20201283 Ver 1_401_IC_Comments to USACE_20210104

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANI£L SMITH
Director
NORTH CAROLINA
Environmental Quality
January 4, 2021
Corps Action ID# SAW-2015-02646
DWR# 20201283 v1
Person County
Chris Hopper
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
331 Heritage Trade Drive Suite 105
Wake Forest, NC 27587
(Delivered via email at [e-mail])
Subject Project: Duke Energy Roxboro Steam Electric Plant Ash Basin Landfill Project
Dear Mr. Hopper,
On behalf of the NC Division of Water Resources (Division), we respectfully request that you
consider the following comments within your review of the 404 Individual Permit request for
the above referenced project:
1. The Division recommends that the USACE consider accepting a reduced 1:1 mitigation
ratio only for those areas with a NCSAM or NCWAM score of low, or those with a score
of medium that are directly influenced by the existing ash basins.
2. The application indicates that borrow areas located near the Roxboro plant have been
chosen primarily due to "shorter distances between borrow areas and the landfill
expansion" which "decreases time and cost for each load of suitable fill material." The
Division does not believe that cost and/or ease of transport of borrow material meets
purpose and need or satisfies avoidance and minimization. While the Division
understands the desire to reduce costs and potential safety issues, more justification for
impacts related to borrow areas is needed beyond these considerations.
3. The Division has requested additional technical information from the applicant and
requests that the USACE also consider the attached letter during the review of the
application.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
N11H fH (:Ai(1!.INA �
0­O,toreWM—talQ"I 919,707.9000

Corps Action ID# SAW-2015-02646
DWR# 20201283v1
Page 2 of 2
Thank you for your considering the Division's comments during your review of this Individual
Permit. If you have any questions, please contact Rick Trone at [e-mail].
Sincerely,
DocuSigned by:
� , e 10
949D91BA53EF4E0...
Paul Wojoski, Supervisor
401 & Buffer Permitting Unit
cc: Julia Tillery, Wood MIS (via email)
Lori Tollie, Duke Energy (via email)
Steven Lanter, DWR GRS
DWR 401 & Buffer Permitting Branch file