20191577 Ver 1_More Info Received_20200422

Strickland, Bev
From: Clement Riddle <[e-mail]>
Sent: Wednesday, April 22, 2020 2:09 PM
To: Fuemmeler, Amanda J CIV (US)
Cc: Homewood, Sue; Moore, Andrew W
Subject: [External] RE: Ranger - 2019-01867
Attachments: Frac 4.1.20.docx
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Amanda,
Attached is the most recent version of the Frac out Plan. Please let me know if you have any questions about this or
anything else.
Clement
From: Fuemmeler, Amanda J CIV (US) <[e-mail]>
Sent: Wednesday, April 22, 2020 1:18 PM
To: Clement Riddle <[e-mail]>
Cc: Sue Homewood ([e-mail]) <[e-mail]>; Moore, Andrew W
<[e-mail]>
Subject: RE: Ranger - 2019-01867
Thanks Clement.
In response to #1 below, please submit a plan that addresses how any accidental frack out will be contained/cleaned up
during the drilling.
As an update, I just emailed the finalized MCA for signature to Renee with SHPO which they have 30 days to
review/sign. I sent an email to Byron asking on the status of the BA/BO..never heard anything.
And just curious on DWR's end if there were any comments received to their Public Notice/comment period and if those
were going to be made available?
Amanda
828-271-7980 ext. 4225
From: Clement Riddle <[e-mail]>
Sent: Thursday, March 26, 2020 5:06 PM
To: Fuemmeler, Amanda J CIV (US) <[e-mail]>
Cc: Sue Homewood ([e-mail]) <[e-mail]>; Moore, Andrew W
<[e-mail]>
Subject: [Non-DoD Source] Ranger - 2019-01867

Amanda,
Please see below and the attached for the requested additional information. Should you have any additional questions,
please do not hesitate to contact me.
Thank you,
Clement
From: Fuemmeler, Amanda J CIV (US) <[e-mail]>
Sent: Monday, March 16, 2020 11:37 AM
To: Clement Riddle <[e-mail]>; Homewood, Sue <[e-mail]>
Cc: Jones, M Scott (Scott) CIV USARMY CESAW (USA) <[e-mail]>; Lee Thomason
<[e-mail]>; Hamstead, Byron <byron [e-mail]>
Subject: RE: [Non-DoD Source] FW: Ranger update: USACE Action ID 2019-01867 - DWR Project NO.20191577
Clement,
Thanks for the update and wanted to respond with some additional items based on my site visit, your response and
previous meetings/discussions along with an update on some other coordination issues:
1. 1 concur with Sue's comment so please copy me as well: "Will you please provide a plan sheet that shows where
the HDD drilling pads and drilling mud containment areas will be. The Division will likely request additional
information regarding the construction details for the HDD activities but for now if we can just have an updated
plan showing the location that will help". (ClearWater) Please see attached new Figure 5.1.
2. Regarding the 25-foot buffer/protective fencing on undisturbed wetlands/streams: Thanks for getting that
going as it will be a condition of our permit. Can this be extended to the five archeological sites referenced in
Renee's January 14, 2020 letter? (ClearWater) Yes, protective fencing around Cultural resource areas has
already been installed at sites 82 and 85. Fencing will be added at the remaining three locations before work
begins near those portions of the site.
3. Regarding the Substation and revised building pad boundaries, coordination with Renee/SHPO will need to
happen to make sure nothing has changed with regards to effects to listed historic properties. I'm assuming not
but please provide a separate email to me covering these changes in relation to surveyed archaeological sites
and historic structures so I can coordinate accordingly with their office. The location for the HDD footprint needs
to be included as well if it outside previous project boundaries. (ClearWater) A separate email was sent to you
on March 17, 2020 regarding the status of additional review. The completed addendum was emailed to you on
March 26, 2020.
4. The Draft River Safety Plan (provided in 01/06/20 email): Please verify if there are any missing outfitters. We
discussed the company next to Carrier Park and another potential company off Riverside Drive in Woodfin that
needs to be included. Please see the revised River Safety Plan. (ClearWater) We have added two additional
outfitters to the River Safety Plan. We are not aware of anyone else at this time but are continuing to review
and will update this as necessary.
5. Additional information on minimization at bridge location (i.e. three lane versus five lane bridge): Please
quantify the difference in impacts for a 3 versus 5 lane bridge, clarification on what future uses may be
supported by a five lane bridge, and if DOT is requiring the pedestrian/sidewalk portion.

