20090329 Ver 1_401 Application_20090309

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ENVIRONMENTAL
March 23, 2009
Mr. Ian McMillan
401 Coordinator
North Carolina Division of Water Quality
1628 Mail Service Center
Raleigh, NC 27699-1628
Re: Pre-Construction Notification (PCN) Application Form
Narrow's Dam Cove Remediation Project
Dear Mr. McMillan:
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09-0329
BHE Environmental, Inc. (BHE) is pleased to submit this Pre-Construction Notification Application
Form on behalf of Alcoa, Inc for the above mentioned project. The application is being submitted in
coordination with Cheryl Marks and the NCDENR, Division of Waste Management, Superfund Section,
Inactive Hazardous Waste Sites Branch. In addition, we have been coordinating with Emily Hughes of
the U.S. Army Corps of Engineers.
Included in this submittal are the following materials:
1) Seven (7) copies of the completed Pre-Construction Notification Application Form,
2) Seven (7) copies of the Temporary and Permanent Impacts Summary (stand alone
document),
3) Seven (7) copies of the Temporary and Permanent Impacts Summary figure,
4) Seven (7) copies of the March 17, 2009, revised Narrow's Dam Cove Remediation Work Plan.
Please contact me with any questions or concerns at [e-mail] or (513) 326-
1518.
Sincerely,
BHE ENVIRONMENTAL, INC.

Timothy P. Gessner, PE
Vice President
24M

09-0329
O-W A?
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Office Use Only:
Corps action ID no.
DWQ project no.
Form Version 1.4 January 2009
Pre-Construction Notification (PCN) Form
A. Applicant Information
1. Processing
1 a. Type(s) of approval sought from the Corps: ?X Section 404 Permit ? Section 10 Permit
1 b. Specify Nationwide Permit (NWP) number: 38 or General Permit (GP) number:
1c. Has the NWP or GP number been verified by the Corps? ?X Yes ? No
1 d. Type(s) of approval sought from the DWQ (check all that apply):
?X 401 Water Quality Certification - Regular ? Non-404 Jurisdictional General Permit
? 401 Water Quality Certification - Express ? Riparian Buffer Authorization
le. Is this notification solely for the record
because written approval is not required? For the record only for DWQ
401 Certification:
?X Yes ? No For the record only for Corps Permit:

? Yes ?X No
1f. Is payment into a mitigation bank or in-lieu fee program proposed for
mitigation of impacts? If so, attach the acceptance letter from mitigation bank
or in-lieu fee program.
? Yes Q No
1g. Is the project located in any of NC's twenty coastal counties. If yes, answer 1h
below. ? Yes ?X No
1 h. Is the project located within a NC DCM Area of Environmental Concern (AEC)? ? Yes ?X No
2. Project Information
2a. Name of project: Narrow's Dam Cove Remediation
2b. County: Montgomery
2c. Nearest municipality / town: Badin
2d. Subdivision name:
2e. NCDOT only, T.I.P. or state project
3. Owner Information f+
3a. Name(s) on Recorded Deed: Alcoa Power Generating, Inc.
3b. Deed Book and Page No. DOM - V?ArER GIIA
3c. Responsible Party (for LLC if
applicable): Kirk Gribben
3d. Street address: 201 Isabella Street
3e. City, state, zip: Pittsburgh, PA 15212
3f. Telephone no.: [phone]
3g. Fax no.: [phone]
3h. Email address: [e-mail]
Page 1 of 10
PCN Form - Version 1.4 January 2009
4. Applicant Information (if different from owner)
4a. Applicant is: ? Agent ? Other, specify:
4b. Name:
4c. Business name
(if applicable):
4d. Street address:
4e. City, state, zip:
4f. Telephone no.:
4g. Fax no.:
4h. Email address:
5. Agent/Consultant Information (if applicable)
5a. Name: Tim Gessner
5b. Business name
(if applicable): BHE Environmental, Inc.
5c. Street address: 11733 Chesterdale Road
5d. City, state, zip: Cincinnati, OH 45246
5e. Telephone no.: [phone]
5f. Fax no.: [phone]
5g. Email address: [e-mail]
Page 2 of 10
B. Project Information and Prior Project History
1. Property Identification
1a. Property identification no. (tax PIN or parcel ID):
I NA
1 b. Site coordinates (in decimal degrees): Latitude: 35.418675 Longitude: 80.091403
1c. Property size: 0.34 acres
2. Surface Waters
2a. Name of nearest body of water to proposed project: Yadkin River
2b. Water Quality Classification of nearest receiving water: WS-IV
2c. River basin: Yadkin River
3. Project Description
3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this
application:
The site consists of a peninsula that is made of exposed metavolcanic bedrock, boulderstcobbles, and thick vegetation where sediment and soil are
present. The land in the vicinity of the project could be described as evergreen/deciduous forest with some baron (rocky) areas.
3b. List the total estimated acreage of all existing wetlands on the property: 0
3c. List the total estimated linear feet of all existing streams (intermittent and perennial) on the property: 0
3d. Explain the purpose of the proposed project:
The purpose of this project is to remediate PCB and lead impacted soils and sediments located in the cove area.
3e. Describe the overall project in detail, including the type of equipment to be used:
See the attached Work Plan for project details.
4. Jurisdictional Determinations
4a. Have jurisdictional wetland or stream determinations by the
Corps or State been requested or obtained for this property /
project (including all riot phases) in the past? ? Yes Q No ? Unknown

Comments: No wetlands -the area consists of bedrock and rocks
4b. If the Corps made the jurisdictional determination, what type
of determination was made?
? Preliminary ? Final
4c. If yes, who delineated the jurisdictional areas?
Name (if known): Agency/Consultant Company:
Other:
4d. If yes, list the dates of the Corps jurisdictional determinations or State determinations and attach documentation.
5. Project History
5a. Have permits or certifications been requested or obtained for
this project (including all prior phases) in the past? [I Yes ? X No
El Unknown
5b. If yes, explain in detail according to "help file" instructions.
6. Future Project Plans
6a. Is this a phased project? ? Yes Q No
6b. If yes, explain.
Page 3 of 10
PCN Form - Version 1.4 January 2009
C. Proposed Impacts Inventory
1. Impacts Summary
1 a. Which sections were completed below for your project (check all that apply):
? Wetlands ?X Streams - tributaries ? Buffers ® Open Waters ? Pond Construction
2. Wetland Impacts
If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted.
2a.
Wetland impact
number
Permanent (P) or
Temporary T 2b.
Type of impact 2c.
Type of wetland 2d.
Forested 2e.
Type of jurisdiction
Corps (404,10) or
DWQ (401, other) 2f.
Area of
impact
(acres)
W1 - Choose one Choose one Yes/No
W2 - Choose one Choose one Yes/No
W3 - Choose one Choose one Yes/No
W4 - Choose one Choose one Yes/No -
W5 - Choose one Choose one Yes/No -
W6 - Choose one Choose one Yes/No
2g. Total Wetland Impacts:
2h. Comments:
3. Stream Impacts
If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this
question for all stream sites impacted.
3a.
Stream impact
number
Permanent (P) or
Temporary (T) 3b.
Type of impact 3c.
Stream name 3d.
Perennial (PER) or
intermittent (INT)? 3e.
Type of
jurisdiction 3f.
Average
stream
width
(feet) 3g.
Impact
length
(linear
feet)
S1 T Barge Landing Yadkin River PER 60 20
S2 T Boulder Movement Yadkin River PER 60 100
S3 Choose one
S4 - Choose one
S5 Choose one
S6 Choose one
3h. Total stream and tributary impacts 120
3i. Comments:
After initial review the corps determined that this project would be evaluated primarily on Open Water Impact basis. See C - No. 4.
Page 4 of 10
PCN Form - Version 1.4 January 2009
4. Open Water Impacts
If there are proposed impacts to lakes, ponds, estuaries, tributaries, sounds, the Atlantic Ocean, or any other open water of
the U.S. then individual) list all open water impacts below.
4a. 4b. 4c. 4d. 4e.
Open water Name of waterbody
impact number (if applicable) Type of impact Waterbody Area of impact (acres)
Permanent (P) or type
Temporary
01 T Narrow's Cove Silt Curtain Cove 0.0006
02 P Narrow's Cove Fill (Aqua Dam Foundations) Cove 0.01
03 T Narrows Cove Aqua Dams Cove 0.01
04 P Narrow's Cove Sediment removal (dry condition) Cove 0.022
4f. Total open water impacts 0.065
Comments: a will a so a proa roe cap placed over a remove se ime area. area impa a VA e e me a area
4g
.
impacted during removal, or roughly 0.022 acres. The cap will consist of 8.7 cu. yards of non-toxic clay and 8.7 cu. yards of stone.
5. Pond or Lake Construction
If and or lake construction roosed then complete the chart below.
5a. 5b. 5c. 5d. 5e.
Pond ID number Proposed use or Wetland Impacts (acres) Stream Impacts (feet) Upland
purpose of pond (acres)
Flooded Filled Excavated Flooded Filled Excavated
P1 Choose one
P2 Choose one
5f. Total:
5g. Comments:
5h. Is a dam high hazard permit required? ? Yes ? No If yes, permit ID no:
5i. Expected pond surface area (acres):
5j. Size of pond watershed (acres):
5k. Method of construction:
6. Buffer Impacts (for DWO)
If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts
below. If an impacts require mitigation, then you MUST fill out Section D of this form.
6a. Project is in which protected basin? ? Neuse ? Tar-Pamlico ? Catawba ? Randleman ? Other:
6b. 6c. 6d. 6e. 6f. 6g.
Buffer Impact Reason for impact Stream name Buffer Zone 1 Zone 2
number- mitigation impact impact
Permanent (P) or required? (square (square
Temporary T feet feet
61
Yes/No
B2 - Yes/No
B3 -
Yes/No
B4
Yes/No
B5 - Yes/No
B6 - Yes/No
6h. Total Buffer Impacts:
6i. Comments:
Page 5 of 10
D. Impact Justification and Mitigation
1. Avoidance and Minimization
1 a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project.
The intent of this project is to remove impacted sediment from the cove area adjacent to the Narrows Powerhouse. To assure no sediment migration
occurs during work activities, a silt curtain will be installed in the neck of the cove. Other sediment and erosion control devices (i.e. hay bails or silt
fence) will be used on the peninsula. All temporary structures placed below the average water depth at the peninsula will be removed at completion.
1 b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques.
The removal of the impacted sediment requires the installation of two temporary damming structures. The dams will provide an additional sediment
control barrier and will isolate the impacted area so that water covering the sediment can be pumped out. This will allow for the impacted sediment
work to be isolated from the general cove and Yadkin River.
2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a. Does the project require Compensatory Mitigation for
impacts to Waters of the U.S. or Waters of the State? ? Yes Q No
2b. If yes, mitigation is required by (check all that apply): ? DWQ ? Corps

2c. If yes, which mitigation option will be used for this
project? ? Mitigation bank
? Payment to in-lieu fee program

? Permittee Responsible Mitigation
3. Complete if Using a Mitigation Bank
3a. Name of Mitigation Bank:

3b. Credits Purchased (attach receipt and letter) Type: Choose one
Type: Choose one
Type: Choose one Quantity:
Quantity:
Quantity:
3c. Comments:
4. Complete if Makin a Payment to In-lieu Fee Program
4a. Approval letter from in-lieu fee program is attached. ? Yes
4b. Stream mitigation requested: linear feet
4c. If using stream mitigation, stream temperature: Choose one
4d. Buffer mitigation requested (DWQ only): square feet
4e. Riparian wetland mitigation requested: acres
4f. Non-riparian wetland mitigation requested: acres
4g. Coastal (tidal) wetland mitigation requested: acres
4h. Comments:
5. Complete if Using a Permittee Responsible Mitigation Plan
5a. If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan.
Page 6 of 10
PCN Form - Version 1.4 January 2009
6. Buffer Mitigation (State Regulated Riparian Buffer Rules) - required by DWQ
6a. Will the project result in an impact within a protected riparian buffer that requires
buffer mitigation? Yes No
6b. If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the
amount of mitigation required.

Zone 6c.
Reason for impact 6d.
Total impact
(square feet)
Multiplier 6e.
Required mitigation
(square feet)
Zone 1 3 (2 for Catawba)
Zone 2 1.5
6f. Total buffer mitigation required:
6g. If buffer mitigation is required, discuss what type of mitigation is proposed (e.g., payment to private mitigation bank,
permittee responsible riparian buffer restoration, payment into an approved in-lieu fee fund).
6h. Comments:
Page 7 of 10
E. Stormwater Management and Diffuse Flow Plan (required by DWQ)
1. Diffuse Flow Plan
1a. Does the project include or is it adjacent to protected riparian buffers identified ? Yes © No
within one of the NC Riparian Buffer Protection Rules?
1 b. If yes, then is a diffuse flow plan included? If no, explain why.
? Yes ? No
2. Stormwater Management Plan
2a. What is the overall percent imperviousness of this project? 75%
2b. Does this project require a Stormwater Management Plan? ? Yes ?X No
2c. If this project DOES NOT require a Stormwater Management Plan, explain why:
The project site is less than an acre and storm water management issues are addressed in the Administrative Agreement NCGS 130A-310.9(b)
between Alcoa and the North Carolina Department of Environment and Natural Resources.
2d. If this project DOES require a Stormwater Management Plan, then provide a brief, narrative description of the plan:
2e. Who will be responsible for the review of the Stormwater Management Plan?
3. Certified Local Government Stormwater Review
3a. In which local government's jurisdiction is this project? NA
? Phase II
3b. Which of the following locally-implemented stormwater management programs ? NSW
apply (check all that apply): ? USMP
? Water Supply Watershed
? Other:
3c. Has the approved Stormwater Management Plan with proof of approval been ? Yes ?X No
attached?
4. DWQ Stormwater Pr ram Review
?Coastal counties
?HQW
4a. Which of the following state-implemented stormwater management programs apply ?ORW
(check all that apply): ?Session Law 2006-246
? Other:
4b. Has the approved Stormwater Management Plan with proof of approval been ? Yes ? No
attached?
5. DWQ 401 Unit Stormwater Review
5a. Does the Stormwater Management Plan meet the appropriate requirements? ? Yes ? No
5b. Have all of the 401 Unit submittal requirements been met? ? Yes ? No
Page 8 of 10
PCN Form - Version 1.4 January 2009
F. Supplementary Information
1. Environmental Documentation (DWQ Requirement)
1a. Does the project involve an expenditure of public (federal/state/local) funds or the ? Yes ® No
use of public (federal/state) land?
1b. If you answered "yes" to the above, does the project require preparation of an
environmental document pursuant to the requirements of the National or State ? Yes ? No
(North Carolina) Environmental Policy Act (NEPA/SEPA)?
1c. If you answered "yes" to the above, has the document review been finalized by the
State Clearing House? (If so, attach a copy of the NEPA or SEPA final approval
letter.) ? Yes ? No
Comments:
2. Violations (DWQ Requirement)
2a. Is the site in violation of DWQ Wetland Rules (15A NCAC 2H .0500), Isolated
Wetland Rules (15A NCAC 2H .1300), DWQ Surface Water or Wetland Standards, ? Yes Q No
or Riparian Buffer Rules (15A NCAC 2B .0200)?
2b. Is this an after-the-fact permit application? ? Yes ?X No
2c. If you answered "yes" to one or both of the above questions, provide an explanation of the violation(s):
3. Cumulative Impacts (DWQ Requirement)
3a. Will this project (based on past and reasonably anticipated future impacts) result in ? Yes Q No
additional development, which could impact nearby downstream water quality?
3b. If you answered "yes" to the above, submit a qualitative or quantitative cumulative impact analysis in accordance with the
most recent DWQ policy. If you answered "no," provide a short narrative description.
4. Sewage Disposal (DWQ Requirement)
4a. Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of wastewater generated from
the proposed project, or available capacity of the subject facility.
Water will be pumped from the cove into holding tanks prior to excavating the sediment in the cove area. As water is pumped it will pass through a 5
micron filter and samples will be collected. The samples will be analyzed for PCBs using Method 8081 with a method detection limit of 3 ppb. If
PCBs are detected in the sample, the water will be re-filtered using a 1 micron filter and sampled again. jAs outlined in our plan which is subject to
the Administrative Agreement, if the sample is non-detect it will be discharged to the Yadkin River. If it again fails, alternative treatment technologies
will be investigated or alternate disposal locations will be considered.
Page 9 of 10
PCN Form - Version 1.4 January 2009
5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected species or Yes ? X No
habitat?
5b. Have you checked with the USFWS concerning Endangered Species Act ?x Yes ? No
impacts?
5c. If yes, indicate the USFWS Field Office you have contacted. Asheville
5d. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical
Habitat?
Currently the Yadkin River Goldenrod (YRGR) is listed by USFWS as a candidate species. Alcoa acknowledged this information and coordinated with
BHE and botanist Moni Bates with Ecologic to conduct a YRGR potential habitat survey. Results from the study are provided in the work plan.
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as essential fish habitat? ? Yes ?X No
6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat?
Called Corps directly.
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
7a. Will this project occur in or near an area that the state, federal or tribal
governments have designated as having historic or cultural preservation ? Yes ? No
status (e.g., National Historic Trust designation or properties significant in
North Carolina history and archaeology)?
7b. What data sources did you use to determine whether your site would impact historic or archeological resources?
8. Flood Zone Designation (Corps Requirement)
8a. Will this project occur in a FEMA-designated 100-year floodplain? ?X Yes ? No
8b. If yes, explain how project meets FEMA requirements:
The water elevation at the project site will be managed by the Narrow's Dam and the Fall's Dam. During heavy precipitation events, the Fall's Dam
can pass more water to keep the water elevation at the project site consistent.
8c. What source(s) did you use to make the floodplain determination?
National Flood Insurance Program Flood Insurance Map: North Carolina Panel 6670
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Applicant/Agent's Printed Name Ap li nt/ gent's Signature Date
(Agent's si ture is valid only if an authorization
letter from the applicant is provided.)
Page 10 of 10
401/404 Permit Application Water Body Impacts Summary
TEMPORARY IMPACTS
1. Barge Landing Area on Peninsula
Due to access restrictions and topography on the peninsula, it will be necessary to install a barge landing
area on the peninsula to safely offload equipment, materials and personnel at the project site. The
construction technique and materials used for the landing are at the discretion of the Contractor. It
could potentially consist of concrete barriers, class A rip rap, and/or a 20' flat top quip bridge. The
anticipated footprint of the landing area that is below the average pool depth is roughly 810 square feet
(0.02 acres). In this area there is a potential for materials to be placed and boulders to be moved. No
materials will be removed. Any materials placed below the average pool depth will be removed upon
completion of the project.
2. Silt Curtain
A silt curtain will be installed in the neck that separates the cove from the Falls Reservoir (Yadkin River).
The curtain will be installed prior to any excavation work takes place on the peninsula or in the cove. It
is anticipated that the curtain will be roughly 25' in length and be anchored at each side.
3. Sediment Traps
Two sediment traps will be installed downstream from the cove in the Falls Reservoir to collect any
sediment that could potentially migrate past the other control structures. A detail drawing for the
sediment trap is provided in the work plan. The temporary footprint from the sediment traps should be
minimal at roughly 9 square feet (0.0002 acres) per trap.
4. Aqua Dams
Two Aqua Dams will be installed in the cove area to assist in excavating the sediment below the average
pool depth in the cove. One of the dams will be installed in the by-pass tunnel, and the other will
installed near the middle of the cove. The dams will isolate the impacted sediment and allow for it to be
more readily accessible to the excavating equipment. It is anticipated that the Aqua Dams will
temporarily impact 207 square feet apiece (0.005 acres) or 414 square feet (0.01 acres) total area
between the two.
PERMANENT IMPACTS
4. Aqua Dam Foundations
The bottom of the cove area is very rocky and unlevel. Prior to placing and filling the Aqua Dams, a
bentonite and sand mixture will be placed in the cove to level the bottom and provide a flat surface as a
foundation for the Aqua Dams. The footprint for each is roughly 225 square feet (0.005 acres). This
material will remain after the removal of the aqua dams.
I.a L=
MAi?-6 2009
DENR - WATER QUALITY
V: ETLA1403 AND STORMVVATER BRA. fir, l
5. Removal of Impacted Sediments
One of the targets in this remediation effort is impacted sediment below the average pool level in the
cove area. The sediment occupies a footprint of roughly 945 square feet (0.022 acres) and is known to
be 2' deep at its thickest location. It is conservatively estimated that 60 cubic yards of sediment will be
removed and hauled off site for disposal.
5. Cap Sediment Area
All impacted sediment will be removed to the maximum extent possible. Upon completing the
excavation, a 2-3" layer of non-toxic clay topped with a 2-3" layer of stone will be placed over the
exposed area that is roughly 945 square feet (0.022 acres) in area. It is anticipated that 8.7 cubic yards
of clay and 8.7 cubic yards of rock will be placed.
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Soil and Sediments
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Proposed Road Construction
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401/404 PCN Permit Application Figure D'
W E 11??1 ' 1`
March 2009 Source Data: ENVIRONMENTAL
S Feet Stanly County GIS Department
Project No. 0990.163 20 0 20 40 60 Stanly County, North Carolina
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BHE 09-0329
ENVIRONMENTAL
PN: 0990.163-001 August 27 2008
Revised: March 17, 2009
REMEDIATION WORK PLAN
NARROW'S DAM COVE ' @ IL I!
ALCOA BADIN OPERATIONS ' b
BADIN, NORTH CAROLINA MAR 61 b 2rjG9
DEMR - WATER QUAL11Y
VVETV.1DS AND S T M,WA ER BRANCH
Prepared for:
Alcoa, INC.
0
ALCOA
Prepared by:
BHE Environmental, Inc.
11733 Chesterdale Rd.
Cincinnati, OH 45246-4131
Phone: [phone]
www.bheenvironmental.com
Environeering, Inc.
16350 Park Ten Place
0 Houston, TX 77084
Phone: [phone]
Notice: This report has been prepared by BHE Environmental, Inc., and Environeering, Inc., solely for the
benefit of its client in accordance with an approved scope of work. BHE and Environeering assume no liability
for the unauthorized use of this report or the information contained in it by a third party.
TABLE OF CONTENTS
1.0 INTRODUCTION .................................................................................... 1
1.1 Purpose ..................................................................................... 1
1.2 Background ................................................................................ 1
2.0 TECHNICAL APPROACH OVERVIEW AND ARAR ASSESSMENT .............................. 6
2.1 Technical Approach Overview .......................................................... 6
2.2 ARAR Assessment ....................................... 7

