Elnitski to Skvarla - Excavation Plans for four priority sites_20141113

John Elnitsky
Senior Vice President
Ash Basin Strategy
DUKE
ENERGY®
November 13, 2014
John E. Skvarla, III
Secretary
North Carolina Department of Environment & Natural Resources
Mailing: 1636 Mail Service Center
217 W. Jones Street
Raleigh, NC 27699-1636
Dear Secretary Skvarla:
550 South Tryon Street
DEC 22C
Charlotte, NC 28202
Mailing Address:
P.O. Box 1321
Charlotte, NC 28201
0:704.382.4371
Once Of the s/Dretp
ry
NOV 13 2014
bapamnslv
110votur01t5n lronme
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As requested in the letter from the North Carolina Department of Environment and Natural Resources
(NC DENR) to Duke Energy dated August 13, 2014, Duke Energy is submitting the attached Coal Ash
Excavation Plans for Riverbend Steam Station, Dan River Steam Station, L.V. Sutton Electric Plant, and
Asheville Steam Electric Generating Plant.
In general, these Excavation Plans cover the first 12 — 18 months (Phase 1) of ash basin excavation
activities, including site preparation, ash basin preparation, the initiation of basin dewatering, and ash
removal from the basins. These plans will normally be updated and submitted to NC DENR annually or
earlier as required by Subsequent Phase(s). These plans also represent the activities necessary to
satisfy the requirements outlined in Sections 3(b) and 3(c) Subparagraph 1 &2 of the Coal Ash
Management Act of 2014.
Each Excavation Plan details what Duke Energy considers to be the necessary permits to begin work or
facilitate subsequent phases of work. Integral to the success of the Excavation Plans is the timely receipt
of permits, including industrial stormwater, National Pollutant Discharge Elimination System, landfill,
structural fill and mine reclamation permits where applicable.
The objective of these excavation efforts is to achieve ash basin closure in a reasonable, prudent, and
cost effective manner. The initial phases of these Excavation Plans will incorporate off -site transportation
and disposition options, which are generally more costly than the utilization of on -site, lined landfills. Initial
use of offsite solutions is necessary for the Company to meet the deadlines prescribed in the Coal Ash
Management Act of 2014 for High Priority sites. Timely receipt of landfill permits will enable the Company
to expeditiously transition from more costly off -site storage locations at sites where these landfills are
practical.
We are prepared to implement these Excavation Plans upon receipt of NC DENR written approval of
these plans and necessary permits.
7nE_InitskP'..i',.",

Asheville Steam Electric Generating Plant
Coal Ash Exca►►ation Plan
(� DUKE
�, ENERGY

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
Table of Contents
I.
Statement of Purpose...................................................................................................................2
II.
General Facility Description.........................................................................................................3
III.
Project Charter...............................................................................................................................6
IV.
Critical Milestone Dates................................................................................................................8
V.
Level 1 Schedule...........................................................................................................................9
VI.
Erosion and Sedimentation Control Plan................................................................................10
VII.
Dewatering Plan..........................................................................................................................10
Vill.
Proposed Location(s) for Removed Ash..................................................................................11
IX.
Transportation Plan.....................................................................................................................12
X.
Environmental Permitting Plan..................................................................................................12
XI.
Contracting Strategy...................................................................................................................15
XII.
Environmental, Health, and Safety Plan..................................................................................15
XIII.
Communications Plan.................................................................................................................16
XIV.
Glossary........................................................................................................................................17
XV.
Reference Documents................................................................................................................19
1

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
I. Statement of Purpose
Duke Energy (Company) is required by Section 3(b) of the Coal Ash Management Act
of 2014 to close in accordance of Section 3(c) the coal combustion residuals (CCR)
surface impoundments located at the Asheville Steam Electric Generating Plant
Buncombe County (Asheville or Plant) as soon as practicable, but not later than August
1, 2019.
This Coal Ash Excavation Plan (Plan) for Asheville documents key activities as
requested by North Carolina Department of Environment and Natural Resources (NC
DENR), Division of Water Resources (DWR) stated in a letter to Duke Energy dated
August 13th, 2014 (NC DENR Letter). The Plan represents Phase I and subsequent
phase(s) to satisfy the requirements outlined in Section 3(b) and 3(c) Subparagraphs
1 &2 of the Coal Ash Management Act of 2014.
In general, Phase 1 of the Plan addresses the first 12 —18 months of ash basin
excavation activities. For Subsequent Phase(s), this document will be revised for any
modifications to the Plan. The Plan will be updated and submitted to NC DENR at least
annually or earlier as required by Subsequent Phases.
The NC DENR Letter specifically requests that the Plan includes 1) a schedule for soil
and sedimentation erosion control measures, 2) dewatering, and 3) the proposed
location(s) of the removed ash. These requirements are found in Section V. Level 1
Schedule, Section VI. Erosion and Sedimentation Control Plan, Section VII.
Dewatering Plan, and Section VIII. Proposed Location(s) for Removed Ash.
The Plan covers some of the work required by Sections 3(b) and 3(c) of the Coal Ash
Management Act of 2014 (Session Law 2014-122) (Coal Ash Act, or 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. Additionally, it may become necessary for the Company to modify the Plan to
address other legal requirements or factors that develop during ash basin excavation.
Any changes will be included in annual updates to the Plan that Duke Energy will submit
to NC DENR.
The precise scope of work in excavating the ash basins will be determined by applicable
laws, rules, permits, and approvals that control the activities to be performed under the
Plan. For example, the United States Environmental Protection Agency (EPA) is
considering issuing rules regarding the management of coal ash (proposed EPA Coal
Ash Rules). Similarly, the water quality permit for the discharge from the basins

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
(National Pollutant Discharge Elimination System Permit No. #NC0000396 Buncombe
County) or its reissuance or amendment (NPDES Permit) could contain terms that
control or affect the scope of that work. DENR filed legal cases in Superior Court
(DENR Cases), which could be resolved through decision or settlement. DENR also
sent Duke Energy Notices of Violation (NOVs) regarding surface water and groundwater
quality issues at the Plant.
All of the above (Coal Ash Act, NC DENR Letter, NPDES Permit, DENR Cases, NOVs
and the proposed EPA Coal Ash Rules) are illustrative of actions that could potentially
affect the precise scope of the work to be performed under the Plan. As a
consequence, neither the submittal of this Plan nor its approval by DENR should be
taken as requiring actions different from other such applicable requirements. Thus,
Duke Energy submits this Plan to DENR based on the understanding that it may be
necessary to make changes in the Plan in the future to reflect any such actions and
reserves the right to make such changes after DENR's approval of the Plan.
II. General Facility Description
The Plant is located in Arden, NC, approximately eight (8) miles south of Asheville, NC.
Asheville Plant's Unit 1 was constructed in 1964 with a second coal burning unit (Unit 2)
added in 1971. Current generation capacity of the plant is 376 megawatts (MW) from
two (2) coal fired units. In 1999 and 2000, two (2) natural gas and oil combustion
turbines (CT) with an additional output of 324 MW were added.
YEAR (net MW) COMBINErP
1
Coal Fired
Steam
1964 191 376
1971 185
2
3
Natural Gas
and Oil
1999 162
1999 162 324
4
Combustion
Total 700
The Plant has two (2) ash storage basins. The first basin was created in 1964 when the
plant began operations. In 1982 a second basin was constructed and placed into
operation directly adjacent to the 1964 basin's south retention dam.
1964 Ash Basin
The 1964 Ash Basin Dam (Bunco-097) was constructed in 1964 to serve as a
wastewater treatment facility for the treatment of ash sluice water. The surface area of
the basin is approximately 45 acres. The basin does not retain a permanent pool with
the exception of a three (3) acre unlined retention pond known as the "Duck Pond". In
2005, engineered and lined wetlands were constructed within the 1964 basin footprint to
treat flue gas desulfurization (FGD) process wastewater.

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
Currently, production ash is sluiced to a concrete rim ditch system that is located within
the footprint of the 1964 basin. The rim ditch system also receives plant stormwater
drainage and low volume wastewater. Coal combustion residuals are dredged from the
rim ditch, dewatered, and transported offsite to a structural fill project at the Asheville
Regional Airport approximately two (2) miles from the plant. The wastewater from the
rim ditch process is treated in the lined rim ditch system and then routed to the Duck
Pond area within the 1964 basin for further treatment prior to discharge to a small
settling pond outside of the 1964 dam. This settling pond serves as the monitoring point
for Outfall 001 of the plant's NPDES permit (NC0000396). Treated water discharged
from this settling pond is routed directly to the French Broad River.
The 1964 Ash Basin is estimated to contain approximately 2.3 million tons of ash.
1982 Ash Basin
In response to the filling of the 1964 ash basin in the late 1970s, a second basin was
constructed in 1982 with the establishment of a dam (Bunco-089) in the adjacent valley
of the 1964 ash basin. The 1982 ash basin reached capacity in the early 2007
timeframe. In an effort to continue plant operations an ash harvesting plan was
developed to increase ash storage capacity. The 1982 basin has been dewatered and
is currently being excavated in accordance with the Asheville Plant's ash reuse permit
(Distribution of Residual Solids (503 Exempt) Permit Number WQ0000020). The
harvested ash is transported to the Asheville Regional Airport for a structural fill project
for its taxiway infrastructure.
Currently, inflows into the 1982 ash basin consist of stormwater that collects naturally
on the basin. Stormwater collected at the combustion turbine area of the Asheville
Plant, adjacent to the coal-fired units, is also pumped into the basin. Water collected in
the basin is pumped to the head of the rim ditch system where it is treated prior to
discharge via Outfall 001.
As of September 30, 2014, the 1982 Ash Basin contains approximately 867 thousand
tons of ash remaining from an original inventory of approximately 3.7 million tons.
4

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
Figure 1: Asheville Steam Electric Generating Plant

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
III. Project Charter
As a further commitment, Duke Energy has formed an internal team, the Ash Basin
Strategic Action Team (ABSAT). This team is dedicated to executing a comprehensive
strategy for increased oversight and excavation of all of the Company's ash basins.
Dewatering of the ash basins and the removal of ash from the site will be performed
within project phases, Phase I and Subsequent Phase(s). Phase I will include the
removal of remaining ash in the 1982 basin, dewatering of the rim ditch system and
engineered wetlands that lie within the footprint of the 1964 ash basin, and completion
of any subsequent permitted activities.
During Phase I, the Company will continue to perform the pre -construction and planning
activities for the Subsequent Phase(s). These activities include project planning,
development of new disposal or beneficial reuse options, and completion of the required
permitting for the ash removal from the ash basins. Knowledge and opportunities for
program improvement obtained during Phase I of the project will be applied to the
Subsequent Phase(s).
Project Charter Objectives
Phase I Objectives
1. Complete removal of ash in the 1982 Ash Basin
2. Identify disposition of rim ditch, lined retention pond, and engineered wetlands in
the 1964 Ash Basin
3. Submit and obtain permits for Phase I activities
4. Evaluate, procure, design, construct and commission alternative waste water
treatment methodologies to replace the wetlands and rim ditch system within the
1964 basin
5. Evaluate, select, design, build and commission an alternate treatment method to
treat FGD process water to replace engineered wetlands process
6. Decommission, dewater, and demolish existing rim ditch system and wetlands in
the 1964 Ash Basin
7. Plan activities for Subsequent Phase(s)
8. Continue developing option(s) for proposed location(s) for removed ash for the
Subsequent Phase(s)
9. Validate production rates to meet project requirements
10. Gain knowledge and opportunities for program improvement that can be applied
to the Subsequent Phase(s)
Subsequent Phase(s) Objectives
1. Dewater the unlined retention pond (Duck Pond)
2. Remove ash from the 1964 basin
6

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
3. Decommission, dewater, and demolish the rim ditch system in the 1982 Ash
Basin
4. Perform ash basin closure activities
Project Charter Scope
Phase I Scope
1. Continue excavation of ash from the 1982 Ash Basin to the permitted structural
fill project at the Asheville Regional Airport utilizing current contractor
2. Obtain all applicable permits for work in Phase 1
3. Determine the contents of the engineered wetlands to determine disposal options
for the spoil materials
4. Engineer, build and commission a new rim ditch and primary and secondary lined
retention pond in the 1982 Ash Basin
5. Engineer, build and commission an alternate treatment methodology to replace
the engineered wetlands outside of the ash basins
6. Decommission, dewater and demolish rim ditch system and wetlands in the 1964
Ash Basin
7. Initiate excavation of ash in the 1964 Ash Basin
8. Finalize planning for the dewatering of the unlined retention pond
9. Continue developing beneficial reuse opportunities and placement alternatives
for subsequent phase ash removal of the 1964 basin
10. Finalize decision for need of onsite landfill in 1982 ash basin
11. Submit and/ or obtain all remaining required permit applications for ash removal
activities for Subsequent Phase(s)
Subsequent Phase(s) Scope
1. Prepare all remaining required permit applications for next Subsequent Phase for
ash removal activities (if applicable)
2. Finalize and/or develop additional location(s) for removed ash (if applicable)
including obtaining all required permits
3. Excavate and transport the remaining ash from Asheville to an approved landfill
or structural fill location
4. Decommission, dewater and demolish the rim ditch and primary and secondary
lined retention ponds in the 1982 Ash Basin
5. Complete closure activities as outlined in in Sections 3(b) and 3(c)
Subparagraphs 1 &2 of the Coal Ash Management Act of 2014
7

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
IV. Critical Milestone Dates
Critical Milestones within the Plan are summarized in the table below. These
milestones have been added to the Level 1 Schedule.
MILESTONES i1M.
Submit Excavation Plan
NO LATER THAN DATE
November 15, 2014
Complete comprehensive engineering review
November 30, 2014
Receive Dam Safety Permit to excavate 1982 Ash Basin
dam face
December 12, 2014
Receive updated DORS Permit
February 28, 2015
Receive NPDES permit modification for Rim Ditch System
July 2, 2015
Commission new 1982 rim ditch, primary and secondary
retention ponds
July 17, 2015
1964 Rim Ditch demolished and begin excavation of 1964
basin
September 1, 2015
Complete removal of ash from 1982 basin (except interim
storage of production ash
September 15, 2015
Decommission Engineered Wetlands and Commission
alternate FGD Wastewater Treatments stem
November 3, 2015
Dewater and Demolish Engineered Wetlands
March 2, 2016
Submit Updated Excavation Plan for Subsequent Phases
Annually
Convert Units 1 & 2 to "dry" fly ash handling
December 31, 2018
Impoundments closed per Sections 3.(b) and 3.(c) of the
Coal Ash Management Act of 2014
August 1, 2019
Convert Units 1 & 2 to "dry" bottom ash handling
December 31, 2019
At facilities actively producing CCR, end storm -water
discharge into impoundments
December 31, 2019
9

Asheville Steam Electric Generating Plant —Coal Ash Excavation Plan
November 13, 2014
V. Level 1 Schedule
ASHEVILLE EXCAVATION PLAN
Print Date 04-Nov-1415:25
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Note: This Level 1 Schedule is a living element of this Plan. Dates and durations are based on known information at the date of this Plan.

