20051457 Ver 1_Emails_20070726

Stallings, Hannah
From: Michelle Raquet [Michelle.Raquet @ncmail.net]
Sent: Thursday, July 26, 2007 4:03 PM
To: Hannah Stallings
Subject: Comments DWQ #13869
Attachments: Comments FBR and Knob Creek.doc; Comments to COE Alan Clark.doc; Comments to
Section 401.doc
Okay.... based on Melba's email and Darlene's suggestions here's my comments for the scoping
document submitted by the Cleveland County Sanitary District on the two reservoirs (First
Broad River and Knob Creek). Attached, please find everything that is on your desk. The
copies on your desk have signatures; these do not. As I wrote in the Comments FBR and Knob
Creek.doc, these comments are pertinent to this project as well as the first one I reviewed.
-- Michelle
Michelle Raquet
Basin Planner
NCDENR Division of Water Quality
Planning Section
Basinwide Planning Unit
1617 Mail Service Center
Raleigh, North Carolina 27699 -1617
Phone: [phone] x367
http: / /h2o.enr.state.nc.us /basinwide
1

Division of Water Quality
Basinwide Planning Unit
July 26, 2007
To: Hannah Stallings
From: Michelle Raquet
RE: Cleveland County Sanitary District Proposal to Build Two Reservoirs on the First
Broad River and Knob Creek
DENR # 08 -0005
DWQ# 13869
The DWQ Planning Section has reviewed the scoping document submitted by the Cleveland
County Sanitary District. Attached, please find comments that were submitted to David Baker
(U.S. Army Corps of Engineers) and to Cyndi Karoly (DWQ Section 401 Oversight) in July and
August 2005, respectively. These comments are directed towards a scoping document submitted
for the reservoir on the First Broad River. These comments are pertinent to both of the reservoirs
currently being submitted for review by the Cleveland County Sanitary District.

MEMORANDUM
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
August 16, 2005
TO: Cyndi Karoly
Section 401 Oversight
THRU: Darlene Kucken, Supervisor
Basinwide Planning Unit
FROM: Michelle Raquet
Basinwide Planning Unit
RE: Proposed First Broad River Reservoir
Cleveland County Sanitary District
Corps Action ID# 200330194
DWQ Project # 2005 -1457
Alan W. Klimek, P.E. Director
Division of Water Quality
The DWQ Planning Section has reviewed the public notice issued by the US Army Corps of
Engineers — Wilmington District for the proposed reservoir on the First Broad River and offers
the following information and /or comments for your consideration.
The proposed First Broad River Reservoir is located within subbasin 03 -08 -04 of the Broad
River basin. No permitted dischargers are located upstream of the proposed reservoir
location; however, two water supply intakes and two dischargers are located downstream.
Existing and future water supply demands should be carefully evaluated for potential
impacts the proposed reservoir may have on the downstream water and wastewater
treatment plants.
Several tributaries upstream of the proposed reservoir are designated trout (Tr) waters, and
the North Fork First Broad River and its tributaries were recently determined to meet the
criteria for reclassification to Outstanding Resource Waters (ORW) (Environmental
Sciences Section Memorandum, March 11, 2005). Being upstream of the proposed reservoir
location, extra care should be taken during and after construction to protect these waters
from significant changes in land use (i.e., development and road construction activities).
Currently, streams in the First Broad River watershed are marginally supporting their best -
intended use for aquatic life (Broad River Basinwide Water Quality Plan, February 2003).
Construction of the dam and resulting downstream flow impacts could result in further
degradation of the aquatic communities and impairment in the river or its tributaries.
Minimum stream flows should be evaluated in order maintain water quality downstream of
the dam.
One
NorthCarolina
Natirrallrl
North Carolina Division of Water Quality 1617 Mail Service Center 512 N. Salisbury St. Phone [phone] Customer Service
Internet: h2o.enr.state.ne.us Raleigh, NC 27699 -1617 Raleigh, NC 27604 FAX [phone]
An Equal Opportunity /Affirmative Action Employer — 50% Recycled /10% Post Consumer Paper

