20180582 Ver 2_More Info Requested_20191028

ROY COOPER
COVHnp'
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
October 28, 2019
DWR q 20180582 V2
Jackson County
Cashiers Canoe Club Development, LLC
Attn: Roseanne Giordani
PO Box 300849
Austin, TX 78703
Subject: REQUEST FOR ADDITIONAL INFORMATION
Cashiers Canoe Club Development and Lake Dredging
Dear Ms. Giordani:
On April 12, 2019, the Division of Water Resources — Water Quality Programs (Division) received your re-
application dated April 12, 2019, requesting a 401 Individual Water Quality Certification from the
Division for your project. Additional information was requested by the Division on June 3, 2019 and
received on July 15, 2019, August 12, 2019 and August 30, 2019. A public hearing was held on
September 5, 2019 with a public comment period from July 29, 2019 — October 7, 2019. Comments
received are available for review at the following link:
https://edocs.deg.nc.gov/W aterResources/Browse.aspx?dbid=0&sta rtid=961445
Based on the comments received, the Division has determined that the following additional information
is necessary to continue to process your application. The application is on -hold until all of the following
information is received:
1. The Division received multiple comments expressing concerns for pollutants that may be present
within the dredge material. It was brought to the Division's attention during the hearing a plastics
manufacturing facility previously existed in Cashiers and that it may have had discharges upstream
of Cashiers Lake. It was also noted that sampling data provided to the Division indicated high levels
of Chromium.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699 1617
919.707.9000

Cashiers Canoe Club Development, LLC
DWR# 20180582 v2
Request for Additional Information
Page 2 of 3
Please provide a proposed sediment sampling plan that includes all constituents listed in 40 CFR EPA
Appendix ll to Part 258 - List of Hazardous Inorganic and Organic Constituents to ensure compliance
with the May 2019 NCDEQ Preliminary Soil Remediation Goals (PSRG). The sampling plan must
include a detailed description of the proposed locations and methodology for the proposed
sampling. The Division recommends following the guidance detailed in Part III of the EPA/USACE
Evaluation of Dredged Material Proposed For Discharge in Waters of the U.S. — Testing Manual
(Inland Testing Manual).
The Division received multiple comments expressing concerns regarding invasive plant species
which currently exist within Cashiers Lake, specifically Parrot Feather and Yellow Flag Iris. Multiple
commenters indicated that removal of the invasive species would be a benefit of the proposed
dredging project. Please provide an invasive species management plan that addresses the concern
of mobilization of invasive seed sources during the dredging and disposal activities.
3. The Division received multiple comments expressing concern that the downstream waters would
not be adequately protected during in -lake construction activities unless a complete pump around
system was utilized. Specifically, they were concerned that inadequate storage would exist to
accommodate significant precipitation events during the dredging activities. Please provide a
detailed explanation and/or analysis of how downstream waters will be protected from turbidity
during significant rain events during in -lake construction activities.
Pursuant to Title 1SA NCAC 02H .0502(e), the applicant shall furnish all of the above requested
information for the proper consideration of the application. Please respond in writing within 30
calendar days of receipt of this letter by sending one (1) copy of all of the above requested information
to the 401 & Buffer Permitting Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617 OR by
submitting all of the above requested information through this
link: https://edocs.deg.nc.goy/Forms/Supplemental-Information-Form (note the DWR# requested on
the link is referenced above).
If all of the requested information is not received within 30 calendar days of receipt of this letter, the
Division will be unable to approve the application and it will be returned. The return of this project will
necessitate reapplication to the Division for approval, including a complete application package and the
appropriate fee.
Please be aware that you have no authorization under the Water Quality Certification Rules for this
activity and any work done within waters of the state may be a violation of North Carolina General
Statutes and Administrative Code.

Cashiers Canoe Club Development, LLC
DWR# 20180582 v2
Request for Additional Information
Page 3 of 3
Please contact Sue Homewood at 336-776-9693 or Sue. HomewoodCcDncdenr.aov if you have any
questions or concerns.
Sincerely,
Mac Haupt, Acting Supervisor
401 and Buffer Permitting Branch
cc: Clement Riddle, ClearWater Environmental Consultants Inc. (via email)
David Brown, USACE Asheville Regulatory Field Office (via email)
Andrea Leslie, NCWRC (via email)
Byron Hamstead, USFS (via email)
DWR ARO 401 files
DWR 401 & Buffer Permitting Unit