NC0001422_2018 Sutton Final Excavation Plan_20181204

L.V. Sutton Electric Plant
Coal Ash Excavation Plan
-( DUKE
E ENERGY..
2018 Update

Table of Contents
I.
Statement of Purpose...................................................................................................................1
II.
General Facility Description.........................................................................................................2
III.
Project Charter...............................................................................................................................3
IV.
Critical Milestone Dates................................................................................................................6
V.
Erosion and Sediment Control Plan...........................................................................................
7
VI.
Dewatering Plan............................................................................................................................
8
VII.
Location(s) for Removed Ash......................................................................................................8
Vill.
Transportation Plan.......................................................................................................................9
IX.
Environmental and Dam Safety Permitting Plan......................................................................
9
X.
Contracting Strategy...................................................................................................................11
Xl.
Environmental, Health, and Safety Plan..................................................................................11
XII.
Communications Plan.................................................................................................................12
XIII.
Glossary........................................................................................................................................12
XIV.
Reference Documents................................................................................................................14
Exhibits
Exhibit A: Excavation Soil Sampling Plan

Statement of Purpose
Duke Energy Progress, LLC (Duke Energy, or the Company) is required by Part II, Section
3(b) of the Coal Ash Management Act of 2014 (Session Law 2014-122) (Coal Ash Act or
Act) to close, in accordance with Part II, Section 3(c), the coal combustion residuals
(CCR) surface impoundments located at the L.V. Sutton Electric Plant (Sutton or Plant),
National Pollutant Discharge Elimination System (NPDES) Permit No. NC0001422, in
New Hanover County, as soon as practicable, but not later than August 1, 2019.
This Coal Ash Excavation Plan (Plan) represents activities to satisfy the requirements
outlined in Part ll, Sections 3(b) and 3(c), Subparagraphs 1 and 2 of the Act and the
requests set forth in the North Carolina Department of Environmental Quality's (NCDEQ)
August 13, 2014 letter titled "Request for Coal Ash Excavation Plans for Asheville Steam
Electric Generating Plant, Dan River Combined Cycle Station, Riverbend Steam Station,
L.V. Sutton Electric Plant" (NCDEQ Letter). The NCDEQ Letter specifically requests that
the Plan include 1) soil and sediment erosion control measures, 2) dewatering, and 3) the
proposed location(s) of the removed ash. These requirements are discussed in this
updated Plan.
This is a revision of the Coal Ash Excavation Plan dated December 1, 2017, which covers
the subsequent phase of ash basin excavation activities, including dewatering, site
preparation, landfill operation, ash basin preparation, and ash removal from the basins at
Sutton. The Plan has been updated and submitted to NCDEQ annually, but no further
updates will be prepared upon completion of excavation of the ash basins in accordance
with the applicable CAMA provisions.
The Plan covers some of the work required by Part ll, Sections 3(b) and 3(c) of the Coal
Ash Act. The Act requires the closure of the ash basins as soon as practicable, but no
later than August 1, 2019. However, the Act contains no requirement for the submittal of
an excavation plan of the kind presented here. Thus, while the formulation, submittal,
and review of this Plan will assist in Duke Energy's work to close the ash basins, its
ultimate approval is an action not specifically required by statutory, regulatory, or other
applicable authority.
The precise scope of work in excavating the ash basins has been determined by
applicable laws, rules, permits, and approvals that control the activities to be performed
under the Plan. There are several external and internal factors that could potentially affect
the precise scope of the work to be performed under the Plan. As a consequence, neither
the submittal of this Plan nor its acknowledgement by NCDEQ should be taken as
requiring actions different from such applicable requirements. Duke Energy submits this
Plan to NCDEQ based on the understanding that it may be necessary to take actions that
1: Sutton

