HomeMy WebLinkAbout20060645 Ver 2_More Info Received_20120111Strickland, Bev
From: Homewood, Sue
Sent: Wednesday, January 11, 2012 12:44 PM
To: Strickland, Bev
Subject: FW: Belews Creek Steam Station Landfill Expansion SAW- 201100972 (UNCLASSIFIED)
Attachments: Response to USFWS_2012.01.11.pdf
For file 06 -0645 v2
Sue Homewood
NC DENR Winston -Salem Regional Office
Division of Water Quality
585 Waughtown Street
Winston - Salem, NC 27107
Voice: (336) 771 -4964
FAX: (336) 771 -4630
E -mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed
to third parties.
- - - -- Original Message---- -
From: Darrin Peine fmailto:DPeineksmeinc.coml
Sent: Wednesday, January 11, 2012 12:37 PM
To: Thomas, John T JR SAW
Cc: Homewood, Sue; Leap, Tom Y Jr; Kenneth Daly
Subject: RE: Belews Creek Steam Station Landfill Expansion SAW- 201100972 (UNCLASSIFIED)
Hello John,
I have attached to this message as "Response to USFWS 2012.01.11.pdf'
our response to the USFWS public notice comments that you provided for review on January 05.
We believe our response adequately addresses the USFWS comments, however, please let me know if you have any questions
with the information.
It is my understanding that following the close of the second public notice, barring any upsetting comments, you will possibly
be in a position to render a decision on the 404 permit after receiving the state's WQC 401 permit. In December I provided an
updated impacts table to include the FGD area of potential impacts and Kelly Williams from EEP provided a revised response
letter for the In -Lieu Fee mitigation request.
Please let me know if you need any additional information or assistance from us. We appreciate yours and Sue's attention to this
prof ect!
Regards,
Darrin Peine
Project Scientist
S &ME, Inc.
704 -523 -4726 - office
704 - 930 -5670 - mobile
dllelnena,smelnc. com
www. smemc. com
- - - -- Original Message---- -
From: Thomas, John T JR SAW fmailto: John. T. Thomas. JRnausace.army.mill
Sent: Thursday, January 05, 2012 5:23 PM
To: Darrin Peine
Subject: FW: Belews Creek Steam Station Landfill Expansion SAW- 201100972
(UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
Darrin
Please review the attachments and provide me your comments by e -mail
John Thomas
Raleigh Regulatory Field Office
919 554 -4884 ext. 25
- - - -- Original Message---- -
From: Thomas, John T JR SAW
Sent: Thursday, January 05, 2012 4:29 PM
To: Homewood, Sue
Subject: FW: Belews Creek Steam Station Landfill Expansion SAW- 201100972
(UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
Sue
Attached are the FWS comments we discussed. It appears that their recommendation is to permit just the supplement (i.e. the
FGD landfill) which would give 8 years of capacity. Duke could then use the 8 years to examine other alternatives to avoid
additional impacts. It does not account that the FGD landfill is currently being used for storage and would conflict with existing
separation of fly ash from the FGD stock piling plus the point of the permit is a long term action (i.e. 32 years). At first review,
I do not see this as a practical alternative because of the stated reasons.
I plan to talk to Darrin and I will let you know what was discussed.
John Thomas
- - - -- Original Message---- -
From: Allen Ratzlaff(afws.gov fmailto:Allen RatzlaffAfws.govl
Sent: Wednesday, December 21, 2011 10:10 AM
To: Thomas, John T JR SAW
Cc: shari.b ant �,newildlife.org
Subject: Belews Creek Steam Station Landfill Expansion SAW- 201100972
Attached are comments from the U.S. Fish and Wildlife Service.
Allen Ratzlaff
USFWS
160 Zillicoa St.
Asheville, NC 28801
828/258 -3939 x229
Classification: UNCLASSIFIED
Caveats: NONE
Classification: UNCLASSIFIED
Caveats: NONE
January 11, 2012
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Attention: Mr. John Thomas
John.T.Thomas.JR@usace.army.mil
Reference: Response to USFWS December 21, 2011 Comments to
Individual Permit Application Amendment
Duke Energy — Belews Creek Steam Station
Proposed Craig Road Landfill Expansion, Stokes County, North Carolina
S &ME Project No. 1356 -10 -041
USACE Action ID No. 2011 -00972
Dear Mr. Thomas:
Thank you for providing the U.S. Fish and Wildlife Service ( USFWS) letter response
dated December 21, 2011 from the U.S. Army Corps of Engineers ( USACE) Public
Notice for the proposed expansion of the Craig Road landfill project. S &ME, Inc.,
(S &ME) on behalf of Duke Energy is providing this response to the USFWS letter.
As stated in the permit application and supplemental information, the project purpose is to
provide disposal capacity for the next 32 years for the coal combustion products generated
at Duke Energy's Belews Creek Steam Station. Duke Energy currently disposes coal
combustion products at two on site landfills, the Craig Road landfill and the FGD landfill.
Based on current projections, the Phase 1 Craig Road landfill will reach capacity in early
2013, and the FGD landfill will reach capacity in early 2014.
We understand the USFWS recommendation is to permit the "Alternative C Supplement"
(which is the FGD landfill expansion) before any other alternatives. Please note that this
is referred to as the "Alternative D (existing FGD landfill) in S &ME's November 8, 2011
Individual Permit Application Amendment. The "Alternative C Supplement" would
provide an estimated 8 years of capacity. Furthermore the USFWS recommends
permitting Alternative B (no stream and wetland impacts) second and this would provide
approximately 6 more years of capacity. The two alternatives together, stand to provide
about 14 years of capacity therefore not meeting the project need and purpose.
S &ME, INC. /9751 Southern Pine Blvd/ Charlotte, NC / p 704.523.4726 / f 704.525.3953/www.smeinc.com
Response to USFWS December 21, 2011 Comments S &ME Project Number 1356 -10 -041
Proposed Craig Road Landfill Expansion January 11, 2012
The proposed Alternative C (proposed location) is estimated to provide 24 years of
capacity. The proposed Alternative C (proposed location) combined with the Alternative
D (existing FGD landfill) can provide an estimated 32 years of capacity. Considering the
inherent variables associated with a project of this scope and magnitude and the
information previously submitted to the agencies it is our opinion that permitting the
proposed Alternative C (proposed location) coupled with the proposed Alternative D
(existing FGD landfill) if needed is the preferred path because it meets the stated project
need.
In addition, the USFWS has indicated that stream mitigation should be considered at a
higher ratio than 1:1. However, S &ME has previously confirmed with the USACE that a
1:1 stream mitigation ratio is appropriate for this project.
Thank you for your assistance with this project.
Sincerely,
S &ME
Imo[-
Kenneth Daly, P.E. Darrin M. Peine, QEP
Senior Project Engineer Natural Resources Project Scientist
kdalv(&smeinc.com dneine(&,smeinc.com
CC: Tom Leap, Duke Energy
Sue Homewood, DWQ Winston -Salem Regional Office