20180582 Ver 2_More Info Received_20191127

CLearWaLer
C1earWater Environmental Consultants, Inc.
www.cwenucom
November 27, 2019
Ms. Sue Homewood
NC DWR, 401 & Buffer Permitting Unit
450 W. Hanes Mill Road, Suite 300
Winston-Salem, North Carolina 27105
RE: DWR Request for Additional Information
Cashiers Canoe Club
Jackson County, North Carolina
Action ID SAW-2016-00032; DWQ Project # 2018-0582
Dear Ms. Homewood,
Please reference the letter dated October 28, 2019 (Attachment A) sent by the NC
Division of Water Resources (DWR) in response to the permit application submitted by
ClearWater Environmental Consultants, Inc. (CEC) on behalf of the Cashiers Canoe Club
Development (Applicant) represented by Ms. Roseanne Giordani. The permit application
requested written authorization for impacts associated with the maintenance dredging of
the existing Cashiers Lake and associated mixed -use development. Comments provided
by the DWR are discussed below.
DWR Comment # 1 - The Division received multiple comments expressing concerns for
pollutants that may be present within the dredge material. It was brought to the
Division's attention during the hearing a plastics manufacturing facility previously
existed in Cashiers and that it may have had discharges upstream of Cashiers Lake. It
was also noted that sampling data provided to the Division indicated high levels of
Chromium. Please provide a proposed sediment sampling plan that includes all
constituents listed in 40 CFR EPA Appendix II to Part 258 - List of Hazardous Inorganic
and Organic Constituents to ensure compliance with the May 2019 NCDEQ Preliminary
Soil Remediation Goals (PSRG). The sampling plan must include a detailed description
of the proposed locations and methodology for the proposed sampling. The Division
recommends following the guidance detailed in Part Ill of the EPAIUSACE Evaluation of
Dredged Material Proposed For Discharge in Waters of the U.S - Testing Manual
{Inland Testing Manual).
32 Clayton Street
Asheville, NC 28801
828-698-9800 Tel

The applicant has proposed the attached sampling plan (Attachment B), which
includes the required constituents for analysis. The proposed sampling plan
indicates the locations and methods for proposed sampling as recommended in
part III of the EPA/USACE Evaluation of Dredged Material Proposed for
Discharge in Waters of the U.S. (Inland Testing Manual).
DWR Comment #2 - The Division received multiple comments expressing concerns
regarding invasive plant species which currently exist within Cashiers Lake, specifically
Parrot Feather and Yellow Flag Iris. Multiple commenters indicated that removal of the
invasive species would be a benefit of the proposed dredging project. Please provide an
invasive species management plan that addresses the concern of mobilization of invasive
seed sources during the dredging and disposal activities.
The Cashiers lake sediment and erosion control plan includes the use of Floating
Sediment curtains, which shall be used to isolate the wetland dredge and fill areas
from open water. These flexible sediment control barriers are designed to prevent
the spread of silt, sediment, and turbidity in water bodies while the dredging work
is being performed. While dredging in areas containing invasive aquatic plants,
the floating silt curtains will serve as an effective barrier against the transport of
any potentially dislodged plant material, thereby reducing the potential of
downstream transport of invasive aquatic plants. Disposal of dredged material
will occur ;in an upland area, which is not conducive to the growth of aquatic
invasive plants, therefore there is very low risk of transported parrot feather and
yellow flag iris becoming established within the upland disposal area. Sediment
and erosion control measures such as silt fence installed around the perimeter of
the disposal area will prevent the downstream transport of silt, sediment, and any
potentially dislodged invasive plant parts to areas conducive to aquatic plant
habitat.
The invasive plant populations currently established m open water and edge areas
not proposed for dredging would require multiple years of successive
management treatment, including the use of mechanical removal combined with
application of aquatic herbicide. Currently, invasive plants established in areas
outside the dredge and fill area are not proposed for treatment by herbicide or
mechanical removal and will continue to have the potential to continue to spread
within the lake and in downstream waters regardless of proposed dredging
activities. The persistence of invasive plants within Cashiers Lake is an existing
condition not likely to be positively or negatively affected by the dredging
activities. Eradication of the existing invasive plant population in Cashiers Lake is
outside of the range of the dredging proposal.

DWR Comment #i 3 - The Division received multiple comments expressing concern that
the downstream waters would not be adequately protected during in -lake construction
activities unless a complete pump around system was utilized. Specifically, they were
concerned that inadequate storage would exist to accommodate significant precipitation
events during the dredging activities. Please provide a detailed explanation and/or
analysis of how downstream waters will be protected from turbidity during significant
rain events during in -lake construction activities.
Erosion control on the site shall comply with (NCDENR) Erosion Control
Planning & Design Manual Standards & Specifications. The erosion control
design prepared by Land Design focuses on capturing sediment near the source,
along with protecting downstream flows to sensitive trout waters. The recently
rebuilt dam structure and impoundment capacity in place has been designed to
handle the 1/3 PMP storm event. This impoundment far exceeds any and all local
and state statues for downstream attenuation and water quality protection and
shall will remain in place to do so throughout the proposed dredging procedure.
The Construction Sequence for the Erosion Control is as follows:
1. Contractor shall verify that all applicable permits have been obtained prior to the
beginning of construction, and hold a preconstruction meeting and coordinate with
owner, engineer, and all applicable regulatory agencies.
2. Project is located in an environmentally sensitive area and is adjacent to a trout stream.
Contractor shall use extreme care throughout project.
3. Submit shop drawings to engineer for review and approval for all materials.
4. Contractor shall notify all affected property owners and obtain permission for property
access prior to proceeding with work.
5. Contractor should locate all existing utilities within the defined project area as shown in
the erosion control plan. Contractor shall notify engineer if there are any discrepancies
between the plans and field conditions.
6. Contractor shall work within allowable construction limits — sensitive property owners.
7. Contractor shall maintain vehicular access along Cashiers Lake Road (SR 1113) at all
times.
8. Stabilize construction entrances and access drives with gravel and mulch. Stake clearing
limits.
9. Install all upland silt fence, and other measures as shown on plans, clearing only as
necessary to install these devises.
10. All erosion measures shall be constructed in accordance with the NC erosion and
sediment control planning and design manual and US Department of Agriculture.
11. Call for on -site inspection by inspector and engineer.
12. Contractor shall lower the lake from the NWSE of 3471 to 3467. The dewatering of the
lake shall be a gradual process and the maximum rate of drawdown is 0.5' per day.
During the lake drawdown process contractor shall ensure the water being removed from
the lake drawdown process contractor shall ensure the water being removed from the lake
into the river is free of sediment. If sediment becomes a problem during the dewatering
process contractor shall contact engineer immediately.

