HomeMy WebLinkAbout20201125 Ver 1_More Info Requested_20200925Strickland, Bev
From: Yankura, Kaylie
Sent: Friday, September 25, 2020 4:23 PM
To: Jon Swaim; Kyle Seaman
Cc: Brown, David W CIV USARMY CESAW (USA); Leslie, Andrea J; Moore, Andrew W
Subject: Request for Additional Information — Horsepasture River WWTP and Collection
System Improvements; DWR# 20201125
Mr. Swaim,
On August 31, 2020, the Division of Water Resources (Division) received your application requesting a 401 Water Quality
Certification from the Division for the subject project. The Division has determined that your application is incomplete
and cannot be processed. The application is on hold until the following items are addressed:
1. The PCN states that the 30" culvert associated with impact S2 will be buried 6 inches into the streambed. Please
provide cross section details showing the provisions for aquatic life passage for permanent culvert
installation. This information should be shown on the construction drawings for contractor reference. [15A NCAC
=mIffl
2. Per General Condition 11.9 of GC 4135, all work must be done "in the dry'. Therefore, dewatering methods will be
necessary to temporarily dewater the stream channel during pipe installation. The application states that work
will occur in the dry, but does not specifically address how this will be accomplished. Please provide a construction
sequence that details the method of dewatering to be utilized at the site and the sequence of construction events
to be followed to ensure compliance with this condition. In addition, please ensure that the location of temporary
impacts associated with the proposed dewatering/pump around method are shown on the construction drawings
and that associated temporary impacts are clearly indicated in the PCN impact table (e.g. temporary fill for coffer
dams, jersey barriers, etc.). [15A NCAC 02H .0506 (b)(2)]
3. Please confirm if the culvert alignment associated with the proposed 72 linear feet of temporary stream impact
S1 has been appropriately designed to form a perpendicular stream crossing. I am concerned that the outlets of
the proposed alignment will disproportionately direct stream flow and cause downstream channel instability.
Please provide information supporting the proposed design and indicate how downstream degradation will be
avoided. Please also indicate what design alternatives have been considered for the crossing (e.g. the use of less,
larger diameter culverts, etc.). [15A NCAC 02H .0506 (b)]
4. Please indicate if riprap dissipater pads are a component of the culvert installation associated with temporary
stream impact S1. If so, please include the use of riprap dissipater pads on the submitted plans. [15A NCAC 02H
.0506 (b)(1)]
5. Please evaluate the proposed use of #57 washed stone/surge stone associated with stream impact S1, per the
details included on Sheet C-217. The use of larger stone as backfill may be more effective at preventing stone
washout and transport downstream. [15A NCAC 02H .0506 (b)(3)]
6. The permit application indicates that concrete will be used to reinforce riprap installed on the streambank
associated with temporary stream impact S1 and on the temporary roadbed. Please indicate what best
management practices will be utilized to ensure that concrete does not impact surface waters during preparation
and application. [15A NCAC 02H .0502 (c)] [15A NCAC 02H .0506(b)(2) and (3)]
7. Temporary stream crossings are intended for short-term use. Please indicate the proposed timeline regarding use
of the temporary stream crossing associated with impact S1. [15A NCAC 02H .0502 (c)]
1
8. Condition 11.11. of 401 General Water Quality Certification 4135 requires that "Installation of culverts in wetlands
shall ensure continuity of water movement and be designed to adequately accommodate high water or flood
conditions. When roadways, causeways, or other fill projects are constructed across FEMA-designated floodways
or wetlands, openings such as culverts or bridges shall be provided to maintain the natural hydrology of the system
as well as prevent constriction of the floodway that may result in destabilization of streams or wetlands." Sheet
C-209 submitted with the PCN appears to depict a stormwater pipe connecting the western portion of Wetland C
to the eastern portion of Wetland C. However, it is difficult to determine from the details on Sheet C-210 whether
the pipe will be installed at an elevation that ensures continuity of water movement. It appears the invert of the
pipe is proposed to be set at an elevation above existing ground. Please provide additional details regarding how
the referenced condition will be met including proposed elevation of existing ground and pipe invert elevation.
[15A NCAC 02H .0506 (b)(2)]
9. Please provide a qualitative indirect and cumulative impact analysis for the project. [15A NCAC 02H .0506(b)(3)]
Please see the Division's policy for guidance on our website at:
https://fi les. nc.gov/ncdeq/Water% 20Qual ity/Surface % 20Water/ 20Protection/401/Policies—Gu ides —Ma nua Is/C
umulativelmpactPolicy.pdf. Note that the Division is in receipt of the TWSA-WWTP —Water Resources Cumulative
Impact Analysis provided with the PCN. However, the provided document does not complete the analysis as
required by the Division's policy.
Pursuant to Title 15A NCAC 02H .0502(c), the applicant shall furnish all of the above requested information for the proper
consideration of the application. If all of the requested information is not received, the Division will be unable to approve
the application and it will be returned.
Please contact me if you have any questions. You may provide your response via email or mail to the address below.
Thank you,
Kaylie Yankura
Environmental Specialist —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
828 296 4685 office
828 231 9634 mobile
kaylie.yankuraa-ncdenr.gov
f-eeo --e - D, E
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
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.