deviate from the Plan in the future, and the Company reserves the right to make such
changes.
General Facility Description
Duke Energy's Coal Combustion Residuals Removal Verification Sutton is located in New
Hanover County near Wilmington, NC, situated between the Cape Fear River to the west
and the Northeast Cape Fear River to the east. Sutton was a three -unit, 575 megawatt
(MW) coal-fired power plant. The Plant operated from 1954 until retirement of the coal-
fired units in November 2013. Upon retirement of the coal-fired units, a new 625 MW
gas -fired unit began operations.
There are two CCR basins —the 1971 and 1984 Basins —containing fly ash, bottom ash,
boiler slag, stormwater, ash sluice water, coal pile runoff, and low volume wastewater.
One other area that contains CCR material is the Lay of Land Area (LOLA). The LOLA
consists mostly of bottom ash and soil. The Sutton facility also includes a cooling lake
(also known as "Sutton Lake"), which does not contain CCR. Sutton Lake is accessible
to the general public and is used for recreational purposes. Sutton Lake was classified
as Waters of the State on November 5, 2014.
Procedure (Removal Verification Procedure) will be used to verify that primary source ash
has been removed from the basin. Subsequent to removal of the ash pursuant to the
Removal Verification Procedure, Duke Energy will implement its Excavation Soil
Sampling Plan (ESSP), which was developed for the purpose of meeting the applicable
performance standard. Although not required under CAMA, in November 2016, NCDEQ
sent Coal Combustion Residuals Surface Impoundment Closure Guidelines for Protection
of Groundwater to Duke Energy instructing the Company to submit the ESSP to NCDEQ
as part of the site's excavation plan. In accordance with this directive, a copy of the ESSP
for the 1984 Basin is attached as Exhibit "A" to this Plana
1971 Ash Basin
The 1971 Basin was operated from 1971 to 1985. It was opened again in 2011 for
temporary use during repair work and ash removal activities. The 1971 Basin is unlined
and was initially constructed with a crest elevation of 18 feet mean sea level (msl), which
was raised in 1983 to 26 msl. The 1971 Basin initially contained approximately 3.8 million
tons of CCR material. The southern basin dikes of the 1971 Basin contain ash and will
be excavated as part of final closure.
1 The ESSP for the 1971 Basin was not updated and, therefore, is not attached hereto.
2: Sutton

1984 Ash Basin
The 1984 Basin was operated from 1984 to 2013. The 1984 Basin was constructed with
a 12-inch thick clay liner at the basin bottom, which extends along the side slopes where
it is protected by a 2-foot thick sand layer. The 1984 Basin crest elevation is 34 feet msl.
In 2006, an Interior Containment Area (ICA) was constructed within the 1984 Basin with
a crest elevation of 42 feet msl. The 1984 Ash Basin initially contained approximately 2.8
million tons of CCR material.
LOLA
The LOLA is located between the discharge canal and the coal pile. It is believed that
the presence of CCR in this area may have been due to Plant operations between
approximately 1954 and 1972. A small portion adjacent to the coal pile storage area was
used to locate fuel oil storage tanks. This area contains approximately 686,000 tons of
CCR and soil mixture at depths of 0 to 15 feet.
Current Operating Permit Details
The Cooling Basin, 1971 Basin, and 1984 Basin are operated under NPDES Permit No.
NC0001422 to regulate effluent discharges to the Cape Fear River. Additionally, the
dams of the Cooling Basin, 1971 Basin, and 1984 Basin are listed under the NCDEQ
Dam Safety Program. The dam identification numbers for the Cooling Basin, 1971 Basin,
and 1984 Basin are NEWHA-003, NEWHA-004, and NEWHA-005, respectively. The
dam inventory lists the Cooling Basin and 1971 dams as exempt. The 1984 dam is listed
as impounding, hence regulated. In 2014, these dams were re -rated as high hazard by
NCDEQ. The 2006 Interior Containment Area (ICA) constructed within the 1984 Basin
was permitted and used as a "basin within a basin," where an interior dam was
constructed on top of the CCR within the basin; sluiced CCR was excavated from rim
ditches, placed within the interior basin, and compacted to heights that are above the
exterior basin dams. This operation was discontinued before reaching the permitted final
grades when the Plant was shut down in November 2013.
Project Charter
Dewatering of the ash basins and the removal of ash from the site is being performed in
project phases. As of November 1, 2018, approximately 4.56 million tons of ash have
been excavated. Approximately 2.0 million tons were moved to an off -site structural fill
and the remainder to the on -site landfill. The project has completed Phase I and is now
implementing Phase II.
The following items in Phase I have been completed or initiated:
1. Developed and installed approved erosion and sediment control measures.
3: Sutton

