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HomeMy WebLinkAbout20070133 Ver 1_More Info Received_20071012CLEARWATER ENVIRONMENTAL CONSULTANTS, INC. October 10, 2007 Mr. Ian McMillan NC Division of Water Quality 401 Oversight/Express Review Permitting Unit 1650 Mail Service Center Raleigh, North Carolina 27699 U ~~~U RE: The Ridge at South Mountain ~~ Laurel Lake and Lake Sandy Plains Monitoring Rutherford and Polk Counties OC r ~ 2 207 Corps Action ID: 2007328381 ~ENR. ~,A DWQ Project # 07-0133 ~'~STr~~ry NCH Dear Mr. McMillan, Please reference the "Large Impoundments in Polk/Rutherford Counties" email (Attachment A) dated July 23, 2007 sent by Mr. Kevin Barnett of the North Carolina Division of Water Quality (DWQ) in response to the permit application and subsequent communications regarding the construction of a dam and impoundment at the development known as the Ridge at South Mountain. At the request of the DWQ, Clearwater Environmental Consultants, Inc. (CEC) chose two lakes and conducted the required sampling. This sampling provides data that can be used as a comparison, as well as, offer guidance for construction at the proposed lake within the Ridge at South Mountain development. Methods, collected data, and an explanation of CEC's findings will be discussed below. The Ridge at South Mountain and CEC, with guidance from the DWQ, developed a monitoring plan to evaluate water quality standards in two impoundments located in the Upper Piedmont ecoregion of North Carolina. These impoundments are comparable in size (surface area and watershed) and location; and one lake has a similar cold-water release structure as the lake proposed at the Ridge at South Mountain. This submittal also supports previous response to DWQ comments submitted on behalf of the applicant on April 4, 2007 and May 22, 2007. CEC believes that the applicant is demonstrating a serious commitment to improving dam design and water quality associated with lakes. The willingness to institute proposed measures including the installation of a mechanical aeration system and acold-water release discharge mechanism, implementation of a lake management plan and the associated operation and maintenance agreements, implementation of the previously proposed year-long study of water quality parameters, and five years of monitoring should allow the DWQ to determine that the applicant is going above and beyond to minimize water quality impacts and mitigate for permanent impacts associated with construction and operation of the lake. 718 Oakland Street Hendersonville, North Carolina 28791 Phone: 828-698-9800 Fax: 828-698-9003 www.cwenv.com Proposed Lake The Ridge at South Mountain is located northeast of Sunshine in Rutherford County, North Carolina. The development will be approximately 450 acres and will consist of approximately 225 residential lots and a 30-acre lake. The watershed draining to the lake will be approximately 360 acres. As proposed, the lake will have acold-water release discharge mechanism and impound an unnamed tributary to Roberson Creek. Roberson Creek is classified as a Class "WS- V" water by the DWQ. Study Lakes Laurel Lake is located in the Bills Creek community of Rutherford County, North Carolina. This lake is approximately 8 acres with a 335-acre watershed, has acold-water release discharge mechanism, and impounds an unnamed tributary to Bills Creek. Bills Creek is classified as a Class "C" water by the DWQ. Lake Sandy Plains is located in the Sandy Plains community of Polk County, North Carolina. This lake is approximately 30 acres with a 525-acre watershed, has atop-water release discharge mechanism, and impounds Collinsville Creek. Collinsville Creek is classified as a Class "C" water by the DWQ. A vicinity map, USGS topographic map, and aerial photo for each site has been included for review (Figures 1-9). The following table summarizes the above information: Rid es Lake Lake Sand Plains Laurel Lake Pond Size (acres) 30 30 8 Watershed Size (acres) 360 525 335 Ecore ion Upper Piedmont Upper Piedmont Upper Piedmont Water Release cold-water top-water cold-water Impounded Stream UT Roberson Creek Collinsville Creek UT Bills Creek Stream Classification WS-V C C Water Quality Sampling and Parameters Five water quality sampling stations were established at Lake Sandy Plains and Laurel Lake. The stations were as follows at each lake: • Station 1 is upstream of the impoundment and samples were taken near the water surface; • Stations 