20150041 Ver 1_Add Info 20150717 to USACE_20150729

Burdette, Jennifer a
From:
Sent:
To:
Subject:
Attachments:
Rebekah Newton <rebekah @cwenv.com>
Wednesday, July 29, 2015 11:26 AM
Burdette, Jennifer a
FW: Response to Corps Items 1 -3
Corps Email 06.30.15.pdf, Public Involvement List.pdf, EJ and Econ Analysis Addendum
(07.15.15).pdf
Please consider the environment before printing this e -mail.
From: Rebekah Newton
Sent: Friday, July 17, 2015 11:28 AM
To: Gibby, Jean B SAW (Jean.B.Gibby @usace.army.mil); Craig.J.Brown @usace.army.mil
Subject: Response to Corps Items 1 -3
Dear Ms. Gibby and Mr. Brown,
Please reference the email dated June 30, 2015 (attached) sent by the US Army Corps of Engineers (Corps) in
response to the permit application submitted by ClearWater Environmental Consultants, Inc. (CEC), on behalf
of Green Meadow, LLC represented by Mr. Charles Price. The permit application requested written
authorization for the impacts associated with disposal of coal ash at the Brickhaven and Sanford
Mines. Comments 1 -3 provided by the Corps in the referenced email are listed and discussed below.
Comment 41 — "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."
To the best of CEC's knowledge, 16 meetings or events have taken place since November of 2014
which have given the public, or elected officials on behalf of the public, the opportunity to voice
comments and concerns regarding proposed activities at the Sanford and Brickhaven Mine sites. Duke
Energy and /or Charah, Inc. were present at six of the meetings or events. The six meetings
1

included: three County Board of Commissioner meetings, one closed session with the Chamber of
Commerce Board, and two Open House events. Attached is a comprehensive list of the 16 meetings and
events that have taken place, links to meeting minutes or videos (when available), summaries of
comments made, and summaries of Q &A sessions.
Comment 42 — "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."
Charah, Inc. (Charah) submitted an Industrial User Wastewater Survey and Permit Application to the
City of Sanford on March 10, 2015. The City issued a draft permit on June 3, 2015, Permit 4000035,
dated July 1, 2015 and expiring on September 1, 2019. The City held a public meeting regarding the
draft permit on June 29, 2015 during which the City's Engineer, Hazen and Sawyer (H &S), discussed
the ability of the Big Buffalo Creek Wastewater Treatment Plant (WWTP) to process the leachate from
Charah. H &S's review indicated that the City's WWTP is capable of handling the volume requested by
Charah which was calculated to be 288,000 gallons per day (gpd) or 0.288 million gallons per day
(mgd). Charah's flow is approximately 7% of the hydraulic capacity of the City's WWTP (4 mgd).
Charah has contracted with VLS Recovery Services, LLC (VLS) to provide pump and haul services
along with treatment of leachate, as needed. VLS has provided documentation that they can process
(store, treat, and discharge) 80,000 gallons per day from both the Brickhaven and Sanford sites at their
facility located in Mauldin, South Carolina.
Comment 43 — "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."
Haley & Aldrich, Inc. completed an "Addendum on Community Transportation Impacts from Coal Ash
Transport to Colon and Brickhaven Mine Sites" dated July 2015 (attached). The addendum addresses
potential impacts associated with school bus traffic and emergency vehicles.
The applicant believes the information included above addresses comments 1 -3 in the email dated June 30,
2015. Should you have any questions or comments concerning this project please do not hesitate to contact me
at 828 - 698 -9800.
Thank you.
N

Rebekah Newton
WE'VE MOVED! PLEASE NOTE OUR NEW ADDRESS!!
Please consider the environment before printing this e -mail.

The following is a list of meetings or events where the public has had the opportunity to voice
comments and concerns regarding the proposed Sanford and Brickhaven Mine sites:
• Nov. 11, 2014
— Lee County Board of Commissioners Meeting (Duke/Charah present)
• Dec. 1, 2014 -
Lee County Board of Commissioners Meeting
• Dec. 2, 2014 —
Lee County Chamber of Commerce Closed Session (Duke/Charah present)
• Dec. 8, 2014 —
Lee County Public Hearing
• Dec. 10, 2014
— Lee County Open House (Duke/Charah present)
• Dec. 11, 2014
— Chatham County Open House (Duke/Charah present)
• Dec. 15, 2014
— Chatham County Board of Commissioners Meeting
• Jan. 5, 2015 -
Lee County Board of Commissioners Meeting
• Jan. 20, 2015 -
Chatham County Board of Commissioners Meeting (Duke/Charah present)
• Mar. 2, 2015 -
Lee County Board of Commissioners Meeting
• Mar. 2, 2015 -
Chatham County Board of Commissioners Meeting (Duke/Charah present)
• Mar. 16, 2015
- Lee County Board of Commissioners Meeting
• Apr. 13, 2015
- Chatham County Board of Commissioners Meeting
• Apr. 13, 2015
— NCDENR Public Hearing, Lee County
• Apr. 16, 2015
— NCDENR Public Hearing, Chatham County
• May 18, 2015
- Chatham County Board of Commissioners Meeting
Each meeting is summarized in further detail on the following pages.
Page 1 of 1 l

