HomeMy WebLinkAbout20061203 Ver 2_Western Wake Comment Summary 9-27-07 PDT materials_20070927Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Comments on Materials Presented at September 27, 2007 PDT Meeting No. 5
Paul Barth - New Hill Community Association
New Hill community's position is that we want to be assured that Initial and
WRF Candidate Intermediate screening criteria is done for Site 14 even if it can not be
1 Screening to Develop eliminated at this time. USACE and DENR need to see that once Site 14 is Data for Site 14 will be provided with the WRF site screening analysis.
Alternatives compared to the "short list" of candidates that Site 14 is NOT the best site
for this project regardless of the Partners making it their preferred site.
Also, we do not agree that Site 14 could be approved just because it might
be "permitable". A project of this magnitude and impact to an entire
WRF Candidate community needs to be permitted once ALL factors are considered, not just
2 Screening to Develop the Partners preference. To allow outside municipalities to further destroy Site evaluations will consider various factors, including community
9 ty impacts.
Alternatives our rural area is not acceptable. New Hill community has already given
more than it deserves. For example: nuclear plant with potentially multiple
reactors, high voltage electrical power lines, power substations, gas
pipelines, major highways (US 1), Jordon Lake, etc.
The Nuclear Regulatory Commission (NRC) has stated that it expects Progress Energy
to request to build and operate two additional reactors at the Harris Nuclear Plant. In
order to increase the cooling water supply to accommodate the new reactors, the water
surface elevation of Harris Lake would need to be raised approximately 20 feet (to
elevation 240 feet). In addition to the increased inundation, Progress Energy expects
that a 50-foot water quality buffer will be needed around the new lake footprint.
Progress Energy has indicated to the Partners that the final determination of the water
surface elevation requirements for Harris Lake will be deferred until detailed technical
As for sites being eliminated due to potential PE raising the Harris Lake and environmental analyses are complete. Pending completion of those analyses,
level, 260 feet is questionable as a maximum elevation for flood storage. If however, Progress Energy has communicated to local governments that it will not
WRF Candidate the Partners continue to use 260 feet or suggest a higher elevation, we grant utility easements in the vicinity of Harris Lake below an elevation of 260 feet.
3 Screening to Develop would like to point out that the current nuclear reactor is located at 260 feet, The most recent communication to this effect was issued by Progress Energy to the
Alternatives and I don't think the NRC will allow existing or future nuclear reactors to be Town of Holly Springs in 2006 in response to a request by the Town for a water and
placed in a floodplain. Also, at 260 feet, this might even flood portions of sewer utility easement.
US 1. The design for the increased lake level will also have to provide for flood storage or
surcharge. Available information for Harris Lake shows that the documented flood
plain around Harris Lake for the current 220-foot conservation pool elevation ranges
from Elevation 240 to 260. This is a 20- to 40-foot difference from the conservation
pool elevation. Applying the minimum end of this range to the proposed new
conservation pool elevation would conservatively put the new 100-year flood plain
elevation at approximately 260 feet. Since the WRF is critical public infrastructure, it is
recommended that it be located to avoid inundation during the Harris Lake spillway
design event. That event should be at least the % probable maximum precipitation
(PMP) storm and will result in a water surface elevation above the 100-year flood plain.
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Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Comments on Materials Presented at September 27, 2007 PDT Meeting No. 5
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WOM
WRF Candidate Area will also be needed for mitigation for stream and wetland losses, loss of terrestrial
3 Screening to Develop habitat, and loss of Game Lands. Mitigation ratios are unknown at this time. Progress
(contd.) Alternatives Energy may also need to mitigate areas that were previously used for mitigation for the
(cont'd.) original project. For these reasons, USACE agrees that using 260 feet as the
maximum elevation is reasonable.
PDT Meeting # Site access will be measured in the Intermediate Screening Analysis as distance from
5 - WWRWMF Site access, transportation and other services. These need to be each WRF site boundary to the nearest major road (defined as an NC highway, a US
4 PowerPoint Slide 14 specifically defined so that a judgment can be made. highway, or an interstate) along a reasonable route. This will serve as an
Presentation approximation of the length of road that would need to be constructed (or
improvements made to existing roads) to access each WRF site.
PDT Meeting # For the Intermediate Screening Analysis, the length of pipelines criterion will consider
5 5 - WWRWMF
Slide 14 Length of pipelines. Specify size, pressures, cost per foot, routing, the length of influent and effluent pipelines required for each WRF site. Sizes, costs,
PowerPoint maintenance activity/monitoring, gravity lines, pumping stations, etc. routing, and other site-specific information will be considered during the detailed
Presentation evaluations conducted for the final few sites.
The NC Wildlife Resources Commission (WRC) is tasked with the conservation and
management of the state's fish and wildlife resources. NCWRC manages over 2
million acres of state Game Lands, which provide areas for research, restoration,
PDT Meeting # rehabilitation, and improvement of wildlife habitat. Game Lands provide recreational
6 5 - WWRWMF Slide 15 We don't see why it matters if a site is a designated Gameland. areas for citizens to trap, hunt, and fish. Construction of wastewater facilities on NC
PowerPoint Game Land will cause fragmentation and loss of wildlife habitat, loss of habitat
Presentation connectivity, and loss of recreational areas for citizens.
For these reasons, USACE agrees that including Game Lands as a factor in the
Intermediate Screening Analysis is reasonable.
PDT Meeting #
7 5 - WWRWMF
Slide 15 What is meant by public land? To our knowledge none of the sites being For the Intermediate Screening Analysis, public land will be defined as federal lands
PowerPoint considered land is public land. and state-owned land.
Presentation
For the Intermediate Screening Analysis, determinations of T&E species on site will be
PDT Meeting # made using the NC Natural Heritage Program's Natural Heritage Element Occurrence
5 - WWRWMF T&E species. As we understand, a US Fish and Wildlife person will need to GIS shapefile. For the detailed evaluations of the final few sites, biological
8
PowerPoint Slide 15 walk over the land to determine this. Can we go along with them for this assessments will be made by qualified biologists, either from the US Fish and Wildlife
Presentation survey? Service or a qualified consultant. Results of the surveys will be available for review.
USACE will check with USFWS to determine whether USFWS allows third parties to
participate in these surveys.
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Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Comments on Materials Presented at September 27, 2007 PDT Meeting No. 5
PDT Meeting # Social Parameters. We need to insure that very specific guidelines of
9 5 - WWRWMF Slide 15 NEPA and Federal EPA are defined and detailed analysis is presented for Environmental justice will be addressed thoroughly at the appropriate time as
PowerPoint
environmental justice issues. determined by USACE.
Presentation
In the Intermediate Screening, constructability will be measured by the amount of land
PDT Meeting # that is practicable for construction. This area will be identified on a map by first
10 5 - WWRWMF Slide 16 Constructability. Specific parameters need to be defined, percent slope eliminating the perimeter buffer and stream buffers to the extent practicable. The
PowerPoint over how much area, definitions to "constructible area," etc. practicable area will then be delineated to achieve an area of approximately 50 acres
Presentation of contiguous area of a reasonable shape while avoiding environmental impacts to the
extent practicable.
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