20150041 Ver 1_Add Info 2015713 to USACE_20150713

Burdette, Jennifer a
From: Rebekah Newton <rebekah @cwenv.com>
Sent: Monday, July 13, 2015 1:47 PM
To: Jean.B.Gibby @usace.army.mil; Craig.J.Brown @usace.army.mil
Cc: Burdette, Jennifer a
Subject: Brickhaven and Sanford Mines
Attachments: Corps Email 06.30.15.pdf
Dear Ms. Gibby and Mr. Brown,
Please reference the email dated June 30, 2015 (attached) sent by the US Army Corps of Engineers (Corps) in
response to the permit application submitted by ClearWater Environmental Consultants, Inc. (CEC), on behalf
of Green Meadow, LLC represented by Mr. Charles Price. The permit application requested written
authorization for the impacts associated with disposal of coal ash at the Brickhaven and Sanford
Mines. Comments 4 -8 provided by the Corps in the referenced email are listed and discussed below (comments
1 -3 will be address in a separate email at a later date).
Comment 44 — "On page 25 of the Project Alternatives analysis, the availability of industrial solid waste
landfills in North Carolina operated by Duke Energy at eight power generation plants is discussed. Besides the
industrial solid waste sites owned and operated by Duke Energy, were other industrial solid waste landfills
identified and contacted concerning their availability to take some of the coal ash? Please discuss."
Industrial solid waste (ISW) is defined as waste that is generated by businesses from an industrial or
manufacturing process; or waste generated from non - manufacturing activities that are managed as a
separate waste stream. Industrial solid waste is a special classification of non - hazardous, non - household
waste that requires special evaluation (characterization) to determine the proper disposal
method. Generally, ISW landfills are monofills. A monofill landfill or cell is designated and tailored
for only one specific type of waste. Due to liability concerns with mixing waste products, Duke requires
a monofill landfill operation for disposal of coal ash (industrial solid waste landfills at plant sites are
monofill).
The NC Department of Environment and Natural Resources, NC Division of Waste Management, Solid
Waste Section identifies 60 ISW landfills as occurring in North Carolina. Of the 60 landfills, 15 are
listed as "open" or active. Nine of the open landfills are associated with power generation and are
owned and operated by Duke: Allen, Belews Creek (two landfills), Cliffside, Mayo, Marshall (two
landfills), Roxboro, and McGuire Nuclear Station. Duke -owned ISW landfills were discussed in the
permit application. Six of the open landfills are private ISW landfills owned by
businesses: International Paper (wood pulping), OmniSource Southeast (metal recycling), Blue Ridge
Paper Products (wood pulping), Eveready Battery (manufacturing), Domtar Paper Company (wood
pulping), and Louisiana - Pacific Corporation (industrial wood products and pulping).
ISW landfills at manufacturing facilities are reserved for the specific waste product generated at the
facility where the landfill is located. Placing ash at these landfills is not possible because they are
private landfills reserved for the facility, the waste stream characterization at these sites does not include
coal ash, and the sites would no longer be monofill as required. For these reasons, privately held ISW
landfills are not feasible for the disposal of coal ash.
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Comment 45 — "Stated in the Project Alternatives (page 27): The landfill [Anson County] can accept a total of
500, 000 tons of ash with the possibility of accepting additional tonnage in 2 -3 years. " What agreements, if any,
does Duke Energy have with the Anson County Landfill to accept coal ash."
Use of the Anson County Landfill is an option for disposal; however, Duke has opted to not utilize the
Anson County Landfill at this time. Anson County can provide an initial disposal volume of up to
500,000 tons and will have a new cell that could be devoted to ash placement. The new cell could
contain up to 2 million tons of ash and will be ready by the third quarter of 2015. Even with new cell
construction, Anson County cannot accept all ash that needs disposal. At best, Anson County would
have the ability to contain up to approximately 5% (2.5 million tons) of all the ash needing
disposal. Mandates in CAMA14 require all ash from Riverbend and Sutton be removed by August 1,
2019. The CAMA14 timeline does not provide enough time to complete additional landfill expansions
nor is the permitting process for landfill expansion guaranteed. However, use of the Anson County
Landfill remains an element of the comprehensive ash basin closure /excavation strategy.
Comment 46 — "In addition, with regards to alternatives analysis, please discuss the viability of saltstone
encapsulation as several comments from the public pertained to this topic and considered it a viable
alternative. Please discuss this alternative for our inclusion in the alternatives analysis."
Saltstone is a by- product of nuclear waste disposal. Currently, the only facility in the United States
producing saltstone as described by the commenters is in Aiken, South Carolina at the Department of
Energy's (DOE) Savannah River Site (SRS). The Savannah River Site was originally constructed
during the early 1950s to produce the basic materials used in the fabrication of nuclear weapons,
primarily tritium and plutonium -239, in support the United States' defense programs. Nuclear waste
from the SRS is immobilized in two separate waste forms: glass, which contains approximately 99% of
the radioactivity, and cement -like grout (saltstone), which contains most of the volume. Soluble salts
from the nuclear waste are treated to remove radionuclides. The treated salt solution is then sent to a
Saltstone Production Facility (SPF). At the SPF, the low- radioactive salt solution is stabilized by
mixing it with cement, fly ash, and ballast furnace slag. The resulting grout mixture is mechanically
pumped into concrete disposal vaults (divided into cells) that make up the Saltstone Disposal Facility
(SDF). There, the grout solidifies into saltstone which is a non - hazardous, low- radioactive, stable waste
form. Each cell is 100 feet long, 100 feet wide, and 25 feet tall. After filling, the vaults are capped with
clean concrete to isolate them from the surrounding environment. Final closure of the area where the
vaults are located consists of covering the vaults with engineered closure caps, backfilling with clean
soil, and seeding to control water infiltration and erosion.
