS 1 $3,673,545 $3,673,545 TOTAL $115,035,676 Preliminary Based on Information Available as of 11/08/2018 3 of 4 PROJECT PLANT NAME: CLOSURE TYPE: SHEET REV. NO. A=1 COM CCR IMPOUNDMENT CLOSURE ESTIMATES FOR DUKE ENERGY Mayo CCR Rule & CAMA Compliant Close -in -Place Assumptions 4 SUBJECT IMPOUNDMENT NAME: CLOSURE METHOD: AECOM JOB NO. CALCULATION SHEET PreliminarV Promect Costs Sheets Ash Basin Close -in -Place 60432144 ACTIVITY CLOSURE OPTION: LAST UPDATED BY: DATE LAST MODIFIED: REVIEWED BY: Close -in -Place Assumptions 1 2 1 Claudia Prado 1 11/08/18 1 JDP KEY ASSUMPTIONS The following key assumptions and limitations are associated with the project design, implementation and performance: 1 The cost estimates were prepared using 2018 dollars and do not include any escalation. 2 A 25% contingency has been included for this cost estimate. 3 The cost for Engineering Support (Design & CQA) for the Close -in -Place option assumes $2M for design and $900K for CQA (assuming CQA cost is $25K/month for 3 years) 4 The unit rate costs are based on AECOM & Duke experience. 5 Surface area to be regraded and limited surficial dewatering will be necessary. 6 Abandonment of existing structures/piping includes the demolition in -place or bulkheading of existing pipes and inlets/outlet structures, grouting of outlet pipes that extend beyond the limits of waste, and backfilling of existing structures in -place for the purposes of a close -in -place closure of an impoundment. 7 To establish the minimum top slopes of 2% (post settlement), assume existing ash will be utilized to establish crown. 8 Cap cross section for the CCR impoundment will consist of (from bottom to top): ash / geomembrane / geocomposite drainage layer / 24" protective cover soil. The top 6-inches will be topsoil, or soil 9 Common soil for embankment and protective cover soil construction are available onsite and topsoil would come from offsite 10 Groundwater monitoring costs are based on values provided by Duke. 11 O&M costs are based on values provided by Duke. 12 Statements of Probable Construction Cost prepared by AECOM represent AECOM's judgment as a design professional familiar with the construction industry. It is recognized, however, that neither AECOM nor the Owner has control over the cost of labor, materials or equipment nor over the contractor's methods of determining the bid price or other competitive bidding, market, or negotiating conditions. Accordingly, AECOM cannot and does not warrant or represent that proposals, bids or actual construction costs will not vary from any statement of Probable Construction Cost or other estimates or evaluations prepared by AECOM. Preliminary Based on Information Available as of 11/08/2018 4 of 4 PROJECT: PLANT NAME: CLOSURE TYPE: SHEET: REV. NO.: 'CO CCR IMPOUNDMENT CLOSURE ESTIMATES FOR DUKE ENERGY Mayo CCR Rule & CAMA Compliant Cost Summary 4 SUBJECT: IMPOUNDMENT NAME: CLOSURE METHOD: AECOM JOB NO.: CALCULATION SHEET PreliminarV Promect Costs Sheets Ash Basin Closure by Removal 60432144 ACTIVITY: CLOSURE OPTION: LAST UPDATED BY: DATE LAST MODIFIED: REVIEWED BY: Cost Summary: Closure by Removal Cost Estimate for CCR Impoundment 1 3 1 Claudia Prado 1 11/8/2018 1 KK MAYO PLANT - OPTION 3 CLOSURE BY REMOVAL: EXISTING ON -SITE LANDFILL Closure & Post Closure Cost mary Closure by Removal Tasks Cost (2018 Dollars) Mobilization / Site Prep / Demobilization $6,349,444 Dewatering / Excavation / Convey Material $93,563,111 Onsite Landfill Construction, Disposal and Closure $51,709,494 Stormwater Management / E&S Controls / Site Restoration $4,179,045 Contingency (25%) $38,950,274 Engineering Support (Design & CQA) $5,000,000 Total Closure Cost of CCR Impoundment = $199,751,368 Post -Closure Tasks Cost (2018 Dollars) Groundwater Monitoring $14,790,000 Operations & Maintenance (O&M) $3,128,220 Contingency (25%) $4,479,555 Engineering Costs (10%) $2,239,778 Total Post -Closure of CCR Impoundment = $24,637,553 Total Closure & Post -Closure of CCR Impoundment Cost = $224,388,921 Preliminary Based on Information Available as of 11/08/2018 1 of 4 PROJECT: PLANT NAME: CLOSURE TYPE: SHEET: REV. NO.: 44"7co CCR IMPOUNDMENT CLOSURE ESTIMATES FOR DUKE ENERGY Mayo CCR Rule & CAMA Compliant Closure by Removal Costs 4 SUBJECT: IMPOUNDMENT NAME: CLOSURE METHOD: AECOM JOB NO.: CALCULATION SHEET PreliminarV Promect Costs Sheets Ash Basin Closure by Removal 60432144 ACTIVITY CLOSURE OPTION: LAST UPDATED BY: DATE LAST MODIFIED: REVIEWED BY: Closure By Removal Costs 1 1/3/1900 1 Claudia Prado 1 11/08/18 1 KK BASIS OF THE ESTIMATE YEAR COST BASIS 2018 AREA OF OPEN FREE WATER IN IMPOUNDMENT (AC) Not Used TOTAL AREA TO BE RESTORED (AC) 140 AVG. DEPTH OF FREE WATER (FT) Not Used TOTAL IMPOUNDMENT AREA (AC) 140 VOLUME OF FREE WATER IN IMPOUNDMENT (GAL) Not Used VOLUME OF ASH IN IMPOUNDMENT (CY) 5,500,000 MOBILIZATION/ SITE PREP/ DEMOBILIZATION ACHIEVE CLOSURE BY REMOVAL/ CONVEY MATERIAL ONSITE LANDFILL CONSTRUCTION, DISPOSAL AND CLOSURE CLOSURE BY REMOVAL ESTIMATED COSTS INSTALLED IMPOUNDMENT TASK ITEM UNIT QUANTITY UNIT COST CLOSURE COST NOTES MOBILIZATION / SITE PREP / DEMOBILIZATION Mob/Demob & insurance: (1 % of Total EPC Bid Price) includes 1 MOBILIZATION / DEMOBILIZATION LS 1 $1,614,266 $1,614,266 administration (mtgs, health & safety, trailer, phone/fax/electricity, temporary facilities, utilities, roll off boxes, waste disposal, and cleanup). 2 REMOVAL OF OUTLET STRUCTURES / PIPING LS 1 $994,112 $994,112 Assume outlet structures and piping will be excavated and removed. 3 REMOVAL & FILTRATION OF FREE WATER MONTHS 36.0 $103,919 $3,741,066 Based on Initiation Time DEWATERING / EXCAVATION / CONVEY MATERIAL 4 REMOVAL & TREATMENT OF PORE WATER WITHIN ASH MONTHS 84.0 $225,832 $18,969,912 Based on Construction Time Assume CCR material must be stockpiled within impoundment EXCAVATE ASH FOR CLOSURE BY REMOVAL / STOCKPILE area to decant prior to loading. Done in conjunction with Step 1. 5 ASH CY 5,500,000 $8 $44,000,000 Decant water collected and treated along with pore water from Step 1. Once material has decanted, CCRs must be excavated out of 6 EXCAVATE ASH FROM STOCKPILE / LOAD / HAUL ASH CY 3,426,500 $8 $28,885,395 stockpile, loaded on trucks and hauled to onsite disposal site. (DISPOSE ON -SITE) Quantity takes into consideration reduction of volume due to dewatering of ash down to 30% moisture content. 7 EXCAVATE / LOAD / HAUL CCR-IMPACTED SOIL (ON -SITE) CY 225,900 $8 $1,707,804 Assume 1 foot of additional material to be removed over total impoundment area (including upstream dam face). 8 EXCAVATE / LOAD / HAUL CCR MATERIAL (OFF -SITE LF) TON 0 $60 $0 Only include if disposing CCRS at an off -site landfill (assume density of 1.2 tons/cy) 9 EXCAVATE / LOAD / HAUL CCR-IMPACTED SOIL (OFF -SITE LF) TON 0 $57 $0 Only include if disposing CCRS at an off -site landfill (assume density of 1.2 tons/cy) ONSITE LANDFILL CONSTRUCTION, DISPOSAL AND CLOSURE Assume existing landfill designed and constructed in accordance with CAMA and CCR Rules. Additional acreage of liner needed to 10 CONSTRUCT ON -SITE LANDFILL AND ASSOCIATED AC 30 $803,245 $24,097,350 store an additional 5.5 million CY of CCR. Cost includes landfill COMPONENTS construction and all associated components, including: liner system, leachate management, stormwater management, access