10_NCS000250_CompostSeedingCreditRequestApproval

From:
Randall, Mike
To:
Lipscomb, Brian S
Cc:
McDaniel, Andrew H.
Subject:
RE: NCDOT non-structural BMP retrofit credit request -compost seeding
Date:
Tuesday, September 04, 2012 8:57:17 AM
NCDOT's request for a retrofit credit for this non-structural BMP is approved.
Please note that NCDOT can only get credit for one retrofit per Division and only for those Divisions
where the non-structural BMP is installed.
Mike
From: Lipscomb, Brian S
Sent: Tuesday, September 04, 2012 8:54 AM
To: Randall, Mike
Cc: McDaniel, Andrew H.
Subject: NCDOT non-structural BMP retrofit credit request -compost seeding
Mike,
Hope you are doing well and had a great Labor Day weekend.
I believe that Matt had mentioned to you in the past about a project the DOT had initiated back in
2010, which involved compost seeding of critically eroding slopes around the state. We feel that
there was significant water quality benefit gained through this activity with sediment retention as
well as increased infiltration as vegetation became established. We have completed a report which
summarizes these activities and quantifies the amount of work completed. We would like to request
retrofit credit for this non-structural BMP. I have attached the report and a draft request letter.
Could you please review these documents and provide your thoughts and comments? We would be
more than happy to set up a meeting to discuss this activity and request. We will send an official
request letter once we've received your feedback and had a chance to discuss.
Thanks,
Brian
Brian S. Lipscomb, PE
NCDOT, Hydraulics Unit
Highway Stormwater Program
1590 Mail Service Center
Raleigh, NC 27699-1590
email: blipscomb(@ncdot.gov
Direct Phone: [phone]
Office Phone: [phone]
Fax: [phone]
website: http://ncdot.org/programs/environment/stormwater/

Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.

6 �. STATgq
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
BEVERLY EAVES PERDUE
GOVERNOR
September 4, 2012
Mike Randall
Stormwater Staff Engineer
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Randall:
EUGENE A. CONTI, JR.
SECRETARY
SUBJECT: NPDES Permit NCS000250 Part II Section B Item 2 - BMP Retrofits
Request for Retrofit Credit for Implementation of a Multi -Division Non-
structural BMP Compost Seeding Project
Under the provisions of Part II Section B Item 2 - BMP Retrofits, in the NCDOT's
NPDES stormwater permit NCS000250, the Department must implement both structural
and non-structural BMPs to address pollutant loading. In 2010 the Department initiated a
project, to use compost seeding on rights -of -way with slopes deemed critically eroding.
The Department had eight (8) Divisions across the state participate in the project.
Through the project the Department compost seeded a total of 125.78 acres at a total cost
of approximately $397,000. Implementation of this compost seeding technology has
resulted in an estimated total reduction in sediment loss of up to 4,239.56 tons/year,
based on modeling estimates using RUSLE2, and thus has resulted in significant
sediment retention and water quality benefit. In addition to sediment retention; the
compost treatment and associated root penetration is expected to enhance stormwater
infiltration compared to the previous existing conditions, further enhancing water quality
benefit into the future. Based on these results, the Department respectfully requests to be
granted eight (8) retrofit credits, based on one (1) credit per participating Division and in
consideration of the significant overall level of investment.
Because of the demonstrated success of the compost seeding project, NCDOT expects to
employ this technology in the future where appropriate- Therefore, the Department
requests that similar projects in the future shall also yield one (1) retrofit credit per
Division that completes a minimum of $50,000 worth of compost seeding. This level of
effort is equivalent to NCDOT's average past investment in one high quality structural
retrofit BMP located in an area with minimal utility conflicts or other site constraints.
MAILING ADDRESS: TELEPHONE; 919-707.6700 LOCATION:
NC DEPARTMENT OF TRANSPORTATION FAX: [phone] CENTURY CENTER COMPLEX
HYDRAULICS UNIT BU{LUNG B
1590 MAIL SERVICE CENTER WEBSITE: WWW.DON.DOT.STATE.NC.US 1020 BIRCH RIDGE DRIVE
RALEIGH NC 27699-1590 - RALEIGH NC

For each compost seeding project qualifying for retrofit credit as described above,
NCDOT will retain all appropriate documentation and records and will make these
available to DWQ upon request.
The NCDOT understands the importance of a balanced mix of structural and non-
structural BMPs to effectively meet the objectives of the retrofit requirements in the
Department's NPDES permit. Therefore, it should be noted that the Department does not
expect, nor intend, for this type of project to account for the majority of retrofit credits
needed for permit compliance over the five year permit term.
A report entitled `Critically Eroding Slopes — Compost Seeding as a Corrective Measure'
documenting this effort is included in this package for your reference.
We appreciate your written response to this request at your earliest convenience. If you
should have any questions or concerns regarding this request, please contact Brian
Lipscomb, at blipscomb@,ncdot.Qoy , 919-707-6735 or Andy McDaniel, at
amcdanielkncdot.gov or 919-707-6737.
Sincerely,
David S. Chang, Ph.D., PE
State Hydraulics Engineer
DSC/bsl/ahm
Attachment: Report `Critically Eroding Slopes — Compost Seeding as a Corrective
Measure'
cc: Brian Lipscomb, PE
Andy McDaniel, PE
Ken Pace, PE