13. Once the lake is lowered the contractor shall maintain minimum base flow at all times to
the Chattooga River at a minimum of 70% of inflow as measured by the inflow and
outflow meters (7Q10 information taken from NSGS). The minimum base flow shall be
accomplished by using either mechanical pump or siphon system and shall remain in
operation throughout the dredging and refilling process.
14. Contractor shall install & stabilize construction entrances into lake bed.
15. Contractor shall install temp Sediment Basin #1 with all associated temp ditches and silt
fence & turbidity baffles prior to any activity within the lake bed.
16. Once contractor has appropriately installed temp sediment basin #1, Contractor shall
begin installing TD #1 to establish a new stabilized base channel with associated
temporary crossings to allow all upper basin base flow to bypass the dredging area.
17. Only after Contractor has established & stabilized temp ditch #1 shall contractor be
allowed to commence with any other activities within the lake bed.
18. All wetland area dredging shall be done in an upstream to downstream direction. This is
so disturbed sediment can be captured in the downstream wetland. Sediment curtains
shall be used to isolate the dredge and fill areas from open water.
19. Install silt fence and other measures as shown on plans, clearing only as necessary to
install all devices within the lake bed area.
20. Lake shall be dewatered to an elevation of 3467 after storm events as needed per
sequence described in item #14.
21. The contractor shall diligently and continuously maintain all erosion control devices and
structures. Erosion control measures should be checked periodically and after every
rainfall event. Repairs shall be made immediately as required. Inspection and repair
reports shall be kept by the contractor and provided to the state erosion control agent
upon request.
22. Call geotechnical consultant for site inspection prior to grubbing or placing fill.
23. Contractor shall maintain one lane of traffic on Cashiers Lake Road (NCDOT SR 1113)
at all times.
24. When site has been permanently stabilized, remove erosion control devices and apply
permanent seeding in area of disturbance.
25. Coordinate with erosion control inspector prior to removal of any erosion control
measures.
26. Upon completion of the construction activities and stabilization the lake will be gradually
refilled, this will be accomplished by the contractor maintaining the minimum base flow
at all times to the Chattooga River at a minimum of 70% of inflow as measured by the
inflow and outflow meters (7Q10 information taken from NSGS). The minimum base
flow shall be accomplished by using either mechanical pump or siphon system. Flows
from the dam to the Chattooga River must be maintained at all times at 70% of the
incoming flow during Lake Refill.
Note: Erosion and sediment control measures shall be inspected daily and after any
rainfall. Any repairs or deficiencies shall be corrected immediately. A daily record log
shall be maintained on the site by the general contractor and will record any deficiencies
and the corrective measures taken. Installation of additional erosion and sediment control
measures may be necessary if requested by on -site inspection of NCDENR staff or the
owners' representative of the engineer. Reference the North Carolina Erosion and
Sediment Control Manual sections 6.01-6.02 for additional information.

Turbidity Monitoring Plan
The construction of this project will require in -water soil disturbing activities, which
must meet the state's water quality anti -degradation criteria. Lake Cashiers is located in
the Chattooga River basin and is considered an Outstanding Resource Water (ORW). The
contractor shall meet the following conditions:
1. Contractor shall place (3) Turbidity sensors within the project limits. Existing ambient
water quality within the mixing zone may be degraded to allow for in -water construction
activities. Turbidity levels shall not average greater than ten (10) Nephelometric
Turbidity Units (NTUs) above natural background conditions at the discharge zone
boundary
2. Ambient background samples shall be collected at the edge of ROW up stream of the
existing culverts at Frank Allen Road, fee from the source of turbidity. The background
sampling site will be marked by stakes and shall be maintained for the duration of the
sampling program. Background samples will be collected from the up -current sampling
location at the surface, mid -depth and one foot above bottom. In water, which is less than
six feet deep, mid -depth samples are not required.
3. All construction activities that have a potential to create turbidity, such as dredging that
require in -water soil disturbance, shall require monitoring. Sampling shall commence
prior to the start of construction activities, and continue twice daily, with a maximum of
four-hour intervals, during ongoing potential turbidity creating construction activities.
Samples shall be collected at all 3 locations simultaneously. The contractor is
encouraged to reduce the disturbed are within the dredging area to minimize the impacts
of turbidity to the remaining waterbody.
4. All samples will be collected with a grab sampler (or inline pipe / floating buoy constant
reporting devices located in the following 3 designated locations thru-ought the project.
a. In -line device upstream from the headwaters of the dual culverts under Frank
Allen Road to collect water prior to entering lake dredge area.
b. Floating buoy device located near cold water intake/ siphon at damn outlet
structure to collect water leaving dewatering area.
c. In -line device designated to collect water samples downstream of darn.
Samples must be analyzed for turbidity as they are collected. The following
information must be recorded for each sample taken and submitted in a
Monitoring Report.
5. In addition to the above mentioned, each Monitoring Report must include the following:
a. Site number;
b. Collector's name and affiliation
c. Date and time of day when sample was collected;
d. Sample collection depth and total depth;
e. Antecedent weather conditions, including wind direction and velocity; and,
f. Flow direction, if applicable.
6. In addition to the above mentioned, each Monitoring Report must include the following:
a. A statement of methodology including types of sampling equipment and
b. Analytical instrumentation, preservation, and handling;
c. Permit number;
d. A map indicating numbered locations of all sampling sites;

