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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management

James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director

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- -- --
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DEHNR

February 16, 1996

MEMORANDUM

TO: Melba McGee

FROM: Steve W. Tedde

SUBJECT: Project Review #96-0470 - Corps of Engineers Scoping Letter, Section 216
Study of Island Creek Dam and Pumping Station, John H. Kerr Reservoir,
Granville County

The Water Quality Section has reviewed the subject scoping letter. In addition, section
staff (John Dorney, Juan Mangles, and Monica Swihart) met with the Corps of Engineers
(COE) on February 9, 1996 to discuss the proposed project. The following issues will need
to be addressed in the Section 216 reconnaissance report:

1. Wetland Mitigation - The COE estimates that about 1,050 acres of wetlands would be
lost due to flooding, should the pumping station be abandoned. This would require an
immense wetland mitigation effort - one of the largest ever undertaken in North Carolina.
Costs of mitigation are notoriously difficult to quantify since costs vary tremendously.
However, costs for restoration of bottomland hardwood forests have been reported to average
25 thousand dollars per acre. This would yield a mitigation cost of 25-50 million dollars (the
later assuming a 2: 1 mitigation ratio). In their economic evaluation, the COE should include a
more exact cost of mitigating for the flooded wetlands. Questions regarding the Division's
401 Water Quality Certification process should be directed to John Dorney in the Section's
Ecological Assessment Group, at [phone].

2. Tailings Pond - The possibility of not flooding the tailing pond by raising the height
of the lower dam should be examined. Since lead (and possibly other heavy metals) are
present in the tailings pond, flooding of these areas may result in a water quality problem
depending on the environmental chemistry of lead. At the very least, the COE should examine
the likelihood of lead (and other metals) migrating from the flooded ponds into Kerr
Reservoir. I recommend the COE contact Dianne Reid in the Section's Classifications and .
Standards Group, at [phone], ext.568., to discuss water quality standards issues and
possible risk. assessment methodologies. In addition, the COE should cont,act Coleen Sullins in
the Section's Permits and Engineering Unit, at [phone], ext.550, regarding potential
NPDES permitting issues associated with this project.

P.O. Box 29535, Raleigh. North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper

Ms. Melba McGee
February 16, 1996
Page 2

3. Expansion of the Scope of the Section 216 Study - We strongly recommend that the
COE expand the scope of the Section 216 study downstream of John H. Kerr Reservoir to
parallel those being conducted by North Carolina Power Company as part of the FERC
relicensing of the Gaston and Roanoke Hydroelectric Projects. The operations of Kerr, Gaston
and Roanoke Rapids reservoirs are interconnected and the water quality impacts in the lower
Roanoke River are influenced by each of these projects. According to the FERC license for
the Roanoke Rapids and Gaston hydropower facilities, and the flood control Memorandum of
Understanding between Virginia/Carolina Power and the COE, floods are directly passed
downstream via the Roanoke Rapids dam due to the limited storage capacity of the Roanoke
Rapids reservoir. Therefore, both the COE and VirginiaINorth Carolina Power share
responsibility regarding the downstream water quality impacts associated with these lake
operations.

Our Division is concerned about the water quality impacts of floodplain inundation
during flood control operations and the subsequent return of water stored in overbank. areas to
the main channel during low flow releases. During July 1995, the COE had been operating
Kerr Reservoir in flood control mode at ranges from about 19,000 cfs to 25,000 cfs for about
thirty days, after which flows were reduced overnight to about 4,000 cfs at the Roanoke
Rapids dam. A major fish kill in the lower Roanoke followed that summer and it is believed
to have been caused by drainage of hypoxic swamp water into the river mainstem following
inundation of the flood plain during the high flow release period.

Since that time, several Divisions in our Department have attended a series of
meetings with representatives of North Carolina Power and the COE to discuss proposed
measures for minimizing the possibility of a recurrence of another fish kill along the
Roanoke. North Carolina Power has developed and initiated implementation of a "Lower
Roanoke River Environmental Betterment Plan" as part of an overall management strategy for
the lower Roanoke River. As part of this plan, NC Power has been involved in promoting
and participating in Lower Roanoke River Basin water quality modeling studies.

As part of the relicensing, VirginiaINorth Carolina Pow~r plan to ~ponsor the
development of a hydrologic model from Roanoke Rapids to the Albemarle Sound. This
model will be developed by the U.S. Geological Survey to evaluate the effects of selected
dam release scenarios on streamflow and the extent of floodplain inundation. The proposed
model has been specifically designed to be fully compatible with water quality models
maintained by the U.S Army COE Waterways Experiment Station. This approach was
developed with the understanding that in the future, the COE may develop a water quality
model to be used in conjunction with the USGS hydrologic model.

