20191748 Ver 1_More Info Received_20200121

Providing Sound Environmental Solutions
10565 Highway 421 South
Trade, TN 37691
ph/fax: [phone]
[e-mail]
January 21, 2020
Division of Water Resources
Department of Environmental Quality
Winston-Salem Regional Office
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
RE: REQUEST FOR ADDITIONAL INFORMATION
Twin Rivers Community Structure Repair
Ms. Park,
Enclosed please find the responses to your letter requesting additional information dated
January 17th 2020. Brushy Fork Environmental Consulting, Inc. will continue to be the authorized
agent for this permit application. If you have further questions please give me a call at
423.727.4476.
Sincerely,
Digitally signed by
Sj�,l,d f� 1J Josselyn Lucas
C,1WMV Date:2020.01.21
16:23:01-05'00'
Josselyn Lucas
cc: Ms. Sue Homewood

Response to DEQ Request for Additional Information
1) Please provide an analysis of the material used to repair the bank stabilization
structure along the 70 linear foot reach of the Watauga River to ensure that it meets the
following requirements of the Water Quality General Certification Number 4134:
a. Per Section II Item 18 "Any rip -rap used for stream or shoreline stabilization shall be
of a size and density to prevent movement by wave, current action, or stream flows and
shall consist of clean rock or masonry material free of debris or toxic pollutants. Rip -rap
shall not be installed in the streambed except in specific areas required for velocity
control and to ensure structural integrity of bank stabilization measures. [15A NCAC 02h
.0506(b)(2)1."
The Notice of Violation was issued to the Twin Rivers Community on 11/13/2019. In
Response, BFEC visited the violation site on 11/21/19, 12/09/19, and 12/21/19. The
purpose of the visits was to assess the 70-foot restoration and the surrounding
damage to the side channel of the Watauga River caused by construction access to the
project site. BFEC gave recommendations on how to repair the streambank damage to
the side channel and implement proper erosion control at the site. After inspecting
the site BFEC concluded that the 70 foot repair which was implemented is sound;
however temporary. The large boulders used on the toe of the bank were clean,
restoration -grade stone. As far as BFEC understands, this stone was existing material
from a previous natural channel design structure (Toe Rock) which had blown -out in
the last several years due to high flows and improper structure placement and poor
footer and sill construction. In our professional opinion, we believe the temporary
repair should remain in place until the completion of the current flood study and
design of the larger encompassing project (Phase II; to be permitted separately). Once
the permitting for Phase II of the project is submitted to the proper authorities and
has been approved, it will be up to Twin Rivers to hire a qualified contractor to
perform the restoration work. At that point, this 70 foot temporary repair should be
replaced with an engineered natural channel design which has been modeled at the
100 year flood stage (Base Flood Elevation) which will ensure stability and sound
construction using properly sized materials which meet the requirements of the Water
Quality General Certification Number 4123: a. Per Section II Item 18 "Any rip -rap used
for stream or shoreline stabilization shall be of a size and density to prevent
movement by wave, current action, or stream flows and shall consist of clean rock or
masonry material free of debris or toxic pollutants. Rip -rap shall not be installed in the
streambed except in specific areas required for velocity control and to ensure
structural integrity of bank stabilization measures. [15A NCAC 02h .0506(b)(2)].".
2) Please clarify that the structure repair of the 70 linear foot reach of the Watauga
River is the area that was identified in the violation letter dated November 13, 2019
(NOV-2019-PC-0726) from the Division.

The 70 linear foot reach of the Watauga River referenced in the PCN is the same area
which was identified by Kelli Park and Mike Turner of the Division of Water Resources
in the violation letter dated November 13, 2019.
3) Please clarify if restoration work on the side channel of the Watauga River has been
completed.
As stated in NOV-2019-PC-0726, a small side channel running parallel to the Watauga
River was impacted by heavy machinery which was driven through it for access to the
Watauga River Streambank. BFEC visited the site on 11/21/19 and recommended
smoothing out the banks and installing coconut coir matting, seed, and straw, as well
as livestaking the impacted area(s). The Twin Rivers representative present at that
time was grounds manager, Joe Sanders. BFEC instructed Joe to trench in all coconut
coir matting; seed, straw, and livestake the impacted areas. When BFEC visited the
site on 12/21/19 the area had been repaired as instructed and grass was slowly
beginning to establish cover, however, due to the fact that this was during the
dormant season, the grass was not coming up as quickly or readily as it would during
the growing season.
4) A site visit will be scheduled to document the current stability of the violation areas
prior to issuance of a 401 Water Quality Certification.
BFEC has scheduled a site visit with DEQ for January 27th, 2020 at 11:00 am to review
repairs and answer questions.