2 - 4 are evenly spaced across the centerline of the lake and samples were taken from within 3 inches of the water surface; and • Station 5 is downstream of the impoundment and samples were taken near the water surface. Water temperature, dissolved oxygen (DO), and pH were monitored at each station during August and early September. Each parameter and monitoring data are indicated in this section; however, a compiled table including all data for all parameters is enclosed for review (Attachment B). Acceptable ranges of water temperature, DO, and pH are defined by the DWQ and are based on a tributary's surface water classification. The evaluated tributaries and their surface water classifications can be found in the respective table illustrated under the "Study Lakes" section of this letter. Surface water classifications present in this study include Class "C" and Class "WS- V" waters. Class "C" waters are those waters protected for secondary recreation, fishing, wildlife, fish and aquatic life propagation and survival, agriculture and other uses suitable for Class "C" waters. Secondary recreation includes wading, boating, and other uses involving human body contact with water where such activities take place in an infrequent, unorganized, or incidental manner. Class "WS-V" waters are those waters that are protected as water supplies, which are generally upstream and draining to other water supply watersheds, or waters previously used for drinking water supply purposes or waters used by industry to supply their employees, but not municipalities or counties, with a raw drinking water supply source. Class "WS-V" waters are suitable for all Class "C" uses. The water quality standards for all fresh surface waters, regardless of classification, are the basic standards applicable to Class "C" waters. Standards associated with Class "C" waters, along with additional and more stringent standards applicable to other specific freshwater classifications are specified in NC Administrative Code 15A NCAC 02B.0100, .0200, & .0300, also known as the "Redbook". A review of the "Redbook" for standards related to water temperature, DO, and pH for waters classified as "WS-V", yielded no additional standards or requirements other than those listed for Class "C" waters. Water Temperature Temperature is a critical water quality and environmental parameter because it governs the kinds and types of aquatic life in the water body, regulates the maximum dissolved oxygen concentration of the water, and influences the rate of chemical and biological reactions. Organisms within an ecosystem have preferred temperature regimes that change as a function of season, organism age or life stage, and environmental factors. With respect to chemical and biological reactions, the higher the water temperature the higher the rate of chemical and metabolic reactions (Wilkes University Center for Environmental Quality). The DWQ indicates that temperature is "not to exceed 2.8 degrees C (5.04 degrees F) above the natural water temperature and in no case to exceed 29 degrees C (84.2 degrees F) for mountain and upper piedmont waters". Temperature sampling results for each of the five locations at Lake Sandy Plains and Laurel Lake are listed below. Lake Sandy Plains Date Station 1 Station 2 Station 3 Station 4 Station 5 Overall Change 8/8/2007 20.7 no data no data no data 25 4.3 8/21/2007 21.6 32.2 31.1 31.6 25.1 3.5 8/30/2007 19.8 29.6 29.5 29.2 24.4 4.6 9/11/2007 21.1 28.1 28.2 28.1 23.5 2.4 Laurel Lake Date Station 1 Station 2 Station 3 Station 4 Station 5 Overall Change 8/8/2007 22.1 no data no data no data 23.3 1.2 8/21/2007 20 29.5 29.1 29.7 21.9 1.9 8/30/2007 23.4 30.1 29.9 29.7 24.5 1.1 9/11/2007 19.7 26.9 26.9 26.6 23.7 4 *temperature measured m "C: **values in "red" exceed water quality standards Dissolved Oxygen (DO) DO is the form of oxygen in water that is freely available to aquatic plants and animals. DO is vital to fish and other aquatic life and for the prevention of odors. Oxygen is transferred from the atmosphere into the surface waters at the point of contact where the surface of the water interfaces with air. Once dissolved in water, oxygen diffuses throughout a water body very slowly since distribution depends on the movement of aerated water by turbulence and currents, water flow, and thermal upwelling. DO would be higher at the lake surface because the lake has a larger surface area and area of interface when compared to low gradient or