20121074 Ver 1_Staff Comments_20130116

Surface Water Protection
Winston Salem Regional Field Office
Division of Water Quality
January 16, 2013
Memorandum:
TO: Chuck Wakild, Division of Water Quality Director
FROM: Sue Homewood, Winston Salem Regional Office
THROUGH: Karen Higgins, Webscape Unit
SUBJECT: Individual Permit — Public Comment Review
Ashley Furniture Mid - Atlantic Manufacturing and Distribution Center
Davie County, NC
On November 26, 2012 the Division received an application for an Individual 401 Water Quality
Certification from Ashley Furniture Industries Inc. The Division must take final action on the
application prior to February 4, 2013.
On December 6, 2012 the US Army Corps of Engineers ( USACE) issued a Public Notice of the
application. This served as notice by the Division per 15A NCAC 02H .0503(c). The comment
period closed on January 7, 2013. The Division received six public comments. The six
comments comprised of the following concerns /requests:
• Increased flooding of the watershed immediately below the site.
• Possible contamination of adjacent surface waters and aquifers.
• Five requests for an extended comment period as a result of Notice occurring over the
holiday season.
• Concern that Public Notice incorrectly stated the adjacent area was mostly pasture and
forest with few residential homes.
• Request for a Public Hearing in Davie County.
• Request that the final stormwater management plan be available for review.
• Request that the Erosion and Sediment Control Plan be available for review
• Request to review any monitoring plan for stormwater treatment, discharges, leachates,
area surface waters and residential well water.
• Two requests for Denial of the Water Quality Certification.
In addition, the USACE received two additional requests for a Public Hearing and four
comments in favor of the project.

The Winston Salem Regional Office has reviewed the application in detail and determined that:
• The Division has received a conceptual plan to review. A detailed stormwater
management plan (SMP) will be required to be submitted and approved by the Division
prior to commencing construction activities.
• The engineering firm designing the SMP has indicated to the Division that in addition to
treating all new impervious surfaces, Ashley Furniture will also contain and treat
stormwater from approximately 50% of the existing impervious surface. These measures
should address many of the concerns about downstream flooding.
• If the facility has any stormwater discharges associated with industrial activity, an
NPDES Industrial Stormwater Permit or No Exposure Certification will be required in
accordance with Federal and State regulations.
• Davie County will be providing sewer connections to the site. Any wastewater generated
inside of the building and being discharged to the sewer system will be addressed by
Davie County.
• A Sediment and Erosion Control Plan will be required by the DEMLR.
The Winston Salem Regional Office believes that the concerns raised through the public
comment period have been or will be sufficiently addressed through the permitting process. The
Webscape Unit concurs with this position.
cc: Ted Bush