SW3240101_Response To Comments_20240913

September 12, 2024
Attn: Brianna Holland
512 N. Salisbury St
Raleigh, NC 28115
CESI
Itemized response letter
Re: Request for Additional Information Stormwater Permit No. SW3240101 Huntley
Brothers Home Office Cabarrus County
Please refer to the following responses to comments:
1. Previous comment unresolved: Please ensure that this project is meeting the
definition of"Runoff Treatment" per 15A NCAC 02H .1002(43). In order for a
project to meet Runoff Treatment, the net increase in BUA must be captured and
treated in one or more primary SCMs. If it is not practicable to capture the net
increase in BUA, the portions of the site that do not drain to the SCM can be
permitted as a low-density area (in accordance with 15A NCAC 02H .1003(1)(d))
provided that the area meets the low-density requirements outlined in 15A NCAC
02H .1003(2) (NOTE: If pursuing this option, you will need to revise the
Supplement- EZ Form, Application, O&M Agreement, etc... to reflect the low-
density area). If it is not practicable to capture the net increase in BUA and the
uncaptured areas do not meet the low-density requirements, we will need to
discuss a variance for the project. The comment response document, included
below, indicates that not all runoff will be treated by the SCM included with this
permit. If this is the case, the adjacent property's permit will need to be modified
to allowed for"off-site BUA", and the package will have to be revised to apply for
treatment by an "off-site SCM" that will provide treatment for this BUA.
Response: Off-site SCM is not needed due to Post DA-3 being completely non-
impervious area (See Sheet WQ101). Four-inch corrugated pipes have been
added to both sides of the building connecting the down spouts to treat water
from POST DA-4 ( See sheets C600 and WQ101).
2. All sections of the Supplement-EZ must be completed. Do not modify the
application documents remove any required information. This is required per
(Section V & Section VI, 3).
Response: Original Supplement EZ has been resubmitted without modifications to
original formatting.
3. Application
a. Previous comment unresolved: Section III 1C: Per the provided sales
agreement, it appears that the property will be sold to Huntley Brothers Co,

Inc. If this is the case, please uncheck the "Lessee" box, or provide the lease
agreement as directed on the Application Section III 1C.
Response: Applicant has been updated, as well as the application section III
with correct information.
4. Supplement-EZ
a. Previous comment unresolved: Cover, Line 2: Revise the project areas to
match the project area calculated in the Application Section IV 7.
Response: Total project has been updated to 16.893
b. Previous comment unresolved: Wet Pond, Line 28: Please see
comment below regarding average depth. This is different from
the depth of the main pool. The calculations were revised but this
item was not. Please revise for consistency.
Response: The item now matches the calculations.
c. Line 34 - The cleanout depth of the forebay is the distance
from the permanent pool surface elevation to the top of the
sediment storage zone.
Response: The cleanout depth is 48 inches.
d. Wet Pond, Line 35: The value should be the volume between
the temporary pool (682.50 per the plans) and the permanent
pool (679.50). Please revise.
Response: Design SCM has been updated to have a volume between the
temporary pool and the permanent pool.
e. Wet Pond, Line 40: The drawdown time is the period of time
required to draw down from the temporary pool elevation to the
permanent pool elevation. Please revise.
Response: Drawn down time calculations have been submitted as well to
ensure that the drawn down time is still between 2 to 5 days from the
temporary pool elevation to the permanent pool.
f. Wet Pond, Line 43-44: The forebay entrance must be deeper
than the forebay exit. Wet Pond MDC 5
Response: Forebay entrance elevations have been updated to ensure the
entrance is deeper than the exit.

5. Consistency:
a. The Supplement-EZ lists the temporary pool elevation as 683.83,
the Calculations list the temporary pool elevation as 684.5, and
the plans show the lowest bypass elevation (that determines the
temporary pool as 682.50).
Response: Elevations on calculations and supplement EZ form has been
updated.
6. Previous comment unresolved: 15A NCAC 02H .1003 (7): The permittee shall
record deed restrictions and protective covenants prior to the issuance of a
certificate of occupancy to ensure the permit conditions and the approved plans
and specifications are maintained in perpetuity. This recording would limit the
BUA to amount that will be permitted. Per the narrative, the maximum BUA
allowed in the deed restrictions for this lot is 652,375 SF. The deed restrictions
will either need to be re-recorded or this potential future BUA will need to be
accounted for in the sizing of the SCM.
Response: The current SCM design treats all the water in the current BUA; if BUA
area increases then we will do a separate submittal for water untreated by first
SCM.
7. Previous comment unresolved: 15A NCAC 02H .1042 (2) (h) (i):
Plan details shall include a benchmark for clean-out, this must be
shown for the sediment forebay.
Response: Cross section detail has been updated to show benchmark detail on
page C310
8. Previous comment unresolved: 15A NCAC 02H .1042 (2) (h) (i), (ii):
Plan details shall include pretreatment area. Both forebays need to
be represented with their relevant dimensions, side slopes, and
elevations with a benchmark for cleanout. Please ensure both
forebays are depicted in the cross sectional detail.
Response: Both forebays with their relative size and elevations are now shown on
page C310 in cross section detail.
9. 15A NCAC 02H .1042 (2) (h) (ii): Plan details shall include all
conveyance devices, including inlet device and energy dissipater.

Response: Energy dissipater details has been updated to show all its dimensions.
10. Previous comment unresolved: 15A NCAC 02H .1042 (2) (i)(i), (ii):
Provide signed, sealed, and dated planting plans for the wet pond.
The planting plan shall include plant layout with species names and
locations and total number and sizes of all plant species. The
Supplement-EZ states "Bermuda Grass"will be planted on the dam
and embankment, please provide this on the plans.
Response: Call out has been added to sheet L100 to show the "Bermuda Grass"
will be planted on the dam and embankment.
11. Previous comment unresolved: Wet Pond MDC 5 (b): The forebay
entrance shall be deeper than the forebay exit. Please revise on the
plans.
Response: Plans and elevations have been updated to show forebay entrance is
now deeper than forebay exit.
12. Please provide a Response to Comments letter indicating, in a point-
by-point manner, how each of the above comments has been
addressed. This item is required per 15A NCAC 02H .1042(3)(b).
Response: Response letter provided
13. Please correct the following with the O&M Agreement Form:
a. Please correct the cover page of the O&M Agreement Form. (I've
corrected in red)
Response: OM agreement has been updated to reflect the changes you made
in red.
b. Multiple forebays are proposed, please provide additional
information in the Wet Detention Pond Design Summary so that
the relevant information on the additional forebay is presented.
Response: Wet Detention Pond Design Summary has been updated so that
the relevant information on additional forebay is presented.

c. A "vegetated filter"refers to a vegetated filter strip placed
downstream of the pond outlet (it was required per the previous
version of the rules) and does not appear to be incorporated as
part of the design for the wet pond. The plans now appear to
point to the vegetated shelf, which is not a vegetated filterstrip.
For more information about vegetated shelves, see Chapter C-3
of the manual. For information about vegetated filter strips, see
Chapter C-9 of the manual.
Response: A "vegetated filter"has been called out on sheet L100.
d. Please revise the elevations shown in the wet detention pond
design for consistency with the Supplement-EZ:
Response: Wet detention pond design is now consistent with supplement EZ
form.