November 17, 2014 — Lee County Board of Commissioners Meeting
Meeting Minutes can be found at link below:
http://Ieecountync.gov/LinkClick.aspx?fileticket=Of-fVcQbo8vU�/o3d&tabid=85
® Reference to public and Duke/Charah comments regarding coalash are on Pages 3-4.
A video of the meeting is located in the Lee County Video Archive:
http://www.leecountync. Dov/Commissioners/V ideoFil ming/V ideoArchive/tabid/84/Default.aspx
® Eight citizens gave public comments (these comments start at approximately 59:51 in the
video and are mixed in with comments regarding other topics). Comments were similar
to written comments received by NCDENR and the Corps; and general topics mentioned
are listed below.
o References to the Dan River spill.
o Concerns regarding toxins and heavy metals.
o Importance of groundwater monitoring.
o Potential impacts to groundwater.
o Concerns regarding liner integrity and failure.
o Importance of protection of the Cape Fear River Basin as a drinking water supply.
o Health of citizens and potential illness caused by coal ash.
o Potential road deterioration because of hauling.
o Potential economic impacts to Lee County.
o Potential impacts to property values.
o Potential impacts to wildlife, gravesites, and aesthetics.
o Potential impacts caused by dust.
The comments are followed-up by a presentation from Duke/Charah (starts at
approximately 1:27:07 in the video) and a Q&A session with the BOC (starts at
approximately 1:43:09 in the video). The following representatives from Duke and
Charah were present:
o Charlies Price — Charah
o Scott Sewell — Charah (presenter)
o Rob Reynolds — Charah
o Mike Hughes — Duke (presenter)
o Jay Whitlock — Duke
o Indira Everett - Duke
The Q&A included questions regarding the following topics:
o CAMA14 and what prompted looking for ash disposal sites.
o When Charah was engaged on the project and why.
o When the County first new about the project and how they addressed citizens.
o Groundwater monitoring.
o Alternatives and other uses of coal ash.
o Coal ash constituents.
o Benefits to Lee County —job creation and additional revenue in the County.
o Clarification of the approval process and required permits.
o Education of citizens and the importance of a local liaison.
Page 2 of 11

December 1, 2014 — Lee County Board of Commissioners Meeting
Meeting Minutes can be found at link below:
http:l/Ieecountvnc.gov/LinkClick.aspx?fileticket=pOlew8nGJZM%3d&tabid=85
® Reference to public comments regarding coal ash are on Page 3.
A video of the meeting is located in the Lee County Video Archive:
http://leecountvnc.gov/Commissioners/VideoFilming/VideoArchlve/tabid/84/Default. ,s
Seven citizens gave public comments (these comments start at approximately 9:24 in the
video and are mixed in with comments regarding other topics). Comments were similar
to written comments received by NCDENR and the Corps; and general topics mentioned
are listed below.
o Potential impacts to environmental justice populations.
o Alternative uses of coal ash.
o Potential impacts associated with the transportation of coal ash.
o Increased traffic.
o Concerns regarding components for coal ash.
o Concerns regarding liner integrity and failure.
o Potential impacts to groundwater.
December 2, 2014 — Lee Countv Chamber of Commerce Closed Session
• Local government, local businesses, and community leaders in attendance at closed
session lunch -meeting. Representatives from Charah were also in attendance.
e The Q&A included questions regarding the following topics:
o Depth of soil used to cover the cap liner.
o Impacts to economic development and the stigma of having a coal ash site in the
county.
o How Duke will compensate Chatham County for disposal.
Page 3 of 11

December 8, 2014 — Public Hearing of the Lee County Board of Commissioners
Meeting Minutes can be found at link below:
http://leecountync.gov/LinkCIlck.aspx?fileticket=xhvgxKl 2BbY%3d&tabid=85
A video of the meeting is located at the Central Carolina Community College website:
mms://Ictv.cccc.edu/TRMSVOD/I 394- 1 CoalAshPublicHearin2120814.wmv
Twenty-five citizens gave public comments (speakers that did not receive the chance to
comment at the 11/17 meeting). Comments were similar to written comments received
by NCDENR and the Corps and general topics mentioned are listed below.
o Lack of regulatory oversite.
o Liability for project.
o Potential for impacts to future generations.
o Alternatives to disposal in Lee County.
o Recommendations to leave ash in place.
o Potential for impacts to Cape Fear River Basin.
o Transportation of coal ash.
o Potential for dust.
o Potential impacts to surface waters.
o Potential impacts of severe weather on open cells.
o Concerns regarding the components of coal ash — heavy metals and radioactivity.
o Potential impacts to streams and wetlands.
o Potential impacts to wildlife.
o Potential impacts associated with flooding.
o Leachate management and testing.
o Concerns regarding liner integrity and failure.
o Potential road impacts due to hauling.
o Social and environmental injustice.
o Saltstone as an alternative use.
o Coal ash link to fracking.
o Potential effects to human health.
o Lack of education and information given to the public.
o Potential impacts to economic development.
o Potential increases to traffic.
Page 4 of 11