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
Vi. Erosion and Sedimentation Control Plan
Current excavation is being performed under the Distribution of Residual Solids (503
Exempt) Permit (WQ0000020) issued by the NCDENR Division of Water Quality. The
permit, in Section 11.7, provides "Adequate provisions shall be taken to prevent wind
erosion and surface runoff from conveying ash from stockpile/storage areas onto
adjacent property or into any surface waters prior to distribution and use. The Permittee
shall provide to the recipient of the ash a copy of the most -recent version of the Material
Safety Data Sheet (MSDS) for the ash as well as the most -recent version of the
Permittee's Document No. EVC-FGDC-00101 "Ash Utilization Plan" so that the recipient
of the ash is aware of guidance regarding how to take adequate provisions to prevent
wind erosion and surface runoff from conveying ash from the location of use onto
adjacent property or into any surface waters."
Asheville Plant site conditions allow for the excavation and transport of ash on existing
paved roads. No new construction is anticipated for continued ash excavation for either
the 1982 or the 1964 ash basins. Should any construction be needed that disturbs
more than one acre, the appropriate permits will be obtained.
Vil. Dewatering Plan
The 1982 Ash Basin is currently void of free-standing water. However, current water
inflows into the ash basin continue as described earlier. Water is captured and pumped
to the head of the rim ditch wastewater treatment system within the footprint of the 1964
Ash Basin.
The focus of dewatering of the 1964 Ash Basin consists of removing the current
wastewater streams in the engineered wetlands that treat FGD process water, the rim
ditch system, and the unlined retention pond (Duck Pond area) that serves as the
permitted wastewater treatment system for the plant's production ash. These elements
must cease to treat wastewater, be decommissioned, and be demolished in order to
facilitate ash excavation of the 1964 ash basin.
During Phase I, an evaluation of alternatives to treat all waste water streams will inform
needed permitting activities specifically related to the existing NPDES permit. Once any
needed permits are obtained, the alternate treatment system must be commissioned in
order to abandon the current rim ditch and engineered wetlands systems. Phase 1 will
culminate in decommissioning and demolition of the rim ditch and engineered wetlands
system. The unlined retention pond will then be dewatered through current operational
processes. All water will be treated prior to discharge through an updated NPDES
permit.
10

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
VIII. Proposed Location(s) for Removed Ash
Phase is Ash Disposition Site
Phase I of ash removal from the Asheville Plant will include excavation and removal of
the remaining 867 thousand tons of ash from the 1982 Ash Basin. The ash will be
transported approximately two (2) miles from the Plant to the Asheville Regional Airport
where it will continue to be placed into a permitted lined structural fill area developed
and managed by the excavating contractor, Charah.
Should the structural fill opportunity become unavailable, alternate ash disposition sites,
including disposal in permitted municipal landfills, will be identified during Phase I.
These sites, to date, have not been determined. Currently, a study has been
commissioned to identify potential areas of ash disposal within a 25 mile radius of the
Asheville Plant. This study will be finalized in November 2014. This study will also
inform potential disposal locations for all, or a portion of, the 2.3 million tons of ash in
the 1964 basin.
Subsequent Phase(s): Ash Disposition Sites
Currently, two potential beneficial reuse opportunities have been identified for ash
disposition during the subsequent phase(s) of ash excavation. Duke Energy, and their
vendor Charah, have identified another structural fill opportunity at the airport and are
working toward finalizing details of the project. The opportunity will not provide
adequate capacity for all of the ash in the 1964 Ash Basin. However, the beneficial use
opportunity may be utilized as an element of the overall ash basin excavation strategy.
The second opportunity, construction of a lined structural fill or landfill in the soon -to -
close 1982 Ash Basin, will be evaluated with other potential placement sites that will be
identified during Phase I.
Asheville Regional Airport Arden, NC ±1.7M Structural Fill
On -Site Structural Fill or Asheville Plant 550k — 2.25M Lined Landfill or
Lined Landfill Structural Fill
11

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
IX. Transportation Plan
Phase I
Ash from the 1982 basin will continue to be transported by Charah from the plant to the
Asheville Regional Airport via double -axle trucks. The haul is approximately two (2)
miles each way and the current tonnage equates to approximately 200 truckloads per
day. At peak of excavation in spring and summer 2015, tonnage hauled would equate
to approximately 280 truckloads per day.
Current transportation policies and standards will remain in place through final
excavation and will continue to meet Department of Transportation (DOT) and other
applicable federal, state, and local regulations. All drivers will follow all DOT regulations
pertaining to the trucking, including DOT bridge laws.
Subsequent Phase(s)
For subsequent phase(s), the transportation plan will be evaluated and reviewed to
provide any improvements discovered in Phase I or the previous Subsequent Phase.
These options may include continued trucking or moving ash by rail.
X. Environmental Permitting Plan
Phase I
Phase 1 will include continued excavation and removal of ash from the 1982 ash basin
to the Asheville Airport. Phase 1 will also include removal of the 1964 Basin
Engineered FGD Wetlands. Implementation for Phase I will continue under the current
DORS and NPDES permit. Phase I will include permitting activities for subsequent
phases.
Through the Excavation Plan approval process, Duke Energy is seeking to confirm that
all necessary approvals have been identified for subsequent phase(s). The Excavation
Plan is intended to authorize the excavation and movement of ash once the identified
permits have been obtained.
Excavation of ash creates potential for stormwater impacts. The facility holds an
NPDES stormwater permit and a stormwater pollution prevention plan (SWPPP).
Future modifications to the permit/plan will be managed as necessary.
Throughout the project, all necessary Dam Safety approvals will be obtained to cover
activities on or around jurisdictional dams. During Phase I, it is anticipated that ash
removal along the 1982 Ash Basin dam interior face will require review by the Division
of Energy, Mineral and Land Resources. Subsequent phases will assume the same
review for excavation work along the 1964 Ash Basin dam face.
12

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
There are no jurisdictional wetlands/streams associated with the removal of ash in the
1982 ash basin and the 1964 ash basin in Phase I. Future jurisdictional determinations
will be managed through the US Army Corps of Engineers with particular attention paid
to the difference between jurisdictional wetlands/streams under Section 404 and those
arising from Section 402 waters.
Subsequent Phase(s)
Subsequent Phases will include dewatering (once NPDES permit modification
complete) and excavation and removal of ash from the 1964 ash basins.
Excavation of ash creates potential for stormwater impacts. The facility holds an
NPDES Stormwater permit. The primary method to manage stormwater discharges is
the use of best management practices (BMPs), which are incorporated in the NPDES
permit and the stormwater pollution prevention plan (SWPPP). Future modifications to
the permit/plan will be managed as necessary.
Based on suggestion from NC DENR and US EPA, modification of the NPDES
wastewater permit may be necessary to initiate removal of free-standing water from
inactive ash basins. Removal of other water (sometimes referred to as pore water) is
likely to require NPDES permit modification.
Future jurisdictional determinations will be managed through the US Army Corps of
Engineers with particular attention paid to the difference between jurisdictional
wetlands/streams under Section 404 and those arising from Section 402 waters. Any
Section 404 permitting will require Section 401 Water Quality Certification by DENR.
If the Company pursues an on -site landfill solution for ash placement during subsequent
phase(s), site suitability approvals (Site Suitability Report, Required Public Comment,
DWM Approval of Site Suitability), Permit -to -Construct (Construction Plan Application,
Receive Permit -to -Construct from DWM), and Permit -to -Operate (Construction Quality
Assurance Report, Receive Permit -to -Operate) will be obtained.
If the Company chooses to utilize a mine reclamation solution for ash placement during
subsequent phase(s), an individual structural fill permit will need to be obtained by the
mine reclamation project owner/operator. It is anticipated that the mining permit will be
transferred from the existing mine owner to a mine reclamation contractor. Once the
permit is transferred, the mine reclamation contractor will submit an individual structural
permit application and mine reclamation plan to the Division of Mining. It is anticipated
that the Division of Mining will then forward the reclamation plan to the Division of Water
Resources, Division of Waste Management, and other divisions as necessary for
comments. Subject to any changes from Division of Mining, the revised reclamation
plan would be approved and an individual Structural Fill Permit will be issued.
13

Asheville Steam Electric Generating Plant —Coal Ash Excavation Plan
November 13, 2014
If used, before shipping ash to a third -party Subtitle D landfill, waste characterization
and approval will be completed. All necessary Dam Safety approvals will be obtained
to cover activities on or around jurisdictional dikes. Breaching of the dikes will require
Dam Safety approval. Any impacted wells or piezometers will be properly abandoned
and dispositioned with NC DENR. Fugitive dust will be managed to mitigate impacts to
neighboring areas. Impacts to threatened and endangered species will be avoided.
Subsequent Phases Permit Matrix
Media
Permit
Milestone/Targot Date
Reasoning
Excavation of ash creates potential for
stormwater impacts. The facility holds
an NPDES Stormwater permit. The
primary method to control stormwater
discharges is the use of best
Industrial Stormwater Permit
5/29/2015
management practices (BMPs) which
are incorporated in the NPDES permit
and the stormwater pollution prevention
plan (SWPPP). Future modifications to
the permit/plan will be managed as
necessary.
DENR has indicated dewatering
activities, including free water removal,
Water
Wastewater NPDES Permit
may require NPDES wastewater permit
Modification
12/31/2015
modification. Based on this, Duke is
submitting proposed dewatering permit
conditions in its pending NPDES permit
application.
Identify if project scope results in
impacts to jurisdictional wetlands or
streams. Obtain JD and pursue 404
Jurisdictional Wetland and Stream
permit for impacts from the ACOE. Also,
Impacts/404 Permitting and 401
10/30/2015
404 permits are required for working
WQC
below the ordinary high water mark. If
Federal permitting is required, obtain
401 WQC. There are no identified
jurisdictional wetland/stream impacts in
Phase I.
Mine Reclamation Owner/Operator to
Individual Structural Fill Permit
5/29/2015
obtain a structural fill permit as set forth
in Subpart 3 of Part 21 of Article 9 of the
Coal Ash Management Act
Hauling and excavation activities must
not impact a jurisdictional dam or dike.
Dam Safety Approvals
10/30/2015
Activities are initially staying 50 It away
from the jurisdictional dike. Breaching
Waste
of dike will require Dam Safety approval.
Site Suitability Report
9/30/2016
Site Suitability anticipated for offside
landfill must go through public comment
Must receive permit to begin
Permit -to -Construct
212412017
construction and corresponding E&SC
approval to cover approved Construction
design
Must provide Construction Quality
Permit -to -Operate
Fpermit
1/26/2018
Assurance Report and then receive
before operation
Site specific
Local
Nuisance/Noise/Odor/Other
N/A
No local nuisance requirements
Ordinances
Requirements including DOT and
identified.
FERC Requirements
14

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
XI. Contracting Strategy
Phase I
Duke Energy has contracted with Charah since 2007 for excavation of ash in Asheville's
1982 Ash Basin on a firm, fixed price per ton price basis. Duke Energy will continue to
manage the contract with Charah through final excavation of the 1982 Ash Basin as
indicated in Phase I of the Excavation Plan.
For the dewatering elements of phase 1, Duke Energy will engage multiple contractors
to drive competition, system -wide innovation, and the collection of best practices.
Subsequent Phases
During the subsequent phase(s) of ash removal, the Company will award the
excavation, transportation, and disposal of the ash to a single contractor. The
contracting strategy may shift for subsequent phases as the Company recognizes
enhancements that may drive costs lower, such as the use of incentives or risk sharing
to drive productivity and unit cost. The Company's core values of safety and quality are
non-negotiable and will not be compromised in order to increase productivity or
generate cost savings.
In summary, The Company's contracting strategy will provide the most effective
combination of ash removal, transportation, disposition, and beneficial use options while
balancing safety, scope adherence, cost and schedule.
XII. Environmental, Health, and Safety Plan
Protecting workers, the public, the community and the environment
Duke Energy 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, Duke Energy and its contractors will follow the Duke Energy
Safe Practices; the ABSAT Environmental, Health, and Safety (EHS) supplement
document, and any additional requirements. Occupational health and safety
expectations include oversight and continuous improvement throughout the project.
The project will include comprehensive environmental, health and safety plans
encompassing all aspects of the project work including at the plant, in transit and at the
final destination as needed.
In addition to adhering to all applicable environmental, health and safety rules and
regulations, Duke Energy and contractors will focus on ensuring the safety of the public
and environment during each phase of the project.
15

Asheville Steam Electric Generating Plant— Coal Ash Excavation Plan
November 13, 2014
XIII. Communications Plan
Many different external stakeholders including neighbors, government officials and
media have an interest in this project. For example, there is the potential for facility
neighbors and the general public to see or experience construction -related impacts
such as truck traffic, landscape changes, or noise. The Company is committed to
providing information by proactively communicating about the Project activities to
potentially affected parties and responding to inquiries in a timely manner.
The Project team will coordinate with Duke Energy's Corporate Communications
Department to develop a comprehensive external communications plan tailored to the
specific needs of each phase of the project.
16

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
XIV. Glossary
TERM
DEFiNITI
ABSAT
Duke Energy organization acronym for Ash Basin Strategic Action
Team
ABSAT Project
Duke Energy organization acronym for Ash Basin Strategic Action
Controls
Team responsible for financial reporting, scheduling and
management reporting
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.
Beneficial Re -use
Beneficial use of coal combustion residuals, or byproducts, removed
Opportunities
from the site in compliance with the requirements of Section .1700 of
31 Subchapter B of Chapter 13 of Title 15A of the North Carolina 32
Administrative Code (Requirements for Beneficial Use of Coal 33
Combustion By -Products) and Section .1205 of Subchapter T of 34
Chapter 2 of Title 15A of the North Carolina Administrative Code 35
(Coal Combustion Products Management
Bottom Ash
The agglomerated, angular ash particles formed in pulverized coal
furnaces that are too large to be carried in the flue gases and collect
on the furnace walls. Bottom Ash falls through open grates to an
ash hopper at the bottom of the furnace.
CCR
Coal Combustion Residuals. Residuals include fly ash, bottom ash,
boiler slag produced by a coal fired generating unit
Coal Ash
Plan required by NC DENR letter dated August 13, 2014 including a
Excavation Plan
schedule for soil and sedimentation erosion control measures,
dewatering, and the proposed location of the removed ash
Coal Ash
North Carolina Session Law 2014-122
Management Act of
2014
17

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
TERM
DEFINITION
Decanting
The act of removing water from ash
Dewatering
The act of removing bulk and entrapped water from the ash basin
Dewatering Plan
Engineered plan and the associated process steps necessary to
dewater an ash basin
Duke Safe Work
Document detailing the Duke Energy safety guidelines
Practices
Engineer of Record
Duke Energy or 3rd party contracted engineer responsible for final
verification of specific plan actions and documents
Excavation
Tasks and work performed related to the planning, engineering and
Activities
excavation of ash from an ash basin
Excavation Plan
Refer to Coal Ash Excavation Plan
Fly Ash
Very fine, powdery material, composed mostly of silica with nearly
all particles spherical in shape, which is a product of burning finely
ground coal in a boiler to produce electricity and is removed from
the plant exhaust gases by air emission control devices.
Level 1 Schedule
Schedule view that shows the main milestones to complete the
project
NPDES
National Pollutant Discharge Elimination System
NPDES Permit
A permit that regulates the direct discharge of wastewater to surface
waters
Off -Site Facility
A structural fill or mine reclamation for the long term storage of coal
combustion residuals
Permit
Federal, state, county or local government authorizing document
1964 Ash Basin
Ash pond created in 1964 for wastewater treatment of industrial
wastewater produced by coal combustion for electric steam
generation (#BUNCO-097)
1982 Ash Basin
Ash pond created in 1982 for wastewater treatment of industrial
wastewater produced by coal combustion for electric steam
generation (#BUNCO-089)
18

Asheville Steam Electric Generating Plant — Coal Ash Excavation Plan
November 13, 2014
XV. Reference Documents
19

Dan River Steam Station
Coal Ash Excavation Plan
DUKE
�, ENERGY

Dan River Steam Station — Coal Ash Excavation Plan
November 13, 2014
I.
Statement of Purpose...................................................................................................................2
II.
General Facility Description.........................................................................................................4
III.
Project Charter...............................................................................................................................6
IV.
Critical Milestone Dates................................................................................................................8
V.
Level 1 Schedule...........................................................................................................................9
VI.
Erosion and Sedimentation Control Plan................................................................................10
VII.
Dewatering Plan..........................................................................................................................10
VIII.
Proposed Location(s) for Removed Ash..................................................................................11
IX.
Transportation Plan.....................................................................................................................12
X.
Environmental Permitting Plan..................................................................................................13
XI.
Contracting Strategy...................................................................................................................18
XII
Environmental, Health, and Safety Plan..................................................................................18
XIII.
Communications Plan.................................................................................................................18
XIV.
Glossary ........................................................................................................................................20
XV.
Reference Documents................................................................................................................22
1

Dan River Steam Station — Coal Ash Excavation Plan
November 13, 2014
I. Statement of Purpose
Duke Energy Carolinas, LLC (Duke Energy or the Company) is required by Section 3(b)
of the Coal Ash Management Act of 2014 to close in accordance of Section 3(c) the
coal combustion residuals (CCR) surface impoundments located at the Dan River
Combined Cycle Plant, National Pollutant Discharge Eliminations System Permit No.
#NC0003468 Rockingham County (Dan River) as soon as practicable, but not later than
August 1, 2019. Further, by letter to Duke Energy dated August 13, 2014, North
Carolina Department of Environment and Natural Resources (NC DENR) requested that
Duke Energy submit coal ash excavation plans for inactive coal ash impoundments at
Dan River no later than November 15, 2014 (NC DENR Letter).
This Coal Ash Excavation Plan (Plan) represents Phase I and other Subsequent
Phase(s) activities to satisfy the requirements outlined in Sections 3(b) and 3(c)
Subparagraph 1 &2 of the Coal Ash Management Act of 2014 and the requests set forth
in the NC DENR Letter.
In general, the Plan covers the first 12 — 18 months of ash basin excavation activities,
including the initiation of basin dewatering, site preparation, ash basin preparation, and
ash removal from the basins. These activities may include decanting ash within the ash
basin system.
For Subsequent Phase(s), this document will be revised for any modifications to the
Plan for the site. The Plan will be updated and submitted to NC DENR annually or
earlier as required by Subsequent Phase(s).
The NC DENR Letter specifically requests that the Plan include 1) a schedule for soil
and sedimentation erosion control measures, 2) dewatering, and 3) the proposed
location(s) of the removed ash. These requirements are found in Section V. Level 1
Schedule, Section VI. Erosion and Sedimentation Control Plans, Section VII.
Dewatering Plan, and Section VIII. Proposed Location(s) for Removed Ash.
The Plan covers some of the work required by Sections 3(b) and 3(c) of the Coal Ash
Management Act of 2014 (Session Law 2014-122) (Coal Ash Act, or 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. Additionally, it may become necessary for the Company to modify the Plan to
address other legal requirements or factors that develop during the ash basin
excavation. Any changes will be included in annual updates to the Plan that Duke
Energy will submit to NC DENR.