2.2.1 .................................
Environmental Issues ....................................................... .
.
8
2.2.1.1 Air Quality Issues ................................................................ . 8
2.2.1.2 Waste Management Issues ..................................................... . 8
2.2.1.3 TSCA Issues ....................................................................... .
9
2.2.1.4 Clean Water Act Issues ......................................................... . 9
2.2.1.5 Water Quality / NPDES Issues .................................................
10
2.2.1.6 SPCC (Spill Prevention, Control and Countermeasures) Issues ........... 10
2.2.2 Notifications It Public Review ............................................ 11
2.2.2.1 NC DENR, Division of Waste Management ................................... 11
2.2.2.2 NC DENR Division of Water Quality ........................................... 11
Regulation: Section 401 General Water Quality Certification (WQC) #3696........ 11
2.2.2.3 NC Dam Safety Notification ................................................... 12
2.2.2.4 U.S. Army Corps of Engineers (COE) Notification .......................... 12
2.2.2.5 U.S. Coast Guard Notification ................................................. 12
2.2.2.6 Federal Energy Regulatory Commission (FERC) Notification .............. 12
3.0 TECHNICAL APPROACH ......................................................................... 13
3.1 Imple mentation Steps ...................................................................
13
3.1.1 Mobilization and Site Preparation ........................................ 13
3.1.1.1 Identify and mark Yadkin River Golden Rod (YRGR) potential habitat
area ............
3.1.1.2 Barge system preparation and peninsula landing area construction .... 15
3.1.1.3 Setup water management tanks (<20,000 gallons) and lay secondary
contained pipe from cove to tanks ................................ 15

3.1.1.4 ........................
Mobilize equipment to peninsula by barge ..................................
15
3.1.1.5 Setup erosion controls and silt curtain systems ............................ 15
3.1.1.6 Install two sediment traps in Falls Reservoir ............................... 17
3.1.1.7 Setup material management systems ........................................ 17
3.1.1.8 Setup waste staging area on and external to the Peninsula .............. 17
3.1.1.9 Stage construction materials onsite (i.e. gravel, cap material, Aqua
dams, aqua block, etc.) .................................... 17

3.1.2 .................................
Initial Removal of Impacted soils and debris ...........................
17
3.1.2.1 Target removal of TSCA material ....................... 17
3.1.2.2 ......................
Clear vegetation and construct access road to cove area ................ 18
3.1.2.3 Inspect and construct soil and sediment control structures at cove .... 18
3.1.2.4 Remove debris and soils above the waterline at the base of the
Powerhou se ................................................................................... 18
BHE Environmental, Inc. i Defining Environmental Solutions
3.1.2.5 Install temporary cover system over the area of removed material at
the base of the Powerhouse above the waterline ....................................... 18
3.1.2.6 Transport generated materials to the designated waste management
area for shipping and disposal .............................................................. 20
3.1.3 Removal of impacted sediments below the waterline in the cove
area ........................................... ........................... 20
3.1.3.1 Stage equipment and materials needed to address materials below
the waterline ................................................................................. 20
3.1.3.2 Close the APGI boat launch and limit motorized boating traffic in the
Falls Reservoir ................................................................................
20
3.1.3.3 Lower water level in the Falls Reservoir to maximum practical extent 20
3.1.3.4 Install an isolation barrier around submerged impacted sediments
within the cove area ......................................................................... 22
3.1.3.5 Remove exposed sediments and debris to practical extent .............. 23
3.1.3.6 Transport generated materials to the designated waste management
area for shipping and disposal .............................................................. 25
3.1.3.7 Place capping material over the excavated area within the cove....... 25
3.1.3.8 Remove isolation barrier system .............................................. 25
3.1.3.9 Raise Falls Reservoir to normal level ........................................ 26
3.1.4 Finish final cover system above and below water line ................ 26
3.1.5 Final site restoration ....................................................... 26
3.1.6 Remove all construction equipment and other structures from the
Powerhouse and peninsula ................................................ 26
3.1.7 Off site cleaning of construction equipment (at Old Brick Landfill) 26
3.1.8 Management of containerized water generated during the
removal action .............................................................. 27
3.1.9 Decommission waste and water management areas .................. 27
4.0 PROJECT EXECUTION ............................................................................27
4.1 Project Schedule ......................................................................... 27
4.2 Access to Construction Area ........................................................... 27
5.0 WASTE MANAGEMENT ........................................................................... 28
5.1 Waste management Summary .......................................................... 28
5.1.1 Non-Hazardous Solid Wastes .............................................. 29
5.1.2 TSCA ..........................................................................
29
5.1.3 Hazardous Solid Wastes .................................................... 29
5.2 Approved Disposal Facility .............................................................. 31
5.3 Waste Manifest Tracking ................................................................ 31
6.0 POST REMEDIATION COVER SYSTEM INSPECTION ..........................................32
BHE Environmental, Inc. ii Defining Environmental Solutions

LIST OF FIGURES
Figure 1-1. General Site Map, Narrow's Dam ................................................................ 2
Figure 1-2. Project Site Map, Narrow's Dam Et Cove ....................................................... 3
Figure 1-3. Narrow's Cove Impacted Area ...................................................................
5
Figure 3-1. Yadkin Low Water River Soundings, Depth (ft) - Water Elevation 362 feet ............. 14
Figure 3-2. Yadkin River Golden Rod potential habitat area ............................................ 16
Figure 3-3. Probable Narrow's Peninsula Access Road and Barge Landing Area ...................... 19
Figure 3-4. Narrow's Cove - Aquadam Schematic ......................................................... 24
Figure 3-5. Typical Cover Cross-Section .................................................................... 25
Figure 5-1. Possible Haz-Waste Storage Areas ............................................................ 30
LIST OF TABLES 8t PHOTOS
Table 3-1: Yadkin Water Elevation Information
Photo # 1: Impacted Sediment
Photo # 2: Cove
APPENDICES
APPENDIX A: AQUABLOCS MATERIAL DESCRIPTION Et SPECIFICATION
APPENDIX B: COE NATIONWIDE PERMIT PROGRAM (NWP) - WATER QUALITY CERTIFICATION #3696
APPENDIX C: COE NATIONWIDE PERMIT PROGRAM PRECONSTRUCTION NOTIFICATION FORM
APPENDIX D: JOINT COE / DWQ NATIONWIDE PERMIT PROGRAM CERTIFICATION OF COMPLETION
FORM
APPENDIX E: ECOLOGIC LETTER VARIFYING YADKIN RIVER GOLDENROD POTENTIAL HABITAT
SURVEY
APPENDIX F: YADKIN RIVER GOLDEN ROD MITIGATION PLAN
APPENDIX G: SEDIMENT TRAP DETAIL DRAWINGS
BHE Environmental, Inc.
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1.0 INTRODUCTION
1.1 PURPOSE
The purpose of this work plan is to outline the technical approach for the remediation of lead
and PCB impacted soils, sediments, and debris at base of the Powerhouse in the Narrow's
Dam Cove. The remedial objective is to reduce or eliminate potential exposure from the
impacted materials to the environment. The remedial objective will be achieved by removing
impacted materials to the practical extent and installing a barrier or cover on any materials
that cannot be effectively removed. Removal of impacted material to the practical extent is
the remedy and the installation of a barrier or cover is a precautionary measure. This
remedial project will be completed under an Administrative Agreement with the North
Carolina Department of Environment and Natural Resources (NCDENR).
1.2 BACKGROUND
The Narrow's Dam Cove is an isolated area adjacent to the Narrow's Dam Powerhouse. The
Powerhouse is owned and operated by Alcoa Power Generating, Inc. (APGI) and is located on
the Yadkin River in Montgomery County approximately two miles northeast of the town of
Badin, North Carolina. Figure 1-1 shows Alcoa's Badin Works, the Narrow's Dam, Narrow's
Reservoir (Badin Lake), and the Falls Reservoir (section of the Yadkin River downstream of
the Narrow's Dam.
The Narrow's Dam and Powerhouse were constructed in the early 1900's. During the facilities
90 years of operation, material from the Powerhouse working deck was lost over the back to
an isolated area adjacent to the cove. The Powerhouse working deck is approximately 35
feet higher in elevation than the cove area. Materials such as sandblasting grit, electrical
equipment, broken glass, metal, brick and other miscellaneous rubble are found in a debris
pile at the base of the Powerhouse adjacent to the cove. The debris pile extends from the
Powerhouse into the cove. Characterization of the debris pile has shown it to be impacted
with lead and PCBs.
The Narrow's Dam Cove is a manifestation of the construction of two by-pass tunnels used to
divert water during the construction of the dam. Some of the rock spoil from the
construction of the by-pass tunnels was piled on a rock ridge along the southeastern side of
the Powerhouse. The piled rock forms a peninsula which creates an isolated cove at the
mouth of the two by-pass tunnels. Figure 1-2 shows the cove and surrounding features. The
cove is bordered by a shear rock face cliff on the north, a nearly vertical bluff on the east,
and the rock peninsula on the western and southern edges. The Cove's water surface is only
0.15 acres.
The water level in the cove is interconnected to the Falls Reservoir. The water is able to
flow in and out of the cove through a five feet wide channel on the south end of the cove and
through the pore space in the rock spoil on the peninsula. The northern portion of the Yadkin
River upstream of the Falls Dam is called the Falls Reservoir. The Falls Dam is located two
grit tnvironmental, Inc. 1 Defining Environmental Solutions
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miles downstream of the Narrow's Dam. The Falls Reservoir surface elevation is controlled by
water being released for power generation at the Narrow's and Falls Dam. Surface water
levels in the Reservoir and Cove normally vary between two and five feet. During extreme
weather conditions or emergency situations the water level can be outside of the normal
range. Regardless of the water elevation, the peninsula and rock spoil restrict surface water
communication between the Falls Reservoir and the cove.
Access to the cove area from the Powerhouse and Reservoir is limited and difficult. The
Powerhouse is located on the eastern side of the Reservoir. A single lane bridge, which is
approximately 10 feet wide, transverses the Reservoir from the Powerhouse parking lot to the
Powerhouse. The Powerhouse parking lot is a 7,650 sq ft (175 ft. X 45 ft) fenced area on the
west side of the Reservoir. A small working deck is assessable at the back of the Powerhouse.
Access to the Cove is possible from this working deck. Access to the cove is also possible
from the Reservoir. The Reservoir access requires boat travel from a boat launch area
approximately two miles downstream and entrance to the cove is achieved by traversing the
rock peninsula created from the construction of the by-pass tunnels. It is not possible to get
a boat into the cove directly from the Reservoir.
The Cove has undergone three phases of investigation that were completed in 2001, 2003,
and 2005. The comprehensive findings of the three phases are outlined in the Investigation
Summary Report, Alcoa Power Generating, Inc. - Yadkin Division, Narrow's Dam Powerhouse,
February 2006. The investigations indicate:
1. Soils impacted by PCBs above 50 mg/kg are located in two areas. Figure 1-3 identifies
these two areas. The total estimated volume of this soil is 6 cubic yards. The
targeted PCB soils in these two areas will be removed and segregated first.
2. Soils impacted by lead above the NCDENR Soil Remediation Goal and PCBs below 50
mg/kg are localized to the debris pile immediately southeast of the Powerhouse, and
cover a surface area of approximately 3,200 square feet. The debris pile is relatively
shallow and bounded vertically by the rock that forms the peninsula. Figure 1-3
identifies the boundary of the impacted soil. The total estimated volume of soil
targeted for removal is 111 cubic yards.
3. Sediments below the average pool depth of the cove are impacted by lead above the
NCDENR Soil Remediation Goal and PCBs below 50 mg/kg and are localized to the fan
of debris located in the northwest corner of the cove. The thickness of the fan of
debris is generally less than two feet and bounded by the rock bottom of the cove.
Figure 1-3 identifies the boundaries of the impacted sediment. The total estimated
volume of sediment targeted for removal is 60 cubic yards.
BHE Environmental, Inc. 4 Defining Environmental Solutions
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2.0 TECHNICAL APPROACH OVERVIEW AND ARAR ASSESSMENT
2.1 TECHNICAL APPROACH OVERVIEW
This section provides an overview of the technical approach to remediate the impacted
materials in the Narrow's Cove. A more detailed description of the technical approach is
provided in Section 3.0.
1) Mobilization and Site Preparation
i. Identify and mark the Yadkin River Golden Rod (YRGR) habitat area.
ii. Barge system preparation and peninsula landing area construction.
iii. Setup water management tanks (<20,000 gallons) and lay secondary
contained pipe from the cove to tanks.
iv. Mobilize equipment to the peninsula by barge.
v. Setup erosion and sediment control systems (i.e. silt fence & hay bails).
vi. Install two sediment traps in the Falls Reservoir.
vii. Setup material management systems (i.e. vac or conveyor) on the
peninsula or back of the powerhouse.
viii. Setup waste staging area on and external to the peninsula.
ix. Stage construction materials on and external to the peninsula (i.e.
gravel, cap material, Aqua dams, aqua block, etc.).
2) Initial Removal of Impacted soils and debris
i. Target removal of TSCA material.
ii. Clear vegetation and construct access road to cove area.
iii. Inspect soil and sediment control structures at cove.
iv. Remove debris and soils above the waterline at the base of the
Powerhouse.
v. Install temporary cover system over the area of removed material at the
base of the Powerhouse above the waterline.
vi. Transport generated materials to the designated waste management
area for shipping and disposal.
3) Removal of impacted sediments below the waterline in the cove area
i. Stage equipment and materials needed to address impacted sediments.
ii. Close the APGI boat launch and limit motorized boating traffic in the
Falls Reservoir.
iii. Lower water level in the Falls Reservoir to maximum practical extent.
iv. Install an isolation barrier around submerged impacted sediments within
the cove area.
1. Pump water from the isolated area in to the water dam or
temporary storage tank
v. Remove exposed sediments and debris to practical extent.
BHE Environmental, Inc. 6 Defining Environmental Solutions
vi. Transport generated materials to the designated waste management
area for shipping and disposal.
vii. Place capping material over the excavated area within the cove.
viii. Remove isolation barrier system.
ix. Raise Falls reservoir to normal level.
4) Finish final cover system above and below water tine.
5) Final site restoration.
6) Remove all construction equipment and other structures from the Powerhouse
and peninsula.
7) Off site cleaning of construction equipment (at Old Brick Landfill).
8) Management of containerized water generated during the removal action
i. Collect water sample from containerized water.
ii. If necessary treat and then discharge containerized water to the Falls
reservoir.
9) Decommission waste and water management areas.
The sequencing of tasks will be as follows:

