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HomeMy WebLinkAbout20170359 Ver 2_WRC Min Release Info_20190927Homewood, Sue From: Leslie, Andrea J Sent: Friday, September 27, 2019 9:25 AM To: Homewood, Sue; Tarver, Fred Cc: Moore, Andrew W; Goudreau, Chris J. Subject: RE: lake dredging project Attachments: GrandfatherGolfCoCLubLakeDredginglP_LinvilleR_Avery_WRCComments.pdf; Grandfather GCC - special considerations; RE: Grandfather Golf Dam project (UNCLASSIFIED); McGill Response2NCWRCDiscPointsGrandfatherGolf&CC_ 200ct20l 5.pdf Fred, Chris and I worked with the applicant in 2015 to get a minimum flow during the project locked in. I don't know if we ever involved you (if not, our bad) — but we settled on a minimum of 2 cfs. You can see the discussions and how we got there in the attachments. See what you think. Andrea Andrea Leslie Mountain Habitat Conservation Coordinator NC Wildlife Resources Commission 645 Fish Hatchery Rd., Building B Marion, NC 28752 828-803-6054 (office) 828-400-4223 (cell) www.ncwildlife.org Get NC Wildlife Update delivered to your inbox from the N.C. Wildlife Resources Commission. Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties. From: Homewood, Sue <sue.homewood@ncdenr.gov> Sent: Friday, September 27, 2019 8:55 AM To: Tarver, Fred <fred.tarver@ncdenr.gov> Cc: Moore, Andrew W <andrew.w.moore@ncdenr.gov>; Leslie, Andrea J <andrea.leslie@ncwildlife.org> Subject: lake dredging project Hey Fred, Andrew Moore and I have a permit application for lake dredging (and other lake improvements) in Avery County. We're just starting our review. Comments are due to the USACE on 10/23 per their public notice. Here's the LF file. This project came up a couple years ago (but they didn't finalize it) and Andrea Leslie recommended a minimum release flow which they have incorporated into their current application. Please let me know by 10/11 if you have any comments or concerns. That will give us time to discuss further prior to developing comments to go to the USACE/applicant. Thanks, Sue Homewood Division of Water Resources, Winston Salem Regional Office Department of Environmental Quality 336 776 9693 office 336 813 1863 mobile Sue. Homewood@ncdenr.gov 450 W. Hanes Mill Rd, Suite 300 Winston Salem NC 27105 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Homewood, Sue From: Leslie, Andrea J Sent: Monday, April 24, 2017 2:32 PM To: john vilas Qohn.vilas@mcgillengineers.com); Jon Swaim Cc: Moore, Andrew W; 'Elliott, William A CIV USARMY CESAW (US)' Subject: Grandfather GCC - special considerations Hi John and Jon, I wanted to summarize our concerns and ideas about the Grandfather Golf & CC (GGCC) dredging project. I'm poised to send NCWRC's official comments on the 404/401, but thought it would be wise to work out some ideas about turbidity monitoring with you beforehand. Due to the quality of the downstream resource (excellent wild Brown and Rainbow Trout fishery, rare and endemic Grandfather Mountain Crayfish) and because you have requested to work within the trout moratorium, we'd like some specific measures incorporated to minimize risk to the Linville River. We worked out some of measures during our conversations in Fall 2015 for the dam repair project. Most of these ideas were also discussed on our site visit, but we didn't talk about turbidity monitoring. Here are our key recommendations: • We'll allow GGCC to work during the Rainbow Trout Moratorium/ latter half of the Brown Trout moratorium—January 1- April 15. • As the spoil site is to be placed on a steep hillside that is already fashioned into a plateau by spoil, geotechnical analysis should be performed of the spoil site to ensure that it can hold the spoil anticipated. In addition, a sediment and erosion control plan for the spoil site should be developed, including measures (in addition to silt fences) that will keep sediment on site. • Oversight of project activities should be overseen by McGill staff. I recommend a daily site visit during dredging activities. Flows must be maintained in the Linville River at all times, with a minimum of 2 cfs. As the project will be performed during the trout moratorium, we ask that GGCC monitor turbidity with a turbidity meter during project activities. My thoughts are that at a minimum, this should be done at least 2x/day during dredging. Turbidity readings could be reported daily to McGill and shared with NCWRC if over a certain threshold, which could be related to some background level. Can you come up with some specific guidelines here? Andrea Andrea Leslie Mountain Habitat Conservation Coordinator NC Wildlife Resources Commission 20830 Great Smoky Mountain Expressway Waynesville, NC 28786 828-558-6011; 828-400-4223 (cell) www.ncwildlife.org FMq f. ■ 4 00 p w, + Get NC Wildlife Update delivered to your inbox from the N.C. Wildlife Resources Commission. Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties. � North Carolina Wildlife Resources Commission � Gordon Myers, Executive Director August 11, 2017 Mr. William Elliott U.S. Army Corps of Engineers, Regulatory Branch 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-5006 SUBJECT: Grandfather Golf and Country Club Lake Dredging Project Linville River, Avery County Action ID#: SAW -2017-01373 Dear Mr. Elliott: Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an individual permit application for Grandfather Golf and Country Club (GCC) to mechanically dredge up to 42,000 yd from 6.2 acres and stabilize 1,568 feet of shoreline on Loch Dornie, an in-line pond on the Linville River in Avery County. I visited the site with staff of the NC Division of Water Resources (NCDWR) and McGill Associates on April 5, 2017. Our comments on this application are offered for your consideration under provisions of the Clean Water Act of 1977 (33 U.S.C. 466 et. seq.) and Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d). There are Brown Trout and Rainbow Trout in the Linville River downstream of the project. To allow the applicant to achieve this work during their off-season, we will allow work to proceed during the second half of the Brown Trout moratorium. Project activities should be avoided between October 15 and December 31. The Linville River also supports the endemic and rare Grandfather Mountain Crayfish (Cambarus eeseeohensis, US Federal Species of Concern, NC Significantly Rare). The project will involve lowering the lake to dewater the upper 6.2 -acre area of Loch Domie that is to be dredged. The river will be routed to the western side of the upper lake area to allow the other side of the lake to dry out. This dewatered side of the lake will be mechanically dredged. Then flows will be routed to the eastern side of the upper lake area and the western side be allowed to dry out, after which it will be mechanically dredged. A turbidity curtain will be set up in the lake downstream of the work areas to minimize turbidity loss from the work areas to the lake. Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721 Telephone: (919) 707-0220 • Fax: (919) 707-0028 Grandfather GCC Lake Dredging Project August 11, 2017 Linville River, Avery County Up to 42,000 yd of spoil will be deposited on a 1.6 -acre upland site. The spoil area is a cut and filled area on a steep hillside. We recommend that the applicant perform a geotechnical analysis of the site to assure that it will remain stable with the planned additional spoil. In addition, we recommend that additional sediment and erosion control measures be used at the site to ensure that sediment will not be lost from the area, such as settling ponds. Flows must be maintained within the Linville River at all times per our recommendations provided in previous correspondence between McGill Associates and NCWRC in the fall of 2015 (email from J. Vilas to A. Leslie and T. Alexander, November 2, 2015) regarding GCC dam maintenance activities. This correspondence stipulated that a minimum flow of 2 cfs is to be maintained at all times, including during pond refill. In addition, as the dredging activity is so extensive and will likely be implemented during the trout moratorium, we request that the applicant monitor turbidity at the lake outfall during lake drawdown, dredging, and refill. We recommend that the applicant work with the NC Division of Water Resources and NCWRC to develop turbidity monitoring methods, turbidity benchmarks, and actions to be taken if excessive turbidity does occur. We offer the following additional recommendations to minimize impacts to terrestrial and aquatic resources from the project: 1. Project activities should be accomplished as quickly as possible and vigilance used in sediment and erosion control during site preparation, construction, and clean up. Dredge areas should be surrounded by silt fence and/or other measures used to retain sediment at the dredge site. 2. Disturbed areas at the sediment disposal site and stream bank stabilization areas should be seeded, mulched and/or matted as soon as possible. Any erosion control matting used should be free of plastic or nylon mesh, as this type of mesh netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last for years. 