2. Developed and constructed the infrastructure to remove and transport the
ash.
3. Completed the installation of a wastewater treatment system to support
dewatering of the ash basins.
4. Began dewatering of the ash basins.
5. Completed the work scope and bid event to support ash basin closure.
6. Initiated and completed the removal of the first 2 million tons of ash from the
Sutton site.
7. Development of option(s) for proposed ash disposal or beneficial use
locations.
8. Rerouted approximately two miles of the Sutton Lake public boat ramp
access road.
9. Initiated development of the on -site landfill.
10.Obtained permit to construct the on -site landfill.
The Sutton NPDES wastewater permit was issued to Duke Energy in December 2015 to
allow for removal of bulk free water. The removal of the bulk free water was completed
on January 28, 2016. After the required wastewater treatment facility was installed and
operational, removal and treatment of the basin interstitial water commenced in June
2016. Based on revisions to the NPDES permit, the stormwater from the fossil plant has
been rerouted and no longer discharges into the basins. Therefore, rainwater is the only
inflow into the basins. Basin dewatering is currently being implemented on an as -needed
basis to maintain the basins' clear water ponds as low as reasonably possible.
Under this Plan, the Company began removing ash to an off -site location while
simultaneously developing an on -site landfill in order to meet the closure requirement
mandated in the Coal Ash Act. The Sutton on -site landfill construction permit was
received on September 22, 2016. This date was significantly later than originally planned,
resulting from delays with NCDEQ's environmental justice review.
The construction of the on -site landfill commenced early in the fourth quarter of 2016.
The first permit to operate for a completed landfill cell was obtained on July 6, 2017 from
the NC Division of Waste Management. Phase I CCR excavation and transport off -site
completed on June 27, 2017, and the Phase 11 CCR excavation and placement in the on -
site landfill commenced on July 7, 2017. Landfill construction was completed March 26,
2018. Currently four cells are in operation. Two of the operating cells are scheduled for
closure in the first and second quarters of 2019.
The Sutton site was significantly impacted by Hurricane Florence in September 2018.
Normal operation was suspended for storm preparation beginning September 10, 2018,
and ash excavation and transport was not resumed until October 1, 2018. Suspended
operations resulted in the loss of approximately 99,500 tons of production during that
period.
4: Sutton

Due to the late start of landfill construction, combined with the impacts of both Hurricane
Matthew in 2016 and Hurricane Florence in 2018, the projected completion date has
moved beyond the mandatory closure date of August 1, 2019. Schedule recovery
opportunities are and will continue to be evaluated and implemented.
Pursuant to N.C.G.S. § 130A-309.215, on November 16, 2018, Duke Energy submitted
to the North Carolina Department of Environmental Quality an application for a variance
to extend by six months (i.e., until February 1, 2020) the CAMA closure deadline
applicable to the 1971 and 1984 Ash Basins at Sutton, because, despite Duke Energy's
application of best available technology found to be economically reasonable, compliance
with the applicable CAMA deadline cannot be achieved.
The following items in Phase II have been completed or initiated:
1. Received NCDEQ Permits to Operate (PTO) landfill Cells 5, 6, 7, and 8.
Completed construction of the on -site landfill.
2. Continued the excavation and transport of Phase II ash to the on -site landfill.
3. Began on -site treatment of landfill leachate wastewater through the on -site
wastewater treatment facility.
4. Received NCDEQ permits to decommission the 1971 Basin dikes and
outfall structure.
5. Received NCDEQ permits to decommission the 1984 Basin dikes and
outfall structure.
6. Commenced the excavation of CCR and the removal of the 1971 Basin
southern berm.
7. Commenced operation of the on -site landfill.
8. Performed pump and haul operations of landfill leachate wastewater to a
local Publically Owned Treatment Works (POTW) facility
9. Completed the construction of 4,600 feet of sheet pile wall to support future
dike and berm removal.
10. Relocated several thousand feet of Piedmont Natural Gas gas line that was
in operation through the LOLA.
11. Completed construction of the second phase of the wastewater treatment
facility to support basin dewatering and landfill leachate treatment.
12. Completed the installation of the on -site extraction well system.
13. Completed the relocation of several miles of outfall discharge piping to
support operation of the extraction well system and future dike excavation.
Project Charter Objectives
Phase II Objectives
1. Continue to dewater ash basins, pumping water through the on -site
wastewater treatment facility.
5: Sutton