roads, closure system and all associated components,etc. DISPOSE/SPREAD/COMPACT ASH AND CCR-IMPACTED Place, spread and compact in thin lifts dewatered ash and CCR- 11 MATERIALS FROM CLOSURE BY REMOVAL AREA IN ON -SITE CY 3,652,400 $8 $27,612,144 impacted materials excavated from closure by removal area into LANDFILL landfill. Preliminary Based on Information Available as of 11/08/2018 2 of 4 PROJECT: PLANT NAME: CLOSURE TYPE: SHEET: REV. NO.: 44"7co CCR IMPOUNDMENT CLOSURE ESTIMATES FOR DUKE ENERGY Mayo CCR Rule & CAMA Compliant Closure by Removal Costs 4 SUBJECT: IMPOUNDMENT NAME: CLOSURE METHOD: AECOM JOB NO.: CALCULATION SHEET PreliminarV Promect Costs Sheets Ash Basin Closure by Removal 60432144 ACTIVITY CLOSURE OPTION: LAST UPDATED BY: DATE LAST MODIFIED: REVIEWED BY: Closure By Removal Costs 1 1/3/1900 1 Claudia Prado 1 11/08/18 1 KK BASIS OF THE ESTIMATE YEAR COST BASIS 2018 AREA OF OPEN FREE WATER IN IMPOUNDMENT (AC) Not Used TOTAL AREA TO BE RESTORED (AC) 140 AVG. DEPTH OF FREE WATER (FT) Not Used TOTAL IMPOUNDMENT AREA (AC) 140 VOLUME OF FREE WATER IN IMPOUNDMENT (GAL) Not Used VOLUME OF ASH IN IMPOUNDMENT (CY) 5,500,000 CLOSURE BY REMOVAL ESTIMATED COSTS INSTALLED IMPOUNDMENT TASK ITEM UNIT QUANTITY UNIT COST CLOSURE COST NOTES STORMWATER MANAGEMENT / E&S CONTROLS / SITE RESTORATION 10 PERMANENT RIPRAP STORMWATER CHANNELS TON 8,700 $50 $435,000 Assume 12,000 If x 10 ft. wide x 1 ft. thick, 145 pcf riprap lined stormwater channels. STORMWATER 11 SITE EROSION AND SEDIMENT CONTROL ACRE 140 $2,000 $280,000 Assume total area to be restored will require site erosion and sediment control. MANAGEMENT/ E&S CONTROLS / 12 BACKFILL AND REGRADING CY 225,900 $13 $2,936,700 Assumes entire restoration area with 1 foot of backfill material SITE RESTORATION Assume 6-inches of top soil needed to establish vegetative 13 TOPSOIL CY 0 $13 $0 stabilization over total closure by removal area. 14 SEED / FERTILIZE / MULCH ACRE 140 $3,767 $527,345 Assume total area of disturbance will be mulched, fertilized, and seeded. CONTINGENCY / CONTINGENCY / ENGINEERING SUPPORT ENGINEERING SUPPORT CONTINGENCY (25%) LS 1 $38,950,274 $38,950,274 ENGINEERING SUPPORT (DESIGN & CQA) LS 1 $5,000,000 $5,000,000 POST -CLOSURE 15 GROUNDWATER MONITORING ANNUAL 30 $493,000 $14,790,000 Annual groundwater monitoring costs for each CCR unit are based on POST -CLOSURE current groundwater monitoring system 16 OPERATIONS & MAINTENANCE (O&M) ANNUAL 30 $104,274 $3,128,220 Annual O&M costs are 3475.80/ac/yr. Based on Q3 2018 Post Closure Maintenance data CONTINGENCY / ENGINEERING COST CONTINGENCY / ENGINEERING CONTINGENCY (25%) LS 1 $4,479,555 $4,479,555 COST ENGINEERING COST (10%) LS 1 $2,239,778 $2,239,778 TOTAL $224,388,922 Preliminary Based on Information Available as of 11/08/2018 3 of 4 PROJECT PLANT NAME: CLOSURE TYPE: SHEET REV. NO. AUXO CCR IMPOUNDMENT CLOSURE ESTIMATES FOR DUKE ENERGY Mayo CCR Rule & CAMA Compliant Closure by Removal Assumptions 4 SUBJECT IMPOUNDMENT NAME: CLOSURE METHOD: AECOM JOB NO. ^ CALCULATION SHEET PreliminarV Promect Costs Sheets Ash Basin Closure by Removal 60432144 ACTIVITY CLOSURE OPTION: LAST UPDATED BY: DATE LAST MODIFIED: REVIEWED BY: Closure by Removal Assumptions 3 Claudia Prado 11/08/18 KK KEY ASSUMPTIONS The following key assumptions and limitations are associated with the project design, implementation and performance: 1 The cost estimates were prepared using 2018 dollars and do not include any escalation. 2 A 25% contingency has been included for this cost estimate. 3 The cost for Engineering Support (Design & CQA) for the Closure by Removal w/ Onsite Landfill option assumes $3.5M for design and $1.5M for CQA (assuming CQA cost is $25K/month for 5 years) 4 The unit rate costs are based on AECOM & Duke experience. 