slow moving streams. During the summer months, a process called thermal stratification occurs in many lakes. The water stratifies, or separates, into two layers: a warm surface layer that is relatively rich in DO and a colder bottom layer. The oxygen in the lower layer is gradually used up as organic material, which is washed into the lake when it rains or is discharged from sewage treatment plants, industries, or other sources settles to the bottom and decays. Because of the temperature difference, the two layers of water do not mix. As a result, the oxygen in the lower layer is not replaced. By the end of the summer, oxygen supplies near the bottom can be entirely depleted. Traditionally, the level of DO has been accepted as the single most important indicator of a water body's ability to support desirable aquatic life. The amount of oxygen required varies according to species and the life stage of that species. Usually, DO levels of 5.0 to 6.0 milligram per liter (mg/1) are required for growth and activity. DO levels below 3.0 mg/1 are stressful to most aquatic organisms. When levels fall below 2.0 mg/1 for an extended period of time, most fish will not survive. Oxygen is a particularly sensitive constituent because its availability during different times of day and different times of year is influenced by temperature, other chemicals present in the water, and biological processes. Temperature plays a major role in influencing the amount of DO in water; cold water has the ability to contain more oxygen than warm water (Texas State University; River Systems Institute). The DWQ indicates that for non trout waters, DO should not be "less than a daily average of 5.0 mg/1 with a minimum instantaneous value of not less than 4.0 mg/1". DO sampling results for each of the five locations at Lake Sandy Plains and Laurel Lake are listed below. Lake Sandy Plains Date Station 1 Station 2 Station 3 Station 4 Station 5 Overall Change 8/8/2007 9.64 no data no data no data 7.5 -2.14 8/21/2007 8.39 9.35 8.6 8.58 7 -1.39 8/30/2007 10.91 6.39 6.4 6.2 5.77 -5.14 9/11/2007 10.67 11.7 11.85 11.2 8.9 -1.77 Laurel Lake Date Station 1 Station 2 Station 3 Station 4 Station 5 Overall Change 8/8/2007 8 no data no data no data 6.5 -1.5 8/21/2007 8.3 9.3 9.3 9.45 5.6 -2.7 8/30/2007 5.93 7.41 7.27 7.18 4.89 -1.04 9/11/2007 10.15 11 11.45 11.8 7.3 -2.85 *DO measured in mg/1 using an 1~;x5tik 1)U6UU lltssolved Oxygen ivieter **values in "red" do not meet water quality standards Water pH is an indication of the water's acidity measurements on a scale of 1.0 to 14.0, with a pH of.7.0 considered neutral. A range of pH from 6.5 to 8.2 is optimal for most organisms. Generally, an aquatic organism's ability to complete a life cycle greatly diminishes as pH becomes greater than 9.0 or less than 5.0. Rapidly growing algae and submerged aquatic vegetation remove carbon dioxide from the water during photosynthesis. This can result in significant increases in pH levels, which in turn can affect aquatic life indirectly by changing other aspects of the water chemistry. For instance, toxic metals trapped in sediment are released into the water at lower pH levels, and the level of ammonia that fish can tolerate varies tremendously within a small range of pH values. Human activities such as accidental spills, agricultural runoff (pesticides, fertilizers, animal wastes), and sewer overflows may also change pH (Texas State University; River Systems Institute). The DWQ indicates that pH "shall be normal for the waters in the area, which generally shall range between 6.0 and 9.0". The pH sampling results for each of the five locations at Lake Sandy Plains and Laurel Lake are listed below. Lake Sandy Plains Date Station l Station 2 Station 3 Station 4 Station 5 Overall Change 8/8/2007 7.16 no data no data no data 7.11 -0.05 8/21/2007 8.38 10.5 9.85 9.78 8.32 -0.06 8/30/2007 8.61 9.16 9.08 8.89 8.66 0.05 9/11/2007 8.3 10.02 9.96 9.95 8.24 -0.06 Laurel Lake Date Station 1 Station 2 Station 3 Station 4 Station 5 Overall Change 8/8/2007 8.33 no data no data no data 7.9 -0.43 8/21/2007 8.26 10.06 9.99 10.13 7.13 -1.13 8/30/2007 8.71 10.7 10.51 10.3 7.78 -0.93 9/11/2007 7.68 9.02 8.96 9.18 7.14 -0.54 *DO measured in mg/1 using an ExStik EC500 pH Meter **values in "red" do not meet water quality standards Discussion of Results Although the data sets in this study are minimal, it is evident from the data collected that characteristics of water change within a lake setting. How