20210050 Ver 1_More Info Requested_20210129

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
January 29, 2021
DWR # 20210050v1
Durham County
Durham Public Schools
ATTN: Mr. Bernard Hall
211 Hamlin Road
Durham, NC 27704
(Delivered via email at Bernard [e-mail])
Subject: REQUEST FOR ADDITIONAL INFORMATION
Northern High School Replacement Project
Mr. Hall,
On December 23, 2020, the Division of Water Resources (Division) received your application requesting
a 401 Individual Water Quality Certification and Riparian Buffer Authorization 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 information is received:
1. Your application proposes a total of 56,861 square feet of permanent buffer impacts for the
project. Please submit a modified buffer impact table that specifically lists each type of buffer
impact (e.g. grading, road crossing, utility crossing, etc.) as outlined in 15A NCAC 02B
.0714(10).
2. Please demonstrate why impacts to Riparian Buffers can not be avoided or minimized by
converting the SCM discharges to Dispersed Flow prior to entering the buffer. In addition, the
Division has concerns that the perpendicular alignment of these discharges may destabilize
the receiving streams banks. Please demonstrate why further minimization can not be
achieved by re -aligning these discharge points to an oblique angle to the receiving stream.
Please address this for Impact Areas 1, 2, 3, 4, 7, 8, and 9. [15A NCAC 02B .0714 (9), 15A
NCAC 02B .0611(2) and 15A NCAC 02H .0506(b)].
Please clarify the need for a 70-foot right-of-way for Site Drive 2/Hebron Road Extension. The
Division believes that impacts to features SE and SD and associated riparian buffers can be
further avoided by a reduction in width of Site Drive 2/Hebron Road Extension right-of-way.
The Division understands the requirements imposed by NC DOT and the DCHC-MPO
regarding the need for ingress/egress points, safety, and aligning the Hebron Road Extension
with the existing Wellington Drive as proposed and outlined in the Traffic Impact Analysis.
However, it is unclear if the accommodation of the Hebron Road Extension right-of-way
portion of the roadway is necessary to accommodate traffic for site access. Please clarify if
Hebron Road Extension is approved as part of a Transportation Improvement Plan (or similar)
or is speculative based on an anticipated future traffic demands, considering that this
roadway extension project is not part of the City -County of Durham Capital Improvement
D Q
�� 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
NORTH CAROLINA i
o.Pb .'m919.707.9000

Northern High School Replacement Project
DWR # 20210050v1
Request for Additional Information
Page 2 of 3
Plan and has not been scheduled or funded. In addition, please clarify if the proposed Hebron
Road Extension is planned to connect to the existing Hebron Road to the east [15A NCAC 02H
.0506(b)(1)].
4. Impact Area 1 (Site Drive 2/Hebron Road Extension) is proposed to impact stream feature SD
through the addition of two culverts, fill, and rip rap resulting in 187 linear feet of impact.
Information provided in the application indicates the width of this crossing to be, at least in
part, due to the addition of stacking lanes along the Hebron Road Extension resulting in a
much wider road. Please demonstrate why it is infeasible to begin lane stacking after the
crossing of stream feature SD. [15A NCAC 02H .0506(b)(1)].
5. Please provide a detailed engineering plan, profile view, and cross-section of the proposed
culvert for stream SE. These drawings must include details regarding stream alignment in
relation to pipe alignment, pipe slope, pipe burial, and dissipater pad [15A NCAC 02H .0502]
.0502(a)(9).
6. Please explain how the width of the road crossing at Impact Area 5 has minimized to the
maximum extent practicable. [15A NCAC 02H .0506(b)(1)].
7. The angle of stream SD as it enters the proposed culvert at Impact Area 5 is likely to result in
accelerated erosion and underscoring to the area on the outside of this bend as it enters the
culvert. Please describe how potential problems such as erosion and underscoring will be
prevented in this area and if an alternate crossing location has been explored [15A NCAC 02H
.0506(b)(1)].
8. Please clarify that stream impacts were calculated based on stream length, not culvert length
and update impact table if necessary. [15A NCAC 02H.0502(a) and (c)].
9. Mitigation is required for losses of equal to or greater than 300 linear feet of perennial
stream. Please provide a mitigation plan that conforms to the requirements of 15A NCAC 02H
.0506(c). Furthermore, buffer mitigation is required for some of the proposed buffer impacts.
Please submit a mitigation plan in compliance with 15A NCAC 02B .0295. [15A NCAC 02H
0506(c) and 15A NCAC 02B .0714(12)].
10. If the U.S. Army Corps of Engineers requests a response to any comments received as a result
of the Public Notice, please provide the Division with a copy of your response to the USACE.
[15A NCAC 02H .0502(c)]
Pursuant to Title 15A 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.gov/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 denied as incomplete. The denial of this

Northern High School Replacement Project
DWR # 20210050v1
Request for Additional Information
Page 3 of 3
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 Section 401 of the Clean Water Act for this
activity and any work done within waters of the state may be a violation of North Carolina General
Statutes and Administrative Code.
Please contact Rick Trone at [e-mail] if you have any questions or concerns.
Sincerely,
E DOCUSigned
by:
949D91 BA53EF4E0...
Paul Wojoski, Supervisor
401 & Buffer Permitting Branch
cc: April Norton, USACE Wake Forest Regulatory Field Office (via email)
Anna Reusche, SEPI Engineering and Construction Inc. (via email)
DWR 401 & Buffer Permitting Branch file
File: 20200050 Ver 1—Northern High School Replacement Project_401_IC_Addlnfo