Coal ash is a component of saltstone production but saltstone production is not specifically an ash
disposal method. For many decades, steam and power needed to operate the SRS facilities was
produced by an on -site coal- burning powerhouse. As a result, the SRS contains four coal ash basins
comprised of approximately 100 acres. Approximately 1.3 million cubic yards of coal ash is contained
within these basins. In June of 2015, excavation of the coal ash at the SRS began. According to a recent
press release, coal ash is being consolidated into two mounds. Each mound will be capped with a thick
earthen cover consisting of fill dirt, a synthetic material, and clay. The basin closure plan was developed
and approved by a core team consisting of members of the DOE; and state and federal environmental
agencies. According to the press release, the "closure plan uses proven technology and methods
successfully implemented in the past to close contaminated, water - filled basins at the SRS ". The SRS is
using the same methodology and technology to close ash basins as the proposed projects at the Sanford
and Brickhaven mines. Coal ash disposal and saltstone production are two different processes for
disposing of two very different waste materials.
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Additionally, saltstone disposal is generally comprised of the same or similar steps as coal ash
disposal. Coal ash would still need to be removed from existing basins and hauled, not only to a
disposal location but, to a production facility resulting in double - handling of waste materials. The final
waste product still needs to be buried and encapsulated requiring large land areas. And, the closed site
would still be required to treat leachate and monitor for chemical constituents in groundwater and
surface waters. Saltstone disposal would require more land area because a SPF would need to be
constructed and because coal ash is only a component of saltstone. Higher volumes of saltstone would
need to be produced to dispose of a specific volume of coal ash when compared to disposing of the same
volume of coal ash as a single component of the waste. Because of the link to radioactive waste, the
need for construction of a production facility, and the increased land requirements, saltstone production
was not considered a feasible alternative for disposal of coal ash.
Comment 47 — "When referencing the comment pertaining to coal ash being utilized as a component of cement,
your response indicated that Duke Energy is sending 25,000 tons /mth (equals 300,000 tons per year) to
Roanoke Cement Co. and plans to send 10,000 tons /mth from Riverbend, resulting in 115,000 tons. Is the
10, 000 tons per month in addition to the 25, 000 tons per month already being sent."
The permit application indicated that Duke Energy was sending approximately 25,000 tons of coal ash
per month to Roanoke Cement Company for their use in production of Portland Cement; this included
10,000 tons of ash per month from Riverbend. A recent investigation into the presence of fire ants
within the ash material at Riverbend found conclusive evidence of fire ant infestation. The US
Department of Agriculture, Animal and Plant Inspection Service (APHIS) and State cooperators work to
prevent artificial (human assisted) spread of fire ants by enforcing a Federal Quarantine (7 CFR
301.81). The Federal Quarantine places restrictions on interstate movement of "regulated
articles ". "Regulated articles" include fire ants and any material that is capable of transporting fire
ants. Restrictions are imposed on the movement of "regulated articles" from quarantined areas into or
through non - quarantined areas. Coal ash would be considered a "regulated article ", Mecklenburg and
Gaston Counties are both included in the Federal Quarantine area, Troutville, Virginia (the location of
Roanoke Cement Company) is not included in the Federal Quarantine area. In order to comply with the
Federal Quarantine, Duke Energy cannot transport coal ash from Riverbend in North Carolina to the
Roanoke Cement Company in Virginia because of the presence of fire ants; therefore, this reuse option
has been removed from the list of alternatives.
Comment 48 — "P & N - In your comment response letter, you stated that the Applicant's Redefined Project
Purpose- The purpose of the proposed project is to dispose of coal ash in a suitable manner, using the best
available technology , and in an environmentally sound location. The long -term disposal of coal ash in suitable
locations will facilitate the closing of coal ash basins across North Carolina, as required by the CAMA14. In
discussing this purpose with our attorney, we noted that you added the phrase "using the best available
technology ", he indicated that this phrase would be confining on the project's purpose and it is better suited to
address as an alternative. For example, some might consider that saltstone encapsulation or other technology
might be the best available."
The applicant has redefined the project purpose as recommended: The purpose of the proposed project
is to dispose of coal ash in a suitable manner and in an environmentally sound location. The long -term
disposal of coal ash in suitable locations will facilitate the closing of coal ash basins across North
Carolina, as required by CAMA14.
The applicant believes the information included above addresses comments 4 -8 in the email dated June 30,
2015. Responses to comments 1 -3 will be submitted in a separate email at a later date. Should you have any
questions or comments concerning this project please do not hesitate to contact me at 828 - 698 -9800.
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Thank you
Rebekah Newton
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