this change effects downstream water quality depends on many factors including in-lake structures (i.e. cold-water release discharge mechanism, mechanical aeration), which can be directly deduced by this data, and landscape orientation. Temperature Lake Stations 2 - 4 represent the temperatures present within the body of the lakes. Average temperature in Lake Sandy Plains for the dates recorded is 29.7°C. Average temperature upstream of the impoundment for the dates recorded is 20.8°C. When comparing average upstream temperatures with average in-lake temperatures, this yields a change in temperature of 8.9°C. Average downstream water temperature for the dates recorded is 24.5°C; this is 3.7°C warmer than average water temperature upstream of the lake. Lake Sandy Plains does not have a cold-water release discharge mechanism. The water temperature maximum (29°C) listed in the water quality standards for Class "C" waters is exceeded within the lake boundary. Although temperatures at Station 1 and Station 5 do not exceed water quality standards, the change of temperature from Station 1 to Station 5 exceeds the 2.8°C maximum listed for change "above the natural water temperature". For this study, CEC considered the water temperature measured at Station 1 to be "natural". Average temperature in Laurel Lake for the dates recorded is 28.7°C. Average temperature upstream of the impoundment for the dates recorded is 21.3°C. When comparing average upstream temperatures with average in-lake temperatures, this yields a change in temperature of 7.4°C. Average downstream water temperature for the dates recorded is 23.4°C; this is 2.1 °C warmer than the average water temperature upstream of the lake. It is important to note the "Overall Change" column of the Laurel Lake table. Temperature measurements taken on September 11, 2007 yield an overall change of 4°C; all other measurements taken yield a change below 2°C. It is suspected that the data set for September 1 1, 2007 is an outlier. If this data set is removed from the calculation, average overall change in temperature from upstream to downstream is 1.4°C, well within the bounds of the water quality standards. Laurel Lake has a cold-water release discharge mechanism. The water temperature maximum (29°C) listed in the water quality standards for Class "C" waters is exceeded within the lake boundary; however, Station 1, Station 5, and the "Overall Change" (not including the September 11, 2007 data set) meet the water quality standards listed for Class "C" waters. According to the data collected, lakes increase water temperature (as measured near the surface) within the lake boundary; however, this should not lead to the conclusion that water discharged from a lake significantly increases downstream water temperature. The temperature data collected in this study supports the use of a cold-water release discharge mechanism as a way to stay within the bounds of the water quality standards for temperature set forth for Class "C" waters. Dissolved OxY eg_n (DO) DO measurements for all dates and all stations, except for the measurement taken at Laurel Lake at Station 5 on August 30, 2007, exceed water quality standards set forth for Class "C" waters. In general, DO within 3 inches of the lake surface is greater than the DO upstream of the impoundment. This trend is evident in all data sets, except for the data set collected at Lake Sandy Plains on August 30, 2007. Overall change from Station 1 to Station 5, in both lakes, constitutes a decrease in DO. If measurements from Lake Sandy Plains on August 30, 2007 are discarded because they do not follow the trend, the average overall decrease in DO for that lake is 1.76 mg/1 as compared to an average decrease of 2.02 mg/1 in Laurel Lake. Many factors could explain the difference in these values. One probable cause is the use of the cold-water release discharge mechanism. The data collected indicates that the use of a cold-water release discharge mechanism to influence water temperature also influences the level of DO. Although the difference in DO between the two lakes is small, it appears that decreased DO is a consequence of the cold-water release discharge mechanism and the desire to discharge cooler water from the bottom of the lake. P~ All pH measurements taken at Stations 2 - 4 in both lakes, with the exception of one measurement at each lake, fall out of the "normal" range indicated by the DWQ. Average pH in Lake Sandy Plains for