3. We request that McGill Associates provide daily oversight of project activities, assuring that adequate sediment and erosion control is being used at both the dredging and spoil deposition sites. Thank you for the opportunity to review and comment on this project. Please contact me at (828) 558-6011 if you have any questions about these comments. Sincerely, Andrea Leslie Mountain Region Coordinator, Habitat Conservation Program ec: John Vilas, McGill Associates Andrew Moore and Sue Homewood, NC Division of Water Resources David Goodfred, Chris Wood, and TR Russ, NCWRC McGill A S S O C I A T E S October 20, 2015 Ms. Andrea Leslie Balsam Depot, 20830 Great Smoky Mtn. Expy Waynesville, NC 28786 Re: Grandfather Golf and Country Club PCN for Dam Maintenance Activities Response to WRC Comments Dear Andrea, Thank you for your comments, I have discussed these with the project engineer and would like to provide the following response: General Information: The crest of the dam is at elevation 3798', the normal pool elevation of the lake is 3788', the low flow/bottom drain invert is approximately 3758'. The approximate drainage area of the Linville River at GGCC dam is 3.6 sq. -mi. Construction Sequence Relating to Flow in Linville River: 1. Open bottom drain valve to begin lake drawdown 2. Contract WWTP Operator to monitor turbidity levels in valve -pipe channel below pipe according to approved schedule 3. Lake level drops below spillway 4. Lake level drops below 3768, large by-pass pumps are mobilized on site 5. Contingency for excess sediment discharge: close valve until outflow turbidity is reduced and start surface drain with by-pass pumps 6. Lake drains to within 2 feet of invert pipe elevation — begin bypass pumping over spillway, pumps run 24/7 7. Install cofferdam as soon as area around intake pipe is drained 8. Pump out cofferdam into silt bags or filter basin to drain back into lake bed 9. Monitor weather forecast for at least 3 consecutive days of minimal precipitation 10. Commence pipe rehabilitation and valve replacement with minimum of 3 rain -free days forecast 11. Commence irrigation intake structure replacement (separate contractor) 12. Complete pipe and valve rehabilitation 13. Complete irrigation intake structure replacement 14. Remove cofferdam and any excess fill material in lake bed 15. Slow by-pass pumping and allow lake to begin to fill E n v i r o n m e n t a l 0 P l a n n i n g 0 F i n a n c e McGill Ass ociates, P.A. • 468NewMarketBlvd. Ste. B, Boone, North Curolina28607 Office: (828) 386-1920 • Fax: (828) 386-1923 16. When lake level rises to approximately 2 feet above pipe, open valve to maintenance flow rate, stop by-pass pumps, allow lake to refill naturally Turbidity Monitoring: The Contract WWTP operator for GGCC will collect samples from the bottom drain discharge pipe once per day during the drawdown phase. Samples will be tested for turbidity, if testing results indicate turbidity levels exceed 25 ntu's during this drawdown process, the bottom drain valve will be partially closed until measured turbidity of discharge water is less than 25 ntu's. Estimated Drawdown Time: The estimated drawdown time for the lake is uncertain due to the large number of factors that could influence the estimate, however, based on past experience, in the absence of substantial rain, drawdown should occur in between one and two weeks. Prosect Timeline: The entire process from beginning to install the cofferdam to removal of the cofferdam is expected to take approximately 2 weeks but this could be affected by weather. The most critical portion of the operation will be inserting the new pipe sleeve and grouting the space between the old and new pipe, this phase is expected to take 3 or 4 days. Low/Maintenance Flow Analysis: The drainage area of the Linville River at GGCC is approximately 3.6 sq.mi., In the absence of recorded flow data for this section of the Linville River, comparisons are made with data from two sources (see Table below). 