7. All turbidity monitoring reports shall be held onsite for Erosion Control inspector review
and submitted to the local Erosion Control office within (7) days of sample collection.
All correspondence should include the Permittee name and permit number. Failure to
submit reports in a timely manner constitutes a violation of the permit and may be
grounds for revocation.
8. The Contractor shall comply with the following QAIQC requirements for each sample
collected:
a. All turbidity analysis shall be performed on instruments that can perform
Nephelometric measurements;
b. The instrument must be calibrated each morning and each time the instrument is
turned on, and recalibrated every four hours thereafter,
c. Calibrations must be performed against a blank, and at least one formalin or gel -
type standard. The standard value should be in the same range as the sample
readings.
d. All calibration procedures must be recorded in a permanent log book, and copies
must be submitted with the date; and,
e. Date and time of collection, date and time of analyses, and the name of the
analyst must be included in the log.
9. All in -water soil disturbing construction activities shall cease immediately whenever
water quality samples exceed thresholds specified in item #1 at the boundary of the
discharge zone. The violation shall be reported within 4 hours of the violation. The
violation report shall include the description of the corrective actions being taken or
proposed to be taken. If violations are noted after normal business hours, on holidays or
on weekends, the report shall be made as soon as possible after normal business hours
resume. A copy of all monitoring data sheets, which indicate violations, shall be
forwarded immediately to the Erosion Control Inspector.
10. When turbidity violation is found, in -water soil disturbing construction operations may
not resume until a compliance inspection by District personnel has been conducted and a
set of samples has been taken which demonstrate that the water quality standards
designated above are being achieved.
11. Interim samples taken following the violation shall be taken in the same manner as the
routine monitoring and at the same locations. If samples demonstrate the water quality
standards specified for turbidity specified above are still being violated, sampling shall
continue at two-hour intervals until the interim samples demonstrate that water quality
standards are being achieved.
12. Failure to report violations and stop work and submit a corrective action plan to the local
erosion control inspector for approval before resuming work will constitute grounds for
enforcement action and may subject the Contractor to potential penalties

Stormwater
In 2009, Cashiers Canoe Club was given approval for a subdivision permit from Jackson
County along with an authorization to construct stormwater management plans via permit
SW 1080801. At the time, the permitted land parcel consisted of 53.79 total acres and
the development program was to construct 45 single family houses and 38 duplex units.
In 2010, the permitted plans were shelved due to the economic downturn and these plans
have not been revisited since their conception. Since this original design was permitted,
the owners have added additional land to the initial holding for the previously described
project in hopes of putting together a more comprehensive plan for the fixture. While this
new plan has been in conceptual development, the original stormwater permit has
remained active and is set to expire in May 2020. The approved development permits
with Jackson County that correspond to this stormwater permit, however, have expired
and are inactive.
In late 2016 as economic conditions improved, ownership commissioned a design
charrette to vet and discuss concept design feasibility for a new masterplan. The
programmatic elements that arose from this multi -discipline design and engineering
charrette included residential homes, retail and hospitality designs that would be fitting in
the context of the core of a village such as Cashiers. These elements include:
• Restore the lake to a portion of its historic open water condition;
• Restore, enhance and preserve additional aquatic resources in the watershed;
• Improve recreational activity opportunities on Cashiers Lake for the current and
future residents and visitors to the lake;
• Conduct maintenance activities, such as dredging portions of the wetlands that
have been expanding due to sedimentation from upstream over the past 60 to 70
yam;
• Facilitate a sediment removal program to help manage the continued upland
sediment migration and erosion deposits that negatively impact Cashiers Lake and
Frank Allen Road.
Without action, we believe the lake will continue to become more depredated and
eventually become inundated and unusable. As a result of these beliefs, the owners hired
C1earWater Environmental and LandDesign to facilitate a plan request for specific
dredging and permitting for the removal of some of the excess sediment (now wetlands)
that have settled in the lake since the 1950's and has begun impeding water to the open
lake body.
Since C1earWater Environmental's original application submittal to the Corp or
Engineers, the design team has responded to all requests with complete disclosure of any
and all upland development plans within the new overall upland boundary. Given that a
specific development concept has not been selected nor permitted with Jackson County,
the responses have been conceptual in nature. Therefore, in late 2019, the team was
requested to submit the latest version of concept uplands plan in order to go thru a N.C.