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7 Decon Equipment td _
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2.2 ARAR ASSESSMENT
Alcoa is seeking an Administrative Agreement with the North Carolina Department of
Environment and Natural Resources (NCDENR), which will require that Alcoa meet the general
requirements of relevant environmental regulations without formally obtaining all permits for
this project. In some cases, the Administrative Agreement will supersede the permit process.
The following Applicable or Relevant and Appropriate Requirements (ARAR) assessment
reviews both the federal and state (North Carolina) regulations. The ARAR assessment
evaluates both permitting and notification issues.
BHE Environmental, Inc. 7 Defining Environmental Solutions
2.2.1 Environmental Issues
The specific environmental issues covered in the ARAR assessment include:
• Air;
• Waste Management (both non-hazardous and hazardous solid waste issues);
• TSCA (Toxic Substances Control Act); and
• Clean Water Act (Section 404 Nationwide Permit, Section 401 General Water Quality
Certification, National Pollution Discharge Elimination System (NPDES) and SPCC (Spill
Prevention, Control, and Countermeasures));
2.2.1.1 Air Quality Issues
Regulation: State of North Carolina - 15A NCAC 02D (Control of Fugitive Particulates / Dust)
Discussion £t Administrative Control: No volatile air emissions are anticipated for this
project. Fugitive dust emissions from the construction activities (i.e. access road
construction) are potentially an issue. To meet the general requirements of the regulation,
water and a means of spraying for dust control will available on site to suppress dust if it
becomes an issue.
2.2.1.2 Waste Management Issues
Regulation: State of North Carolina Solid Waste Requirements - 15A NCAC 13B
Discussion £t Administrative Control: The Contractor will be responsible for solid waste
storage, collection, and disposal. 15A NCAC Chapter 13B .0103(a), (b), and (e) - (g) requires
that solid waste management must meet the following specific conditions:
1. Solid waste must be stored, collected, transported, separated, processed, recycled,
recovered, and disposed of according to the Division rules, and
2. Solid waste may not be disposed of in or on waters that results in solid waste entering
waters or being deposited upon lands of the state.
In addition, 15A NCAC Chapter 13B .0104 states that solid waste will also include remediation
debris & any brush along with common trash. To meet the general requirements a waste
management plan will be prepared that covers solid waste material handling requirements.
Regulation: State of North Carolina Hazardous Waste Requirements (RCRA)
Discussion & Administrative Control: In accordance with RCRA (40 CFR 262 - Hazardous
Waste Generators Requirements), the Contractor must ensure that excavated hazardous
waste material is property disposed. A waste management plan will be prepared that will
cover hazardous waste material handling requirements. The waste management plan will
BHE Environmental, Inc. g Defining Environmental Solutions
incorporate the Contractor's project specific construction techniques used to execute this
Remediation Work Plan.
2.2.1.3 TSCA Issues
Regulation: Toxic Substance Control Act (TSCA) 15 U.S.C. 2601 et seq.
Discussion Et Administrative Control: In accordance with the TSCA, the Contractor must
ensure that excavated /dredged PCB waste materials are properly disposed of in accordance
with federal and state law. PCB material at concentrations greater than 50 mg/Kg, will be
regulated as TCSA wastes. A waste management plan will be prepared that covers TSCA
waste material handling requirements.
2.2.1.4 Clean Water Act Issues
Regulation: Section 404 of the Clean Water Act / 33 CFR 330 (Nationwide Permit Program)
Section 401 General Water Quality Certification
Discussion Et Administrative Control: The Nationwide Permit Program (33 CFR 330) was
established by Section 404 of the Clean Water Act. The program is administered by the US
Army Corps of Engineers with the nearest COE office being the COE Wilmington District (1-
910-251-4625). Since Alcoa is seeking an Administrative Agreement with NCDENR, the use of
NWP #38 - Cleanup of Hazardous and Toxic Waste is applicable for this project. NWP #38
covers activities required to effect the containment, stabilization, or removal of hazardous or
toxic waste materials that are performed, ordered, or sponsored by a government agency
with established legal or regulatory authority provided the permittee notifies the District
Engineer in accordance with the "Notification" general condition. Court ordered remedial
action plans or related settlements are also authorized by this NWP. The general conditions
for NWP #38 are provided in Appendix B. The COE Pre-construction Notification Form is
provided in Appendix C and the DWQ Certification of Completion is provided in Appendix D.
In addition to NWP #38, Alcoa will meet the requirements of the State of North Carolina's
Water Quality Certification (WQC) #3696 (Cleanup of Hazardous and Toxic Waste). WQC
#3696 is a general North Carolina certification for projects that are eligible for Corps of
Engineers NWP #38. A separate notification to the North Carolina Division of Water Quality
(DWQ) is required. The WQC #3696 is provided in Appendix B.
The Narrow's tailwater area is known to support the Yadkin River Golden Rod (YRGR)
(Solidago plumose). This species is a federally listed "candidate species" and is listed S1
(critically endangered in the state) by North Carolina. Alcoa has coordinated with the North
Carolina Wildlife Resources Commission (WRC) and the United States Fish and Wildlife Service
(USFWS) and has completed a plant habitat survey in February 2009. Since the location of the
individual plants is variable and may change from year to year, the survey provided the
location of potential YRGR habitat areas. The potential habitat area was reviewed and
incorporated in the remediation plan to eliminate the potential for any impact. Although it is
not planned, if plants on the peninsula are impacted during the remediation by equipment
laydown, barges, roads, or general foot traffic, a mitigation plan has been developed and will
be implemented. The mitigation plan is provided in Appendix F.
BHE Environmental, Inc. 9 Defining Environmental Solutions
2.2.1.5 Water Quality / NPDES Issues
Regulation: North Carolina Sedimentation Pollution Control Act of 1973, North Carolina
Administrative Code Title 15A, North Carolina Department of Environment Et Natural
Resources Chapter 4 - Sedimentation Control, NC General Statute 143 Article 21A. NPDES
General Storm water Permit No. NCG010000, NC General Statutes 113A Article 4 and NC
General Statute 113A - 54.1 (Surface Water)
Discussion Et Administrative Control: Alcoa will obtain an Administrative Agreement with
either EPA or the State of North Carolina that requires Alcoa meet the substantial
requirements of the various permit provisions of the NPDES General Storm Water Permit No.
NCG010000, without having to actually obtain the NPDES Permit. One of the provisions
requires that the Contractor control the impact of erosion and sedimentation to nearby
waters of the state. Thus, prior to the commencement of land disturbing activities (i.e.
clearing ft grubbing, road construction, remediation, debris pile removal, and ongoing road
traffic), it will be necessary to erect a barrier between the Falls Reservoir and those land
areas being disturbed as part of the project. These barriers may consist of silt fences, straw
bales, plastic sheeting runoff diversion fences, and/or erosion control matting.
The monitoring required includes qualitative observation at the discharge points, access road,
and any other disturbed land area that could result in storm water runoff impact to the Falls
Reservoir will be conducted as part of this work plan. Figure 3-3 shows the location of
proposed sediment barriers.
2.2.1.6 SPCC (Spill Prevention, Control and Countermeasures) Issues
Regulation: 40 CFR 112 (Oil Pollution Prevention / SPCC) Et the North Carolina Oil Pollution Et
Hazardous Substance Control Act (North Carolina Administrative Code Article 21A / G.S. 143-
215)
Discussion £t Administrative Control: In accordance with 40 CFR 112 and the North Carolina
Oil Pollution Et Hazardous Substance Control Act, the Contractor shall not exceed a total
quantity of 1,320 gallons of diesel, gasoline, motor oil, tube oil, etc. storage at any time.
Therefore this regulation is not applicable, but all tanks, drums, containers, etc. that are
used will be secondarily contained. In addition, we will minimize activities (i.e.
maintenance) associated with regulated materials.
Should an accident involving a spill occur the Contractor shall report to the NC DENR Central
Office or the NC DENR Mooresville Regional Office, any oil or hazardous substance release /
discharge which may endanger human health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee or owner/operator became
aware of the circumstances. A written report shall also be provided within 5 calendar days of
the time the permittee or owner/operator becomes aware of the circumstance. The written
report shall contain a description of the noncompliance, its cause, the noncompliance period,
anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate
and prevent reoccurrence of the noncompliance.
twit tnvironmental, Inc. 10 Defining Environmental Solutions
Regulation: 40 CFR 112 (Oil Pollution Prevention) Et National Contingency Plan
Discussion £s Administrative Control: The Contractor shall maintain a spill containment kit
onsite consisting of absorbents, pads, booms, socks, etc. at a minimum. If a spill occurs,
Contractor will notify Alcoa and the local authorities (if necessary).
2.2.2 Notifications Et Public Review
The specific notification and public review issues covered in the ARAR assessment include:
¦ North Carolina Department of Environment Et Natural Resources (NC DENR), Division of
Waste Management
¦ NC DENR Division of Water Quality
¦ NC DENR Division of Parks and Recreation
¦ North Carolina Natural Heritage Program
¦ North Carolina Dam Safety
¦ U.S. Forest Service
¦ U.S. Fish and Wildlife
¦ U.S. Army Corps of Engineers (COE)
¦ U.S. Coast Guard (USCG) Notification
¦ Federal Energy Regulatory Commission (FERC) and associated contacts listed below:
o North Carolina State Clearinghouse
o North Carolina Wildlife Resources Commission
o North Carolina Department of Cultural Resources
o NC DENR Division of Water Resources
o Montgomery County
o Historic Preservation Management Plan
2.2.2.1 NC DENR, Division of Waste Management
Regulation: NC DENR, Division of Waste Management requirement for Administrative
Agreement
Discussion Et Administrative Control: Alcoa has been working with the Division of Waste
Management on establishing an Administrative Agreement for this project. In Addition, Alcoa,
via submittal of the Final Work Plan, will provide NC DENR, Division of Waste Management 90
days advance notification of this project. The plan will be submitted for review and approval
to Cheryl Marks, Hydrogeologist, Superfund Section, Division of Waste Management, (919)
508-8465.
2.2.2.2 NC DENR Division of Water Quality
Regulation: Section 401 General Water Quality Certification (WQC) #3696
Discussion Et Administrative Control: The COE Nationwide Permit Program requires
notification to the NC DENR Division of Water Quality (DWQ) in order to obtain a certification.
Alcoa has been working with Ian McMillan with the DWQ in clarifying project specifications in
BHE Environmental, Inc. 11 Defining Environmental Solutions
order to obtain the certification. The plan will be submitted to Ian McMillan
([e-mail]) for final review and approval 90 days prior to the anticipated start
of the project.
2.2.2.3 NC Dam Safety Notification
Regulation: State of North Carolina Title 15A Subchapter 2K (NC Dam Safety Law of 1967)
Discussion Et Administrative Control: In keeping with the historical practice of notifying NC
DENR Division of Land Resources regarding work being completed in and around the Narrow's
Dam, Alcoa will notify Mr. Max Fowler, P.E., State Dam Safety Engineer at NC DENR Division
of Land Resources a minimum of 2 weeks in advance of the start of field work. Alcoa will to
contact Mr. Fowler at [phone] or in writing at DSWC, DEHNR Regional Office 919 N.
Main Street, Mooresville, NC 28115 with regard to working near the Narrow's Dam.
2.2.2.4 U.S. Army Corps of Engineers (COE) Notification
Regulation: 33 CFR Part 330 (Nationwide Permit Program)
Discussion Et Administrative Control: In accordance with 33 CFR 330 Section C, General
Condition (GC) # 13, the Contractor must submit a Pre-Construction Notification (PCN)
Application Form to both the COE District Office and the North Carolina DENR Department of
Water Quality (DWQ) Office and allow for a 30 day comment period. The plan and the PCN
Application form will be submitted 90 days prior to the anticipated start of the project to
allow for responses to be made to comments. Upon completion of all work, in accordance
with GC # 14, a Certification of Completion / Compliance must be submitted to the DWQ
office. Refer to Appendix B for the GCs # 13 and # 14, Appendix C for the Pre-Construction
Notification Form, and Appendix D for the Completion Certification Form.
2.2.2.5 U.S. Coast Guard Notification
Regulation: 33 CFR Part 6 (Protection Et Security of Vessels, Harbors, Et Waterfront Facilities)
Discussion Et Administrative Control: The Contractor must provide a 48 hour advance
notification to the USCG COTP regarding the need for vessels (i.e., boats or barges) on the
Falls Reservoir downstream of the Narrow's Dam. The USCG COTP is located at MSU (Marine
Safety Unit) Wilmington, NC (Ph 1-910-772-2191).
2.2.2.6 Federal Energy Regulatory Commission (FERC) Notification
Regulation: Energy Policy Act of 2005
Discussion Ei Administrative Control: Based on the ARAR review it does not appear that
there is anything that requires FERC approval. Alcoa does intend to provide FERC 30 days
advance notification regarding the possible drawdown of the Falls Reservoir during
remediation activities. As part of the notification Alcoa will provide a copy of this Work Plan
to the FERC Regional Office (3125 Presidential Parkway, Suite 300 in Atlanta, GA 30340 (Ph 1-
BHE Environmental, Inc. 12 Defining Environmental Solutions
770-452-3800)) as well as the FERC Federal Office (1200 G St NW, Washington, DC 20005 (1-
202-383-2141)).
3.0 TECHNICAL APPROACH
3.1 IMPLEMENTATION STEPS
3.1.1 Mobilization and Site Preparation
Access to the Narrow's Peninsula and Cove is a significant challenge. There are two possible
routes:
1. Powerhouse Route
A narrow single lane bridge provides access to the Powerhouse working deck level. In the
southeast corner of the Powerhouse, there is a rolling garage door that provides access to
a concrete porch (approx. 10 ft X 20 ft). The back porch is approximately 35 feet above
the nearest impacted soil area. The soil area is sloped away from the porch towards the
water. The elevation of the water is approximately 48 feet below the elevation of the
porch. It may be possible to vacuum or hoist impacted material from the peninsula to the
Powerhouse working deck. It is possible to access the peninsula from the back porch via a
ladder that can be extended down approximately 35 feet to the nearest point. Because of
ladder safety concerns and the peninsula's steep slopes, ladder access is not preferred.
2. Falls Reservoir Route
The peninsula and cove can be accessed via water transport along the Falls Reservoir.
There is a boat launching ramp approximately 2 miles south of the Narrow's cove. Figure
3-1 provides depth information for the critical portions of the Falls Reservoir. The
sounding data indicates that access to the peninsula with small barges is feasible. Access
via barge requires careful management of the water elevations and avoidance of several
rock outcrops. Direct access to the Cove via boat is not possible because the channel that
connects the Falls Reservoir to the Cove is very narrow (approx. 5 ft wide) and shallow
(approx. 1 ft deep).
Depending on the work requirements, both routes may be used. The Falls Reservoir route
provides the best access to get workers, equipment, materials, etc. to the Peninsula and
the Cove. The Powerhouse route provides secondary emergency egress and access for
soil/sediment removal. Both routes could be used to haul material away from the
remediation area. Regardless of the material transport route, the project's intent is to
minimize impacts/exposure to the water.
3.1.1.1 Identify and mark Yadkin River Golden Rod (YRGR) potential habitat area
On February 19, 2009, BHE personnel accompanied Moni Bates of Ecologic to the peninsula to
identify potential habitat for the YRGR. Ms. Bates is an endangered species specialist with
significant YRGR experience. The survey identified a potential habitat area that
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is shown on Figure 3-2. The area is comprised of exposed, cracked bedrock with fissures;
typical for YRGR habitat. The area is located on the western third of the peninsula.
Appendix E contains a letter from Ecologic verifying the results of the habitat assessment
shown in Figure 3-2.
The potential habitat area will be well marked by the Contractor. Per the plan, no
construction activities will occur within this area. However, if encroachment in the area is
unavoidable, the steps outlined in the Mitigation Plan will be followed.
3.1.1.2 Barge system preparation and peninsula landing area construction
It will be necessary to use a floating barge system to transfer materials and equipment to the
work site. The system will need to be constructed at the local public access landing located
roughly one mile downstream from the Narrow's Dam site. The public access landing has
been used as an assembly point for barge systems in the past. No modifications to the
existing landing are expected in order to assemble or launch the barge system.
In stream construction will be necessary at the peninsula in order to establish a landing area
where materials and equipment can be safely loaded and unloaded. The construction
technique (i.e. bridging, rock, etc.) will be determined by the Contractor. All materials used
in constructing the landing will have to be removed at the end of the project.
3.1.1.3 Setup water management tanks (<20,000 gallons) and lay secondary contained
pipe from cove to tanks
During the removal of the sediment in the cove water management will be required.
Approximately 20,000 gallons of water can be managed in frac tanks and water dams. The
location of the tanks will depend on Contractor preference and logistics. Possible locations
include the Powerhouse parking lot, the Powerhouse working deck, or the peninsula. The
water dams will be located in the cove area.
3.1.1.4 Mobilize equipment to peninsula by barge
The initial trip from the boat landing to the peninsula will include all equipment, materials
and support personnel necessary to construct the peninsula landing area referred to in section
3.1.1.2. Additional trips from the public access landing to the peninsula will be made in