Dan River Steam Station — Coal Ash Excavation Plan
November 13, 2014
The precise scope of work in excavating the ash basins will be determined by applicable
laws, rules, permits, and approvals that control the activities to be performed under the
Plan. For example, the United States Environmental Protection Agency (EPA) is
considering issuing rules regarding the management of coal ash (proposed EPA Coal
Ash Rules). Similarly, the water quality permit for the discharge from the Pond (National
Pollutant Discharge Elimination System Permit No. #NC0003468 Rockingham County)
or its reissuance or amendment (NPDES Permit) could contain terms that control or
affect the scope of that work. NC DENR filed legal cases in Superior Court (NC DENR
Cases), which could be resolved through decision or settlement. NC DENR also sent
Duke Energy a Notices of Violation (NOVs) regarding surface water and groundwater
quality issues at the Plant.
All of the above (Coal Ash Act, NC DENR Letter, NPDES Permit, NC DENR Cases,
NOVs, and the proposed EPA Coal Ash Rules) are illustrative of actions that could
potentially affect the precise scope of the work to be performed under the Plan. As a
consequence, neither the submittal of this Plan nor its approval by NC DENR should be
taken as requiring actions different from other such applicable requirements. Thus,
Duke Energy submits this Plan to NC DENR based on the understanding that it may be
necessary to make changes in the Plan in the future to reflect any such actions and
reserves the right to make such changes after NC DENR's approval of the Plan.
M

Dan River Steam Station — Coal Ash Excavation Plan
November 13, Z014
ll. General Facility Description
The Dan River coal station began operation around 1950 and is currently being
decommissioned. The Primary Ash Basin was constructed in 1956, with an
embankment crest elevation of 523.5 feet. In 1968, the pond embankment crests were
raised to elevation 530 feet and extended in length approximately 1,200 feet east along
the Dan River. An intermediate dike was constructed in 1976, resulting in two basins,
with the primary basin dam crest being raised to elevation 540 feet. The Primary Ash
Basin was periodically dredged and the material dry -stacked on higher terrain north of
the ponds (referred to as dry ash stacks). The dam numbers for the ash basins are
ROCKI-237 and ROCKI-238. The dry ash stacks have been capped.
Primary Ash Basin
The Primary Ash Basin at Dan River consists of a composite dam made up of local
borrow materials, including silty sands and sandy silts with some clay. Portions of the
dam may have been built on, or contain, ash materials. The eastern face of the
embankment is armored with dumped rock up to elevation 512 feet. A rock fill berm
was constructed alongside the river, up to elevation 503 feet. An intermediate bench
was constructed at approximate elevation of 530 feet. The Primary Ash Basin has an
approximate footprint of 39 acres with a surface water area of 18 acres. The Primary
Ash Basin received sluiced ash from pipes in the southwest corner, and outlets into the
Secondary Ash Basin through a decant structure in the northwest corner. Currently, the
Primary Ash Basin contains approximately 957 thousand tons of CCR material.
Intermediate Dike (separates the Primary Ash Basin and the Secondary Ash Basin)
The intermediate dike was constructed in 1976-77, bisecting the pond into Primary and
Secondary Ash Basins. The dike was constructed on existing ash deposits, with an
upper crest elevation of 540 feet adjacent to the Primary Ash Basin and a lower crest
elevation of 530 feet adjacent to the Secondary Ash Basin. The dike has a surface road
at the 540 foot level. It has a vegetated slope adjacent to the road which extends to a
530 foot elevation shelf adjacent to the Secondary Ash Basin. A dumped rock buttress
was constructed below the elevation 530 foot crest. The width of the intermediate dike
is approximately 100 feet.
Secondary Ash Basin
The Secondary Ash Basin embankments, including the intermediate dike forming the
southwest boundary, have a crest elevation of 530 feet and are constructed of the same
local materials as the Primary Ash Basin. The eastern face of the embankment is
armored with dumped rock up to elevation 512 feet. A rock fill berm was constructed
alongside the river, up to elevation 503 feet. The pond receives decanted flow from the
4

Dan River Steam Station — Coal Ash Excavation Plan
November 13, 2014
Primary Ash Basin in the western corner, and flows exit the basin through a decant
structure in the northeast corner. Flow from the Secondary Ash basin is controlled by
National Pollutant Discharge Elimination System (NPDES) Permit #NC 0003468. The
pool level is controlled by the decant riser using concrete stop -logs and conveys to the
outlet through a 36-inch diameter reinforced concrete pipe (RCP) constructed through
the embankment dike. Currently, the Secondary Ash Basin contains approximately 207
thousand tons of CCR material.
Ash Stacks
The dry ash stacks are located to the North of the Primary and Secondary Ash Basins.
These ash stacks consist of CCR material dredged from the Primary Pond. Ash Stack 1
and Ash Stack 2 contain approximately 1.1 million tons and 372 thousand tons of CCR
material, respectively. For the purposes of water management, the Ash Stacks are
located within the ash basin system. Stormwater run-off from the Ash Stacks is
contained within the ash basin system and flows to the Primary and Secondary Ash
Basins.
Figure 1: Dan River Combine Cycle Plant (#NC 0003468) in Rockingham County
5

Dan River Steam Station — Coal Ash Excavation Plan
Novembor 13, 2014
III. Project Charter
As a further commitment, the Company has formed an internal team, the Ash Basin
Strategic Action Team (ABSAT). This team is dedicated to strengthening and executing
a comprehensive strategy for increased oversight and closure of all of the Company's
ash basins.
Dewatering of the ash basins and the removal of ash from the site will be performed
within project phases, Phase I and Subsequent Phase(s). Required permits for each
phase are set forth in Section X of this Plan. Phase I will include site preparation,
dewatering, ash excavation to an off -site landfill location, and completing any other
subsequent permitted activities. The excavation will begin with the approval of this Plan
by NC DENR and the receipt of final permits.
In addition, a dewatering plan for the ash basins has been drafted and, if approved by
NC DENR, bulk dewatering will be expedited during the initial phase of work. Duke
Energy has submitted an application to modify its NPDES wastewater permit to include
controls to be implemented during dewatering activities.
During Phase I, the Company will continue to perform the pre -construction and planning
activities for the Subsequent Phase(s). These activities include project planning,
development of new permanent disposal and sale or reuse options, and completion of
additional required permitting that may be necessary for the ash removal from the ash
basins. Knowledge and opportunities for program improvement obtained during Phase I
of the project will be applied to the Subsequent Phase(s).
The Plan will begin 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
Management Act. Permits to construct and operate the landfill must be received no
later than October 24, 2015 and June 1, 2017; respectively, in order to make the on -site
landfill a viable option to comply with the mandatory closure date of August 1, 2019.
Project Charter Objectives
Phase I Objectives
1. Initiate the removal of ash from the Dan River ash basins
2. Begin dewatering of the ash basins
3. Determine the disposition of the ash stacks
4. Obtain permit to construct on -site landfill by October 24, 2015
5. Plan activities for Subsequent Phase(s), including development of option(s) for
reuse or proposed ash disposal location(s)
6. Gain knowledge and opportunities for program improvement that can be applied
to Subsequent Phase(s)
n

Dan River Steam Station — Coal Ash Excavation Plan
November 13, 2014
7. Validate production rates to meet project requirements
8. Evaluate the on -site landfill option and sale and beneficial reuse options
Subsequent Phase(s) Objectives
1. Remove remaining ash from ash basins and ash stacks
2. Obtain permit to operate the on -site landfill by June 1, 2017
3. Develop, construct, and operate the on -site landfill if viable
4. Continue developing beneficial reuse opportunities and placement alternatives
for subsequent phase(s) ash removal
Phase I Scope
1. Finalize end location(s) for removed ash and obtain all required permits
2. Obtain all applicable permits for work in Phase 1
3. Begin site preparation activities, including mobilization
4. Install site erosion and sediment control measures
5. Install required site haul roads
6. Prepare and install rail load out spur for rail transportation
7. Prepare and install truck load out and truck wash for truck transportation
8. Perform site preparation for the basin dewatering (Primary & Secondary Ash
Basins)
9. Engineer plan to stop water inputs into the ash basins
10.Initiate rerouting or elimination of inflows to the ash basins
11. Begin bulk dewatering of the Secondary Basin
12. Perform site preparation in the Primary & Secondary Ash Basins for ash
excavation
13. Perform site preparation for ash stack removal
14. Develop the on -site landfill if viable
15. Excavate and transport approximately 1.2 million tons of ash from the Primary
and Secondary Ash Basin & Ash Stacks to an approved landfill or structural fill
location
16. Perform an engineering and constructability review for the on -site landfill
17.Obtain all required permits for subsequent phase activities
7

Dan River Steam Station — Coal Ash Excavation Plan
November 13, 2014
Subsequent Phase(s) Scope
1. Identify and/or develop additional off -site ash options
2. Obtain all required permits for the added options
3. Obtain all remaining required permits for next Subsequent Phase activities
4. If viable construct and operate the on -site landfill
5. Complete basin dewatering
6. Excavate and transport the remaining ash from the Dan River Station to the on -
site landfill or off -site reuse options
7. Complete closure activities as outlined in Sections 3(b) and 3(c) Subparagraphs
1 &2 of the Coal Ash Management Act of 2014
IV. Critical Milestone Dates
Critical Milestones within the Plan are summarized in the table below. These
milestones have been added to the Level 1 Schedule.
MILESTONES■ LATER THAN DATE
Elk
Submit Excavation Plan November 15, 2014
Complete comprehensive engineering review
November 30, 2014
Excavation Plan Approval
February 17, 2015
Industrial Stormwater Permit
March 18, 2015
Commence work - ash removal
Final permit approval + 60 Days
Receive Permit to Construct On -site Landfill
October 24, 2015
Submit Updated Excavation Plan — Subsequent
Phase(s)
December 31, 2015
Receive Permit to Operate On -Site Landfill
June 1, 2017
Eliminate stormwater discharge into impoundments
December 31, 2018
Impoundments closed per Sections 3(b) and 3(c) of
the Coal Ash Management Act of 2014
August 1, 2019
0

Dnn River Stearn Station - Coal Ash Excavation I --
November 13.2014
V. Level 1 Schedule
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E--tiao Fla< Schedule
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Note: This Level 1 Schedule is a living element of this Plan. Dates and durations are based on known information on the
date of this Plan.

Dan River Stcam Station — Coal Ash Excavation Plan
November 13, 2014
VI. Erosion and Sedimentation Control Plan:
The Erosion and Sedimentation Control Plan (E&SC) for the excavation of the Ash
Stack is being developed. The approval of this plan by NC DENR will meet the
requirement outlined in the NC DENR Letter.
Any deviations from the current E&SC for Subsequent Phase(s) will be submitted to and
approved by NC DENR prior to installation and initiation of subsequent phases of work.
The approved contractor will install the E&SC measures indicated in the plan. The
Engineer of Record will review the installation prior to commencing excavation on site.
All control measures will be maintained through the project in accordance with the
E&SC.
VIA. Dewatering Plan
The Dan River ash basins will be dewatered to facilitate the removal of ash and to
mitigate risk. Lowering the water level within each basin will improve safety factors of
the dams by reducing the driving force on the upstream face of the dam. Similarly,
dewatering will improve the physical properties of the retained ash, making it less
susceptible to flow in the event of an unexpected dam failure.
An Engineered Dewatering Plan for Dan River is being developed. This plan details
removal of the following water:
Sequence
Primary Ash Basin — Removal of water 25 feet below top of ash
The Primary Ash Basin contains an undetermined amount of water which will be
pumped to the Secondary Ash Basin at a maximum drawdown rate of one foot
over seven days. Following free water removal, vacuum well points will be
installed in the ash along the dam to draw down entrapped water in the vicinity of
the dam.
2. Secondary Ash Basin — Removal of water 15 feet below top of ash
Based on data from April 2014, the Secondary Ash Basin contains approximately
20.7 million gallons of free water. The maximum free water drawdown rate will
be one foot over seven days. Following free water removal, vacuum well points
will be installed in the ash along the dam to draw down entrapped water in the
vicinity of the dam.
10

Darr River Steam Station — Coal Ash ExcavaJon Plan
November 13, 2014
VIII. Proposed Location(s) for Removed Ash
Phase I of the Plan will include the excavation and removal of approximately 1.2 million
tons of ash from Dan River. Subsequent Phase(s) will remove the remaining ash at the
site. Ash removed from the site will be transported by the contractor to properly
permitted facilities. The ash placement location will be properly managed and
maintained to ensure environmental compliance with all applicable rules and
regulations.
Phase l: Ash Disposition Sites
For Phase I, the Maplewood Landfill located in Jetersville, Virginia has been identified
for ash placement. This primary option provides a solution for Phase I and/ or
Subsequent Phase(s).
Contingent Plan: Ash Disposition Sites
In the event of any issues with accepting ash at the Maplewood Landfill, the Atlantic
Landfill has been determined as a suitable alternative site. All necessary steps will be
taken to assure that the Atlantic Landfill is ready to accept ash in the event of any
issues at the Maplewood Landfill. The Atlantic Landfill is located in the city of Waverly,
Virginia.
11

Dan River Steam Station — Coal Ash Excavation Nan
November 13, 2014
Subsequent Phase(s): Ash Disposition Sites
The project team will utilize lessons learned from Phase I to develop an off -site disposal
strategy and/ or alternative sale or reuse site(s) that will provide the improvements
below.
• Provide a reliable, long-term, cost effective, solution for ash designated for
removal
• Develop a supplier diverse Program to drive innovation and competition
• Establish performance baselines and the system to optimize pickup, transport,
drop-off and reuse
IX. Transportation Plan
Ash will be transported from the site via rail car to the off -site facility. Transportation of
the CCR will be conducted by approved transporters and meet DOT and other
applicable federal, state, and local regulations.
Phase 1: Transportation
For Phase 1, all CCRs will be transported by rail from Dan River to the Maplewood
Landfill site. Trains will consist of approximately 65 gondola cars at 100 tons per car.
One train will leave the site every other day or 2.5 to 3 trains per week on average
establishing a production rate of approximately 16,400 tons per week. The operation of
loading rail cars will be completed with a crew working typically 10 hours per day, 5
days per week. Plans are being made to design and install a rail loading system at Dan
River that would transport ash to the Maplewood Landfill.
.'�anvt4le `SgT .. 0 ... .
ORoxboro
Figure 2: Typical Truck Route to Maplewood Landfill
12

