20200758 Ver 1_Request for SW Info Response_20200723

Wanucha, Dave
From:Nancy Oberle <[e-mail]>
Sent:Wednesday, July 22, 2020 2:17 PM
To:Wanucha, Dave; [e-mail]; Jim Mason
Cc:Parker, Jerry A; Wilver, David; Craig Young; Ketner, Brian K
Subject:RE: \[External\] RE: Request for Stormwater Information - NCDOT Division 7 - U-6010
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]

Hi Dave,
Stormwater BMP measures were considered upstream of Site 1, but ultimately we were unable to utilize them due to
topographical, geographical, right of way, and environmental concerns.

Topographical/Geographical: Upstream of the proposed culvert extension/additional on the west side, there is an
existing draw, which discharges just upstream of the existing culvert. Due to the height of the proposed roadway
embankment, the existing swale is filled by the proposed fill slope. Just upstream of this existing draw is an existing
jurisdictional feature. This jurisdictional feature did not afford us the room to fit a stormwater measure and provide an
adequate discharge prior to the buffer. It was requested by NCDOT personnel to avoid impacts to the buffer and pipe
any roadway drainage to the culvert.

Right of Way: Due to current development to the west of the culvert extensions, right of way was limited in this area.
The areas to the west are being developed with commercial, industrial, and residential zoning.

Environmental: After drainage was originally designed and approved, we received comments from Nicole Thomson
during review of the wetland permit drawings/erosion control plans about discharging into and through the buffer at
both culvert locations. It was requested to eliminate all ditches through buffers, even if we were replacing existing
draws. Our original design incorporated a short run of swale through the buffer, tying to the existing 72” RCP, impacting
BZ-2. If stormwater BMP’s had been utilized, we had concerns about how to discharge treated water through the buffer
without having adverse effects.

Hopefully this provides the clarification you needed on the stormwater question. Please let us know if we can provide
anything else.

Thank you,
Nancy

Nancy Scott Oberle
Three Oaks Engineering
324 Blackwell Street , Suite 1200
Durham, NC 27701
919 732 1300 office
919 900 6535 direct – please note my new number
[e-mail] – please note my new email
www.threeoaksengineering.com

From: Wanucha, Dave <[e-mail]>
Sent: Tuesday, July 21, 2020 12:36 PM
1

To: Nancy Oberle <[e-mail]>; [e-mail]; Jim Mason
<[e-mail]>
Cc: Parker, Jerry A <[e-mail]>; Wilver, David <[e-mail]>; Craig Young
<[e-mail]>; Ketner, Brian K <[e-mail]>
Subject: RE: \[External\] RE: Request for Additional Information - NCDOT Division 7 - U-6010, Alamance County; SAW-
2018-01083

Hi Nancy,
Just a little more clarification is needed relative to stormwater discharges into culvert at Site 1. What were the
reasons for not providing some sort of stormwater bmp to provide treatment through the buffer rather than a
direct discharge to the culvert?

Thanks.

Dave W.

Division of Water Resources
401 & Buffer Transportation Permitting
NC Department of Envirionmental Quality

336-776-9703 office
336-403-5655 mobile
[e-mail]

NC DEQ Winston Salem Regional Office
450 West Hanes Mill Road, Suite 300
Winston Salem, NC 27106

Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or
are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging
time.

From: Nancy Oberle <[e-mail]>
Sent: Tuesday, July 14, 2020 4:34 PM
To: Wanucha, Dave <[e-mail]>; [e-mail]; Jim Mason
<[e-mail]>
Cc: Parker, Jerry A <[e-mail]>; Wilver, David <[e-mail]>; Craig Young
<[e-mail]>; Ketner, Brian K <[e-mail]>
Subject: RE: \[External\] RE: Request for Additional Information - NCDOT Division 7 - U-6010, Alamance County; SAW-
2018-01083

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]

Hi Dave,
Please see below responses to your questions in red. Let us know if any further information is needed.
Thank you,
Nancy
2

From: Wanucha, Dave <[e-mail]>
Sent: Tuesday, July 14, 2020 2:28 PM
To: Nancy Oberle <[e-mail]>; [e-mail]; Jim Mason
<[e-mail]>
Cc: Parker, Jerry A <[e-mail]>; Wilver, David <[e-mail]>; Craig Young
<[e-mail]>; Ketner, Brian K <[e-mail]>
Subject: RE: \[External\] RE: Request for Additional Information - NCDOT Division 7 - U-6010, Alamance County; SAW-
2018-01083

Nancy,
Please clarify a few items listed below and provide a more complete Stormwater Management Plan (SMP).