order to bring additional equipment necessary for remedial activities.
3.1.1.5 Setup erosion controls and silt curtain systems
Prior to any construction activities on the peninsula, a silt curtain will be installed in the
outlet from the cove to the Falls Reservoir as shown in Figure 3-4. Other erosion controls,
including silt fence, hay bails, etc., will be installed along the bank of the cove and Falls
Reservoir as shown in Figure 3-4.
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3.1.1.6 Install two sediment traps in Falls Reservoir
Per the request from the NCDNR, two sediment traps will be installed in the Falls Reservoir to
collect suspended sediments. The traps are intended as a precautionary measure that would
allow for a quantitative measure of impacts to the downgradient waters if a release were to
occur. As planned, the construction methods prevent sediment from reaching these traps but
if adequate sediment is collected (i.e. greater than 10 grams dried weight), a sample will be
taken and sent to a lab to be analyzed for PCB's and lead. The locations of the sediment
traps can be seen in Figure 3-3. Two example sediment trap detail drawings are provided in
Appendix G. These examples come from generally accepted sediment collection methods
provided in the Handbook of Techniques for Aquatic Sediments Sampling: 2nd Edition, edited
by Alena Mudroch and Scott D. MacKnight, and the website:
http://www.wtdeift.ni/rnd/intro/ fields/ morphology/ pdf/H5-6-2-3_ Trap_samplers.pdf.
These sediment traps (or an approved equivalent) will be used by the Contractor.
3.1.1.7 Setup material management systems
The Contractor could potentially use a number of different systems (i.e. vac or conveyor) to
transport material from the peninsula to more accessible locations such as the Powerhouse
parking lot. Systems should be setup and tested to assure functionality prior to any impacted
material being removed.
3.1.1.8 Setup waste staging area on and external to the Peninsula
The Contractor has limited options for waste staging. As materials are removed, some of the
soils (i.e. TSCA soils) will require staging on the peninsula before transport to secondary
waste staging areas. Possible locations for waste staging include the Peninsula, the Narrow's
Dam parking lot, the boat ramp near the Falls Dam, and the Old Brick Landfill. After
Contractor selection and before the start of field work, the waste staging areas will be
finalized and outlined in a written Waste Management Plan.
3.1.1.9 Stage construction materials onsite (i.e. gravel, cap material, Aqua dams, aqua
block, etc.)
To the extent practical, all construction materials and equipment will be staged on site.
Because of the tight project schedule requirements all materials will be received prior to the
start of the project. Since the peninsula is mostly rock and large rubble, there is not much
material that can be used for construction (i.e. road building). Approximately 140 cubic
yards of road construction material (i.e. soil Et road rock) will be needed in order to construct
the access roads and equipment lay down areas. The materials can be staged on the
peninsula, at the boat ramp, or in the Powerhouse parking lot.
3.1.2 Initial Removal of Impacted soils and debris
3.1.2.1 Target removal of TSCA material
Figure 1-3 shows the location of impacted material that is above the normal water elevation.
The impacted material contains two areas that have PCB concentrations greater than 50
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mg/Kg and therefore their disposal will be regulated under TSCA. These areas are associated
with historical sample locations HA-1, HA-4, Et HA-11. Approximately 6 cubic yards of TSCA
material will be removed by hand before the general excavation begins. The TSCA material
will be managed in 55-gallon drums and disposed according to the waste management plan
discussed in Section 5.0.
3.1.2.2 Clear vegetation and construct access road to cove area
Following the installation of soil and sediment control devices, portions of the peninsula will
be cleared so that a temporary access road can be constructed. The cleared vegetation will
be segregated and removed from the peninsula before the removal of impacted material.
The access road will be constructed utilizing as much on site rock as possible. Only after this
material is utilized should other materials be used. The access road construction will not
encroach on the identified YRGR area. If encroachment does occur, activities outlined in the
Mitigation Plan located in Appendix F will take effect. The road will be constructed prior to
any remediation activities. The proposed location is depicted on Figure 3-3.
3.1.2.3 Inspect and construct soil and sediment control structures at cove
It is important to ensure that dry material being removed from above the water line does not
fall into the cove water. The first line of defense in eliminating suspended sediment from
reaching the water wilt be erosion control devices (i.e. sediment fence and hay bales) along
the water's edge. The second line of defense will be to limit the lowering of the Falls
Reservoir. The only time water discharges from the cove to the Reservoir is when the
Reservoir is lowered. Limiting the lowering the Reservoir can be accomplished by ensuring
that the Narrow's Powerhouse is by-passing water from Badin Lake into the Falls Reservoir.
The third tine of defense will be the two sediment traps that in the mouth of the cove (see
Figure 3-4).
3.1.2.4 Remove debris and soils above the waterline at the base of the Powerhouse
The lead impacted soils will be removed using a combination of small excavator, dry vacuum
removal, and hand digging. The lead impacted material is mixed with large rocks and
boulders, therefore complete removal is challenging but care will be taken to remove it to
the extent feasible.
It is anticipated that material will be transported for disposal in roll off boxes via barge
and/or over the one lane bridge from the Power House. Sampling, characterization, and
material disposal will be in accordance with Section 5.0 of this document.
3.1.2.5 Install temporary cover system over the area of removed material at the base
of the Powerhouse above the waterline
Following the removal of the lead contaminated soil above the water line and prior to the
removal of sediments below the water line, a temporary gravel cover will be installed over
the excavated area. This will stabilize the bank and enable the equipment to be moved
closer to the water's edge. The temporary cap will also prevent potential contamination of
the equipment tracks.
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3.1.2.6 Transport generated materials to the designated waste management area for
shipping and disposal
All soils impacted with lead will be removed from the peninsula prior to the start of sediment
removal. The soils will be moved to a designated waste management area as outlined in the
waste management plan described in Section 5.0.
3.1.3 Removal of impacted sediments below the waterline in the cove area
3.1.3.1 Stage equipment and materials needed to address materials below the
waterline
In preparation of sediment removal, all necessary equipment will be mobilized and staged on
the Peninsula. The excavation and vacuum equipment will already be mobilized. Since the
sediments will be mixed with water, dewatering and water management equipment will need
to be staged onsite.
3.1.3.2 Close the APGI boat launch and limit motorized boating traffic in the Falls
Reservoir
Prior to the next phase involving the lowering of the Falls Reservoir, motorized boat traffic
will be required to move to deeper water. Figure 3-1 shows the estimated Reservoir depths
and can be used to identify the deeper water zones. The reservoir bottom around the
peninsula is jagged rock and it is infeasible to leave boats/barges close to the peninsula when
lowering the water.
3.1.3.3 Lower water level in the Falls Reservoir to maximum practical extent
Managing the elevation of the water in the Yadkin River and the cove is critical to the success
of the project. Both coordination with the Narrow's Powerhouse and the Falls facility will be
required. The key elevation information and the corresponding effects are summarized in
Table 3-1.
Table 3-1: Yadkin River Water Elevation Information
Pond
Elevation (ft) Powerhouse Elevation
Terminology Description and Effects
370 Max This is the worst case high elevation. Water in
this range is hard to control and water traffic is
not possible.
364 Full Pond This is the normal high pond elevation during
normal operating conditions. Barge traffic and
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Pond Powerhouse Elevation Description and Effects
Elevation (ft) Terminology
boat traffic to the peninsula is feasible.
362 Low Pond This is the normal low pond elevation during
normal operation conditions. Barge traffic is
feasible but not preferred.
358 Low-Low Pond At this elevation the Powerplant looses cooling
water and power generation must cease.
Barge traffic is not possible.
355 Drain Level Because of ponding in the Yadkin river, this is
the lowest elevation that can be achieved by
manipulating the operating conditions at the
two power plants. This is the elevation
planned for sediment removal activities in the
cove. Any cove sediments below 355 would
likely be covered in-place. At this elevation
the water in the cove is isolated from the Falls
Reservoir. See Photographs # 1 ft 2.
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Photo #1 - Impacted sediment (shown at approximate water elevation 355 ft.)
3.1.3.4 Install an isolation barrier around submerged impacted sediments within the
cove area
Since the ability to isolate the area with water dams (i.e. Aqua-dam ®) is not known for
certain this plan allows for two options. The first option is to install two temporary Aqua-
dams0 (or equivalent) to isolate the impacted area. The dams will be installed in the by-pass
tunnel and in the northwest portion of the cove. Figure 3-4 provides a schematic of the area.
Personnel present at the site when the water was lowered to approximate elevation 355 ft.
reported that natural rock features in the northwest quadrant may make isolation of the area
possible. The installation of the dams includes:
1. Smooth/level portions of the bottom of the rock cove with a bentonite-sand mixture,
2. Place inflatable water dams in the tunnel and on top of the leveled areas,
3. Fill the Aqua-dams ® with the water from the isolated area,
4. Pump the remainder of the water from the isolated area into frac tanks,
5. Extract the impacted sediment.
Because of the rock and boulder bottom of the cove, water seepage could be significant. The
volume of water that would need to be managed to execute this task could be significant and
the storage volume will be limited. The total volume of water that could feasibly be
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Photo #2 - Cove (looking southeast at approximate water elevation 355 ft.)
managed is limited to approximately 20,000 gallons. It is estimated that two 10,000 gallon
frac tanks could be used.
Since the water being used to fill the dams is in contact with the impacted sediments, it will
be sampled as it is pumped into the water dams. A one gallon aliquot will be pulled every
500 gallons and placed into a 55 gallon drum. Assuming a maximum of 20,000 gallons of
managed water, the sample will be 40 gallons. This sample will be mixed thoroughly and
analyzed for NPDES discharge parameters. Because of the short duration of the sediment
removal step, the analysis will have to be completed using a one-day turnaround. This
sampling plan will ensure that the controlled release of the water from the water dams meets
discharge requirements. If the sample shows unacceptable levels of constituents, the water
will have to be treated prior to discharge into the cove.
If isolating the impacted sediments is not feasible, the second option calls to remediate the
unrecoverable sediments by installing a non-toxic clay cover material. An in-situ placement
of a composite aggregate like AquaBloc@ (or equivalent) will prevent potential impacts from
the sediments to the water or aquatic life. Detailed information regarding AquaBloc can be
found in Appendix A. The plan includes a two to three inch composite cover material
followed by two to three inches of protective crushed stone. Figure 3-5 provides a typical
planned section.
3.1.3.5 Remove exposed sediments and debris to practical extent
Following the lowering of the water elevation, the debris and sediment removal can be
completed more effectively. The materials will be removed by vacuum systems and by hand.
When the water is lowered to elevation 355 ft., the water in the cove is completely isolated
from the water in the Falls Reservoir. This minimizes the potential for suspended sediment to
reach the Reservoir but as discussed in Section 3.1.2.3 there will be two sediment traps
installed in the mouth of the cove for additional protection. The Powerhouse operational
managers have indicated that we have from approximately Friday afternoon through Sunday
evening to lower the water and perform the removal. If the isolation dams work, we
potentially have a longer period of time because work could continue after the water in the
cove is allowed to rise. It is estimated that 50 cubic yards of impacted material will be
removed.
Since the sediments being removed during this phase will be wet, dewatering or stabilization
of the material may be required in order to pass the paint filter test required for landfilling.
If dewatering is required, the decanted water will not be discharged until it has been
properly sampled and if necessary, treated. Since this work will be completed under an
administrative agreement, the project and any associated discharge will meet the standards
typically associated with an NPDES permit. If water discharge is required, sampling and
analysis will be completed before discharging water to the cove. The process may require
that the material be handled twice in order to transfer from the storage boxes to transport
containers on barges or in the Powerhouse.
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Cross - Section
Aquadam Note:
A - A' ry;. The natural rock feature along with the Aquadams will
be used to isolate the area containing the impacted
sediments. The water is 20,000 gallons) removed
"9 ad°" from the isolated area will be managed in frac tanks.
Be tonitet sand
_ teu?s Soil Erosion Note:
_ r1 The soil erosion control practices will follow North
Carolina's Erosion Ft Sediment Control Field Manual;
\ 1?,t \ specifically, section 6.2 regarding sediment fence (Siit
Fence). Wire reinforced fencing will be used.
N Figure 3-4: Narrow's Cove - Aquadam Schematic
W E
March 2009 Base Aerials: ENVIRONMENTAL
Feet Stanly County GIS Department
S Project No. 0990.105 20 0 20 Stanty County, North Carolina
L- I I- I
•
•
•
Approximate
Elevation Ift. i
2 • 3- stony
Protective Craver
r - 3' Compwte Cover
iAqua B" i
Uni-- uverabte Sediments
Figure 3-5. Typical Cover Cross-Section
3.1.3.6 Transport generated materials to the designated waste management area for
shipping and disposal
Following the dewatering and/or stabilization, the sediments will be moved to a designated
waste management area as outlined in the waste management plan described in Section 5.0.
3.1.3.7 Place capping material over the excavated area within the cove
A cover will be installed over the remediated area. The typical cover cross-section is shown
in Figure 3-5. The cover includes a two to three inch composite non-toxic clay capping
material (i.e. AquaBloc@ or equivalent) followed by two to three inches of protective crushed
stone.
3.1.3.8 Remove isolation barrier system
Following the cap construction, the water in the water dams will be released in a controlled
manner. As discussed in Section 3.1.3 the water will be sampled and managed accordingly.
The water dam structures will be removed from the cove and the sand/bentonite foundations
will be left in place.
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3.1.3.9 Raise Falls Reservoir to normal level
Following the removal of all equipment and tooling from the cove, the Reservoir can be
returned to its normal operating level.
3.1.4 Finish final cover system above and below water line
Section 3.1.2 calls for a temporary cover system over the remediated area that is above the
water line. Since the area will be used for access for the sediment remediation, the cover
system will likely need repair and final grading. The final layer of the cover system will be 2
to 3 inches of stone that will protect the area as well as minimize residual sediment erosion.
3.1.5 Final site restoration
All areas impacted by the construction activities shall be restored, as near as possible, to the
contours which existed prior to the commencement of the project. The exception will be the
constructed road. Since the peninsula is primarily rock, boulders, and cobbles it is reasonable
to leave the rock slopes and graded rock road in place. All sediment control systems, unused
construction materials, construction debris and miscellaneous refuse will be removed from
the Peninsula. Any materials (i.e. rock) used for grade transition from the water to the
peninsula will be removed from the water edge. All materials used in constructing the
docking area at the peninsula will be removed from the stream and bank, and restored to
pre-construction state.
3.1.6 Remove all construction equipment and other structures from the Powerhouse and
peninsula
After the Reservoir is returned to normal operating water levels the barge traffic can return
to the Peninsula to remove construction equipment and remaining construction materials. All
materials that may have come into contact with contamination must be placed in
containment boxes before transport over the Reservoir. If the Powerhouse working deck is
used for material transfer, it must also be cleaned and returned to its preconstruction
condition.
The Contractor will remove all soil and sediment controls prior leaving the site. The plan
includes leaving rock covered areas as part of the final cover therefore long term soil erosion
control structures are not applicable. The Contractor will also complete and file the Joint
COE/DWQ Nationwide Permit Programs Certification of Completion form provided in Appendix
D of this plan.
3.1.7 Off site cleaning of construction equipment (at Old Brick Landfill)
Before demobilizing equipment all construction equipment will be collected at the Old Brick
Landfill and inspected. All final cleaning will take place before the equipment is loaded for
transport.
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3.1.8 Management of containerized water generated during the removal action
Among the options for water management, was the use of frac tanks, poly tanks or other
similar devices. These devices will be located on the Powerhouse working deck, employee
parking lot or former Powerhouse foundation below parking lot. If these options are used the
water must be properly managed. As water is pumped from the Narrow's Cove into the tanks