Division of Energy, Mine, and Land Resources (DEMLR) submittal for fast track process
hoping to secure an overall concept plan approval from DEMLR. After lengthy
discussion with the department review, DEMLR suggested pulling the application since
we technically are not designing anything that needs a DEMLR permit. It appeared that
DEMLR did not see the need to issue authorization to construct a watershed master plan
without a specific request for impervious area. Since there currently is not a development
program, the design team has been asked to produced several iterative conceptual design
possibilities in an effort be complete and thorough to create assurances that there will be
no additional stream or wetland impacts, such as road culvert crossings, required for
future development scenarios at the Canoe Club. In summary, the presented goal is to
keep wetland impacts isolated to the existing lake area for the purposes of this permit
request to the NC DWR and Corp of Engineers.
Given this history, we respectfully request that this application be reviewed simply for
the purposes of the lake dredge and that all upland development associated with this
parcel simply be subject to all jurisdictional local and state environmental criteria which
includes that state implemented stormwater water management program for Outstanding
Resource Waters 15A NCAC 2H .1000.
The applicant is willing to accept a permit condition that requires the review and approval
of the stormwater management plan prior to upland development. A copy of this
approved stormwater plan will be submitted to the NC Division of Water Resources.
The Applicant believes the information submitted in this package addresses all issues set
forth by the DWR in the letter dated October 28, 2019. Should you have any questions or
comments concerning this project please do not hesitate to contact me at 828-698-9800.
Sincerely,
R. Clement Riddle, P.W.S.
Principal
ATTACHMENTS:
Attachment A — DWR Request for Additional Information (October 28, 2019)
Attachment B — Proposed sediment sampling plan
Copy furnished:
David Brown — US Army Corps of Engineers, Asheville Field Office
Kevin Mitchell — Division of Water Resources, Asheville Regional Office

ATTACHMENT A
N.C. Division of Water Resources
Request for Additional Information October 28, 2019

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
October 28, 2019
DWR q 20180582 V2
Jackson County
Cashiers Canoe Club Development, LLC
Attn: Roseanne Giordani
PO Box 300849
Austin, TX 78703
Subject: REQUEST FOR ADDITIONAL INFORMATION
Cashiers Canoe Club Development and Lake Dredging
Dear Ms. Giordani:
On April 12, 2019, the Division of Water Resources — Water Quality Programs (Division) received your re-
application dated April 12, 2019, requesting a 401 Individual Water Quality Certification from the
Division for your project. Additional information was requested by the Division on June 3, 2019 and
received on July 15, 2019, August 12, 2019 and August 30, 2019. A public hearing was held on
September 5, 2019 with a public comment period from July 29, 2019 — October 7, 2019. Comments
received are available for review at the following link:
https://edocs.deg.nc.gov/W aterResources/Browse.aspx?dbid=0&sta rtid=961445
Based on the comments received, the Division has determined that the following additional information
is necessary to continue to process your application. The application is on -hold until all of the following
information is received:
1. The Division received multiple comments expressing concerns for pollutants that may be present
within the dredge material. It was brought to the Division's attention during the hearing a plastics
manufacturing facility previously existed in Cashiers and that it may have had discharges upstream
of Cashiers Lake. It was also noted that sampling data provided to the Division indicated high levels
of Chromium.
North Carolina Department of Environmental Quality I Division of Water Resources
rn.
D_E 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699 1617
919.707.9000

Cashiers Canoe Club Development, LLC
DWR# 20180582 v2
Request for Additional Information
Page 2 of 3
Please provide a proposed sediment sampling plan that includes all constituents listed in 40 CFR EPA
Appendix ll to Part 258 - List of Hazardous Inorganic and Organic Constituents to ensure compliance
with the May 2019 NCDEQ Preliminary Soil Remediation Goals (PSRG). The sampling plan must
include a detailed description of the proposed locations and methodology for the proposed
sampling. The Division recommends following the guidance detailed in Part III of the EPA/USACE
Evaluation of Dredged Material Proposed For Discharge in Waters of the U.S. — Testing Manual
(Inland Testing Manual).
The Division received multiple comments expressing concerns regarding invasive plant species
which currently exist within Cashiers Lake, specifically Parrot Feather and Yellow Flag Iris. Multiple
commenters indicated that removal of the invasive species would be a benefit of the proposed
dredging project. Please provide an invasive species management plan that addresses the concern
of mobilization of invasive seed sources during the dredging and disposal activities.
3. The Division received multiple comments expressing concern that the downstream waters would
not be adequately protected during in -lake construction activities unless a complete pump around
system was utilized. Specifically, they were concerned that inadequate storage would exist to
accommodate significant precipitation events during the dredging activities. Please provide a
detailed explanation and/or analysis of how downstream waters will be protected from turbidity
during significant rain events during in -lake construction activities.
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested
information for the proper consideration of the application. Please respond in writing within 30
calendar days of receipt of this letter by sending one (1) copy of all of the above requested information
to the 401 & Buffer Permitting Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617 OR by
submitting all of the above requested information through this
link: https://edocs.deg.nc.goviForms/Supplemental-Information-Form (note the DWR# requested on
the link is referenced above).
If all of the requested information is not received within 30 calendar days of receipt of this letter, the
Division will be unable to approve the application and it will be returned. The return of this project will
necessitate reapplication to the Division for approval, including a complete application package and the
appropriate fee.
Please be aware that you have no authorization under the Water Quality Certification Rules for this
activity and any work done within waters of the state may be a violation of North Carolina General
Statutes and Administrative Code.

Cashiers Canoe Club Development, LLC
DWR# 20180582 v2
Request for Additional Information
Page 3 of 3
Please contact Sue Homewood at 336-776-9693 or Sue. HomewoodCeDncdenr.aov if you have any
questions or concerns.
Sincerely,
Mac Haupt, Acting Supervisor
401 and Buffer Permitting Branch
cc: Clement Riddle, ClearWater Environmental Consultants Inc. (via email)
David Brown, USACE Asheville Regulatory Field Office (via email)
Andrea Leslie, NCWRC (via email)
Byron Hamstead, USFS (via email)
DWR ARO 401 files
DWR 401 & Buffer Permitting Unit

ATTACHMENT B
Pre -Dredging Assessment Plan
Headwater Geology PLLC

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Pre -Dredging Assessment Plan
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Cashiers Lake
Jackson County
Cashiers, North Carolina
Headwater Project # A19-158.01
Prepared for:
Cashiers Canoe Club Development, LLC
PO Box 300849
Austin, Texas 78703
November 26, 2019
r.;
40