December 10, 2014 — Lee County Public Information Open House
Organized by Duke Energy
Lee County Arts & Community Center
507 N. Steele St.
Sanford, NC
• Public and press invited.
• Meeting was noticed via local media advertising and news articles; notification letters
mailed to residents within 2-3 miles of mine.
• Approximately 70 attendees.
• Open house format with booths and handouts covering topics such as:
o Coal ash management plans.
o Environmental stewardship.
o Mines and transport of coal ash.
• Approximately 25 experts from Duke and Charah were at booths and throughout meeting
room to answer questions and receive feedback.
December 11, 2014 — Chatham County Public Information Open House
Organized by Duke Energy
Harris Energy and Environmental Center
3932 New Hill Holleman Road
New Hill, NC
• Public and press invited.
• Meeting was noticed via local media advertising and news articles; notification letters
mailed to residents within 2-3 miles of mine.
• Approximately 40 attendees.
• Open house format with booths and handouts covering topics such as:
o Coal ash management plan.
o Environmental stewardship.
o Mines and transport of coal ash.
• Approximately 25 experts from Duke Energy and Charah were at booths and throughout
meeting room to answer questions and receive feedback
Page 5 of 11

December 15, 2014 — Chatham County Board of Commissioners Meeting
Meeting Minutes and transcripts can be found at the link below:
http://www.chathamnc.org/index.aspx?page=1757
® Public comments regarding coal ash are on Pages 6 and 14-16.
® Three citizens gave public comments (these comments are mixed in with other comments
on different topics). Comments were similar to written comments received by NCDENR
and the Corps; and general topics mentioned are listed below.
o Potential for impacts to air, soil, and water.
o Potential effects to human health and life expectancy.
o Potential impacts to the Cape Fear River Basin as a drinking water supply.
o Lack of information in the decision process for placement of ash.
A video of the meeting is located at the Chatham County Vimeo Channel:
https:Hvimeo.com/channels/chathambocmeetings/114670798 - Part 1
https:Hvimeo.com/channels/chathambocmeetin�s/114673641 - Part 2
January 5, 2015 — Lee County Board of Commissioners Meeting
Meeting Minutes can be found at link below:
http://Ieecountyn�ov/LinkClick.aspx?fileticket=3KZHOCWLimc°/c3d&tabid=85
0 References to public comments regarding coal ash are on Page 2.
A video of the meeting is located in the Lee County Video Archive:
httr)://Ieecountvnc.2ov/Commissioners/VideoFilmina/VideoArchive/tabid/84/Default.aSDX
Two citizens gave public comments (these comments start at approximately 4:11 in the
video). Comments were similar to written comments received by NCDENR and the
Corps; and general topics mentioned are listed below.
o Potential impacts to the watershed.
o Potential impact to drinking water wells.
o Potential impacts to gravesites.
Page 6 of 11

January 20, 2015 — Chatham County Board of Commissioners Meeting
Meeting Minutes and transcripts can be found at the link below:
http://www.chathamnc.org/index.aspx?page-1797
® Public and Duke/Charah comments regarding coal ash coal ash are on Pages 2-19.
• Duke/Charah give a presentation to the BOC and attendees at the meeting (link to
presentation in meeting minutes and on video).
® The following representatives from Duke and Charah were present:
o Charlies Price — Charah
o Scott Sewell — Charah (presenter)
o Mike Hughes — Duke (presenter)
o Jay Whitlock — Duke
o Indira Everett - Duke
® A Q&A session with the BOC follows the presentation. The Q&A included questions
regarding the following topics:
o Excavation depths and boundaries; and the process of filling cells.
o Liner age and integrity.
o Leachate management and testing.
o Stormwater management.
o Liability after the 30 -year closure.
o Environmental studies completed at the site.
o Groundwater monitoring.
o Ash transportation.
o Alternatives and other uses of coal ash.
o Economic future of the County.
o Potential for dust.
Three citizens gave public comments. Comments were similar to written comments
received by NCDENR and the Corps; and general topics mentioned are listed below.
o Concerns regarding the components of coal ash.
o Concerns regarding dust from trucks.
o Lack of information in the decision process for placement of ash.
o Relationship/link between Charah and Green Meadows.
o Leachate management.
o Potential impacts to groundwater.
o Concerns regarding the components of clay.
o Potential impacts to the Cape Fear River Basin.
A video of the meeting is located at the Chatham County Vimeo Channel:
https://vimeo.com/channels/chathambocmeetings/117414498 - Part 1
httpsJ/vimeo.com/channels/chathambocmeetings/117415088 - Part 2
Page 7 of 11