it will pass through a 5 micron filter. Before discharge to the Reservoir, samples must be
collected and analyzed for PCB's using Method 8081 with a method detection limit (MDL) of 3
ppb. If PCB's are detected in the sample, the water will be re-filtered using a 1 micron filter
and sampled again. If the sample is non-detect it will be discharged directly to the Reservoir.
If it again fails, possible treatment technologies will be investigated or alternate disposal
locations will be considered.
3.1.9 Decommission waste and water management areas
As a final step, all waste and water management areas must be returned to their
preconstruction condition. All temporary fencing, secondary containment, miscellaneous
equipment, etc. must be removed and demobilized from the site. All proper sampling and
documentation must be collected in accordance with the Waste Management Plan described
in Section 5.0.
4.0 PROJECT EXECUTION
4.1 PROJECT SCHEDULE
One of the primary issues impacting the project schedule is the ability to manage the river
elevation. The power plant operation and seasonal precipitation could have a significant
impact on the success of the project. Based on historical operation and rainfall trends it is
recommended that this project take place in the summer or fall. In addition, the project
requires that the water be lowered to the maximum extent practical (approximately 355 ft.);
therefore site work involving lower of the water elevation will take place on the weekends.
Power generation requirements are lower on the weekend and the ability to manage water
levels in Falls Reservoir is much more practical. Alcoa expects that field work be completed
within five weeks of the start of project.
4.2 ACCESS TO CONSTRUCTION AREA
Access to the area in which the work will be performed is restricted. Workers can enter the
area by ladder on the southeast side of the power plant or via boat from the Falls Reservoir.
Equipment access to Peninsula is only available by barge via the Falls Reservoir. While
navigating in the river, the Powerhouse requires that constant radio communication be kept
with the Alcoa security gate. At a minimum, four clear and consistent status reports per day
are required to be made to the security personnel. These updates ensure that radio contact
is maintained and that communication to the Power Plant operators is available in the case of
an emergency.
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5.0 WASTE MANAGEMENT
This section outlines how waste materials will be characterized and managed during the
remediation of the Narrow's cove. The objectives are to minimize waste generation and
provide procedures to meet the requirements of the applicable state and federal solid and
hazardous waste regulations.
The Alcoa Power Generating, Inc. (APG) maintains an EPA Haz-waste Generator ID and a
waste management plan. The remediation tasks involving waste storage, transportation, or
disposal will be completed under the guidelines of the APG plan. The current plan will have
to be modified to adequately cover some of the activities and storage requirements of this
project. The plan will be revised before the start of the project.
Temporary waste storage is a critical component of this project. Because of the limited
access to the peninsula and cove, and the remedial options outlined in this work plan (i.e.
transport over water or transport across the one lane bridge), the temporary waste storage
area is not yet designated. As project plans are finalized and the Contractor is selected, the
revised APG waste management plan will require that temporary waste storage areas be
designated. At this time, there are three potential temporary waste storage areas. These
areas are shown on Figure 5-1 and include:
1. Parking Lot - Located on the west end of the one lane bridge leading to the
Powerhouse. This lot is used for Powerhouse personnel parking. The area is fenced
and could be used for temporary storage if material handling involves transportation
across the one lane bridge.
2. Boat Launch Ramp - Located approximately three miles downstream of Narrow's Dam.
The ramp is a public boat launch area. Temporary fencing and security would be
required. The location is a logical storage area if material is transported down the
river.
3. Old Brick Landfill - Located approximately one mile southwest from the Powerhouse
parking lot. The landfill is a Solid Waste Management Unit associated with Alcoa's
Badin Operations. The landfill cap area will not be used for temporary waste storage.
The containerized material will be stored at a secured area by the landfill. The
capped landfill area is fenced but there are other areas outside the fence near the
landfill (i.e. the soil borrow area) that could be used as temporary storage. These
adjacent areas would require the installation of a temporary fence.
5.1 WASTE MANAGEMENT SUMMARY
Existing data indicates that PCBs and lead have impacted the soils, sediments, and debris at
the site. TSCA, Hazardous Solid Waste rules, and Non-Hazardous Solid Waste rules will apply
to the management and disposal of the materials at the Narrow's Cove. Because of the sites
limited access and very limited storage area, the preferred characterization and disposal
strategy is to sample and profile the materials while they are in-situ and then immediately
dispose of the materials. Existing data can be used to support characterization and profiling
before the start of field activities. The exceptions will be the decontamination materials and
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PPE materials that will be handled in drums. These materials will likely be consolidated and
characterized as the project progresses.
5.1.1 Non-Hazardous Solid Wastes
The following non-hazardous solid waste streams will be generated during this project:
1) Soil, rocks, sticks, lumber, and vegetation
2) Construction Debris (plastic covering, material packaging, etc.)
3) General trash (paper, plastic, wood, etc.)
Native soils, rocks, and vegetation will be kept on the peninsula to the extent practical.
Attempts to contour and smooth surfaces will be made. General trash, construction debris,
and any remaining materials will be disposed. General trash will be collected in plastic bags
and transported to the Alcoa facility municipal trash dumpsters. The municipal trash is taken
to the local Stanly County sanitary landfill.
5.1.2 TSCA
The materials that could be subject to TSCA waste regulations are:
1) Contaminated soil;
2) Wash water from decontamination (decon) processes; and
3) Contaminated personal protective equipment (PPE).
In two areas, see Figure 1-3, the PCB concentrations exceed 50 mg/Kg and will have to be
managed as a TSCA waste. These same areas also contain lead at levels that could make
them hazardous waste. The technical approach calls for a targeted removal of these areas by
hand digging and placing the materials in 55-gallon drums. Approximately 5 cubic yards of
TSCA material is expected. All waste profiling and manifesting will take place prior to the
start of the project and the TSCA drums will be removed from the site immediately and
transported for disposal. Drums for wash water and contaminated PPE will be kept separate
from the contaminated soil.
5.1.3 Hazardous Solid Wastes
The materials that could be subject to hazardous waste regulations are:
1) Contaminated soil and sediments;
2) Wash water from decontamination (decon) processes; and
3) Contaminated personal protective equipment (PPE).
All hazardous excavated soils and sediments will be placed in waste material bins (i.e. vac
boxes located off of the peninsula or roll-off boxes located on the peninsula). All waste
BHE Environmental, Inc. 29 Defining Environmental Solutions
profiling and manifesting will be organized before the start of the project so that material
can be transported for disposal immediately upon removal from the peninsula.
Decontamination wash water will be placed in appropriate DOT approved 55-gallon drums,
treated as necessary and discharged in accordance with the requirements of the
Administrative Agreement. PPE and other miscellaneous trash that come into contact with
the contaminated material will be consolidated into appropriate DOT approved 55-gatton
drums and removed for disposal off-site.
5.2 APPROVED DISPOSAL FACILITY
Wastes generated during the completion of this project will be transported and disposed by
Alcoa current approved vendor. The current Contractor is:
Ashland Environmental
3930 Glenwood Drive
Charlotte, NC 28208
EPA ID#NC061263315
Tel: [phone]
Fax: [phone]
5.3 WASTE MANIFEST TRACKING
Since Alcoa Powerhouse has an active management plan for the transportation and disposal of
non-hazardous and hazardous waste, the existing EPA ID number for the facility will be used.
The following processes will be used to track waste generated by this project:
1) Ensure that wastes are properly characterized and documentation of the
characterization is kept in accordance with 40 CFR 5262.40 or equivalent regulations.
2) Hazardous waste manifests are to be used for hazardous waste and non-hazardous
waste manifests or appropriate Bill of Lading will be used for other wastes.
3) Manifests shall be prepared by the Contractor Responsible Person and signed by a
designated Alcoa site representative. Any persons signing the manifest must be
trained as required by RCRA and DOT and must be knowledgeable of the
characteristics of the waste to certify correctness of the manifest information.
4) The person signing the manifest will be responsible for tracking the manifest copies
including the generator's copy with the signature of the initial transporter and the
returned copy received from the disposer.
5) The person signing the manifest will be responsible for submitting a discrepancy report
to EPA or the State regulatory agency should signed disposer copies of the manifests or
Certificates of Disposal not be received within the time limits provided in the
hazardous waste regulations (40 CFR 5262.42).
6) A copy of the Generator's Copy of the manifest will be submitted to the Alcoa Project
Manager as part of the final documentation.
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A
•
•
7) Alcoa's project manager will ensure that waste disposal reporting is accomplished in
accordance with applicable regulations including hazardous and industrial wastes.
6.0 POST REMEDIATION COVER SYSTEM INSPECTION
Three years after the completion of the remediation project, an inspection will take place in
order to assess the effectiveness of the installed cover system. The inspection will be
coordinated with NCDENR and include the following tasks:
1) Visual inspection of the cove area to determine if any noticeable damage has occurred
to the cover system;
2) Installation of three (3) to five (5) hand auger borings to assess the state of the Aqua
Bloc and cover.
Results from the inspection will be coordinated back to NCDENR within 30 days of completion.
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APPENDIX A:
AQUABLOCO MATERIAL DESCRIPTION 8t SPECIFICATION
BHE Environmental, Inc. Defining Environmental Solutions
AquaBlokTM
Technology
Overview
General Description
AquaBlokTM' is a patented, com-
posite-aggregate technology resem-
bling small stones and typically com-
prised of a dense aggregate core, clay
or clay sized materials, and polymers
(Figure 1). For typical freshwater prod-
uct formulations,AquaBlok's clay (seal-
ant) component consists largely of ben-
tonite day. However, other clay minerals
or clay-sized materials can be incorpo-
rated to meet project-specific needs, in-
cluding product use in saline environ-
ments. Other technology parameters
(particle size, relative day content, etc.)
can also be modified, as appropriate.
clay (sealant) layer
hyAntion
tlms
aggregate core
Figure 1.
Conflguradon of Typical
AquaBlok Particle.
General Functional Attributes
AquaBlok particles expand when
hydrated, with the degree of net vertical
expansion determined largely by the
formulation, application thickness,
and salinity of the hydrating water.
When a mass of particles is hydrated,
the mass transforms into a continu-
ous and relatively soft body of mate-
rial. Once developed, the hydrated
AquaBlok material can act as an ef-
fective physical, hydraulic, and chemi-
cal environmental barrier by virtue of
its: relatively cohesive and homoge-
neous character, low permeability to
water, and chemically active (sorptive)
nature.
AquaBlok can also provide sub-
strate for wetland vegetation and habitat
for macroi nverteb rate organisms, par-
ticularly when additional organic mate-
rial is provided, either as part of the
product formulation or as a surficial
dressing. The AquaBlok technology can
also deliver plant seeds to a targeted
area to facilitate wetland restoration
(see discussions related to the
SubmerSeed"m technology) as well as
chemical reagents for in situ treatment
of environmental contaminants.
Typical Applications
For many projects, AquaBlok use gen-
erally involves applying dry masses of the
product through water and across the sur-
face of contaminated sediments. In a matter
of days, a homogeneous and relatively co-
hesive, low-permeability cap - or barrier- is
formed between contaminated sediments
and the overlying water column and its in-
habitants. Barrier thickness will depend on
a number of factors, including: type of for-
mulation, water depth and salinity, applica-
tion thickness, number of lifts applied, and
sediment characteristics.
AquaBlok can also be used as a hy-
draulic/chemical barrierto the movement of
water- or sediment-borne contaminants into
underlying groundwater resources, or to
minimize leaching losses of water from res-
ervoirs or wastewater discharge basins.
Integration with Other Remedial
Approaches
Effective management of contaminated
sediments may involve remedial capping
exclusively or an integration of capping with
other management technologies like dredg-
ing and/or monitored natural recovery. In situ
capping may also be integrated within situ
sediment treatment technologies to affect
mass reduction of encapsulated contami-
nants.
Ecosystem Applicability
AquaBlok can be applied to impacted
wetland and deepwater aquatic ecosys-
tems characterized by either freshwater or
saline (including brackish) conditions.
Methods of Installation
AquaBlok can be handled and installed
using commonly available equipment and
technologies, including conveyors (e.g.
Photograph 1), excavators, cranes with
clamshell buckets, and even helicopters.
Other techniques could also be
used to effectively install AquaBlok-
based sediment caps. The most appro-
priate installation method(s) will depend
of a variety of factors including: water or
shoreline access, bank slope, surface
water characteristics and ecology, size of
the project area, and relative costs.
Costs
Costs for implementing an
AquaBlok-based capping remedy will
vary widely depending on a number of
project- and site-related factors that will
collectively dictate the most appropriate
AquaBlok formulation, cap design, and
method for cap installation. Project costs
will also depend on whether material is
packaged and transported to the project
site, or whether is is manufactured at or
near the site. Costs associated with
project planning and management; pre-
liminary laboratory studies (if required);
cap design; permitting; construction QC;
long-term performance monitoring; and
cap maintenance should also be consid-
ered.
If you think that the AquaBlok com-
posite particle system could be of use in
your remediation projects, call us. We
will be happy to discuss your project with
you, and help determine how the
AquaBlok technology could integrate into
a cost-effective solution.
For more information, including per-
formance test reports and case histo-
ries, call AquaBlok, Ltd. at (800) 688-
2649 or fax us at [phone].
You can also email us at:
[e-mail], or visit our
web site at www.aquablokinfo.com.
AquaBlok`
AquaBlok, Ltd.
3401 Glendale Avenue, Suite 300
Toledo, Ohio, U.S.A. 43614
Phone[phone]
Fax [phone]
e-mail: [e-mail]
hftp://www.aquablokinfo.com
AquaBlokTM is a trademark of AquaBlok, Ltd.
AquaBlokTM' composite particles are patented.
LAST REVISED 9/11/03
Photograph 1.
Product applied using barge-based
conveyor.
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AquaBlok=
TEST REPORT #6:
Hydrated-State
Physical
Characteristics of
Typical Freshwater
AquaBlokTM
Formulations
Background and
Purpose of Testing
Typical AquaBlokTM use involves
placing dry quantities of product
through water and across the sur-
face of contaminated sediments or
a leaking pond liner. In several
days, the material hydrates and ex-
pands, with particles coalescing
into an homogeneous and cohesive,
low-permeability barrier
The rate and degree of product
hydration and expansion depend on
AquaWk ApuaWk A3er
F_cefoye Hylratinn tirne? Hydration anz:
cxpan&on
rd ro xak
Figure 1. Development of
Typical AquaBlok Caps.
water salinity; thickness and formu-
lation of product; number of layers
applied; water depth; sediment type
and thickness; and other factors.
In this test report, information is
presented related to thickness, bulk
density, and moisture contents of
selected freshwater-compatible
product formulations in their hy-
drated state.
Methods
Numerous laboratory scale stud-
ies have been conducted to evaluate
product and cap development as a
function of variable product formula-
tion; substrate conditions; water-col-
umn thicknesses; dry product cover-
age rates; and testing scales.
Different results may be ex-
pected when testing at different
scales, and when using different wa-
ter-column and substrate conditions.
To facilitate a more direct compari-
son of relative physical characteris-
tics and performance of different
freshwater formulations, results pre-
sented here involve: (a) one test ves-
sel per dry product coverage rate per
formulation; (b) clear, -2.3 to 10-
gallon vessels, with basal areas of
-0.3 to 1.4 square feet; (c) a -1
inch-thick basal layer of gravel in
test vessels prior to AquaBlok place-
ment; (d) a hydraulic connection be-
tween the gravel layer and overlying
water column to promote basal hy-
dration of product; (e) placing even,
single lifts of dry product at rates
equaling -10, 20, 30, 40, or 50
pounds per square foot (lbs./SF); (f)
inundating dry product with freshwa-
ter (municipal tap water); and (g) col-
lecting baseline (initial) product
thickness measurements and
measurments over the next 5 to
23 days.
Photograph 1 illustrates typical
setup and development of product
Photograph 1.
Cap Development Studies
in testing vessels.
At the end of testing, multiple
sub-samples of hydrated material
are collected from each vessel (e.g.
Photograph 2) for determination of
mean net vertical expansion; wet
bulk density; and oven-dry moisture
content.
Mean net Photograph 2.
vertical expan- Core collection.
sion equals
mean hydrated
thickness/mean a.
initial thickness
x 100. Mean
wet bulk density
is determined by
weighing a hy-
drated sample
and also determining the volume of
water it displaced.
If needed, much larger testing ves-
sels can also be used to assess prod-
uct development in the laboratory
(Photographs 3 and 4).
Photograph 4.
12 ft. steel-
reinforced
acrylic column
b