1) The Linville River gage at Nebo (DA=66.7 sq.mi.) and 2) Mill Timber Creek at Crossnore (DA=3.9 sq.mi.). Drainage area ratios were used to directly compare recorded low flow data between these watershed areas. Watershed Avg. Unit R/O (cfs/mi^2) 7Q2 (cfs) 30Q2 (cfs) 7Q10 (cfs) W7Q10 (cfs) Mill Timber Ck 2.5 2.4 3 1.6 2.2 Ratio x.9 LR @ GGCC 2.16 2.7 1.44 1.98 LR @ Nebo 2.2 31 40 17 27 Ratio x.054 LR @ GGCC 1.67 2.16 .92 1.46 E n v i r o n m e n t a l • P l a n n i n g 0 F i n a n c e McGill Ass ociates, P.A. • 468NewMarketBlvd. Ste. B, Boone, North Curolina28607 Office: (828) 386-1920 • Fax: (828) 386-1923 Comments Regarding Pumping to Maintain Flow in Linville River from Spillway to Valve -Pipe Channel During All Phases of Project: Our assessment of the comments provided on this issue break down the flow management into three phases: 1. Drawdown: Maintain flow between the spillway and valve -pipe channel during initial drawdown of the lake from when the lake level drops below the spillway elevation to when the By -Pass pumps begin pumping 2. Construction: Maintain flow in the Linville River downstream of the project area during the period of construction while the low -flow valve is closed 3. Refill: Maintain flow between the spillway and valve -pipe channel from the time that construction is complete and the low -flow valve is opened until the lake level rises to normal pool elevation Background: The long-standing lake management regime has been to maintain a low flow cold water release through the 24" cmp connected to the lake bottom drain valve. This is the pipe to be rehabilitated as part of this project. During low flow periods, every year and often multiple time per year flow into the lake drops below the maintenance flow level released through the bottom drain and the lake level drops below the spillway elevation. When this happens, the portion of river bed between the spillway and the confluence with the valve -pipe channel is fed by a small tributary that drains to the riverbed less than 100 -feet below the spillway. In addition to flow from this tributary, there are apparent groundwater inputs along this reach of channel as evidenced by the increase of flow rate along this reach. There is also a very large pool (approximately 50 feet -long and up to 8 feet -deep) located about 200 linear feet downstream of the spillway and below an almost continuous stretch of cascading bedrock falls. This pool is the first area, below the spillway that provides substantial instream habitat. This information is significant to show that the channel between the spillway and the valve - pipe channel does receive constant flow whether or not water is discharging over the spillway, and that this reach of channel is resilient to periods when no flow is passing over the spillway because of the inputs from the tributary and groundwater. In light of this information, we suggest that providing pumps and maintaining those pumps 24/7 during the Drawdown and Refill phases of the project will not fulfill a proportionate need to protect aquatic life in the Linville River and, therefore, we propose to only pump flow from the Linville River over the dam during the Construction phase. This argument is grounded in a basic cost/benefit analysis. First, the benefit side of the equation, the goal is to protect the aquatic resource and the species it supports, as well as all downstream users of the resources. We understand and fully anticipate the need to pump the flow coming into the lake bed during the Construction phase, while the low flow valve is closed. Pumping during this phase of the project is essential both to maintain downstream flows and to keep the work area dry to facilitate the proposed work. The real issues are with maintaining flow during the Drawdown and Refill phases when the low -flow valve will be open. Pumping during these two phases will only serve to increase flow, over background, for about 1100 linear E n v i r o n m e n t a l 0 P l a n n i n g • F i n a n c e McGill Ass ocicries, P.A. • 468NewMarketBIvd. Ste. B, Boone, North Carolina28607 Office: (828) 386-1920 • Fax: (828) 386-1923 feet of channel. As discussed in the background paragraph above, we would argue that within this 1100 foot -long reach, the current and long-standing flow regime is highly variable with the lake level dropping below the spillway crest occasionally most years during dry periods. Combine this with the fact that there is one small tributary and additional groundwater inflow to the 1100 foot -long channel that provide a level of baseflow that, in our opinion, is sufficient to sustain aquatic life in this reach, particularly for short periods during the cooler part of the year when the proposed work is planned. Second, is the cost side of the equation, which is a little more uncertain due to weather variability, but can be broken into project phases. There are two periods of time where pumping of maintenance flows have been recommended, during the Drawdown phase and again during the Refill phase. Both operations would be similar in terms of methods and equipment. The unknown factor is time and this is primarily tied to weather, a rain event during drawdown will add time and a lack of rain during refill will add time. The primary cost items are as follows: • Pump and power source: The pump required to move 1 cfs approximately 800 feet horizontally and approximately 30 feet vertically • Pump operator: Someone would have to be onsite 24/7 to monitor pump operation, fuel levels, and intake hose An accurate estimate of the total cost for these two items would be difficult to make at this time but it is clear that this would be a major project cost that we do not believe is necessary. Construction Pumping Phase: Pumping of flows entering the lake basin during the construction is essential to the success of the project. It is anticipated that this phase will last approximately two weeks. The most critical portion of the operation will be inserting the new pipe sleeve and grouting the space between the old and new pipe, this phase is expected to take 3 or 4 days. It is anticipated that a pumping capacity of 4 to 6 cfs will be needed to manage flows during the construction phase. Trout Moratorium Comment: It has been recommended that the proposed work occur outside of the October 15 to April 15 moratorium period generally applied to waters containing Brown and Rainbow trout. We request on behalf of our client that the proposed work be allowed to occur during the late fall or late winter/early spring period. It is our opinion that this is a reasonable request for the following reasons: 1. The project involves a flow management plan that will insure that no disruption of flow occurs in the Linville River downstream of the lake. 2. The project has been designed to avoid any work in flowing waters and the only work in waters will be in the drained lake bed. 3. Turbidity monitoring is proposed during the drawdown period, with a contingency plan to slow or stop the drawdown if levels exceed 25 ntu's. 4. Lake refill and a return to the normal flow regime and management strategy should occur more rapidly during the non -summer period when base flow is generally higher. 5. Safety concerns are greatly reduced by conducting the work in the off season, the construction area is located on the only road across the Linville River within the development. Working along this corridor during the off-season means there will be E n v i r o n m e n t a l • P l a n n i n g • F i n a n c e McGill Ass ocicries, P.A. • 468NewMarketBIvd. Ste. B, Boone, North Curolina28607 Office: (828) 386-1920 • Fax: (828) 386-1923 much less traffic, fewer residents on property, deduced likelihood of emergency situations, and fewer curious on -lookers. If you have any questions please feel free to contact me. Thank you. Sincerely, McGILL ASSOCIATES, P.A. JOHN VILAS Program Services Manager — Environmental Cc: Tasha Alexander, USACE RJ Mozeley, PE McGill Associates E n v i r o n m e n t a l • P l a n n i n g • F i n a n c e Mc Gill Associates, P.A. • 468 New Market Blvd. Ste. B, Boone, North Carolina 28607 Office: (818) 386-1910 • Fax: (828) 386-1923 Homewood, Sue From: John Vilas <john.vilas@mcgillengineers.com> Sent: Monday, November 2, 2015 4:54 PM To: Leslie, Andrea J; Alexander, Tasha L SAW Cc: Goudreau, Chris J.; RJ Mozeley; Goudreau, Chris J.; Cox, David R.; Goodfred, David W.; Wood, Chris J. Subject: RE: Grandfather Golf Dam project (UNCLASSIFIED) Andrea, Please revise #6 to read: #6: Excess turbidity means >25 ntu's. If excess turbidity is measured, the release valve will be partially closed to see if this reduces turbidity and WRC staff will be notified if two or more turbidity readings exceed 25 ntu's. McGill Associates staff will evaluate the likely cause of excessive turbidity and consult with WRC staff regarding other possible responses. We agree that a turbid discharge is better than no discharge so in no case will the valve be completely closed unless surface pumping has commenced at a rate of at least 2 cfs. See comment #8 regarding maintenance of pumping capacity on site during the project. Let me know if this addresses the comment or if additional changes are needed. Thanks, John John Vilas Program Services Manager - Environmental McG0 fl A S S O C[ A T I' S 468 New Market Blvd. Suite B I Boone, NC 28607 Phone: 828.386.1920 1 Cell: 828.964.3962 1 Fax: 828.386.1923 6ohn.vilas@mcgillengineers.com I www.mcgillengineers.com From: Leslie, Andrea J [mailto:andrea.leslie@ncwildlife.org] Sent: Monday, November 02, 2015 4:00 PM To: John Vilas <john.vilas@mcgillengineers.com>; Alexander, Tasha L SAW <Tasha.L.Alexander@usace.army.mil> Cc: Goudreau, Chris J. <chris.goudreau@ncwildlife.org>; RJ Mozeley <Rj.Mozeley@Mcgillengineers.Com>; Goudreau, Chris J. <chris.goudreau@ncwildlife.org>; Cox, David R. <david.cox@ncwildlife.org>; Goodfred, David