Pre -Dredging Assessment Plan
Cashiers Lake
Jackson County
Cashiers, North Carolina
Headwater Project # A19-158.01
November 26, 2019
Prepared for
Cashiers Canoe Club Development, LLC
PO Box 300849
Austin, Texas 78703
Prepared by
Headwater Geology, PLLC
43 College Place, Suite 212
Asheville, North Carolina 28801
/ 4 �_4
Adam M. Tripp
Mike H. Falknor

Cashiers Lake —Pre -Dredging Assessment Plan
TABLE OF CONTENTS
1 Introduction............................................................................................................... 1
1.1 Background...........................................................................................................................1
1.1.1 DEQ Public Hearing —September 2019..................................................................2
2 Proposed Lake Sediment Assessment Activities...................................................... 5
2.1
Initial Contaminants of Concern Review..............................................................................5
2.1.1 Consolidated Metco Facility.....................................................................................5
2.1.2 Plastics Industry Information....................................................................................6
2.1.3 Cashiers Lake Sediment Sampling..........................................................................6
2.1.4 Initial Contaminants of Concern Summary ..............................................................6
2.2
Phase I: Sediment Sampling—Chattooga River....................................................................7
2.3
Sample Analyses..................................................................................................................7
2.4
Identification of Constituents of Concern.............................................................................7
2.5
Phase II: Sediment Sampling —Cashiers Lake......................................................................8
2.6
Summary Report..................................................................................................................8
3 References............................................................................................................... 9
FIGURES
Figure 1
Figure 2
APPENDICES
Appendix A
Location Map
Sample Location Map
Soil and Groundwater Report —Tables and Figures (Besinger & Garrison
2007)
Headwater Geology

Cashiers Lake —Pre -Dredging Assessment Plan
1 Introduction
Headwater Geology PLLC. (Headwater), on behalf of Cashiers Canoe Club Development, LLC
(CCCD), prepared this Pre -Dredging Assessment Plan (Work Plan) for the assessment of an
approximate 6.56-acre portion of Cashiers Lake. The subject area is located to the south of Frank
Allen Road in Cashiers, Jackson County, North Carolina (the Site). The lake location, and
proposed dredging area, is shown on the attached Figure 1 and Figure 2.
This Work Plan contains a project background and a summary of the North Carolina Department
of Environmental Quality (DEQ) public hearing. Headwater has also offered responses to
comments provided by the DEQ following the public hearing. Finally, a summary of the sediment
assessment strategy and methodology is provided.
1.1 Background
Headwater previously submitted a Pre -Dredge Environmental Review, dated December 14, 2018
for the Site (Headwater 2018). The scope of that review was discussed with, and approved by,
the DEQ as -well -as the Department of the Army (DA), and was completed in response to a June
28, 2018 DA Corps Comment and Request for Additional Information notice.
On November 28, 2018, six sediment samples (SB-1 0-2, SB-1 2-4, SB-2 0-2, SB-2 2-4, SB-3 0-
2, and SB-3 2-4) were collected from within the proposed dredging area of Cashiers Lake and
from two "background" locations (BG-1 0-2, BG-1 2-4, BG-2 0-2, and BG-2 2-4). Each sample
was collected at an area considered to be representative of Site conditions at that location.
At each location, sediment samples were collected from a 0-to-2 feet below grade surface (ft-bgs)
and a 2-to-4 ft-bgs depth interval. Additionally, four background samples were collected for
analysis of Resource Conservation Recovery Act (RCRA) metals from outside the proposed
dredging footprint at the same depths as the lake dredge samples. Samples were collected
utilizing a stainless -steel hand auger. The hand auger was decontaminated with an Alconox
solution and rinsed with de -ionized water before and between advancement at each sampling
point.
Based on direction provided by Mr. Ervin Lane of the DEQ-Division of Waste Management
(DWM), sediment samples were analyzed for:
• Volatile Organic Compounds (VOCs)
• Semi -Volatile Organic Compounds (SVOCs) and
• RCRA metals
Sediment samples collected from the background locations were analyzed for RCRA metals only
No constituents of concern (COCs) were identified above the applicable regulatory limits with the
exception of total chromium in all 10 samples (including background samples). Headwater
requested the laboratory speciate total chromium to allow for a more thorough comparison to
Headwater Geology 1

Cashiers Lake —Pre -Dredging Assessment Plan
regulatory standards. The results of the chromium speciation analysis indicated that trivalent
chromium concentrations were below applicable regulatory standards. Hexavalent chromium was
not detected above laboratory reporting limits in any sample analyzed (Headwater 2018).
1.1.1 DEQ Public Hearing —September 2019
Subsequently, a public hearing, regarding the Site dredging plan was held on September 5, 2019.
Based on comments received during the hearing and public comment period (July 29, 2019 to
October 7, 2019); the DEQ issued a second Request For Additional Information, dated October
28, 2019.
DEQ's October 2019 letter included the following comment:
1) "...it was brought to the Division's attention during the hearing a plastics manufacturing
facility previously existed in Cashiers and that it may have had discharges upstream of
Cashiers Lake. It was also noted that sampling data provided to the Division indicated high
levels of Chromium. Please provide a proposed sediment sampling plan that includes all
constituents listed in 40 CFR EPA Appendix I I to Part 258-List of Hazardous Inorganic and
Organic Constituents to ensure compliance with the May 2019 NCDEQ Preliminary Soil
Remediation Goals PSRGs. The sampling plan must include a detailed description of the
proposed locations and methodology for the proposed sampling. The Division
recommends following the guidance detailed in Part III of the EPA/USACE Evaluation of
Dredged Material Proposed For Discharge in Waters of the U.S. - Testing Manual (Inland
Testing Manual)."
Response to certain DEQ comments is described in the following sections.
1.1.1.1 Regulatory Comment —Elevated Chromium
The October 28, 2019 Request for Additional Information provided by the DEQ incorrectly
references the identification of "high levels of Chromium" based from the findings of Headwater's
2018 Pre -Dredge Environmental Review. To clarify, initial sampling completed by Headwater
identified "total" chromium in excess of applicable regulatory standards; however, once chromium
speciation was completed, it was determined that trivalent chromium was below applicable
regulatory standards and that hexavalent chromium was not present in excess of laboratory
reporting limits.
1.1.1.2 Regulatory Comment —Plastics Manufacturing
During the public comment period for the proposed project, concern over an upstream
manufacturing facility was referenced. According to available DEQ documents, that facility is
referenced as Consolidated Metco, formerly located at 95 Plastic Plant Road, approximately 0.25-
miles northwest of the Site.
Headwater Geology 2

