20170359 Ver 2_Response to DWR comments_20191111_20191112

Jobnohazenandsawyer.com
Hazen and Sawyer
4011 WestChase Boulevard, Suite 500
Raleigh, NC 27607 • 919.833.7152
November 11, 2019
Ms. Sue Homewood
North Carolina Department of Environmental Quality
401 & Buffer Permitting Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: DWR# 20170359 v2 – Response to the Additional Information Request for the Loch Dornie
Dredging, Island Enhancements, and Linville River Stabilization Project, Avery County, NC
Dear Ms. Homewood:
On October 23, 2019, Grandfather Golf and Country Club (GGCC) received a request for additional
information letter from the Division of Water Resources — Water Quality Programs (Division) regarding
GGCC’s application for a 401 Individual Water Quality Certification for the subject project. GGCC’s
responses to the Division inquiries and comments are provided herein for your consideration. The
Division’s comments are included, with GGCC’s responses in italicized text below each comment for
clarity.
1.If the U.S. Army Corps of Engineers requests a response to any comments received as a
result of the Public Notice, please provide the Division with a copy of your response to the
USACE. [15A NCAC 02H .0502(c)]
GGCC has noted the Division’s request and intends to copy the Division, as well as the North
Carolina Wildlife Resources Commission (WRC) on all pertinent communication with the
USACE on the project.
2.Please provide a map depicting all jurisdictional features within the project area and please
locate all features as overlays on the site plan. [15A NCAC 02H .0502(b)]
Two figures depicting the jurisdictional features are attached to this letter.
3.Phase 2E in the Sequence of Construction Phasing on Sheet E000 states that the
Permittee will harvest class 1 and 2 boulders from fairway 17 stream crossing and
stockpile for j-cluster wall use and bridge 5 use. Please explain if the material to be
harvested is native stream substrate or some other material. [15A NCAC 02H .0502(b)]
Please note that some design elements that were included in the original permit application
have been eliminated following the October 9, 2019 onsite meeting with USACE, the
Division, and WRC. One such element is the j-cluster wall. No work is currently proposed at
the fairway 17 stream crossing. Boulders to be used for bridge 5 will be rock removed from
the project area as part of the proposed dredging work. The rock is naturally occurring
material that has been relocated downstream to its current location by past high-flow events.
Hazen
Ms. Sue Homewood
November 11, 2019
4. The Project Description section of the application indicates bank stabilization #2 will
consist of a rock wall along 80 feet of the Linville River. However, stream impact S5 in
the table indicates the impact length for bank stabilization #2 is 54 feet of temporary
impact. Please clarify the discrepancy. Please note that the Division will consider this
impact to be permanent, although it will not be considered a loss of water for the
purposes of mitigation requirements. [15A NCAC 02H .0502(b)]
Bank stabilization #2 has been eliminated from the proposed project. If GGCC elects to
pursue this work at a later time, it will be submitted to the regulatory agencies for
authorization under separate cover and as a separate project. Please see the revised project
plan sheets and impact figures and table, which denote the project components that have
been removed from the subject project.
5. Please clarify if the construction details for S 1 (Sanitary sewer protection) are the same as the
S4 (Grade control sills) as depicted on Sheet C300. [15A NCAC 02H .0502(b)]
All grade control sills, including those associated with S1 and S4, have been removed from
the subject project. If GGCC elects to pursue this work at a later time, it will be submitted to
the regulatory agencies for authorization under separate cover and as a separate project.
