20080833 Ver 1_More Info Received_20080623

Re: Fletcher-Meritor Site Comments
01-005
Subject: Re: Fletcher-Meritor Site Comments
From: Salam Murtada <[e-mail]>
Date: Mon, 23 Jun 2008 16:13:38 -0400
To: Eric Kulz <eric. kulz@ncmail. net>
CC: "Deborah A. Daniel" <[e-mail]>
Eric,
I attached HDR's responses to your comments. Also included are USACE's responses in
the same letter for your review as well. Please let me know if you need additional
information or have further questions. Thanks!
Salam
Eric Kulz wrote:
Salam;
Please see attached.
Feel free to contact Tammy or me if you have any questions.
Please note that I will be out Monday and tuesday next week.
Eric
Salam Murtada, PE, CFM
Design and Construction Unit
Ecosystem Enhancement Program
Work Phone: [phone]
Fax: [phone]
404-401 Comment Response Memo 6-23-08.pdf
1 of 1 6/26/2008 12:29 PM
TO: Salam Murtada, PE, CFM - EEP Review Coordinator
FROM: John Jamison, Environmental Scientist
CC: Debbie Daniel - EEP Project Manager
DATE: June 23, 2008
SUBJECT: Responses to 404/401 Comments dated June 13, 2008
lul
MEMORANDUM
Raleigh, North Carolina
Project: Fletcher-Meritor Stream & Wetland Restoration
County: Henderson County, NC
DWQ Project ID: 08-0833
DWO
"The project proposes riparian zone planting at a density of 436 stems per acre, to achieve a
mature survivability of 320 trees per acre. However, in Section 8.0, no success criteria for
vegetation is presented. Current guidance for both stream and wetland mitigation list success
criteria for stream riparian zone and wetland vegetation as 320 stems per acre in year three, with
a final target density of 260 stems per acre in year 5. Please verify that this is the criteria to be
employed for this project."
RESPONSE: The intention of the vegetation planting density is to meet or exceed the
USACEIDff"Q regulatory criteria. Therefore, we will amend the year five target to 2610 stems
per acre and add 320 stems per acre as the year three interim target.
2. "The project states that wetland hydrology will be monitored using three automated wells and
three manual wells. However, the report does not present success criteria for hydrology. Please
provide the proposed hydrologic success criteria for this project."
RESPONSE: The hydrologic success criteria for the wetland component of the project will be
consecutive davs totaling more than 5% of'the growing season. With the growing season
approximated tit 192 days. for Ienderson County, 5% of the growing season is 10 days and
12.5% is 24 days. Gf'e anticipate the wetland areas will not be inundated for long periods, but
that soils will be saturated in the upper 12 inches throughout the winter months and into the
spring growing season durhng a Year of normal rainfall.
"In addition, the report does not describe monitoring hydrology in the reference wetland. Very
often, monitoring of the reference wetland can provide valuable data during unusual periods (e.g.
drought or very wet periods). Comparison of the mitigation site data to the reference can often
be used in conjunction with the success criteria to evaluate whether a wetland mitigation site is
developing into the desired wetland type. Please provide the rationale for not monitoring the
reference wetland."
RESPONSE: We will work with EEP and the landowner to attempt to equip one o f the nearby
reference wetland sites with an automated well and access during monitoring events.
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3. "The project proposes planting of red maple and sweetgum in the riparian zone. DWQ agrees
that these species are a normal component of riparian zones throughout North Carolina.
However, both trees tend to be rapid colonizers and volunteers almost always appear on
restoration sites during the five-year monitoring period. These species should be counted during
monitoring of the vegetation. However, DWQ does to not recommend planting of these species,
as planted stock and volunteers can cause the total numbers of these species to exceed 20% of
the riparian zone vegetation."
RESPONSE: We will remove red maple and sweetgum from the planting palette for the project.
We agree that typically these tivo species readily colonize most restoration sites. I , lowever, this
project site has been under cultivation,for the better part of 100 yearn, and no significant
nttrnbers ol red rrrcxl)le or sweetgum are present in the lirrrited existing vegetation on-Site. We
were proposing to use these two to augment the early-successional vegetation palette. We will
use sugarberry (Celtis laevigata) to replace red maple in zones 2 and 3, and will add sycamore
(Platanus occidentalis) to the Zone 3 list for planting in the botiomland hardwood area.