Dan River Steam Station — Coal Ash, Excavation Plan
!November 13, 2014
Contingent Plan: Transportation
To support the transportation of ash for the Contingent Location, ash will be transported
to the Atlantic Landfill instead of the Maplewood Landfill. In the event of rail
transportation disruption, truck transportation remains a contingency option for either
the Maplewood Landfill or the Atlantic Landfill.
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Figure 3: Typical Truck Route to Atlantic Landfill
Subsequent Phase(s): Transportation
The transportation plan and any other options will be reviewed and could be amended
in Subsequent Phase(s) to enhance the excavation process and objectives.
X. Environmental Permitting Plan
Phase /
Phase 1 will include excavation and removal of 1.0 — 1.2 million tons of ash either from
the ash stack or ash basins. Implementation for Phase I can begin once the permitting
for Phase I is in place, although different permitting may be necessary prior to initiating
Subsequent Phase work. Phase I will include permitting activities for subsequent
phases.
Through this Excavation Plan approval process, Duke Energy is seeking to confirm that
all necessary approvals have been identified. The Excavation Plan is intended to
authorize the excavation and movement of ash once the identified permits have been
obtained.
Excavation of ash creates potential for stormwater impacts. NC DENR has indicated an
industrial stormwater permit may be needed. Based on this representation from NC
13

Dan River Steam Siation — Coul Ash Excavation Plan
Novembor 13, 2014
DENR, Duke Energy has applied for an NPDES industrial stormwater permit to support
ash removal at the site. A stormwater pollution prevention plan (SWPPP) incorporating
best management practices (BMPs) will be created. Future modifications to the
permit/plan will be managed as necessary.
NC DENR has recently indicated that modification of the NPDES wastewater permit
may be required to initiate removal of free water from inactive ash basins. Duke is
submitting additional information to NC DENR for its consideration to support
incorporating dewatering requirements into the pending the Company's pending NPDES
permit application. The Company is working with United States Environmental
Protection Agency (EPA) and NC DENR with a goal of identifying the regulatory
framework that will allow the removal of free-standing water from inactive basins to
move forward.
There are no jurisdictional wetlands/streams associated with the removal of the Ash
Stack or Primary or Secondary Ash Basins in Phase I. Future wetlands/stream impacts
and jurisdictional determinations will be managed through the US Army Corps of
Engineers (ACOE) with particular attention paid to the difference between jurisdictional
wetlands/streams under Section 404 and those arising from Section 402 waters.
Before creation of new mine reclamation structural fills, an individual structural fill permit
will need to be obtained by the mine reclamation project owner/operator. It is
anticipated that the mining permit will be transferred from the existing mine owner to a
mine reclamation contractor: Once the permit is transferred, the mine reclamation
contractor will submit an individual structural permit application and mine reclamation
plan to the Division of Mining. It is anticipated that the Division of Mining will then
forward the reclamation plan to the Division of Water Resources, Division of Waste
Management, and other divisions as necessary for comments. Subject to any changes
from Division of Mining, the revised reclamation plan would be approved and an
individual Structural Fill Permit will be issued.
No information currently exists to indicate that the Dan River ash should be treated as a
DOT hazardous material shipped via truck or rail.
Subsequent Phase(s) will include dewatering (once NPDES permit modification
complete) and continued excavation and removal of ash from the Primary and
Secondary Ash Basins. Subsequent Phase(s) also potentially include the construction
of an offsite landfill.
Future jurisdictional determinations will be managed through the US Army Corps of
Engineers with particular attention paid to the difference between jurisdictional
14

Dan River Steam Station — Coa; lash Excavation Plan
Noveinber 13, 2014
wetlands/streams under Section 404 and those arising from Section 402 waters. Any
Section 404 permitting will require Section 401 Water Quality Certification by NC DENR.
In order to facilitate adjacent -site ash monofill construction and operation, Site Suitability
approvals (Site Suitability Report, Required Public Comment, DWM Approval of Site
Suitability), Permit -to -Construct (Construction Plan Application, Receive Permit -to -
Construct from DWM), and Permit -to -Operate (Construction Quality Assurance Report,
Receive Permit -to -Operate) will be obtained. If used, before shipping ash to a third -
party Subtitle D landfill, waste characterization and approval will be completed. All
necessary Dam Safety approvals will be obtained to cover activities on or around
jurisdictional dams. Breaching of the dams will require Dam Safety approval. Any
impacted wells or piezometers will be properly abandoned and dispositioned with NC
DENR. Fugitive dust will be managed to mitigate impacts to neighboring areas.
Impacts to threatened and endangered species will be avoided.
No additional site -specific or local requirements have been identified.
15

Dan River Steam Station — Coal Ash Excavation Plan
Novembcr 13, 2014
Phase I Permit Matrix
Media
Permit
Milestone/ Target
Reasoning
Date
Excavation of ash creates
potential for stormwater
impacts. The facility will seek
an approved E&SC and
associated Construction
Industrial Stormwater NPDES
Stormwater Permit approval for
Permit
March 18, 2015
ash stack removal. NC DENR
has indicated an industrial
stormwater permit may also be
needed. Duke has applied for
this permit. A SWPPP
incorporating BMPs will be
Water
created.
NC DENR has indicated
dewatering activities including
free water removal, may require
Wastewater NPDES Permit —
NPDES wastewater permit
Minor Modification
March 27, 2015
modification. Based on this
requirement, Duke Energy is
submitting proposed dewatering
permit conditions in its pending
NPDES permit application.
Jurisdictional Wetland and
There are no identified
Stream Impacts/ 404 Permitting
N/A
jurisdictional wetland/stream
and 401 WQC
impacts in Phase I.
Hauling and excavation
activities must not impact a
jurisdictional dam or dike.
Activities are initially staying
away from the jurisdictional
Dam Safety Approvals
May 29, 2015
dike. Removing ash from the
Primary and Secondary Ash
Basins will have to be reviewed
Waste
with Dam Safety. Breaching of
dike will require Dam Safety
approval.
Mine Reclamation
Owner/Operator to obtain a
Individual Structural Fill Permit
March 27, 2015
structural fill permit as set forth
in Subpart 3 of Part 2 of Article
9 of the Coal Ash Management
Act.
Site Specific
Local
Nuisance/Noise/Odor/Other
N/A
No local nuisance requirements
Ordinances
Requirements including DOT
identified.
and FERC Requirements
16

Dan River Steam Station — Coal Ash Excavation Plan,
November 13, 2014
Subsequent Phase(s) Permit Matrix
Media
Permit
Milestone/ Target
Reasoning
Date
Excavation of ash creates potential
for stormwater impacts. The facility
will seek an approved E&SC and
associated Construction Stormwater
Industrial Stormwater NPDES
June 26, 2015
Permit approval for ash stack
Permit
removal. NC DENR has indicated an
industrial stormwater permit may
also be needed. Duke has applied
for this permit. A SWPPP
incorporating BMPs will be created.
NC DENR has indicated dewatering
activities including free water
removal, may require NPDES
Water
Wastewater NPDES Permit —
October 30, 2015
wastewater permit modification.
Major Modification
Based on this requirement, Duke
Energy is submitting proposed
dewatering permit conditions in its
pending NPDES permit application.
Identify if project scope results in
impacts to jurisdictional wetlands or
streams. Obtain JD and pursue 404
Jurisdictional Wetland and Stream
permit for impacts from ACOE.
Impacts/ 404 Permitting and 401
October 30, 2015
Also, 404 permits are required for
WQC
working below the ordinary high
watermark. If Federal individual
permitting is required, obtain 401
WQC.
Mine Reclamation Owner/Operator
Individual Structural Fill Permit
March 27, 2015
to obtain a structural fill permit as set
forth in Subpart 3 of Part 2 of Article
9 of the Coal Ash Management Act.
Hauling and excavation activities
must not impact a jurisdictional dam
Dam Safety Approvals
October 30, 2015
or dike. Activities are initially staying
50 feet away from the jurisdictional
dike. Breaching of dike will require
Dam Safety approval.
Waste
Site Suitability anticipated for offsite
Site Suitability Report
January 30, 2015
landfill must go through public
comment.
Must receive permit to begin
Permit -to -Construct
October 24, 2015
construction and corresponding
E&SC approval to cover approved
Construction design.
Must provide Construction Quality
Permit -to -Operate
June1, 2017
Assurance Report and then received
permit before operation.
Site Specific
Local
Nuisance/Noise/Odor/Other
N/A
No local nuisance requirements
Ordinances
Requirements including DOT and
identified.
FERC Requirements
17

Dan River Steam Station — Coal Sash Excavation Plan
November 13, 2014
XI. Contracting Strategy
The Ash Management Program strategy is to engage multiple contractors, to drive
competition, system wide innovation and the collection of best practices. During the
initial phase (Phase 1) of ash removal at Riverbend, L.V. Sutton, Dan River and
Asheville, the Company will award the excavation, transportation, and disposal of the
Ash to a single contractor for each site. The result may be two to three contractors, with
each contractor having responsibility for one, or two sites, working on a firm fixed per
ton price basis. The contracting strategy will shift for subsequent Phases, and
potentially during Phase 1, as the Company and the selected contractors recognize
enhancements that can increase productivity or drive unit cost lower. Duke Energy's
core values of safety and quality are non-negotiable and will not be compromised in
order to increase productivity or generate cost savings.
In summary, the Company's contracting strategy will provide the most effective
combination of ash removal, transportation, disposal, and beneficial reuse options
balancing strategic intent, cost, and schedule. The health and safety of workers, the
communities, and environment will not be sacrificed to achieve these goals.
XJI. Environmental, Health, and Safety Plan
Protecting workers, the public, the community, and the environment
The Company is committed to the health, safety and welfare of employees, contractors
and the public, and to protecting the environment and natural resources. During all
phases of the project work, the Company and its contractors will follow the Company
Safe Practices; the ABSAT Environmental, Health, and Safety (EHS) supplement
document, and any additional requirements. Occupational health and safety
expectations include oversight and continuous improvement throughout the project.
The project will include comprehensive environmental, health and safety plans
encompassing all aspects of the project work including at the plant, in transit and at the
final destination as needed. The project's commitment is to minimize public and
environmental impacts.
MI. Communications Plan
Many different external stakeholders including neighbors, government officials and
media have an interest in this project. For example, there is the potential for facility
neighbors and the general public to see or experience construction -related impacts
such as truck traffic, landscape changes, or noise. The Company is committed to
18

Dan River Steam Station — Coal Ash Excavation Plan
November 13, 2014
providing information by proactively communicating about the Project activities to
potentially affected parties and responding to inquiries in a timely manner.
The Project team will coordinate with Duke Energy's Corporate Communications
Department to develop a comprehensive external communications plan tailored to the
specific needs of each phase of the project.
19

Elan River Stem Station — Coal Ash Excavation Plan
i%!overnber 13, 2014
'NIV. Glossary
DefinitionTerm
ABSAT
Duke Energy organization acronym for Ash Basin Strategic Action Team
Ash Basin
Synonymous with Coal Combustion Residual Impoundment. A
topographic depression, excavation, or dammed area that is primarily
formed from earthen materials; without a base liner approved for use by
Article 9 of Chapter 130A of the General Statutes or rules adopted
thereunder for a combustion products landfill or coal combustion residuals
landfill, industrial landfill, or municipal solid waste landfill; and an Area that
is designed to hold accumulated coal combustion residuals in the form of
liquid wastes, wastes containing free liquids, or sludge, and that is not
backfilled or otherwise covered during periods of deposition.
Ash Ponds
Coal Combustion Residual stored in wet impoundments, or ponds
Ash Stack
Ash storage areas located north and west of the Primary and Secondary
Ash Basins.
Beneficial and
Projects promoting public health and environmental protection, offering
Beneficial Use
equivalent success relative to other alternatives, and preserving natural
resources
Bottom Ash
The agglomerated, angular ash particles formed in pulverized coal
furnaces that are too large to be carried in the flue gases and collect on
the furnace walls. Bottom Ash falls through open grates to an ash hopper
at the bottom of the furnace.
Bulk Water
Water above the ash contained in the ash basin. Synonymous with free
water
Coal Ash Excavation
Plan required by NC DENR letter dated August 13, 2014 including a
Plan
schedule for soil and sedimentation erosion control measures, dewatering,
and the proposed location of the removed ash
Coal Ash
North Carolina Session Law 2014-122
Management Act of
2014
Coal Combustion
Residuals, including fly ash, bottom ash, boiler slag, mill rejects, and flue
Residuals (CCR)
gas desulfurization residue produced by a coal-fired generating unit
Decanting
The act of removing water from ash
20

Dan River Steam Station — Coal Ash Excavation Plan
November 13, 2014
DefinitionTerm A
Dewatering
The act of removing bulk and entrapped water from the ash basin
Dewatering Plan
Engineered plan and the associated process steps necessary to dewater
an ash basin
Duke Safe Work
Document detailing the Duke Energy safety guidelines
Practices
Engineer of Record
Duke Energy or 3rd party contracted engineer responsible for final
verification of specific plan actions and documents
Entrapped Water
Flowable water below the ash surface which creates hydrostatic pressure
on the dam
Excavation Activities
Tasks and work performed related to the planning, engineering and
excavation of ash from an ash basin
Excavation Plan
Refer to Coal Ash Excavation Plan
Factor of Safety
In reference to dam safety, the ratio of the forces or moments resisting
mass movement to the forces or moments tending to produce mass
movement
Free Water
Water above the ash contained in the ash basin. Synonymous with bulk
water
Fly Ash
Very fine, powdery material, composed mostly of silica with nearly all
particles spherical in shape, which is a product of burning finely ground
coal in a boiler to produce electricity and is removed from the plant
exhaust gases by air emission control devices
Grading Plan
Document detailing the final elevation, drainage and lay of the excavated
area
Level 1 Schedule
Schedule view that shows the main milestones to complete the project
NPDES
National Pollutant Discharge Elimination System
NPDES Permit
A permit that regulates the direct discharge of wastewater to surface
waters
Off -Site Disposal
A structural fill or mine reclamation for the long term placement of coal
Facility
combustion residuals
Permitting
Federal, state, county or local government authorizing document
21

Dan River Steam Station — Coal i'--,sh Excavation Plan
November 13, 2014
Reference Documents
1 Letter to Duke Energy, Request for Excavation Plans August 13, 2014
2 Coal Ash Management Act of 2014 September 20, 2014
22

I.M. Sutton Electric Plant
Goal Ash Excavation Plan
(� DUKE
�. ENERGY

L.V Suttor's Electric Plant — Coal Ash Excavation Flan
November 13, 2014
Table of Conten.ts
I.
Statement of Purpose...................................................................................................................2
II.
General Facility Description.........................................................................................................4
III.
Project Charter...............................................................................................................................7
IV.
Critical Milestone Dates................................................................................................................9
V.
Level 1 Schedule.........................................................................................................................10
VI.
Erosion and Sedimentation Control Plan................................................................................11
VII.
Dewatering Plan..........................................................................................................................11
Vill.
Proposed Location(s) for Removed Ash..................................................................................12
IX.
Transportation Plan.....................................................................................................................13
X.
Environmental Permitting Plan..................................................................................................15
XI.
Contracting Strategy...................................................................................................................19
X11.
Environmental, Health, and Safety Plan..................................................................................19
X1I1.
Communications Plan.................................................................................................................19
XIV.
Glossary ........................................................................................................................................21
XV.
Reference Documents................................................................................................................23
1

L.V. Sutton Electric Plant -- Coal Ash Excavation Plan,
November 13, 2014
I. Statement of Purpose
Duke Energy Progress, Inc. (Duke Energy or the Company) is required by Section 3(b)
of the Coal Ash Management Act of 2014 to close in accordance of Section 3(c) the
coal combustion residuals (CCR) surface impoundments located at the L.V. Sutton
Electric Plant, National Pollutant Discharge Eliminations System Permit No.
#NC0001422 New Hanover County (Sutton) as soon as practicable, but not later than
August 1, 2019. Further, by letter to Duke Energy dated August 13, 2014, North
Carolina Department of Environment and Natural Resources (NC DENR) requested that
Duke Energy submit coal ash excavation plans for inactive coal ash impoundments at
Sutton no later than November 15, 2014 (NC DENR Letter).
This Coal Ash Excavation Plan (Plan). represents Phase I and other Subsequent
Phase(s) activities to satisfy the requirements outlined in Sections 3(b) and 3(c) Sub
paragraph 1 &2 of the Coal Ash Management Act of 2014 and the requests set forth in
the NC DENR Letter.
In general, the Plan covers the first 12 — 18 months of ash basin excavation activities,
including the initiation of basin dewatering, site preparation, ash basin preparation, and
ash removal from the basins. These activities may include decanting ash within the ash
basin system.
For Subsequent Phase(s), this document will be revised for any modifications to the
Plan for the site. The Plan will be updated and submitted to NC DENR annually or
earlier as required by Subsequent Phase(s).
The NC DENR letter specifically requests that the Plan include 1) a schedule for soil
and sedimentation erosion control measures, 2) dewatering, and 3) the proposed
location(s) of the removed ash. These requirements are found in Section V. Level 1
Schedule, Section VI. Erosion and Sedimentation Control Plans, Section VII.
Dewatering Plan, and Section Vill. Proposed Location(s) for Removed Ash.
The Plan covers some of the work required by Sections 3(b) and 3(c) of the Coal Ash
Management Act of 2014 (Session Law 2014-122) (Coal Ash Act, or 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. Additionally, it may become necessary for the Company to modify the Plan to
address other legal requirements or factors that develop during the ash basin
excavation. Any changes will be included in annual updates to the Plan that Duke
Energy will submit to NC DENR.
2

