19970945 Ver 1_COMPLETE FILE_19920101

April 29, 1998
MEMORANDUM
TO: Mary Kiesau
?
THROUGH: John Dorne A
A
FROM: Eric FleI
SUBJECT: Holiday Inn Sunspree Resort (DENR# 910)
After reviewing the document and conferring with Joanne Steenhuis of the WIRO, the following
recommendations should be implemented for this project to reduce associated impacts from turbidity:
1) The 6000 yd3 °f fill material to be used at this site to bring the building pad and surrounding areas up to
12' msl should first be placed in a high ground area and the runoff ponded and released slowly after
the suspended sediment has settled out.
If there are any questions regarding g this matter please feel free to call me at 733-1786 or via e-mail.
Environmental Review Tracking Sheet
DWQ - Water Quality Section
Date: (n
MEM ORANDUM
TO.
O Trish MacPherson (end. sps) F
O Kathy Herring (forest/ORW/HC
O Larry Ausley (ecosystems)
O Matt Mathews (toxicology)
O Jay Sauber (intensive survey)
0
q10 _
DENR # '-A
Q I ZO--
APR 2 ftgrc/ Prg Mgmt Coordination Branch
O Ed Buchen (Archdale 9th)
wrT_ O..,Brent McDonald (Archdale 12th)
Non-Discharee Branch (Archdale 9th)
O Kim Colson (Permitting)
W tlands (WQ Lab)
John Dorney (Corps, 401)
r_J I- Bell (DOT)
Eric F1eek (dredging)
O Eric Galamb (other)
O Asheville O Mooresville O Washington
O Fayetteville O Raleigh O Wilmington
0. Winston - Salem
Plannine Branch (Archdale 6th
O Alan Clark (basinwide planning)
O Boyd DeVane (classifications & standards)
O Beth McGee (management planning)
O Steve Zoufaly (reclassifications)
O Ruth Swanek (modeling) (Archdale 9th)
Point Source Branch (Archdale 9th)
O Dave Goodrich (NPDES) O
O Bradley Bennett (Stormwater) O
O Tom Poe (Pretreatment) (Archdale 7th) O
FROM:
PROJECT:
Attached is a copy of the above document. Subject to the requirements of the North Carolina Environmental
Policy Act, you are being asked to review the document for potential significant impacts to the environment,
especially pertinent to your jurisdiction, level of expertise or permit authority. Please check the appropriate
box below and return this form to me along with your written comments, if any, by the date indicated.
RESPONSE DEADLINE: y 2 bra
F_j NO COMMENT COMMENTS ATTACHED
Name: ri C2t.
Date:
Thank you for your assistance. Suggestions for streamlining this process are greatly appreciated!
Notes:
I can be reached at:
phone: [phone], ext. 565
fax: [phone] e-mail: [e-mail]
mis:\circmemo - mac version
U&&-Martin, Regional / Program Management Coordination Branch, 12th Floor, Archdale
M-- )/..<-,.

ENVIRONMENTAL As (EA)
' APPLICATION FOR MODIFICATION OF
MAJOR CAMA PERMIT #150-97

HOLIDAY INN SCRIGHTSVILLE BEACH, N.C.
PROPOSED DREDGED FILL
?BMS Architects, PC
614 Market Street PO Box 3667
Wilmington, NC 26406
MOORE'S INLET ST.
= SITE
AR A.MAP
NOT TO SCALE
MIUNITY MAP
NOT TO SCALE
' ENVIRONMENTAL ASSESSMENT (EA)
APPLICATION FOR MODIFICATION
OF MAJOR CAMA PERMIT #150-97
(1) Existing Environment: This site is on the ocean front in the Town of
Wrightsville Beach. The site contains 4.11 acres and is relatively flat with slopes
less than one percent (I%). There is no vegetation at this time since
' construction of a new hotel is in progress.
Land Use: This site is in zoning District IV and was previously occupied by a
Holiday Inn Hotel demolished in 1997. The hotel now under construction was
' approved by a Town of Wrightsville Beach Conditional Use Permit certified
November 5, 1997 and by Major CAMA Permit #150-97 issued 12/1/97.
Soil Type: This site is composed of medium dense to dense clean sand with
some shell fragments.
Surface Water: There is no surface water on this site. The site will be graded
' to drain storm water into catch basins and routed into an infiltration pipe system.
The storm water management plan was approved July 30, 1997.
Ground Water: Ground water on this site was found to be approximately 7'
' below the surface of the ground during soil investigations done by S&ME Inc. In
April 1997. The average existing ground elevation is +9.00 MSL. The report
i noted that the ground water level will fluctuate with tidal and climatic change.
(2) Need: This application is a request for approval to obtain and use dredged fill
on the site in selected areas. The site for this project varies from elevation 8.00
' to 10.00 MSL, average at 9.00 MSL. This entire site will be filled generally to
elevation 12.00 MSL. This level of the project will be utilized for parking and a
swimming pool. The entrance to the hotel will be at level 2, elevation 22.00
MSL, accessed by vehicular ramps. This requires a substantial quantity of fill to
construct driveway ramps and contour this quadrant of the site. Stormwater is