W. <david.goodfred@ncwildlife.org>; Wood, Chris J. <chris.wood@ncwildlife.org> Subject: RE: Grandfather Golf Dam project (UNCLASSIFIED) Thank you John. All looks good with the exception of #6. If excess turbidity is measured for one sample, then the release valve should be partially closed to see if this reduces turbidity. If not, Grandfather Golf and Country Club must be prepared switch to surface pumping and closing the valve completely. Andrea Andrea Leslie Mountain Habitat Conservation Coordinator NC Wildlife Resources Commission 20830 Great Smoky Mountain Expressway Waynesville, NC 28786 828-558-6011; 828-400-4223 (cell) www.ncwildlife.orL, FST f L6 Get NC Wildlife Update delivered to your inbox from the N.C. Wildlife Resources Commission. Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties. From: John Vilas[mailto:iohn.vilas@mcgillengineers.com] Sent: Monday, November 02, 2015 3:05 PM To: Leslie, Andrea J <andrea.leslie@ncwildlife.org>; Alexander, Tasha L SAW <Tasha.L.Alexander@usace.army.mil> Cc: Goudreau, Chris J.<chris.goudreau@ncwildlife.org>; RJ Mozeley <Ri.Mozeley@Mcgillengineers.Com>; Goudreau, Chris J.<chris.goudreau@ncwildlife.org>; Cox, David R. <david.cox@ncwildlife.org>; Goodfred, David W. <david.goodfred@ncwildlife.org>; Wood, Chris J.<chris.woodchris.wood@ncwildlife.org> Subject: RE: Grandfather Golf Dam project (UNCLASSIFIED) Andrea, Thank you for discussing this we me last week. On behalf of our client, Grandfather Golf and Country Club we provide the following response that I believe will be in keeping with our conversation and should provide final resolution to this issue. The responses are numbered consecutively according to the original comments: 1. This comment is accepted and we agree to pump at least 2 cfs during the entire construction phase of the project. 2. We accept, no instream/in-lake work will occur between October 15 and December 31. 3. As we discussed, McGill staff will visit the site daily during the critical phase of the drawdown phase which is between the period when the lake is 15 feet below normal to full drawdown. McGill staff will observe the coffer dam and related work associated with access to the work area. During construction McGill staff will observe pipe sleeve and valve installation as needed to determine that installation is according to plan. 4. McGill will advise Client to purchase a turbidity meter and will provide guidance and training as needed to bring Client's personnel up to speed with collecting and analyzing turbidity samples. During the critical phase of drawdown McGill staff will perform or observe one turbidity test per day. Turbidity sampling will occur 3 times per day during drawdown and construction phases and once per day during the refill phase. 5. A rain gage will be monitored daily with results recorded with turbidity results. 6. Excess turbidity means >25 ntu's for two consecutive samples. If excess turbidity is measured, the release valve will be partially closed to see if this reduces turbidity and WRC staff will be notified and consulted regarding other possible responses. We agree that a turbid discharge is better than no discharge so in no case will the valve be completely closed unless surface pumping has commenced at a rate of at least 2 cfs. 7. As discussed, Turbidity sampling will occur 3 times per day during drawdown and construction phases and once per day during the refill phase or until NCWRC agrees sampling is no longer needed. 8. We agree to maintain at least 2 cfs pumping capacity at all times during the drawdown and construction phases and until normal flows can be maintained through the rehabilitated pipe and valve. Minimum discharge of 2 cfs will be maintained downstream of the project. John Vilas Program Services Manager - Environmental MeGM A s 5 0 C! A T B' S 468 New Market Blvd. Suite B I Boone, NC 28607 Phone: 828.386.1920 1 Cell: 828.964.3962 1 Fax: 828.386.1923 0ohn.vilas@mcgillengineers.com I www.mcgillengineers.com From: Leslie, Andrea J[mailto:andrea.leslie@ncwildlife.org] Sent: Friday, October 23, 2015 4:18 PM To: John Vilas <john.vilas@mcgillengineers.com>; Alexander, Tasha L SAW <Tasha.L.Alexander@usace.army.mil> Cc: Goudreau, Chris J.<chris.goudreau@ncwildlife.org>; RJ Mozeley<R*.Mozeley@Mcgillengineers.Com>; Bill Roark <Bill.Roark@ Mcgillengineers.Com>; Goudreau, Chris J.<chris.goudreau@ncwildlife.org>; Cox, David R. <david.cox@ncwildlife.org>; Goodfred, David W.