1.4 Aqut??ok

Photograph 3.
8 ft. acrylic
column
AquaBlok-
TEST REPORT #2:
Typical Settling
Characteristics
of Individual and
Bulk Masses of
AquaBlok'" Particles
Through Water
Background and
Purpose of Testing
Variable quantities or types of
clay minerals can be used to
manufacture different
AquaBlokTM formulations to ac-
commodate site-specific needs
and overall project objectives.
The physical characteristics of
dry, bulk (mixed) AquaBlok
masses as well as discrete grain
size classes vary as a function
of product formulation (see Test
Report #1). Nevertheless, de-
spite differences in physical pa-
rameters like bulk density or
percent clay content between
formulations, bulk samples of
AquaBlok consistently display a
broad range of particle sizes as
well as predictably variable par-
ticle densities amongst the size
fractions (Test Report #1).
The settling velocity of any single
particle through a standing (non-flow-
ing) water column depends on a
particle's size, density, and shape,
and on water density and viscosity.
In general, the settling velocity of a
larger particle is higher than that of a
smaller particle of the same density
and shape. Quantitatively, Stoke's
law states that, under such condi-
tions, a particle's settling velocity is
proportional to the square of its ra-
dius (Day, 1965). Unpublished labo-
ratory research conducted in the Uni-
versity of Toledo's Civil Engineering
Department (UT) also indicates that
constant (terminal) settling velocities
for individual AquaBlok particles of
different sizes typically occur within
one foot of vertical descent through a
standing water column.
In contrast to the relatively predict-
able settling behavior of individual
particles, the settling behavior of bulk
(mixed composite) material masses
through water is typically much more
complex. Bulk material tends to settle
as a single entity rather than as indi-
vidual particles (Dortch, 1990). As a
mass settles, shear stresses and
drag forces develop at the mass/wa-
ter interface, resulting in the forma-
tion of turbulent eddies within and
around the settling mass. According
to Dortch (1990), a settling mass
tends to reach terminal velocity after
falling only a short distance.
The purpose of this laboratory test-
ing was two-fold: (1) to quantitatively
demonstrate average settling veloci-
ties of individual AquaBlok particles
of different sizes through small,
standing water columns, and (2) to
qualitatively demonstrate settling
characteristics of different bulk
AquaBlok masses through field-scale
water columns. Data related to the
settling characteristics of individual
AquaBlok particles provide a useful
theoretical basis for characterizing
the settling behavior of bulk
AquaBlok masses through standing
water columns, which is more rel-
evant to field applications.
In turn, laboratory observa-
tions
of settling characteristics of bulk
AquaBlok masses through non-
flowing water columns provides
baseline information that can be
used when modeling applica-
tions to flowing-water environ-
ments.
Methods
Settling Velocity of
Individual Particles
Ten representative AquaBlok
particles were chosen from se-
lected particle-size fractions of a
sieved, air-dry sample of a 5050
FW formulation (see Test Re-
port #1). Each particle was
dropped through a 31 inch-tall
standing column of municipal
tap water at room temperature
(-70° F) from just above the
water surface and the fall time
for each particle was measured
with a stop watch to the nearest
0.01 second.
Settling Characteristics of
Bulk AquaBlok Masses
The general settling character-
istics of bulk masses of 5050
FW AquaBlok were observed as
part of several large-scale set-
tling column studies. The studies
were conducted using a large
(23-inch x 23-inch x 12 foot-tall),
steel-reinforced plexiglas settling
column. Each AquaBlok mass
was applied from just above the
water surface by "pouring" the
material from a bucket. Relative
settling velocities of different
sized particles comprising the
bulk mass were qualitatively ob-
served, as was the general na-
ture of dispersion and move-
ment of the mass during de-
scent. (continued on back)
A+
APPENDIX B:
COE NATIONWIDE PERMIT PROGRAM (NWP) -WATER
QUALITY CERTIFICATION #3696
BHE Environmental, Inc. Defining Environmental Solutions
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Water Quality Certification No. 3696
GENERAL CERTIFICATION FOR PROJECTS ELIGIBLE
FOR U.S. ARMY CORPS OF ENGINEERS NATIONWIDE PERMIT NUMBER 38
(CLEANUP OF HAZARDOUS AND TOXIC WASTE)
AND RIPARIAN AREA PROTECTION RULES (BUFFER RULES)
Water Quality Certification Number 3696 is issued in conformity with the requirements of Section
401, Public Laws 92-500 and 95-217 of the United States and subject to the North Carolina
Division of Water Quality Regulations in 15A NCAC 2H, Section .0500 and 15A NCAC 213.0200
for the discharge of fill material to waters and wetland areas as described in 33 CFR 330
Appendix A (B) (38) and the Riparian Area Protection Rules (Buffer Rules) in 15A NCAC 2B
.0200.
The State of North Carolina certifies that the specified category of activity will not violate
applicable portions of Sections 301, 302, 303, 306 and 307 of the Public Laws 92-500 and 95-217
if conducted in accordance with the conditions hereinafter set forth.
Any proposed fill or modification of wetlands or waters, including streams, under this General
Certification requires application to and written approval from the Division of Water Quality (the
"Division"). Activities that are located within river basins with Riparian Area Protection
Rules (Buffer Rules) require written approval unless listed in the Table of Uses as
"EXEMPT".
In accordance with North Carolina General Statute Section 143-215.3D(e), any requirement for
written approval for a 401 Water Quality Certification must include the appropriate fee. If a
project also requires a CAMA Permit, then one payment to both agencies shall be submitted and
will be the higher of the two fees.
Conditions of Certification:
1. No Impacts Beyond those in Authorized in the Written Approval
No waste, spoil, solids, or fill of any kind shall occur in wetlands, waters, or riparian areas
beyond the footprint of the impacts authorized in the written approval, including incidental
impacts. All construction activities, including the design, installation, operation, and
maintenance of sediment and erosion control Best Management Practices, shall be
performed so that no violations of state water quality standards, statutes, or rules occur.
2. Standard Erosion and Sediment Control Practices
Erosion and sediment control practices must be in full compliance with all specifications
governing the proper design, installation and operation and maintenance of such Best
Management Practices:
a. Design, installation, operation, and maintenance of the sediment and erosion control
measures must be such that they equal, or exceed, the requirements specified in the
most recent version of the North Carolina Sediment and Erosion Control Manual. The
devices shall be maintained on all construction sites, borrow sites, and waste pile (spoil)
projects, including contractor-owned or leased borrow pits associated with the project.
b. For borrow pit sites, the erosion and sediment control measures must be designed,
installed, operated, and maintained in accordance with the most recent version of the
North Carolina Surface Mining Manual.
c. Reclamation measures and implementation must comply with the reclamation in
accordance with the requirements of the Sedimentation Pollution Control Act and the
Mining Act of 1971.
Water Quality Certification No. 3696
Water Quality Certification No. 3696
d. Sufficient materials required for stabilization and/or repair of erosion control measures
and stormwater routing and treatment shall be on site at all times.
e. If the project occurs in waters or watersheds classified as Primary Nursery Areas
(PNA's), Trout Jr), SA, WS-I, WS-11, High Quality (HQW), or Outstanding Resource
(ORW) waters, then the sediment and erosion control requirements contained within
Design Standards in Sensitive Watersheds (15A NCAC 04B .0124) supercede all other
sediment and erosion control requirements.
3. No Sediment and Erosion Control Measures in Wetlands or Waters
Sediment and erosion control measures should not be placed in wetlands or waters without
prior approval from the Division. If placement of sediment and erosion control devices in
wetlands and waters is unavoidable, then the design and placement of temporary erosion
control measures shall not be conducted in a manner that may result in dis-equilibrium of
wetlands or stream beds or banks, adjacent to or upstream and down stream of the above
structures. All sediment and erosion control devices shall be removed and the natural grade
restored within two (2) months of the date that the Division of Land Resources or locally
delegated program has released the project.
4. Construction Stormwater Permit NCG010000
Upon the approval of an Erosion and Sedimentation Control Plan issued by the Division of
Land Resources (DLR) or a DLR delegated local erosion and sedimentation control program,
an NPDES General stormwater permit (NCG010000) administered by the Division is
automatically issued to the project. This General Permit allows stormwater to be discharged
during land disturbing construction activities as stipulated by conditions in the permit. If your
project is covered by this permit [applicable to construction projects that disturb one (1) or
more acres], full compliance with permit conditions including the sedimentation control plan,
self-monitoring, record keeping and reporting requirements are required. A copy of this
permit and monitoring report forms may be found at
http.//h2o.enr.state.nc.us/su/Forms Documents htm.
5. Riparian Area Protection (Buffer) Rules
Activities located in the protected 50-foot wide riparian areas (whether jurisdictional wetlands
or not) within the Neuse, Tar-Pamlico, Randleman, Catawba (or any other basin with buffer
rules), shall be limited to "uses" identified within and constructed in accordance with 15A
NCAC 2B.0233, .0259,.0250, and.0243, and shall be located, designed, constructed, and
maintained to have minimal disturbance to protect water quality to the maximum extent
practicable through the use of best management practices. All riparian area protection rule
requirements, including diffuse flow requirements, must be met.
6. Water Supply Watershed Buffers
The 30-foot wide vegetative buffer (low-density development) or the 100-foot wide (high-
density development) must be maintained adjacent to all perennial waters except for
allowances as provided in the Water Supply Watershed Protection Rules [15A NCAC 2B
.0212 through .02151.
Water Quality Certification No. 3696
Water Quality Certification No. 3696
7. Work in the Dry
All work in or adjacent to stream waters should be conducted in a dry work area. Approved
best management practices from the most current version of the NC Sediment and Erosion
Control Manual, or the NC DOT Construction and Maintenance Activities Manual, such as
sandbags, rock berms, cofferdams, and other diversion structures shall be used to minimize
excavation in flowing water. Channel realignments shall be constructed by excavating the
new channel from downstream to upstream before connecting it to the existing channel.
8. Construction Moratoriums and Coordination
All moratoriums on construction activities established by the NC Wildlife Resources
Commission (WRC), US Fish and Wildlife Service (USFWS), NC Division of Marine Fisheries
(DMF), or National Marine Fisheries Service (NMFS) to protect trout, anadromous fish,
larval/post-larval fishes and crustaceans, or other aquatic species of concern must be
obeyed.
Work within the twenty-five (25) designated trout counties or identified state or federal
endangered or threatened species habitat shall be coordinated with the appropriate WRC,
USFWS, NMFS, and/or DMF personnel.
The timing of the dredging and discharge shall be coordinated with State and Federal
agencies and the applicant in order to lessen impact on aquatic organisms and their
reproduction.
9. If an environmental document is required under NEPA or SEPA, then this Certification is not
valid until a Finding of No Significant Impact (FONSI) or Record of Decision (ROD) is issued
by the State Clearinghouse.
10. If concrete is used during this activity, then a dry work area should be maintained to prevent
direct contact prevent direct contact between curing concrete and stream water. Water that
inadvertently contacts uncured concrete should not be discharged to surface waters due to
the potential for elevated pH and possible aquatic life/fish kills.
11. Additional site-specific conditions may be added to the written approval letter in order to
ensure compliance with all applicable water quality and effluent standards.
12. Person(s) performing activities under this General Certification shall also be compliant with
29 CFR Part 1910.120 (Occupational Safety and Health Administration) and 40 CFR Part
300 et al. (US Environmental Protection Agency).
13.When written authorization is required for use of this certification, upon completion of all
permitted impacts included within the approval and any subsequent modifications, the
applicant shall be required to return the certificate of completion attached to the approval.
One copy of the certificate shall be sent to the DWQ Central Office in Raleigh at 1650 Mail
Service Center, Raleigh, NC, 27699-1650.
14.This General Certification shall expire three (3) years from the date of issuance of the
written approval or on the same day as the expiration date of these corresponding
Nationwide and Regional General Permits. The conditions in effect on the date of issuance
of Certification for a specific project shall remain in effect for the life of the project, regardless
of the expiration date of this Certification. If the construction process for approved activities
will overlap the expiration and renewal date of the corresponding 404 Permit and the Corps
allows for continued use of the 404 Permit, then the General Certification shall also remain in
effect without requiring re-application and re-approval to use this Certification for the specific
impacts already approved.
Water Quality Certification No. 3696
Water Quality Certification No. 3696
15. The applicant/permittee and their authorized agents shall conduct all activities in a manner
consistent with State water quality standards (including any requirements resulting from
compliance with §303(d) of the Clean Water Act), and any other appropriate requirements of
State and Federal Law. If the Division determines that such standards or laws are not being
met, including failure to sustain a designated or achieved use, or that State or Federal law is
being violated, or that further conditions are necessary to assure compliance, then the
Division may reevaluate and modify this General Water Quality Certification.
Non-compliance with or violation of the conditions herein set forth by a specific fill project shall
result in revocation of this General Certification for the project and may result in criminal and/or
civil penalties.
The Director of the North Carolina Division of Water Quality may require submission of a formal
application for individual certification for any project in this category of activity if it is determined
that the project is likely to have a significant adverse effect upon water quality, including state or
federally listed endangered or threatened aquatic species, or degrade the waters so that existing
uses of the wetland, stream or downstream waters are precluded.
Public hearings may be held for specific applications or group of applications prior to a
Certification decision if deemed in the public's best interest by the Director of the North Carolina
Division of Water Quality.
Effective date: November 1, 2007
DIVISION OF WATER QUALITY
By
Coleen H. Sullins
Director
History Note: Water Quality Certification Number 3696 replaces Water Quality Certification
Number 2672 issued on January 21, 1992, Certification Number 2745 issued on February 11,
1997, Certification Number 3360 issued on March 18, 2002, and Certification Number 3637
issued on March 19, 2007. This General Certification is rescinded when the Corps of Engineers
re-authorizes Nationwide Permit 38 or when deemed appropriate by the Director of the Division of
Water Quality.
Water Quality Certification No. 3696
APPENDIX C
COE NATIONWIDE PERMIT PROGRAM
PRECONSTRUCTION NOTIFICATION FORM
BHE Environmental, Inc. Defining Environmental Solutions
T
a
Office Use Only:
Corps action ID no.
DWQ project no.
Form Version 1.4 January 2009
Pre-Construction Notification (PCN) Form
A. Applicant Information
1. Processing
1 a. Type(s) of approval sought from the Corps: ? Section 404 Permit ? Section 10 Permit
1b. Specify Nationwide Permit (NWP) number: or General Permit (GP) number:
1c. Has the NWP or GP number been verified by the Corps? ? Yes ? No
1d. Type(s) of approval sought from the DWQ (check all that apply):
? 401 Water Quality Certification - Regular ? Non-404 Jurisdictional General Permit
? 401 Water Quality Certification - Express ? Riparian Buffer Authorization
1e. Is this notification solely for the record
because written approval is not required? For the record only for DWQ
401 Certification:
? Yes ? No For the record only for Corps Permit:

? Yes ? No
1f. Is payment into a mitigation bank or in-lieu fee program proposed for
mitigation of impacts? If so, attach the acceptance letter from mitigation bank
or in-lieu fee program.
? Yes ? No
1g. Is the project located in any of NC's twenty coastal counties. If yes, answer 1 h
below. ? Yes ? No
1h. Is the project located within a NC DCM Area of Environmental Concern (AEC)? ? Yes ? No
2. Project Information
2a. Name of project:
2b. County:
2c. Nearest municipality / town:
2d. Subdivision name:
2e. NCDOT only, T.I.P. or state project no:
3. Owner Information
3a. Name(s) on Recorded Deed:
3b. Deed Book and Page No.
3c. Responsible Party (for LLC if
applicable):
3d. Street address:
3e. City, state, zip:
3f. Telephone no.:
3g. Fax no.:
3h. Email address:
Page 1 of 10
PCN Form - Version 1.4 January 2009
4. Applicant Information (if different from owner)
4a. Applicant is: ? Agent ? Other, specify:
4b. Name:
4c. Business name
(if applicable):
4d. Street address:
4e. City, state, zip:
4f. Telephone no.:
4g. Fax no.:
4h. Email address:
5. Agent/Consultant Information (if applicable)
5a. Name:
5b. Business name
(if applicable):
5c. Street address:
5d. City, state, zip:
5e. Telephone no.:
5f. Fax no.:
5g. Email address:
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B. Project Information and Prior Project History
1. Property Identification
1a. Property identification no. (tax PIN or parcel ID):
1b. Site coordinates (in decimal degrees): Latitude: Longitude:
1c. Property size: acres
2. Surface Waters
2a. Name of nearest body of water to proposed project:
2b. Water Quality Classification of nearest receiving water:
2c. River basin:
3. Project Description
3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this
application:
3b. List the total estimated acreage of all existing wetlands on the property:
3c. List the total estimated linear feet of all existing streams (intermittent and perennial) on the property:
3d. Explain the purpose of the proposed project:
3e. Describe the overall project in detail, including the type of equipment to be used:
4. Jurisdictional Determinations
4a. Have jurisdictional wetland or stream determinations by the
Corps or State been requested or obtained for this property /

project (including all prior phases) in the past? ? Yes ? No ? Unknown

Comments:
4b. If the Corps made the jurisdictional determination, what type
of determination was made? ? Preliminary ? Final
4c. If yes, who delineated the jurisdictional areas?
Name (if known): Agency/Consultant Company:
Other:
4d. If yes, list the dates of the Corps jurisdictional determinations or State determinations and attach documentation.
5. Project History
5a. Have permits or certifications been requested or obtained for
this project (including all prior phases) in the past? ?Yes ? No ? Unknown
5b. If yes, explain in detail according to "help file" instructions.
6. Future Project Plans
6a. Is this a phased project? ? Yes ? No
6b. If yes, explain.
Page 3 of 10
PCN Form - Version 1.4 January 2009
C. Proposed Impacts Inventory
1. Impacts Summary
1a. Which sections were completed below for your project (check all that apply):
? Wetlands ? Streams - tributaries ? Buffers ? Open Waters
? Pond Construction
2. Wetland Impacts
If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted.
2a.
Wetland impact
number
Permanent (P) or
Tem orar T 2b.
Type of impact 2c.
Type of wetland 2d.
Forested 2e.
Type of jurisdiction
Corps (404,10) or
DWQ (401, other) 2f.
Area of
impact
(acres)
W11 Choose one Choose one Yes/No
W2 Choose one Choose one Yes/No
W3 Choose one Choose one Yes/No
W4 Choose one Choose one Yes/No
W5 Choose one Choose one Yes/No
W6 Choose one Choose one Yes/No
2g. Total Wetland Impacts:
2h. Comments:
3. Stream Impacts
If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this
question for all stream sites impacted.
3a.
Stream impact
number
Permanent (P) or
Temporary (T) 3b.
Type of impact 3c.
Stream name 3d.
Perennial (PER) or
intermittent (INT)? 3e.
Type of
jurisdiction 3f.
Average
stream
width
(feet) 3g.
Impact
length
(linear
feet)
S1 Choose one
S2 Choose one
S3 Choose one
S4 Choose one
S5 Choose one
S6 Choose one
3h. Total stream and tributary impacts
3i. Comments:
Page 4 of 10
PCN Form - Version 1.4 January 2009
4. Open Water Impacts
If there are proposed impacts to lakes, ponds, estuaries, tributaries, sounds, the Atlantic Ocean, or any other open water of
the U.S. then individual) list all open water impacts below.
4a.
Open water
impact number
Permanent (P) or
Temporary T 4b.
Name of waterbody
(if applicable) 4c.

Type of impact 4d.

Waterbody
type 4e.

Area of impact (acres)
01 Choose one Choose
02 Choose one Choose
03 Choose one Choose
04 Choose one Choose
4f. Total open water impacts
4g. Comments:
5. Pond or Lake Construction
If and or lake construction proposed, then complete the chart below.
5a.
Pond ID number 5b.
Proposed use or
purpose of pond 5c.
Wetland Impacts (acres) 5d.
Stream Impacts (feet) 5e.
Upland
(acres)
Flooded Filled Excavated Flooded Filled Excavated
P1 Choose one
P2 Choose one
5f. Total:
5g. Comments:
5h. Is a dam high hazard permit required? ? Yes ? No if yes, permit ID no:
5i. Expected pond surface area (acres):
5j. Size of pond watershed (acres):
5k. Method of construction:
6. Buffer Impacts (for DWQ)
If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts
below. If an impacts require mitigation, then you MUST fill out Section D of this form.
6a. Project is in which protected basin? ? Neuse ? Tar-Pamlico ? Catawba ? Randleman ? Other:
6b.
Buffer Impact
number -
Permanent (P) or
-Temporary T 6c.
Reason for impact 6d.
Stream name 6e.
Buffer
mitigation
required? 6f.
Zone 1
impact
(square
feet 6g.
Zone 2
impact
(square
feet
B1 Yes/No
B2 Yes/No
B3 Yes/No
B4 Yes/No
B5 Yes/No
B6 Yes/No
6h. Total Buffer Impacts:
6i. Comments:
Page 5 of 10
D. Impact Justification and Mitigation
1. Avoidance and Minimization
1a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project.
1 b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques.
2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a. Does the project require Compensatory Mitigation for
impacts to Waters of the U.S. or Waters of the State? ? Yes ? No
2b. If yes, mitigation is required by (check all that apply): ? DWQ ? Corps

2c.
If yes, which mitigation option will be used for this
project? ? Mitigation bank

El Payment to in-lieu fee program
? Permittee Responsible Mitigation
3. Complete if Using a Mitigation Bank
3a. Name of Mitigation Bank:

3b. Credits Purchased (attach receipt and letter) Type: Choose one
Type: Choose one
Type: Choose one Quantity:
Quantity:
Quantity:
3c. Comments:
4. Complete if Makin a Payment to In-lieu Fee Program
4a. Approval letter from in-lieu fee program is attached. ? Yes
4b. Stream mitigation requested: linear feet
4c. If using stream mitigation, stream temperature: Choose one
4d. Buffer mitigation requested (DWQ only): square feet
4e. Riparian wetland mitigation requested: acres
4f. Non-riparian wetland mitigation requested: acres
4g. Coastal (tidal) wetland mitigation requested: acres
4h. Comments:
5. Complete if Using a Permittee Responsible Mitigation Plan
5a. If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan.
Page 6 of 10
PCN Form - Version 1.4 January 2009
6. Buffer Mitigation (State Regulated Riparian Buffer Rules) - required by DWQ
6a. Will the project result in an impact within a protected riparian buffer that requires
buffer mitigation? ? Yes ? No
6b. If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the
amount of mitigation required.