L.V. Sutton Electric Plant — Coal Ash Excavation Plan
November 13, 2014
The precise scope of work in excavating the ash basins will be determined by applicable
laws, rules, permits, and approvals that control the activities to be performed under the
Plan. For example, the United States Environmental Protection Agency (EPA) is
considering issuing rules regarding the management of coal ash (proposed EPA Coal
Ash Rules). Similarly, the water quality permit for the discharge from the Pond (National
Pollutant Discharge Elimination System Permit No. #NC0001422 New Hanover County
(Sutton) or its reissuance or amendment (NPDES Permit) could contain terms that
control or affect the scope of that work. NC DENR filed legal cases in Superior Court
(NC DENR Cases), which could be resolved through decision or settlement. NC DENR
also sent Duke Energy a Notices of Violation (NOVs) regarding surface water and
groundwater quality issues at the Plant.
All of the above (Coal Ash Act, NC DENR Letter, NPDES Permit, NC DENR Cases,
NOVs, and the proposed EPA Coal Ash Rules) are illustrative of actions that could
potentially affect the precise scope of the work to be performed under the Plan. As a
consequence, neither the submittal of this Plan nor its approval by NC DENR should be
taken as requiring actions different from other such applicable requirements. Thus,
Duke Energy submits this Plan to NC DENR based on the understanding that it may be
necessary to make changes in the Plan in the future to reflect any such actions and
reserves the right to make such changes after NC DENR's approval of the Plan.
3

L.V. Sutton Elect is Plint- — Coal Ash Excavaiion Flan
November 'i 3, 2014
II. General Facility Description
Sutton is located in New Hanover County near Wilmington, North Carolina, situated
between the Cape Fear River to the west and the Northeast Cape Fear River to the
east. Sutton was a three -unit, 575 megawatt (MW) coal-fired power plant. The Plant
operated from 1954 until retirement of the coal-fired units in November 2013. Upon
retirement of the coal-fired units a new 625 MW gas -fired unit began operations.
There are two CCR basins, the 1971 and 1984 basins, and a large Cooling Basin. The
Cooling Basin is accessible to the general public and is used for recreational purposes.
Two other areas that contain CCR material are the Lay of Land Area (LOLA) and the
1971 Borrow Area. The LOLA consists mostly of bottom ash and soil, while the 1971
Borrow Area consists of fly and bottom ash.
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, which was raised in 1983
to 26 feet mean sea level (MSL). An area underneath the footprint of the 1971 Basin
contains additional CCR materials and is referred to as the 1971 Borrow Area. The
1971 Basin and the Borrow Area contain approximately 3.5 million tons of CCR
material.
1984 Ash Basin
The 1984 Basin was operated from 1984 to 2013. Both the 1984 and 1971 Basins
contain fly ash, bottom ash, boiler slag, stormwater, ash sluice water, coal pile runoff,
and low volume wastewater. The 1984 Basin was constructed with a 12 inch thick clay
liner at the basin bottom which extended 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 was constructed within the 1984 Basin with a crest elevation
of 42 feet MSL. Currently, the 1984 Ash Basin contains approximately 2.8 million tons of
CCR material.
WOM
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 the plant operations between
approximately 1954 and 1972. A significant portion of this area toward the discharge
canal is heavily vegetated while the portion adjacent to the coal pile storage was used
to locate fuel oil storage tanks. The LOLA is on the North Carolina Inactive Hazardous
4

L.V. Sutton Electric Plant — Coal Ash E;scavation Plan
November 13, 2014
Waste Sites Priority List. This area contains approximately 840 thousand tons of CCR
and soil mixture at depths of 2 to 15 feet.
Current Operating Permit Details
The Cooling Basin, 1971 Basin and 1984 Basin are operated under the State of North
Carolina National Pollutant Discharge Elimination System (NPDES) permit number
NC0001422 to regulate effluents to the Cape Fear River. Additionally, the dams of the
Cooling Basin, 1971 Basin and 1984 Basin, are listed under the NC DENR 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. Furthermore, the
dam inventory lists the cooling basin and 1971 dams as exempt. The 1984 dam is
listed as impounding, hence regulated. These dams are rated as low hazard by NC
DENR. The 2006 Interior Containment Area 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.
5

L)i8uttonElectric Plant — Coal Ash Excavation Plan
RQureY: LV.Sutton Electric Plant |nNew Hanover County (WC0UO1422
A

L.V. Sort'Lcn Eleciric Plant - Coal Ash Excavation Plan
November 13, 2014
Ill. Project Charter
As a further commitment, the Company has formed an internal team, the Ash Basin
Strategic Action Team (ABSAT). This team is dedicated to strengthening and executing
a comprehensive strategy for increased oversight and closure of all of the Company's
ash basins.
Dewatering of the ash basins and the removal of ash from the site will be performed
within project phases, Phase I and Subsequent Phase(s). Required permits for each
phase are set forth in Section X of this Plan. Phase I will include site preparation,
dewatering, ash excavation to an off -site location, and complete any other subsequent
permitted activities. The excavation will begin with the approval of this Plan by NC
DENR and the receipt of final permits.
In addition, a dewatering plan for the ash basins has been drafted and, if approved by
NC DENR, bulk dewatering will be expedited during the initial phase of work. Duke
Energy has submitted an application to modify its NPDES wastewater permit to include
controls to be implemented during dewatering activities.
During Phase I, the Company will continue to perform the pre -construction and planning
activities for the Subsequent Phase(s). These activities include project planning,
development of new storage options, and completion of additional required permitting
that may be necessary for the ash removal from the ash basins. Knowledge and
opportunities for program improvement obtained during Phase I of the project will be
applied to the Subsequent Phase(s).
This Plan will begin 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
Management Act. Permits to construct and operate the landfill must be received no
later than December 23, 2015 and August 1, 2016; respectively, in order to make the
on -site landfill a viable option to comply with the mandatory closure date of August 1,
2019.
N

L.V Sutton Electric Plant — Coal Ash Excavation Plun
November 13, 2014
Project Charter Objectives
Phase I Objectives
1. Initiate the removal of ash from the Sutton site
2. Begin dewatering of the ash basins
3. Development of option(s) for proposed ash disposal or beneficial reuse locations
4. Gain knowledge and opportunities for program improvement that can be applied
to the Subsequent Phase(s)
5. Complete a work scope and award a contract to support ash basin closure by
August 2019
6. Validate production rates to meet project requirements
7. Initiate the development and permitting of the on -site landfill
8. Obtain permit to construct on -site landfill by December 23, 2015
Subsequent Phase(s) Objectives
1. Dewater the ash basins
2. Remove ash from the 1971 Basin, 1984 Basin, and the LOLA area
3. Obtain permit to operate the on -site landfill by August 1, 2016
4. Construct and operate the on -site landfill if viable
Project Charter Scope
Phase I Scope
1. Finalize off -site end location for ash relocation
2. Obtain all applicable permits for Phase 1
3. Install required site haul roads
4. Prepare and install rail load out spur for transportation by rail
5. Prepare and install truck load out and truck wash for transportation by truck
6. Install site erosion control and sediment control measures
7. Perform site preparation for ash basin ash removal
8. Perform site preparation for the basin dewatering (both 1971 basin & 1984 basin)
9. Begin bulk dewatering of the 1984 Basin
10. Excavate and transport approximately 2.0 million tons of ash from the 1984 Basin
and the 1971 Basin to an approved landfill or structural fill location
11. Engineer plan to stop water inputs into the ash basins
12. Initiate rerouting or elimination of inflows to the ash basins
13. Start installation of the basin and lake isolation measures along Sutton Cooling
Lake and the discharge canal
14. Finish the engineering for the on -site landfill
15. Modify the lease arrangement for public boat ramp access and install alternate
access
16. Initiate landfill development for the on -site landfill
9

L.V. Sutton Electric Plant — Coal Ash Excavation Plan
Noy; rnoer 13, 2014
17. Begin site preparation activities for Subsequent Phase(s)
18. Plan activities for Subsequent Phase(s) and submit an updated Plan
Subsequent Phase(s) Scope
1. Identify and/or develop additional off -site ash storage options
2. Obtain all required permits for on -site land fill development
3. Construct and operate the on -site landfill
4. Continue to excavate and transport remaining ash from Sutton to an on -site
landfill or structural fill location
5. Obtain all remaining required permits for next Subsequent Phase activities
6. Complete activities to stop basin inflows
7. Complete basin dewatering
8. Install discharge canal isolation measures around the LOLA area
9. Excavate and transport the material from the LOLA area
Complete closure activities as outlined in Sections 3(b) And 3(c) Subparagraphs
1 &2 of the Coal Ash Management Act of 2014
IV. Critical Milestone Cates
Critical Milestones within the Plan are summarized in the table below. These
milestones have been added to the Level 1 Schedule.
MILESTONES■ LATER THAN D.
Submit Excavation Plan November 15, 2014
Complete comprehensive engineering review
November 30, 2014
Excavation Plan Approval
February 17, 2015
Industrial Stormwater Permit
February 18, 2015
Commence work — ash removal
Final permit approval + 60 Days
Receive Permit to Construct On -site Landfill
December 23, 2015
Submit Updated Excavation Plan — Subsequent
Phase(s)
December 31, 2015
Receive Permit to Operate On -Site Landfill
August 1, 2016
Eliminate stormwater discharge into impoundments
December 31, 2018
Impoundments closed per Sections 3(b) and 3(c) of
the Coal Ash Management Act of 2014
August 1, 2019
M

L.V- Sutton Electric Plant —Coal Ash Ex,--,,3tiun PLin
Novcnib�;- 13, 2014
V. Level I Schedule
Sution k0i Pond Cls Project Sutton Ash Pond Closure Project PrO DaX, 10-18-14 10:19
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Note: This Level 1 Schedule is a living element of this Plan. Dates and durations are based on known information on the
date of this Plan.
10

L.V. Sutton Electric Plant— Coal Ash Excavation Plan
November 13, 2014
VI. Erosion and Sedimentation Control Plan
The Erosion and Sedimentation Control Plan (E&SC) for the excavation of ash is being
developed and planned for submittal by January 30, 2015. The approval of this plan by
NC DENR will meet the requirement outlined in the NC DENR Letter.
Any deviations from the current E&SC for Subsequent Phase(s) will be approved by NC
DENR prior to installation and initiation of subsequent phase work.
The approved contractor will install the E&SC measures indicated in the plan. The
Engineer of Record will review the installation prior to commencing excavation on site.
All control measures will be maintained through the project in accordance with the
E&SC.
V11. Dewatering pian
The Sutton ash basins will be dewatered to facilitate the removal of ash and to mitigate
risk. Dewatering the free water will improve the physical properties of the retained ash,
making it less susceptible to flow in the event of an unexpected dam failure.
Engineering analysis has shown that lowering the water below the level of ash within
each basin does not improve the factor of safety (FS) against failure of the associated
dam; therefore removal of entrapped water is not required.
An Engineered Dewatering Plan for Sutton was developed. This plan details the
removal of the following water:
Sequence
1. 1971 Basin — Removal of free water
Based on data from July 2014, the 1971 Basin contains approximately 362
thousand gallons of free water. The free water in the 1971 Basin will be pumped
to the 1984 Basin. The maximum free water drawdown rate will be one foot over
seven days. Following free water removal, accumulated stormwater will be
removed at a maximum rate of 2 feet over 1 day.
2. Interior Containment Area— Removal of free water
The 2006 ICA has accumulated an undetermined amount of free water during the
summer of 2014. The free water in the 2006 ICA will be drained to the 1984
Basin. The maximum free water drawdown rate will be one foot over seven
days. Following free water removal, the accumulated stormwater will be
removed at a maximum rate of 2 feet over 1 day.
11

L.V. Sutton Electric Plant— Coal Ash Excavation Plan
November 13, 2014
3. 1984 Basin — Removal of free water
Based on data from July 2014, the 1984 Basin contains approximately 65 million
gallons of free water. The maximum free water drawdown rate will be one foot
over seven days. Following free water removal, accumulated stormwater will be
removed at a maximum rate of 2 feet over 1 day.
VIII. Proposed Location(s) for Removed Ash
Phase I of the Plan will include the excavation and removal of approximately 2.0 million
tons of ash from Sutton. Subsequent Phase(s) will remove the remaining ash at the
site. Ash removed from the site will be transported by the contractor to properly
permitted facilities. The ash storage placement will be properly managed and
maintained to ensure environmental compliance with all applicable rules and
regulations.
Phase l: Ash Disposition Sites
For Phase I, Brickhaven Mine located in Moncure, North Carolina has been identified for
ash placement. This primary option provides a solution for Phase I and/or Subsequent
Phase(s).
Brickhaven Mine
The mine is located near the city of Moncure in Chatham County of North Carolina. The
mine resides on approximately 299 acres. Its primary mined minerals are clays. Ash
will be transported to the mine as a reclamation project. The Brickhaven Mine will
comply with the requirements set forth in Sections 4(b) and (c) of the Coal Ash
Management Act of 2014.
Contingent Plan: Ash Disposition Sites
In the event of any issues with accepting ash at the Brickhaven Mine, the Sanford Mine
has been determined as a suitable site. All necessary steps will be taken to assure that
the Sanford Mine is ready to accept ash in the event of any issues at the Brickhaven
Mine.
12

L.V. SLItton Electric Plait— coal Ash Excavation Plan
Ncv4mher 13, 2014
Sanford Mine
The Sanford Mine is located in Sanford, North Carolina. Ash will be transported from
Sutton to the Sanford Mine as a reclamation project.
Structural Fill Alternative
In the event the structural fill options are not available, the Anson County Landfill, a
permitted solid waste landfill, has been identified as the alternate location. The Anson
County Landfill is located in Polkton, NC. Material will be transported by rail.
Subsequent Phase(s): Ash Disposition Sites
The project team will utilize lessons learned from Phase I to develop an off -site disposal
strategy and/ or alternative beneficial reuse site(s) that will provide the improvements
below.
• Provide a reliable, long-term, cost effective, solution for ash designated for
removal
• Develop a supplier diverse Program to drive innovation and competition
• Establish performance baselines and the system to optimize pickup, transport,
drop-off and reuse
IX. Transportation Alan
Ash will be transported from the site, via rail car to the off -site facility. Transportation of
the CCR will be conducted by approved transporters and meet DOT and other
applicable federal, state, and local regulations.
Phase 1: Transportation
For Phase 1, all CCRs will be transported by rail from Sutton to Brickhaven site. Trains
will consist of 110 gondola cars at 100 tons per car. One train will leave the site every
other day or 3 to 3.5 trains per week on average. The operation of loading rail cars will
be completed with a crew working typically 12 hours per day, 7 days per week. Plans
are being made to design and install a rail loading system at Sutton that would transport
ash to the Brickhaven Mine.
13

L.V. Sutton Electric Plant-- Coal Ash Excavation Plan
November 13, 2014
01
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Figure 2: Typical Truck Route to Brickhaven Mine
Contingent Plan. Transportation
To support the transportation of ash for the Contingent Plan, ash will be transported to
the Sanford Mine (see Figure 3) instead of the Brickhaven Mine. In the event of rail
transportation disruption, truck transportation remains a contingency option for either
Brickhaven or Sanford. The workforce, tonnages, and schedules would remain the
same as described above.
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Figure 3: Typical Truck Route to Sanford Mine
Subsequent Phase(s): Transportation
The transportation plan and any other options will be reviewed and could be amended
in Subsequent Phase(s) to enhance the excavation process and objectives.
14