March 2, 2015 — Lee County Board of Commissioner Meeting
Meeting Minutes can be found at link below:
ham://leecountync.gov/LinkClick.aspx?fileticket=ZDVSYSx 1 uAA%3d&tabid=85
® A List of speakers providing public comments regarding coal ash are on Page 2.
A video of the meeting is located in the Lee County Video Archive:
http://leecountync. Dov/Commissioners/VideoFilming/VideoArchive/tabid/84/Default.aspx
® Nine citizens gave public comments (these comments start at approximately 2:50 in the
video and are mixed in with comments regarding other topics). Comments were similar
to written comments received by NCDENR and the Corps; and general topics mentioned
are listed below.
o Potential impacts to gravesites.
o Potential impacts due to train traffic.
o Leachate treatment.
o Potential impacts to wildlife.
o Potential impacts to floodplains.
o Concerns over lack of information provided to the public.
o Potential impacts to pastureland and agricultural.
o Potential impacts to property values.
o Potential impacts to economic development.
o Potential impacts to groundwater and surface water.
o Potential impacts to air quality.
o Alternative uses of coal ash.
o Concerns regarding liability.
o Potential impacts to Environmental Justice populations.
o Potential impacts to drinking water.
o Potential impacts to human health.
Page 8 of 11

March 2, 2015 — Chatham County Board of Commissioners Meeting
Meeting Minutes and transcripts can be found at the link below:
http://www.chathai-nnc.org/index.asix`. pale=1757
® Public and Duke/Charah comments regarding coal ash are on Pages 7-11 and 17-29.
® Four citizens gave public comments (these comments are mixed in with other comments
on different topics). Comments were similar to written comments received by NCDENR
and the Corps; and general topics mentioned are listed below.
o Concerns regarding hauling of ash.
o Concerns regarding dust.
o Concerns regarding components of ash.
o Saltstone as an alternative use.
o Potential impacts to surface waters.
o Potential impacts to public health and safety.
o Environmental monitoring.
o Education of citizens and citizen involvement.
o Potential impacts to the community.
o Liner integrity.
The following representatives from Duke and Charah were present:
o Charlies Price — Charah
o Scott Sewell — Charah (presenter)
o Jeff Brooks — Duke
o Indira Everett - Duke
A Q&A session with the BOC was held during the meeting. The Q&A included
questions regarding the following topics:
o Leachate management and testing.
o Liner integrity.
o Final elevations of the site.
o Potential damage to roads due to hauling.
o Management of dust.
o Groundwater monitoring.
o Transportation of ash.
A video of the meeting is located at the Chatham County Vimeo Channel:
https://vimeo.com/channels/chathambocmeetin s/121252110 - Part 1
https:Hvimeo.com/channels/chathambocmeetings/121261425 - Part 2
https://vimeo.com/channels/chathamboemeetings/121264848 - Part 3
Page 9 of 11

March 16, 2015 — Lee County Board of Commissioner Meeting
Meeting Minutes can be found at link below:
http://Ieecountync.gov/LinkClick.aspx?fileticket=kBD4P8wgFhU%3d&tabid=85
® Reference to public comments regarding coal ash are on Page 2.
A video of the meeting is located in the Lee County Video Archive:
http://leecountyne. gov/Commissioners/VideoFilming/VideoArchive/tabid/84/Default. aspx
® Ten citizens gave public comments (these comments start at approximately 3:50 in the
video). Comments were similar to written comments received by NCDENR and the
Corps; and general topics mentioned are listed below.
o Potential impacts to human health.
o Potential impacts to community.
o Potential impacts of dusting.
o Potential impacts to traffic.
o Potential impacts to air quality.
o Potential impacts to water quality.
o Potential impacts to agriculture.
o Liner integrity.
o Concerns regarding toxicity of coal ash.
o Concerns regarding public safety.
o Lack of information provided to the public.
April 13, 2015 — Chatham County Board of Commissioners Meeting
Meeting Minutes and transcripts can be found at the link below:
http://www.chathamnc.org/index.aspx?page=1757
® Public comments regarding coal ash are on Pages 1-5.
• Seven citizens gave public comments. Comments were similar to written comments
received by NCDENR and the Corps; and general topics mentioned are listed below.
o Safe transportation of ash.
o Potential dust during transportation.
o Liner integrity.
o Leachate management.
o Establishment of fees for ash disposal.
o Potential dust from fill cells.
o Potential impacts to school bus routes.
o Provision for spills of ash on roadways.
o Impacts to wildlife and wetlands.
o Potential illness caused by exposure to dust.
o Potential groundwater contamination.
o Potential impacts to property values.
o Potential impacts to the local economy.
o Liability after 30 -year closure.
A video of the meeting is located at the Chatham County Vimeo Channel:
https://vimeo.com/channels/chathambocmeetin�y,s/124968822.
Page 10 of 11