5 Removal of existing structures/piping includes the excavation and disposal of existing structures within the limits of waste and the bulkheading or grouting of existing outlet pipes that extend beyond the limits of waste. This will be performed during the closure by removal of an impoundment. 6 Pore water to be partially removed using combination of open pit dewatering and rim-ditch/wet stack methods until material can be excavated and stockpiled. Assume saturated ash must be dewatered down to 30% moisture content to haul and dispose on site. Assume treatment for TSS, pH, Arsenic & Selenium. Costs based on AECOM' estimates from Duke's dewatering projects. 7 Assumed all CCR material excavated must be stockpiled in close proximity to the impoundment to be decanted. After decanting, the material will be excavated, loaded, and hauled to the on -site landfill for disposal. 8 Costs for onsite landfill construction based on current construction and closure cost, as provided by Duke. 9 AECOM has assumed an over -excavation of 1 foot is necessary to achieve closure by removal conditions. 10 Groundwater monitoring costs for CCR unit is based on current groundwater monitoring system, as provided by Duke. 11 O&M costs provided by Duke. 12 Statements of Probable Construction Cost prepared by AECOM represent AECOM's judgment as a design professional familiar with the construction industry. It is recognized, however, that neither AECOM nor the Owner has control over the cost of labor, materials or equipment nor over the contractor's methods of determining the bid price or other competitive bidding, market, or negotiating conditions. Accordingly, AECOM cannot and does not warrant or represent that proposals, bids or actual construction costs will not vary from any statement of Probable Construction Cost or other estimates or evaluations prepared by AECOM. Preliminary Based on Information Available as of 11/08/2018 4 of 4 Attachment C Preliminary Scoring for Evaluation Closure Options Evaluation Ash Basin Closure - Master Site Name: Mayo Plant 11/13/2018 Threshold Criteria: All closure options must comply with the following threshold criteria based on Duke Energy Guiding Principles for Ash Basin Closure 1. Provide continued geotechnical stability meeting appropriate safety factors under applicable loading conditions 2. Provide flow capacity and erosion resistance during design storm and flooding conditions 3. Effectively mitigate groundwater impacts (in conjunction with GW remediation where present) 4. Comply with applicable state and federal regulations (e.g. North Carolina Coal Ash Management Act) Duke Energy = Option -Specific User Input 1 = Calculated Value Option Hybrid Closure Closure In Place Zero (0) values have been entered in "Calculated or User Selected Score" under Beneficial Reuse to prevent division by zero error text in calculated score cells. Revision O 1 3 1Cosure By Removal: Existing On -site Landfill I Environmental Protection and Impacts Weight: 30% I _ I _ • . • • . Refer to Modeled plume intersecting surface water Please refer to the Groundwater Sub -Scoring Document for details GW Sub -Scoring Sheet • • 23.8% 7.1% Modeled groundwater impact beyond the current Refer to Please refer to the Groundwater Sub -Scoring Document for details compliance boundary GW Sub -Scoring Sheet • • 23.8% 7.1% Refer to Modeled off -site groundwater impact Please refer to the Groundwater Sub -Scoring Document for details GW Sub -Scoring Sheet • • 23.8% 7.1% Relative rank based on visual interpretation of Refer