Cashiers Lake —Pre -Dredging Assessment Plan
According to documents available via the DEQ-DWM, Laserfiche website, soil samples were
initially collected from the facility in association with due diligence related to a potential property
transaction in January 15, 2007. The results of that assessment identified volatile and semi -
volatile compounds in soil and recommend further soil and groundwater review. As a result of this
initial assessment, a release was attributed to the operations of the facility, and the then
Department of Environment and Natural Resource (DENR) issued a Notice of Violation (NOV) on
March 7, 2007. That NOV references the facility as Incident Number 88035 and requested further
assessment and remediation of the Consolidate Metco Plant.
In response to the March 7, 2007 NOV, Consolidate Metco engaged Besinger & Garrison (B&G)
to complete additional soil and groundwater review. B&G issued an August 21, 2007 Soil
and Groundwater Report. Based on the findings of that report, B&G recommended that
more extensive groundwater monitoring be completed within the building footprint and
downgradient of the facility as -well -as the collection of additional soil samples to further
delineate identified impacts. Tables and figures from the B&G August 2007 report are
included in Appendix A. Figure 2 of B&G's report shows three outfalls discharging to the
Chattooga River (referenced as Cashiers Creek on the figure). Outfall 001 appears to be
associated with stormwater drainage from the access road to the facility, and Outfall 002 and 003
appear to be associated with stormwater drainage from the facility footprint.
B&G later issued a Comprehensive Site Assessment (CSA) report in January of 2008. The results
of the CSA identified of impacted soil; including locations beneath a "press room", within a "drum
storage area", beneath a "storm drain adjacent to the drum storage area", and downgradient of
stormwater "outfall 003".
Additionally, assessment during the completion of the CSA, confirmed several locations of
impacted groundwater. The results of the CSA also identified the conveyance of impacted
stormwater downgradient of the facility via a stormwater outflow (Outfall 003). Soil assessment at
this outflow discharge identified oil and grease constituents in excess of the regulatory allowable
limits. In response, soil excavation along with off -site disposal was engaged in the vicinity of the
outflow discharge, as -well -as in vicinity to the associated storm drain inlet, and a drum storage
area. A total of approximately 65 tons of impacted soil were removed for off -site disposal.
The CSA results indicated that plant demolition was planned for 2008, at which time further
remediation was recommended.
Based on the results of the 2008 CSA, the DENR issued a Notice of Regulatory Requirement
(NORR) requesting further downgradient groundwater assessment.
Plant demolition occurred between February and April of 2008. After plant demolition was
completed, B&G engaged a series of soil excavation and disposal events between June 2008
and November 2008. The total amount of soil removed from the facility totaled approximately
2,275 tons.
Headwater Geology 3

Cashiers Lake —Pre -Dredging Assessment Plan
Additionally, groundwater remediation pits and a free product recovery well were utilized to
address previously inaccessible areas and to recover free -phase product. After four events, the
pits and well were abandoned as infiltration of impacted groundwater was no longer observed.
Various additional assessment and reporting documents were provided by B&G to the DENR
through March 2009. In a Report of Additional Assessment Activities, dated March 2, 2009, B&G
requested that a No Further Action status be applied for on behalf of the Responsible Party,
Consolidated Metco.
On March 11, 2009 the DENR issued a Notice of No Further Action (NFA) regarding the
Consolidated Metco facility, Incident Number 88035. No additional facility -specific documentation
was available after this date.
Headwater Geology 4

Cashiers Lake —Pre -Dredging Assessment Plan
2 Proposed Lake Sediment Assessment Activities
Proposed lake sediment assessment activities were prepared in general accordance with the
requests detailed in the October 28, 2019 DEQ Request for Additional Information (Item 1) and
the Evaluation of Dredged Material Proposed for Discharge to Waters of the U. S — Testing Manual
(Inland Testing Manual) prepared by the United States Environmental Protection Agency (EPA)
and dated February 1998 (EPA 1998).
Headwater recommends assessment be performed in a phased approach involving two phases.
Phase I will involve the evaluation of sediment within areas proximate to potential sources of
contamination and will be used to identify constituents of concern (COCs) that might be present
in Cashiers Lake sediment. Phase 11 will involve the collection of sediment samples within
Cashiers Lake. Sediment samples collected in Cashiers Lake will be analyzed for only COCs.
This approach is supported by the Inland Testing Manual. Specifically, "Subpart G of the 404(b)(1)
guidelines requires the use of available information to make a preliminary determination
concerning the need for testing of the material proposed for dredging." Further, "knowledge of the
proposed dredging site proximity to other sources of contamination as well as that gained from
previous testing, may be utilized to conclude that there is no reason to believe that contaminants
are present" (EPA 1998)
As such, Phase I of this assessment includes the collection of sediment samples proximate and
downgradient of the Consolidated Metco Site, in locations that are most likely to contain sorbed
contaminants from historical permitted or illicit discharge from the Consolidated Metco facility. If
Consolidated Metco is a source of contaminants to sediment in Cashiers Lake, the concentrations
of these contaminants will be more elevated in source area sediments. These samples will also
be representative of accumulated sediment from upgradient, urban stormwater runoff. The
purpose of the Phase I samples is to meet the requirements of the Inland Testing Manual and to
identify COCs that may be present in Cashiers Lake sediment.
A summary existing information regarding contaminants of concern as -well -as proposed Phase I
and 11 assessment is included in the following subsections.
2.1 Initial Contaminants of Concern Review
Headwater has reviewed existing environmental data for the former Consolidated Metco facility,
located upstream of the Site, general contaminant information associated with the plastics
industry, as well as sediment sampling previously performed in Cashiers Lake by Headwater in
order to perform a preliminary review of COCs.
2.1.1 Consolidated Metco Facility
Soil, sediment, and groundwater evaluation at the Consolidated Metco facility consisted primarily
of analysis of Volatile Organic Compounds (VOCs) by EPA Method 8260 and Semi -Volatile
Headwater Geology 5