 Proposed box culvert at Site 1 that replaces existing pipe will be carrying storm flow in addition to base
flow or only stormflow? Plans show two stormwater pipes entering proposed box culvert—is that
correct? The JS does a significant outside meander as it enters the culvert at Site 1. The streambank
will likely be under significant sheer stress during stormflows. Is the streambank at that location
stable/armored enough to hold up against stormflow and velocities?
There are two proposed stormwater outfalls discharging into the culvert at site 1. This culvert is being
utilized as an overflow barrel to convey storm events without causing a rise in water surface
elevations. The CL II Riprap on the banks is sufficient to handle shear stresses resulting from larger
storm events. Therefore, the overflow culvert will be utilized to convey average daily flow/Ingle Branch
during large storm events and any storm drainage from the pipe networks discharging into the single
barrel RCBC.

 Stormwater outfall near Station 48+17.39-L- has relatively small amount of riprap (11 tons) vs. outfalls
at Sites 3 and 4 ( 75 and 54 tons) yet drainage area appears to be similar. Will 11 tons rip rap be
enough to minimize velocities at that location? The SMP provided only a narrative with no other data
regarding stormwater management. Attached is the standard spreadsheet to provide that
information. Please send a more complete SMP.
The 11 tons of CL I riprap at the outfall near 48+17 RT is utilizing a standard tonnage of CL I riprap and
SY of geotextile recommended by NCDOT. NCDOT Standard Detail 876.02 was referenced in this
scenario. Site 3 is bank stabilization and is calculated using existing field information and contours to
calculate a cross sectional area of the channel and banks. Using this cross sectional area, we are able to
calculate the 54 tons of CL II riprap to be used at the inlet of the 2@8’x6’ RCBC. Site 4 is a riprap tail
ditch which ties to an existing draw. Riprap was utilized to reduce the shear stress and velocities of
storm water discharge prior to leaving the project site. This tonnage is also calculated using multiple
cross sectional areas throughout the length of the proposed tail ditch. Generally, we do not
incorporate proposed riprap dissipator pads in the SMP unless a pipe is being directly discharged into a
jurisdictional stream or buffered area. Throughout the project, we were able to avoid discharging any
roadway drainage directly into a jurisdictional/buffered area, therefore, we did not include any outfalls
on the energy dissipator tab of the stormwater management plan.

Thanks.

Dave W.

Division of Water Resources
401 & Buffer Transportation Permitting
3

NC Department of Envirionmental Quality

336-776-9703 office
336-403-5655 mobile
[e-mail]

NC DEQ Winston Salem Regional Office
450 West Hanes Mill Road, Suite 300
Winston Salem, NC 27106

Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or
are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging
time.

From: Nancy Oberle <[e-mail]>
Sent: Monday, July 13, 2020 9:58 AM
To: [e-mail]; Jim Mason <[e-mail]>
Cc: Wanucha, Dave <[e-mail]>; Parker, Jerry A <[e-mail]>; Wilver, David
<[e-mail]>; Craig Young <[e-mail]>; Ketner, Brian K
<[e-mail]>
Subject: \[External\] RE: Request for Additional Information - NCDOT Division 7 - U-6010, Alamance County; SAW-2018-
01083

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]

