20080868 Ver 2_Emails_20080808

PCS Phosphate Alt. L minimization
Subject: PCS Phosphate Alt. L minimization
From: "Walker, William T SAW" <[e-mail]>
Date: Fri, 8 Aug 2008 11:01:48 -0400
To: "Becky Fox" <[e-mail]>, <[e-mail]>, "smtp-Sechler, Ron"
<[e-mail]>, <Welborn. [e-mail]. gov>, "Pace.Wilber"
<Pace. [e-mail]>
CC: "Jolly, Samuel K SAW" <[e-mail]>, "Lamson, Brooke SAW"
<Brooke. [e-mail]. army.mil>, "Lekson, David M SAW"
<David. M. Lekson@usace. army. mil>, "Jones, Scott SAW" <Scott. [e-mail]. army. mil>,
"John Dorney" <[e-mail]>
All,
I have been trying to identify further reasonable minimization possibilities for the L boundary
based on your comment letters and our July 23 discussion. Attached are three maps with some ideas.
I believe these could be logistically practicable but per EPA's request, I have not talked with the
applicant about them so am not sure. The proposed new edge of operations lines are in Red. The
original lines are mostly visible but I tried to outline them in Blue where they became hard to
distinguish. If you recall, the maps in the FEIS indicated both the disturbance limits (visible here as
grey) and the excavation limits (visible here as black). The proposed red lines are meant to be
disturbance limits. I had CZR do some planimeter work to calculate approximate acreages. All
acreages given are additional avoidance over that of the current Alternative L. My graphics
capabilities are somewhat limited so the map and lines may not match up unless you view in
"Print Layout" in MSword.
NCPC - Further minimization on this tract was complicated due to all the tight corners and narrow
openings that already exist. The revised lines would result in further avoidance of about 23 ac. (18 ac
wetlands) as follows:
Bottomland Hardwood Wetland = 3 ac.
Wet Pine Plantation = 13 ac
Wet mix pine hardwoods = lac
Wet Herbaceous Assemblage = 1 ac
Upland communities = 5 ac
Bonnerton - Again, logistically practicable mining area becomes a factor. EPA has suggested that
avoidance be concentrated on the Nonriverine Wet Hardwood Forest and associated communities that
have been determined by NC Natural Heritage Program to be nationally Significant Natural Heritage
Area (SNHA). The L boundary currently avoids some of this area and also other wetland and upland
areas riparian to Porter Creek. It is the opinion of the Corps that the areas bordering Porter Creek
should remain outside the impact footprint. Based on comments from July 23, I believe we would all
agree that any further avoidance of the SNHA should not be at the expense of areas currently avoided.
The arrangement of the SNHA within the tract makes avoidance problematic in that other areas around
the SNHA are potentially rendered logistically un-mineable. As we have all learned through this
process, there are operational constraints based on mining technology and methodology that cannot be
safely overcome. Therefore, total avoidance of this area would likely reduce available mining on
Bonnerton by more than 1 year as EPA has suggested.
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PCS Phosphate Alt. L minimization
Taking into consideration all agency comments, logistics, and the recent information on the human
manipulation that has potentially contributed to the development of this SNHA, the Corps suggests the
attached revised boundary. This revised boundary would result in further avoidance of about 90 acres
(83 ac. wetlands) as follows:
Wet Herbaceous Assemblage = 13 ac
Wet Shrub - scrub = 7 ac
Hardwood Wetland = 6 ac
Wet mix pine hardwoods = 40 ac
Wet Pine Forest = 17 ac
Soil type and landscape position of these additional avoidance areas are very similar or identical to that
of the existing Hardwood wetland SNHA. There is evidence that much of the existing Nonriverine
Wet Hardwood Forest areas on this site developed over the last few decades from areas similar to
these additional avoidance areas. Therefore, there is good reason to believe that these areas, with little
management, could be developed into Nonriverine Wet Hardwood Forest meeting the Schafale and
Weakley description. Preservation of this area coupled with the SNHA and other wetlands already
avoided would likely, over a short time, result in a 150 + acre contiguous Nonriverine Wet Hardwood
Forest at the top of Porter Creek headwaters.
S33 - The Corps suggests expanding the buffers on Broomfield Swamp and Cypress Run to further
minimize impacts in the S33 tract. It is important to note that both of these systems, within the project
area, are channelized and regularly maintained drainages predominately through agricultural land.
Few wetlands exist within their riparian corridors. The proposed Broomfield Swamp revision follows
basically the SCR line for that area. The proposed Cypress Run revision expands the buffer around
Cypress Run proper and avoids more of the Hardwood Wetland located to the south of the run. This
revised boundary would result in further avoidance of about 300 acres (19 ac. wetlands) as follows:
Bottomland Hardwood Wetlands = 2 ac
Hardwood Wetlands = 15 ac
Wet mix pine hardwoods = 2 ac
I would like to discuss these revisons with the applicant very soon. Please provide any comment you
may have on these proposed lines to me by next Wednesday (8/13/08). Should you have any
questions, you can reach me @ 828-271-7980 ext. 222 today (8/8/08) and Wednesday (8/13/08) and @
828-696-6609 Monday and Tuesday.
Thanks
Tom
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LEGEND
BONNERTON BASE PROJI
BONNERTON L ALTERNAT
BONNERTON L ALTERNAT
RECOVERABLE CONCENTF
1 CREEKS/OPEN WATER
i-"- 1 A DI IRI IP TRI MT API
51 a
0 M 5
NC 306
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LEGENp ACRES
NCPC BASE PROJECT AREA 3,608,
NCPC Extension-ALT L 2,185
NCPC Extension-Excavation Limits 1,3641
15 a Recovered Concentrate = 37,697,000 Tons*
CREEKS/OPEN WATER
1A PUBLIC TRUST AREAS 0 LF 0
5 19 PERENNIAL STREAM 0 LF 0,
1C INTERMITTENT STREAM 6,427 LF <1,
PA 2 WETLAND BRACKISH MARSH^COMPLE)( ^^rT • O