20060645 Ver 2_Mitigation_20110105

Strickland, Bev
From: Homewood, Sue
Sent: Thursday, January 05, 2012 4:39 PM
To: Strickland, Bev
Subject: FW: Belews Creek Steam Station Landfill Expansion SAW- 201100972 (UNCLASSIFIED)
Attachments: 11 -061 Belews Creek Steam Station Landfill Expansion 3.pdf
For file 06 -0645 v2 please
Sue Homewood
NC DENR Winston -Salem Regional Office
Division of Water Quality
585 Waughtown Street
Winston - Salem, NC 27107
Voice: (336) 771 -4964
FAX: [phone]
E -mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed
to third parties.
- - - -- Original Message---- -
From: Thomas, John T JR SAW fmailto: John. T. Thomas. JR(,usace. army. mil]
Sent: Thursday, January 05, 2012 4:29 PM
To: Homewood, Sue
Subject: FW: Belews Creek Steam Station Landfill Expansion SAW- 201100972 (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
Sue
Attached are the FWS comments we discussed. It appears that their recommendation is to permit just the supplement (i.e. the
FGD landfill) which would give 8 years of capacity. Duke could then use the 8 years to examine other alternatives to avoid
additional impacts. It does not account that the FGD landfill is currently being used for storage and would conflict with existing
separation of fly ash from the FGD stock piling plus the point of the permit is a long term action (i.e. 32 years). At first review,
I do not see this as a practical alternative because of the stated reasons.
I plan to talk to Darrin and I will let you know what was discussed.
John Thomas
- - - -- Original Message---- -
From: Allen Ratzlaff(&fws.aov fmailto:Allen Ratzlaffnafws.aovl
Sent: Wednesday, December 21, 2011 10:10 AM
To: Thomas, John T JR SAW
Cc: shari.b ant �,newildlife.org
Subject: Belews Creek Steam Station Landfill Expansion SAW- 201100972
Attached are comments from the U.S. Fish and Wildlife Service.

Allen Ratzlaff
USFWS
160 Zillicoa St.
Asheville, NC 28801
828/258 -3939 x229
Classification: UNCLASSIFIED
Caveats: NONE

'�qRC ;sag Asheville Field Office
160 Zillicoa Street
Asheville, North Carolina 2880I
December 21, 2011
Mr. John Thomas
Raleigh Regulatory Field Office
U.S Army Corps of Engineers
3331 Heritage Trade Drive, Ste. 105
Wake Forest, North Carolina 27587
Dear Mr. Thomas:
Subject: Public Notice for the Proposed Expansion of the Craig Road Landfill, Duke Energy
Belews Creek Steam Station, Stokes County, North Carolina (Action ID: 2011 - 00972)
This is the report of the U.S. Fish and Wildlife Service and the Department of the Interior on the
U.S. Army Corps of Engineers' (Corps) public notice (PN) of an application for an individual
permit submitted by Duke Energy Belews Creek Steam Station, represented by Mr. Tom Leap.
Information for this report is based on a review of the subject PN, the original PN issued by the
Corps (June 23, 2011) and a letter from S &ME, Inc. to the U.S. Fish and Wildlife Service (dated
November 19, 2010) pertaining to the project. We previously commented on this project in a
letter to you dated June 27, 2011. This report is submitted in accordance with the provisions of
the Fish and Wildlife Coordination Act, as amended (16 U.S.C. 661- 667e), the National
Environmental Policy Act (42 U.S.C. §4321 et seq.); the Clean Water Act (33 U.S.C. §1251 et
seq.); and section 7 of the Endangered Species Act of 1973, as amended (16 U.S.C. 1531 -1543)
(Act).
Project Description (from subject PN) — The proposed landfill expansion project (Alternative
C) will extend the existing Phase 1 Craig Road Landfill to the south. The proposed landfill
expansion will be organized and developed in about five -year operational phases consistent with
the North Carolina Department of Environment and Natural Resources (NCDENR) Solid Waste
Section regulations and permitting requirements. Based on anticipated waste generation rates,
the proposed landfill expansion is estimated to provide about 24 -25 (both values are given at
different times throughout the PN) years of disposal capacity. The Craig Road Landfill areas
were evaluated for available waste management capacity, access, operation, groundwater and
surface water monitoring systems, and operational flexibility. In general, anticipated landfill
construction will require installation of erosion and sediment control measures, clearing, mass
grading of existing ridges and valleys to establish landfill base grades, constructing a stormwater
management system, and constructing the landfill liner system. Consistent with the existing
Phase 1 landfill, the proposed landfill expansion will be constructed with a composite liner
system. From the top down, the liner system will consist of a leachate collection system, a 60-
mil thick high density polyethylene geomembrane, a geosynthetic clay liner with a permeability

