20191577 Ver 1_More Info Email 2 1-6-20_20200106

Moore, Andrew W
From: Clement Riddle <[e-mail]>
Sent: Monday, January 6, 2020 12:17 PM
To: Moore, Andrew W; Anna Priest
Subject: [External] RE: Request for Additional Information, Project Ranger, Buncombe County
(DWR Project #20191577)
Attachments: 303_Biltmore Farms -Delineation Map -Updated 7.7.16_ReducedSizePDF.pdf; Permit
Drawing_Biltmore French Broad Bridge 5A 12.30.19.pdf, 1-6-20 Impact Map 5-0 Project
Ranger.pdf
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Andrew,
We are submitting this email response to NC Division of Water Resources comments dated December 13, 2019 for
project Ranger. In addition to our responses below, there have been several changes to the bridge design which more
than doubles the length of the center span over the river as well as reduce the overall permanent impact and duration
of the temporary impacts.
The proposed bridge design has changed from approximately 550 feet long with five concrete spans of 110 ft and three
bents in the river to an approximately 610 foot long continuous steel girder type bridge with a center span of 240 feet
and two bents in the river (see attached revised permit Figures 5.0 and 5A). For an estimated 12 month period,
temporary rock causeway footprints will extend 114 ft in the direction of flow and 80 ft and 70 ft out in the river from
the west and east banks, respectively, such that less than 50% of the river is blocked at one time. The centermost,
approx. 100 ft, of this girder span will be installed last. In order for cranes to reach out and hang this last 100 ft steel
beam, both temporary rock causeways will have to be extended an additional 24 ft downstream and an additional 40 ft
out into the river for a short period of time estimated at 1 month. This will result in an additional 0.327-acre temporary
impact. Temporary disturbance in the French Broad River for both Phases of the temporary causeways is expected to be
reduced from an estimated 19 months to an estimated 12 months. As a result, the proposed jurisdictional impacts are
now:
• Impact S1- 25 If. of stream impact in the French Broad River for the bridge footings, 5 piers per bent and piers
are 5 foot diameter. Total of 10 piers for the bridge. Piers are 20 sq. ft per pier and total 0.005 ac of impact
• Impact S2 - The temporary causeways impact will have two phases. Phase 1 of the temporary causeway will
include 114 If. of stream impact and the causeway size is reduced to 0.170 acre each (east and west causeway
). Phase 1 impact is approximately 0.34 acre. Phase 1 impacts are expected to remain for approximately
12months. Phase 2 temporary causeway impact will increase each causeway for approximately 1 month to 138
If. of stream impact and the causeway size will increase by an additional 0.166 ac (west) and 0.161 acre
(east). Total Phase 2 impacts are approximately 0.327 ac.
• Impacts S3 -114 linear feet of permanent stream impact (0.031 ac) for bank stabilization on each side of the
French Broad River which will consist of class II riprap (24-inch thick) keyed into the riverbank
• Impact S4 - wetland W1- 0.067 acres of wetland impact (2,898 sq. ft).
Reduction in Tree -clearing, Limits of Disturbance and Excavation
There will be approximately 80.0 of tree clearing for Project Ranger. An additional 3.0 acres will be graded
within the limits of disturbance that are not forested.