Page 1
t

' ENVIRONMENTAL ASSESSMENT (EA)
APPLICATION FOR MODIFICATION
OF MAJOR CAMA PERMIT #150-97
controlled by retaining walls and landscaped terraces at the street frontage and
at the north and south boundaries. All Stormwater will be retained on site in
underground trenches as detailed in the Stormwater management plan
' approved 11/7/97.
' Along the ocean frontage of this site a sand dune will be constructed to top at
elevation 16.00 MSL. This sand dune construction will continue north across
the 65' public ROW by agreement with the Town of Wrightsville Beach. All of the
construction described is shown on the drawings attached to the Application for
the Major CAMA Permit issued 12/1/97.
Th
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o
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fill required to accomplish this work is estimated to be
30,000 CY. Approximately 6,000 CY of this must be placed under the building
h
w
ere compaction and timing is critical. This fill will be transported by truck from
an approved source.
The balance of this fill, approximately 24,000 CY, can be dredged
material and th
W
i
ht
ill
e
r
g
sv
e Beach renourishment project
terminates at the south boundary of this site. An extension of the
renourishment project's design profile across the 335' beach
frontage of the Holiday Inn site, and onto the site to a dike to be
constructed by the Holiday Inn contractor, will provide this quantity
of fill above the elevation 6.00 MSL transition beach fill that is to be
placed under the existing Wright3viile Beach dredged fill contract.
The COE has confirmed that the-approved borrow area In
Masonboro Inlet and Banks Channel can provide an additional
30,000 CY of material without modification of the COE project.
Please refer to the COE March 11, 1998 letter attached.

Page 2

011
' ENVIRONMENTAL ASSESSMENT (EA)
APPLICATION FOR MODIFICATION
OF MAJOR CAMA PERMIT #150-97
The landowner, PVC Inc., requests permission to negotiate with the dredging
contractor, Weeks Marine, Inc. for a quantity of dredged fill not to exceed 30,000
CY. The landowner will pay for this dredged fill and be responsible for moving
and shaping it on the project site.
The transition beach will remain as shown on the COE project design profile
and plan with the construction berm at 6.00 MSL. The storm berm at 10.50 MSL
and the dune at 13.50 MSL will be reinforced by the dune we will construct on
the ocean front portion of the hotel property and on the public right-of-way
adjacent.
(3) Alternative Analysis: The alternative to this dredged material is truck
transported fill from an approved source. This amount of fill will require
approximately 2,400 10 yard truck loads. This can be done but the time
schedule for completion of the Wrightsville Beach renourishment project
correlates very well with the Holiday Inn project schedule and the dredge pipe
' line will terminate at this location.
The utilization of this dredged material will be beneficial to the
Town of Wrightsville Beach and the state highway system by
' elimination of the need for approximately 2,400 truck loads of fill.
This quantity can be pumped by the dredge in a 24 hour period.
(4) Environmental Consequences
A. han a in land use.
? There is no change in the permitted land use.
B. We la ds. There are no wetlands on this site.
I Page 3

ENVIRONMENTAL ASSESSMENT (EA)
APPLICATION FOR MODIFICATION
OF MAJOR CAMA PERMIT #150-97
C. Prime or Unique Agricultural Lands. This is an ocean front beach site in
a fully developed island municipality with no conceivable agricultural
use.
D. Public Lands: This is a owned s'
-- privately site that adjoins a public beach
on the Atlantic Ocean and a Town of Wrightsville Beach public parking lot
on the north boundary. Both public facilities will be improved by
this project. The dune structure along the beach frontage as a part of
the Holiday Inn project will reinforce the transition beach that terminates
the COE Beach Renourishment Project now underway and will extend
across the public ROW on the north side by agreement with the town.
The owner has also agreed to construct a walk over structure to connect
the public parking lot and the public beach.
t E. Scenic or Recreational Areas. Response to 4-13 applies.
F. Areas of Archeological or Historic Value. There are no areas of
archeological or historic value on or near this site to the best of our
knowledge.
G. Air ualit : The air quality will not be affected by this project except for
temporary effect of the exhaust fumes of trucks and construction
equipment. This request for approval to utilize dredged material for much
of the fill required on this site will lessen this effect by elimination of the
need for approximately 2,400 truck loads of fill.
' H. Ground Water Quality: We do not believe there will be any impact on the
ground water quality due to this construction or the proposal to utilize
some dredged fill.
Page 4

