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HomeMy WebLinkAbout20011551 Ver 4_Other Agency Comments_20120606Regulatory Division/1145 DEPARTMENT OF THE ARMY WILMINGTON DISTRICT, CORPS OF ENGINEERS 69 DARLINGTON AVENUE WILMINGTON, NORTH CAROLINA 28403 -1343 Action ID: SAW- 2011 -01765 NC Granite Corporation Mr. Kenny Moles 151 Granite Quarry Trail Mount Airy, North Carolina 27030 Dear Mr. Moles: June 4, 2012 o 1- 1 SSl Y4 Reference the letter from your authorized agent, Mr. Michael Wood of The Catena Group, dated March 30, 2012, responding to comments received by our Public Notice on your proposed project within the Ararat River at the North Carolina Granite Corporation in Mount Airy, Surry County, North Carolina. Also reference the follow -up email dated May 15, 2012, containing the No- Rise/No- Impact Certification from the local FEMA Floodplain Administrator. After reviewing this information, we have determined that additional details are needed prior to a permitting decision. Regarding the information provided in response to questions from the North Carolina Division of Water Resources, the following items need clarification: 1) The lip ( "invert") of the w -weir and the intake are both set at an elevation of 1013.5'. The 7Q10 is estimated to occur at 1013.8'. However, the document also states "...the invert of the intake is set at 20.7% of the low flow (7Q 10), which provides a physical impediment to water withdrawal." 20.7% equates to 2.69 cfs. Does this imply that there will be a lip in front of the intake set at an unspecified elevation between 1013.5 and 1013.8 ft to allow 2.69 cfs to pass? 2) A Stage - Discharge Rating Table is provided and the table header states the elevation to be above the invert but doesn't say which invert, the intake or the w -weir. It was initially thought that it is the intake because at the estimated 7Q 10 flow of 13 cfs the elevation is 0.333, versus 0.3. However, the 20.7% invert that equates to 2.69 cfs is not evident because the table shows that at a depth of 0.05' the total flow is 0.4 cfs with a withdrawal of 0.1 cfs. Also, the withdrawals don't cap at 20% but continue to 19.2 cfs at 1', which equates to 147% of the 7Q 10. Please provide further clarification. In addition, please confirm that the proposed withdrawal system does not have the capacity to withdraw greater than a volume equivalent to 20% of the estimated Printed on Recycled Paper - 2 - 3) It is unclear if this is a passive or pumping intake. If passive, what is the maximum instantaneous withdrawal capacity of the conduit at the top elevation of the conduit? If pumping, please provide the maximum instantaneous withdrawal, as opposed to the maximum daily of the pumps. 4) Please clarify the Stage - Discharge Rating Table regarding the potential for the sum of `Qweir' and `Qintake' to equal `Qtotal'? Additional information is needed if you have accounted for supplementary figures within `Qtotal', and not disclosed them within the Table. In addition, a few comments /questions were raised from US Army Corps of Engineer staff concerning this proposal and the downstream Renfro Levee. Please reference the "Hydraulic Analysis Report No- Impact Certification, Ararat River Project at NC Granite Facility" and supply additional information as requested: 1) It appears that the newly proposed project will have very little impact on the level of protection needed for FEMA's no -rise certification for the 100 -yr base flood condition. 2) It would be very useful to have each of the water surface elevations plotted in the HEC -RAS cross sections of the report, including pre - project water surfaces. 3) It appears that although these water surfaces are useful for determining if the newly proposed project will be acceptable for no -rise certification for 100 -yr Base Flood, there is no indication in this report that the Base Flow, which could be best described as "every -day normal flow" and it's associated water surface elevation at the Renfro site would be impacted by this newly proposed structure, thereby affecting the operability of the flap gates and interior drainage. One of the main reasons the former project (dam) was causing problems in the beginning was that there was water up against the flap gates at the Renfro site during Base Flow conditions (again, not to be confused with Base Flood conditions) because of the backwater caused by the dam. In flood conditions, the new project is completely submerged and so has little impact on the resultant 100 -year water surface elevation. Please supply additional information to help with this determination. On May 31, 2012, Mr. Monte Matthews and Mr. Wood met on site to discuss additional avoidance and minimization measures for the Ararat River side channel. In particular, these measures would explore methods for supplying adequate base and storm flow hydrology to the side channel to support typical stream functions. Adequate flow, as demonstrated during a monitoring period, would lessen anticipated changes in stream functions, minimize and/or avoid impacts, and help defer the need for compensatory mitigation. However, the site visit found the side channel - 3 - hydrology not sufficient to preclude the need for an additional analysis on additional avoidance and minimization, as required prior to a permitting decision. Depending on the information you provide, compensatory mitigation may still be required unless the hydrology can be augmented. Your response to these comments must be given full consideration before we can make a final decision on your application. We need your information to address the concerns /issues raised over the proposed project. You may submit additional information, revise your plans to help resolve the issues, rebut the issues made, or request a decision based on the existing record. Once we have determined that all comments have been adequately addressed, we will re -open our assessment of your project. If you have questions or comments, please contact Monte Matthews at the Raleigh Regulatory Field Office address, telephone (919) 554 -4884 ext. 30. Sincerely, Copy Furnished: Mr. Ian McMillan NCDWQ 1650 Mail Service Center Raleigh, NC 27699 -1650 Ms. Amy Euliss NC DENR Winston -Salem Regional Office DWQ 585 Waughtown Street Winston - Salem, NC 27107 Mr. Michael Wood The Catena Group 410B Millstone Drive Hillsborough, NC 27278 Jean B. Gibby Chief, Raleigh Regulatory Field Office