20150610 Ver 3_WRC Comments_20170612

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
MEMORANDUM
TO: Richard Harmon
Amec Foster Wheeler Environmental & Infrastructure, Inc.
FROM: Olivia Munzer
Western Piedmont Coordinator
Habitat Conservation
DATE: 12 June 2017
SUBJECT: Individual Permit Application for the Duke Energy Dan River Steam Station Stormwater
Diversion Project and Associated Projects; Rockingham County; DEQ Project No.
201506100.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
documents. Comments are provided in accordance with provisions of the Clean Water Act of 1977 (as
amended) and Fish and Wildlife Coordination Act Wildlife Coordination Act (48 Stat. 401, as amended;
16 U.S.C. 661 et seq.).
On behalf of Duke Energy, Amec Foster Wheeler Environment & Infrastructure, Inc. has submitted an
Individual Permit application for the stormwater diversion project and other previously permitted projects
(SAW -2016-00331, SAW -2014-01477, and SAW -2015-01670) at the Dan River Steam Station located
southeast of Eden, Rockingham County, North Carolina (N.C.). Impacts to stream and wetlands for the
stormwater diversion project previously permitted projects, including prior work activities, total 1137
linear feet (lf) of streams, 1.89 acres of a dredge basin, and 0.915 acres of wetlands. Duke Energy
proposes to pay into the N.C. Division of Mitigation Services In -Lieu Fees Program to offset impacts at a
mitigation ratio of 2:1 for 11371f of perennial stream; a 1:1 ratio for 1.89 acres of dredge basin impacts; a
2:1 ratio for 0.597 acres of non -riparian wetland impacts; and 2:1 ratio for 0.318 acres of riparian wetland
impacts.
Unnamed tributaries to the Dan River flow through the site and the Dan River borders the southern side of
the site. Dan River occurs in the Roanoke River basin and is classified as a Class C stream by N.C.
Division of Water Resources (NCDWR). The Dan River is designated as the Dan River Aquatic Habitat
Natural Heritage Natural Area.
We have records of the federal and state endangered Roanoke logperch (Percina rex) and James
spinymussel (Pleurobema collina); federal species of concern and state significantly rare Roanoke bass
(Ambloplites cavifrons); federal species of concern and state endangered green floater (Lasmigona
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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12 June 2017
Dan River Steam Station
DEQ Project No. 20150610v3
subviridis) and yellow lampmussel (Lampsilis cariosa); state threatened bigeye jumprock (Moxostoma
ariommum); state significantly rare quillback (Carpoides cyprinus); and state special concern riverweed
darter (Etheostoma podostemone) in the Dan River within the vicinity of the site. The United States Fish
and Wildlife Service (USFWS) also lists the smooth coneflower (Echinacea laevigata), a federally and
state endangered species, as having the potential to occur at the site; however, smooth coneflower was not
found during surveys of the site.
We have no objections to the project; however, we offer the following recommendations to minimize
impacts to aquatic and terrestrial wildlife resources.
1. Due to the presence of protected species in the Dan River, ensure off-site stormwater does not
contact other contaminated water or coal combustion residue from the site and is routed around
the site. All discharges into the Dan River or its tributaries should comply with NPDES permit
requirements.
2. Culverts should be designed to provide aquatic life passage. Culverts or pipes should be buried at
least one foot or 20% of their size below the natural streambed (measured from the natural
thalweg depth). Aquatic life passage should be assured during low flow or drought conditions.
Any riprap used should not interfere with aquatic life movement during low flow.
3. Native vegetation and bioengineered structures should be used for stream stabilization where
possible. Riprap used for stream bank stabilization should be limited to the stream bank below
the high-water mark, and vegetation should be used for stabilization above the high-water mark.
Long-term stabilization can be accomplished using native plants such as red maple, black willow,
sycamore, river birch, silky dogwood, and other native woody species. Riprap should not be
placed in the stream bed.
4. Re -seed disturbed areas with seed mixtures that are beneficial to wildlife. Avoid fescue -based
mixtures because fescue is invasive and provides little benefit to wildlife. Using native species
instead of ornamentals should reduce the need for water, fertilizers, and pesticides. Further
information and free technical guidance from NCWRC is available upon request.
5. Sediment and erosion control measures should use advanced methods and installed prior to any
land -disturbing activity. The use of biodegradable and wildlife -friendly sediment and erosion
control devices is strongly recommended. Silt fencing, fiber rolls and/or other products should
have loose -weave netting that is made of natural fiber materials with movable joints between the
vertical and horizontal twines. Silt fencing that has been reinforced with plastic or metal mesh
should be avoided as it impedes the movement of terrestrial wildlife species. Excessive silt and
sediment loads can have detrimental effects on aquatic resources including destruction of
spawning habitat, suffocation of eggs, and clogging of gills.
Thank you for the opportunity to review and comment on this project. If I can be of further assistance,
please contact me at [phone] or olivia.munzer&ncwildlife.org.
ec: Sue Homewood, NCDWR
David Bailey, USACE
Byron Hamstead, U.S. Fish and Wildlife Service
Steve Cahoon, Duke Energy