(ClearWater) The raised center median of the currently proposed bridge (wide enough for five lane) is located
such that it aligns with the existing intersection of NC 191(Brevard Rd) and the Blue Ridge Parkway Access Road
and does not require relocation of this intersection. Relocation of this intersection is not considered feasible for
this project as doing so would have major constraints including National Park Service land, steep topography in
the northwest quadrant and Bent Creek passing just south. Relocating this intersection would require
realignment of the Blue Ridge Parkway Access Road which would also likely require extension or relocation of
existing culverts over Bent Creek.
If a narrower three -lane bridge were constructed initially, it is anticipated the raised median would be
constructed in the same location as the current proposed median (in order to line up with the existing
intersection as noted above). If an additional 12-foot lane was added in each direction for future bridge
widening, it is expected that 12 feet would have to be added to each bridge face as opposed to adding 24 feet to
one side due to the insufficient distance (approximately 150 feet) between NC 191 and the start of the bridge
for traffic to shift 12 feet over.
If the bridge was built in two phases, the total footprint of temporary causeway impacts for both phases
combined (this includes both the 12 month and 3 month portions of the causeways) would exceed that of the
current proposed five -lane bridge. This is primarily due to the temporary causeways being required to extend
both up and downstream of the bridge footprint during the future expansion, whereas the causeways are only
required to extend downstream of the current proposed bridge. (e.g. Current bridge temporary impacts allow
for workpads to extend 25 feet downstream of the downstream bridge face as large cranes will sit on these pads
to hang the steel girders. Impacts extend an additional 9 feet downstream to account for side slope down to
river bottom. For the future expansion, cranes would not be able to reach over the original bridge to hang
girders on the opposite sides, so workpads would be required to extend these same distances both up and
downstream of each respective bridge face.) Estimated total temporary causeway impacts for a three -lane
bridge and the future widening are 0.55 and 0.58 acres, respectively. This gives a total of 1.13 acres with 0.33
acres of this being overlap between the two phases leaving a total of 0.80 acres of temporary causeway
footprint when not double counting the overlap. By comparison, total temporary causeway impacts for the
current five -lane bridge are 0.67 acres
If the bridge was built in two phases, total permanent stream impacts for both phases would be expected to
roughly match the corresponding permanent impacts for the current proposed five -lane bridge. Estimated total
permanent bank stabilization impacts for a three -lane bridge and the future widening are estimated at 88 LF
(0.024 acres) and 26 LF (0.007 acres), respectively. This gives a total of 114 LF (0.031 acres) which matches the
current five -lane bank stabilization impacts. A three -lane bridge would be expected to have four piers per bent
with two bents giving a total of 0.004 acres. The expansion would likely add an additional pier to each end of
each bent giving an additional 0.002 acres. This total nearly matches the estimated total permanent drilled pier
stream impacts of 0.005 acres for the current five -lane bridge.
The bridge and road will incorporate elements of multi -modal transportation and NCDOT Complete Streets
design criteria to facilitate turning over maintenance of the bridge to NCDOT. If additional lanes are required in
the future, the striping on the bridge could be changed to accommodate these lanes. The bridge is being
proposed because as discussed above and in the PCN submittal there are financial and environmental benefits
to undertaking construction of this bridge all at one time, even if additional lanes are not needed for years or
decades.
Update on Coordination/Status of Application:
Section 106 NHP — see above request (#3) but have forwarded a draft copy of the MOA to our legal counsel for
review/comment that proposes a data recovery plan to mitigate the adverse effects on the only eligible site
(archeological site on west bank of River in bridge footprint). MOA will need to be finalized before can issue our
permit.

