20060645 Ver 2_Public Notice Comments_20110818

*S&ME
August 12, 2011
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
North Carolina Division of Water Quality
401 Wetlands Unit
2321 Crabtree Boulevard, Suite 250
Raleigh, North Carolina 27604-2260
Attention: Mr. ]an McMillan
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of ENR
AUG 1 2011
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ftcYjioral Office
Regarding: Response to June 27, 2011 Public Notice Comments
Duke Elnergy - Belews Creek Stearn Station
Proposed Craig Road Landfill Expansion, Stokes County, North Carolina
S&ME Project No. 1356-10-041
USACE Action ID No. 2011-00972
DWQ No. 06-0645
Dear Mr. Thomas and Mr. McMillan:
S&ME, Inc., (S&ME) on behalf of Duke Energy hereby acknowledge the concerns of the
U.S. Fish and Wildlife Service (USFWS), as expressed in their letter to you, dated June
27, 2011 regarding the Public Notice of the proposed expansion of the Craig Road
Landfill. S&ME would like to provide the following additional information to address
the specific concern that the selected alternative (Alternative C) is not expected to
provide adequate capacity to meet the stated purpose and need which is to secure a coal
combustion product disposal capacity for the next 32 years.
S&ME identified and evaluated six alternatives to secure coal combustion product
disposal capacity to support the continued and future power generation at the Belews
Creek Steam Station. The proposed landfill configuration depicted as Alternative C is
estimated to provide nearly 24 years of capacity based on estimated annual coal
combustion product generation rates. This Alternative provides the most capacity of the
alternatives evaluated.
S&ME, INC. / 9751 Southern Pine Boulevard / Charlotte, NC 28273-5560 / p 704.523.4726 / 704.525.3953 / www.smeinc.com
Response to USFWS Public Notice Comments
Proposed Craig Road Landfill Expansion
S&ME Project Number 1356-10-041
August 12, 2011
A landfill project of this magnitude that spans tens of years, takes several inherent
variables into consideration in estimating coal combustion product generation rates. One
variable is the future power demand, which is subject to fluctuation with market and
consumer demands. Future power demand influences the operating life of the Belews
Creek Steam Station and the quantity of coal combustion products generated. A second
variable involves the characteristics of the coal burned, which affects coal combustion
product generation rates. A third variable is that coal combustion products are
marketable for beneficial reuse that decreases the demand for landfill capacity. Fly ash
(coal combustion by-product) is recovered and recycled as a cement replacement in
concrete and flue gas desulfurization residue (FGD, also known as synthetic gypsum) in
wall board production.
Working closely with Duke Energy personnel we have considered these variables and are
using annual coal combustion product generation rates that we believe are on the upper
range of generation rates. Considering the inherent variables, we believe pursuing the
proposed Alternative C is a prudent step to meet the project need.
As noted in the June 9, 2011 Application for Section 404 Individual Permit (Individual
Permit Application), Section 3, Project Purpose and Need, Duke Energy operates two
permitted on-site landfills; the Craig Road Landfill and the FGD Landfill. Based on
current projections, the Craig Road Landfill is estimated to reach capacity in the second
quarter of 2013 and file FGD Landfill will reach capacity in the first quarter of 2014. The
proposed Alternative C is for expansion of the Craig Road Landfill. When the FGD
Landfill reaches its capacity, it is Duke Energy's intent to place FGD in the Craig Road
Landfill. Six on-site locations were evaluated for Alterative D "Other On-Site
Locations" which are summarized in the Individual Permit Application. Tire FGD
Landfill expansion was one of the six on-site locations considered as Alterative D.
identified as Site Number 5 in Table T-1. The FGD landfill has potential for lateral
expansion that can provide the capacity to meet the remaining need.
The proposed Alternative C (proposed location) combined with Alternative D (Site
Number 5) can meet the stated project need. A possible future scenario is that Duke
Energy will pursue expansion of the FGD Landfill, when (or if) future conditions
indicate that the Craig Road Landfill capacity is diminishing while the need for landfill
space remains. The FGD Landfill expansion project will need to begin within five years
of the Craig Road Landfill reaching its capacity to allow adequate time for permitting,
design, and construction.
Considering the inherent variables associated with a landfill project of this magnitude and
duration, coupled with the potential for Alternative C when combined with Alternative D
Site 5 (the existing FGD Landfill) if needed, to meet the project need, we conclude that
Alternative C is preferred. In addition, considering the uncertainty surrounding
developing another site that may meet the stated project need yet has fewer speculated
impacts, it is our opinion that Alternative C, the proposed landfill configuration, is the
preferred alternative.
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Response to USFWS Public Notice Comments SWE Project Number 1356-10-041
Proposed Craig Road Landfill Expansion August-12,2011
Thank you for your assistance with this project. Please notify us if there may be
additional information we can provide to satisfy the concerns expressed by the USFWS.
Sincerely,
S&ME

Kenneth Daly, P.E.
Senior Project Engineer
Senior Review by Al Quarles
a Yq, pt?
Darrin M. Peine, QEP
Natural Resources Project Scientist
CC. Tom Leap, Duke Energy
Sue Homewood, DWQ Winston-Salem Regional Office
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