20090569 Ver 2_More Info Letter_20100322

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
March 22, 2010
Mr. Patrick E. Carlton, Trustee
P.O. Box 2128
Cashiers, NC 28717
Subject: Request for More Information
401 Water Quality Certification
Chinquapin Irrigation Supply Project
DWQ Project # 09-0569 v2
Jackson County
Response deadline: April 26, 2010
Dear Mr. Carlton:
The Division of Water Quality (DWQ) has performed a preliminary review of a 401 Water Quality Certification
application submitted for the above referenced property (the first submittal was returned July 14, 2009).
Additional information will be required in order to complete the review process.
Please provide the following information so that we may continue to review your project.
Additional Information Requested:
The proposed pump system will be placed in Robinson Creek, a Class WS-III, Tr waterbody in
the Little Tennessee River Basin. Per 15A NCAC 2B .0215(3)(b)(i)(H) for WS (water supply)
water bodies, water dependent structures "may be allowed where no practicable alternative
exists."
With the resubmittal of the application, many alternatives were reviewed and determined to be
unfeasible. After the meeting conducted at the Chinquapin site on September 1, 2009, the DWQ
was hopeful that an off-line pond would be a feasible alternative. Because it appears that this
may not be the case due to the limited available land areas and the existing conservation
easement, the DWQ would like further explanation on the feasibility of a pump house
configuration (instead of the submersible pump system placed directly in the stream). Installing
a permanent instream structure to be used mainly for emergency "severe drought condition"
purposes still does not seem to be the best solution. Please evaluate in more detail and
compare/contrast a floating pump system (this may be a new option) vs. a pump house system
vs. the submersible pump system. In this comparison, costs, energy consumption, maintenance,
Location: 2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: [phone] FAX [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity ? Affirmative Action Employer
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NorthCarolina
Aitturally
Mr. Carlton
March 22, 2010
Page 2 of 3
etc. should be evaluated. Although noise is stated as one factor in the elimination of the
centrifugal pump system, this factor could be remedied through use of an insulated pump house.
Additionally, the submerged pump system is also likely to be noisy. As part of the evaluation,
provide details of the total pumping distance and elevation change, etc. that was used to
determine head and pump size.
2. To ensure that 7QI Os is maintained, please state how, practically, this is going to be met (if this
were a condition of the 401 approval). Since the DWQ did not receive a copy of the Operation
and Maintenance manual that was submitted to Chinquapin, we do not know specifically how
this would be met during operation.
DWQ needs confirmation of the 7Q IOs value provided by Mr. Tarver. Traditionally, this value
is provided by USGS. Did Mr. Tarver obtain this value from USGS? Did he estimate the 7QIOs
himself based on drainage area and nearby gauge stations? Please provide correspondence from
Mr. Tarver or USGS confirming the 7QIOs value.
Please provide your response in writing to the addresses below prior by April 26, 2010. Four copies of the
required information should be provided to the 401 Permitting Unit at:
Mr. Ian McMillan
401 Permitting Unit
1650 Mail Service Center
Raleigh, NC 27699-1650
and a single copy to the Asheville Regional Office at:
NIs. Susan A. Wilson
Surface Water Protection Section
2090 US HWY 70
Swannanoa, NC 28778
If we do not hear from you by the deadline, we will assume that you no longer want to pursue this project and
we will consider the project withdrawn.
This letter only addresses the preliminary application review and does not authorize any impacts to wetlands,
waters or protected buffers.
11r. Carlton
March 22, 2010
Page 3 of 3
Please be aware that any impacts requested within your application are not authorized (at this time) by the
DWQ. Please call Ms. Susan A. Wilson 828-296-4500, if you have any questions.
Sincerely,
Roger C. Edwards, Regional Supervisor
Surface Water Protection
Asheville Regional Office
cc: Ms. Lori Beckwith - US Army Corps of Engineers Asheville Field Office
David McHenry - North Carolina Wildlife Resources Commission
Ian McMillan - 401 Permitting Unit
Jackson County Planning/ Robbie Shelton
ARO File copy
S:\SWP\.Jackson\401s\Non-DOT1Chinquapin Irrigation supply\Addlnfo.Chinquapin Irr Ver2.3 2010.doc