the dates recorded is 9.69. Average pH upstream of the impoundment for the dates recorded is 8.11. When comparing average upstream pH with average in-lake pH, this yields an increase in pH of 1.58. Average downstream pH for the dates recorded is 8.05; the average decrease in pH from Station 1 to Station 5 for Lake Sandy Plains is 0.055. Although the data collected within the lake is out of the "normal" range indicated by DWQ, pH levels upstream and downstream of the impoundment are similar and well within the stated range. Average pH in Laurel Lake for the dates recorded is 9.87. Average pH upstream of the impoundment for the dates recorded is 8.25. When comparing average upstream pH with average in-lake pH, this yields an increase in pH of 1.62. These measurements are consistent with those at Lake Sandy Plains; however, the average downstream pH for the dates recorded is 7.49. The average decrease in pH from Station 1 to Station 5 for Laurel Lake is 0.76. The overall decrease in pH is greater at Laurel Lake. As with DO, it is suspected that one probable cause is the use of the cold-water release discharge mechanism. Although the data collected within the lake is out of the "normal" range indicated by DWQ, pH levels upstream and downstream of the impoundment are well within the stated range. Many factors affect the pH levels of water. As plants photosynthesize, they remove carbon dioxide and other nutrients from the water; this process increases pH. In especially low-velocity or still waters with increased amounts of plant life, such as lakes, an increase in pH can be expected during the growing season or even during warm, sunny afternoons. Anthropogenic activities can also significantly effect pH. Summary and Recommendations With regards to water temperature, the data collected supports the use of a cold-water release discharge mechanism as a way to meet water quality standards for Class "C" waters set forth by the DWQ. CEC supports the proposal to construct acold-water release discharge mechanism on the intended lake at the Ridge at South Mountain. In general, DO at both study lakes is well within the bounds of listed water quality standards; however, in both lakes there is a decrease in DO when comparing Station 1 values with Station 5 values. The overall change in DO indicated by the measurements leaves room for improvement. If values are troublesome or the DWQ feels there is a risk of DO values dropping below accepted levels, the Ridge at South Mountain is prepared to design the outfall to increase DO or install machinery to mechanically aerate the water discharged from the impoundment. For instance, the DO saturation point of water at 25°C (the highest outfall temperature recorded, which was from the non-cold-water release lake) is approximately 8.0 mg/1. The lowest DO reading from an outfall was 4.89 mg/1. Based on the equation for cascade aeration (H = (R-1)/[((O.ll)ab(1+0.046T)]), only a 9-foot tall cascade would be required to bring the 4.89 mg/1 up to an ideal DO of 6.0 mg/1 For this particular project, the outfall temperature should be much cooler yielding a higher DO saturation point, resulting in DO values exceeding 6.0 mg/1. The pH levels upstream and downstream of the impoundment are within the general accepted range identified by the DWQ; the pH levels within the lake exceed the accepted range. CEC recommends that a lake management plan be developed by a professional lake manager. Specifically identified in this plan should be limitations and guidelines for land use around the lake and a systematic plan to control aquatic vegetation, which does not involve the use of chemical herbicides. With the installation of a cold-water release discharge mechanism and aeration device (dependent on DWQ guidance), along with the implementation of a lake management plan, which includes monitoring, CEC feels that the lake proposed at the Ridge at South Mountain will be consistent with or an improvement over similar lakes in the area. The lake proposed at the Ridge at South Mountain can be constructed and managed in a way to ensure compliance with water quality standards set forth by the DWQ for Class "C" waters. The Ridge at South Mountain requests that the DWQ consider all additional information and additional measures provided and proposed by the applicant in determining the completeness of all associated environmental reviews. The applicant is demonstrating a serious commitment and has gone above and beyond to