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HomeMy WebLinkAbout20110905 Ver 1_Other Agency Comments_20111222US Department oic Homeland Securit United States Coast Guard Ms Christy Wicker U S Army Corps of Engineers Regulatory Division 69 Darlington Avenue Wilmington NC 28403 Dear Ms Wicker I\- bc� 05 Voi�-f Commanding Officer 1240 East Ninth Street United States Coast Guard Room 2179 Civil Engineering Unit Cleveland Cleveland Ohio 44199 2060 Staff Symbol ER ce Phone (216) 902 -6304 Fax (216) 902 6277 Email mark a lamb@uscg mil t t � � 11000 DEC 16 2011 The U S Coast Guard (USCG) has received your letter dated 18 November 2011 regarding our proposed project to conduct maintenance dredging of the small boat mooring basm on an as needed basis at USCG Sector North Carolina facility located at 2301 East Fort Macon Road Atlantic Beach Carteret County North Carolina In addition the USCG received conditions from the North Carolina Department of Environment and Natural Resources (NC DENR) Division of Coastal Management (DCM) and the NCDENR Division of Water Quality (DWQ) This correspondence provides your office with a USCG Response to Comments from Regulatory Agencies in Enclosure (1) The USCG is responding to the following 1) comments from the U S Army Corps of Engineers (USACE) letter to the USCG dated 18 November 2011 2) consistency conditions from the NC DENR DCM letter to the USCG dated 31 October 2011 regarding Federal Consistency determination C11 062 and 3) certification conditions from the NCDENR DWQ in their letter to the USCG dated 14 November 2011 regarding 401 Water Quality Certification Approval (Certificate #3872) Project # 2011 0905 As shown in Enclosure (2) the USCG has modified Construction Drawing C 05 to change the physical location of the discharge pipe to assure compliance with this condition Thank you for your attention to this matter If you have any questions please contact Mr Mark Lamb of my staff at (216) 902 6304 Sincerely 14 ._ ----_ S PLACZ P E Technical Director, Civil Engineering Unit By direction of the Commanding Officer Enclosure (1) USCG Response to Comments from Regulatory Agencies (2) Modified Construction Drawing Copy Stephen Rynas NCDENR DCM Coleen Sullins NCDENR DWQ D DEC 2 s 2011 DENR WATER OUALITy WETLANDSAND STORMWATER BRANCH ENCLOSURE (1) USCG RESPONSE TO COMMENTS FROM REGULATORY AGENCIES Enclosure (1) 25 NTU) shall not be exceeded for the dewater system s accumulated water that will be discharged back to Bogue Sound Background USCG Sector North Carolina is located dust west of Fort Macon in Carteret County North Carolina USCG Sector North Carolina has many missions including the safeguarding of navigational interests (governmental commercial, and private), protecting North Carolina s coastline from pollution and marine accidents and enforcement of Federal Laws and responsibilities under the Homeland Security Act Maintenance dredging has been conducted in the basin in several times in the past Existing Conditions Since the previous dredge protect the basin area has locations that have filled into 5 to 10 MLW This is impinging on the ability to utilize the basin for the functions of the unit The material to be dredged is expected to be a mixture of fine sand and silty sediment materials Alternatives Analysis Feasible alternatives to the proposed project are discussed below The No Action Alternative Not dredging the small boat basin at USCG Sector North Carolina would result in continued filling of the project area When the area has filled too much the USCG would be unable to execute its mission from the Sector North Carolina Dredging Given the need to maintain efficient operation of the Sector North Carolina s small boat basin the only feasible alternative is dredging There are several methods of dredging available for accomplishing the work These methods are contract hydraulic pipeline dredge mechanical (clamshell dragline etc ) dredge, side cast dredge and special purpose (hopper) dredge The result of dredging would be the removal of sediments lying above the 12 feet MLW plus 1 foot allowable overdepth Impacts of the different dredging alternatives would essentially be the same regardless of the method utilized Given the relatively small quantity of material to be dredged (8 800 cy) the use of governmental and/or private dredging operations in the area would be important to reduce and/or avoid the expense of contract/commercial dredge plant mobilization and demobilization The USCG will contract out the dredging to a commercial entity should the governmental dredge not be available in a timely manner Disposal of the dredged material would be dependent upon the method of dredging used and the grain size of the material to be dredged Different disposal options are discussed below Disposal Option 1 — Brandt Island (USACE Disposal Island) 3 Enclosure (1) NCDWQ classifies waters within the Morehead City Channel as SA and HQW None of the project areas (dredging or disposal sites), are located in Outstanding Resource Waters (ORW) as defined by NCDWQ The NC Division of Marine Fisheries does not classify the project areas (dredging and disposal sites) as a Primary Nursery Area (PNA) in accordance with (15A NCAC 07H 0208(a)(4)) It is unlikely that any submerged aquatic vegetation (SAV) is present within the area to be dredged since the area is routinely navigated and historically dredged The area experiences tidal and current action in addition to sand movement There are no shellfish beds located in the project area (15A NCAC 07H 0208(a)(2) The project site is not designated as a Natural and Cultural Resources Area (15A NCAC 07h 0501) Since the project area has been dredged before this project is not likely to impact any natural or cultural resources Each dredge event will be conditioned to ensure that care is taken during all aspects of the work Any cultural resources encountered will be protected and coordination with the USACE and the NC Department of Cultural Resources Underwater Archaeology Unit will occur USACE Comment 2 It is necessary for you to have taken all appropriate and practicable steps to minimize wetland losses Please indicate all that you have done especially regarding development and modification of plans and proposed construction techniques to minimize adverse impacts USCG Response 2 There are no wetlands within the limits of the proposed project action area, therefore there will not be any wetland losses USACE Comment 3 The MOA requires that appropriate and practicable mitigation will be required for all unavoidable adverse impacts remaining after all appropriate and practicable minimization has been employed Please indicate your plan to mitigate for the projected unavoidable loss of waters or wetlands or provide information as to the absence of any such appropriate and practicable measures USCG Response 3 The USCG will implement the following environmental mitigations to minimize adverse impacts to waters Based on the project location type of work temporary nature of the work, and short term duration of the project any environmental impacts are expected to be minimized The USCG will not conduct in -water work from February 1 through July 31 This moratorium incorporates all moratoriums on construction activities established by the commenting state and Federal regulatory agencies to minimize biological and environmental impacts 0 Enclosure (1) Condition 7 The effluent water from the dredge spoil will not be released into open shellfish waters without notification to Shellfish Sanitation and DWQ As shown in Enclosure (2) the USCG has modified Construction Drawing C 05 to change the physical location of the discharge pipe to assure compliance with this condition Condition 8 The USCG will not conduct in -water work from February 1 through July 31 so that all moratoriums on construction activities established by the NC Wildlife Resources Commission (WRC) US Fish and Wildlife Service (USFWS) NC Division of Marine Fisheries (DMF) 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