20190288 Ver 1_More Information Received_20190815

Staff Review
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ID#* Version* 1
20190288
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Reviewer List:* Sue Homewood:eads\slhomevtood
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Project Submittal Form
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Project Contact Information
Name: Anna Priest
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Project Information
Existing ID #: Existing Version:
20190288 1
20170001 (no dashes)
Project Name: Buckeye Reservoir Modifications
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County (ies)
Watauga
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995 CW response to agency comments
184.04KB
08062019. pdf
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Response to agency comments
V By checking the box and signing box below, I certify that:
• I have given true, accurate, and complete information on this form;
• I agree that submission of this form is a "transaction" subject to Chapter 66, Article 40 of the NC General Statutes (the
"Uniform Electronic Transactions Act")
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• I understand that an electronic signature has the same legal effect and can be enforced in the same way as a written
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Signature:
Submittal Date: Is filled inautorratically.

CLearWater
C1earWater Environmental Consultants, Inc.
vvvv'w.cwenv com
August 6, 2019
Ms. Amanda Jones
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
Subject: Response to Agency Comments
Request to Modify 404 Permit, Buckeye Reservoir, Town of Beech Mountain
Buckeye Creek Reservoir, Watauga County, North Carolina
Dear Ms. Jones:
Below are responses to comments received by the North Carolina Wildlife Resources Commission
and the North Carolina Division of Water Resources regarding the Buckeye Creek Reservoir
permit modification request that was submitted to the US Army Corps of Engineers on February
21, 2019.
Please review the following responses to each comment for clarification to modify the US Army
Corps of Engineers permit that was issued to the Town of Beech Mountain on November 28, 1984.
NC Wildlife Resources Commission (WRC) comments from letter dated March 7,2019:
1. The proposal would require the town to release the 7Q10 value when upstream flows are at or
greater than 7Q10 and require that inflows equal ou�qows when upstream flows are lower than
7QI0. Thus, the Town would only be required to release 7QI0 or lesser flows. The 7Q10 was
never meant to be an instream flow standard, and it is inadequate to protect aquatic ecosystems.
We recommend that flow requirements be based on Mean Annual Flow and follow a 3 -tiered
system like that recommended by NC Division of Water Resources (NCDWR) at the on-site
meeting held on October 15, 2018 and described in their February 1, 2016 letter regarding the
Buckeye Creek Reservoir required minimum release reevaluation. This 3 -tiered system allows
for varied minimum releases based on the Mean Annual Flow and Water Shortage Response
Plan tiers.
Below are proposed modifications to the Special Conditions for the Buckeye Lake dam
permit modification request. The tables below have been adopted from the February 1,
2016 NC Department of Environmental Quality Required. Minimum Release Reevaluation
letter. Please note, the Mean Annual Flow figure has been modified from 7.0 cfs as noted
in the 2016 DEQ letter to 6.32 cfs per the Jennings Environmental Hydrologic Study dated
November 12, 2018.
32 Clayton Street
Asheville, NC 28801
828-698-9800 Tel

SAW -2018-02144
August 6, 2019
Page 2 of 5
Minimum Release Requirement Tables Ia. and lb.
Table 1 a. January 1— April 15:
Tier
Reservoir
Flow Statistic
Minimum
Town Water
Water
Release
Restriction Action
Surface
Requirement
Elevation
CFS (MAF =
6.32
1
Top of
40% MAF
2.53
Voluntary Restrictions
spillway
= 3,428 ft
amsl*
2
4 -- 6.5 ft
20% MAF
1.26
Mandatory
below
Restrictions (10% -
spillway
20% reduction
3
13.5—
0-19% MAF
Inflow will
Emergency Restriction
23.5 ft
equal outflow
(25% reduction) and
below
using Upstream
Water Rationing
spillway
USGS Stream
Gauge Data
Notes:
*above mean sea level
Table 1b. April 16 — December 31:
Tier
Reservoir
Flow Statistic
Minimum
Town Water
Water
Release
Restriction Action
Surface
Requirement
Elevation
CFS (MAF =
6.32
1
Top of
20% MAF
1.26
Voluntary Restrictions
spillway
= 3,428 ft
amsl
2
4 — 6.5 ft
15% MAF
0.95
Mandatory
below
Restrictions (10% -
spillway
20% reduction
3
13.5—
0-14% MAF
Inflow will
Emergency Restriction
23.5 ft
equal outflow
(25% reduction) and
below
using Upstream
Water Rationing
spillway
USGS Stream
Gauge Data