2. Submit and obtain any necessary permits for Phase II activities.
3. Excavate and transport ash from the 1971 and 1984 Ash Basins.
4. Construct, operate, and close cells for the on -site landfill.
5. Gain knowledge and opportunities for program improvement that can be
applied to the subsequent phase(s).
Inactive Ash Areas Objectives
1. Submit and obtain any necessary permits for activities.
2. Excavate and transport ash from the LOLA to commence in 2019.
3. Operate and close cells for the on -site landfill.
4. Gain knowledge and opportunities for program improvement.
Project Charter Scope
Phase II Scope
1. Submit and obtain applicable permits.
2. Install and maintain required site haul roads.
3. Continue dewatering of the 1984 and 1971 Basins and treat landfill leachate
water using the on -site wastewater treatment facility.
4. Commence landfill operations.
5. Continue to excavate and transport approximately an additional 2.1 million
tons of material from the 1971 and 1984 Ash Basins to an approved on -site
landfill.
6. Continue infrastructure activities that are required to support the future
excavation of the basins and the LOLA.
7. Complete closure activities for the 1971 and 1984 Ash Basins.
Inactive Ash Areas Scope
1. Excavate and transport the approximately 686,000 tons of material from the
LOLA to the on -site landfill.
2. Reinforce the LOLA western dike.
3. The LOLA will be closed as part of overall site closure, but is not subject to
Part II, Sections 3(b) and 3(c) of the Coal Ash Act.
4. Operate and close cells for the on -site landfill.
Critical Milestone Dates
Critical milestones within the Plan are summarized in the table below.
MILESTONES•
LATER THAN DATE
Submit Excavation Plan
November 15, 2014 Completed
November 13, 2014
Complete Comprehensive
November 30, 2014 Completed
Engineering Review
November 30, 2014
6: Sutton

MILESTONES
NO LATER DATE
STATUS
Excavation Plan Acknowledgement
February 17, 2015
Completed
February 2, 2015
Submit Updated Excavation Plan to
November 15, 2015
Completed
NCDEQ
November 13, 2015
Commence Work — Ash Removal
Final permit approval
Completed
+ 14 Days
October 30, 2015
Receive NPDES Wastewater
December 11, 2015
Completed
Permit
December 2015
Delayed due to NCDEQ
Receive Permit -to -Construct
February 29, 2016
environmental justice
On -site Landfill
review; completed
September 22, 2016
Submit Updated Excavation Plan to
December 31, 2016
Completed
NCDEQ
December 21, 2016
Receive permit for basin dam
August 1, 2017
Completed
decommissioningDecember
7, 2017
Receive Permit -to -Operate
August 31, 2017
Completed
On -Site Landfill, Cell 3
July 6, 2017
Submit Updated Excavation Plan to
December 31, 2017
Completed
NCDEQ
December 1, 2017
Eliminate Stormwater Discharge
December 31, 2018
Completed
into Impoundments
July 2016
Challenged due to
1971 and 1984 Basins closed
permitting delays and
pursuant to Part II, Sections 3.(b)
August 1, 2019
severe weather, including
and 3.(c) of the Coal Ash Act
Hurricane Matthew in 2016
and Hurricane Florence
in 2018
Excavate CCR From the Lay of the
June 20, 2020
On Track
Land Area LOLA
Submit Updated Excavation Plan
December 31, Annually
On Track
V. Erosion and Sediment Control Plan
The project currently has one active Erosion and Sediment Control (E&SC) plan: Site
Wide Clearing Activities (NEWHA-2016-025). Additional applications are expected to be
submitted during this phase as the project planning develops. Modifications from E&SC
plans for subsequent phase(s) will be approved by NCDEQ prior to installation and
initiation of subsequent phase work. The approved contractor will install the E&SC
measures indicated in the plan. All control measures will be maintained throughout the
project in accordance with the E&SC plans and permits. When possible, portions of the
E&SC plan will be closed out at the approval of NCDEQ as areas become stabilized.
7: Sutton