Zone 6c.
Reason for impact 6d.
Total impact
(square feet)
Multiplier 6e.
Required mitigation
(square feet)
Zone 1 3 (2 for Catawba)
Zone 2 1.5
6f. Total buffer mitigation required:
6g. If buffer mitigation is required, discuss what type of mitigation is proposed (e.g., payment to private mitigation bank,
permittee responsible riparian buffer restoration, payment into an approved in-lieu fee fund).
6h. Comments:
Page 7 of 10
E. Stormwater Management and Diffuse Flow Plan (required by DWQ)
1. Diffuse Flow Plan
1 a. Does the project include or is it adjacent to protected riparian buffers identified
within one of the NC Riparian Buffer Protection Rules? ? Yes ? No
1 b. If yes, then is a diffuse flow plan included? If no, explain why.
? Yes ? No
2. Stormwater Management Plan
2a. What is the overall percent imperviousness of this project? %
2b. Does this project require a Stormwater Management Plan? ? Yes ? No
2c. If this project DOES NOT require a Stormwater Management Plan, explain why:
2d. If this project DOES require a Stormwater Management Plan, then provide a brief, na rrative description of the plan:
2e. Who will be responsible for the review of the Stormwater Management Plan?
3. Certified Local Government Stormwater Review
3a. In which local government's jurisdiction is this project?

3b.
Which of the following locally-implemented stormwater management programs
apply (check all that apply): ? Phase II
? NSW
? USMP
? Water Supply Watershed
? Other:
3c. Has the approved Stormwater Management Plan with proof of approval been
attached? ? Yes ? No
4. DWQ Stormwater Program Review

4a.

Which of the following state-implemented stormwater management programs apply
(check all that apply): ?Coastal counties
?HQW
?ORW
?Session Law 2006-246
?Other:
4b. Has the approved Stormwater Management Plan with proof of approval been
attached? ? Yes ? No
5. DWQ 401 Unit Stormwater Review
5a. Does the Stormwater Management Plan meet the appropriate requirements? ? Yes ? No
5b. Have all of the 401 Unit submittal requirements been met? ? Yes ? No

Page 8 of 10
PCN Form - Version 1.4 January 2009
F. Supplementary Information
1. Environmental Documentation (DWQ Requirement)
1a. Does the project involve an expenditure of public (federal/state/local) funds or the ? Yes ? No
use of public (federal/state) land?
1 b. If you answered "yes" to the above, does the project require preparation of an
environmental document pursuant to the requirements of the National or State ?Yes ? No
(North Carolina) Environmental Policy Act (NEPA/SEPA)?
1c. If you answered "yes" to the above, has the document review been finalized by the
State Clearing House? (If so, attach a copy of the NEPA or SEPA final approval
? Yes ? No
letter.)
Comments:
2. Violations (DWQ Requirement)
2a. Is the site in violation of DWQ Wetland Rules (15A NCAC 2H .0500), Isolated
Wetland Rules (15A NCAC 2H .1300), DWQ Surface Water or Wetland Standards, ? Yes ? No
or Riparian Buffer Rules (15A NCAC 2B .0200)?
2b. Is this an after-the-fact permit application? ? Yes ? No
2c. If you answered "yes" to one or both of the above questions, provide an explanation of the violation(s):
3. Cumulative Impacts (DWQ Requirement)
3a. Will this project (based on past and reasonably anticipated future impacts) result in ?Yes ? No
additional development, which could impact nearby downstream water quality?
3b. If you answered "yes" to the above, submit a qualitative or quantitative cumulative impact analysis in accordance with the
most recent DWQ policy. If you answered "no," provide a short narrative description.
4. Sewage Disposal (DWQ Requirement)
4a. Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of wastewater generated from
the proposed project, or available capacity of the subject facility.
Page 9 of 10
PCN Form - Version 1.4 January 2009

5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected species or
habitat? ? Yes ? No
5b. Have you checked with the USFWS concerning Endangered Species Act
impacts? ? Yes ? No
5c. If yes, indicate the USFWS Field Office you have contacted. -
5d. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical
Habitat?
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as essential fish habitat? ? Yes ? No
6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat?
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
7a. Will this project occur in or near an area that the state, federal or tribal
governments have designated as having historic or cultural preservation
status (e.g., National Historic Trust designation or properties significant in
North Carolina history and archaeology)?
? Yes ? No
7b. What data sources did you use to determine whether your site would impact historic or archeological resources?
8. Flood Zone Designation (Corps Requirement)
8a. Will this project occur in a FEMA-designated 100-year floodplain? ? Yes ? No
8b. If yes, explain how project meets FEMA requirements:
8c. What source(s) did you use to make the floodplain determination?

Applicant/Agent's Printed Name Applicant/Agent's Signature
(Agent's signature is valid only if an authorization
letter from the applicant is provided.) Date
Page 10 of 10
APPENDIX D
JOINT COE / DWQ NATIONWIDE PERMIT PROGRAM
CERTIFICATION OF COMPLETION FORM
BHE Environmental, Inc. Defining Environmental Solutions
OR.- W AT ?RQG
r
O 'C
CIO
DWQ Project No.: County:
Applicant:
Proiect Name:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Date of Issuance of 401 Water Quality Certification or Buffer Authorization:
Certificate of Completion
Upon completion of all work approved within the 401 Water Quality Certification or applicable Buffer
Rules, and any subsequent modifications, the applicant is required to return this certificate to the
401/Wetlands Unit, North Carolina Division of Water Quality, 1650 Mail Service Center, Raleigh, NC,
27699-1650. This form may be returned to DWQ by the applicant, the applicant's authorized agent, or
the project engineer. It is not necessary to send certificates from all of these.
Applicant's Certification
I, , hereby state that, to the best of my abilities, due care
and diligence was used in the observation of the construction such that the construction was observed to
be built within substantial compliance and intent of the 401 Water Quality Certification and Buffer
Rules, the approved plans and specifications, and other supporting materials.
Signature: Date:
Agent's Certification
I, , hereby state that, to the best of my abilities, due care
and diligence was used in the observation of the construction such that the construction was observed to
be built within substantial compliance and intent of the 401 Water Quality Certification and Buffer
Rules, the approved plans and specifications, and other supporting materials.
Signature: Date:
ff this project was designed by a Certified Professional
I, , as a duly registered Professional (i.e.,
Engineer, Landscape Architect, Surveyor, etc.) in the State of North Carolina, having been authorized
to observe (periodically, weekly, full time) the construction of the project, for the Permitee hereby state
that, to the best of my abilities, due care and diligence was used in the observation of the construction
such that the construction was observed to be built within substantial compliance and intent of the 401
Water Quality Certification and Buffer Rules, the approved plans and specifications, and other
supporting materials.
Signature Registration No.
Date
Nil*ENR
North Carolina Division of Water Quality, 401 Wetlands Certification Unit,
1650 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address)
2321 Crabtree Blvd., Raleigh, NC 27604-2260 (Location)
919-733-1786 (phone), 919-733-6893 (fax), http://h2o.enr.state.nc.ustncwetiands/

APPENDIX E
Ecologic Letter Verifying Yadkin River Golden Rod
Potential Habitat Survey
BHE Environmental, Inc.
Defining Environmental Solutions
ZECOLOGIC
March 5, 2009
Frank Schuler, Jr.
BHE Environmental, Inc.
11733 Chesterdale Road
Cincinnati, Ohio 45246
3808 Clifton Road • Greensboro NC 27407
[phone] • Fax [phone]
www.ecologic-nc.com
RE: YRGR Habitat Survey
Narrows Dam Cove, Montgomery County, NC
Dear Frank:
On February 19, 2009, Moni Bates visited the Narrows Peninsula at the base of the Narrows
Dam with Frank Schuler of BHE. During that time, we delineated the Yadkin River goldenrod
habitat area. The delineation included the habitat occupied by the species and potential habitat.
The potential habitat includes natural rock outcropping that contains crevices. We obtained GPS
coordinates for the boundary between the potential habitat and rock rubble that is not appropriate
habitat. This is accurately represented in the map file titled "Narrows Peninsula - YRGR Habitat
Area Map - February 2009.pdf " provided by BHE.
The proposed construction access road, as shown on the map referenced above, is located
entirely within the rock rubble, which is neither natural nor suitable habitat for the species. The
proposed road avoids impacts to Yadkin River goldenrod and to its actual and potential habitat.
Please let us know if we may help with other issues relating to Yadkin River goldenrod.
Sincerely,
Ecologic Associates, P.C.
2a* o v ct, Bate4-
Ramona "Moni" Bates
Senior Associate Botanist
APPENDIX F
Yadkin River Golden Rod Mitigation Plan
•
•
•
•
•
BHE Environmental, Inc.
Defining Environmental Solutions
Mitigation Plan
for impacts to
Yadkin River Goldenrod
(Solidago plumosa Small)
Remediation of Lead and PCB at
Narrows Dam Cove
Badin, North Carolina
Montgomery County
August 29, 2008
Revised by BHE Environmental March 10, 2009
OECOLOGIC
Ecologic Associates, PC
Principal Botanist: Mom Bates
Principal Reviewer: Mark Taylor PE, CPESC
[phone]
Mitigation Plan for Impacts to Yadkin River Goldenrod - Narrow's Dam Cove
Table of Contents
1. Introduction ......................................................................................................... ......................................................2
2. Consultation to Date ............................................................................................ ......................................................2
3. Species Account .................................................................................................. ......................................................2
4. Habitat ................................................................................................................. ......................................................4
4a. Critical Habitat ............................................................................................... ......................................................5
5. Current Management Direction ........................................................................... ......................................................5
6. Description of the Proposed Action ..................................................................... ......................................................5
6a. Type of project ............................................................................................... ......................................................6
6b. Project Location ............................................................................................. ......................................................6
6c. Project Action Area ........................................................................................ ......................................................6
6d. Implementation Schedule .............................................................................. ......................................................6
6e. Who is going to do the action and under what authority? .............................. ......................................................7
7. Remediation Methods .......................................................................................... ......................................................7
7a. Potential Impacts ............................................................................................ ......................................................7
7b. Habitat Status on Site ..................................................................................... ......................................................7
7c. Is the Project Growth-Inducing? .................................................................... ......................................................8
7d. Other Yadkin River goldenrod Subpopulations ............................................. ......................................................8
7e. Information on Mitigation .............................................................................. ......................................................8
8. Existing Condition Survey ............................................................................... ......................................................9
9. Effects of the Proposed Mitigation ...................................................................... ......................................................9
9a. Cumulative Effects (Other State and Private Actions) ................................... ....................................................10
9b. Reasonable and Prudent Alternatives ............................................................ ....................................................10
10. Conclusion and Determination .......................................................................... ....................................................10
11. Literature Cited .................................................................................................. ....................................................10
12. Maps .................................................................................................................. ....................................................11
March 10, 2009 1 EcoLogic Associates, P.C.
Mitigation Plan for Impacts to Yadkin River Goldenrod - Narrow's Dam Cove
1. Introduction
The purpose of this mitigation plan is to review the proposed remediation of lead and PCB
impacted soils, sediments, and debris at the base of the powerhouse at the Narrow's Dam Cove
in sufficient detail to determine whether the proposed action may affect any of the threatened,
endangered, proposed or sensitive species, or their habitat listed below. This mitigation plan is
prepared in accordance with legal requirements set forth under Section 7 of the Endangered
Species Act (16 U.S.C. 1536 (c)).
The species considered in this document is: Candidate
Yadkin River goldenrod (Solidago plumosa Small)
Currently, the United States Fish and Wildlife Service (USFWS) lists Yadkin River goldenrod as
a Candidate species. It is listed as Endangered on the Natural Heritage Program List of Rare
Plant Species of North Carolina (Franklin and Finnegan, 2006). Yadkin River goldenrod is
ranked S1/G1. GI species are those that have one to five (5) extant populations worldwide.
They are critically imperiled globally because of extreme rarity or because of some factor(s)
making it especially vulnerable to extinction (Franklin and Finnegan, 2006).
2. Consultation to Date
The occurrence of Yadkin River goldenrod on the peninsula at the base of the powerhouse at
Narrow's Dam Cove was noted on September 6, 2007. EcoLogic's staff biologist notified the
project coordinator from BHE Environmental, Inc., of the finding on September 7, 2007. In
addition, EcoLogic completed an "in-field" habitat assessment on February 19, 2009.
3. Species Account
Yadkin River goldenrod was first observed in 1894 and described it as a new species in 1896 and
1898 (Small, 1896 and 1898). In 1917, the Narrows Dam was constructed at the location that
botanists believe John Small described as the "canon" of the Yadkin River. In 1919, Falls Dam
was constructed in the region that botanists believe was described by Small as the "falls of the
Yadkin." For decades, the species was apparently forgotten and was not included in the
published floras for the Carolinas (Radford et. al., 1964 and Radford et. al, 1968). Apparently
botanists considered the Yadkin River goldenrod extinct due to the construction of the two dams
and inundation of the Yadkin River gorge. Ironically, in 1994 two botanists independently
rediscovered Yadkin River goldenrod growing downstream of the Narrow's Dam Cove on the
Montgomery County side of Falls Lake. This was nearly 100 years after Small first observed
Yadkin River goldenrod. The only known location that a population of Yadkin River goldenrod
occurs, historically or currently, is at the base and downstream of Narrows Dam, with a few
individuals known to occur at the base and downstream of Falls Dam.
The Yadkin River goldenrod is a member of the Aster family (Asteraceae). This species is one
of 80 to 100 species in the genus native primarily to North America (Weakley, 2006). A few
March 10, 2009 2 EcoLogic Associates, P.C.
Mitigation Plan for Impacts to Yadkin River Goldenrod - Narrow's Dam Cove
species are native to South America, Macaronesia, and Eurasia (Weakley, 2006). Yadkin River
goldenrod is closely related to Solidago racemosa Greene (Sticky goldenrod). Yadkin River
goldenrod is distinguished from Sticky goldenrod by its glabrous achenes, generally taller
flowering plants, broad cylindrical inflorescence that averages five (5) to six centimeters in
diameter, and its restricted habitat on the Yadkin River in the piedmont of North Carolina
(Weakley, 2006).
Upon discovering Yadkin River goldenrod in the latter part of August 1894, John Small
described the species as differing from specimens of northern localities. Small (1986) described
the new species as taller than northern specimens, with an average height of three feet and a few
specimens up to four feet. Small (1896) also mentioned the glabrous achenes.
In 1898, Small published a species description of Yadkin River goldenrod. The description
follows: "Perennial, bright green, glabrous or nearly so below the inflorescence, inclined to be
glutinous, especially above. Stems erect, often tufted, 4-10 dm. high, ridged, purple, strict:
leaves alternate; blades spatulate to narrowly linear, 2-30 cm. long, obtuse, acute or acuminate,
thickish, entire or remotely and shallowly toothed, narrowed into slightly margined petiole or the
upper ones nearly sessile with smaller ones sometimes clustered in their axils: heads numerous,
in narrow terminal panicles, 5-8 mm long, often densely disposed: involucres campuanulate at
maturity: bracts linear, inner ones narrowly so, obtuse, erect: flowers 11-15, crowded; rays 3-5,
yellow, 5-6 mm. long: achenes 3-3.5 mm. long, glabrous." Cronquist (1980) describes Yadkin
River goldenrod as 4-13 dm tall with up to 20 basal leaves that may be 30 cm in length and 1.5
cm in width. Like Weakley, Cronquist (1980) mentions the glabrous achenes. Cronquist (1980)
describe the inflorescence as broad, branched, and loosely thyrsoid-paniculate.
During most of the year Yadkin River goldenrod is a rosette with a dense rhizome that anchors
the rosette into crevices of rock outcrops. The rosettes produce a flowering stalk and flowers in
August and September. The seeds mature by October and November. On November 6, 1999,
Bates collected mature seeds. Seeds were placed on germination cardboard, moistened with
water, and placed in filtered sunlight. The germination rate was 90%. These seedlings were
grown in a greenhouse at the North Carolina Zoological Park. In September 2000, twenty-two
plants were transplanted to the Montgomery County population. In April 2001, the survivorship
was 100%. One year after transplant, survivorship dropped to 73%. Fifty-six percent of these
individuals produced flowers. Two years after transplanting, survivorship was 18%. Fifty
percent of these individuals produced flowers. During the second year, a drought in central
North Carolina may have contributed to the low survivorship. The typical life span of an
individual rosette is unknown.
Field work for the Montgomery County Natural Heritage Inventory (Bates, 2001) and Richmond
County Natural Areas Inventory (Sorrie, 2001), sponsored by the LandTrust of Central North
Carolina (LTCNC) and North Carolina Natural Heritage Program (NCNHP), was conducted in
1999 and 2000. During this time, no new populations of Yadkin River goldenrod were located in
either county. Furthermore, no new populations were located during field work for a USFWS
report, Range Expansion Survey and Monitoring of Solidago plumosa (Yadkin River goldenrod)
(Bates, 2005). For this project, suitable rock outcrop habitat along the Yadkin River was
• March 10, 2009 3 EcoLogic Associates, P.C.
Mitigation Plan for Impacts to Yadkin River Goldenrod - Narrow's Dam Cove
searched from the known population to the headwaters of the Yadkin River in Caldwell County,
North Carolina.
4. Habitat
Yadkin River goldenrod is a locally endemic species and apparently rare due to its restrictive
habitat requirements. Currently, the species is only known to occur in a 2.5-mile stretch of the
Yadkin River downstream of the Narrows and Falls Dams located in Montgomery and Stanly
County in central North Carolina. Upon the discovery of Yadkin River goldenrod, Small (1896)
described the habitat as "crevices of the rocks at the bottom of the canon at the falls of the
Yadkin River, and at the Narrows some miles above the falls in middle North Carolina." The
construction of the Narrows and Falls Dams in the early 1900's inundated the canyon.
Yadkin River goldenrod occurs on rock-outcrops and boulders along the shoreline of the Yadkin
River. The short, dense rhizomes enable the species to grow and anchor in the crevices. The
outcrops are mapped as mafic and intermediate metavolcanic rock (Goldsmith et. al., 1988).
However, in 1997 Bates and Coomans reported to the NCNHP that twenty-five (5) plants were
observed growing from the cracks in concrete from a bridge piling or other human constructed
structure at the base of the Narrows Dam. This suggests that Yadkin River goldenrod is not
restricted specifically to mafic rock habitat. At the known subpopulations, habitat that consists
of gravel, cobble, or soil does not support Yadkin River goldenrod.
In addition to the restricted rock outcrop habitat, Yadkin River goldenrod grows within an
estimate of ten to twenty meters from the shoreline. The rocky habitat supports few woody
species, thus the canopy and understory are open and provides sunlight to the herb layer. Yadkin
River goldenrod appears to thrive in an open canopy. Botanists speculate that historically natural
flooding scoured the rocky shoreline and suppressed woody growth. Today, Yadkin River
goldenrod does not occur on rock outcrops that are frequently inundated. This suggests that the
species requires rock outcrop habitat that receive sufficient flooding to control the growth of
woody species, but the rhizomes and rosettes cannot survive extended periods of inundation.
Botanists describe the natural community as "glade-like" or "river prairies." Two other rare
plant species that occur in the vicinity of Yadkin River goldenrod are Amorpha schwerinii
(Piedmont indigo-bush) and Baptisia alba (Thick-pod white wild indigo). Piedmont indigo-bush
grows in forests and woodlands, primarily rather xeric and rocky (Weakley, 2006). Thick-pod
white wild indigo grows in dry woodlands. The North Carolina status of these species is
significantly rare (Franklin and Finnegan, 2006). Some of the common species that grow in the
vicinity of Yadkin River goldenrod include Schizachyrium scoparium (Little blue stem), Ulmus
alata (Winged elm), Hypericum prolificum (Shrubby St.-John's-wort), Liquidambar styraciua
(Sweet gum), Vaccinium arboreum (Sparkleberry), Amorpha fruticosa (Tall indigo-bush),
Mecardonia acuminata var. acuminata (Mecardonia), Gelsemium sempervirens (Carolina
jasmine), and Rhus aromatica var. aromatica (Fragrant sumac).
Invasive plant species are known to grow on the rock outcrop and adjacent habitat. Albizia
julibrissin (Mimosa) grows from the rock crevices and shades portions of the Yadkin River
March 10, 2009 4 EcoLogic Associates, P.C.
Mitigation Plan for Impacts to Yadkin River Goldenrod - Narrow's Dam Cove
goldenrod population. Other invasive species such as Lonicera japonica (Japanese
honeysuckle), Ligustrum sinense (Privet), Rosa sp. (A Rose), and Lonicera standishii (Standish's
honeysuckle) grow in or adjacent to Yadkin River goldenrod habitat.
The U.S. Forest Service owns the property that is adjacent to the Montgomery County
subpopulation of Yadkin River goldenrod. The steep slopes on U.S. Forest Service property are
wooded. Likewise, the other subpopulations of Yadkin River goldenrod are surrounded by a
forested landscape.
4a. Critical Habitat
The USFWS has not designated critical habitat for Yadkin River goldenrod. None of the
following plans or agreements exist for Yadkin River goldenrod: Habitat Conservation Plan,
Safe Harbor Agreement, Candidate Conservation Agreement, or Candidate Conservation
Agreement with Assurances (http://ecos.fws.gove/speciesProfile/SpeciesReport).
Private corporations own the subpopulations of Yadkin River goldenrod. These corporations are
subject to licenses from the Federal Energy Requirement Commission (FERC) to operate. FERC
is required to include in the project boundary "those lands necessary for operation and
maintenance of the project and for other project purposes, such as recreation, shoreline control,
or protection of environmental resources." These tail water reaches are integral to the operation
and maintenance of the hydroelectric projects. Accordingly, the sites immediately downstream
of Narrows Dam lie within the federally controlled project boundary of the Yadkin River
Hydroelectric Project (FERC Project No. 2197), which is owned and operated by Alcoa Power
Generating, Inc. (http://ecos.fws.gove/speciesProfile/SpeciesReport.). All of the individual
plants at the base of the powerhouse at Narrow's Dam Cove occur within these boundaries.
The long-term survival of Yadkin River goldenrod requires protection of the existing habitat and
individuals where subpopulations are known to occur. Restoration of marginal habitat may
promote flowering, seed production, and seed germination. Additionally, the survivorship of life
stages, such as seedling, juvenile, and adult, may increase with habitat restoration. The long
term survival of the Yadkin River goldenrod will be addressed as part of the re-licensing of the
hydroelectric project. The re-licensing process includes developing a management plan for the
Yadkin River goldenrod.
5. Current Management Direction
There are no existing management plans for Yadkin River goldenrod at the local, regional, or
state level.
6. Description of the Proposed Action
March 10, 2009 5 EcoLogic Associates, P.C.