Cashiers Lake —Pre -Dredging Assessment Plan
Organic Compounds (SVOCs) by EPA Method 8270 as "screening level analysis" such as Oil and
Grease by Method 9071, Diesel Range Organics (DRO) by Method CA-LUFT and Gasoline
Range Organics (GRO) by Method CA-LUFT.
Multiple VOCs, SVOCs, were detected in soil at concentrations exceeding the DEQ-Solid Waste
Section, Underground Storage Tank (UST) Section Soil -to -Groundwater Maximum Soil
Contaminant Concentration Levels (MSCCs). Several samples contained Oil and Grease, DRO,
and GRO exceeding screening levels. However, a screening level for Oil and Grease is no longer
used by the UST Section or other DEQ divisions. DRO and GRO are considered to be screening
level analysis, where an exceedance indicates that the sample should also be analyzed for risk -
based constituents which include VOCs, SVOCs, and other petroleum fraction analyses,
depending on what the source of the release was.
2.1.2 Plastics Industry Information
According to Table 4-1 of the Inland Testing Manual, the plastics industry is associated with
sediment impacts from acenaphthene and lead (EPA 1998). Acenaphthene is included in the
Method 8270 SVOC analysis and lead is included in the 6010 RCRA metals analysis. Neither of
these compounds were detected in the Cashiers Lake sediment samples collected in 2018 (see
Section 2.1.3.
2.1.3 Cashiers Lake Sediment Sampling
Headwater performed a sediment assessment in Cashiers Lake as documented in the 2018 Pre -
Dredge Environmental Review. This assessment involved the collection of sediment samples for
analysis of VOCs, SVOCs, and RCRA metals.
The results of this assessment did not find any constituents in excess of the Preliminary Soil
Remediation Goals (PSRG). SVOCs were not detected above laboratory reporting limits. Only
two VOCs, toluene and p-isopropyltoluene were detected above the laboratory reporting limits.
Toluene was detected at a concentration of 0.0371 milligrams per kilogram (mg/kg) in only one
sample, which is below the most conservative PSRG, the Protection of Groundwater PSRG of
8.3 mg/kg. P-isopropyltoluene was detected at a concentration of 0.155 mg/kg, also below the
Protection of Groundwater PSRG of 1.24 mg/kg.
2.1.4 Initial Contaminants of Concern Summary
Based on this review, the constituents detected on the Consolidated Metco facility have not
migrated to sediment in Cashiers Lake in appreciable quantities. However, in order to meet the
requirements of the DEQ's Request for Additional Information, additional assessment is
necessary to further identify COCs.
Headwater Geology 6

Cashiers Lake —Pre -Dredging Assessment Plan
2.2 Phase I: Sediment Sampling—Chattooga River
In order to identify COCs associated with potential sources of contamination, Headwater will
collect composite sediment samples adjacent to and downstream of the now -closed -incident
associated with the former Consolidated Metco facility; located approximate 0.25-miles to the
northwest of the Site, but hydrologically connected to the Site via the Chattooga River.
Headwater will collect three composite sediment samples within the footprint of the Chattooga
River's high-water mark. One sample will be collected adjacent to former Consolidated Metco
Outfall 002 and a second sample from locations adjacent to Outfall 003 (See Figure 2 of B&G's
report in Appendix A for Outfall locations). A third sample will be collected from a downstream
location, directly upstream of Cashiers Lake. See Figure 2 for proposed sample locations.
Composite samples will be collected using a stainless -steel hand auger and will be composed of
4 aliquots of sediment collected from multiple locations within each sample area. The samples
collected near outfalls will be collected primarily from the western bank of the river, which is where
potential impacted media from Consolidated Metco is expected to accumulate. Sample aliquots
will be generally collected from 0.25 to 2 feet below ground surface and locations will be targeted
to contain primarily fine-grained material such as silt and clay with organic content, which is more
likely to sorb contaminants.
2.3 Sample Analyses
Based on an October 28, 2019 Request for Additional Information, the DEQ is requesting that
pre -dredge assessment activities include analysis for all constituents listed in 40 CFR EPA
Appendix II Part 258 - List of Hazardous Inorganic and Organic Constituents (Appendix II).
Therefore, Phase I sediment samples will be analyzed for:
• VOCs by EPA Method 8260
• SVOCs by EPA Method 8270
• Pesticides/Poly-Chlorinated Bisphenols (PCBs) by EPA Method 8081/8082
• Herbicides by EPA Method 8151
• Organophosphorus Pesticides by EPA Method 8141
• Cyanide by Standard Method 4500
• Sulfide by Standard Method 4500
• RCRA Metals by EPA Method 6010C and 7471
2.4 Identification of Constituents of Concern
Headwater will review the results of the Phase I sediment sampling and compare the results to
the PSRGs in order to identify COCs for further analysis. Site COCs will be defined as any
constituent with a concentration detected in any of the three Phase I sediment samples that
exceeds the lowest of the PSRGs.
Headwater Geology 7