DWQ Comments on DWQ Project # 2005 -1457 Page 2
Proposed First Broad River Reservoir
The Instream Flow Incremental Methodology (IFIM) utilized by the Division of Water
Resources (DWR) in 1992 should be reevaluated and updated to reflect the changes in
physical habitat and species numbers and types. Varying flow regimes should be examined
and evaluated for potential water quality impacts from both point and nonpoint sources of
pollution (NCDWR Memorandum, July 27, 2005). Dissolved oxygen levels, changes to
temperature and flow fluctuations should also be considered.
The First Broad River and the tributaries within the proposed reservoir are currently
classified as WS -IV. Water supply critical areas (CA) will need to be assessed, and
reclassification for these areas may be necessary. The classifications for the waters located
in subbasin 03 -08 -04 are attached. This document can also be found at
http: / /li2o. enr.state.nc.usibims/ reports/ basinsandwaterbodies /03- 08- 04.pdf.
Sediment accumulation often reduces the water storage capacity of the reservoir and
movement of sediment from the reservoir to the downstream river segments. Reducing the
magnitude and frequency of normal flows may change the morphology of the existing river,
and consequentially, impact aquatic habitat and water quality (NC Wildlife Resource
Commission Memorandum, August 1, 2005). To evaluate the impacts of sedimentation, a
sediment analysis should be completed.
Elevated nutrients and the potential for eutrophication problems may exist once the dam is
in place. In order to assess the potential impacts and inputs into the system, a nutrient model
is recommended. The nutrient model should factor in the potential land use changes
associated with construction activities and population growth.
The DWQ Planning Section recommends that an Environmental Assessment be prepared
and include mitigation to restrict development adjacent to the reservoir; measures to control
stormwater and nonpoint runoff; riparian area (i.e., buffer) delineation; frequent instream
flow and water quality monitoring in the upstream and downstream tributaries and the
reservoir; and appropriate means for public access for boating, fishing and wildlife viewing.
A comprehensive water quality assessment should also be completed so that current water
quality conditions can be assessed.
We appreciate the opportunity to comment and provide information to Section 401 Oversight. If
you have any questions or would like any additional information, please contact Michelle Raquet
919.733.5083 extension 367.
Attachment: Classifications Schedule for Subbasin 03 -08 -04
http: / /h2o. enr. state.nc. us /bims/ reports' basinsandwaterbodies /03- 08- 04.pdf

DWQ Comments on DWQ Project # 2005 -1457
Proposed First Broad River Reservoir
References:
Page 3
North Carolina Department of Environment and Natural Resources (NCDENR). Division of Water Resources. July
27, 2005. Memorandum. RE: Proposed First Broad River Reservoir. Cleveland County Sanitary District. Corps
Action ID# 200330194.
NCDENR. Division of Water Quality (DWQ). Environmental Sciences Section. March 11, 2005. Memorandum.
SUBJECT: North fork Broad River Reclassifications Study.
NCDENR. DWQ. Planning Section. February 2003. Broad River Basin Water Quality Plan.
North Carolina Wildlife Resources Commission. August 1, 2005. Memorandum. SUBJECT: US Army Corps of
Engineers Public Notice (Action ID# 200330194). Cleveland County Sanitary District. First Broad River
Reservoir, Cleveland County.
cc: Alan Clark, Chief, DWQ Planning Section
Alex Marks, SEPA
Elizabeth Kountis, Classifications and Standards
Michelle Woolfolk, TMDL
Rex Gleason, Surface Water Protection Supervisor, MRO
Fred Tarver, Division of Water Resources
Ron Linville, Wildlife Resources Commission
Jim McRight, Department of Environmental Health, Public Water Supply
Dianne Reid, DWQ Environmental Sciences Section