April 13, 2015 — NCDENR Public Hearing, Sanford (Lee County)
Transcripts can be found at the link below:
http://its.enr.state.nc.us/Webl'nk8/0/doc/276265/Pa el.aspx
Approximately 40 citizens gave public comments. Comments were similar to written
comments received by NCDENR and the Corps. Corps representatives were present at
the Public Hearing; therefore, general topics mentioned have not been summarized.
April 16, 2015 — NCDENR Public Hearing, Brickhaven
Transcripts can be found at the link below:
http://its.enr.state.nc.us/Weblink8/0/doc/276272/Pagel .aspx
® Approximately 39 citizens gave public comments. Comments were similar to written
comments received by NCDENR and the Corps. Corps representatives were present at
the Public Hearing; therefore, general topics mentioned have not been summarized.
May 18, 2015 — Chatham County Board of Commissioners Meeting
Meeting Minutes and transcripts can be found at the link below:
http://www.chathamnc.org/index.aspx?page=1757
® Public comments regarding coal ash are on Pages 8-9.
m Three citizens gave public comments (these comments are mixed in with other comments
on different topics). General topics mentioned are listed below.
o Comments regarding Commissioners' role in project.
A video of the meeting is located at the Chatham County Vimeo Channel:
https://vimeo.com/channels/chathambocmeetings/128294915 - Part 1
https://vimeo.com/channels/chathambocmeetings/128298539 - Part 2
Page 11 of 11

ADDENDUM ON
www.haleyaldrich.com
COM M UNITYTPANS:IORTAII ON I M PACTS FROM OOALASH
TRANSPORT TO OOLON AND BPI CKHAVEN M I NE SITES
by Haley & Aldrich, Inc.
Bedford, New Hampshire
for
Charah, Inc.
File No. 41844 -022
July 2015

TABLE OF OONTENTS
List of Tables ii
List of Figures ii
A. Community transportation impactsfrom coal ash transport to Colon and
Brickhaven mine sites 1
A.1 SCHOOLS I N THE OOLON M I N E STU DY AREA
A.2 SCHOOLS I N THE BRI CKHAVEN M I NE STUDYAREA
A.3 TRANSFORTATION OF OOAL A,9 i TOM I NE 3TES
A.3.1 Rail Traffic t o t he Mine 9tes
A.3.2 Truck Traffic to the Mine3tes
A.3.3 Mitigation of Dust
A.4 OONCLU30N
Tables
Figures
1
2
2
3
3
4
5

List of Tables
Table No. Title
A 1 Race and Rhnicity Data for Schools near Trucking and /or Rail Fbutesof the
Brickhaven and Colon Mines
List of Figures
Figure No. Title
A-2 Bementary School DistrictsWithin a 5 -Mile F?adiusof the Colon Mine with Truck
Fbutesand Flail Lines
A -3 Middle School DistrictsWithin a 5 -Mile F?adiusof the Colon Mine with Truck
Fbutesand Flail Lines
A4 High School DistrictsWithin a5 -Mile F?adiusof the Colon Mine with Truck
Fbutesand Flail Lines
A-5 SchoolsWithin a5 -Mile F?adiusof the Brickhaven Mine with Truck
Fbutesand Flail Lines
A-6 School DistrictsWithin a5-Mile Padiusof the Brickhaven Minewith Truck
Fbutesand Rail Lines
A-7 SchoolsWithin a5 -Mile F?adiusof the Brickhaven Minewith Truck
Fbutesand Flail Lines
�Rlcm

A. Community transportation impactsfrom coal ash transport to Colon and
Brickhaven mine sites
Army Corps of Engineers (ACE) has requested additional information on precautions, considerat ions and
impacts of transportation of coal ash t o t he Colon and Brickhaven mine sites. Specifically, ACE requested
additional information to address these specific questions:
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 Criatham
counties We assume that there was dialogue with the Energency Managers of the subject
counties, please provide a summary of such discussions
In evaluating the socioeconomic and environmental justice (P impactsto the Colon and Brickhaven
mine study areas, an analysis of school demographic and school assignment s was cond ucted to identify
schools near trucking and rail routes and in the vidnity of the mine sites. The information on school
assignments was obtained from the Lee County ,13,hoolsand Chatham County ,13choolswebsites. Lee
County GISand Chatham County GISdatawere used to identify school assignment districts. Information
on rail safetythat could impact emergency vehi des and school buses was obtained from the rail
company that will be hauling the ash, CEXODrporation.
SCHOOLSIN THECOLON MINESTUDYAREA
The Lee County public schools within the Colon mine study area five -mile radius are:
• BT Bullock Bementary
• Warren Williams Bementary
• Deep Ewer Bementary
• ,R Ingram Jr. Bementary
• East Lee Middle
• Lee County High
• Lee Early College (co- located with Lee County High School)
Demographics of the schools within the five mile radius are given in Table A -1. Demographic data was
obtained from the Educational Directory and Demographical Information Exchange provided by the
North Carolina State Board of Education. Ascan be seen from Table 1, several of the Lee County schools
within the Colon mine study area have minority populationsover 50 percent. The analysisof potential
environmental justice populationsfor the Colon mine study area isdiscussed in Sactions4.1 and 4.2 of
the SDcioeconomic Analysis report.
1 �Rlcm