improve dam designs and water quality associated with lakes. The Ridge at South Mountain respectfully requests the issuance of the 401 Water Quality Certification for the specific activities proposed within jurisdictional waters. Should DWQ have any questions regarding the matters addressed in this letter please do not hesitate to contact me at (828) 698-9800. Sincerely, J/ ., R. Clement Riddle, P.W. . Principal clement riddle Attachment A From: Kevin Barnett [Kevin.Barnett@ncmail.net] Sent: Monday, July 23, 2007 12:15 PM To: Clement Riddle Cc: David McHenry; Hair, Sarah E SAW; Amanda Jones; John Dorney; Ian McMillan; Eric Kulz Subject: Large Impoundments in Polk / Rutherford Counties :~1 Kevin.Barnett.vcf (389 B) Hi Clement: After much discussion on Friday afternoon and evening, the DWQ will be sending out an additional information request on these projects again. In order to ensure that water quality standards are not contraveined, we are asking that you locate similar sized impoundments in similar sized watersheds in the same eco-region (upper piedmont) with the same as proposed water release structure. A plan and map for these facilities will be forwarded to the Regional Office prior to beginning the sampling protocol. You are being asked to provide Temp and D.O. monitoring for at least 5 samples over the month of August (next month) in the stream before the impoundment (near the surface), 3 samples within 3 inches of the surface evenly spaced across the center line of the impoundment, and one sample in the stream below the impoundment (near the surface). This data will be collected using standardized methods (EPA methods) using calibrated equipment. All collected data and calibration records for said equipment shall be submitted within 15 days of the end of the testing protocol such that the agency can make a determination as to wether the proposed activity will violate water quality standards, or not. Thanks, Kevin Kevin Barnett - Kevin.Barnett@ncmail.net North Carolina Dept. of Environment and Natural Resources Asheville Regional Office Division of Water Quality - Water Quality Section 2090 U.S. 70 Highway Swannanoa, NC 28778 Tel: 828-296-4500 Fax: 828-299-7043 1 The Ridge at South Mountain Rutherford County North Carolina CLEARWATER ~-'~ os~wc~sroR!~w%~~~H~,-~ Environmental Consultants, Inc. 718 Oakland Street Vicinity Map l Icndersonville, NC 28791 Figure ~ 81°49.000' W 81°48.000' W 81°47.00}0' W jWGS84 s ' Y'/ 1 / •/�'`-. 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I ~ Map created with TOPO!®m2003 National Geographic [www.nationalgeogmphic.comltopo) DtNf2 -WATER QUALITY ' vu cTLANDS AND STORl~fWA~ g(ZA~N CLEARWATER Lake Sandy Plains Environmental Consultants, Inc. USGS TOPO Polk County 718 Oakland street Figure 8 North Carolina }Icndersonville. NC 28791 828-698-9800 Q~c~~onr~~ OCi 1 2 2001 uEWk - wArEr~ ~~TY ~rIANQq ANO SrOR!~14YATf~ BRANCFY CLEARWATER Lake Sandy Plains F,nvironmental Consultants, [nc. Aerial Photo POIk COUnty 718 Oakland Street FlgUre 9 North Carolina Hendersonville, NC 28791 828-698-9800 ATTACHMENT B Lake Sandy Plains Date Station 1 (upstream) Station 2 (left) Station 3 (middle) Station 4 (right) Station 5 (downstream) Overall Change (change from Station 1 to Station 5) Tem DO H Tem DO H Tem DO H Tem DO H Tem DO H Tem DO H 8/8/2007 20.7 9.64 7.16 no data no data no data 25 7.5 7.11 4.3 -2.14 -0.05 8/21/2007 21.6 8.39 8.38 32.2 9.35 10.5 31.1 8.6 9.85 31.6 8.58 9.78 25.1 7 8.32 3.5 -1.39 -0.06 8/30/2007 19.8 10.91 8.61 29.6 6.39 9.16 29.5 6.4 9.08 29.2 6.2 8.89 24.4 5.77 8.66 4.6 -5.14 0.05 9/11/2007 21.1 10.67 8.3 28.1 11.7 10.02 28.2 11.85 9.96 28.1 11.2 9.95 23.5 8.9 8.24 2.4 -1.77 -0.06 Laurel Lake Date Station 1 (upstream) Station 2 (left) Station 3 (middle) Station 4 (right) Station 5 (downstream) Overall Change (change from Station 1 to Station 5) Tem DO H Tem DO H Tem DO H Tem DO H Tem DO H Tem DO H 8/8/2007 22.1 8 8.33 no data no data no data 23.3 6.5 7.9 1.2 -1.5 -0.43 8/21/2007 20 8.3 8.26 29.5 9.3 10.06 29.1 9.3 9.99 29.7 9.45 10.13 21.9 5.6 7.13 1.9 -2.7 -1.13 8/30/2007 23.4 5.93 8.71 30.1 7.41 10.7 29.9 7.27 10.51 29.7 7.18 10.3 24.5 4.89 7.78 1.1 -1.04 -0.93 9/11 /2007 19.7 10.15 7.68 26.9 11 9.02 26.9 11.45 8.96 26.6 11.8 9.18 23.7 7.3 7. t 4 4 -2.85 -0.54 Le end Abbreviation Parameter Units Tem tem erature °C DO dissolved o en m /I pH pH no unit "values in "red" exceed water quality standards for class "C" waters. 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