... " SIlo

Ms. Melba McGee
February 16, 1996
Page 3

Due to the significance of the impacts that tpe operations of Kerr Reservoir have on
downstream water quality, the Division strongly recommends that the Island Creek Section
216 project be expanded to expedite the development of this important modeling effort.

Thank you for the opportunity to provide these comments. Please feel free to contact
Monica Swihart, of my staff at [phone], ext.567, if you have any questions regarding
this memorandum.

11171er.mem

cc:

Ken Eagleson
Dennis Ramsey
Coleen Sullins
John Dorney
Juan Mangles
Steve Kroeger
Monica Swihart
Dianne Reid
Steve Reed, Division of Water Resources

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From:

Date:

Subject:
To:

Page 1

Note for Jimmie Overton

Jimmie Overton

Fri, Jun 14, 1996 12:32 PM
RE: Kerr Lake - Wetlands Mitigation
Don Safrit

If possible we would like to change the date on this meeting. John definately needs to be
there. He would be able to meet Monday, Tuesday, or Friday of this week. or we could
meet tuesday of june 25. Any of these work?

From: Don Safrit on Thu, Jun 6,19961:20 PM
Subject: Kerr Lake - Wetlands Mitigation
To: Jim Overton; Ken Eagleson
Cc: Steve Tedder

Steve would like for us to meet at 8:00 am on Thursday, June 20th (his office) to discuss a
proposal by the Corps of Engineers to flood a "low priority" superfund site on Island Creek.
This site was a previous tungsten mine that was last used in 71. The current pump station
that is used to keep the area from flooding is approaching it's useful life and the COE is
interested in evaluating flooding vs the $10 million upgrade.

One particular issue that they are uncomfortable about is the estimate John Dorney gave them
(their word) of $50,000 per acre mitigated. With approximately 1,000 acreas of wetlands that
would be inundated, that comes to $50 million, way more than the upgrade.

I'll give you more scoop at the meeting concerning characterization of the site, EAlEIS, risk
assessments, etc... Please let me know if this date and time cause any conflict.

Thanks, Don

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Page 1

Note for Jimmie Overton

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From:

Don Safrit
Thu, Jun 6, 1996 1:20 PM
Kerr Lake - Wetlands Mitigation
Jim Overton; Ken Eagleson
Steve Tedder

Date:

Subject:
To:

Cc:

Steve would like for us to meet at 8:00 am on Thursday, June 20th (his office) to discuss a
proposal by the Corps of Engineers to flood a "low priority" superfund site on Island Creek.
This site was a previous tungsten mine that was last used in 71. The current pump station
that is used to keep the area from flooding is approaching it's useful life and the COE is
interested in evaluating flooding vs the $10 million upgrade.

One particular issue that they are uncomfortable about is the estimate John Dorney gave them
(their word) of $50,000 per acre mitigated. With approximately 1,000 acreas of wetlands that
would be inundated, that comes to $50 million, way more than the upgrade.

,

111 give you more scoop at the meeting concerning characterization of the site, EAlEIS, risk
assessments, etc... Please let me know if this date and time cause any conflict.

Thanks, Don

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Department of Environment, Health, and Natural Resources
O.ffice of Legislative and Intergovernmental Affairs
Project Review Form

Project Number:

County:

Date:

This project is being reviewed as indicated below:

o Project located in 7th floor library

11111

Regional Office/Phone

Regional Office Area

In-House Review

o Asheville
o Fayetteville
o Mooresville
o Raleigh
o Washington
o Wilmington
o Winston-Salem

o All R/O Areas
DAir
o Water ..
o Groundwater
o Land Quality Engineer
o Recreational Consultant
o Coastal Management Consultant
o Others
PWS