The immediate vicinity of the Colon mine is assigned t o t he Deep Fiver Bementary School, located four
(4) miles north oft he mine site; East Lee Middle School, located five (5) milessoutheast; and Lee County
High School, located five (5) miles south. Figures A -2, A 3 and A -4 show the school assignments.
Although specific school bus routes change annually, a review of 2013 -2014 bus assignments and routes
shows that two elementary school buses, two middle school buses and two high school buses will serve
the area in the vicinity of the Colon mine, and roads that would bet raveled by contingent truck traffic.
The elementary and middle schools start at about 7:30 am and dismiss at about 2:30 pm (the middle
school starts and dismisses 10 minutes later than the elementary school). The high school day begins at
8:00 am and dismisses at 3:00 pm. Based on this schedule, it is anticipated that six buses would be on
the nearby roadways in the morning between 6:00 and 8:00am, and again between the hours of 2:30
and 4:30 pm.
SCHOOLSI N 1 = BR CKHAVEN M I NESTUDY AREA
As shown in Figure A-5, only one school is within a five -mile radius of the Brickhaven mine site —
M oncure School, which includes grades kindergarten through eight (K-8). The elementary school
assignment map for Chatham County is shown in Figure A -6. The immediate vicinity of the Brickhaven
mine isassigned to Moncure School and Northwood High. Northwood High is located 18 miles
northwest of the mine site. It should be noted that a portion oft he Brickhaven study area is zoned for
Deep Fiver Bementary in Lee County and for Broadway Bementary in Lee County, located 10 miles
south.
Specific school bus routesto Moncure School and Northwood High School were unavailable from
Chatham County schools, and these routes are subject to change annually. However, the Chief
Operations Officer for Chatham County ,13choolswascontacted directly to obtain information on busing.
M oncureSchool operates four buses, each starting the morning route at 6:00 am and arriving to the
school by 7:55 am. The school day ends at 3:00 pm and buses are traveling their routes through 4:45
pm.
Northwood High School runs two buses within the M oncureSchool district. The school day is from
7:30am — 3:15pm. Due to the distance to the high school, buses begin their routes at 5:00 am, and are
bade at the school by 5:30 pm following the afternoon route.
Demographics of Moncure School and Northwood High School are given in Table A 1. Both schools have
a minority population of about 30 percent. As defined in Sactions4.1.2 and 4.2.2 of the Socioeconomic
Analysis report, the populations in the Brickhaven mine study area do not meet the definitions for
having potential environmental justice population based on minority population or poverty level.
TRANSPORTA11ON OFCOALASHTOMINESTI S
The structural fill permitsspecify transportation operations plansthat include:
i. loading, transfer in -route and offloading of coal ash
ii. monitoring of vehicles along transportation routes
iii. emergency response in the event of accidental release of coal ash during transportation to mine
sites
iv. deanup standards
v. documentation of spills and any supporting documents should be retained as part of the
facility's operational record
2 �Rlcm

vi. documentation and records should be made available for review and inspection upon request.
Transportation of coal ash to the mine sites is expected to be complete within five to seven years.
Transport of ash will mainly be via rail, with trucking used asa contingency in the event of a delay or
disruption of rail traffic. As such, rail and contingent truck traffic in the study areas will be temporary.
1 Rail Trafficto the Mine Sites
C C P s are planned to be transported t o t he CDIon and Brickhaven mines by rail along a CSXCorporation
line. Once rail spurs are completed to the mine sites, one train comprised of 100 - 110 covered gondola
cars will travel to each site on average every three days. The trains carrying coal ash will be standard
coal trains that have between 100 and 110 rail cars. Based upon the existing train traffic in the area as
defined by CSX the communities will not experience a significant increase in train traffic.
All rail transportation routeswill be managed by CSX; therefore, all transportation of coal ash by rail will
be performed in accordance with Code of Federal Fagister (CPF , Title 49, Subtitle B, Chapter II (Federal
Railroad Administration) standards. Train personnel aretrained and tested in a000rdancewith CFR
49.242.119 (Training) and 49.242.121 (Knowledge Testing). Operational performance is monitored and
documented by local CSXmanagement staff as required by CFR49.242.123 (Monitoring Operational
Performance) which mandates monitoring the conduct of certified conductors by performing
unannounced operating rules compliance tests. Track infrastructure is inspected and maintained as
specified in CFR49.213 (Track Safety Sandards) and all signal systems that govern train movement are
maintained as outlined in CFR49.233 (Signal': rstem Reporting Requirements). Train noise is regulated
by CFR49.210 (Railroad Noise Emission Compliance Regulations).
CSXemploysasecure train and rail car monitoring system, SBcureNOW, which provides enhanced
monitoring to help law enforcement and emergency personnel prepare for and respond to emergency
situations. This system along with established procedures for coordinating with local emergency
responders can identify the status of rail traffic and help emergency vehicles avoid train traffic at
crossings. CSXalso maintains a dedicated railroad emergency hotline to report rail emergencies,
including blocked crossings and accidents. Additionally, Charah has an Emergency Action Ran in the
event ash is spilled from rail cars.
Truck Traffic to the M i ne Sites
In the event of temporary disruption to rail service to the mine sites, transportation of coal ash by truck
will be used as a short-term contingency. The truck route to the Colon mine is shown in Figure A-7 and
the route to the Brickhaven mine is shown in Figure A-5. These figures also show the location of schools
relative to the contingency trucking route. Truck operators are required to be properly licensed and
insured a000rdingto North Carolina state standards, attend Charah Safety Orientation, and remain
compliant with all applicable Charah safety rules. Drivers and trucks are subject to inspection and are
monitored by Charah management while on -site and traveling on roadways. Copies of safety training
and inspection documentsshall be maintained on -site by Charah site management. Additionally, Charah
hasan Emergency Action Ran in the event ash isspilled from trucks.
The selection of trucking routeswas designed to minimize trafficon local roadways. The primary
highway that would be used to access both mine sites is USHighway 1 (Us1). Us'1 is a four to six -lane
divided highway that already a000mmodates significant truck traffic.
3 �&C"