Cashiers Lake —Pre -Dredging Assessment Plan
2.5 Phase II: Sediment Sampling —Cashiers Lake
Following identification of COCs, up to 10 composite sediment samples will be collected from
Cashiers Lake. Each composite sample will be composed of 4 aliquots of sediment. Sample
aliquots will be collected using a piston core sampler and will be collected from sediment surface
to a depth of 2 to 3 feet below sediment surface. The aliquots will be mixed and composited into
samples for laboratory analysis. Sample locations will be evenly distributed within the proposed
dredging area shown on Figure 2.
The sediment samples will be transferred to laboratory supplied sample containers and placed in
a cooler on ice. The sample cooler will be delivered to a North Carolina -certified laboratory under
chain -of -custody protocol. Sediment samples will only be analyzed for Site COCs, which may
include the following analyses:
• VOCs by EPA Method 8260
• SVOCs by EPA Method 8270
• Pesticides/Poly-Chlorinated Bisphenols (PCBs) by EPA Method 8081/8082
• Herbicides by EPA Method 8151
• Organophosphorus Pesticides by EPA Method 8141
• Cyanide by Standard Method 4500
• Sulfide by Standard Method 4500
• RCRA Metals by EPA Method 6010C and 7471
2.6 Summary Report
Following completion of assessment activities, a summary report will be prepared. The report will
include field observations, tabulated sample analytical results compared to applicable standards,
a map showing the location of sample locations, a copy of the laboratory analytical report. If COCs
are present in sediment in excess of Health -Based PSRGs, Headwater will provide recommended
procedures for impacted sediment management and will work with the DEQ-DWR to identify
acceptable dredging and disposal methodology.
Headwater Geology 8

Cashiers Lake —Pre -Dredging Assessment Plan
3 References
DEQ (North Carolina Department of Environmental Quality) 2012. North Carolina Department of
Environment and Natural Resources Guidelines for the Closure of Treatment Ponds and
Lagoons. June 22, 2012.
Headwater 2018. Pre -Dredge Environmental Review. December 14
USEPA 1998. Evaluation of Dredged Material Proposed for Discharge to Waters of the U.S —
Testing Manual (Inland Testing Manual). February
Division of Waste Management Site Locator Tool. Incident #88035. Accessed between
November 25 and 26, 2019.
Headwater Geology

FIGURES

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SOURCE FIGURE 1
Headwater USGS SITE LOCATION MAP
./ ENV I RON MENTAL I N c. 7.5-minute Topographic Quadrangles Cashiers Canoe Club
Cashiers, North Carolina (1997) Cashiers, Jackson County
Date: 11/25/2019 Contour Interval = 40 feet North Carolina
Headwater Project # A19-158
1 inch = 2,000 feet
Prepared by: NJC �!

I -f#
Legend
Proposed dredging area
Former Metco plant location
Surface waters
♦ Phase I sampling location
Note: This is not a survey. All locations are approxime
Headwater
ENVIRONMENTAL INC.
Date: 11 /25/2019
Prepared by: NJC
I� -'YAK-.•: •'' - _- -_
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Cashiers Lake
SOURCE
NC One Map
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ArcGIS Online
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County, North Carolina
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0 250 500 1,000
FIGURE 2
SAMPLE LOCATION MAP
Cashiers Canoe Club
Cashiers, Jackson County
North Carolina
Headwater Project # A19-158

APPENDICES

M M r M r r r Ml M w M M M M M M a
U
V
E
TABLE V ConMet Cashiers
January 15 - 16, 2007 Sampling Event Results Summary
BORING
PARAMETER
SR-A-8
HZ-1
HZ-2
DS-1
DS-3
P-1
P-3
P-5
CR-1
CR-2
CR-3
1J0-1
MR-1
MR-2
MR-3
SD
PRlil,
BG
SED
Sail -to -Groundwater
Acetone
0.037
0.0052
0.012
1.6
0.58
0.062
0-27
0.16
$
2.81
m, -){ lenes
0.0022J
450E
O.057
5
Toluene
0,0012
0.0016
7
Bis(2-eth ihex ) ph,IlAate
0.77
0.46
1 .2J
7.1 R-05
0.86
0.81
30
58
15
35*'
1.2,4-Trimeth lbenzene
30
O,0075
8
1,3,5-Tdmoth 1benzene
15
0.005
7
2-13utanone
1.81
0.0017J
0.0045J
0.017
0.69
4-Isopropyltoluene
4.9
0,0023
-
Ethylbenzene
19
0,02
0-24
lsopropylbenzene
3.2
0-00092J
2
Naphthalene
4.0i2.6 R-05
0.0015
0.58
n-ButylBenzene
2.5
4
n-Propyl Benzene
1.2
2
o-Xylene
89
0,0083
5
soc-Bu (benzene
0.831
3
1 -Me t hylnaphthalene
5.4 R-05
--
2-Meth Ina hthalene
8.3 R-05
3
Oil & Grease
52,900
387
8820
ND
2300
2740
175
1 ND
1220
250*
DRO (C10 - C24)
739
41.1
256
4.21
52.1
440
40.3
106
901
40*
GRO C6 - C10
ND
NDJ
ND
ND
ND
2.49J
18.0
6 74J
ND
10'
Butylbenzylphthalate
0.0811
0-191
2400"
Phenol
0.58
0.79J
3600**
* Action Level of the Groundwater Section
" Remcdiation Goal of the Inactive Hazardous Sites Branch
E - Estimated
J - estimated
R-05: Sample was diluted resulting in elevated reporting limits
Shaded cells are above Cleanup Standard

1
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