VI. Dewatering Plan
The Sutton ash basins will be dewatered to facilitate the removal of ash and to mitigate
risk. Engineering analysis has shown that lowering the water below the level of ash within
each basin does not improve the factor of safety against failure of the associated dam;
therefore, removal of entrapped water is not required.
An engineered Dewatering Plan for Sutton was developed, and dewatering has been in
progress since October 2015. Interstitial basin dewatering will likely continue throughout
the life of the project. Pumping is managed to control the water level as low as reasonably
possible.
The current plan calls for the removal of ash from the 1971 Basin through different
methods than from the 1984 Basin and the LOLA. Heavy equipment operation directly
on top of the ash in the basin has been deemed impractical due to high groundwater
recharge rates. Therefore, removal of the ash from the 1971 Basin incorporates hydraulic
dredging and dewatering of the resulting dredged material. The water generated during
ash removal will be directed back to the 1971 Basin.
Interstitial dewatering and landfill leachate wastewater treatment will be performed by the
on -site wastewater treatment facility in accordance with the NPDES permit.
ocation(s) for Removed Ash
Ash removed from the site was transported by the contractor to permitted facilities. The
ash storage location has been managed and maintained to ensure environmental
compliance with applicable rules and regulations.
UISPUSai OIres
Brickhaven Structural Fill was the primary disposal location for the first two million tons of
CCR material that was excavated at Sutton, and the on -site landfill located at Sutton is
the primary disposal location for the remaining CCR material.
Brickhaven Structural Fill
The Brickhaven Structural Fill is located at the Brickhaven Mine near the City of Moncure
in Chatham County, NC. It resides on approximately 299 acres. Ash was transported
and beneficially used as fill material for a structural fill project at the reclaimed mine.
The final rail shipment of ash to the Brickhaven Structural Fill from Sutton occurred on
June 27, 2017.
Sutton On -Site Landfill
Ash excavated from the basins and LOLA will be disposed of in the on -site CCR
landfill. The project includes the installation of a liner and leachate collection system for
the landfill.
8: Sutton

Vill. Transportation Plan
Ash is currently being transported from the basins via off -road articulated dump truck to
the on -site landfill. Truck loading operations is being conducted with a crew working
typically 10-12 hours per day, five to six days per week.
IX. Environmental and Dam Safety Permitting Plan
Excavation of ash creates potential for stormwater impacts. Since Sutton has no point
source discharges consisting solely of industrial stormwater, NCDEQ determined that an
individual industrial stormwater permit is not necessary. Instead, NCDEQ has included
internal stormwater outfalls and the requirement to develop a stormwater pollution
prevention plan as a requirement of the NPDES wastewater permit. Future modifications
to the permit/plan will be managed as necessary.
NCDEQ has determined that removal of dry ash from the Sutton ash basins can be
regulated via the Construction Stormwater General Permit. Ash removal activities were
originally permitted when NC DEMLR approved erosion control plan NEWHA-2016-023.
These activities are now encompassed in NEWHA-2016-025.
NCDEQ determined that dewatering activities, including free water removal, required a
NPDES wastewater permit modification. Based on this requirement, the Company
applied for a permit modification to specifically allow decanting of free water and
dewatering of interstitial water. Application was made in January 2015. The Company
received the modified NPDES permit in December 2015 for a term of one year. On
October 1, 2017, the permit was re -issued and included the authorization to treat and
discharge landfill leachate through the on -site wastewater treatment plant.
There are no jurisdictional wetlands/streams associated with the removal of ash from the
1984 and 1971 Ash Basins during Phase I and 11. The current and future wetland/stream
impacts and jurisdictional determinations will be managed through the United States Army
Corps of Engineers with particular attention paid to the difference between jurisdictional
wetlands/streams under Section 404 and those arising from Section 401 waters. Any
Section 404 individual permitting will require Section 401 Water Quality Certification by
NCDEQ. Wetlands stream impacts have been permitted for the construction of the on -
site landfill. Sutton ash is a non -hazardous material.
Subsequent phase(s) will include dewatering and continued excavation and removal of
ash from the 1984 and 1971 Basins and the LOLA. Subsequent phase(s) also include(s)
the continued construction of the on -site landfill.
All necessary Dam Safety approvals will be or have been obtained to cover activities on
or around jurisdictional dams. Breaching of the dams will require Dam Safety approval.
Any impacted wells or piezometers will be properly abandoned in accordance with
9: Sutton