The changes in the bridge design will result in further reduction of tree clearing at the bridge location. Tree -
clearing in the vicinity of the bridge will total approximately 3.0 ac to accommodate excavation and bridge
construction. On the west side of the river, clearing will be reduced from approximately 500 to 270 linear feet
along river or from 1.7 to 1.3 acres. On the east side of the river, clearing will be reduced from approximately
400 to 260 linear feet along river or from 2.0 to 1.7 acres. Not including the bridge construction site, tree -clearing
limits will extend no closer than 400 ft. from the French Broad River for the manufacturing facility. On the west
bank of the river, there is currently a gap in the canopy that spans approximately 200 ft., located south of the
proposed bridge at Bent Creek River Park. A 230-ft. (approximate) canopy gap occurs on the east side of the river
where transmission lines cut across, with a corresponding gap of 270 ft. on the west side. The remaining
riverbanks are forested within the Action Area. Design revisions will also reduce excavation in the vicinity of
the bridge from 3.7 to 0.6 acres.
From: Moore, Andrew W <[e-mail]>
Sent: Friday, December 13, 2019 9:37 AM
To: Clement Riddle <[e-mail]>
Cc: Fuemmeler, Amanda J CIV (US) <[e-mail]>; Leslie, Andrea J <[e-mail]>
Subject: Request for Additional Information, Project Ranger, Buncombe County (DWR Project #20191577)
Clement,
On November 14, 2019, the Division of Water Resources (Division) received your application requesting a 401 Water
Quality Certification from the Division for the subject project. The Division has determined that your application is
incomplete and cannot be processed. The application is on hold until the following items are addressed:
1. Please provide the Division a copy of your response to the December 4, 2019 comment email from the U.S. Army
Corps of Engineers. [15A NCAC 02H .0506(b)]
ClearWater will send a copy to the Division of the applicants response to the US Army Corps comments.
2. Please provide the Division a copy of the approved jurisdictional determination map for the 445-acre parcel. (15A
NCAC 02H .0502(a)(9)]
Attached is a copy of the Approved Jurisdictional Determination map verified by the Corps of Engineers
on October 20, 2016.
3. Please provide additional details regarding how in -stream work, particularly the drilled piers for the bridge and
the investigative drilling, will be conducted so that the flowing stream does not come in contact with the
disturbed area as required in Condition 11.9 of General Water Quality Certifications 4132 and 4135. [15A NCAC
02H .0506(b)(3)]
• Investigative drilling - Investigative drilling for the bridge footings will require roughly two 6-inch diameter
borings for each bent to be placed in the water. A maximum of four investigative borings will take place in
the riverbed for two bents in the water. The drill cores will be retrieved and removed from the river and
analyzed in laboratory. Sediment disturbed during investigative drilling will be substantially contained with
a steel casing. Any sediment coming in contact with river water during this process will be negligible and
considered to be de minimis.
• Piers - Drilling (for the 5 ft diameter drilled shafts) will be performed within an oversized (larger than 5 ft
diameter) temporary steel casing. The top of the temporary steel casing will be at or above the top
elevation of the temporary causeway. The bottom of the temporary steel casing will begin several feet
below the streambed and proceed to fall farther below the streambed as drilling proceeds down. This
temporary steel casing will prevent flowing river water from coming in to contact with areas disturbed by

drilling. The drilling fluid will be a mixture of bentonite (a natural, inert clay material) and river water which
is recycled. Any sediment or drilling fluid removed from the shaft will be pumped through a hose (typically
approx. 4 inch diameter) to an upland disposal area at least 30 feet from the edge of the river and treated
through a stilling basin or silt bag. The type of pump used is typically propelled by an air compressor
mounted on the drill rig. Once drilling is complete, the shaft will be pumped clean and dry. Reinforced
concrete will then be installed inside the casing. The casing will also prevent flowing river water from
coming in to contact with fresh uncured concrete. The temporary steel casing will not be removed until
after concrete is cured.
4. Please explain why the gravel road access from the south cannot be improved to provide suitable access to
support the proposed industrial development. (15A NCAC 02H .0506(b)(1) and (2)]
The gravel access road connects to Schenk Parkway and runs under Interstate 26 and generally follows the edge
of the French Broad River until it crosses under the Blue Ridge Parkway and enters the Project Ranger site. The
existing gravel road is approximately 10-14 ft wide and runs parallel to a 36 inch diameter and a 24 inch
diameter MSD interceptor lines.
A. The gravel road is within the FEMA floodway and prone to standing water or localized flooding in heavy
rain events. The entire road would need to be raised 2 feet above the base flood elevation which would
be expected to cause flooding at upstream properties and insurable structures.
B. In addition, it is bounded in numerous (12) locations by streams and/or wetlands that would be
impacted by widening the roadway for permanent access. As a result permanent impacts to streams
and wetlands would be greater than are currently proposed.
C. The existing right-of-way for Biltmore Farms under the Blue Ridge Parkway Bridge is a limited narrow -
width right-of-way (ROW) 14 ft. and is not of sufficient width to provide a permanent, public road
right-of-way or suitable emergency access.
5. Has an analysis been conducted to confirm that the proposed causeway material will remain immobile during
anticipated high flows of the river? If so, provide documentation of the analysis. If not, please provide
documentation that demonstrates that the causeway material will not move during storm events resulting in
unauthorized impacts. (15A NCAC 02H .0501 and .0502]
Yes, an analysis has been conducted to evaluate the stability of the proposed temporary causeway material. As
shown on the Permit Drawing, causeway material will consist of NCDOT Class II Rip Rap or larger (if a cap layer is
used, it will consist of Class B or larger). Class II has a median diameter of 14 inches and is big as 23
inches. Channel velocity and shear stress have been analyzed for both existing and proposed conditions as well
as temporary conditions while causeways are in place under both normal (2050 cfs) and high (100yr, 50000 cfs)
flow conditions with results shown below.
Channel Velocities (feet/second)
Distance
upstream of
Normal Discharge 100-YR Flood Event Discharge
proposed
Proposed
12 Month
1 Month
Proposed
12 Month
1 Month
crossing (miles)
Existing
Existing
Permanent
Causeway
Causeway
Permanent
Causeway
Causeway
-0.32
2.1
2.1
2.1
2.1
5.7
5.7
5.7
5.7
-0.15
3.2
1 3.2
3.2
3.2
10.0
10.0
10.0
10.0
-0.03
2.0
2.0
2.0
2.0
6.1
6.1
6.1
6.1
Bridge
2.0
2.0
2.0
2.3
5.9
6.1
6.1
6.3
Causeway
N/A
2.1
3.2
5.7
N/A
6.1
6.5
6.9