to Please refer to the Groundwater Sub -Scoring Document for details modeled boron plume GW Sub -Scoring Sheet • • 13.6% 4.1% Air emissions off -site (based on miles driven round- Interpolation. Min value trip) scores 10. Max value scores 0. Truck miles driven Miles • • 0 2 10 10 0 5.0% 1.5% Air emissions on -site cubic yards of Interpolation. Min value excavation/movemen excavation/movement scores 10. Max value scores 0. t Cu.Yds • off • • off off 1,050,000 6,526,000 7 10 0 5.0% 1.5% Avoidance of greenfield disturbance Interpolation. Min value Disturbed acres of scores 10. Max value scores 0. greenfield Acres • • 4.5 30 10 0 0 5.0% 1.5% - • 2.75 2.44 2.55 Cost Weight: 35% _ _ • Closure Cost Interpolation. Min value Closure Cost USD •• of •$ 74,626,681 $ 199,751,368 7.2 10.0 0.0 80.0% 28.0% Operation Maintenance and Monitoring Cost scores 10. Max value scores 0. OM&M Cost USD • • • •: • • $ 24,6371553 $ 40,408,995 5.3 0.0 10.0 20.0% 7.0% . 2.39 2.80 0.70 Site Name: Mayo Plant 11/13/2018 Preliminary Scoring for Evaluation Closure Options Evaluation Ash Basin Closure - Master Duke Energy = Option -Specific User Input 1 = Calculated Value Zero (0) values have been entered in "Calculated or User Selected Score" under Beneficial Reuse to prevent division by zero error text in calculated score cells. Revision O Revision O Criteria for Evaluation of Closure Options Closure Options Evaluation Worksheet Ash Basin Closure - Master Programmatic Document Duke Energy Threshold Criteria: All closure options must comply with the following threshold criteria based on Duke Energy Guiding Principles for Ash Basin Closure 1. Provide continued geotechnical stability under applicable loading conditions and safety factors 2. Provide flow capacity and erosion resistance during design storm and flooding conditions 3. Effectively mitigate groundwater impacts 4. Comply with applicable state and federal regulations (e.g. North Carolina Coal Ash Management Act) Category Criterion Guidance Modeled plume intersecting surface water Please refer to the Groundwater Sub -Scoring Document for details Modeled groundwater impact beyond the current compliance boundary Please refer to the Groundwater Sub -Scoring Document for details Modeled off -site groundwater impact Please refer to the Groundwater Sub -Scoring Document for details Relative rank based on visual interpretation of modeled boron plume Please refer to the Groundwater Sub -Scoring Document for details Air emissions off -site (based on miles driven round-trip) Based on truck miles driven for hauling CCR and soil. Air emissions on -site cubic yards of excavation/movement Based on total cubic yards of cut and fill on site as a surrogate for gallons of fuel consumed. Avoidance of greenfield disturbance Refer to Scoring System and Required Input columns on scoring sheet. • Capital Cost From rough order -of -magnitude cost estimate or detailed cost estimate. Operation, Maintenance and Monitoring Cost Initiation Time From preliminary schedule for designing, permitting, bidding and constructing the option. Construction Duration Plan or potential for beneficial reuse of site Refer to Scoring System and Required Input columns on scoring sheet. Imported soil needs Refer to Scoring System and Required Input columns on scoring sheet. Beneficial reuse of CCR Refer to Scoring System and Required Input columns on scoring sheet. Transportation impact Based on truck miles driven for hauling CCR and CCR-contaminated soil. Noise impact due to on -site activity Based on proximity of neighbors to specific on -site work areas. View impact I Based on final height of storage facility and land uses