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HomeMy WebLinkAbout20070291 Ver 4_More Info Received_20090126LMG LAND MANAGEMENT GROUP INC. Environmental Consultants January 22, 2009 1. To better understand the economic impact that this project will have on the Town of East Arcadia and the County of Bladen as we try to attract industry to this area. a. The impact of being located in a protected watershed. The Environmental Assessment that was submitted in regards to this project addressed the affected environment and concerns that could be associated with the construction of this project. As the proposed project involves the installation of approximately 1,200 linear feet of 60-inch raw water main and a three screen intake apparatus that will run parallel to the existing raw water intake pipe and screens, no additional impacts are anticipated in regards to being located within a protected watershed. The existing system currently provides 45 million gallons per day (MGD) of raw water to four customers (City of Wilmington, Brunswick County, Invista and Praxair). The proposed project will increase that available capacity to these customers to approximately 55 MGD to meet near future demands as projected by these entities. TO: Mr. Ronnie Smith U.S. Army Corps of Engineers P.O. Box 1890 Wilmington, NC 28402-1890 RE: King's Bluff Pump Station; Action ID# SAW-200641503 Bladen County, NC Dear Ronnie: o1-aQ-CgI Vi r--- r= r;;;, D, JAN 2 6 2009 DENR - WATER CUAL! ! t WETLANDS AND STORfAWATER BRPNCH Thank you for your letter dated November 2e, 2008 in which you provide comments received during the Public Notice review period for the King's Bluff Pump Station Expansion Project. Comments were received from the Town of Arcadia and from the NC Wildlife Resources Commission. Below is a response to each of these comments. Town of Arcadia The governing board of the Town of East Arcadia is requesting that a public hearing be held to consider the proposed application. The reasons far this requested public hearing is as follows: www.lmgroup.net • info@lmgroup.net • Phone: 910.452.0001 • Fax: 910.452.0060 3805 Wrightsville Ave., Suite 15, Wilmington, NC 28403 • P.O. Box 2522, Wilmington, NC 28402 b. How does this project, that provides approximately 130 MGD to the Wilmington area, affect our ability to be able to meet the demands of other industries that we would hopefully be able to attract in the future? The 7Q10 flow at Lock & Dam No. 1 is 530 MGD of which 20% is 106 MGD. The proposed withdrawal rate of the authority is 96 MGD for the year 2030. The City of Wilmington raw water pump station (located adjacent to the Authority's Kings Bluff Station) withdraws approximately 10 MGD from the river and is not anticipated for expansion. The City has requested that the Authority become the long-term raw water provider for the City. Therefore, the Authority's requested withdrawal is consistent with the 20% 7Q 10 flow. During the recent and ongoing drought, water flow and withdrawal from Lock & Dam No. 1 has been stable and largely unaffected by the drought conditions. It is noted that the Division of Water Resources is currently evaluating the Cape Fear River Basin, projected flows, and water withdrawals. c. Will the removal of 130 MGD have a long term effect on our ability to provide water to our citizens as we experience growth in the future? Please reference the response to comment b, above. The need for the proposed project is based upon current and future raw water demands to serve the Authority's customers. As the projections below indicate, Authority customers will require 96 MGD of raw water from the system by the year 2030. This withdrawal is consistent with 20% of the 7Q 10 flow. Based on this, long term effects on the Town of East Arcadia are not anticipated. Customer Current Demand (MGD) 2010 Demands (MGD) 2015 Demands (MGD) 2020 Demands (MGD) 2025 Demands (MGD) 2030 Demands (MGD) City of Wihnin ton 15 17.9 27.1 29.9 33.2 36.9 Brunswick Count 24 28 34 38 42 43 Invista 4.1 4.1 4.1 4.1 4.1 4.1 Praxair 0.1 0.1 0.1 0.1 0.1 0.1 Pender County 0 2 5 7.2 9.2 12 Totals 43.2 52.07 70.27 79.27 88.57 96.07 2. Will this project effect the current watershed classification of this area? Will there be any more restrictions or ordinance conditions imposed on our citizens as to what will be required for them to be able to develop their property? Surface waters in the project area are part of Cape Fear River Basin. Classification of the river at this location is WS-IV, C. These classifications stand for: 2 Class WS-IV - Waters used as sources of water supply for drinking, culinary, or food processing purposes where a WS-I, II or III classification is not feasible. These waters are also protected for Class C uses. WS-IV waters are generally in moderately to highly developed watersheds or Protected Areas. Class C - Waters protected for uses such as secondary recreation, fishing, wildlife, fish consumption, aquatic life including propagation, survival and maintenance of biological integrity, and agriculture. Secondary recreation includes wading, boating, and other uses involving human body contact with water where such activities take place in an infrequent, unorganized, or incidental manner. The proposed project will not affect the watershed classifications. Additionally, the existing watershed ordinance will remain in place. No new restrictions or ordinance conditions will be imposed on citizens or adjacent landowners. 3. To provide a better explanation and understanding to our citizens in regard to the watershed ordinance that has already been imposed on them as it relates to the existing water intake. It is suggested that the citizens of the Town of Sandyfzeld and other surrounding areas affected by this ordinance be invited to the requested public hearing. We hope that our response here has addressed concerns regarding the watershed ordinance and that a public hearing is not necessary. 