Causeway
N/A
2.1
3.1
4.2
N/A
6.1
6.6
6.9
Bridge
2.4
2.4
2.2
2.0
6.0
6.2
6.2
6.3
0.10
1.9
1.9
1.8
1.6
6.3
6.3
6.3
6.3
0.16
2.7
2.7
2.6
2.2
6.9
6.9
6.8
6.8
Parkway Bridge
3.3
3.3
3.2
2.9
8.1
8.1
8.1
8.0
Parkway Bridge
3.2
3.2
3.1
2.8
8.1
8.1
8.1
8.0
0.19
3.2
3.2
3.1
2.9
9.0
9.0
9.0
8.9
0.33
2.3
2.3
2.3
2.3
7.2
7.2
7.2
7.1
0.53
2.8
2.8
2.8
2.8
7.5
7.4
7.4
7.4
0.74
1.6
1.6
1.6
1.6
5.2
5.2
5.2
5.1
0.82
6.2
6.2
6.2
6.2
8.0
8.0
7.9
7.9
1.18
2.2
2.2
2.2
2.2
9.9
9.9
9.9
9.8
2.28
2.6
2.6
2.6
2.6
7.3
7.3
7.3
7.3
Min:
1.6
1.6
1.6
1.6
5.2
5.2
5.2
5.1
Max:
6.2
6.2
6.2
6.2
9.9
9.9
9.9
9.9
As shown, estimated existing channel velocities under normal flow typically range from 2 to 6 ft/s for this
portion of the river. Under high flow, typically 6 to 9 ft/s. Results indicate a negligible increase in velocity from
existing to proposed permanent conditions for both normal and high flows. Results also indicate negligible
increases for both causeway phases under high flow as well as the normal flow for the primary (12 month
duration) causeway. The most notable increase is seen for the normal flow, short term (1 month) causeway
phase with estimated velocities to increase from 2.1 to at most 5.7 ft/s. Class I Rip Rap (smaller than Class 11) is
commonly used to line channels with design velocities in excess of 10 ft/s; therefore, the Class 11 as proposed is
expected to remain in place.
• Maximum shear stress values were also computed for each causeway phase under both normal and high
flows. These values ranged from 0.4 to 1.8 psf. By comparison, maximum permissible shear stress for Class II &
Class B is 4.8 and 3.2 psf, respectively; therefore, the material as proposed is expected to remain in place.
Based on this analysis and in TGS engineering judgment, the proposed causeway material is anticipated to
remain immobile during possible high flow events in the French Broad River.
Pursuant to Title 15A NCAC 02H .0502(c), the applicant shall furnish all of the above requested information for the
proper consideration of the application. If all of the requested information is not received, the Division will be unable to
approve the application and it will be returned.
Feel free to contact me if you have any questions or would like to discuss further.
Andrew W. Moore, PG
Environmental Specialist - Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ - Division of Water Resources
828 296 4684 office
email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778

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