Truck traffic t o t he ODIon mine would travel north on UG1 to ODIon Fbad and onto Brickyard Fbad. This
route minimizes truck traffic on local roadways. The length of ODIon Fbad that would bet raveled by
trucks in the event of temporary rail disruption is approximately 3.6 miles. The length of Brickyard Fbad
traveled by truck would be approximately 1600 feet. This small percentage of route along local roads is
not expected to pose a disruption to local traffic. As the total bust raffic nearby the ODIon mine is
estimated to be six buses, truck traffic should not interfere with busing routes. Truck traffic would only
occur if rai I service was temporarily disrupted. In the event the contingent truck route is blocked or
inaccessible, a short -term detour is available off US1 via Amos Bridges Fbad or Farrell Fbad. These
alternative routes would avoid truck traffic through the city of Sanford and have minimal impact to
sensitive receptors.
Truck traffic t o t he Brickhaven mine would travel north on UG1 to Old US Highway 1 to Corinth Fbad to
M oncure- Ratwood Fbad. This route is frequently used by other trucks to access industrial
manufacturing facil it ies along Od US Highway land Corinth Fbad. The length of Corinth Fbad that
would bet raveled by trucks is four miles. This route avoids truck traffic along roads that travel through
residential areas, thus minimizing the potential for impacts to school bus routes. Based on the limited
number of buses serving the area near the Brickhaven mine and along trucking routes (which are
primarily industrial), disruption to school bust raffic is not antici pated. In the event the truck route along
Corinth Fbad is blocked or inaccessible, ashort -term detour is available off UG1 via Moncure- Ratwood
Fbad. This alternative route would not pass additional sensitive receptors. All detours would only be
short -term and minimally affect trucking routes.
%.3.3 Mitigation of Du:
Dust control measures will be used to mitigate airborne emissions from transport of coal ash. The
measures are required by North Carolina General Assembly (NOGA) regulation (Sanate Bill 729, Coal Ash
Management Act of 2014) and the structural fill permits and are intended to prevent dust from
becoming a nuisance or hazard to public health and safety. Coal ash will be conditioned to 20 percent
moisture to prevent dusting, and the use of an absorbent will prevent water from rising to the surface
during transport. Dust from rail cars is controlled by the use of gondola carsthat have a fiberglass cover
fitted and clamped to the car. Truckswould be equipped with tarps that are secured in place for
transport. The tarps are visually inspected to ensure they remain secure and in place, and have no tears,
rips or holes.
Unloading operations at the mine fill siteswould consist of removing the covers and the using straddle
carrier excavators to remove the ash. The load -out area will be paved and located above a liner system
designed to contain spillage of ash or contact water. Ash spillage would be collected with avacuum
truck and taken to the structural fill for placement. Contact water from the load -out area would be
collected in a sump and pumped to the leachate collection and treatment system.
After unloading, rail cars and trucks are cleaned of ash using awashing station and /or vacuum truck
prior to leaving the mine site. Residual ash that may be in the truck or rail container would be removed
during cleaning proceduresto minimize tracking dust outside of the facility. Truck and rail car exteriors
are cleaned and visually inspected to ensure that no residual ash remains before being released from
the structural fill facility.
4 �Rlcm