within viewshed. Consider stormwater management, geotechnical, and dewatering ISubjective and relative comparison to other options Environmental Groundwater Sub -scoring Worksheet Closure Options Evaluation Duke Energy Station/Plant Name: Mayo Steam Electric Plant Scored .11/9/18 Evaluation Criteria: Criteria 1. Modeled Plume Intersecting Surface Water Modeled plume' does not intersect surface waters after 10 years 10 Modeled plume' does not intersect surface waters after 100 years 5 Modeled plume' does not intersect surface waters after 200 years 0 (Option 1) (Option 2) (Option 3) Closure By Removal: Existing Hybrid Closure Closure In Place Onsite Landfill Criteria 1 Score 10 10 10 Criteria 2. Groundwater Impact Beyond the current z Compliance Boundary SI - (-- Modeled plume' is within current compliance boundary after 10 years 10 Modeled plume' is within current compliance boundary after 100 years 5 Modeled plume' is within current compliance boundary after 200 years 0 (Option 1) (Option 2) (Option 3) Closure By Removal: Existing Hybrid Closure Closure In Place Onsite Landfill Criteria 2 Score 10 10 10 Criteria 3. Modeled Off-stte Impact '-- Modeled plume' does not go off -site 10 Modeled plume' is predicted to remain off -site after 100 years 5 Modeled plume' is predicted to remain off -site after 200 years 0 (Option 1) (Option 2) (Option 3) Closure By Removal: Existing Hybrid Closure Closure In Place Onsite Landfill Criteria 3 Score 10 10 10 Criteria 4. Relative rank based on visual interpretation of modeled boron plume Score Ranked #1 among the three Closure Options based on visual interpretation of modeled boron plume 10 Ranked #2 among the three Closure Options based on visual interpretation of modeled boron plume 5 Ranked #3 among the three Closure Options based on visual interpretation of modeled boron plume 0 (Option 1) (Option 2) (Option 3) Closure By Removal: Existing Hybrid Closure Closure In Place Onsite Landfill Criteria 4 Score 5 0 10 Note 1: Based on avaliable data at the time of scoring, the modeled plume considered boron at a concentration of 4,000 ug/I or greater; 4,000 Vg/L does not represent a remediation goal, however this concentration does represent the EPA Tap Water Regional Screening Level (RSL) in resident tapwater for boron. Note 2: The current compliance boundary is the compliance boundary found in the figure "Waste and Compliance Boundaries" provided to NCDEQ on 2/15/18 Environmental Groundwater Sub -scoring Worksheet Closure Options Evaluation Duke Energy Mayo Ash Basin Groundwater Sub -Scoring Document Justification (Option 1) (Option 2) (Option 3) Justification Notes Hybrid Closure Closure In Place Closure By Removal: Existing Onsite Landfill 1 Criteria 1. Modeled Plume Intersectinq Surface 10 is 10 Based on the predictive model for the year 2027, found in the November Based on the predictive model for the year 2027, found in the Based on the predictive model for the year 2027, found in the November Water 2018 Preliminary Updated Groundwater Flow and Transport Modeling November 2018 Preliminary Updated Groundwater Flow and 2018 Preliminary Updated Groundwater Flow and Transport Modeling Report for Mayo Steam Electric Plant, simulated boron concentrations for Transport Modeling Report for Mayo Steam Electric Plant, simulated Report for Mayo Steam Electric Plant, simulated boron concentrations for the Hybrid Closure scenario with natural attenuation did not show boron boron concentrations for the Closure -In -Place scenario with natural the Closure By Removal scenario with natural attenuation did not show of 4,000 ppb or greater intercepting surface water bodies. attenuation