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Home My WebLink About20060645 Ver 2_More Info Received_20120111Strickland, Bev From: Homewood, Sue Sent: Wednesday, January 11, 2012 12:44 PM To: Strickland, Bev Subject: FW: Belews Creek Steam Station Landfill Expansion SAW- 201100972 (UNCLASSIFIED) Attachments: Response to USFWS_2012.01.11.pdf For file 06 -0645 v2 Sue Homewood NC DENR Winston -Salem Regional Office Division of Water Quality 585 Waughtown Street Winston - Salem, NC 27107 Voice: (336) 771 -4964 FAX: (336) 771 -4630 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: Darrin Peine fmailto:DPeineksmeinc.coml Sent: Wednesday, January 11, 2012 12:37 PM To: Thomas, John T JR SAW Cc: Homewood, Sue; Leap, Tom Y Jr; Kenneth Daly Subject: RE: Belews Creek Steam Station Landfill Expansion SAW- 201100972 (UNCLASSIFIED) Hello John, I have attached to this message as "Response to USFWS 2012.01.11.pdf' our response to the USFWS public notice comments that you provided for review on January 05. We believe our response adequately addresses the USFWS comments, however, please let me know if you have any questions with the information. It is my understanding that following the close of the second public notice, barring any upsetting comments, you will possibly be in a position to render a decision on the 404 permit after receiving the state's WQC 401 permit. In December I provided an updated impacts table to include the FGD area of potential impacts and Kelly Williams from EEP provided a revised response letter for the In -Lieu Fee mitigation request. Please let me know if you need any additional information or assistance from us. We appreciate yours and Sue's attention to this prof ect! Regards, Darrin Peine Project Scientist S &ME, Inc. 704 -523 -4726 - office 704 - 930 -5670 - mobile dllelnena,smelnc. com www. smemc. com - - - -- Original Message---- - From: Thomas, John T JR SAW fmailto: John. T. Thomas. JRnausace.army.mill Sent: Thursday, January 05, 2012 5:23 PM To: Darrin Peine Subject: FW: Belews Creek Steam Station Landfill Expansion SAW- 201100972 (UNCLASSIFIED) Classification: UNCLASSIFIED Caveats: NONE Darrin Please review the attachments and provide me your comments by e -mail John Thomas Raleigh Regulatory Field Office 919 554 -4884 ext. 25 - - - -- Original Message---- - From: Thomas, John T JR SAW 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(afws.gov fmailto:Allen RatzlaffAfws.govl 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 Classification: UNCLASSIFIED Caveats: NONE January 11, 2012 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 John.T.Thomas.JR@usace.army.mil Reference: Response to USFWS December 21, 2011 Comments to Individual Permit Application Amendment Duke Energy — Belews Creek Steam Station Proposed Craig Road Landfill Expansion, Stokes County, North Carolina S &ME Project No. 1356 -10 -041 USACE Action ID No. 2011 -00972 Dear Mr. Thomas: Thank you for providing the U.S. Fish and Wildlife Service ( USFWS) letter response dated December 21, 2011 from the U.S. Army Corps of Engineers ( USACE) Public Notice for the proposed expansion of the Craig Road landfill project. S &ME, Inc., (S &ME) on behalf of Duke Energy is providing this response to the USFWS letter. As stated in the permit application and supplemental information, the project purpose is to provide disposal capacity for the next 32 years for the coal combustion products generated at Duke Energy's Belews Creek Steam Station. Duke Energy currently disposes coal combustion products at two on site landfills, the Craig Road landfill and the FGD landfill. Based on current projections, the Phase 1 Craig Road landfill will reach capacity in early 2013, and the FGD landfill will reach capacity in early 2014. We understand the USFWS recommendation is to permit the "Alternative C Supplement" (which is the FGD landfill expansion) before any other alternatives. Please note that this is referred to as the "Alternative D (existing FGD landfill) in S &ME's November 8, 2011 Individual Permit Application Amendment. The "Alternative C Supplement" would provide an estimated 8 years of capacity. Furthermore the USFWS recommends permitting Alternative B (no stream and wetland impacts) second and this would provide approximately 6 more years of capacity. The two alternatives together, stand to provide about 14 years of capacity therefore not meeting the project need and purpose. S &ME, INC. /9751 Southern Pine Blvd/ Charlotte, NC / p 704.523.4726 / f 704.525.3953/www.smeinc.com Response to USFWS December 21, 2011 Comments S &ME Project Number 1356 -10 -041 Proposed Craig Road Landfill Expansion January 11, 2012 The proposed Alternative C (proposed location) is estimated to provide 24 years of capacity. The proposed Alternative C (proposed location) combined with the Alternative D (existing FGD landfill) can provide an estimated 32 years of capacity. Considering the inherent variables associated with a project of this scope and magnitude and the information previously submitted to the agencies it is our opinion that permitting the proposed Alternative C (proposed location) coupled with the proposed Alternative D (existing FGD landfill) if needed is the preferred path because it meets the stated project need. In addition, the USFWS has indicated that stream mitigation should be considered at a higher ratio than 1:1. However, S &ME has previously confirmed with the USACE that a 1:1 stream mitigation ratio is appropriate for this project. Thank you for your assistance with this project. Sincerely, S &ME Imo[- Kenneth Daly, P.E. Darrin M. Peine, QEP Senior Project Engineer Natural Resources Project Scientist kdalv(&smeinc.com dneine(&,smeinc.com CC: Tom Leap, Duke Energy Sue Homewood, DWQ Winston -Salem Regional Office