L..V. Sutton Electric Plan— Coal Asti Excavation Plan
November 13, 2011.4
X. Environmental Permitting Man
Phase l
Phase 1 will include initiating excavation and removal of ash from the 1984 ash basin
and the 1971 ash basin to an offsite location. Implementation for Phase I can begin
once the permitting for Phase I is in place, although different permitting may be
necessary prior to initiating Subsequent Phase work. Phase I will include permitting
activities for subsequent phases.
Through the Excavation Plan approval process, Duke Energy is seeking to confirm that
all necessary approvals have been identified. The Excavation Plan is intended to
authorize the excavation and movement of ash once the identified permits have been
obtained.
Excavation of ash creates potential for stormwater impacts. NC DENR has indicated an
industrial stormwater permit may be needed. Sutton Plant has no discharges consisting
of stormwater only and has therefore not submitted Form 2F applications for industrial
stormwater coverage. Stormwater is combined with wastewater and permitted under
the current NPDES permit. It is not anticipated that excavation will create new separate
stormwater discharges. A stormwater pollution prevention plan (SWPPP) incorporating
best management practices (BMPs) will be created, if necessary. Future modifications
to the permit/plan will be managed as necessary.
NC DENR has recently indicated that modification of the NPDES wastewater permit
may be required to initiate removal of free water from inactive ash basins. The
Company is submitting additional information to NC DENR for its consideration to
support incorporating dewatering requirements into the pending the Company's pending
NPDES permit application. The Company is working with United States Environmental
Protection Agency (EPA) and NC DENR with a goal of identifying the regulatory
framework that will allow the removal of free-standing water from inactive basins to
move forward.
There are no jurisdictional wetlands/streams associated with the removal of ash in the
1984 ash basin and the 1971 ash basin in Phase I. Future wetland/stream impacts and
jurisdictional determinations will be managed through the US Army Corps of Engineers
with particular attention paid to the difference between jurisdictional wetlands/streams
under Section 404 and those arising from Section 402 waters.
Before creation of new mine reclamation structural fills, an individual structural fill permit
will need to be obtained by the mine reclamation project owner/operator. It is
anticipated that the mining permit will be transferred from the existing mine owner to a
15

L.V. Sutton Electric Plant— Coal Ash Excavation Plan
November 13, 201,4
mine reclamation contractor. Once the permit is transferred, the mine reclamation
contractor will submit an individual structural permit application and mine reclamation
plan to the Division of Mining. It is anticipated that the Division of Mining will then
forward the reclamation plan to the Division of Water Resources, Division of Waste
Management, and other divisions as necessary, for comments. Subject to any changes
from Division of Mining, the revised reclamation plan would be approved and an
individual Structural Fill Permit will be issued.
No information currently exists to indicate that the Sutton ash should be treated as a
DOT hazardous material shipped via truck or rail.
Subsequent Phase(s) will include dewatering (once NPDES permit modification
complete) and continued excavation and removal of ash from the 1984 and 1971 ash
basins and the LOLA area. Subsequent Phase(s) also potentially include(s) the
construction of an on -site landfill.
Future jurisdictional determinations will be managed through the US Army Corps of
Engineers with particular attention paid to the difference between jurisdictional
wetlands/streams under Section 404 and those arising from Section 402 waters. Any
Section 404 individual permitting will require Section 401 Water Quality Certification by
NC DENR.
If used, before shipping ash to a third -party Subtitle D landfill, waste characterization
and approval will be completed. All necessary Dam Safety approvals will be obtained to
cover activities on or around jurisdictional dams. Breaching of the dams will require
Dam Safety approval. Any impacted wells or piezometers will be properly abandoned
and dispositioned with NC DENR. Fugitive dust will be managed to mitigate impacts to
neighboring areas. Impacts to threatened and endangered species will be avoided.
No additional site -specific or local requirements have been identified.
16

L,11, Sutton Electric Plant— Coal Ash Excavation Plan
ilovember 13, 201.4
Phase l Permit Matrix
Media
Permit
Milestone/ Target
Reasoning
Date
Excavation of ash creates
potential for stormwater
impacts. The facility will seek
an approved E&SC and
associated Construction
Stormwater Permit approval for
ash stack removal. NC DENR
Industrial Stormwater NPDES
has indicated an industrial
Permit
February 18, 2015
stormwater permit may also be
needed. Sutton Plant has no
discharges consisting of
stormwater only. Stormwater is
combined with wastewater and
permitted under the current
Water
NPDES permit. A SWPPP
incorporating BMPs will be
created, if necessary.
NC DENR has indicated
dewatering activities including
free water removal, may require
Wastewater NPDES Permit —
NPDES wastewater permit
Minor Modification
March 27, 2015
modification. Based on this
requirement, Duke Energy is
submitting proposed dewatering
permit conditions in its pending
NPDES permit application.
Jurisdictional Wetland and
There are no identified
Stream Impacts/ 404 Permitting
N/A
jurisdictional wetland/stream
and 401 WQC
impacts in Phase I.
Hauling and excavation
activities must not impact a
jurisdictional dam or dike.
Activities are initially staying
Dam Safety Approvals
May 29, 2015
away from the jurisdictional
dike. Removing ash from the
1971 and 1984 Ash Basins will
Waste
have to be reviewed with Dam
Safety. Breaching of dike will
require Dam Safety approval.
Mine Reclamation
Owner/Operator to obtain a
Individual Structural Fill Permit
May 29, 2015
structural fill permit as set forth
in Subpart 3 of Part 2 of Article
9 of the Coal Ash Management
Act.
Site Specific
Local
Nuisance/Noise/Odor/Other
NIA
No local nuisance requirements
Ordinances
Requirements including DOT
identified.
and FERC Requirements
17

L.V. Sutton Electric Plant— Coal Ash Excavation Plan
November 13, 2014
Subsequent Phase(s) Permit Matrix
Media
Permit
Milestone/ Target
Reasoning
Date
Excavation of ash creates potential
for stormwater impacts. The facility
will seek an approved E&SC and
associated Construction Stormwater
Permit approval for ash stack
removal. NC DENR has indicated an
Industrial Stormwater NPDES
February 18, 2015
industrial stormwater permit may also
Permit
be needed. Sutton Plant has no
discharges consisting of stormwater
only. Stormwater is combined with
wastewater and permitted under the
current NPDES permit. A SWPPP
incorporating BMPs will be created, if
necessary.
Water
NC DENR has indicated dewatering
activities including free water
removal, may require NPDES
Wastewater NPDES Permit
October 30, 2015
wastewater permit modification.
Major Modification
Based on this requirement, Duke
Energy is submitting proposed
dewatering permit conditions in its
pendinq NPDES permit application.
Identify if project scope results in
impacts to jurisdictional wetlands or
Jurisdictional Wetland and Stream
streams. Obtain JD and pursue 404
Impacts/ 404 Permitting and 401
October 30, 2015
Permit for impacts from ALOE. Also,
WQC
404 permits are required for working
below the ordinary high water mark.
If Federal individual permitting is
required, obtain 401 WQC.
Mine Reclamation Owner/Operator to
Individual Structural Fill Permit
May 29, 2015
obtain a structural fill permit as set
forth in Subpart 3 of Part 2 of Article 9
of the Coal Ash Management Act.
Hauling and excavation activities
must not impact a jurisdictional dam
Dam Safety Approvals
October 30, 2015
or dike. Activities are initially staying
50 feet away from the jurisdictional
dike. Breaching of dike will require
Waste
Dam Safety approval.
Site Suitability anticipated for offsite
Site Suitability Report
March 31, 2015
landfill must go through public
comment.
Must receive permit to begin
Permit -to -Construct
December 23, 2015
construction and corresponding
E&SC approval to cover approved
Construction design.
Must provide Construction Quality
Permit -to -Operate
August 1, 2016
Assurance Report and then received
permit before operation.
Site Specific
Local
Nuisance/Noise/Odor/Other
N/A
No local nuisance requirements
Ordinances
Requirements including DOT and
identified.
FERC Requirements
18

L.V. Sutton Electric Plant— Coal rash Excavation Plan
November 13, 2014
X1. Contracting Strategy
The Ash Management Program strategy is to engage multiple contractors, to drive
competition, system wide innovation and the collection of best practices. During the
initial phase (Phase 1) of ash removal at Riverbend, L.V. Sutton, Dan River and
Asheville, the Company will award the excavation, transportation, and disposal of the
Ash to a single contractor for each site. The result may be two to three contractors, with
each contractor having responsibility for one, or two sites, working on a firm fixed per
ton price basis. The contracting strategy will shift for Subsequent Phase(s), and
potentially during Phase 1, as the Company and the selected contractors recognize
enhancements that can increase productivity or drive unit cost lower. Duke Energy's
core values of safety and quality are non-negotiable and will not be compromised in
order to increase productivity or generate cost savings.
In summary, the Company's contracting strategy will provide the most effective
combination of ash removal, transportation, disposition, and beneficial reuse options
balancing strategic intent, cost, and schedule. The health and safety of workers, the
communities, and environment will not be sacrificed to achieve these goals.
XII. Environmental, Health, and Safety Plan
Protecting workers, the public, the community and the environment
The Company is committed to the health, safety and welfare of employees, contractors
and the public, and to protecting the environment and natural resources. During all
phases of the project work, the Company and its contractors will follow the Company
Safe Practices; the ABSAT Environmental, Health, and Safety (EHS) supplement
document, and any additional requirements. Occupational health and safety
expectations include oversight and continuous improvement throughout the project.
The project will include comprehensive environmental, health and safety plans
encompassing all aspects of the project work including at the plant, in transit and at the
final destination as needed. The project's commitment is to minimize public and
environmental impacts.
X111. Communications Plan
Many different external stakeholders including neighbors, government officials and
media have an interest in this project. For example, there is the potential for facility
neighbors and the general public to see or experience construction -related impacts
such as truck traffic, landscape changes, or noise. The Company is committed to
19

L.V. Sutton Electric Plane— Coal Ash Excavation Plan
November 13, 201zi
providing information by proactively communicating about the Project activities to
potentially affected parties and responding to inquiries in a timely manner.
The Project team will coordinate with Duke Energy's Corporate Communications
Department to develop a comprehensive external communications plan tailored to the
specific needs of each phase of the project.
20

L.V. Sutton Electric Pl;,nt— Coal Ash Excavation Plan
November 13, 2014
XIV. Glossary
Term
Definition
ABSAT
Duke Energy organization acronym for Ash Basin Strategic Action Team
Ash Basin
Synonymous with Coal Combustion Residual Impoundment. A
topographic depression, excavation, or dammed area that is primarily
formed from earthen materials; without a base liner approved for use by
Article 9 of Chapter 130A of the General Statutes or rules adopted
thereunder for a combustion products landfill or coal combustion
residuals landfill, industrial landfill, or municipal solid waste landfill; and
an Area that is designed to hold accumulated coal combustion residuals
in the form of liquid wastes, wastes containing free liquids, or sludge, and
that is not backfilled or otherwise covered during periods of deposition.
Ash Ponds
Coal Combustion Residual stored in wet impoundments, or ponds
Ash Stack
An ash feature external to the ash basin
Beneficial and
Projects promoting public health and environmental protection, offering
Beneficial Use
equivalent success relative to other alternatives, and preserving natural
resources
Bottom Ash
The agglomerated, angular ash particles formed in pulverized coal
furnaces that are too large to be carried in the flue gases and collect on
the furnace walls. Bottom Ash falls through open grates to an ash
hopper at the bottom of the furnace.
Bulk Water
Water above the ash contained in the ash basin. Synonymous with free
water
Coal Ash
Plan required by NC DENR letter dated August 13, 2014 including a
Excavation Plan
schedule for soil and sedimentation erosion control measures,
dewatering, and the proposed location of the removed ash
Coal Ash
North Carolina Session Law 2014-122
Management Act of
2014
Coal Combustion
Residuals, including fly ash, bottom ash, boiler slag, mill rejects, and flue
Residuals (CCR)
gas desulfurization residue produced by a coal-fired generating unit
Decanting
The act of removing water from ash
Dewatering
The act of removing bulk and entrapped water from the ash basin
21

L.V. Sutton Electric Plant— Coal Ash Excavation Plan
Novernber i3, 2014
Definition
Dewatering Plan
Engineered plan and the associated process steps necessary to dewater
an ash basin
Duke Safe Work
Document detailing the Duke Energy safety guidelines
Practices
Engineer of Record
Duke Energy or 3rd party contracted engineer responsible for final
verification of specific plan actions and documents
Entrapped Water
Flowable water below the ash surface which creates hydrostatic pressure
on the dam
Excavation
Tasks and work performed related to the planning, engineering and
Activities
excavation of ash from an ash basin
Excavation Plan
Refer to Coal Ash Excavation Plan
Factor of Safety
In reference to dam safety, the ratio of the forces or moments resisting
mass movement to the forces or moments tending to produce mass
movement
Free Water
Water above the ash contained in the ash basin. Synonymous with bulk
water
Fly Ash
Very fine, powdery material, composed mostly of silica with nearly all
particles spherical in shape, which is a product of burning finely ground
coal in a boiler to produce electricity and is removed from the plant
exhaust gases by air emission control devices.
Grading Plan
Document detailing the final elevation, drainage and lay of the excavated
area
Level 1 Schedule
Schedule view that shows the main milestones to complete the project
LOLA
Lay of Land Area
NPDES
National Pollutant Discharge Elimination System
NPDES Permit
A permit that regulates the direct discharge of wastewater to surface
waters
22

L.V..Sutton El--ctric Plant— Coal Ash Excavation Plan
November 13, 2014
XV. Reference Documents
23

Riverbend steam station
Coal Ash Excavation Plan
(� DUKE
ENERGY.

Riverbend Steam Station — Coal Ash Excavation Plan
dove nbcr 13, 2014
Table of Contents
I.
Statement of Purpose...................................................................................................................2
11.
General Facility Description...........................................................
III.
Project Charter...............................................................................................................................7
IV.
Critical Milestone Dates................................................................................................................9
V.
Level 1 Schedule.........................................................................................................................10
VI.
Erosion and Sedimentation Control Plan................................................................................11
VII.
Dewatering Plan..........................................................................................................................11
Vill.
Proposed Location(s) for Removed Ash..................................................................................12
IX.
Transportation Plan.....................................................................................................................14
X.
Environmental Permitting Plan..................................................................................................16
XI.
Contracting Strategy...................................................................................................................21
XII.
Environmental, Health, and Safety Plan..................................................................................21
XIII.
Communications Plan.................................................................................................................21
XIV.
Glossary ........................................................................................................................................23
XV.
Reference Documents................................................................................................................25
1

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
I. Statement of Purpose
Duke Energy Carolinas, LLC (Duke Energy or the Company) is required by Section 3(b)
of the Coal Ash Management Act of 2014 to close in accordance of Section 3(c) the
coal combustion residuals (CCR) surface impoundments located at the Riverbend
Steam Station, National Pollutant Discharge Eliminations System Permit No.
NC0004961 Gaston County (Riverbend) as soon as practicable, but not later than
August 1, 2019. Further, by letter to Duke Energy dated August 13, 2014, North
Carolina Department of Environment and Natural Resources (NC DENR) requested that
Duke Energy submit coal ash excavation plans for inactive coal ash impoundments at
Riverbend no later than November 15, 2014 (NC DENR Letter).
This Coal Ash Excavation Plan (Plan) represents Phase I and other Subsequent
Phase(s) activities to satisfy the closure requirements outlined in Sections 3(b) and 3(c)
sub paragraph 1 &2 of the Coal Ash Management Act of 2014 and the requests set forth
in the NC DENR Letter.
In general, the Plan covers the first 12 —18 months of ash basin excavation activities,
including the initiation of basin dewatering, ash stack removal, and any other permitted
ash removal activities within the ash basins and/or Cinder Pit Area. These activities
may include decanting ash within the ash basin system. The areas within the Ash Basin
include the Primary Ash Basin, the Secondary Ash Basin, and the Ash Stack.
For Subsequent Phase(s), this document will be revised for any modifications to the
Plan for the site. The Plan will be updated and submitted to NC DENR annually or
earlier as required by Subsequent Phase(s).
The NC DENR letter specifically requests that the Plan include 1) a schedule for soil
and sedimentation erosion control measures, 2) dewatering, and 3) the proposed
location(s) of the removed ash. These requirements are found in Section V. Level 1
Schedule, Section VI. Erosion and Sedimentation Control Plans, Section VII.
Dewatering Plan, and Section VIII. Proposed Location(s) for Removed Ash.
The Plan covers some of the work required by Sections 3(b) and 3(c) of the Coal Ash
Management Act of 2014 (Session Law 2014-122) (Coal Ash Act, or 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 basin, its ultimate approval is
an action not specifically required by statutory, regulatory or other applicable authority.
Additionally, it may become necessary for the Company to modify the Plan to address
other legal requirements or factors that develop during ash basin excavation. Any
2

Rivvrbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
changes will be included in annual updates to the Plan that Duke Energy will submit to
NC DENR.
The precise scope of work in excavating the ash basins will be determined by applicable
laws, rules, permits, and approvals that control the activities to be performed under the
Plan. For example, the United States Environmental Protection Agency (EPA) is
considering issuing rules regarding the management of coal ash (proposed EPA Coal
Ash Rules). Similarly, the water quality permit for the discharge from the Pond (National
Pollutant Discharge Elimination System Permit No. #NC0004961 Gaston County) or its
reissuance or amendment (NPDES Permit) could contain terms that control or affect the
scope of that work. NC DENR filed legal cases in Superior Court (NC DENR Cases),
which could be resolved through decision or settlement. NC DENR also sent Duke
Energy a Notices of Violation (NOVs) regarding surface water and groundwater quality
issues at the Plant.
All of the above (Coal Ash Act, NC DENR Letter, NPDES Permit, NC DENR Cases,
NOVs, and the proposed EPA Coal Ash Rules) are illustrative of actions that could
potentially affect the precise scope of the work to be performed under the Plan. As a
consequence, neither the submittal of this Plan nor its approval by NC DENR should be
taken as requiring actions different from other such applicable requirements. Thus,
Duke Energy submits this Plan to NC DENR based on the understanding that it may be
necessary to make changes in the Plan in the future to reflect any such actions and
reserves the right to make such changes after NC DENR's approval of the Plan.
3

Riverbend Stearn Station — Coal Ash Excavation Plan
November 13, 2014
II. General Facility Description
Riverbend is located off of Horse Shoe Beach Road near the town of Mt. Holly in
Gaston County, North Carolina, on the south bank of the Catawba River. The seven -
unit station began commercial operation in 1929 with two units and then expanded to
seven by 1954. At its peak, the generating facility had a capacity of 454 megawatts. As
of April 1, 2013, all of the coal-fired units were retired.
The CCR from Riverbend's coal combustion operations was historically processed in
the ash basin system located on the northeast of the property adjacent to the Catawba
River. The discharge from the ash basin system is permitted through Outfall #002 to
the Catawba River in the Catawba River Basin by NC DENR's Division of Water
Resources (DWR) under the National Pollutant Discharge Elimination System (NPDES)
Permit # NC0004961. Currently, Riverbend is being decommissioned, and no active
ash placement or sluicing is occurring within the ash basin system.
Ash Basin System
The ash basin system was an integral part of the station's NPDES permitted wastewater
treatment system, which predominantly received inflows from the ash removal system,
station yard drain sump, and stormwater flows. During station operations, inflows to the
ash basin were highly variable due to the cyclical nature of station operations. The
current ash basin system consists of a Primary Ash Basin cell (west side) and a
Secondary Ash Basin cell (north side), which are separated by an intermediate dam.
For the purpose of stormwater management, the Ash Stack is also within the ash basin
system.
The ash basin system is located approximately 2,400 feet to the northeast of the power
plant, adjacent to the Catawba River, as shown on Figure 1. The Primary Ash Basin
cell is impounded by an earthen embankment dam, referred to as Primary Dam
#GASTO-97, located on the west side of the Primary Ash Basin cell. The Secondary
Ash Basin cell is impounded by an earthen embankment dam, referred to as Secondary
Dam #GASTO-98, located along the northeast side of the Secondary Ash Basin cell.
Originally, the ash basin at Riverbend consisted of a single -cell basin commissioned in
1957. It was expanded in 1979 to its current configuration. In 1979, the original single
basin was divided by constructing a divider dam (Intermediate Dam #GASTO-99) to
form two separate cells (Primary Ash Basin and Secondary Ash Basin). This
modification improved the original pond's overall ability for suspended solids removal.
The Intermediate Dam was built over sluiced ash to a crest of 730 feet. At the same
time, the Secondary Dam crest elevation remained at 720 feet. At present, the Primary
Ash Basin and the Secondary Ash Basin are estimated to contain approximately 2.1
million and 700 thousand tons of CCR, respectively.
4

Diver band Stearn Station — Coal Ash Excavation Plan
November 13, 2014
The inflows from the ash removal system and the station yard drain sump are directed
through sluice lines into the Primary Ash Basin cell. The discharge from the Primary
Ash Basin to the Secondary Ash Basin is through a concrete discharge tower located
near the divider dam. The surface area of the Primary Ash Basin is approximately 41
acres with an approximate maximum pond elevation of 724 feet above mean sea level.
The surface area of the Secondary Ash Basin is approximately 28 acres with an
approximate maximum pond elevation of 714 feet above mean sea level. The full pond
elevation of Mountain Island Lake is approximately 647 feet above mean sea level.
Although the station is retired, stormwater and wastewater effluent from other non -ash -
related station flows to the ash basin are discharged in compliance with the station's
NPDES permit to Catawba River through a concrete discharge tower located in the
Secondary Ash Basin. The concrete discharge tower drains through a 30 inch diameter
corrugated metal pipe (CMP) into a concrete -lined channel. The channel extends from
the Secondary Ash Basin to an NPDES Outfall #002 that discharges to the Catawba
River. The Secondary Ash Basin elevation is controlled by the use of concrete stop
logs.
Ash Stack
An ash fill deposit, known as the "Ash Stack", was constructed from ash removed from
the Primary and Secondary Ash Basins during basin clean -out projects. The Ash Stack
was utilized for the ash basin cleanouts periodically to prolong the life of the ash basins.
The Ash Stack is a 29 acre area located south of the Primary Ash Basin and is
estimated to contain 1.5 million tons of CCR. The Ash Stack was constructed during
two ash basin clean -outs; the last recorded ash basin cleanout project was in 2007.
The Ash Stack area currently has a 1.5 — 2.0 ft. soil cover and vegetation that has been
maintained following the last deposition in this area. For the purpose of water
management, the stormwater run-off from the Ash Stack area is routed to the ash basin
system.
Cinder Pit And Other Identified Ash Storage Areas
Prior to construction of the ash basin, bottom ash (cinders) were deposited in a primarily
dry condition in the "Cinder Pit" and other areas near the cinder pit and coal pile. The
Cinder pit is approximately 13 acres and is located in a triangular area northeast of the
coal pile and northwest of the rail spur (See Figure 1). This area was utilized for
storage of ash material at the station prior to the installation of precipitators and a wet
sluicing system. The Cinder Pit contains predominantly dry cinders and is currently
covered with dense vegetation. The Cinder Pit is estimated to contain 300 thousand
tons of CCR.
5

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
Figure 1: Riverbend Steam Station

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
III. Project Charter
As a further commitment, the Company has formed an internal team, the Ash Basin
Strategic Action Team (ABSAT). This team is dedicated to strengthening and executing
a comprehensive strategy for increased oversight and closure of all of the Company's
ash basins.
Dewatering of the ash basins and the removal of ash from the site will be performed
within project phases: Phase I and Subsequent Phase(s). Required permits for each
phase are set forth in Section X of this Plan. Phase I will include the initial removal of
ash from the Ash Stack, begin bulk dewatering, and complete any other subsequent
permitted activities. The excavation will begin with the approval of this Plan by NC
DENR and the receipt of final permits.
In addition, a dewatering plan for the ash basins has been drafted and, if approved by
NC DENR, bulk dewatering will be expedited during the initial phase of work. Duke
Energy has submitted an application to modify its NPDES wastewater permit to include
controls to be implemented during dewatering activities.
During Phase I, the Company will continue to perform the pre -construction and planning
activities for the Subsequent Phase(s). These activities include project planning,
development of new ash disposition options, and completion of additional required
permitting that may be necessary for the ash removal from the ash basins and Cinder
Pit. Knowledge and opportunities for program improvement obtained during Phase I of
the project will be applied to the Subsequent Phase(s).
Project Charter Objectives
Phase I Objectives
1. Initiate the removal of ash from the Riverbend site
2. Plan activities for the Subsequent Phase(s), including development of option(s)
for proposed ash disposal or beneficial reuse location(s)
3. Validate production rates to meet project requirements
4. Gain knowledge and opportunities for program improvement that can be applied
to the Subsequent Phase(s)
Subsequent Phase(s) Objectives
1. Dewater Ash Basins
2. Remove all remaining ash from the Ash Stack, Cinder Pit, Primary Ash Basin and
Secondary Ash Basin
3. Submit permit applications for next Subsequent Phase (if applicable)
7

Riverbend Stearn Staiion — Coal Ash Excavation Plan
November 13, 2014
Project Charter Scope
Phase I Scope
1. Finalize end location(s) for removed ash and obtain all required permits
2. Obtain all applicable permits for work in Phase 1
3. Install site erosion and sedimentation control measures
4. Begin site preparation activities, including mobilization
5. Excavate and transport approximately 1 million tons of ash from the Ash Stack to
Roanoke Cement Company and Brickhaven Mine
6. Engineer plan to stop water inputs into the ash basins
7. Initiate rerouting of inflows to the ash basins
8. Begin dewatering the Primary and Secondary Ash Basins
9. Plan activities for Subsequent Phase(s) and submit an updated Plan
10. Begin site preparation activities for the Subsequent Phase(s)
11.Assess, including delineation, the potential remediation efforts in the Cinder Pit
12. Submit and/or obtain all remaining required permit applications for ash removal
activities for Subsequent Phase(s)
13. Identify and/or develop additional location(s) for removed ash for Subsequent
Phase (if applicable), including obtaining all required permits
Subsequent Phase(s) Scope
1. Obtain all remaining required permits for next Subsequent Phase for ash removal
activities (if applicable)
2. Finalize and/or develop additional location(s) for removed ash (if applicable) and
obtain all required permits
3. Complete activities to stop basin inflows
4. Complete basin dewatering
5. Excavate and transport the remaining ash from Riverbend to an approved landfill
or structural fill location
6. Complete closure activities as outlined in Sections 3(b) and 3(c) subparagraphs
1 &2 of the Coal Ash Management Act of 2014
N.

Piverbend Steam Station _ Coal Ash Excavation Plan
November 13, 2014
IV. Critical Milestone Dates
Critical Milestones within the Plan are summarized in the table below. These
milestones have been added to the Level 1 Schedule.
MILESTONES -,ML
Submit Excavation Plan
NO LATER THAN DATEIJ,
November 15, 2014
Complete comprehensive engineering review
November 30, 2014
Excavation Plan Approval
February 17, 2015
Industrial Stormwater Permit
March 5, 2015
Commence work — ash removal
Final permit approval + 60 Days
Submit Updated Excavation Plan — Subsequent
Phase(s)
December 31, 2015
Eliminate stormwater discharge into impoundments
December 31, 2018
Impoundments closed per Sections 3(b) and 3(c) of
the Coal Ash Management Act of 2014
August 1, 2019
p7

Riverbend Stearn Station — Coal Ash Excavation Plan
November 13, 2014
V. Level 1 Schedule
Rivert—d Ash Relaaatw Project Rk erhend Ash Retacafan Project RW Dam W&14138.47
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Note: This Level 1 Schedule is a living element of this Plan. Dates and durations are based on known information on the
date of this Plan.
10

Piverband Stearn Station — Coal Ash E=:cavation Plan
Noveniber 13, 2014
VI. Erosion and Sedimentation Control Plan
The Erosion and Sedimentation Control Plan (E&SC) for the excavation of the Ash
Stack has been developed. This plan and schedule were submitted to NC DENR and
approved on July 3, 2014. The approval of this plan by NC DENR meets the
requirement outlined in the NC DENR Letter.
The approved contractor will install the E&SC measures indicated in the plan. The
Engineer of Record will review the installation prior to commencing excavation on site.
All control measures will be maintained through the project in accordance with the
E&SC.
The modification of the E&SC for the excavation of the ash basins and Cinder Pit Area
is currently under development and will be submitted as part of the Subsequent
Phase(s). Any deviations from the current E&SC for Subsequent Phase(s) are to be
approved by NC DENR prior to installation.
VII. Dewatering Plan
The Riverbend ash basins will be dewatered to facilitate the removal of ash and to
mitigate risk. Lowering the water level within each basin will improve safety factors of
the dams by reducing the driving force on the upstream face of the dam. Similarly,
dewatering will improve the physical properties of the retained ash, making it less
susceptible to flow in the event of an unexpected dam failure.
An Engineered Dewatering Plan for Riverbend was developed to remove the following
water from the ponds:
rolp-r-OPPM
Primary Ash Basin — Removal of free water
Based on data from June 2014, the Primary Ash Basin contains approximately
2.1 million gallons of free water. The free water in the Primary Ash Basin will be
pumped to the Secondary Ash Basin to minimize hydraulic pressure on the
intermediate dam. The maximum free water drawdown rate will be one foot over
seven days. Following free water removal, accumulated stormwater will be
removed at a maximum rate of 2 feet over 1day.
CONFIDENTIAL - NOT FOR DISTRIBUTION 11

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
2. Primary Ash Basin — Removal of water 10 feet below top of ash
After removal of free water, the entrapped water level within the Primary Ash
Basin will be lowered by approximately 10 feet. To achieve the desired water
level, a trench approximately 15 — 20 feet deep will be constructed in the Primary
Basin just inside the Primary Ash Basin dam to draw down entrapped water in
the vicinity of the dam.
3. Secondary Ash Basin— Removal of free water
Based on data from June 2014, the Secondary Ash Basin contains approximately
101 million gallons of free water. The maximum free water drawdown rate will be
one foot over seven days. Following free water removal, accumulated
stormwater will be removed at a maximum rate of 2 feet over 1 day.
VIII. Proposed Location(s) for Removed Ash
Phase I of the Plan will include the excavation and removal of approximately 1.0 million
tons of ash from the Ash Stack. Subsequent Phase(s) will remove the remaining ash at
the site. Ash removed from the site will be transported by the contractor to properly
permitted facilities. The ash placement location will be properly managed and
maintained to ensure environmental compliance with all applicable rules and
regulations.
Phase l: Storage Sites
For Phase I, several sites have been identified for beneficial reuse. The primary option
provides a solution for Phase I and/ or Subsequent Phase(s). These sites include the
Roanoke Cement Company in Troutville, Virginia and the Brickhaven Mine in Moncure,
North Carolina.
Roanoke Cement Company
The Roanoke Cement Company (RCC) is located at 6701 Catawba Road, Troutville,
Virginia. The material hauled from Riverbend to RCC will be used primarily to produce
fly ash modified concrete. The practice of adding fly ash to concrete has been accepted
12

Riverbed Steam Station — Coal Ash Excavation Plan
November 13, 2314
since the 1970's and will be in accordance with ASTM standards, which provides
standards and specification for the production at the RCC facility.
Brickhaven Mine
The mine is located near the city of Moncure in Chatham County of North Carolina. The
mine resides on approximately 299 acres. Its primary mined minerals are clays. Ash
will be transported to the mine as a reclamation project. The Brickhaven Mine will
comply with the requirements set forth in Sections 4(b) and (c) of the Coal Ash
Management Act of 2014.
Contingent Plan: Ash Disposition Sites
For a Contingent Plan, the RCC facility will be utilized as described above. In the event
of any issues with accepting ash at the Brickhaven Mine, the Sanford Mine has been
determined as a suitable alternative site. All necessary steps will be taken to assure
that the Sanford Mine is ready to accept ash in the event of any issues at the
Brickhaven Mine.
Sanford Mine
The Sanford Mine is located in Sanford, North Carolina. Ash will be transported from
Riverbend to the Sanford Mine as a reclamation project.
Structural Fill Alternative
In the event the structural fill options are not available, the Anson County Landfill, a
permitted solid waste landfill, has been identified as the alternate location. The Anson
County Landfill is located in Polkton, NC. Material will be transported by rail.
13