<david.goodfred@ncwildlife.org>; Wood, Chris J. <chris.wood@ncwildlife.org> Subject: RE: Grandfather Golf Dam project (UNCLASSIFIED) Hi John, Thank you for your response. NCWRC staff have discussed the letter and we have the following responses: 1. Although we are concerned about the effects of no/little flow in the 1100' reach between the spillway and the valve pipe channel to aquatic life, we agree that for this project, the applicant does not need to maintain flow within this portion of the river during drawdown and refill. 2. Due to the concerns voiced over timing of the project, we will allow for the work to be done during the winter, starting January 1. We require that a modified moratorium of October 15 -December 31 be observed. 3. We would like to know who will be on-site, making decisions about whether to close the bottom valve due to turbidity level or start pipe sleeve work. How will McGill staff be involved during project implementation? 4. We appreciate the efforts made to address turbidity monitoring. However, lab -based turbidity analysis will involve a delay in results, and we believe that it is important to have real-time analysis of turbidity in order to minimize the risk of sediment loss. Therefore, we ask that the applicant analyze turbidity on-site with a real-time analysis method (e.g., turbidity meter) three times per day - (1) in the morning, before construction work, (2) mid-day, and (3) end of the day. Turbidity levels should be recorded and sent to McGill staff each day. If there are 2 or more consecutive turbidity readings >25 NTU, NCWRC staff should be notified. 5. We also ask that the applicant monitor rainfall at the site. If the wastewater treatment plant has a rain gauge, this can be used; if not, one should be installed. Daily rainfall should be logged and sent with the turbidity data to McGill staff each day. 6. The construction sequence (CS) provided is helpful. However, it does contradict with information provided in the body of the text. For example, #5 in the CS states that if there is excess sediment discharge (and does this mean turbidity is measured > 25 NTU? Please clarify), the valve will be closed until outflow turbidity is reduced and surface by-pass pumps will be used. However, on p. 2, it is stated that the bottom valve will be partially closed until turbidity is <25 NTU. The valve should be closed completely if turbidity is high. 7. We ask that turbidity be measured from the start of drawdown until lake refill is complete or until NCWRC agrees that turbidity monitoring is no longer needed. 8. Various flow statistics are provided, but a target discharge is not suggested. #15 in the CS states that bypass pumping will be slowed and the lake allowed to refill, and #16 states that downstream flows will be switched to the valve with a'maintenance rate' once the lake level rises 2 ft above the pipe. We recommend that a minimum flow of 2 cfs be maintained in the Linville River at all times, whether via surface pump, bottom valve, or a combination of the two. Flows coming into the lake should be 2-3 times this amount during the winter months, so there should be good excess flow to refill the lake. Have a good week -end, Andrea Andrea Leslie Mountain Habitat Conservation Coordinator NC Wildlife Resources Commission 20830 Great Smoky Mountain Expressway Waynesville, NC 28786 828-558-6011; 828-400-4223 (cell) www.ncwildlife.org Get NC Wildlife Update delivered to your inbox from the N.C. Wildlife Resources Commission. Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties. -----Original Message ----- From: John Vilas[mailto:john.vilas@mcgillengineers.com] Sent: Tuesday, October 20, 201512:02 PM To: Alexander, Tasha L SAW <Tasha.L.Alexander@usace.army.mil> Cc: Leslie, Andrea J <andrea.leslie@ncwildlife.o ; Goudreau, Chris J.<chris.goudreau@ncwildlife.org>; RJ Mozeley <Rj.Mozeley@Mcgillengineers.Com>; Bill Roark<Bill.Roark@Mcgillengineers.Com> Subject: RE: Grandfather Golf Dam project (UNCLASSIFIED) Tasha and Andrea, Please see the attached letter providing a response to comments provided by WRC relating to the PCN submitted for the referenced project. Thanks, John John Vilas Program Services Manager - Environmental 468 New Market Blvd. Suite B I Boone, NC 28607 Phone: 828.386.1920 1 Cell: 828.964.3962 1 Fax: 828.386.1923 john.vilas@mcgillengineers.com I www.mcgillengineers.com -----Original Message ----- From: Alexander, Tasha L SAW [mailto:Tasha.L.Alexander@usace.army.mil] Sent: Thursday, October 15, 2015 10:46 AM To: John Vilas<john.vilas@mcgillengineers.com> Subject: RE: Grandfather Golf Dam project (UNCLASSIFIED) Classification: UNCLASSIFIED Caveats: NONE John, When you have time please respond to Andreas' comments and copy me. I spoke to her this week. After I can review your