Section 7 ESA— Currently waiting on finalized Biological Assessment and then Biological Opinion to be issued before
can issue our permit.
Section 401— Unfortunately the public hearing has been canceled but it appears written comments will be accepted
until April 20t". Please note that we will likely not wait on the issuance of the 401 to issue the 404/10 permit as long
as I have everything I need on my end.
USFS-Bent Creek Experimental Station — we had a request from the archaeologist to review the application and
survey/reports which I have forwarded but haven't received any comment back on yet.
Let me know if you have any questions, thanks!
Amanda
828-271-7980 ext. 4225
CLear\NaLer
32 Clayton Street
Asheville, NC 28801
Office: 828-698-9800
Mobile: [phone]
clement(cDcwenv.com
B1ockedWWW.CWENV.00M
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Frac-out Contingency Plan
All project personnel are responsible to report any indication of an inadvertent return or an
observed inadvertent return. If either of these conditions are reported and confirmed, operations
are to immediately cease and not to resume until cleanup procedures are complete and
appropriate agencies have been notified.
Containment and removal of drilling fluid releases to the surface from an inadvertent release of
drilling fluids will be performed where practical and where there will be a net benefit in the
reduction of total environmental impacts.
Process of Mitigation
Before the drilling occurs:
1. Notification will be sent out to Biltmore Farms upon completion of each drill and starting
date for the next drill. Biltmore Farms will then notify the Army Corps of
Engineers, the Division of Water Resources, and US Fish and Wildlife Service.
2. Silt fence will be installed around perimeter of the drill location.
3. The Contractor will hold meetings with workers involved to explain how to handle a fluid
loss situation.
In the event of a fluid loss the contractor will visually check the surface to determine location and
handle accordingly:
Underwater
a) A monitor will be on site at all times during drilling to continuously search visually for
observable frac-outs. The HDD operator will continuously monitor the pressure readings
on the machine. A loss in pressure will indicate a loss in fluid; however, that does not
specifically mean the material is being released into the stream.
• The Bore -Gel (a mixture of bentonite and water) may congeal the frac-out, which
means that it will harden in the fractures of the rock and prevent the material from
reaching the surface water.
• If pressure loss is observed, we will stop the operation temporarily and monitor to
see if Bore -Gel hardens and plugs the leak.
b) If/when a fluid loss is observed the contractor will temporarily suspend the drill and add a
polymer to help seal the fracture.
c) Upon the stoppage of the fluid loss the contractor will pump out the containment area to
the best of our ability and take back to the recycler.
2. On Ground
a) A monitor will be on site at all times during drilling to continuously search visually for
observable frac-outs and the HDD contractor will continuously monitor pressure
readings.
b) Immediately install silt fence around area of fluid loss to contain and then start pumping
the bore -gel back to machine.
c) Remove deposited Bore -Gel offsite (if any).
d) Regrade areas of Bore -Gel deposition to original slope and contour.
e) Reseed impacted area.

Any material that can be safely and can be cleaned up via vac truck will be done so. A vac truck
will be on -site in event to help minimize a release and assist in containment.
An alternative approach if a frac-out occurs would be to pull the drill and attempt a second shot;
however, this could force a second release of fluid and additional impacts. Therefore, if Bore -Gel
has sealed the initial frac-out and there is no threat to public health or significant impacts to
sensitive environmental areas, drilling will continue at the initial location, which will minimize the
frac-out's impacts (both extent and duration).
In the event of a frac-out, the contractor will notify the Biltmore Farms immediately following
detection. Biltmore Farms will then contact the Army Corps of Engineers, the Division of Water
Resources, and the US Fish and Wildlife Service. Once contact has been made, the contractor
will take the appropriate action specified above.
All effort will be put forth to mitigate the fluid losses and if further measures are deemed impractical
due to actual environmental impacts, the drilling will be completed as soon as possible. In the
event of fluid loss whether underwater or terrestrial, all environmental protection measures will
stay in place until the fluid loss has stopped.
Once the frac-out has stopped, an incident report will be filled out and documented with pictures
before, during and after cleanup. This report will detail the time, place, and measures taken to
stop the frac-out. This report will be furnished to Biltmore Farms, the Corps of Engineers, Division
of Water Resources, and the US Fish and Wildlife Service no later than 10 days following the
incident.
Upon completion, the Bore -Gel will be pumped to a holding tank and stored, until it is disposed of
offsite. Being an inert material, it does not require treatment prior to disposal.