USACE
4. "There is insufficient documentation in the plan to support restoration of wetlands at this site.
There is no site specific information to indicate that the "restoration" areas ever had hydric soils
or wetland hydrology. The plan lacks any site specific soil profile descriptions. The Restoration
Plan in Section 7 seems to indicate that grading and removal of topsoil will be accomplished to
achieve wetland restoration yet there is no indication that the areas were ever filled only farmed.
The wetland work appears to be wetland creation rather than restoration. Base on available
information, we cannot approve the entire plan and it should be clear that NCEEP would be
undertaking the proposed "wetland restoration" at their own risk. We would not support adding
the proposed 6.34 acres of wetland to your asset list without monitoring data to demonstrate
success."
RESPONSE.,: Soil profiles from the well installation and additional miscellaneous borings are
provided as an attachment to this mento. Due to the ongoing drought, our on-site groundwater
data collection efwl does not provide enough evidence to cleorly exhibit the necessary
hydrology. However, based on surficial well data from other permanent monitoring sites in the
area, as well as discussions with NR( S staff irr Henderson County, it appears that surficial
groundwater has been lowered by 1.5 to 3 feet since Summer 2007 and the beginning ofthe
drought (see attached). The referenced Pisgah Forest USGS well is -15 miles southwest of this
site and showed a -2 foot drop in groundwater elevation during the height of the drought
(September thru December 2007), as compared to the 23-year monthly mean. Therefore, we
have provided a chart showing the likely c ffect on groundwater at the site due to the ongoing
drought, and conservatively estimated it at a --1 foot drop in grouncm,ater elevations on-site.
Additionall7,, the soil units mapped by the NRC'S Soil Survey for Henderson C"ounty within the
restoration area are predominately Kinkora loam, a hydric soil, with some Codorus loam, a soil
with hydric. inclusions of T?qxawav silt loam and Hatboro loam. Limited amounts ofgrading will
be performed in order to eliminate anY spoil piles frcrnr the historic ditching and to create limited
2 ?- «?Eagl??r?s? { R'.?trirsilaC?(1
2008
amounts of microtopoggraph)?. General grading activities for the ii,etlancls will not exceed 6
inches of excavation.
5. "Regarding the proposed channel design, we note that the sloping (8:1) floodplain bench will
reduce flood duration (as opposed to a flat bench) and will probably short circuit some of the
flood storage and attenuation functions that you are trying to achieve at the site."
RESPONSE: The primary goal is to provide adequate floodprone area, as this stream is likely to
be in backwater conditions from Cane Creek during most flooding events. In addition, the 8:1
bench helps to alleviate the amount of excavation required, and avoids the need, for an
unnaturall), steep slope in order to tie the neiv_floodplain to existing ground elevations.
Soil Profile Description * - highlighted borings are within wetland restoration area
Boring #1
Depth Ranee (in.l Color Mottles Texture
02 1 OYR 3/2 Silt Loam
4-12 10YR 2/1 7.5YR 4/4 Cla Loam
13-36+ IOYR 2/1 Sand Cla
Boring #2
Denth Rnnoe (in 1 Cnlnr Mnttlea TPVtnre

