20150041 Ver 1_USACE - 2nd Request for Add Info_20150630

Burdette, Jennifer a
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Rebekah,
Gibby, Jean B SAW <Jean.B.Gibby @usace.army.mil>
Tuesday, June 30, 2015 4:31 PM
Rebekah Newton
Brown, Craig J SAW; Burdette, Jennifer a; Pruitt, Carl E SAW
EJ (UNCLASSIFIED)
During our phone conversation of 6/26/15 we discussed the Environmental Issues for the proposed coal ash repositories
in Chatham and Lee County. Per the phone conversation, we have a few points that need further information in order to
determine the extent of the Environmental Justice issues at both sites:
1. Please provide additional information on the 7 public outreach efforts of Duke Energy and Charah concerning the two
coal ash repositories in Lee and Chatham counties. Specifically, describe what was discussed at the public
meetings /presentations, who and how many attended the meetings /presentations and the comments and feedback
received from the public.
2. In the response to our comments, Clearwater states " Charah continues to work with the City of Sanford to secure an
industrial discharge permit allowing for the discharge of leachate into the public sewer system." What is the status of
this industrial discharge permit? Briefly discuss the ability of the Sanford sewer system to process leachate. You further
state in the comments response, "While the assessment with the City of Sanford continues, Charah has contracted a
private wastewater treatment provider to safely and effectively treat leachate at the mine site." Please identify the
private wastewater treatment provider and discuss their capabilities in processing the leachate from the two coal ash
repositories and a letter of acceptance of Charah's proposal by the company to process the leachate. In addition, would
the private company be able to continue to process the leachate for the life of the project in the event that the City of
Sanford is either unable or unwilling to process the leachate.
3. In the transportation of the coal ash to the two sites via truck and rail, what precautions and considerations, if any,
would be taken to ensure the safety and free movement of school bus traffic and emergency vehicles? You mention in
your comment letter that the presence of school zones were a factor when evaluating trucking access for alternative
selection. Did this involve just the examination of whether schools were along the proposed trucking route or did it
involve a more thorough analysis of school bus routes. If specific route evaluation was not a factor, more analysis of this
would need to be provided. Is it anticipated that rail cars carrying coal ash would be blocking routes traveled by either
school bus or emergency vehicle traffic? Of special concern is the school bus and emergency vehicle traffic in the two
host counties of Lee and Chatham counties. We assume that there was dialogue with the Emergency Managers of the
subject counties, please provide a summary of such discussions.
In addition to the above questions that focus on Environmental Justice issues, please respond to these questions
concerning the application received in our office on February 18, 2015:
4. On page 25 of the Project Alternatives analysis, the availability of industrial solid waste landfills in North Carolina
operated by Duke Energy at eight power generation plants is discussed. Besides the industrial sold waste sites owned

and operated by Duke Energy, were other industrial solid waste landfills identified and contacted concerning their
availability to take some of the coal ash? Please discuss.
5. Stated in the Project Alternatives (page 27): The landfill [Anson County] can accept a total of 500,000 tons of ash with
the possibility of accepting additional tonnage in 2 -3 years." What agreements, if any, does Duke Energy have with the
Anson County Landfill to accept coal ash
6. - In addition, with regards to alternatives analysis, please discuss the viability of saltstone encapsulation as several
comments from the public pertained to this topic and considered it a viable alternative. Please discuss this alternative
for our inclusion in the alternatives analysis.
7. When referencing the comment pertaining to coal ash being utilized as a component of cement, your response
indicated that Duke Energy is sending 25,000 tons /mth (equals 300,000 tons per year) to Roanoke Cement Co. and plans
to send 10,000 tons /mth from Riverbend, resulting in 115,000 tons. Is the 10,000 tons per month in addition to the
25,000 tons per month already being sent.
8. P & N - In your comment response letter, you stated that the Applicant's Redefined Project Purpose -The purpose of
the proposed project is to dispose of coal ash in a suitable manner, using the best available technology, and in an
environmentally sound location. The long -term disposal of coal ash in suitable locations will facilitate the closing of coal
ash basins across North Carolina, as required by the CAMA14. In discussing this purpose with our attorney, we noted
that you added the phrase "using the best available technology ", he indicated that this phrase would be confining on the
project's purpose and it is better suited to address as an alternative. For example, some might consider that saltstone
encapsulation or other technology might be the best available.
Should you have any further questions or need clarifications pertaining to our comments, please do not hesitate to
contact either Craig or me.
Thanks so much,
Jean
Jean B. Gibby
Chief, Raleigh Field Office
U.S. Army Corps of Engineers
Regulatory Division
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
(919) 554 -4884, Ext. 24
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