AA OONCWS NV
This addendum has specifically addressed how the transportation of coal ash t o t he mine sites would
impact school and emergency management traffic in Lee and Chatham counties. The information
contained in this addendum supports the conclusionsin the analysis of socioeconomic and
environmental justice issues fort he Colon mine and Brickhaven mine reclamation projects.
Transportation of coal ash t o t he mine sites is not expected to have adverse impacts on environmental
justice populations.
The Colon mine study area has a number of schoolswithin the five -mile radius, but most of the schools
are located south of the mine and would not be impacted by rail or contingency truck traffic. The route
selected for trucking, in the event of atemporary disruption to rail service, would avoid the most
populated areasof Lee County and travel along routesthat currently accommodate truck traffic. There
are an estimated six county school busestraveling the roadwaysthat would be impacted by rail
crossingsand contingency truck routes. The Brickhaven mine study area only hasone school within a
five -mile radius. There would be an estimated six buses traveling the roads in the vicinity of the mine
site.
The rail carrier, C9CCorporation, has numerous tools and operational procedures in place to manage
train traffic and facilitate swift emergency response. These CEXmeasures, along with Charah operational
plans and proceduresas set forth in the structural fill permits, would mitigate any impactson the
surrounding community due to dusting issues, traffic, and emergency incidents.
5 �RICH

Page 1 of 1
Table A,1
Race and Ethnidty Data for Schools Nearby Trucking andf or Rail Routes of the 9ickhaven and Colon Mines
Number
LEA Name
School
School Name
Numberof j Americanlndian
Asian 11
Hispanic 11 Black
White
TwoorMore
Padficlslander
Number
Students 11 Male
I Female 11
Male
I Female 11
Male
I Female 11 Male I Female 11
Male
I Female
Male
I Female
Male
Female
Public5choolsin the vdnityof the 9ickhaven Mine Study Area
190
Chatham County Schools
340
MoncureSchool
296 0.00%
0.34%
0.00%
0.34%
8.45%
6.76% 5.74%
34.12%
1.69%
1.69%
0.00%
0.00%
190
Chatham County Schools
342
Northwood High
1284 0.23%
0.16%
0.55%
0.55%
7.71%
118.11%1
5.69% 8.33% 7.09%
33.33%
132.77%11
32.71%
1.87%
1.79%
0.00%
0.00%
Public Schools in the vanity of the Won neStudyArea
530
Lee County Schools
302
BTBullodk Elementary
710 0.56%
0.00%
0.70%
0.28%
17.89%
17.04% 15.359%, 15.35%
16.20%
13.52%
1.41%
1.69%
0.00%
0.00%
530
Lee County Schools
312
Deep Rver Elementary
609 0.00%
0.00%
0.00%
0.00%
18.88%
21.51% 11.990%, 13.46%
15.93%
14.61%
2.13%
1.48%
0.00%
0.00%
530
Lee County Schools
314
East Lee Middle
686 0.58%
0.58%
0.29%
0.73%
16.91%
19.68% 8.31% 7.00%
20.70%
21.43%
2.19%
1.60%
0.00%
0.00%
530
Lee County Schools
335
Lee Early College
288 0.35%
0.35%
0.35%
1.39%
12.50%
23.96% 5.21% 9.03%
18.40%
26.74%
0.69%
1.04%
0.00%
0.00%
530
Lee County Schools
336
Lee County High
1493 0.27%
0.33%
0.13%
0.40%
14.53%
14.27% 9.51% 10.58%
25.18%
21.97%
1.34%
1.34%
0.07%
0.07%
530
Lee County Schools
354
JRIngram J Elementary
664 0.45%
0.15%
0.45%
0.60%
9.94%
10.24% 19.43% 14.31%
19.28%
20.78%
1.96%
2.41%
0.00%
0.00%
Warren Williams
530
Lee County Schools
358
9 0.00%
0.00%
0.00%
0.00%
11.11%
0.00% 33.33% 0.00%
44.44%
0.00%
11.11%
0.00%
0.00%
0.00%
Elementary Alternative
HALEY & ALDRICH, INC.
School Demographics Table.xlsx 7/10/2015

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IGH SCHOOL
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Rebekah Newton
From:
To:
Classification: UNCLASSIFIED
Caveats: NONE
Gibbu]ean 8 SAW <1eau8/GibbY@uoacearnlymi|>
Tuesday, June 30,2OI55:16PM
Rebekah Newton
Brown, Craig SAW; Burdette. Jennifer a; Pruitt, Carl ESAVV
EJ(UNCLAS5JFIED)
During our phone conversation nf 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.
2.8n 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 |eachate. 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 |eachate from the two coal ash
repositories and a letter of acceptance ofCharaM'a proposal by the company to process the |eachate. in addition, would
the private company be able to continue to process the leachate for the life of the project [mtheeventthattbeC(tyof
Sanford is either unable or unwilling tu process the leachate.
3.|n 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 io 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 27t The landfill [Anson County] can accept total of5O0,0OBtons 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 asacomponent of cement, your response
indicated that Duke Energy is sending 25,000 to (equals 300,00 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'|m 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 [AN1A14. 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 ELG|bbv
Chief, Raleigh Field Office
U.S. Army Corps ofEngineers
Regulatory Division
3331 Heritage Trade Drive, Suite 1Q5
Wake Forest, NC27587
The Wilmington District b committed to providing the highest level of support tn the public. Tn help us ensure vve
continue to do so, please complete the Customer Satisfaction Survey located at http://regulatory.usacesurvey.com/.
Classification: UNCLASSIFIED
Caveats: NONE