NCDEQ requirements. Fugitive dust will be managed to mitigate impacts to neighboring
areas.
Permit Matrix
PERMIT
RECEIVED DATE
TARGETMEDIA D.
Major Modification to allow basin
None
dewaterin : December 2015 R
A NPDES permit revision
was required to authorize
the treatment and discharge
of landfill leachate. The
target date was originally
NPDES Wastewater
January 2017, but was
Permit — Major
Major Modification to allow the
affected by shifts in Agency
Modification
discharge of landfill leachate:
priorities. The draft permit
October 1, 2017 (R)
was posted for public
comment in June 2017 and
again in August 2017. The
Water
approved NPDES
modification was received
and went into effect on
October 1, 2017.
Four cells in the new Sutton
landfill had identified
Jurisdictional
jurisdictional wetland/stream
Wetland and Stream
impacts in Phase I.
Impacts
September 2016 (R)
Wetland permits have been
404 Permitting and
received. No impacts to
401 WQC
jurisdictional wetlands
requiring additional
permitting have been
identified for Phase II.
Dam
Original target date was
Dam Safety
Decommissioning
February 7, 2018 (R)
March, 2017. Permit is
required to support
Request Approval
excavation plan.
Site Suitability obtained for
Sutton landfill. Previous
Site Suitability
date was March 31, 2015.
Report
July 2, 2015 (R)
Change was related to
additional requirements to
complete the report prior to
Waste
submittal.
Permit -to -Construct
September 2016 (R)
The original target date was
Landfill
February 23, 2016.
10: Sutton

PERMITMEDIA
RECEIVED DATE (R)
COMMENTS
TARGETD.
Cell 3: July 6, 2017 (R)
Cell 4: August 25, 2017 (R)
The original project target
date for Cell 3 was
Permit -to -Operate
Cell 5: December 7, 2017 (R)
November 23, 2016. Delay
Landfill
was due to NCDEQ's
Cell 6: February 7, 2018 (R)
environmental justice review
process.
Cells 7 & 8: March 16, 2018 R
Site Site -Specific
Nuisance/Noise/Od
Other
orOther
Requirements
Requirements,
N/A
None identified.
including DOT and
FERC
Requirements
X. Contracting Strategy
The Ash Management Program strategy is to engage multiple contractors, drive
competition, create system -wide innovation, and develop a collection of best practices.
Duke Energy has engaged contractor(s), who are experienced in coal ash excavation,
transportation, and disposal, and continues to evaluate other potential contractors. The
Company provides in-depth oversight, coordination, and monitoring of the contractors to
ensure the work is performed appropriately. Duke Energy's core values include safety,
quality, and protection of the environment, which are incorporated into our contracts. The
Company continues to evaluate alternate approaches, methods, and contracting
solutions and will adjust its strategy, as necessary.
XI. Environmental, Health, and Safety Plan
The Company is committed to the health, safety, and welfare of employees, contractors,
and the public, and to protecting the environment and natural resources. During all
phases of the project work, the Company and its contractors will follow the Duke Energy
Safe Work Practices Manual, the Environmental, Health, and Safety supplement
document, and any additional requirements. Occupational health and safety expectations
include oversight and continuous improvement throughout the project. The project
includes comprehensive environmental, health, and safety plans encompassing all
aspects of the project work. In addition to adhering to all applicable environmental, health,
and safety rules and regulations, Duke Energy and its contractors will focus on ensuring
the safety of the public and protection of the environment during each phase of the project.
11: Sutton