Mitigation Plan for Impacts to Yadkin River Goldenrod - Narrow's Dam Cove
6a. Type of project
This project involves the remediation of lead and PCB impacted soil, sediments, and debris at the
base of the powerhouse at the Narrow's Dam Cove.
6b. Project Location
This project is located about two miles northeast of the Town of Badin at the terminus of State
Road 1704. The project will occur on a peninsula that is immediately downstream and adjacent
to the powerhouse at the Narrow's Dam Cove on the Yadkin River in Montgomery County,
North Carolina. The Narrows Dam is located in the upstream portion of the gorge of the Yadkin
River in the Pee Dee River basin.
6c. Project Action Area
The remediation of the lead and PCB contaminated soil, sediments, and debris will occur on the
peninsula at the Narrow's Dam Cove. The impacted soils and sediment are located to the north
of the Yadkin River goldenrod. There is no suitable habitat for Yadkin River goldenrod at this
location. Based on the February 19, 2009 habitat assessment, which included the habitat
occupied by the species and potential habitat, there is suitable habitat on the southwestern
portion of the peninsula (see attached Narrows Peninsula - YRGR Habitat Area Map - February
2009). The potential habitat includes natural rock outcropping that contains crevices.
Based on the habitat assessment the location of the proposed access road was relocated in order
to avoid impacts to the Yadkin River goldenrod. The access road is located entirely within the
rock rubble, which is neither natural nor suitable habitat for the species. The proposed road
avoids impacts to Yadkin River goldenrod and to its actual and potential habitat. Since the
project is directly adjacent to goldenrod subpopulations, mitigation planning steps are still
warranted.
6d. Implementation Schedule
The biology of Yadkin River goldenrod should be considered when implementing the mitigation
plan. Prior to implementation, consultation with the North Carolina Plant Conservation Program
in Raleigh, North Carolina is recommended. Once the contractor delineates the impact areas, a
botanist should determine if there are any impacts to the Yadkin River Goldenrod. If required,
attempts to remove Yadkin River goldenrod rosettes from rock crevices should occur during the
non-growing season, which is late fall or winter. Collect seeds during late October and
November. In situ seed germination has been observed during November and December (Bates,
observation). Therefore, seeds may be sown on the same day as collected or shortly thereafter.
If sowing seeds is required, it should be completed after the invasive species are controlled on
the peninsula. Seeds may be sown in restored habitat or existing, suitable habitat on the
peninsula. To determine the success of mitigation, annual monitoring for seed germination,
rosette recruitment, and invasive species is recommended.
March 10, 2009
Ecologic Associates, P.C.
Mitigation Plan for Impacts to Yadkin River Goldenrod - Narrow's Dam Cove
6e. Who is going to do the action and under what authority?
The Alcoa Power Generating, Inc. will conduct the remediation under an Administrative
Agreement with the North Carolina Department of Environment and Natural Resources. If
impacts to the Yadkin River goldenrod are not avoidable, then the Yadkin River goldenrod
mitigation will be conducted in consultation with the USFWS.
7. Remediation Methods
7a. Potential Impacts
The Yadkin River goldenrod subpopulation occurs on the south/southwest rock outcrop of the
peninsula at the Narrow's Dam Cove. Refer to Figure 1-3 in the Remediation Work Plan
Narrow's Dam Cove, - by BHE Environmental. The access for construction material and
equipment could potential create trampling conditions that may potentially impact Yadkin River
goldenrod.
7b. Habitat Status on Site
Rock outcrops with crevices that provide habitat for Yadkin River goldenrod are located on the
south and southwest sections of the peninsula at the Narrow's Dam Cove. This area currently
supports Yadkin River goldenrod. The north and northeast areas do not provide potential habitat
for Yadkin River goldenrod because they consist of soil or rocks without crevices. This is the
area of the peninsula where the impacted soil, sediment, and debris are located.
The plant cover on the peninsula at the Narrow's Dam Cove is predominately non-native,
invasive species. These species include Lonicera japonica (Japanese honeysuckle), Lonicera
standishii (Standish's honeysuckle), Microstegium virmineum (Japanese grass), Rosa sp. (A
Rose), Albizia julibrissin (Mimosa), Ligustrum sinensis (Privet), and Ligustrum lucidum (Glossy
privet). Invasive vines, such as Rosa sp. (A Rose) and Lonicera japonica (Japanese
honeysuckle), cover and may obscure potential habitat for Yadkin River goldenrod. Since the
plant cover is dense, it is not possible to positively determine if there are crevices in the
concealed rock outcrop but we have conservatively assumed there are crevices.
The native species on the peninsula include a few trees and shrubs such as Ulmus rubra
(Slippery elm or Red elm), Cercis canadensis (Redbud), Acer negunda (Box elder), and
Diospyros virginiana (Persimmon). A few, small individuals of Fraxinus pennsylvanica (Red
ash), Juniperus virginiana (Red cedar), flex opaca (American holly), and Cephalanthus
occidentalis (Button bush) also grow on the peninsula. The herb layer includes numerous vines
such as Campsis radicans (Trumpet vine), Gelsemium sempervirens (Carolina jasmine), Smilax
bon-nox (A Greenbrier), Parthenocissus quinquefolia (Virginia creeper), Vitis rotundifolia
(Muscadine grape), Vitis sp. (A Grape), Amphicarpaea bracteata var. bracteata (Hog-peanut),
and Cuscuta (Dodder). Some of the herbs noted include Schizachyrium scoparium (Little blue
stem), Boehmeria cylindrica (False nettle), Asplenium platyneuron (Ebony spleenwort), and
Phytolacca americana (Pokeweed).
March 10, 2009 7 EcoLogic Associates, P.C.
Mitigation Plan for Impacts to Yadkin River Goldenrod - Narrow's Dam Cove
7c. Is the Project Growth-Inducing?
If impacts are unavoidable during the remediation of the lead and PCB, then the goal of this
mitigation plan is to enhance and restore available habitat for Yadkin River goldenrod. Removal
and control of invasive species would restore and enhance the natural community. This type of
restoration may improve the success of life stages such as flowering, seed germination, and
seedling, juvenile, and rosette survivorship. Population monitoring is necessary to determine if
the restoration actions promote growth in the species.
7d. Other Yadkin River goldenrod Subpopulations
Other Yadkin River goldenrod subpopulations occur in the vicinity of the powerhouse at the
Narrow's Dam Cove. These subpopulations are located on rock outcrops along the shoreline of
Montgomery and Stanly County and support more individuals than the Narrow's Dam Cove
subpopulation.
7e. Information on Mitigation
There are proposed remediation activities at the Narrow's Dam Cove that may potentially impact
Yadkin River goldenrod individuals on the south and southwest side of the peninsula. The most
likely activity to impact the species is trampling from general construction activities. As
currently planned, the road construction avoids impacts to Yadkin River goldenrod individuals.
Because of the limited space and topography complete avoidance may not be possible. In which
case, there could be impacts to individual plants and habitat.
Prior to any activity involving the YRGR habitat area, the number of impacted individuals
should be determined. If impacts are unavoidable, attempts will be made to remove these
individuals from the rock crevices. Either or both the North Carolina Botanical Garden or North
Carolina Zoological Park should be contacted to determine if they will accept and propagate the
rescued individuals. Following the completion of the remediation project, habitat restoration
should include removing the invasive plant species from the peninsula.Determine if additional
suitable habitat is available after the removal of invasive species. If crevices exist in the rock,
collect and sow seeds in the crevices. The seeds should come from the rescued plants that were
propagated in the greenhouse. If rescued plants do not produce seeds, then collect seeds from the
natural population. If no new rock crevice habitat is restored, then sow seeds in the area of the
peninsula where known individuals are located.
To determine the effectiveness of the mitigation, two types of monitoring are recommended.
One year following the sowing of seed, monitor the establishment of new recruits and monitor
whether invasive species return to the peninsula. If invasive species re-establish on the
peninsula, additional control may be warranted. Long-term invasive specie control is outside the
scope of this remediation project but could be considered as part of the re-licensing process for
the power plant operations.
Trampling is may potentially impact individuals. Botanists have long thought that Yadkin River
goldenrod individuals are impacted from foot traffic on the rock outcrops in Montgomery
March 10, 2009 8 EcoLogic Associates, P.C.
Mitigation Plan for Impacts to Yadkin River Goldenrod - Narrow's Dam Cove
County. During the remediation project, the Yadkin River goldenrod subpopulation should be
delineated with survey flagging and/or paint.
As stated in the Species Recovery Plans for other species, public support for the conservation of
species is very important for their survival. Very few citizens of Montgomery and Stanly
Counties, including citizens who boat on Falls Lake, are aware of this plant and its rarity.
Taking steps to deter foot traffic on the peninsula would enhance the chance of rosette
survivorship.
Considering how little is known about the biology of this species, implementing this mitigation
plan would help determine management for other subpopulations.
8. Existing Condition Survey
An existing condition survey of the Narrow's Dam Cove subpopulation was conducted on
September 6, 2007. There are rock outcrops on the west/southwest shoreline of the peninsula
that exhibit horizontal and vertical fissures. Yadkin River goldenrod grows within these
crevices. A complete census was conducted for the subpopulation. On September 6, 2007, 203
clumps were counted. These clumps consisted of approximately 783 rosettes and 187 stems with
buds and/or flowers. Sixteen dead flowering stems were noted. A few rosettes with dead leaves,
broken flowering stems, and one rosette that appeared to be trampled were observed.
This data is included in the document titled Biological Technical Report - Rare Plant Species
Survey for Solidago plumosa (Yadkin River Goldenrod) prepared by EcoLogic for BHE
Environmental, Inc.
9. Effects of the Proposed Mitigation
In order to avoid impacts to the YRGR, a habitat assessment was completed and construction
access has been revised to avoid the YRGR habitat areas. If contractors indicate total avoidance
is not possible, there will be an attempt to transplant individuals to a greenhouse prior to the
start of construction. Techniques and success of transplantation should be documented. This
will provide valuable information regarding the response of Yadkin River goldenrod to
horticultural manipulations. If successful, these plants could be used for educational purposes.
If suitable habitat is uncovered after invasive species removal, then these plants may serve as a
seed source to enhance the peninsula subpopulation.
Removal of the invasive species will restore a natural community that was impacted from dam
construction and subsequent inundation. For example, Albizia julibrissin (Mimosa) grows from
the rock crevices. Therefore, removal of Mimosa will reduce shading to the Yadkin River
goldenrod rosettes. Once the stumps decompose, it will also free up rock crevice habitat for the
establishment of Yadkin River goldenrod.
March 10, 2009 9 EcoLogic Associates, P.C.
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Mitigation Plan for Impacts to Yadkin River Goldenrod - Narrow's Dam Cove
9a. Cumulative Effects (Other State and Private Actions)
There are no known cumulative effects at this time.
9b. Reasonable and Prudent Alternatives
There are no known alternative remediation methods that would meet the goals of the North
Carolina Department of Environment and Natural Resources and Alcoa Power Generating, Inc.
while avoiding impacts to Yadkin River goldenrod.
10. Conclusion and Determination
The proposed remediation of lead and PCB, as outlined in the Remediation Work Plan Narrow's
Dam Cove, - by BHE Environmental, avoids impacts to the Yadkin River goldenrod
individuals. If unavoidable, contractor activities "may affect" a small number of Yadkin River
goldenrod individuals during construction but those activities are "not likely to adversely affect"
the species in the long term. The proposed mitigation plan, including habitat restoration, will
result in "no jeopardy" to the Yadkin River goldenrod. Transplanting the plants from within the
construction zone to a greenhouse will provide a seed source for future use. The long-term
benefits include expected habitat improvement for Yadkin River goldenrod. The information
learned from transplantation, sowing seeds, and invasive species control will be important for
further management of Yadkin River goldenrod.
11. Literature Cited
Bates, M.C. 2001. Montgomery County Natural Heritage Inventory. North Carolina Natural
Heritage Program. Division of Parks and Recreation. Department of Environment and
Natural Resources, Raleigh, North Carolina.
Bates, M.C. 2005. Range Expansion Survey and Monitoring of Solidago plumosa (Yadkin River
goldenrod). Report completed for the U.S. Fish and Wildlife Service.
Cronquist, A. 1980. Vascular Flora of the Southeastern United States. University of North
Carolina Press, Chapel Hill.
Franklin, M.A. and J. T. Finnegan. 2006. Natural Heritage Program List of Rare Plant Species
of North Carolina. North Carolina Natural Heritage Program Office of Conservation and
Community Affairs. Raleigh, N.C.
Goldsmith, R., D.J. Milton, and J. Wright Horton, Jr. 1988. Geologic Map of the Charlotte I ° x
2° Quadrangle, North Carolina and South Carolina. Department of the Interior U.S.
Geologic Survey.
Radford, A., E., H. E. Ahles, and C.R. Bell. 1964. Guide to vascular flora of the Carolinas. The
University of North Carolina Press, Chapel Hill, NC.
March 10, 2009 10
EcoLogic Associates, P.C.
Mitigation Plan for Impacts to Yadkin River Goldenrod - Narrow's Dam Cove
Radford, A. E., H.E. Ahles, and C. R. Bell. 1968. Manual of the vascular flora of the Carolinas.
The University of North Carolina Press, Chapel Hill, NC.
Small, J.K. 1896. Solidago purshii. Studies in the botany of the southeastern United States. -
VI. Bulletin Torrey Botanical. Club 23:300.
Small, J.K. 1898. Solidago plumosa. Studies in the botany of the southeastern United States -
XIV. Bulletin Torrey Botanical Club 25: 476.
Sorrie, B.A. 2001. Natural Areas Inventory for Richmond County. North Carolina Natural
Heritage Program. Division of Parks and Recreation. Department of Environment and
Natural Resources, Raleigh, North Carolina.
Weakley, A.S. 2006. Flora of the Carolinas, Virginia, Georgia, and surrounding areas.
Published by the University of North Carolina, Chapel Hill, NC.
12. Maps
Refer to the Remediation Work Plan Narrow's Dam Cove, Version 1.0 Draft by BHE
Environmental for site maps and further information
March 10, 2009 11 EcoLogic Associates, P.C.
APPENDIX G
Sediment Trap Detail Drawings
BHE Environmental, Inc. Defining Environmental Solutions

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