Hi Dave,
Thank you for your review of the subject permit application. Here are the responses to your questions below:
1) Project U-6010 is an intersection improvement (University at S. Church Street) project and not tied to U-
2581B/R-2910. The 2020-2029 STIP shows U-2581 BC (section from Knox Road to Rock Creek Dairy Road) as
unfunded (hanging out past 2029 in the STIP). R-2901 is not listed in the 2020-2029 STIP at all.
2) The seven lanes (dual thru, dual left, and separate right turn) is proposed to improve the intersection capacity
and level of service. It has nothing to do with matching another project widening to the west. Also, S. Church
Street was already five lanes at Westbrook Drive. Once the intersection was widened to accommodate dual left
turn lanes, dual through lanes, and a separate right turn lane along with the required storage lengths it did not
make sense to leave a short section of unwidened roadway along S. Church Street between University Drive and
Westbrook Drive.
3) Site 1 – No floodplain benches are proposed at this culvert extension. This culvert is located in a FEMA study
area and the entire opening is needed for compliance. Also, the existing stream width closely matches the
existing culvert width at both the upstream and downstream sections. Site 2 – The existing culvert is only being
extended on the downstream end. A 2’ tall sill is proposed in the northern barrel at the outlet as there is an
existing 2’ sill already on the inlet side. There is an existing floodplain bench on the outlet end that will be
maintained.
4) A DMS request will be submitted.

Please let us know if you have any further questions.

Thanks,
Nancy
4

Nancy Scott Oberle
Three Oaks Engineering
324 Blackwell Street , Suite 1200
Durham, NC 27701
919 732 1300 office
919 900 6535 direct – please note my new number
[e-mail] – please note my new email
www.threeoaksengineering.com \[threeoaksengineering.com\]

From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, June 26, 2020 3:41 PM
To: Jim Mason <[e-mail]>; Nancy Oberle <[e-mail]>
Cc: Wanucha, Dave <[e-mail]>; Parker, Jerry A <[e-mail]>
Subject: Request for Additional Information - NCDOT Division 7 - U-6010, Alamance County; SAW-2018-01083

All,

Thank you for your PCN and attached information, dated 6/10/2020, for the above referenced project. I have reviewed
the information and need clarification before proceeding with verifying the use of Nationwide Permit (NWP) 14
(http://saw-reg.usace.army.mil/NWP2017/2017NWP14.pdf \[saw-reg.usace.army.mil\]). Please submit the requested
information below (via e‐mail is fine) within 30 days of receipt of this Notification, otherwise we may deny verification of
the use of the Nationwide Permit or consider your application withdrawn and close the file:

1) It appears that this project is a segment of the proposed U-2581B/R-2910 project, which completed
Concurrence Points 1 and 2/2A of the Section 404/NEPA Merger Process in October 2011 and November 2013,
respectively. The western-most segment of the U-2581B/R-2910 project was split off to become part of the
Publix Distribution Center project (SAW-2018-00240). However, to our knowledge this overall project had not
been dissolved or permanently shelved, and further piecemealing of this overall project presents additional
questions regarding avoidance and minimization; further, it does not appear that the Merger team was advised
of this segmentation. The Corps highly recommends notifying the remainder of the Merger Team of this action.
2) Per the above, does the project purpose and need justify increasing lanes from 2 to 7 on US Highway 70, west of
University Drive, which then condense back down to two lanes within ~0.15 mile of the intersection? Or, does
that aspect of the project design have more to do with tie-in to a future widened US Highway 70 to the west?
3) Are floodplain benches proposed at the inlet/outlets of Sites 1 and 2? If so, please provide cross-section views
that clearly show the proposal;
4) Currently the proposal does not include compensatory mitigation. However, given that this project is a widening
of a previous NCDOT project (U-2905), and the fact that the Corps views NCDOT projects cumulatively as a state-
wide transportation network, compensatory mitigation would be required in this case for all stream and wetland
impacts resulting in a loss of waters. Compensatory mitigation requirements typically start at a 2:1 mitigation to
impact ratio with decisions to lower those ratios based on aquatic function of the resources proposed for
impact. Note, however, that NCSAM and NCWAM forms provided with the PCN indicate medium or higher rated
resources; as such, 2:1 mitigation is justified.

Please let me know if you have any questions.

Sincerely,

Dave Bailey

---
David E. Bailey, PWS
Regulatory Project Manager
5

US Army Corps of Engineers
CE-SAW-RG-R
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Wake Forest, North Carolina 27587
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Email: [e-mail]

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