bij"soil and Water

o Coastal Management

o Water Resources

,~t1dlife

'fi(Forest Resources

o Land Resources

~arks and Recreation

~nvironmental Management
Monica Swihart
~~~~

Manager Sign-Off/Region:

Date:

Response (check all applicable)

o Marine Fisheries
~Water Planning
~ Environmental Health
o S~lic;l W~~te Management
o Ridfation Protection
o oavtcJ Foster
o Other (specify)

In-House Reviewer/Agency:

Regional Office response to be compiled and completed by Regional Manager. In-House Reviewer complete individual response.

o No objection to project as proposed 0 Not recommended for further development for reasons
stated in attached comments (authorlty(ies) cited)

o No Comment 0 Applicant has been contacted

o InsufficiEmt information to complete review 0 Applicant has not been contacted

o Project Controversial (comments attached)

o Consistency Statement needed (comments attached)

o Consistency Statement not needed

o Full EIS must be required under the provisions of
NEPA and SEPA '

o Approve

o Permit(s) needed (permit files have been checked)

o Recommended for further development with recommendations for
strengthening (comments attached) .

o Recommended for further development if specific & substantive
changes incorporated by funding agency (comments
attached/authority(ies) cited) ,

o Other (specify and attach comments)

RETURN TO:

Melba McGee

, Office of Legislative and Intergovernmental Affairs

.

I.~

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMINGTON, NORTH CAROUNA28402.1890

January 2, 1996

REPLY TO
'= ATTENTION OF

Special Studies and Flood
Plain Services section

Dear Madam or Sir:

We are conducting studies related to the operation
of John H. Kerr Dam and Reservoir, North Carolina and
Virginia. The study is being conducted under the
. section 216 of the 1970 Flood Control Act.
section 216 is for reevaluation 0 purposes
operations of existing Federal projects. The focus of
the studies is on the Island Creek Dam and Pumping
station. The location of the Island Creek facility is
on the North Carolina - Virginia state boundary in the
southwestern part of Kerr Reservoir. The exact
location' is shown on the enclosed map.

In the 1950's it was feared that creat~on OJ: t.h~
Kerr Reservoir would interfere with mining operations
in the Hamme Tungsten District. The Government agreed
to build Island Creek Dam and Pumping station to
minimize the impact of Kerr Reservoir on the mining
operations. The mining company in turn agreed to
compensate the Government for costs of operating and
maintaining the facility.

The agreement made during the construction of the
Kerr and Island Creek facilities remained in effect
until 1983 when the mining company notified the
Government that it had no further interest in the site.
The mining interests have discontinued financial
support for Island Creek and have released the
Government from the obligation to operate and maintain
the pumping station. There has been no other known
interest in the mining operations, and no compensation,
is being made for operation of the facility. Although
the Island Creek facility no longer serves its
authorized purpose, it still requires substantial
expenditures-and energy to maintain and operate.
Furthermore, the facility has now been operating for
over 40 years and the Government 'cannot expect the
pumping station to-continue to operate dependably
indefinitely. As a result, the need for continuation
of the pumping station is being evaluated.

.- Printed on . Recycled Paper

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In this study we are examining the consequences of
the facility's declining reliability and developing
alternative solutions. Two preliminary plans for
modification of the Island Creek facility will be
developed - cessation or continuation of the pumping
operation. Kerr Reservoir on the opposing side of
Island Creek Dam has a normal pool elevation of
300 feet m.s.l. (above mean sea level) and a maximum
flood storage pool elevation of 320 feet m.s.l. The
pumping station draws down the Island Creek Reservoir
to maintain a pool elevation of 258 feet m.s.l. In the
Island Creek basin the Government holds flowage
easements only up to elevation 290 feet m.s.l.
Cessation of pumping would require relocation of any
infrastructure and property between elevation 255 and
320 feet m.s.l., mitigation for loss of habitats, and
removal of any environmental threats from mine
tailings. Continuation of pumping, the other main
alternative, would require improved dependability by
replacement or rehabilitation of the pumping station
and justification and sponsorship for its operation.

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The North Carolina Power Company is currently
involved in studies of the Roanoke River system as part
of its Roanoke Rapids and Gaston Hydropower Relicensing
project. We will consider expanding the scope of our
Section 216 study downstream of John H. Kerr Reservoir
to parallel those being conducted by the North Carolina
Power Company.

We are requesting comments from agencies, interest
groups, and the public to identify and discuss
significant issues of concern and recommendations for
additional studies, if needed. Comments received in
response to this scoping letter will be considered as

we conduct our studies. Significant resources
(including historic resources, recreational and
esthet~c resources, endangered and threatened species,
fish and wildlife resources, wetlands, water quality,
and freshwater and upland ,habitats) will be addressed,
as appropriate, in the Section 216 reconnaissance
report.

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We request that you provide written comments on any
of these matters ~ithin 30 days from the date of this
letter. Comments should be addressed to the District
Engineer; (Attention: Mr. Doug Greene); u.s. Army
Corps of Engineers, Wilmington District; Post Office
Box 1890; Wilmington, North Carolina 28402-1890. No
formal scoping meetings are planned at this time, but
based on the responses received, scoping meetings may
be held with specific agencies or individuals as
required. If you need additional information, please
call Mr. Greene at [phone].

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Enclosure

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