6. Erosion control matting that incorporates plastic mesh and/or plastic twine shall not be used
along or within waters of the state. Please clarify whether the 3D Geomat proposed for island
shoreline stabilization will meet this requirement. [ 15A NCAC 02H .0501 and .0502]
The proposed 3D Geomat is made of a synthetic material. However, it will not be left
exposed. It is designed to be covered by 18 inches of cobble, which will be topped by a layer
of topsoil and a layer of sod and/or select plantings. The geomat is intended to become
integrated with root systems and provide long-term protection to handle fluctuating lake
levels and erosive wind -wave action in the harsh weather environment. Surficial, exposed
erosion control matting proposed for the project consists of a coconut fiber matting that will
be secured on top of the topsoil, seed, and straw in order to retain these materials in place
while the vegetation is establishing itself. The only exposed erosion control matting specified
for the project shall consist of natural fibers.
7. Please perform a Tier I analysis as described in the EPA's and US Army Corps of Engineers
Evaluation of Dredged Material Proposed For Discharge in Waters of the U.S.-Testing
Manual to determine the potential for contaminated -related impacts associated with the
discharge of the dredged material. Depending on the results of the Tier I analysis, a sampling
and analysis plan may be required following the procedures outlined in the manual. [15A
NCAC 02H .0502(b)]
The Tier I analysis is attached hereto.
8. In accordance with Section 6.86 of the NC Erosion and Sediment Control Planning and
Design Manual, polyacrylamide should not be used in the environmental release channel.
[15A NCAC 02H .0502(b)]
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Hazen
Ms. Sue Homewood
November 11, 2019
The sediment control measures that were originally specified within the environmental
release channel have been eliminated from the project, in order to comply with the referenced
regulation. Rather than install sediment control measures in the channel, Hazen construction
oversight staff will regularly monitor turbidity in the Linville River at a location that is
downstream of the mouth of the environmental release channel to ensure that any increased
turbidity levels are known in a timely manner. Please see the attached turbidity monitoring
protocol for additional information.
It appears that new built upon area and a modification of a stormwater piping system
discharging to the lake are proposed in the clubhouse area. Please provide a detailed
drawing/plan showing new built upon area, any removed built upon area, a tabulation of
the net built upon area (new BUA — BUA removed) in the project area, and the
proposed stormwater drainage plan for this area. [15A NCAC 02H .0506(g)]
Please see the attached GG&CC EventLawn BUA.pdf for the stormwater drainage plan.
The largest component of stormwater design for this project is the stormwater drainage
beneath the proposed enlarged event lawn adjacent to the clubhouse. This disturbed area
discharges directly to Loch Dornie. During construction of the event lawn area, the asphalt
cartpath will be removed, lawn will be expanded and regraded using retaining walls, and
new paths will be added. The existing pipe network will be expanded to discharge to the new
edge of water and pick up the additional 3,435 sf of impervious area in the event lawn area.
Area
(sf)
Area
(ac)
Description
New BUA
5221
0.12
Proposed asphalt, pavers, and retaining walls
BUA Removed
1786
0.04
Existing asphalt cart path
Net BUA
3435
0.08
New BUA - BUA removed
10. Please provide a detailed turbidity monitoring plan which includes methodology, schedule,
benchmarks and response action plan. [ 15A NCAC 02H .0506(b)(2)]
A detailed turbidity monitoring plan is attached.
11. Please provide the Division a copy of your response to the October 11, 2019 email from Ms.
Amanda Fuemmeler with the U.S. Army Corps of Engineers requesting additional
information. [15A NCAC 02H .0502(c)]
GGCC's response to USACE was submitted on October 25, 2019 via email. The Division
and WRC were copied on the email. Please let us know if you did not receive the email.
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Hazen
Ms. Sue Homewood
November 11, 2019
If the Division needs additional information or clarification of the information presented herein, please do
not hesitate to contact me at [e-mail] or [phone]. GGCC and Hazen
appreciate the Division's assistance with the proposed project.
Sincerely,
Ms. Keven Arrance
Senior Principal Scientist
Enclosures
cc: Amanda Jones-Fuemmeler, USACE Asheville Regulatory Field Office (via email)
Andrea Leslie, NCWRC (via email)
Byron Hamstead, USFS (via email)
Alan Shuping, Grandfather Golf and Country Club (via email)
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