ENVIRONMENTAL ASSESSMENT (EA)
APPLICATION FOR MODIFICATION
OF MAJOR CAMA PERMIT #150-97
I
'. I. Noise Level: The noise level on this site will be affected by construction
activity temporarily but the proposed use of dredged fill material will
reduce this effect. The dredge can pump the material quantity proposed
in 24 hours and the only noise in this area will be from bulldozers
controlling the fill placement.
' Transport of 24,000 CY of fill by truck would take place over a
period of many weeks of daily hauling.
J. Water Supply: The project will be connected to the Town of Wrightsville

t Beach water system. The water main size at the site is adequate and the
i
ti
i
ex
s
ng serv
ces that served the hotel now demolished is adequate to
supply the new hotel. The Town has assured us that the existing system
has ad
t
l
equa
e supp
y and pressure to serve this project. Therefore, we
do not believe that project presents any environmental consequence and
this proposed modification to permit the use of some dredged material for
. fill would certainly have no effect on the town's ground water supply
source.
t K. Shellfish or fish and their Habitats: The environmental effect of the
hydraulic dredging underway in Masonboro Inlet on marine and

estuarine resources have been studied and discussed in much detail in
the COE Environmental Assessment for the current project dated October
'95 (copy of pages 13 and 14 attached as Exhibit A). The conclusions, in
general, state that the Masonboro Inlet navigation dredging and the
beach renourishment associated, which has occurred many times since
1959 at approximately four year intervals, has had a minor and short term
effect.
Page 5

1
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ENVIRONMENTAL ASSESSMENT (EA)
APPLICATION FOR MODIFICATION
OF MAJOR CAMA PERMIT #150-97

The amount of material proposed by this application is less than .03% of
that to be placed on Wrightsville Beach and any impact on shellfish or
fish and their habitat will be insignificant.
I_. Wildlife and Their Habitat: The COE Environmental Assessment for the
current Masonboro Inlet project contains a list of species that could be in
the project area that are federally listed as endangered or threatened. A
biological assessment by the COE coordinated with USFWS and NHFS
determined that the COE project underway "may affect the loggerhead
sea turtle, green sea turtle, and sea beach armarauth. Other federally
listed endangered or threatened species would not be affected
On page 15 of the COE Environmental Assessment they address this
effect and mitigation measures proposed (copy attached as Exhibit B).
M. Introduction of Toxic Substance: There are no toxic substances involved
in this hydraulic dredging and sand transfer process to be best of our
knowledge.
N. Eutrophication of Receiving Water: The receiving water is the Atlantic
Ocean, a very active body of salt water. The question of Eutrophication is
not applicable. I.
5. Mitigative Measures: Our findings regarding the proposed use of sand
dredged fill material at the Holiday Inn project site and those of the COE,
regarding the Masonboro Island project underway at this time indicate that there
will be no significant impact on the environment as a result of this hydraulic
dredging and beach renourishment operation. The work is scheduled for
I
Page 6

ENVIRONMENTAL ASSESSMENT (EA)
APPLICATION FOR MODIFICATION
OF MAJOR CAMA PERMIT #150-97
completion by April 30 but if it extends beyond that date, standard beach
monitoring procedures for sea turtles will be implemented as discussed in the
COE Environmental Assessment Section 5.07, page 15 (copy attached as
Exhibit B). No other mitigation measures should be required.
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SCALE IN FEET
PROPOSED CHANNEL REALIGNMENT
UA4nunnnn. N r_