0-3 IOYR 2/1 Silt Loam
4-12 10YR 2/1 Silt Loam
13-14 2.5Y 5/1 2.5Y 5/4 Sandy Clay
15-28 2.5Y 5/1 Sandy Clay
29-33+ 25Y 511 Clayey Sand
Boring #3
Denth Ran- (in 1 Cnlnr Mnttlec TPVh?rn
0-12 1 OYR 2/1 Silty Clay
13-18 10YR 2/1 2.5Y 5/4 Silty Clay Loam
19-34 1 OYR 4/2 Clay Sandy Loam
34+ Gley 1 6/10Y Sandy Loam
Boring #4
Denth Ranee (in l Cnlnr Mottles T-fi-
0-10 IOYR 3/2 Silt Loam
11-20 10YR 3/1 7.5YR 4/4 Silty Clay
21-22 IOYR 3/1 7.5YR 4/4 Clay Loam
23-33 7.5YR 2.5/1 5YR 4/4 Sand Clay Loan
33+ 2.5Y 511 Sandy Loam
Boring #5
Denth Range (in 1 Cnl nr Mottles T-fi-
0-6 1 OYR 4/3 Silt Loam
7-13 I OYR 3/2 10YR 5/6 Silt Loam
14-22 1 OYR 6/3 1 OYR 5/6 Silt Loam
23-37+ 25Y 6/1 7.5YR 518 Sandy Loam
Boring #6
Depth Range. (in 1 ('nlnr nMrrl,.? To..t -
0-6 1 OYR 3/2 Silt Loam
7-10 IOYR 3/2 10YR 4/6 Silt Loam
11-16 25Y 4/1 IOYR 4/6 Clay Loam
17-35 2.5Y 6/1 25Y 5/6 Clay
36+ 5Y 6/1 5Y 6/6 Sandy Clay Loam
Boring #7
Depth Ranee (in.] Color Mottles Texture
0-11 2.5Y 5/3 Silty Clay Loam
12-34 2.5Y 5/2 10YR 5/6 Clay Loam
35+ 2.5Y 5/2 ]OYR 5/6 Sandy Clay
Boring #8
Depth Ranee (in.] Color Mottles Texture
0-6 2.5Y 5/3 Silt Loam
7-12 2.5Y 5/2 2.5Y 5/6 Clay Loam
13 40+ 2.5Y 6/1 2.5Y 5/6 Clay
Boring #9
Depth Ranee (inJ Color Mottles Texture
0-13 lOYR 5/4 Silt Loam
14-30 2.5Y 6/1 2.5Y 5/6 Sandy Clay Loam
31-40+ 2.5Y 6/1 Sandy Clay
Boring #10
Denth Range (in 1 CA- Mnttl- To..r?.?o
0-17 2.5Y 4/3 Silt Loam
18-26 2.5Y 6/1 2.5Y 5/6 Silty Clay
27-34 2.5Y 5/1 2.5Y 5/6 Sandy Clay Loam
35-40+ 1 OYR 6/1 7.5YR 5/8 Clay
10
11
12
4)
w
m 13
m
a: 14
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3
O
= 15
r
Q
m
0 16
17
y?
18 1 °- - --- - - -
Figure 1. USGS Pisgah Forest Site (351709082434101) Average Monthly Depth
to Water Level Data for a 22 year period as compared to the 2007 drought year
2007.
Month
Sep Oct Nov Dec
0
- +- - Estimated Water Level for Fletcher Site in an "Average Year"
5 --o- Fletcher Monthly Low Real-Time Data for Sept-Dec 2007
W
r 10
v
c
15
L 20
m
25
0
s
Q. 30
m
D
35
40 ' I
Figure 2. Conservative Estimate of Water Level for the Fletcher Site in an
"Average Year" as Compared to 2007 Drought Water Levels. (based on 50% of
the difference between mean and 2007 levels at Pisgah Forest site 15 miles away)
References
U.S.G.S. Surface-water Daily Data for the Nation. 2008. USGS point 351709082434101.
Available URL: htti)://waterdata.usgs.t!ov/nwis/dv. Accessed June 17, 2008.
Month
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Re: [Fwd: Re: Fletcher-Meritor Site Comments]
Subject: Re: [Fwd: Re: Fletcher-Meritor Site Comments]
From: "[e-mail]" <[e-mail]>
Date: Tue, 24 Jun 2008 10:04:30 -0400 (EDT)
To: <eric. kulz@ncmai 1. net>
5%...always 115%1'... USACE brought up bigger issues with the soils -
that will be an interesting discussion - might be creation instead of
restoration IF it meets the 5%...always 5%... At this point, I suppose
we can deem it issued "at your own risk" as the Corps said, without
approval of any specific credit #s (of course, the credits to be
generated aren't in the plans most of the time now anyway) pending
future debate by the PACG-TC.
Have you decided about the buffer conference? Sounds like JH needs to
make arrangements by Thursday, and I'll need to change some plans if
I'm going to go.
Hope all's well with the 401 class. I'm cruising on paperwork beans
here at home
T
I of 1 6/26/2008 12:37 PM