did not show boron of 4,000 ppb or greater intercepting boron of 4,000 ppb or greater intercepting surface water bodies. surface water bodies. Criteria 2. Groundwater Impact Beyond the Current 10 10 Compliance Boundary Based on the predictive model summary of concentrations over time, Based on the predictive model summary of concentrations over time, Based on the predictive model summary of concentrations over time, lboron model found in the November 2018 Preliminary Updated Groundwater found in the November 2018 Preliminary Updated Groundwater Flow found in the November 2018 Preliminary Updated Groundwater Flow and Flow and Transport Modeling Report for Mayo Steam Electric Plant, and Transport Modeling Report for Mayo Steam Electric Plant, Transport Modeling Report for Mayo Steam Electric Plant, simulated simulated boron concentrations for theHybrid Closure scenario with simulated boron concentrations for the Closure -In -Place scenario with concentrations for the Closure By Removalscenario with natural natural attenuation did not show boron of 4,000 ppb or greater beyond natural attenuation did not show boron of 4,000 ppb or greater attenuation did not show boron of 4,000 ppb or greater beyond the the current (2018) compliance boundary (Point 1). beyond the current (2018) compliance boundary (Point 1). current (2018) compliance boundary (Point 1). Criteria 3. Modeled Off -site Impact Based on the predictive model for the year 2017 and beyond, found in the Based on the predictive model for the year 2017 and beyond, found in Based on the predictive model for the year 2017 and beyond, found in the November 2018 Preliminary Updated Groundwater Flow and Transport the November 2018 Preliminary Updated Groundwater Flow and November 2018 Preliminary Updated Groundwater Flow and Transport Modeling Report for Mayo Steam Electric Plant, simulated boron Transport Modeling Report for Mayo Steam Electric Plant, simulated Modeling Report for Mayo Steam Electric Plant, simulated boron concentrations for the Hybrid Closure scenario with natural attenuation boron concentrations for the Closure -In -Place scenario with natural concentrations for the Closure By Removal scenario with natural did not show boron of 4,000 ppb or greater off of Duke Energy property. attenuation did not show boron of 4,000 ppb or greater off of Duke attenuation did not show boron of 4,000 ppb or greater off of Duke Energy property. Energy property. Criteria 4. Relative rank based on visual s o 1 interpretation of modeled boron plume Based on a review of boron concentrations found in the November 2018 a review of boron concentrations found in the November r8e Based on a review of boron concentrations found in the November 2018 Preliminary Updated Groundwater Flow and Transport Modeling Report minary Updated Groundwater Flow and Transport Modeling Preliminary Updated Groundwater Flow and Transport Modeling Report for Mayo Steam Electric Plant, this scenario is marginally better than Mayo Steam Electric Plant, this scenario is not marginally for Mayo Steam Electric Plant, this scenario is marginally better than Option 2 Closure -in -Place. n Option 1 Hybrid Closure or Options 3 Closure By Removal. Option 1 Hybrid Closure and Option 2 Close -In -Place. Notes: 1. Based on avaliable data at the time of scoring, the modeled plume considered boron at a concentration of 4,000 ug/I or greater; 4,000 µg/L does not represent a remediation goal, however this concentration does represent the EPA Tap Water Regional Screening Level (RSL) in resident tapwater for boron. 2. The current compliance boundary, as of 10/9/18, was used for all scenarios for criteria 2.