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EXHIBIT "A" PAGES 13 AND 14
expected in this portion of the inlet. Since dredging will change the size of only a small portion of
the inlet and will not alter overall tidal exchange, any associated impact should be minor. Marine
' waters of the project area display daily variation in current and salinity conditions due to natural
forces such as freshwater inflow, tides, and wind. Any project-induced changes would be very small
in comparison and are, therefore, considered to be insignificant.
' 5.03 Alr ua fi . The proposed work is not expected to create significant
adverse effects on air
quality of the New Hanover County attainment area. Air quality impacts from the operation of
' dredging equipment should be short-term and minor, and should not significantly elevate the level of
airborne pollutants. These effects will be similar to those which have been occurring periodically
during routine maintenance dredging.
5.04
Marine and Estuarine Resources.
t Nekton. Most free-swimming animals are not expected to experience any significant effects from the
dredging or disposal operations. Most will be able to avoid or escape contact with the dredge
cutterhead and the dredged material placement. However, the larvae and early juvenile stages of
estuarine-dependent species pose a particular concern because their powers of mobility are either
absent or poorly developed, leaving them subject to the effects of tides and currents. This physical
' limitation makes them potentially more susceptible to entrainment by an operating dredge. Organlstns
close to the dredge cutterhead may be captured by the effects of its suction and may be entrained in
the flow of dredged sediment and water. As a worst-case, it is assumed that entrained animals
experience 100 percent mortality, although some small number may survive. Susceptibility to this
effect depends upon avoidance reactions of the organism, the efficiency of its swimming ability, Its
proximity to the cutterhead, the pumping rate of the dredge, and possibly other factors. Behavioral .
t cteristics of different species in response to factors such as salinity, current, and diurnal phase
(daylight versus darkness) are also believed to affect their concentrations in particular locations or
strata of the water column. Any organisms present in high density near the channel bottom would
' be closer to the dredge cutterhead and, therefore, subject to higher risk of entrainment, Seasonal
timing of dredging may also be a factor in the overall risk to larval forms since the peak migration
through North Carolina inlets for the most'common estuarine-dependant species occurs in winter.
The biological effect of hydraulic entrainment has been a subject of concern for more than a decade,
and a number of studies have been conducted n4ionwide to assess its impact on early life stages of
marine resources, including larval oysters (Carriker et al., 1986), post-larval brown shrimp (Van
Dolah et al., 1994), striped bass eggs and larvae (Burton et al., 1992), juvenile salmonid fishes (Buell, .
• 1992), and Dungeness crabs (Armstrong et:_ al., 1982). These studies indicate that the primary
organisms subject to entrainment by hydraulic dredges are bottom-oriented fishes and shellfishes. The
significance, of entrainment's impact depends upon the species present; the number of organisms
entrained; the relationship of the number entrained to local, regional, and total population numbers;
and the natural mortality rate for the various life stages of a species. Assessment of the significance
of entrainment is difficult, but most studies indicate that the significance of impact is low. Reasons
for the low levels of impact include: (1) the very small volumes of water pumped by dredges relative
to the total amount of water in the vicinity, thereby impacting only a small proportion of organisms,
13
' (2) the extremely large numbers of larvae produced by most estuarine-dependent species,
and (3) the
extremely high natural mortality rate for early life stages of many fish species. Since natural larval
mortalities may approach 99 percent (Dew and Hecht, 1994; Cushing, 1988), entrainment by a
hydraulic dredge should not pose a significant additional risk in most circumstances. Neither direct
quantification studies not modeling efforts have demonstrated population level impacts due to larval
entrainment by hydraulic dredges.
The proposed work at Masonboro Inlet is expected to utilize a hydraulic dredge with a discharge pipe
' no larger than 30 inches in diameter. Such a dredge would be capable of transporting about 40,000
cubic yards of sand per day, which would be pumped as a slurry containing about 15 percent sand
'by volume. The volume of water discharged would, thus, be about 226,700 cubic yards pet day, or
about 70 cubic feet per second (cfs). In contrast, the average instantaneous water discharge passing
through Masonboro Inlet is computed to be 38,500 cfs. Therefore, the amount of water intercepted
' by the operating dredge is estimated to be less than two-tenths of 1 percent of the instantaneous inlet
discharge and should be of no consequence to organisms drifting by if they are randomly distributed.
Organisms concentrated along the bottom could be affected in higher numbers. However, with such
a small percentage of larvae subject to entrainment and a dredging period estimated at less than one
month, it is unlikely that impacts on larvae would be significant at the regional or overall population