response perhaps we should all sit down and discuss any permit conditions moving forward. Please take a look at RGL 05-04. I've attached the link. http://www.usace.army.mil/Portals/2/docs/civilworks/RGLS/rg105-04.pdf Thanks, Tasha Alexander Regulatory Specialist Asheville Regulatory Field Office U.S. Army Corps of Engineers -Wilmington District 151 Patton Avenue, Room 208 Asheville, North Carolina 28801 Phone: 828.271.7980, extension 226 email: tasha.l.alexander@usace.army.mil The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we continue to do so, please complete the Customer Satisfaction Survey located at our website at http://www.saw.usace.army.mil/missions/RegLilatoryPermitProgram.aspx to complete the survey online. -----Original Message ----- From: John Vilas [mailto:john.vilas@mcgillengineers.com] Sent: Wednesday, October 07, 2015 3:29 PM To: Alexander, Tasha L SAW Subject: [EXTERNAL] RE: Grandfather Golf Dam project Tasha, On the GGCC Dam project, we are going to respond to some of Andrea's comments, particularly the need to pump (during drawdown and refill phases) into the channel between the spillway and where the bottom drain pipe flow comes in. We also need to get a workaround to the trout moratorium because they need to do this work during the winter when people are not around. I would like a chance to renegotiate her comments before you issue with all those conditions. I'll try to talk to her today or tomorrow about it and see where it goes. I know you guys are really busy so I appreciate you getting the Blowing Rock letter out and working towards the GGCC driving range permit out maybe Friday. Thanks, John John Vilas Program Services Manager - Environmental 468 New Market Blvd. Suite B I Boone, NC 28607 Phone: 828.386.1920 1 Cell: 828.964.3962 1 Fax: 828.386.1923 john.vilas@mcgillengineers.com I www.mcgillengineers.com -----Original Message ----- From: Alexander, Tasha L SAW [mailto:Tasha.L.Alexander@usace.army.mil] Sent: Wednesday, October 07, 2015 2:35 PM To: John Vilas<john.vilas@mcgillengineers.com> Subject: RE: Blowing Rock (UNCLASSIFIED) Classification: UNCLASSIFIED Caveats: NONE No problem. Sorry for the delay. I'm working through piles. I hope to get the country club out soon ... maybe Friday. Oh, are they cutting any trees during that project? FYI- Andrea still has concerns on the dam project. We will have special conditions attached to that verification. It will likely be next week before I get to it. Thanks, Tasha Alexander Regulatory Specialist Asheville Regulatory Field Office U.S. Army Corps of Engineers -Wilmington District 151 Patton Avenue, Room 208 Asheville, North Carolina 28801 Phone: 828.271.7980, extension 226 email: tasha.l.alexander@usace.army.mil The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we continue to do so, please complete the Customer Satisfaction Survey located at our website at http://www.saw.usace.army.mil/missions/RegLilatoryPermitProgram.asl2x to complete the survey online. -----Original Message ----- From: John Vilas [mailto:john.vilas@mcgillengineers.com] Sent: Wednesday, October 07, 2015 2:32 PM To: Alexander, Tasha L SAW; Jon Swaim Subject: [EXTERNAL] RE: Blowing Rock (UNCLASSIFIED) Thank you Tasha! John Vilas Program Services Manager - Environmental 468 New Market Blvd. Suite B I Boone, NC 28607 Phone: 828.386.1920 1 Cell: 828.964.3962 1 Fax: 828.386.1923 john.vilas@mcgillengineers.com I www.mcgillengineers.com -----Original Message ----- From: Alexander, Tasha L SAW [mailto:Tasha.L.Alexander@usace.army.mil] Sent: Wednesday, October 07, 2015 12:43 PM To: Jon Swaim<jon.swaim@mcgillengineers.com>; John Vilas<john.vilas@mcgillengineers.com> Subject: Blowing Rock (UNCLASSIFIED) Classification: UNCLASSIFIED Caveats: NONE Here you go. Tasha Alexander Regulatory Specialist Asheville Regulatory Field Office U.S. Army Corps of Engineers -Wilmington District 151 Patton Avenue, Room 208 Asheville, North Carolina 28801 Phone: 828.271.7980, extension 226 email: tasha.l.alexander@usace.army.mil The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we continue to do so, please complete the Customer Satisfaction Survey located at our website at http://www.saw.usace.army.mil/missions/RegLilatoryPermitProgram.aspx to complete the survey online. -----Original Message ----- From: Tasha.L.Alexander@usace.army.mil [mailto:Tasha.L.Alexander@usace. army.mil] Sent: Wednesday, October 07, 2015 12:41 PM To: Alexander, Tasha L SAW Subject: Scanned Document (Signed) Scanned Image Classification: UNCLASSIFIED Caveats: NONE Classification: UNCLASSIFIED Caveats: NONE Classification: UNCLASSIFIED Caveats: NONE