XII, Communications Plan
The project team has coordinated with Duke Energy's Corporate Communications
Department to develop a comprehensive external communications plan tailored to the
specific needs of each phase of the project. Many different external stakeholders,
including neighbors, government officials, and media have an interest in this project. The
Company is committed to providing information by proactively communicating about the
project activities to potentially affected parties and responding to inquiries in a timely
manner.
XIII. Glossary
Ash Basin
Synonymous with Coal Combustion Residual Impoundment. A topographic
depression, excavation, or dammed area that is primarily formed from
earthen materials; without a base liner approved for use by Article 9 of
Chapter 130A of the General Statutes or rules adopted thereunder for a
combustion products landfill or coal combustion residuals landfill, industrial
landfill, or municipal solid waste landfill; and an area that is designed to
hold accumulated coal combustion residuals in the form of liquid wastes,
wastes containing free liquids, or sludge, and that is not backfilled or
otherwise covered during periods of deposition.
Ash Stack
A dry ash storage feature external to the ash basin
Beneficial
Projects promoting public health and environmental protection, offering
and
equivalent success relative to other alternatives, and preserving natural
Beneficial
Use
resources
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
Bottom Ash
walls. Bottom Ash falls through open grates to an ash hopper at the bottom
of the furnace.
Water above the ash contained in the ash basin; synonymous with free
Bulk Water
water
Coal Ash
Plan required by NCDEQ letter dated August 13, 2014, including a
Excavation
schedule for soil and sediment erosion control measures, dewatering, and
Plan
the proposed location of the removed ash
Coal Ash
Management
North Carolina Session Law 2014-122
Act of 2014
12: Sutton

NUNNDEFINITION
Coal
Combustion
Residuals, including fly ash, bottom ash, boiler slag, mill rejects, and flue
Residuals
gas desulfurization residue produced by a coal-fired generating unit
(CCR)
Dewatering
The act of removing bulk and entrapped water from the ash basin
Dewatering
Engineered plan and the associated process steps necessary to dewater
Plan
an ash basin
Duke Energy
Safe Work
Practices
Document detailing the Duke Energy safety guidelines
Manual
Engineer of
Duke Energy or third -party contracted engineer responsible for final
Record
verification of specific plan actions and documents
Entrapped
Water below the ash surface, which creates hydrostatic pressure on the
Water
dam
Excavation
Tasks and work performed related to the planning, engineering, and
Activities
excavation of ash from an ash basin
Excavation
Refer to Coal Ash Excavation Plan
Plan
Factor of
In reference to dam safety, the ratio of the forces or moments resisting
mass movement to the forces or moments tending to produce mass
Safety
movement
Water above the ash contained in the ash basin; synonymous with bulk free
Free Water
water
Very fine, powdery material, composed mostly of silica with nearly all
particles spherical in shape, which is a product of burning finely ground coal
Fly Ash
in a boiler to produce electricity and is removed from the plant exhaust
gases by air emission control devices.
LOLA
Lay of Land Area
NPDES
National Pollutant Discharge Elimination System
NPDES
A permit that regulates the direct discharge of wastewater to surface waters
Permit
13: Sutton

DEFINITION 07
Permitting
Federal, state, county, or local government authorizing document
XIV. Reference Documents
1
NCDEQ Letter to Duke Energy, Request for Excavation
August 13, 2014
Plans
2
Coal Ash Management Act of 2014
September 20, 2014
3
NCDEQ Letter from Jeff Poupart, Water Quality Permitting
July 20, 2016
Section Chief, to Duke Energy regarding decant
14: Sutton