Benthos. The bottom sediments of the inlet are now subject to periodic maintenance dredging which
results in total loss of all sedentary or slow-moving benthic organisms at each dredging cycle. The
benthic community of the inlet likely experiences substantial recovery between dredging events, but
due to the cyclic disturbance probably does not fully recovery in species diversity and possibly other
population parameters. The proposed work will result in yet another disturbance of the benthic
community structure and will be followed by partial recovery until the next maintenance dredging
event. Ecological significance of these losses is not well-understood but should be minor considering
the low habitat value of the unstable bottom sediments. Also, the area affected is small in relation to
the amount of subtidal bottom habitat available in the vicinity.
Intertidal Macrofauna. Beach disposal of dredged material may have negative impacts on intertidal
macrofauna through direct burial, increased turbidity in the surf zone, or changes in the sand grain
size or beach profile. Some disposal operations have resulted in nearly complete mortality of
intertidal macrofauna (Reilly and Dellis, 1978) while otlhrs involving disposal of coarse sand have
caused temporary shifts in population distribution believed to represent only minor impacts (Hayden
and Dolan, 1974). Any reduction in numbers and/or biomass of intertidal macrofauna present
immediately after beach disposal may have a localized limiting effect on surf-feeding fishes and
shorebirds due to a reduced food supply. However, in most cases, the affected beach should recover
within one or two years following the disposal event. The proposed disposal of dredged material on
Masonboro Island will be confined to a strip of beach no longer than about 4,000 feet, or less than
10 percent of the island's ocean shoreline. Overall, these effects are considered minor and short-term.
5.05 Terrestrial o urges. Resting and foraging habitat for shorebirds will be reduced by the
partial removal of the sand spit at Wrightsville Beach and will be temporarily disrupted during sand
14

EXHIBIT "B" PAGE 15 ONLY
disposal on the beach of Masonboro Island. These effects are minor relative to the amount of such
habitat available and temporary in that the sand spit is expected to reform during the ensuing
multi- year interval between dredging operations. In addition, the beach of Masonboro Island will benefit
¦ from deposition of sand which will partially replace previous erosional losses that have reduced the
beach to a narrow strip.
Disposal of sand on Masonboro Island will be
conducted between November 30 and April 30 to the
degree practicable, in order to minimize potential impacts on nesting sea turtles. If disposal trust
' occur during May through November, impacts will be reduced through . the implementation of a
standard beach monitoring and turtle nest relocation program. Also, after placement of dredged
material, any affected beach will be monitored for hardness and any areas exceeding 500 CPUs will
be tilled in order to make them more suitable for sea turtle nesting. Thus, any adverse impacts on sea
turtles should be minor. In addition, the portion of Masonboro Island which receives sand should
provide increased nesting habitat for sea turtles.
5.06 etlands. Wetlands will not be affected by the proposed action since there are no wetlands
in the immediate inlet complex, on the Wrightsville Beach sand spit, or on the beach of Masonboro
Island.
' 5.07 End- ?a?d and Threatened Sp cies. A biological assessment has been prepared and is
being coordinated with the USFWS and NMFS, pursuant to Section 7 of the Endangered Species Act
of 1973, as amended. This assessment determined that the proposed action may affect the loggerhead
`. sea turtle, green sea turtle, and seabeach amaranth. Other Federally listed endangered or threatened
species would not be affected. Section 7 coordination will be completed prior to the initiation of the
proposed work.
In order to minimize potential impacts to nesting sea turtles and vegetative-stage seabeach amaranth,
work will be timed to occur during the winter months to the maximum extent practicable. Further,
sand will be placed in areas suffering from erosion, minimizing impacts to suitable sea turtle habitat, and upgrading potential habitat for seabeach amaranth. All material will be monitored to
' determine beach hardness and areas where the post-disposal beach is harder than 500 CPUs will be
tilled to improve the suitability of the beach for sea turtle nesting.
' If any work on the. project occurs between May 1 Ind November 30 of any year, a beach monitoring
and nest relocation program for sea turtles will be implemented. This program will include daily
patrols of disposal areas at sunrise, relocation of any nests laid in areas to be impacted by fill
' • placement, and monitoring of hatching succeis of the relocated nests. Sea turtle nests will be
relocated to an area suitable to both the USFWS and the North Carolina Wildlife Resources
Commission's (NCWRC) Sea Turtle Coordinator.
5.09 Cultural Resources. The proposed work involves dredging only to the authorized project
' depth of 14 feet below mlw, plus two feet of allowable overdepth for dredging inconsistencies. Since
1959 dredging to a depth of at least 20 feet below mlw has occurred in all areas proposed for
dredging, and it is concluded that these areas do not contain any historic resources. In addition, no
is