U.11U U.1 VU11U L11%, 1 V1,11113 CL11U VV111 Ul V.,1 L V V 1,11U11U
flow from entering the proposed landfill area. Stormwater adjacent to the landfill will be
controlled by diverting run -on away from disturbed areas of the site and collecting runoff from
disturbed areas in ditches that lead to sediment traps and basins. Stormwater will be managed
and controlled within the landfill by operational, intermediate and final covers. Stormwater
contacting the waste material will be diverted to the leachate collection system. Stormwater
infiltrating the waste material will be collected in the underlying leachate collection system of
the landfill liner. Contact water and leachate will be conveyed to leachate storage basins and
transferred to the BCSS active ash basin.
The proposed landfill development is organized in approximate five -year operational capacity
increments, referenced as phases. The five -year operational capacity is based on current
estimated coal combustion product generation rates. The landfill development approach is to
provide the most volumetric capacity over as small an area as possible. The optimal landfill
layout that satisfies the development approach consists of side -by -side, contiguous phases
developed in sequence. That is, with each new phase developed next to and connected to the
prior phase. Waste placement in each new phase will lie over or "piggy back" on the prior
phase, thus providing more volumetric capacity for the given area. This development approach
decreases the overall land area required to meet the project need because it maximizes the
volumetric capacity for a given area.
As currently designed, the proposed project (Alternative C) would permanently impact 0.27
acres of forested wetland and 4,592 linear feet of stream - the existing Craig Road Landfill
previously impacted 701f of stream.
Alternative Considered — Six alternatives were analyzed and Alternative C was selected based
on environmental impacts, cost, solid waste regulations, and meeting the project purpose and
need. The following summarizes the alternatives considered:
Alternative A (No Action): The landfill expansion would not be constructed and existing
stream and wetland areas would not be disturbed. This alternative was not selected
because it does not meet the need to provide for continued and future coal combustion
product disposal capacity.
Alternative B (proposed location with stream /wetland avoidance): This alternative avoids
impacts to streams and wetlands within the proposed Craig Road Landfill expansion area.
However this alternative falls short of the project need lifetime and would require future
landfill expansion or development on Greenfield sites. Considering the regional geology
and topography, it is likely that streams and wetlands would be impacted during future
landfill expansions at other locations. For these reasons, landfill expansion with
stream /wetland avoidance was considered the second most desirable option.
Alternative C (proposed location): This alternative include impacts to jurisdictional
features within the Craig Road Landfill expansion area and provides airspace for about
24 years of facility operations. It is the most cost - effective option in terms of anticipated
cost per cubic yard of airspace and comes closest to meeting the project need lifetime.
2

uw11au1%1 vFL'%J"-
Alternative D (other sites on Duke property): This alternative falls short of the project
need lifetime and would require future landfill expansion or development on Greenfield
sites. Considering the regional geology and topography, it is unlikely to avoid impacts to
unknown jurisdictional features. This alternative is less cost - effective than Alternative C.
For these reasons, developing another on -site location was considered the third most
desirable option.
Alternative E (developing off -site property): This alternative may minimize impacts to
unknown jurisdictional features, however based on the general topography of the region
and considering estimates indicate that more than 300 acres of property would be needed,
similar quantities of jurisdictional impacts are possible. Whether or not this alternative
could provide for the project need lifetime is uncertain. This alternative likely requires
developing a previously undeveloped, Greenfield property. Additionally, because the
landfill is unlikely to be contiguous to existing Duke property, landfill construction and
operations are likely to be more obtrusive. Also, this alternative is less cost - effective
than Alternative C. For these reasons, developing an off -site location was considered the
fourth most desirable option.
Alternative F (disposal at a regional landfill): This alternative may avoid impacts to on-
site streams and wetlands, however it does not meet the project need timeframe and
regional MSW solid waste disposal capacity would be reduced substantially.
Additionally, disposal at an existing regional landfill would require an increase in haul
distance, cost of waste transport and tipping fees, and increase in truck traffic. For these
reasons, disposal at an existing regional landfill was considered the fifth most desirable
option.
The PN explains that Alternative C, the proposed landfill expansion configuration, was selected
as the best alternative based on the factors of environmental impacts, cost, solid waste
regulations, and whether or not the alternative meets the project purpose and need. Alternative C
provides the most efficient land use in terms of the volumetric capacity generated for the land
area developed and as a result, provides the most cost - effective alternative. The applicant
believes that Alternative C is very likely to satisfy siting and design criteria and gain Solid Waste
Section permit approval on the basis that it is an expansion of an existing approved and permitted
landfill. In addition, Alternative C was evaluated as the best alternative because it comes the
closest to meeting the project need, providing an estimated capacity of 24 -25 years.
To mitigate for the anticipated impacts, the applicant has proposed a payment into the North
Carolina Ecosystem Enhancement Program (NCEEP). The appropriate number and resource
type credits were not available from any private mitigation banks within the 8 -Digit Cataloging
Unit 03010103, at the time the application was submitted.
All of the above description is the same as in the June 23, 2011 PN issued by the Corps. The
subject PN includes section entitled "Supplemental to Alternative C" to explain why, even
though Alternative C alone does not meet the stated purpose and need of 32 years of landfill