4. To mitigate for the 10 foot wide maintenance corridor (0.18 acres of wetlands) the applicant proposes to utilize the North Carolina Ecosystem Enhancement Program for the restoration of 0.25 acre of riparian wetlands. The citizens of East Arcadia along with the Governing Board of East Arcadia would like to better understand how this mitigation will benefit the environmental condition of the Town of East Arcadia. How does one type of wetlands compare to the other. Where are the mitigated wetlands located in relation to the Town of East Arcadia and the County of Bladen? Generally, regulatory agencies require that mitigation be implemented as close to the impact site as possible. Mitigation banks in the state of North Carolina are normally able to offer credits to projects that have impacts located within the eight-digit hydrologic cataloging unit that the bank is located in. This particular project is located within the Cape Fear River Basin (#03030005). There are four broad habitat categories for banks in North Carolina. Of these four types, the riparian wetland habitat (located adjacent to streams) most closely describes the impact area. There are currently no private banks with credits available in the Cape Fear River Basin. Therefore, the applicant has requested to utilize the NC EEP, which is operated by the NCDENR. The applicant's payment would be applied to restoring a riparian wetland system within the #03030005 cataloging unit of the Cape Fear River Basin. Through the ESP's Memorandum of Agreement with the Corps of Engineers, the EEP has up to one year from the time that a payment is received to actually construct a site within that cataloging unit. At this time, we are not aware of where specifically the mitigation site will be located. 3 S. What is the composition of the fill materials that are being placed in the Cape Fear River and adjacent wetlands? Is the composition of the fill materials such that it would not pose a threat to the citizens of East Arcadia? Given that the proposed fill site is located in the 100 year floodplain, if any of the water that has come in contact with the fill materials was to leave the fill site during a f Zood, would a threat be posed to our citizens? The project consists of installing of a 60" raw water intake pipe underground and parallel to the existing 48" raw water intake pipe. Once the pipe has been installed, the wetlands will be returned to natural grade. At the outfall location, three intake screens will be constructed in the run of the river immediately adjacent to the three existing screens currently in operation. Temporary impacts are expected from the construction of the intake screens, which will be installed via sub aqueous methods. It is also possible that a coffer dam may be installed for construction of the screens to minimize impact to river wildlife. Besides these structures, no fill material will be placed within the project area. Sedimentation and erosion control devices will be used during construction to minimize sediment leaving the project area. Silt fences will be used and a designated work corridor will be established to reduce impacts. Once construction is complete, the area will be graded to natural elevations and seeded. Due to these erosion control measures, the project is not expected to affect adjacent property owners. NC Wildlife Resources Commission Comments were received by the Wildlife Resource Commission (NCWRC) during both the IP Public Notice and the Environmental Assessment review process. A response to these comments has already been sent to NCWRC as part of the EA process, but is reiterated below. The NCWRC requested a freshwater mollusk survey to be conducted in order to address the environmental concerns that may exist in the construction of the above mentioned project. Based on findings, as indicated in the survey, there are expected to be no adverse effects from implementation of the project. The NCWRC stated that they are satisfied with the survey and impacts in the river. Impacts to the intake area will be minimized and land disturbance on the river banks will be minimized with any disturbed land being stabilized as soon as possible to reduce sediment and erosion control. 1. For the protection of the early life stages of sensitive aquatic life species, including the diadromonous fish species that occur in the Cape Fear River, we recommend that the screen opening diameters of the three wedge wire screens be no larger than I mm in diameter. The screen openings are designed per the Johnson screen specifications. The screen openings are designed at 0.118 in diameter openings. 2. We request that further information be provided to explain the rate of withdrawal from the Cape Fear River. To reduce negative impacts upon aquatic species, we recommend that the velocity of intake through the screens not exceed 0. S ftis. The through velocity is determined by the Johnson Screen specifications as well. The through velocity is designed to not exceed the 0.5 ft/s rate. 3. Federally endangered and threatened species are particularly affected by secondary and cumulative impacts associated with urban development due to their sensitivity to habitat degradation and resulting high probability of extirpation. To properly address the secondary and cumulative impacts from the proposed project, please refer to our Guidance Memorandum. Secondary and Cumulative impacts associated with the proposed project have been addressed in the Environmental Assessment that has been submitted for this project. The Guidance Memorandum will be consulted for that document. I hope this response adequately addresses your concerns. Please contact me if you have any questions. Thank you for your assistance with this project. Sincerely, Kim Williams Wetland Scientist C: Mr. Don Betz, Lower Cape Fear Water and Sewer Authority Ms. Emily McArthur, McKim & Creed Mr. Ken Averitte, DWQ Mr. Ian McMillan, DWQ 5