20200689 Ver 1_More Info Received_20200710

Strickland, Bev
From: Angela Allen <[e-mail]>
Sent: Friday, July 10, 2020 4:53 PM
To: Homewood, Sue
Cc: Jake McLean; Jonathan Hartsell; Andy Hill; Erin McCombs; Leslie, Andrea J;
Fuemmeler, Amanda J CIV (US
Subject: RE: [External] Ward Mill Dam PCN Comments
Follow Up Flag: Follow up
Flag Status: Flagged
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Sue,
Please see responses below to your questions provided to Jake McLean in e-mail communication on July 2, 2020
regarding the Ward Mill Dam removal project.
1. On Page 17 of the report, Section 2.3.1, you mention that if the turbidity is too high then the rate of dam
removal may be slowed. How and where are you proposing to measure turbidity and determine if its "too
high"?
Turbidity monitoring and evaluation was discussed with DEQ on 7/9/20. Based on discussions, the report has
been revised to clarify the intent to visually monitor turbidity and always assess what options may exist to
minimize turbidity. The goal is to minimize turbidity and to minimize the duration of turbidity and instream
activities. If an event occurs where turbidity is called into question, every effort will be made to discuss this with
the project manager at that time to slow turbidity and to determine if short term measures may be taken. It is
understood that in many cases, particularly during certain phases of demolition, no viable option may exist to
reduce turbidity apart from stopping work. It is also understood that the two state goals may be in conflict and
that typically work will not be stopped or slowed if little or no benefit is derived, or if it is only derived at the
expense of extending the duration of the impact (duration of construction). Work will occur during daylight
hours and turbidity is anticipated to diminish significantly or cease altogether during non -working hours.
2. The Division feels it will be essential to make all efforts to remove as much rebar as possible from any material
reused within the river or on the banks. We may include a permit condition requiring documentation (photos,
removal amounts, or something like that) that this is done.
Efforts will be made to remove rebar from dam material. Rebar removal was discussed with DEQ on
7/9/20. Based on discussions, photograph documentation as well as narrative documentation is proposed to
describe and document rebar removal activities. Additionally, the site will be reviewed as part of a final walk
through and where rebar is visible and can feasibly be removed or altered for safety and aesthetics this will be
done.
3. The adaptive management plan indicates that a final report with future monitoring and management activities
will be developed. Can you provide some assurance that one or more of the project partners will be clearly
responsible for any actions the regulatory agencies may deem necessary to ensure long term stability or water
quality protection during this timeframe.

The adaptive management plan will cover a period of approximately 2 years from the completion of Phase 2 site
work (from fall of 2021 to the end of 2022). During this period, the project management team will be the
primary point of contact responsible for receiving, responding and acting on regulatory agency input. The
project management team will engage Wildlands as they deem necessary to assist with evaluation and response
to any stability or water quality issues. Wildlands' scope includes project site visits through the end of
2021. The goal of the Project Management Team is to retain contingency funding beyond the Phase 2 site work
and planting such that repairs or replanting could be conducted as deemed necessary by the Designer or
Regulatory Staff. The budget available for project incidental costs is intended to cover: (1) materials, (2)
incidental costs such as hauling not covered by USFWS ART, (3) planting, (4) invasive species management, and
(5) repairs and adaptive management. All phases of the project will be managed with the intent to reserve 20%
of the project budget for repairs and adaptive management. The funding available for repairs and adaptive
management will be contingent upon the level of intervention required during Phase 2 in order to apply site
stabilization and bioengineering measures.
4. 1 didn't see this included in the monitoring discussions, but will there be any plan for monitoring/inspection in
the live stakes and replacements if there's survival problems/concerns?
Livestakes and other plantings will be monitored for mortality. It is typical for livestake success rates to be in the
50-75% range. If rates of livestaking do not exceed 50%, or even if they do but it is felt that supplemental
livestaking would benefit long-term stability, livestakes will be supplemented during the subsequent dormant
season, and potentially augmented with herbaceous plugs for signs of early mortality. Livestake mortality will
be checked in May 2021 to determine the preliminary survival rates, and further evaluated in the fall of 2021 to
determine the percentage mortality and prescribe supplemental planting as necessary. Livestakes are typically
planted at a density that allows for normal levels of mortality.
5. Is Appendix B, the ASU scope of the study available? It was not included with the application.
Appendix B was provided via email on 7/6/20.
6. Is there any discussion about contingencies if there are restrictions placed on travel for USFWS team between
Phase 1 and Phase 2 due to uncertainty of the pandemic?
This possibility was discussed with DEQ on 7/9/20. The USFWS believes that they would typically be able to
receive special permission to mobilize in order to address severe water quality issues or safety issues
(emergency repair). For the concern of this scenario delaying Phase 2 beyond the end of 2020, the PMT would
review potential delays with regulatory staff. If no significant concerns are present, Phase 2 would simply be
delayed until such time that USFWS could resume with planned activities. If concerns were present, the PMT
would review options with regulatory staff — the PMT has an incidental cost budget that is to be allocated to (1)
materials, (2) incidental costs such as hauling not covered by USFWS ART, (3) planting, (4) invasive species
management, and (5) repairs and adaptive management. The PMT could reallocate funding intended for Phase
2 site work and planting, as well as items 4 & 5 to emergency repair work in order to hire a local contractor that
could stabilize the site.
Thank you,
Angela
Angela Allen, PE I Water Resources Engineer
0:919.851.9986 x106 M: 703-655-6110
Wildlands Engineering, Inc. [wild landseng.coml

312 West Millbrook Road, Suite 225
Raleigh, NC 27609