20190288 Ver 1_More Info Received_20191017

CLearWater
ClearWater Environmental Consultants, Inc.
www.cwenv.com
October 17, 2019
Ms. Sue Homewood
NC DEQ, Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699
SUBJECT: Response to Request for Additional Information
DWR # 2019-0288
Request to Modify 404 Permit, Buckeye Reservoir, Town of Beech Mountain
Buckeye Creek Reservoir, Watauga County, North Carolina
Dear Ms. Homewood:
Below are responses to comments received by the North Carolina Division of Water Resources
regarding the Buckeye Creek Reservoir permit modification request that was submitted to the US
Army Corps of Engineers on February 21, 2019.
Please review the following responses to each comment for clarification to modify the US Army
Corps of Engineers permit that was issued to the Town of Beech Mountain on November 28, 1984.
NC Division of Water Resources comments from letter dated September 26, 2019:
The response submitted by Clearwater Environmental on August 15, 2019 (dated August
6, 2019) proposed a minimum release schedule in accordance with two tables (Table la
and Table 1 b). The response submitted indicates that the proposed minimum release
schedule is in accordance with a recommended schedule provided by the Division in 2016.
As the proposed schedule (Tables la and lb) and the recommended 2016 schedule were
presented in slightly different formats, the Division would like clarification that the tables
provided below accurately reflect the Town's proposal for a new minimum release schedule
to be required as a condition of a modified 401 Water Quality Certification.
The Town accepts the version of tables below as a proposed new minimum release schedule to be
required as a condition of the 401 Water Quality Certification.
32 Clayton Street
Asheville, NC 28801
828-698-9800 Tel

Ms. Homewood
DWR # 2019-0288
October 17, 2019
January 1—April 15
Reservoir Water
Action as required by
Minimum Release
Surface Elevation
WSRP
MAF = 6.32 CFS
Flowing over spillway
None
40% MAF = 2.53 CFS
Between top of
Tier 1
40% MAF = 2.53 CFS
spillway (but not
Voluntary Restrictions
flowing over) and 4
feet below spillway
Between 4 feet below
Tier 2
20 % MAF =1.26 CFS
spillway and 6.5 feet
Mandatory Restrictions
below spillway
10% reductions
Between 6.5 feet
Tier 3
Outflow will equal Inflow determined
below spillway and
Mandatory Restrictions
using USGS Stream Gauges (upstream and
13.5 feet below
20% reductions
downstream)
spillway
Between 13.5 feet
Ter 4
Outflow will equal Inflow determined
below spillway and
Emergency Restrictions
using USGS Stream Gauges (upstream and
23.5 feet below
25% reductions
downstream)
spillway
23.5 feet below
Tier 5
Outflow will equal Inflow determined
spillway
Water Rationing
using USGS Stream Gauges (upstream and
downstream)
April 16 -- December 31
Reservoir Water
Action as required by
Minimum Release
Surface Elevation
WSRP
MAF = 6.32 CFS
Flowing over spillway
I None
20% MAF =1.26 CFS
Between top of
Tier 1
20% MAF =1.26 CFS
spillway (but not
Voluntary Restrictions
flowing over) and 4
feet below spillway
Between 4 feet below
Tier 2
15 % MAF = 0.95 CFS
spillway and 6.5 feet
Mandatory Restrictions
below spillway
10% reductions
Between 6.5 feet
Tier 3
Outflow will equal Inflow determined
below spillway and
Mandatory Restrictions
using USGS Stream Gauges (upstream and
13.5 feet below
20% reductions
downstream)
spillway
Between 13.5 feet
Tier 4
Outflow will equal Inflow determined
below spillway and
Emergency Restrictions
using USGS Stream Gauges (upstream and
23.5 feet below
25% reductions
downstream)
spillway
23.5 feet below
Tier 5
Outflow will equal Inflow determined
spillway
Water Rationing
using USGS Stream Gauges (upstream and
downstream)

Ms. Homewood
DWR # 2019-0288
October 17, 2019
2. The response submitted on August 15, 2019 indicates "Once the stream gauges are
calibrated for stage -discharge relationships, the Town will utilize the Upstream Gauge
stream flow during low flow conditions ... " Please clarify when it is expected that
calibration will be completed. [15A NCAC 02H.0506(b)]
The USGS gauge number 0347927162 located upstream of Buckeye Reservoir has been
operational throughout 2019. Since February 2019, USGS staff have completed 13 calibration
field measurements of stream discharge ranging between 0.26 and 52.7 cfs. This calibration work
by USGS is expected to continue through early 2020 in order to create a stage -discharge
relationship by June 2020. Real-time stream gage measurements for this site are available on the
USGS web site: https://waterdata.usgs.gov/nwis/inventory/?site no=0347927162
3. In response to public comments received through the US Army Corps of Engineers, the
response submitted on August 15, 2019 states "The Town is committed to replacing
infrastructure to reduce water loss and has allocated $3.3 million in the next two years and
another $3.42 million in the next 6 years to replace waterlines and pressure reducing
valves to reduce the amount of water per day that is lost from defective pipes. " Please
provide an estimate of the reduction in the amount of water lost per day upon completion
of these upgrades. VISA NCAC 02H.0506(b)]
Whereas real water losses through the galvanized steel piping and older service connections is
estimated to be 150,000 gallons per day, and whereas the two projects mentioned would replace
8% to 10% of that older infrastructure, it is estimated that 10%, or 15,000 gallons per day, of water
loss would be eliminated.
Thank you for reviewing the responses to agency comments above. Should you have any questions
or comments concerning this project please do not hesitate to contact me at 828-698-9800.
Sincerely,
Anna Priest, P.W.S.
Project Manager
Copy Furnished:
US Army Corps of Engineers — Amanda Jones
US Fish and Wildlife Service — Byron Hamstead
NC Wildlife Resources Commission — Andrea Leslie
/e A &
R. Clement Riddle, P.W.S.
Principal