SAW -2018-02144
August 6, 2019
Page 3 of 5
2. The proposal notes that the 7Q10 value may be modified based on three years of hydrologic
data from the downstream and upstream gauging stations, which were installed in December
2018 and February 2019. USGS generally bases 7Q10 values on at least 10 years of data, and
we recommend that any 7Q10 modification adhere to this protocol.
The 7Q10 will no longer be used to calculate outflow from the Buckeye Creek Reservoir.
The Town will base minimum release requirements on percentages of the Mean Annual
Flow per the proposed tables above which was calculated as 6.32 cfs in the Jennings
Environmental Hydrologic Study dated November 12, 2018.
3. We request that the applicant explain how' they will maintain outflows that equal inflows.
Information should be provided on the protocols used to adjust flows, including how the
frequency of adjustment, whether the adjustments will be automated or manual, and how
records on flows will be maintained. We also request details on the outflow structure, including
at what elevation it will be set in relation to the lake bottom or normal pool elevation.
US Geological Survey Stream Gauges have been installed upstream and downstream of
the Buckeye Creek Reservoir. These gauges are continuously recording flow stage data
every five minutes and available for public access via the USGS website at
waterdata.usgs.gov. The USGS staff will measure stream velocities at various flow stages
throughout the year to develop stage -discharge calibration relationships for accurately
reporting real-time stream flow in cubic feet per second on the website.
Once the stream gauges are calibrated for stage -discharge relationships, the Town will
utilize the Upstream Gauge stream flow during low flow conditions to maintain required
minimum outflow (Tier 3 from Tables 1 a and Ib above). The Town will also utilize the
Downstream Gauge to adhere to minimum release requirements during Tier 1 and 2
conditions.
The Town has upfitted the drain valve to be electrically mechanized. It is located at
approximately 38 feet below spillway. This valve will be operated by Town staff at the
water plant to adhere to minimum release requirements per Tables 1 a and 1 b above.
4. Any permit modification should be contingent on the upfitting of the dam gate and valve with a
mechanized valve and gate. What is the progress on this- effort?
The dam drain valve was upfitted on May 25, 2019 at elevation 3,390 amsl and is
mechanized and currently releasing enough flow so that when combined with flow over
the spillway the total is at least 1.0 cfs, until further instruction from appropriate
government agencies is given.

SAW -2018-02144
August 6, 2019
Page 4 of 5
NC Division of Water Resources comments from letter dated April 23, 2019:
1. If the US Army Corps of Engineers requests a response to any comments received as a result of
the Public Notice, please provide the Division with a copy of your response to the USA CE.
The US Army Corps of Engineer public notice comment deadline was June 6, 2019
therefore all comments have been received at this time.
Multiple public comments were received that asked the Town to address the issue of aging
waterlines. The Town is committed to replacing infrastructure to reduce water loss and
has allocated $3.3 million in the next two years and another $3.42 million in the next 6
years to replace waterlines and pressure reducing valves to reduce the amount of water per
day that is lost from defective pipes. In recent years the Town has begun upfitting and
replacing the aging infrastructure.
• New Water Treatment Plant constructed in 2017 uses significantly less process
water.
• All 2" commercial meters were replaced in 2018.
• 100 water meters that were installed in 2007 are scheduled to be replaced in 2019.
Upon completion, the Town's water system will have meters with the oldest install
date of 2011.
• A 700 -foot water line replacement on Slopes Road was completed in 2018.
• 17,000 feet of water lines and 142 service connections are currently being permitted
for replacement with an expected completion date of 2020. This project is the
continuation of a water main upgrade plan to replace large areas of galvanized
piping that was installed in the late 1960's by the original developer before the
township was incorporated.
• The recent $1.6 million Spruce Hollow transmission main project replaced about
2.5 miles of mains.
Lastly, with the installation of stream gauges and the dam valve replacement, the Town
should improve downstream water quality by more accurate release amounts.
2. The minimum flow release schedule that has been proposed is not in accordance with previous
comments provided by the Division and other resource agencies. As proposed, the project will
not meet downstream water quality standards and must be modified. The Division recommends
scheduling a meeting between the applicant, their agents, and the permitting and resource
agencies prior to resubmitting a modified minimum flow release schedule.
Please see proposed minimum release requirement Table 1 a and lb above.
3. Provide detailed information on how the Town will maintain outflows from the reservoir in the
future. Information should be provided on the protocols used to adjust flows, including how
the frequency of adjustment, whether the adjustments will be automated or manual, and how
records offlows will be maintained.

SAW -2018-02144
August 6, 2019
Page 5 of 5
Please see response to WRC comment 3 above.
4. Provide details on the outflow structure, including at what elevation it will he set in relation to
the lake bottom or normal pool elevation.
Please see response to WRC comment 4 above.
Thank you for reviewing the responses to agency comments above. Should you have any questions
or comments concerning this project please do not hesitate to contact me at 828-698-9800.
Sincerely,
Priest, P.W.S.
Project Manager
cc:
US Fish and Wildlife Service — Byron Hamstead
NC Wildlife Resources Commission — Andrea Leslie
NC Division of Wildlife Resources — Sue Homewood
� - 9,� �le*
R. Clement Riddle, P.W.S.
Principal