Riverbend Steam Station - Coal Ash Excavation Plan
blovemuer 13, 201
Subsequent Phase(s): Ash Disposition Sites
The project team will utilize lessons learned from Phase I to develop an off -site disposal
strategy and/or alternative beneficial reuse site(s) that will provide the improvements
below.
Provide a reliable, long-term, cost effective, solution for ash designated for
removal
Develop a supplier diverse Program to drive innovation and competition
Establish performance baselines and the system to optimize pickup, transport,
drop-off and reuse
IX. Transportation Plan
Ash will be transported from the site via rail car and/or highway trucks to the off -site
facilities. Transportation will be conducted by approved transporters. Drivers and
trucks will meet Department of Transportation (DOT) and other applicable federal, state,
and local regulations. All drivers will follow all DOT regulations pertaining to the trucking
including DOT bridge laws.
Phase 1: Transportation
For Phase i, approximately 10,000 tons per month of ash will be excavated and hauled
to the RCC facility in the first three to four months via truck (see Figure 2). This tonnage
equates to approximately 15 to 22 truckloads per day. After this start-up period,
throughput will be increased by approximately 50,000 to 55,000 tons per month, which
will be moved to the Brickhaven Mine via truck (see Figure 3). The total tonnage of
60,000 to 65,000 tons per month equates to 120 to 142 truckloads per day.
14

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
rnn-rr,x.w F'WA,r 'Nr:en LY,M �, h1Y r+l� R
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Figure 2: Typical Truck Route to Roanoke Cement Company Facility
t�oios
Mal6erry Shrals �g 52okesdale �r -Busby Fork
if4(tfiStoft-$$lentCa
Moravian Falls' - .,�-GF$er1517oF0
E- le Mills •Farmington Hi
Lenoir ] �; j Chapel Hil
'Lo - it 1501
Statesville Tyro, ., � . . CAry
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ll, }San! yid @
r a RConcord
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Matthews Zin
Fayetteville
gYodc Mrarrroe , Falkton _.
r9 Rock Hill , Rockuig h'+m
,Saratt ~q °LL iiape:'&lills MCI
Figure 3: Typical Truck Route to Brickhaven Mine
Plans are being made to design and install a rail loading system at Riverbend that
would transport ash to the Brickhaven Mine. Once rail loading/unloading systems have
been installed and established at Riverbend and at the Brickhaven Mine, a combination
of rail and truck or all rail can be utilized to transport ash to the two locations. By
utilizing a combination of truck and rail or all rail, an estimated total of 160,000 to
165,000 tons of ash can be transported per month. The schedule estimates that ash
can start being hauled by rail during the seventh month.
15

Riverbend Steam Station — Coal Ash Excavation Plan
November 13, 2014
For Phase I excavation and hauling, a typical 9-hour work shift with two shifts per day
for five days per week will be employed. This typical schedule may be utilized or
modified in Subsequent Phase(s) to meet the August 1, 2019 compliance date.
Gtnar -
rharn
Figure 4: Typical Truck Route to Sanford Mine
Increase Rail Opportunity
1,
If the opportunity of transporting more ash by rail occurs, the amount sent to the RCC
facility may be reduced and the amount sent to the structural fill options may be
increased.
Subsequent Phase(s): Transportation
The transportation plan and any other options will be reviewed and could be amended
in Subsequent Phase(s) to enhance the excavation process and objectives.
X. Environmental Permitting Plan
Phase I
Phase 1 will include initiating excavation and removal of ash from the Ash Stack.
Implementation for Phase I can begin once the permitting for Phase I is in place,
although different permitting may be necessary prior to initiating Subsequent Phase
work. Permitting activities for Subsequent Phase(s) will be included in Phase I.
Through this Excavation Plan approval process, Duke Energy is seeking to confirm that
all necessary approvals have been identified. The Excavation Plan is intended to
authorize the excavation and movement of ash once the identified permits have been
obtained.
16

Riverbend Steam Station -- Coal Ash Excavation Plan
Noaernber 131, 2014
Excavation of ash creates potential for stormwater impacts. The facility holds an
approved Erosion & Sedimentation Control Plan and associated Construction
Stormwater Permit approval for ash stack removal. NC DENR has indicated an
industrial stormwater permit may also be needed. Based on this representation from
NC DENR, Duke Energy has applied for an NPDES industrial stormwater permit to
support ash removal at the site. A stormwater pollution prevention plan (SWPPP)
incorporating best management practices (BMPs) will be created. Future modifications
to the permit/plan will be managed as necessary.
NC DENR has recently indicated that modification of the NPDES wastewater permit
may be required to initiate removal of free water from inactive ash basins. Duke is
submitting additional information to NC DENR for its consideration to support
incorporating dewatering requirements into the Company's pending NPDES permit
application. The Company is working with the United States Environmental Protection
Agency (EPA) and NC DENR with a goal of identifying the regulatory framework that will
allow the removal of free-standing water from inactive basins to move forward.
There are no jurisdictional wetlands/streams associated with the removal of the Ash
Stack or Primary or Secondary Ash basins in Phase I. Future wetland/stream impacts
and jurisdictional determinations will be managed through the US Army Corps of
Engineers (ACOE) with particular attention paid to the difference between jurisdictional
wetlands/streams under Section 404 and those arising from Section 402 waters.
Before creation of new mine reclamation structural fills, an individual structural fill permit
will need to be obtained by the mine reclamation project owner/operator. It is
anticipated that the mining permit will be transferred from the existing mine owner to a
mine reclamation contractor. Once the permit is transferred, the mine reclamation
contractor will submit an individual structural permit application and mine reclamation
plan to the Division of Mining. It is anticipated that the Division of Mining will then
forward the reclamation plan to the Division of Water Resources, Division of Waste
Management, and other divisions as necessary for comments. Subject to any changes
from Division of Mining, the revised reclamation plan would be approved and an
individual Structural Fill Permit will be issued.
No information currently exists to indicate that the Riverbend ash should be treated as a
DOT hazardous material shipped via truck or rail.
Subsequent Phase(s) will include dewatering (once NPDES permit modification is
complete), and continued excavation and removal of ash from the Ash Stack, Primary
and Secondary Ash Basins and the Cinder Pit area.
17

Piverbend Stearn Station — Coal Ash Excavation Plan
November 13, 20,14
Future jurisdictional determinations will be managed through the US Army Corps of
Engineers with particular attention paid to the difference between jurisdictional
wetlands/streams under Section 404 and those arising from Section 402 waters. Any
Section 404 individual permitting will require Section 401 Water Quality Certification by
NC DENR.
If used, before shipping ash to a third -party Subtitle D landfill, waste characterization
and approval will be completed. All necessary Dam Safety approvals will be obtained to
cover activities on or around jurisdictional dams. Breaching of the dams will require
Dam Safety approval. Any impacted wells or piezometers will be properly abandoned
and dispositioned with NC DENR. Fugitive dust will be managed to mitigate impacts to
neighboring areas. Impacts to threatened and endangered species will be avoided.
No additional site -specific or local requirements have been identified.
18

Riverband Steam Station — Coal Ash Excavation Plan
Novarnber 13, 2014
Phase I Permit Matrix
Milestone/Target
Media
Permit
Date
Reasoning
Excavation of ash creates potential for
stormwater impacts. The facility holds
an approved Erosion & Sedimentation
Control Plan and associated
Industrial Stormwater NPDES
Construction Stormwater Permit
Permit
March 5, 2015
approval for ash stack removal. NC
DENR has indicated an industrial
stormwater permit may also be
needed. Duke has applied for this
permit. A SWPPP incorporating BMPs
will be created.
Water
NC DENR has indicated dewatering
activities, including free water removal,
Wastewater NPDES Permit —
may require NPDES wastewater
Minor Modification
March 27, 2015
permit modification. Based on this,
Duke is submitting proposed
dewatering permit conditions in its
pending NPDES permit application.
Jurisdictional Wetland and Stream
Impacts/404 Permitting and 401
N/A
There are no identified jurisdictional
WQC
wetland/stream impacts in Phase I.
Hauling and excavation activities must
not impact a jurisdictional dam or dike.
Activities are initially staying 50 feet
away from the jurisdictional dike.
Dam Safety Approvals
May 29, 2015
Removing ash from the Primary and
Secondary Ash Basins will have to be
reviewed with Dam Safety. Breaching
Waste
of dike will require Dam Safety
approval.
Mine Reclamation Owner/Operator to
Individual Structural Fill Permit
March 27, 2015
obtain a structural fill permit as set
forth in Subpart 3 of Part 21 of Article 9
of the Coal Ash Management Act
Site specific
Local
Nuisance/Noise/Odor/Other
N/A
No local nuisance requirements
Ordinances
Requirements including DOT and
identified.
FERC Requirements
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Riverbend Stean-) Station — Coa! Ash Excavation Plan
November 13, 2014
Subsequent Phase(s) Permit Matrix
Milestone/Target
Media
Permit
Date
Reasoning
Excavation of ash creates potential for
stormwater impacts. The facility holds
an approved Erosion & Sedimentation
Control Plan and associated
Industrial Stormwater NPDES
Construction Stormwater Permit
Permit
March 5, 2015
approval for ash stack removal. NC
DENR has indicated an industrial
stormwater permit may also be
needed. Duke has applied for this
permit. A SWPPP incorporating BMPs
will be created.
NC DENR has indicated dewatering
activities, including free water removal,
Water
Wastewater NPDES Permit —
may require NPDES wastewater permit
Major Modification
August 28, 2015
modification. Based on this, Duke is
submitting proposed dewatering permit
conditions in its pending NPDES
permit application.
Identify if project scope results in
impacts to jurisdictional wetlands or
Jurisdictional Wetland and Stream
streams. Obtain JD and pursue 404
Impacts/404 Permitting and 401
August 28, 2015
permit for impacts from the ACOE.
WQC
Also, 404 permits are required for
working below the ordinary- high water
mark. If Federal individual permitting is
I
required, obtain 401 WQC.
Mine Reclamation Owner/Operator to
Individual Structural Fill Permit
March 27, 2015
obtain a structural fill permit as set
forth in Subpart 3 of Part 21 of Article 9
of the Coal Ash Management Act
Waste
Hauling and excavation activities must
not impact a jurisdictional dam or dike.
Dam Safety Approvals
August 28, 2015
Activities are initially staying 50 feet
away from the jurisdictional dike.
Breaching of dike will require Dam
Safety approval.
Site specific
Local
Nuisance/Noise/Odor/Other
N/A
No local nuisance requirements
Ordinances
Requirements including DOT and
identified.
FERC Requirements
20

Riverbend Siea,n Station - Coal Ash Excavation Plan
Novemt jer 13, 2014
XI. Contracting Strategy
The Ash Management Program strategy is to engage multiple contractors, to drive
competition, system wide innovation and the collection of best practices. During the
initial phase (Phase 1) of ash removal at Riverbend, L.V. Sutton, Dan River and
Asheville, the Company will award the excavation, transportation, and disposal of the
Ash to a single contractor for each site. The result may be two to three contractors, with
each contractor having responsibility for one, or more sites, working on a firm fixed per
ton price basis. The contracting strategy will shift for Subsequent Phase(s), and
potentially during Phase 1, as the Company and the selected contractors recognize
enhancements that can increase productivity or drive unit cost lower. Duke Energy's
core values of safety and quality are non-negotiable and will not be compromised in
order to increase productivity or generate cost savings.
In summary, the Company's contracting strategy will provide the most effective
combination of ash removal, transportation, disposition, and beneficial reuse options
balancing strategic intent, cost, and schedule. The health and safety of workers, the
communities, and environment will not be sacrificed to achieve these goals.
XII. Environmental, Health, and Safety Plan
Protecting workers, the public, the community, and the environment
Duke Energy 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, Duke Energy and its contractors will follow the Duke Energy
Safe Practices; the ABSAT Environmental, Health, and Safety (EHS) supplement
document, and any additional requirements. Occupational health and safety
expectations include oversight and continuous improvement throughout the project.
The project will include comprehensive environmental, health and safety plans
encompassing all aspects of the project work including at the plant, in transit and at the
final destination as needed. The project is committed to minimizing public and
environmental impacts.
XIII. Communications Plan
Many different external stakeholders including neighbors, government officials and
media have an interest in this project. For example, there is the potential for facility
neighbors and the general public to see or experience construction -related impacts
such as truck traffic, landscape changes, or noise. The Company is committed to
21

Riverbend Steam Station -- Coal Ash Excavation Plan
November 13, 2014
providing information by proactively communicating about the Project activities to
potentially affected parties and responding to inquiries in a timely manner.
The Project team will coordinate with Duke Energy's Corporate Communications
Department to develop a comprehensive external communications plan tailored to the
specific needs of each phase of the project.
22

Riverbend Steam Station — Coa! Ash Excavation Plan
November 13, 2014
XIV. Glossary
Term
Definition
ABSAT
Duke Energy organization acronym for Ash Basin Strategic
Action Team
Ash Basin
Synonymous with Coal Combustion Residual Impoundment. A
topographic depression, excavation, or dammed area that is
primarily formed from earthen materials; without a base liner
approved for use by Article 9 of Chapter 130A of the General
Statutes or rules adopted thereunder for a combustion products
landfill or coal combustion residuals landfill, industrial landfill, or
municipal solid waste landfill; and an Area that is designed to
hold accumulated coal combustion residuals in the form of liquid
wastes, wastes containing free liquids, or sludge, and that is not
backfilled or otherwise covered during periods of deposition.
Ash Ponds
Coal Combustion Residual stored in wet impoundments or ponds
Ash Stack
Ash storage area located at the south end of the Primary Ash
Basin
Beneficial and
Projects promoting public health and environmental protection,
Beneficial Use
offering equivalent success relative to other alternatives, and
preserving natural resources
Bottom Ash
The agglomerated, angular ash particles formed in pulverized
coal furnaces that are too large to be carried in the flue gases
and collect on the furnace walls. Bottom Ash falls through open
grates to an ash hopper at the bottom of the furnace.
Bulk Water
Water above the ash contained in the ash basin. Synonymous
with free water
Cinder Pit
Area located northeast of the Riverbend Coal Pile containing
predominately dry cinders
Coal Ash Excavation
Plan required by NC DENR letter dated August 13, 2014
Plan
including a schedule for soil and sedimentation erosion control
measures, dewatering, and the proposed location of the removed
ash
Coal Ash Management
North Carolina Session Law 2014-122
Act of 2014
23

Riverbend Steam Station -- Coal Ash Excavation Plan
November 13, 2014
Term
Definition '4w"
Coal Combustion
Residuals, including fly ash, bottom ash, boiler slag, mill rejects,
Residuals (CCR)
and flue gas desulfurization residue produced by a coal-fired
generating unit
Decanting
The act of removing water from ash
Dewatering
The act of removing bulk and entrapped water from the ash
basin
Dewatering Plan
Engineered plan and the associated process steps necessary to
dewater an ash basin
Duke Safe Work
Document detailing the Duke Energy safety guidelines
Practices
Engineer of Record
Duke Energy or 3rd party contracted engineer responsible for
final verification of specific plan actions and documents
Entrapped Water
Flowable water below the ash surface which creates hydrostatic
pressure on the dam
Excavation Activities
Tasks and work performed related to the planning, engineering
and excavation of ash from an ash basin
Excavation Plan
Refer to Coal Ash Excavation Plan
Factor of Safety
In reference to dam safety, the ratio of the forces or moments
resisting mass movement to the forces or moments tending to
produce mass movement
Free Water
Water above the ash contained in the ash basin. Synonymous
with bulk water
Fly Ash
Very fine, powdery material, composed mostly of silica with
nearly all particles spherical in shape, which is a product of
burning finely ground coal in a boiler to produce electricity and is
removed from the plant exhaust gases by air emission control
devices.
Grading Plan
Document detailing the final elevation, drainage and lay of the
excavated area
24

Riverbend Steam Station -- Coal Ash Excavation Plan
November 13, 2014
DefinitionTerm
Level 1 Schedule
Schedule view that shows the main milestones to complete the
project
NPDES
National Pollutant Discharge Elimination System
NPDES Permit
A permit that regulates the direct discharge of wastewater to
surface waters
Off -Site Facility
A structural fill or mine reclamation for the long term storage of
coal combustion residuals
Permitting
Federal, state, county or local government authorizing document
Primary Ash Basin
Western cell of the Ash Basin system located at Riverbend on the
northeast side of the property (Primary Dam # GASTO-97)
Secondary Ash Basin
Northern cell of the Ash Basin system located at Riverbend on the
northeast side of the property (Secondary Dam # GASTO-98)
Work Plan
Document detailing activities to accomplish a specific task or
scope of work
XV. Reference Documents
25