aiiu L11%, iiiaii�%,LaviiiLy Ul "Y aoii. vr1L11 L11%, vaiiaui%,o Lcm%,ii llll,v �.vuoiu�,ia�ivu, L11%,
applicant believes a "worst- case" scenario would result in Alternative C reaching capacity in 24
years. To provide for the potential 8 years of additional capacity needed, the existing FGD
landfill would /could be expanded. This would result in an additional 699 linear feet of stream
being impacted and an additional 0.478 acres of wetland being filled. These impacts would also
be mitigated through a payment into the NCEEP. The appropriate number and resource type
credits were not available from any private mitigation banks within the 8 -Digit Cataloging Unit
03010103, at the time the application was submitted.
Fish and Wildlife Service Concerns — The applicant's stated Purpose and Need is to secure a
coal combustion product disposal capacity for the next 32 years. Though none of the alternatives
originally met this goal, the selected alternative (Alternative C), which was originally only
expected to provide capacity for 24 or 25 years (both time - frames are stated in the application),
was expanded to include the expansion of the existing FGD landfill which is expected to be able
to provided capacity for the additional 8 years, if needed. Because "Supplemental to Alternative
C" can also be applied to Alternatives B, D, E, and F, the benefits (capacity) and adverse impacts
(streams and wetlands) should be considered a part of all action alternatives.
Because of the uncertainty in the amount of future landfill capacity needed, we continue to
support Alternative B (no stream or wetland impacts). Our support for Alternative B is
strengthened by the availability of the "Supplement to Alternative C" being available for this
alternative — far fewer impacts than Alternative C in combination with the supplement.
We recommend the "Supplement to Alternative C" be permitted before any of the other
alternatives. Doing so will minimize impacts over Alternative C (the applicants preferred
alternative), and because it is expected to provide at least 8 years of capacity, it will provide time
to better determine the amount of capacity needed for the remaining 18 to 24 years. Should less
than the "worse case combination of variables" fail to materialize, Alternative B (with no stream
and wetland impacts) may provide all the future capacity needed.
Mitigation — The applicant's preferred alternative (Alternative C and Supplemental to
Alternative C) will impact about 5,291 if of streams and 0.748 acre of wetlands. As previously
stated, to mitigate for project impacts, the Applicant is proposing payment into the NCEEP.
However, because the application does not detail the quality of the streams to be impacted, the
appropriate mitigation ration is not discussed in the application. No matter which alternative the
Corps decides to allow to go forward, an assessment of the quality of each of the streams needs
to be completed to determine the appropriate mitigation ratios and the amount of mitigation
required. If the streams are of good quality, we believe a 2:1 ratio should be used to calculate the
amount of mitigation credits required. A minimum of a 2:1 ration should be used for the wetland
impacts.
Federally Listed Species — According to our records and a review of the information provided,
no federally listed species or their habitats occur on the sites proposed for any of the reviewed
Alternatives except Alternative E (site unknown). However, obligations under section 7 of the
Act must be reconsidered if: (1) new information reveals impacts of this identified action that
may affect listed species or critical habitat in a manner not previously considered, (2) this action
11

We appreciate the opportunity to provide these comments. If we can be of assistance or if you
have any questions, please do not hesitate to contact Mr. Allen Ratzlaff of our staff at 828/258-
3939, Ext. 229. In any future correspondence concerning this project, please reference our Log
Number 4 -2 -11 -061.
cc:
Ms. Shari L. Bryant, Eastern Piedmont Region Permit Reviewer, North Carolina Wildlife
Resources Commission, P.O. Box 129, Sedalia, NC 27342 -0129